Jilin Gongzhuling Biomass Generation Project
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Host party(ies) China
Methodology(ies) ACM0018
Standardised Baselines N/A
Estimated annual reductions* 149,529
Start date of first crediting period. 01 Jul 12
Length of first crediting period. 7 years
DOE/AE PJR CDM
Period for comments 29 Feb 12 - 29 Mar 12
PP(s) for which DOE have a contractual obligation EDF Trading Limited
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (852 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
If you carefully read through the PDD it is confirmed that this is not a genuine CDM project at all. What is the exact project cost? The project cost is covering what? The machinery is second hand purchased or fresh and new from an OEM? In either case DOE to check all the quotations, proposals, purchase orders, invoices, way bills, transport bills, proof of payments like bank statements. 
DOE to check with banks by way of written confirmation the amount transacted, to whom the money is paid, when the money is paid, is the party paid is the correct party as shown in the purchase orders. It is very clear that the values, party names, dates are fabricated and misrepresented in this project. DOE should terminate their contract for this project immediately. This is the only way out to protect the value of CDM process. It looks like PP is purchasing second hand or second quality equipment by inflating the purchase order values and invoices. This must be probed thoroughly and real values to taken for additionality calculation. Then Iím sure the additionality is not there at all in this project. How is the base line defined in this project? Base line is hypothetically defined with no proper evidences and proper justification. 
DOE cannot take the base line as suggested by the PDD.  Please note that there are no emissions beyond the real and factual base line. This project definitely qualifies for zero CERís, not even one CER. DOE cannot assume values and things as giving by this PP. Whatever values are considered throughout the project in all documents including the real DPR (not the one prepared for CDM, the one given to the banks and others), they must be validated, verified and double checked. Do not ask PP for DPR. Ask the parties who have been given DPR by the PP. Get directly from the bank and others by each page of the DPR and Feasibulity report signed. Such document can be considered as a real DPR or FR. This project is genuinely a fabricated, false and misinterpreted project with no base line and additionality.  


Submitted by: Benedict


The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs