Gujarat forum on CDM respectfully submit the following comments on the Project Design Document (PDD) for 351.43 MW Natural Gas Based Combined Cycle Power Plant at Hazira, Gujarat, India. We thank the CDM Executive Board and Designated Operation Entity (DOE) for recognizing the integral role of transparency in CDM Validation process, and for taking this comment into consideration.
The project is not appropriate for the following points

o	The investment analysis is incomplete and fails to provide the data and assumptions necessary for reader to reproduce the result.

o	No information has been provided regarding the cost of fuel switch in the PDD.


o	As per the EIA report the noise level recorded in the individual process units exceeded the stipulated standards of Central Pollution Control Board (CPCB).


o	In India there is huge shortage of Natural Gas especially the irregular and interrupted supply of the Gas. At the same time the project proposed to use Natural gas which would further aggravated the problem. In that case the present user of the natural gas would be forced to switch to the alternative such as fossil fuel and ultimately the GHG would be released. 

o	Hazira is already heavy industrialised area and one more industry will adversely affect the area in environmental prospect. Secondly, Gujarat is a semi arid zone and many areas come under dark water zone.  Water is not available even for the irrigation purpose. Company proposed that it will take water from Tapi River which will further intensify the problem and the surrounding villagers, farmer especially marginal farmers would be adversely affected by the companies operation. Lots of complaints have already been found in the area regarding effluence and pollution by industries which are still not solved.

o	No plan has been submitted regarding use of 2% of the net revenue accrued from the sale of CER toward achieving the sustainable development goals.

Gujarat Forum on CDM : gujaratforumoncdm@gmail.com