Clean Development Mechanism Projects

Project title

Industrial Fuel Switching from Lignite to Natural Gas in Gujarat, India

Country

India

Project description

The project is to switch the primary fuel to generate steam and process heat from lignite to natural gas to reduce GHG emissions and minimize other environmental impacts. The Palsana Industrial cluster has more than 120 small and tiny textile/dyeing units of which 39 units are currently proposing to take up the fuel switch project. The annual lignite replacement is estimated to be about 139,587MT/y.

The applied methodology is AM0009 Version 02 - Consolidated methodology for fuel switching from coal or petroleum fuel to natural gas.

The project is normal scale CDM project.

Crediting period is renewable 3x7 years starting from 01/01/2006.

Estimated annual emission reduction is 82,952 tCO2 e.

Project documents

Project Design Document (PDD)

Period for comments

Period for comments was 20 July 2006 - 18 August 2006.

The following public comment was received:

Name: Hiral Mehta
Email Address: paryavaranmitra@yahoo.com
Date: 28 July 2006

Palsana Enviro Protection Ltd. is company promoted by Palsana Industrial Association with around 120 small scale industries. The project is about change of fuel from lignite to natural gas. The switch over may contribute to reduce air pollution and sustainable development. But our objection is against content of PDD. Under A.4.4 on page no. 6 it is written that There were/are no national and/or sectoral policies and circumstances that influence the decisions or impose obligations to the proposed project activity.

The use of Lignite and natural gas are not restricted nor demanded by any Indian and/or State legislation. As per Supreme Court of India's order Ministry of Env. & Forest of India has constituted Environment Protection Control Authority - Bhurelal Committee to review Air Pollution in India. This committee is to look after switch over of traditional fuels to natural gas in India. So the committee is in existence in India by Supreme Court direction to implement natural gas as fuel in transportation and industrial sector.

In Narol industrial estate of Ahmedabad this committee is forcing industries to switch over to natural gas. So it is wrong to state above mentioned facts on page 6 of PDD. Under B.2 option C it is written that when revenue related to CDM was highlighted to investors this project can be undertaken. Otherwise they were of opinion that project involves high capital cost and risk. It is highly objectionable because it seems that only to earn revenue associated with CDM projects this project is being undertaken. Risk is involved in this case with or without CDM.

Under G.1 it is written that copy of public consultation meeting and local stakeholders meeting will be submitted to DOE during validation process. Public consultation process is not properly mentioned in G.1,2 &3. It is objectionable that public consultation has not covered properly in PDD itself. It is part of PDD and should be enclosed in that. It is not private document which can be submit to DOE. It is doubt that public consultation is not done in proper manner.
How much and whom were invited for consultation is not specified. It is our demand that public consultation should be done again and incorporated in PDD.