Comments on the Second Project Design Document and Application for Validation after Rejection of Registration by CDM Executive Board GHG Emission Reductions through grid connected high efficiency power generation, Coastal Gujarat Power Ltd., India

CIEL opposes the validation of the Coastal Gujarat Power Ltd. project, citing a failure to properly record local stakeholder concerns in the Project Design Document (PDD) and alleging that the project's use of a once-through sea water cooling system violates Indian environmental law and harms marine ecology.

• The stakeholder engagement process described in the Project Design Document (PDD) was insufficient for the CDM Executive Board to evaluate whether local communities had an adequate opportunity to participate. The PDD records no comments from local villagers, despite an Asian Development Bank (ADB) report noting that 65 people attended a meeting and some "expressed concern about the potential environmental and social impacts of the Project."
• The project's cooling system may violate the conditions of the environmental clearance granted by India's Ministry of Environment and Forests. While the clearance required a closed cycle cooling system with cooling towers, the PDD indicates the project will use a once-through sea water cooling system, which is described as "significantly more harmful to marine ecology."
• There are allegations that the project's intake channel, which is shared with the 4620MW Adani Power Project in the Mundra Special Economic Zone, did not obtain separate environmental clearances or public studies.
• The Mundra Port, an associated facility of the project, was issued a show-cause notice by the Ministry of Environment and Forests for violating the 1991 Coastal Regulation Zone (CZR) notification. Violations include large-scale reclamation on mangrove areas and the obstruction of tidal flow and creek systems.
• CIEL argues that the project contradicts the goal of shifting India's economy toward sustainable energy by creating a long-term dependency on fossil fuels.

APA

Center for International Environmental Law (2011). Comments on the Second Project Design Document and Application for Validation after Rejection of Registration by CDM Executive Board GHG Emission Reductions through grid connected high efficiency power generation, Coastal Gujarat Power Ltd., India. https://www.ciel.org/Publications/Gujarat_Comments_16Jul11.pdf

Chicago

Center for International Environmental Law. Comments on the Second Project Design Document and Application for Validation after Rejection of Registration by CDM Executive Board GHG Emission Reductions through grid connected high efficiency power generation, Coastal Gujarat Power Ltd., India. 2011. https://www.ciel.org/Publications/Gujarat_Comments_16Jul11.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Comments on the Second Project Design Document and Application for Validation after Rejection of Registration by CDM Executive Board GHG Emission Reductions through grid connected high efficiency power generation, Coastal Gujarat Power Ltd., India |date=16 July 2011 |url=https://www.ciel.org/Publications/Gujarat_Comments_16Jul11.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2011comments, author = {{Center for International Environmental Law}}, title = {{Comments on the Second Project Design Document and Application for Validation after Rejection of Registration by CDM Executive Board GHG Emission Reductions through grid connected high efficiency power generation, Coastal Gujarat Power Ltd., India}}, publisher = {Center for International Environmental Law}, year = {2011}, month = jul, url = {https://www.ciel.org/Publications/Gujarat_Comments_16Jul11.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }