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

The Center for International Environmental Law (CIEL) submitted comments on July 16, 2011, arguing that the Project Design Document (PDD) for a high-efficiency power generation project by Coastal Gujarat Power Ltd. in India should not be validated. CIEL contends that the project's stakeholder consultation process was inadequate and that the project causes significant environmental harm, potentially violating Indian environmental law.

• The stakeholder engagement process described in the PDD was insufficient for the CDM Executive Board to evaluate if local communities had an adequate opportunity to participate. The PDD only notes that stakeholders were invited to a meeting on September 19, 2006, via newspaper advertisements on August 15 and 18, 2006, but provides no details on newspaper distribution, language translation, or the meeting's accessibility.
• There is a contradiction between the PDD and an Asian Development Bank (ADB) report regarding community feedback. While the PDD fails to record any comments from local villagers, the ADB report states that 65 people attended the September 19, 2006 meeting and some "expressed concern about the potential environmental and social impacts of the Project."
• The project may violate Indian environmental law by using a once-through sea water cooling system instead of the closed cycle cooling system with cooling towers required by the Ministry of Environment and Forests. Once-through systems are described as more harmful to marine ecology due to entrainment and impingement impacts on aquatic life and the discharge of heated water.
• Local communities allege that the project's intake channel, which is shared with the 4620MW Adani Power Project in the Mundra Special Economic Zone, did not receive separate environmental clearances, and that any conducted studies were not made public.
• The Mundra Port, an associated facility of the project operated by the Adani Group, received a show-cause notice from the Ministry of Environment and Forests on December 15, 2010, for violating the 1991 Coastal Regulation Zone (CZR) notification. Violations include large-scale reclamation on mangrove areas and obstructing tidal flow and seawater flow.
• CIEL argues that the project contradicts the goals of the CDM and the Kyoto framework by locking India into nearly three decades of reliance on greenhouse gas-intensive fossil fuels rather than shifting toward sustainable energy sources.

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} }