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Sierra Club CDM Watch submitted a letter to the CDM Executive Board arguing that Project 4629 in India is non-additional. The authors contend that the project would proceed regardless of CDM support because the Government of India mandates supercritical technology and the owner, Reliance Power, has already committed to such technology through a US$10 billion order. They further argue that the project's baseline scenario is flawed, fails to consider energy efficiency alternatives, and uses an unrealistically narrow coal price sensitivity analysis. If registered, the project could receive over 21 million CERs, potentially providing a windfall of approximately €257 million.