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Carbon Market Watch challenges the project boundaries of a JI waste coal processing project in the Luhansk region of Ukraine, stating that the lack of specific waste heap identification and the potential for adding new facilities during the monitoring period violate the requirements for a conventional JI project.

Carbon Market Watch challenges the validity of a JI project in Ukraine's Sverdlovsk district, arguing that the project's claim of additionality is not credible because it was operational for 4.5 years before the Letter of Approval was issued. The organization also contends that emission reductions are likely exaggerated due to a lack of supporting coal production data and flawed baseline assumptions regarding the spontaneous burning of waste heaps. Additionally, the document criticizes the project's physical boundaries for being insufficiently defined, noting that the project allows for the addition of new waste heaps and complexes during the monitoring period.