Comments to JI PDD form and guidelines for users of the JI PDD form

From Stela Blagova
Date 04/14/2006 10:31 AM
Subject Comments to JI PDD form and guidelines for users of the JI PDD form
   UNFCCC Project-Based Mechanisms Programme

P.O. Box 260 124
D-53153 Bonn

Dear Sir/Madam,

“Overgas Inc” AD is holding company that has 26 gas distribution subsidiaries on the territory of Bulgaria, which invest in, design, construct and exploit the urban gas distribution networks and sell natural gas to the end consumers. I am pleased to announce that it is the most active Bulgarian corporation on the greenhouse gas emission reduction market in Bulgaria with three signed contracts for supply of ERUs to the Netherlands under mechanism “Joint implementation” through the Dutch government agency SenterNovem.

Counting on its experience in the area of elaboration and development of projects under the mechanism “Joint implementation”, “Overgas Inc” AD expresses its positive opinion regarding the suggested for discussion JI PDD form and the guidelines for users of the JI PDD form.

We appreciate the organizational support, which the Secretariat of UNFCCC offers for the development of the Joint implementation mechanism.
We congratulate the Supervisory Committee of JI with the ambitious work plan, which stipulates the development and submission for discussion of a number of documents, required by the potential suppliers of ERU for the preparation of the JI documentation. The availability of similar forms of the documents will activate and facilitate the work on the preparation of JI documentation and the signing of contracts for the delivery of ERU. That is why we express our hope that the JI PDD form and the guidelines for users of the JI PDD form will be accepted and put into use as soon as possible.

We support your view, that the already signed contracts should not be subjected to a second preparation of PDD under the new form /Part 1, A. Item 8/. The new JI PDD form corresponds entirely to the content of the developed by the World Bank and Senter JI PDD form, also multiplied in the tender documents of the other government agencies, which conduct tenders for the delivery of reduced emissions. The follow-up validation would be entirely obsolete and it would lead to a significant increase in the expenses for the preparation of the documentation, and it could also worsen the project indicators.

Taking into considerations the importance of the projects for switch the liquid and solid fuels to the cleaner fuel of natural gas and their contribution in ecological, social and economic aspect on national as well as international level, we are open for deliberations and contacts with the goal of improving and facilitating of the procedures of the mechanisms under the Kyoto protocol and to help for the chastening of climate changes and the reduction of their effect on the ecosystems.

With best regards,

Stela Blagova
Head, Ecology and Sustainable development Dept.