Comments on Project Design Document for Campos Novos Dam, Brazil

Saturday, December 1, 2007

Current Status: Validation Terminated (as of Aug 2009)

Campos Novos Dam filled
Campos Novos Dam filled
Chaver83, Flickr
There are several grounds on which the 880 MW Campos Novos Dam should be rejected: lack of adequate stakeholder consultations (due to suppression of stakeholder voices, including unjustified arrests); illegal practices involved in the development of the project; and blatant non-additionality.

The fact that the project is already operational without CDM credits should disqualify it from any consideration for credits. It is clear that the project would be completed without the CDM because, in fact, it was completed without the CDM. The PDD states that “CDM incentives were the key points to decision-making to implement the project activity.” No evidence is given of this, and indeed, it is hard to imagine what evidence could be believable. Construction on Campos Novos started in 2001, well before the CDM was functional. It is not credible that the decision to build a project with costs estimated at more than half a billion dollars would have been based on speculation that it might perhaps at a later date be able to generate some income from the CDM.

Campos Novos has been the object of controversy since construction began. The dam displaced more than 2,000 small farmers. The companies building the dam suppressed dissent, and ten leaders of the Dam-Affected Peoples´ Movement (MAB) were jailed in anticipation of a protest (that is, the protest was pre-empted by their jailing without just cause). Meaningful stakeholder consultations cannot be conducted in an environment of suppression and illegal jailing. Any project involving suppression and illegal jailing should be rejected on the grounds of not meeting the CDM stakeholder consultation requirements.

Dam-affected communities say they still have not yet received adequate compensation from Enercan, the project developer, which would enable them to restore their previous standard of living.

According to MAB, employees of the dam-building company were involved in real estate speculation in the region where the dam was being built. DNV must look into these claims. Evidence of substantial corruption or fraud should make a project ineligible for inclusion under the CDM, since standard methods of evaluating project barriers would not apply in these cases. Further, the dam´s floodgates were initially closed in October 2005, without authorization by state environmental authorities, and the company was ordered to re-open them.

Shortly after the gates were re-closed, communities downstream noticed that large amounts of water were leaking from the dam. The communities brought their concerns over dam safety to the attention of the dam authorities, but these took no action and issued no information to the public. The dam project made international news when a diversion tunnel ruptured in June, 2006, causing an uncontrolled release of 1.47 billion cubic meters of reservoir water, with a resulting massive fish kill.

The sudden emptying of the reservoir revealed that forested areas along the banks of the river had not been cleared, as required under Brazilian law (and therefore were rotting and emitting greenhouse gases).

The CDM Project Design Document makes statements which are not factual, including the ridiculous comment that Campos Novos “has the characteristics of a small-scale powerplant.” In fact, it is the largest hydro project in the CDM pipeline, is one of the world´s tallest dams, and must have emitted an enormous amount of greenhouse gases during construction and repair of damage to the dam.

The Brazilian interconnected system is inefficient and needs to be updated – technical losses from transmission exceed 16% of power generated, an unacceptably high figure. New independent studies have shown that there is a great potential for energy savings via improved efficiency, a potential that has virtually been ignored by the Brazilian government which favors construction of large hydroelectric projects.

More information: 

International Rivers press release on sudden emptying of Campos Novos reservoir

Campos Novos PDD and Comments (on DNV website)