Methodology Comments

Dear Methodology Panel members, As an expert reviewer for two previous versions of this methodology I recommend that those methodologies not be accepted on the basis that they did not accurately estimate the change in emissions caused by these projects or appropriately test the additionality. Some of the problems I raised are not resolved in the currently proposed methodology, NM0358, and I believe it would be a mistake for the methodology panel to accept this methodology as it is currently written. First, the methodology panel should understand that grid interconnection is common practic

Submitted to CDM Methodology Panel Title of new baseline methodology: Country risk analysis, baseline scenario development, and ex-ante baseline emission rate calculation for a grid-connected project that displaces fossil fuel based power generation from the operation and expansion of the electric sector (NM0054) Barbara HayaConsultantInternational RiversApril 5, 2006

Submitted to CDM Methodology Panel Title of new baseline methodology: "Baseline methodology for displaced electricity generation in a centrally dispatched hydrothermal interconnected power system" (F-CDM-NM0020)

Submitted to the CDM Methodology Panel on Methodology NM-0008.

Submitted to CDM Methodology Panel for Methodology NM-0006.

Submitted to CDM Methodology Panel Title of new baseline methodology: Grid–connected hydroelectric power generation projects in low–density vegetation areas (NM0130) Strengths and weaknesses of the methodology: Strengths of this methodology include the requirement of World Commission on Dams compliance, the use of the additionallity tool, and reservoir emissions accounting with ex–post measurements. World Commission on Dams Compliance: I welcome the requirement for compliance with the World Commission on Dams. Compliance should apply to the entire planning process, not just the social an

In a Centrally Dispatched Hydrothermal Interconnected Power SystemFrom the UNFCCC’s CDM Public Comment Form #NM0125 [Only completed sections of the form appear here. Full form may be downloaded from www.unfccc.int] A. Comment on the proposed new methodologies: I. Comments on the proposed new baseline methodology: Title of new baseline methodology:Baseline Methodology for New Capacity that Displaces Electricity Generation in a Centrally Dispatched Hydrothermal Interconnected Power System Conditions under which this methodology is applicable to other potential projects (e.g. project type, regi

Submitted to CDM Methodology Panel  Title of new baseline methodology: Grid-connected hydroelectric power generation projects in low-density vegetation areas where average water temperature is low (NM0196). Barbara Haya Consultant International Rivers December 19, 2006

Submitted to CDM Methodology Panel Title of new baseline methodology: Hydropower Projects that Create New Reservoirs or Expand Existing Ones (NM0121) The methodology is commendable in that it is the first one to recognize the need to measure emissions of CO2 and CH4 emissions from reservoirs (including degassing at the dam outlets).An important weakness of the proposed methodology is that it does not appear to allow for independent third–party experts to carry out the recommended measurements. It appears that project developers/operators would themselves carry out the measurements. This set

International Rivers Comments on CDM Methodology NM0043 Proposed for Bayano Hydroelectric Expansion and Upgrade Project, PanamaSubmitted to CDM Methodology Panel Methodology is Poorly Described The proposed methodology is described as applying to "grid–connected run–of–river power plants or grid–connected hydroelectric power plants" (PPD p.39). As a run–of–river plant is a hydroelectric plant this explanation is redundant. Methodology fails to prove additionality The arguments in the PDD which attempt to show the additionality of Bayano do not hold up to scrutiny. The PDD admits