Comments on CDM Project Design Document for Tala Dam, Bhutan

Saturday, January 19, 2008

Official CDM project name is "Substitution of grid power generation through transmission of renewable electricity generated in a hydro power generating station"


Submitted to DNV

Wangchu River
Wangchu River
Robert Tyabji
The non-additionality of this project should be obvious.

The project started construction in October 1996 before the Kyoto Protocol was negotiated and before the Clean Development Mechanism even existed on paper. Therefore it is impossible that the CDM was considered in the decision to build the project.

The PDD does not argue that the CDM was required to build the project.

The PDD argues only that: “The project proponents however look up to CDM revenue to provide necessary coverage to any loss arising out of any unexpected difficulties during implementation and operation of the project activity.” Arguing that the CDM will help the developers recover cost overruns does not fulfill the requirements of the additionality tool, which tests if the CDM was required for the project to go forward.

The PDD names two alternatives to the CDM project:
“Alternative 1 – Implementation of the project activity not undertaken as a CDM project activity:
Alternative 2 – Continuation of pre-project scenario i.e. the current situation (no project activity or other alternatives undertaken)”
It then states that alternative 2 is the only “realistic and credible alternative“. No reason is given why alternative 1 is not credible. This also does not fulfill the requirement of the additionality tool.

The first unit of the project started producing power at the beginning of August 2006, a year and four months before the start of the public comment period, and all six units were on line as of March 2007. It can not be argued that the CDM is needed to complete project construction – construction is already complete.

The project developer could not claim that their decision to continue building the project was dependent on the expectation of receiving CERs because the developer could never expect with confidence that the project would be positively validated, because of the questionability of the project’s additionality.

It would be absurd if DNV positively validated this project.


Barbara Haya
International Rivers

More information: 

SANDRP Comments on Tala Hydro Project

Tala Project on CDM website