International Rivers Comments on CDM Methodology Proposed for Nho Que Large Hydro (Vietnam)

Thursday, July 14, 2005

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 and environmental impacts of the project. This would include also, for example, the requirement that projects be assessed against alternatives producing the same services.

      Also, this requirement would be easier to fulfill if it were made more specific. One possibility is to explicitly require the project to meet the criteria described in chapter 9 of the World Commission on Dams report.

      Reservoir Emissions:

      I strongly recommend that the panel consult with experts to evaluate the reservoir emissions estimation methods used in this methodology, and possibly to develop an appropriate method which can be used for all large hydro projects. This jury could evaluate various elements of this methodology, including its definition of low–density vegetation, the inclusion of N2O fluxes, the method of ex–post measuring of degassing, and its applicability to different types of reservoirs (in tropical vs. temperate regions and to different reservoir depths). Further, the 2003 IPCC Good Practice Guidance For Land, Land–Use Change and Forestry provides updated methods for estimating reservoir emissions.

      As Patrick McCully comments on methodology As Negotiations Drag, Subnational Leaders Step Up, there is a question of who should perform the ex–post measurements. I agree with his recommendation to involve independent third party experts to avoid conflicts of interests.

      Additionally, the methodology should allow for the updating of default values and estimation methods as our understanding of reservoir emissions improves.

      Barbara Haya
      International Rivers
      July 14, 2005