CDM Comments

Comments to PJRCES on the Teles Pires Hydropower Project (Brazil)

Thursday, February 23, 2012
Submission by International Rivers to the Perry Johnson Registrars Carbon Emissions Services on the Teles Pires Hydropower ProjectThe Teles Pires Hydropower Plant should clearly not be eligible to receive financial incentives under the CDM. Despite growing scientific evidence attesting to the major significance of GHG emissions from hydroelectric dams in the tropics, the Environmental Impact Study (EIA) for the project simply sidestepped this fundamental question, including its cumulative impacts with four other large hydroprojects slated for construction along the Teles Pires river. The dam

Comments to CF Carbon Fund II Ltd Regarding the Kamchay Hydropower Project (Cambodia)

Friday, January 20, 2012
We request that the Kamchay Hydropower Project in Cambodia, which applied for validation in the fall of 2008 and has now reapplied, not be validated and allowed to apply for CDM credits, because it is not an additional project, was carried out in a poor manner and carries adverse environmental and social impacts.  To review International Rivers’ concerns regarding the Kamchay Dam and its previous application for carbon credits, submitted to SGS (Thailand) Limited on 11 March 2010, please see “Letter to SGS Re Kamchay Hydroelectric BOT Project (Cambodia).” Summary of ConcernsThe projec

Civil Society Letter Regarding the Registration of the Bujagali Hydropower Project

Friday, January 6, 2012
CDM Executive Board UNFCCC Secretariat Martin Luther King Strasse 8 P.O. Box 260124 D-53153 Germany Subject: Unsolicited letter regarding the registration of the Bujagali Hydropower Project Dear Mr. Hession, We are writing to express our serious concerns over the registration of Project 4217: Bujagali Hydropower Project. We understand that the deadline for requesting review was 29 December 2011. Through a miscommunication we were not able to submit our letter in time. However, we trust that you will take our concerns seriously and initiate a review as soon as possible. Registration was

Comments on the Marañon Hydroelectric Project (Peru)

Friday, December 23, 2011
Submitted to the Colombian Institute for Technical Standards and CertificationAdditionality There are several important inaccuracies in the investment analysis that must be corrected and verified. The financial benefits of the project to the developer are greater than what is included in the PDD: First, tariffs in Peru are expected to increase over time. A flat tariff of US$ 0.038 per kWh would not accurately reflect the developer's expected revenues. For example, auctions were held this year for future hydropower projects, which were awarded contracts with energy tariffs between US$ 0.04

Comments on the Nam Ngum 5 Hydropower Project (Lao PDR)

Friday, November 11, 2011
Submitted to the China Environmental United Certification Center Co., Ltd.We are writing to express our concerns over the application for validation of the Nam Ngum 5 Hydropower Project in Lao PDR. Summary of ConcernsThe project is not additional. The project is 60% complete as of June 2011, and is likely being financed by a loan from the National Bank of China. In addition, the Project Design Document (PDD) uses inaccurate values to calculate its IRR in its investment analysis in order to appear economically unviable in the absence of CERs.The PDD is poorly written and riddled with gaps in i

Citizens Concern for Dams and Development Comments Regarding Khuitam HEP (India)

Friday, July 22, 2011
Submission of the Citizens Concern for Dams and Development to Lloyd’s Register Quality Assurance Ltd. in Response to Call for Comments to the PDD of 66 MW Khuitam HEP After perusal of the Project Design Document (PDD), Version 01 dated 21/06/2011(available on the UNFCCC website) of Khuitam Run-of-the-River Hydro Electric Project, Executive Summary of the Project and also the proceedings of the Public Hearing conducted on the proposed project at West Kameng District, Arunachal Pradesh, India and considering the views of affected villagers and the insistence for mega dam construction in almos

Comments to the Korean Foundation for Quality Regarding the Yunnan Gongguoqiao Hydropower Project (China)

Tuesday, June 28, 2011
Project Overview: Project Title: Yunnan Gongguoqiao Hydropower ProjectStatus: Under constructionLocation: Dalishu Village,Yunlong County, Dali Bai Autonomous Prefecture, Yunnan ProvinceProject Participants: Huaneng Lancang River Hydropower Co., Ltd. (China)Vitol S.A. (Switzerland)Claimed Total Installed Capacity: 900 MW (4*225 MW)Claimed Annual Emission Reductions: 1,974,939 tCO2e/yearPlanned starting date of the first credit period: January 1, 2012 or date of registrationThe Yunnan Gongguoqiao Hydropower Project is the northernmost dam in an eight-dam cascade on the Lancang River, which emerg

Comments to TUV NORD Regarding the Thuong Kon Tum Hydropower Project (Vietnam)

Thursday, June 2, 2011
We request that the Thuong Kon Tum Hydropower Project not be validated and allowed to apply for CDM credits, because it is not an additional project, carries adverse environmental and social impacts, is unlikely to offset carbon emissions and has a record of poor planning, which makes it a risky venture. 1) Weak claims of additionality While the PDD sites the April 2009 signing of a CDM consultancy contract for the Thuong Kon Tum Hydropower Project as evidence that the project considered CDM assistance during the dam's early stages, this additionality argument is weak as it fails to expla

Comments to ERM Cert Regarding the Sujiahekou Hydropower Station (China)

Tuesday, April 19, 2011
Project Overview:Project Title: Sujiahekou Hydropower StationStatus: Under constructionLocation: Tengchong County, Baoshan City, Yunnan Province, ChinaProject Participants: Yunnan Baoshan Binglangjiang Hydropower Development Co., Ltd (project owner)Carbon Asset Management Sweden Pte Ltd.Claimed Total Installed Capacity: 315 MW (3*105 MW)Claimed Annual Emission Reductions: 880,979 tCO2e/yearPlanned starting date of the first credit period: January 1, 2012Summary of Concerns:Sujiahekou Hydropower Station is a new hydropower station constructed and operated by Yunnan Baoshan Binglangjiang Hydropo

Letter to the CDM Executive Board Regarding the Barro Blanco Hydroelectric Project

Wednesday, February 9, 2011
To the CDM Executive Board Martin Luther King Strasse 8 P. O. Box 260124 D-53153 Re: CDM Project Application #3237: Barro Blanco Hydroelectric Project. February 7, 2011 Dear Chair of the CDM Executive Board: We are writing to you on behalf of the April 10 Movement for the Defense of the Tabasara River (M-10), Alianza para la Conservacion y el Desarrollo (ACD), Asociacion Ambientalista de Chiriqui (ASAMCHI), International Rivers, the Counter Balance coalition, and CDM Watch to express our serious concerns about the proposed CDM project involving Generadora del Istmo, S. A. (GENISA) in the Tabas

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