CDM Comments

Comments on the La Yesca Large Hydroelectric Dam (Mexico)

Friday, January 21, 2011
Submitted to Spanish Association for Standardisation and CertificationLa Yesca is a business-as-usual dam project that has already secured almost a billion dollars in project financing, is nearing the final stages of construction, and in no way requires – and has never been dependent upon – CDM income to be completed. It is therefore non-additional. It should not be validated for the CDM. The project developer, the public utility CFE, has clearly long been aware of the possibility of obtaining CDM income for La Yesca and its other low carbon projects. As the PDD states, this potential inco

Comments to SASC on the El Quimbo Hydroelectric Project (Colombia)

Saturday, November 27, 2010
International Rivers Comments to the Spanish Association for Standardisation and Certification (SASC) on the CDM Project Design Document for El Quimbo Hydroelectric ProjectThe El Quimbo Hydroelectric Project in Huila, Colombia on the Magdalena River should not be registered as a CDM project, as it is clearly not additional and has negative social and environmental impacts. The project developer tries to use the benchmark, barrier, and common practice analysis to show that the project is additional. In all three cases the arguments presented are full of holes. As shown by new research from the

Conservation Strategy Fund Comments to CITSC on the Bonyic Hydroelectric Project (Panama)

Friday, September 3, 2010
To Whom It May Concern: This letter contains my comments on the subject of Clean Development Mechanism credits for the Bonyic Hydroelectric project in the Teribe watershed of Panama. This project does not meet the CDM's requirement of financial additionality. A study conducted by Conservation Strategy Fund and partners in 2006 found that the Bonyic project was financially feasible without carbon credits. The study analyzed the Bonyic project along with three planned at the time on the Changuinola River, finding that the collection of projects would generate an after-tax net present val

FERN Comments to CITSC on the Bonyic Hydroelectric Project (Panama)

Tuesday, September 21, 2010
FERN supports the comments submitted by Alianza para la Conservación y el Desarrollo (ACD) and requests that the Bonyic hydroelectric project be rejected as a CDM project for the reasons outlined in detail in the ACD submission. In particular, FERN would like to emphasis the controversial nature of the hydro project itself, which led to the Inter-American Development Bank (IADB) having refused to participate in this hydro power project in 2005 (see letter submitted with ACD submission to the CDM). According to the Project Design Document (PDD p. 17-18), Corporacion Interamericana para el Fin

Comments on the Bonyic Hydroelectric Project (Panama)

Saturday, September 4, 2010
Submitted to the Colombian Institute for Technical Standards and Certification (CITSC)The Bonyic Hydroelectric Project should not be eligible to receive CDM credits because the project is non-additional, has numerous adverse environmental and social impacts, and did not properly inform project-affected people. Construction already began in October 2007, prior to the proposed project validation date, so it cannot be considered additional. If the project really depended on the sale of carbon credits to be viable, then the project would not be able to start until validation of the project by the

Comments on Bujagali Hydropower Project's Second Application (Uganda)

Thursday, August 19, 2010
To understand the largely fictional nature of this application to the CDM, one needs only to read the first line of the PDD: "The Bujagali Hydropower Project is a proposed hydropower..." It is not proposed. It is well over half complete. This basic fact is nowhere mentioned in the PDD. Bujagali Dam is going to be completed regardless of whether or not it is able to receive income from selling CDM offsets. It is non-additional and should not be validated as meeting the CDM's requirements. According to the latest issue posted on-line of Bujagali Energy Limited's newsletter, as of 31 March 2010,

Movimiento Social Comments to RINA Regarding the Sogamoso Hydropower Project (Colombia)

Cuenca del río Sogamoso y río Chucurí, donde se tiene proyectado construir la represa.
Friday, July 16, 2010
Argumentos de las comunidades ante la solicitud de MDL por parte de ISAGEN para el proyecto hidroeléctrico Hidrosogamoso, departamento de Santander, ColombiaCuenca del río Sogamoso y río Chucurí, donde se tiene proyectado construir la represa. En ese valle viven comunidades de campesinos, pescadores y mineros artesanales que viven del material de arrastre del río. La foto fue tomada desde la vereda Sogamoso, en el municipio de Betulia, en noviembre de 2008. El Movimiento Social en Defensa del Río Sogamoso, conformado por líderes comunitarios, estudiantes, ambientalistas, organizaciones

Comments to ERM Cert on the Guangxi Dahua Hydropower Project (China)

Monday, July 19, 2010
Comments to ERM Certification and Verification Services Ltd Regarding the Guangxi Dahua Hydropower Project International Rivers provides the following comments on the application for CDM validation of the Guangxi Dahua Hydropower Project (GDHP). The comments are based on information from both government and industry online sources. Summary of Concerns The 110MW GDHP, which is an extension of the existing Dahua Dam, is non-additional. The website of the operator of the existing dam states that the expansion project started construction in 2007 and was completed in July 2009. It cannot therefor

SANDRP Comments About the Proposed CDM Credits for the Teesta VI Hydroelectric Project (India)

Friday, April 2, 2010
Based on reading of the Project Design Document dated March 2, 2010 (version 1 as available on the UNFCCC website) for the above project, having seen the order of Maharashtra Electricity Regulatory Commission on the application of approval of the PPA of MSEDCL with the Project Proponent (PP), having seen the concurrence letter dated Dec 27, 2006 from the Central Electricity Authority (CEA) of Govt of India (GoI) under the section 8 Electricity Act of 2003, having seen the Environment Impact Assessment and also the clearance letter from the Ministry of Environment and Forests (MEF) and having m

Comments to DNV Regarding the Teesta VI Hydroelectric Project (India)

Monday, April 5, 2010
The Project Proponents are providing misleading information to the UNFCCC for gaining undue CDM benefits. The project does not qualify for CDM credits and would form an unhealthy precedent if granted CDM credits. Based on our information we submit that it will not be appropriate to accept the Teesta VI Hydroelectric project in India for CDM credits. Some of the reasons why the project should not be accepted for CDM credits are: 1. It is a business as usual hydro project. There is no demonstrated additionality. Such projects have been implemented in the past without CDM credits. None of the of


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