Minister Tritten’s Response to NGOs on La Esperanza/WCD

From:

Jürgen Tritten
Federal Minister
Member of the Bundestag

Dear Mr. Maier, dear Jürgen,

Thank you very much for your letter dated 26 November regarding the CDM project "La Esperanza" in Honduras. On behalf of the non–governmental organisations working in the German NGO Forum on Environment and Development you strongly lobby for compliance with the rules of the World Commission on Dams (WCD). In my view, the WCD rules are a major improvement in shaping environmental standards for hydropower projects, reasonably including sustainability into the evaluation.

In the future it will be important to implement WCD rules in practice. For this purpose the CDM offers a good opportunity. This is why I welcome that compliance with WCD rules is a binding requirement in the CDM/JI directive of the EU for projects of more than 20 MW. This will be also a legal condition in the national implementation of the EU directive in Germany. Furthermore the Federal Environment Ministry is pleading for viable procedures so compliance with WCD rules can be demonstrated by project developers and investors and can as well be validated by an independent accredited certifier.

However, the CDM project "La Experanza" in Honduras is not an appropriate project for implementing this concern. In their own applicability definition the WCD rules exclude projects like this one. On the one hand it doesn’t reach the critical project size necessary for the application of WCD rules. On the other hand La Esperanza is a cascade of run–of–river power plants based on a historical dam regulating the watercourse. Even with a view to the EU directive the critical limit of 20 MWel is not exceeded by the three "La Esperanza" aggregates that have altogether 12.73 MWel.

Apart from the formal argumentation based on the WCD rules, the question from my point of view is if objections can be raised against the project itself. But neither there were objections raised by you, nor were such arguments brought before the government, or were raised by institutions interviewed in this matter. Nevertheless the Community Development Carbon Fund (CDCF) was asked to explain its consideration of environmental concerns in La Esperanza. The examination of these documents did not reveal any information that would advise to ask for a Request of Review. As regards the procedures I would like to point out that Germany was not involved in approving La Esperanza but for the first time only in the run–up to the registration, as Germany was only involved indirectly within the framework of CDCF.

Compliance of WCD rules is a major concern for the Federal Environment Ministry, not only in the context of the Clean Development Mechanism. This is why I regard the adoption of WCD rules by KfW as essential and trend–setting. Other institutions and players should follow this example. I will argue for that strongly. I hope I can rely on your support for this important task.

Kind regards,

Jürgen Tritten