CDM Comments

SANDRP Comments on ADB Kaldigad Small Hydro Project (Uttaranchal, India)

Sunday, June 4, 2006
Current Status: Validation Terminated (as of Aug 2009) Submitted to Det Norske Veritas (DNV) While projects like the Kaldigad Small hydro project are desirable if taken up in proper manner, the project taken up as present should not be validated for the following reasons.1. The project developer (Uttaranchal Jal Vidyut Nigam Ltd) and funding agency (Asian Development Bank) have not done any satisfactory consultation with the people in the affected villages. The local people have not been given any of the project documents like the detailed project report, have not been given the environment im

Submitting Public Comments on CDM Projects

Wednesday, October 10, 2007
The CDM project approval process allows the public to submit comments on projects applying to be registered with the CDM's Executive Board. Once a project is registered it is then eligible to be issued with carbon credits. A CDM carbon credit is called a Carbon Emission Reduction (CER). Each CER is supposedly equivalent to an avoided emission of one tonne of carbon dioxide equivalent.Projects are open for public comments for 30 days as part of the project "validation" process. The comments are submitted to consulting companies known in the CDM jargon as Designated Operational Entities (DOEs).

International Rivers Comments on Chacabuquito Large Hydro Project (Chile)

Thursday, May 9, 2002
Current Status: Registered on 7 July 2007 Comments on the World Bank PCF Project Design Document for the Chacabuquito Large Hydro ProjectSubmitted to the World Bank Prototype Carbon Fund International Rivers has concerns regarding the absence of discussion of reservoir emissions, a possible overestimation of the cost of emissions reductions credits, and other procedural issues for the proposed Chile–Chacabuquito Hydroelectric Power Project.Costs of emissions reductions: The emissions reduction calculations leave out a discussion of possible emissions from the project’s impoundment.

CORE Comments on Jorethang Loop Large Hydro (Sikkim, India)

Wednesday, September 27, 2006
CORE Comments on Project Design Document for the Jorethang Loop Hydroelectric Project, Sikkim, IndiaSubmitted to Det Norske Veritas (DNV) We have perused the PDD as obtained from the website, and found it seriously deficient in key aspects. Our comments below are brief and not comprehensive in addressing every aspect of the PDD. The project cannot be taken as an additionality, as many viable alternatives exist. Moreover, the region is chock-a-block with hydrolectricity project proposals and projects that have been under consideration for many years. The project has been under proposal for som

International Rivers Comments on Trojes, Benito Juarez & Chilatan Hydros (Mexico)

Sunday, June 20, 2004
Current Status: Trojes was Registered on 4 November 2006; Benito Juarez's Validation was terminated, and there no longer any CDM records for Chilatan (as of Aug 2009) Comments on the World Bank PCF CDM Project Design Document for the the Mexico INELEC Hydroelectric Umbrella ProjectSubmitted to the World Bank’s Prototype Carbon Fund I have common concerns regarding the additionality of the three Mexican hydropower projects under public review ending May 23: the Trojes, Benito Juarez, Chilatan hydroelectric projects. Almost identical additionality discussions are used for these three projec

Comments on El Gallo Large Hydro Project (Mexico)

Wednesday, September 1, 2004
Current Status: Registered on 14 July 2006 Comments on Project Design Document for the World Bank Prototype Carbon Fund El Gallo Large Hydro Project (Mexico)Submitted to the PCF My comments on the El Gallo hydroelectric project are very similar to the comments I previously submitted on the Mexican Trojes, Benito Juarez, and Chilatan hydroelectric projects.While it is argued that the project developers have had difficulty assuring full financing for the project and that the involvement of the PCF in the project helps lend credibility to the project, for a number of reasons it seems very likely

SANDRP Comments on the Budhil Large Hydro Project (Himachal Pradesh, India)

Tuesday, October 3, 2006
Current Status: Registered on 7 May 2009. SANDRP Comments on the Project Design Document for the Budhil Large Hydro Project (Himachal Pradesh, India)Submitted to SGS Based on reading of the PDD, the EIA of the project prepared by Dhiman Environment Forestry Consultants (P) Ltd, the conditional environmental clearance given to the project and knowledge of the hydropower projects in Himachal Pradesh, it seems it will not be appropriate to validate the 70 MW Budhil Hydroelectric Power Project in Chamba district in Himachal Pradesh in North India in current form. As per the conditional enviro

NESPON Comments on the Jorethang Loop Large Hydro Project (Sikkim, India)

Friday, September 1, 2006
NESPON Comments on Project Design Document for the Jorethang Loop Hydroelectric Project on the Rangit River in the state of Sikkim, India.Submitted to Det Norske Veritas (DNV) The Jorethang Loop Hydroelectric Project (JLHEP) is an energy project under CDM activities by DANS Energy Private Ltd on the Rangit River in the state of Sikkim, India. The project is said to have an installed capacity of 96MW and that will generate approx. 441.2 Gwh(net) per annum. The project will involve the construction of a diversion barrage, approximately 13.5 Km downstream of the project of the proposed barrage s

SANDRP Comments on Bhilangana Hydro Project (Uttaranchal, India)

Wednesday, June 14, 2006
Current Status: Registered on 8 January 2007 SANDRP Comments on Project Design Document for Bhilangana Hydro Project (Uttaranchal, India)Submitted to TÜV Nord While (relatively) small hydro projects like the 22.5 MW BHPP are desirable if taken up in proper manner, the project taken up as present should not be validated for the following reasons. The project developer (Swasti Power Engineering Ltd) has not done any satisfactory consultation with the people in the affected villages. The local people have not been given any of the project documents like the detailed project report, have not

Comments on World Bank PCF Xiaogushan Large Hydro Project (China)

Sunday, August 21, 2005
Current Status: Registered on 11 August 2006 Submitted to Japan Consulting Institute (JCI) Project Overview: Status: Under construction.Location: Heihe River, Gansu ProvinceType: 98MW diversion hydropowerProject Participants: World Bank Prototype Carbon Fund (PCF); Xiaogushan Hydropower Co. Ltd. (XHC)Estimated generation: 358 GWh/yClaimed emission reductions: 312,368 tCO2/year (3,123,680 tCO2 over 10 years)Funding: 35% from Asian Development Bank the rest ($52m) from domestic sourcesXiaogushan is non–additional and therefore cannot be validated as a CDM project. Project documentation from

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