Letter

THE TELES PIRES DAM'S CDM PROPOSAL: COMMENTS ON THE PROJECT DESIGN DOCUMENTPhilip M. Fearnside National Institute for Research in Amazonia (INPA) Manaus, Amazonas, Brazil pmfearn@inpa.gov.br The Project Design Document (PDD) for the Teles Pires Dam's proposal for carbon credit under the Kyoto Protocol's Clean Development Mechanism (CDM) is indeed revealing, both of the flaws in the current CDM system and of the inconsistencies between Brazilian government's stated concern for climate change and its engaging in maximum exploitation of loopholes in CDM regulations. The docu

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

In a December 2011 letter from the Kayabi, Apiacás and Mundurucu indigenous tribes to authorities of the Brazilian government, indigenous communities show that the environmental licensing process of the Teles Pires Hydropower Plant has been marred by: i) grave deficiencies in the analysis of impacts on indigenous peoples and their territories, ii)political pressures on federal agencies responsible for indigenous rights and environmental protection (FUNAI and IBAMA, respectively) to illegally approve licenses and iii) lack of free, prior and informed consultations and consent among threatened

Robert Allen Jr. General Manager Theun-Hinboun Power Company Ltd. P.O. Box 3382 Vientiane, Lao PDR Dear Mr. Allen, Findings from International Rivers' Field Visit to the Theun-Hinboun Expansion Project As you are aware, International Rivers has been monitoring and advocating on behalf of communities affected by the Theun-Hinboun Hydropower Project for well over a decade. In September 2011, we visited seven villages in the Theun-Hinboun project area to ascertain the situation of people affected by the Theun-Hinboun Expansion Project (THXP). This was an informal survey which aimed to give us an

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

International Rivers welcomes the opportunity to respond to the CDM Executive Board's call for public inputs on the CDM policy dialogue. Our response suggests improvements to various aspects of the CDM pipeline, process and implementation. Discussions about the future of the flexible mechanisms should be firmly grounded in an analysis of their performance so far. The CDM has largely failed to meet its dual objectives of supporting cost-effective climate change mitigation in Annex 1 countries and sustainable development in non-Annex I countries. In the second commitment period, the CDM

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

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

Dear Ministers, We, more than hundred civil society organisations from 35 countries across all continents, call on Parties to acknowledge the urgency with which climate change needs to be addressed and to agree to ambitious and immediate emissions reduction targets that are in line with the Cancun Agreement to prevent global warming beyond two degrees Celsius. Kyoto Protocol parties must commit to a second commitment period at Durban. The legal and governance structure of the Kyoto Protocol is crucial to ensuring that mitigation commitments are legally binding and have environmental integri

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