Submission to the CDM EB Regarding Se San 4A (Vietnam)

Ame Trandem
Monday, March 11, 2013

Dear CDM Executive Board,

We are writing to express our concern about the proposed CDM Project 9017: Se San 4A Hydropower Project in Vietnam. Registration has been requested following a validation report by TuV NORD CERT GmbH  (Report No. MY-VAL-11/16-11/197), which recommends approval. As a decision is expected to be made soon by the Executive Board, we trust that you will take our concerns seriously and carry out an immediate review of the project, and on the basis of the project’s problems, reject its request for registration.

Attached please find our submission on Project 9017, including supporting evidence for why the project should not be registered. In summary, due to inconsistencies between the project information reported in the Validation Report and Project Design Document (PDD), and the information provided by regional government officials, official news sources, and an environmental impact assessment done in consideration of the project, we believe that the project requires urgent review on the following grounds:

  • The validation report lacks accuracy and proof of additionality;
  • The project was not meant to be a hydropower dam, but rather a re-regulating project with no installed generation capacity;
  • The project does not meet CDM requirements regarding sustainable development as the Validation report and PDD fail to mention the serious adverse impacts being suffered by Cambodians living downstream of the project;
  • Insufficient community consultation.

Based on these concerns, we respectfully request the CDM Executive Board to conduct an immediate review of the project and examine the reasons we have identified as a basis for a rejection of the project.

Ame Trandem
Southeast Asia Program Director

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