Submission to the CDM EB Regarding Nam Ngum 5 (Lao PDR)

Tania Lee
Wednesday, April 10, 2013

Dear Mr. Sengchandala and the CDM Executive Board,

On behalf of International Rivers, we are writing to express concern about the proposed CDM Project 9038: Nam Ngum 5 in Lao PDR. Registration has been requested following a validation report by China Environmental United Certification Centre, Ltd. (Report No.11011127), which recommends approval. As a decision is expected to be made soon by the Executive Board, International Rivers trusts that you will consider these concerns seriously and carry out an immediate review of the project.

The 120MW Nam Ngum 5 Hydropower Project is located on the Nam Ting River, a main tributary of the Nam Ngum. The powerhouse is located 15km south, on the Nam Ngum, into which water is discharged. The Nam Phat and Nam Sout are the two main tributaries nearby that run into the Nam Ting and are affected by the project. The project was built by China's Sinohydro Corporation and Lao PDR's Electricte du Laos (15% stake). The dam’s construction began in 2008 and was completed by December 2012. The dam’s PDD was done by CF Carbon Fund II Ltd.

Due to significant faults and gaps in information provided in the validation report and revised PDD, we believe that the project requires urgent review of the following issues, which make the project’s request for registration highly questionable:

  • The validation report lacks proof of additionality, relying on flawed conclusions related to external investment, common practice, and financial viability; and
  • The project does not meet CDM requirements regarding sustainable development as the validation report and the PDD are based on an incomplete environmental impact assessment, and a failure to assess cumulative impacts as required by Lao law (Decree 112, Part I., Article 4.6).

Attached is our formal submission to the CDM Executive Board detailing these issues. Based on these concerns, we respectfully request the CDM Executive Board and the Climate Change Office within the Lao PDR Department of the Environment to conduct an immediate review of the project and examine the reasons we have identified as a basis for a rejection of the project.

Thank you for this opportunity to provide input. Please do not hesitate to contact us with any questions you may have.


Tania Lee
Lao Program Coordinator

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