CDM Comments

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

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, inc

CDM Executive Board UNFCCC Secretariat Martin Luther King Strasse 8 P.O. Box 260124 D-53153 Germany Subject: Request for the CDM Executive Board to review the Project 8761: Stung Tatay Hydroelectric Project (Cambodia)Dear Mr. Duan and the CDM Executive Board, We are writing to express our serious concern about the proposed CDM Project 8761: Stung Tatay Hydroelectric Project in Cambodia. Registration has been requested following a validation report by Bureau Veritas Certification Holding SAS (Report No. BVC/CHINA-VAL/6203/2011), which recommends approval. As a decision is expected to be made

The PDD for the Panan Hydropower Project lacks accuracy and provides insufficient and non-rigorous information on a number of environmental issues; fails to mention the local opposition by the indigenous Lepcha tribal community; and omits a range of possible negative impacts on freshwater biodiversity and local terrestrial biodiversity, as well as a mitigation plan for seismic risks. In addition, the local stakeholder consultation process failed to include all families that would be directly or indirectly impacted by the project, and the project is common practice and likely non-additional.

Comments on the Jirau Hydropower Project Submitted to Lloyd’s Register Quality Assurance Ltd. We are writing to express our concerns over the application for validation of the Jirau Hydropower Project in Brazil. The Project Design Document (PDD) for this project is flawed and inaccurate. In addition, CDM validation of this project would reward not only a clearly non-additional project, but also one of the most socially and environmentally destructive dams in the Amazon Basin. Summary of Key Concerns The project does not comply with the EU-ETS and EC regulation on the 3rd trading phase. G

Comments on the Jirau Hydropower Project: Transboundary Impacts Submitted to Lloyd’s Register Quality Assurance Ltd.I am writing to express my concerns over the application for validation of the Jirau Hydropower Project in Brazil. The Project Design Document (PDD) for this project is deeply flawed and inaccurate. This is particularly true in relation with transboundary environmental impacts, as is described below. Summary of Key Concerns The project will have serious transboundary environmental and social impacts in Bolivia and Peru. Both independent technical studies and IBAMA (Instituto B

THE JIRAU DAM'S CDM PROPOSAL: COMMENTS ON THE PROJECT DESIGN DOCUMENTUpdated version: June 1, 2012 Philip M. Fearnside National Institute for Research in Amazonia (INPA) Manaus, Amazonas, Brazil pmfearn@inpa.gov.br THE JIRAU DAM Two dams, Santo Antônio and Jirau, are nearing completion on the Madeira River, a major Amazon tributary that drains parts of Brazil, Bolivia and Peru. Both dams have applications pending for carbon credit under the Kyoto Protocol’s Clean Development Mechanism (CDM). The Jirau Dam, located in Brazil’s state of Rondônia near the border with Bolivia, is being built

Comments on the Santo Antônio Hydropower Project Submitted to the Perry Johnson Registrars Carbon Emissions ServicesWe are writing to express our concerns over the application for validation of the Santo Antônio Hydropower Project in Brazil. The Project Design Document (PDD) for this project is deeply flawed and inaccurate. In addition, CDM validation of this project would reward not only a clearly non-additional project, but also one of the most socially and environmentally destructive dams in the Amazon Basin. Summary of Key ConcernsThe project clearly does not meet criteria for addition

Comments on the Project Design Document for the Santo Antônio Dam's CDM Proposal Updated version: June 2, 2012 Philip M. Fearnside National Institute for Research in Amazonia (INPA) Manaus, Amazonas, Brazil pmfearn@inpa.gov.br THE SANTO ANTÔNIO DAM Granting the Santo Antônio Dam Certified Emissions Reductions (CERs) under Clean Development Mechanism (CDM) would allow purchasers of these certificates to release 51 million tons of CO2-equivalent (CO2e) into the atmosphere elsewhere in the world. As will be explained here, none of the supposed reduction in CO2e from the dam project is real,

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