CDM Comments

Comments on the Baglihar Hydropower Project (India)

Baglihar Dam
International Rivers Comments on the Baglihar Proposed CDM ProjectBaglihar Dam Shiva Nagri 1) The name of the project is never given in the PDD so that the identification of the project is unclear. The PDD should be reposted for public comment after information clearly identifying the project is included.In the PDD only the location of the project is given, the name is not given. Also, the project has two stages, and both are 450 MW. It is not clear from the PDD which stage is being proposed as the CDM project. Developers should be required to give information that is commonly expected for th

SANDRP Comments on the Baglihar Hydropower Project in Jammu and Kashmir, India

Friday, June 13, 2008
Comments on the proposal to give CDM credits to "Substitution of Hydro-electric power in the National Grid" Or BAGLIHAR Hydropower project in Jammu & Kashmir, IndiaHaving read the Project Design Document (PDD) and having been familiar with this project over the last few years, my comments on the proposal to CDM credits to this project are as follows. Broadly, this project is not using any new or imported technology that is not already being used in the project area. This project is also not additional, as the project implementation has started many years before the CDM projects came into e

Comments to TÜV SÜD on Baba Multipurpose Hydroelectric Project (Ecuador)

Wednesday, October 15, 2008
Comments on the proposed CDM project: Baba Multipurpose Hydroelectric Project (MBHP) International Rivers submission to the project validator TÜV SÜD September 15, 2008 (resubmitted October 15) Summary of Comments MBHP should not be positively validated for the following reasons: It is most likely non-additional. The draft CDM Validation and Verification Manual (VVM) guidelines by the CDM Executive Board lead to a negative assessment of the additionality of this project.Previous violence and intimidation against members of communities affected by the project does not allow for open stakehol

ACD Comments on Changuinola 1 (Chan 75) Large Hydro Project (Panama)

Fuente: Comision de Politica Energetica, MEF, Panama
Comments on Chan 75 by the Alliance for Conservation and Development (ACD) and the Center for Biological DiversityCarbon Management Service TUV-SUD Group Germany Dear members of the Certification Body: We want to express our highest regards for the members of the certification body and the work do. Respectfully, we recommend that the certification body rejects the request for Certified Emission Reduction (CER) that was presented by AES Corporation for the Changuinola I (Chan 75) hydroelectric project in the Republic of Panama. This project has already caused very severe social and environmenta

Conservation Strategy Fund Comments on Changuinola 1 (Chan 75) Large Hydro Project (Panama)

Friday, August 8, 2008
Comments on Changuinola 1 (Chan 75) Large Hydro Project (Panama)Submitted to Manja Welzel, TÜV SÜD Industrie Service GmbH, by John Reid, President of Conservation Strategy Fund To Whom It May Concern: The purpose of this letter is to comment on the Clean Development Mechanism Project Design Document submitted June 11, 2008, by AES-Changuinola S.A. for the Changuinol I hydroelectric project (also known as Chan 75). The project appears to be financially viable without income from carbon credits, and would therefore result in an overall increase in regulated emissions from parties to the Kyoto

FIAN Comments Re the Project Design Document for Baba Hydroelectric Project (Ecuador)

Wednesday, September 10, 2008
Comments regarding the Project design document (PDD) CDM (MDL, for its Spanish acronym) for the Multipurpose Baba Hydroelectric Project (MBHP) located in the province of Los Ríos, EcuadorA.2. Description of the project activity The PDD states that the project activity aims to increase power generation in Marcel Laniado de Wind plant (MLW) by means of a new 42MW hydroelectric generation unit called "Central Baba."According to the Description of the Project, developed by Efficacitas in its Environmental Impact Study, the project comprises a reservoir and a water transfer towards the Daule-Perip

AIDA et al. Comments to TÜV SÜD Re CDM Validation of Baba Hydroelectric Project (Ecuador)

Friday, September 5, 2008
Comments to TÜV SÜD Re CDM Validation of Multipurpose Baba Hydroelectric Project (MBHP) in EcuadorTO: TUV SUD Industrie Service GmbH RE: CDM Validation of Multipurpose Baba Hydroelectric Project FROM: Interamerican Association for Environmental Defense (AIDA)Earthjustice International ProgramOrganization for Environmental Law & Management (ECOLEX) DATE: September 5, 2008 AIDA, Earthjustice and ECOLEX submit these comments on the Multipurpose Baba Hydroelectric Project in Ecuador (the "MBHP" or the "Project") pursuant to paragraph 40(c) of the modalities and procedures for the clean devel

The Corner House Comments on Changuinola 1 (Chan 75) Large Hydro Project (Panama)

Thursday, August 7, 2008
Comments by Larry Lohmann, The Corner House, on Changuinola 1 Hydropower Project in PanamaCLEAN DEVELOPMENTMECHANISM Changuinola 1 Hydroelectric Project in PanamaPROJECT DESIGN DOCUMENT Version 03.1 CommentsLarry LohmannThe Corner House OVERALL SUMMARY COMMENT 1. The evidence and arguments presented cannot establish the project as additional. The project cannot be argued to have passed any of Steps 0, 1, 3 or 4.2. The project cannot fulfil, and would indeed detract from, the sustainable development objectives of the CDM.3. In addition to the ecological threats the project poses, its notoriety

NRDC Letter to TÜV SÜD on Changuinola 1 (Chan 75) Large Hydro Project (Panama)

Friday, August 8, 2008
Comments on Changuinola I Hydroelectric Project (Panama)Ms. Manja Welzel TÜV SÜD Industrie Service GmbHCarbon Management ServiceFax ++49 89 5791-2756 Dear Ms. Welzel: Comments on Changuinola I Hydroelectric Project (Panama) I am writing, on behalf of the Natural Resources Defense Council ("NRDC"), to express our strong opposition to the application by AES Changuinola ("AES") for certified emission reduction credits ("CER") from the Clean Development Mechanism ("CDM") for its Changuinola I Hydroelectric project ("Chan 75") in Bocas del Toro, Panama. NRDC is a non-governmental environmental o

CIEL Comments on Changuinola 1 (Chan 75) Large Hydro Project (Panama)

Friday, August 8, 2008
COMMENTS SUBMITTED BY THE CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW REGARDING THE CHAN 75 DAM PROJECT IN PANAMASummary CIEL hereby presents comments on the Project Design Document of the Chan 75 project, in light of relevant criteria developed by the Clean Development Mechanism, in accordance with paragraph 40 of the CDM modalities and procedures as defined in Article 12 of the Kyoto Protocol.1 In short, CIEL finds that the project: (1) lacks additionality; (2) fails to adequately consult affected communities and obtain their free and prior informed consent; and (3) does not contribute to sus


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