Project Name:

Substitution of Hydro-electric power in the National Grid

Country:

India

Description:

The project activity of replacing thermal dominated grid electricity by transmitting hydro-electric power through a dedicated transmission line is being developed as a turnkey project on behalf of the Jammu and Kashmir State Power Development Corporation (JKSPDC). The project activity entails transmission of around 450 MW of hydro power into northern regional grid and thereby replacing carbon intensive grid power.

Start Date:

15-05-08 00:00:00 (GMT)

Close Date:

13-06-08 24:00:00 (GMT)

Closed for Comment

Comments:

3

Name: Raghu

City: Aurangabad

Organisation: CDM First

Country: India

1. As per the information available in the Doda district web site (http://doda.gov.in/others/hydro.htm), the surface and sub-surface geological investigations for the project were carried out at the site during 1962-1978, in association with Geological Survey of India. The topographical surveys were also carried out by Survey of India during 1972 for the dam area and the PowerHouse area. NHPC also carried out some further investigations and started the construction of approach road to PowerHouse during late 1980s.Subsequently, this project was conceived in 1992, approved in 1996 and construction began in 1999. This indicates that the project start date is well before 2000 though the project had faced barriers for further progress. PP should explain why this project is considered to be eligible for CDM revenue considering its start date prior to year 2000?
2. It is very well known fact that the project got delayed mainly due to the objections from the pakistan on dam height and reservoir capacity but not due to the financial problems. Though the delay would have caused the rise in project cost, PP should demonstrate very clearly on how CDM revenue is going to mitigate these barriers. It is no where publicly disclosed that J&K Govt is going ahead with this project considering CDM revenue to mitigate any such barriers.
3. As everyone knows the Baglighar dam and project has been in controversy since long due to varied reasons. It is still unclear how the project meets the sustinable criterion considering many socio-economic and environmental issues linked to the development of the project. PP should clarify all the aspects related to these issues considering several issues discussed in one of the case studies submitted on the project (Pls refer http://www.american.edu/ted/ice/baglihar.htm and also http://www.merinews.com/catFull.jsp?articleID=132068).
4. It is really amusing to read some of the aspects mentioned in the section B.5 i.e additionality section especially other barriers and prevailing practice. One must appreciate the J&K Power for appointing a capable consultant to put such a silly and irrelevant things to prove the additionality. None of the aspects mentioned in the section address the genuine CDM requirements for the project. It is really surprising to see such a liberal and incompetent way of putting things for such a prestigious project. For me it appears that consultant/PP has just filled the section for the sake of filling. It is very clear that CDM revenue is not going to help to mitigate any of the barriers mentioned in the PDD. I request PP to relook in to this particular section and produce enough evidence with necessary back ups claiming the CDM revenue for the project.
5. Financial barrier should be complemented with the detailed financial analysis showing the project returns and the role CDM revenue play to overcome this particular barrier.
6. It is also learnt that J&K Govt is planning to release the white paper on delay for the project and on various issues related to the selection of the contractor for the project and also exploring options to claim back any financial loss from the contractor. DOE should look into various aspects of the proposed white paper and its relevance to the CDM applicability.
7. The project also fails to support the 'common practice' test. It is well known fact that hydro is common practice in J&K and no other power plants are appear to be feasible in the state. PP should clarify why hydro power is not a common practice in the state.
8. The present consultation process is not at all sufficient for the project scale of this. PP should conduct an open meeting inviting all the people in the region and other stakeholders inviting their comments on the project. The same need to be included in the PDD.
9. It is now up to DOE, EB and other major stakeholders whether to accept such a large scale projects with many unsustainable issues and with no sufficient evidence for the role of CDM in the project.

Name: Himanshu Thakkar

City: Delhi

Organisation: SANDRP

Country: India

Comments on the proposal to give CDM credits to
“Substitution of Hydro-electric power in the National Grid”
Or BAHLIHAR Hydropower project in Jammu & Kashmir, India

Having 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 existence, and its technical, economic and other viabilities were certified without consideration of CDM credits, long before the CDM project started. Nor can the project be defined as sustainable development, as it is going to have significant social and environmental impacts, the local people would only the losers, because they would get no benefits from the project. Under the circumstances, giving CDM credits to such projects would be wrong for everyone.

Moreover, the PDD is also giving wrong and misleading facts on a number of points, as described below.

The PDD says (section A.2, page 7), “Construction of high voltage transmission line in inaccessible and high altitude mountain terrain, approach roads, dam across the river, power plant and other units of the hydro power plant in the mountainous region is a good example of the use of highly advanced technology for construction in adverse geological conditions.” This statement is wrong and misleading and use of these structures cannot be called import or use of new technology. Such structures have been built for decades all over India, including in Jammu and Kashmir (e.g. the 480 MW Uri HEP and the 690 MW Salal HEP in J&K).

If J&K is facing such huge power shortages as described in PDD (section A.2, page 3), than why has it been decided to sell 50% of the power from the project to PTC (as stated in section A.4.3 of the PDD) to be sold outside the state? Since the home state of the project has such a huge power deficit, all the power from the project should be used in the state. Exporting the power in such a situation is inappropriate and would actually add to system losses.

The PDD states in section B.2 (page 12-13) that the Northern grid has been considered for the project, but at least 50% of the power is to go to Jammu & Kashmir, more should go considering the power deficit in the state, so it is not right to consider Northern grid for the project.

The PDD states in section B.2 (page 12-13), “the reservoir area for the project activity at full reservoir level is approximately 23 x 104 m2”. This is totally wrong and misleading. The reservoir area, as per official website (see: http://doda.gov.in/others/hydro.htm) is 12994.17 kanals, and in Kashmir, 8 kanals equals 1 acre. So the submergence area would come to 6.58 million sq meter, the figure given in the PDD is gross underestimate.

The PDD states in section B.3 (p 15-16) that the methane emission is minor in the baseline area, when there has been no measurement of methane emission from reservoirs in the baseline area. It has also assumed that the methane emission from the project activity is nil, which is not correct. The project will also lead to contribution of emission due to submergence and cutting of forests/ trees, due to use of various materials and works for the project that would contribute emission.

The PDD states in section B.4 (page 16-17) that the only alternative to the project is no project scene. This is totally wrong. J&K itself has large number of options including taking up of small hydro projects, which has huge potential and also reducing the transmission and distribution system losses.

The section B.5 of the PDD, trying to demonstrate additionality, is totally wrong and misleading. The project has been under construction for many years before the first CDM project was considered under UNFCCC and as we write this, it is about to be completed. To claim that this project would not be possible without CDM credits is completely wrong. The project work is about to be completed, all the costs have been incurred, at no stage in the project, was CDM credit discussed, the project has been given all the clearances, including the technical and economic viability clearances without the CDM credit consideration. Hence for this project to be viable, CDM credit is not required.

The section D.1 on environmental impacts is giving an incomplete and misleading picture, but since CDM board has given no important to these issues in the past, we are not elaborating here. If CDM board so required, let us know, we would be happy to give detailed comments on this and subsequent sections.

Giving CDM credits to Baglihar project under such circumstances would be wrong for the whole world, since the world will think that a lot is being done for reducing the carbon emissions, when in reality, nothing, absolutely nothing is happening in this project in that regard. Moreover, this project would also contribute its share of emissions.

Himanshu Thakkar (ht.sandrp@gmail.com) June 13, 2008
South Asia Network on Dams, Rivers & People (www.sandrp.in)

Name: Barbara Haya

City: Berkeley, CA

Organisation: International Rivers

Country: USA

Comments on the Baglihar proposed CDM project

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 the project to be identified, including the name commonly used to refer to it. The PDD should be reposted for public comment, with the name and stage of the proposed CDM project clearly included.

2) The project start date is incorrect

In the PDD the date of financial closure is given as the project start date. In the Glossary of CDM Terms (http://cdm.unfccc.int/Reference/Guidclarif/glos_CDM_v03.pdf) the start date of a CDM project activity is defined as “the earliest date at which either the implementation or construction or real action of a project activity begins.” In India it is common for hydro projects to reach financial closure well after construction has begun, and it is extremely unusual for a project that has begun construction not to reach financial closure, even if financial closure comes later than expected causing delays in project completion.

Construction of the project started in 1999 (see http://www.thehindu.com/2005/11/30/stories/2005113002651500.htm).
This is the appropriate project start date.

3) The project is non-additional

It is not believable that a project that started construction in 1999 was only built because of the CDM. There was far too much uncertainty about the CDM at the time.

It is very rare for a hydro project that has started construction to not be completed. So arguments (if they had been given) that the developers needed the CDM for financial closure are also hard to believe and would require, strong evidence. If the developers decide to make this argument minutes from a board meeting of the developers would not suffice.

4) The PDD fails to provide evidence, or even an argument, that the project would not have been built without the CDM

The PDD simply lists barriers, and makes undefended statements that registration under the CDM is necessary for the implementation of the project and helps mitigate project risks. No argument or evidence is given as to the role the CDM has actually played in enabling the project to go forward.

The draft VVM instruction DOEs to “assess and verify the reliability and creditability of all data, rationales, assumptions, justifications and documentation provided by project participants to support the demonstration of additionality. This requires the DOE to critically assess the presented evidence on the basis of local knowledge and sectoral expertise.” (paragraph 121). This means that rationales and justifications must be included in the PDD. They are not in this PDD.

It also means that goal of the DOE is not just to assess that the statements made in the PDD are true, but that they assess the believability that the project would not have been built had it not been for the CDM.

Let’s take a look at the best rationale and justification given. The entire additionality argument is contained in a sentence does not seem to describe this project: “The project proponent wishes to establish that there are barriers that would prevent the implementation of the project activity from being carried out if the project activity was not registered as a CDM activity.” This sentence does not make sense if it is being used to describe this project. The project has not been registered as a CDM activity, but it has already been implemented. It says that the project will not be completed if the project is not registered under the CDM. This is not true, since the project is almost fully completed. Certain the sentence needs to be revised to match the reality of this project. Maybe they meant to write “…had it not been for the expectation that the project will be registered under the CDM”. The fact that the main sentence justifying the additionality of the project does not tell an accurate picture of the implementation of this project, calls into question if the entire additionality section is written to reflect a true story of what actually motivated the implementation of this project.

Most sincerely,
Barbara Haya