Info Report Check
Submission incomplete:
The DOE is requested to provide information on how it has assessed the credibility of the barrier analysis as per VVM v 1.2 paragraph 118.
The DOE is requested to further substantiate how it validated that the identified barriers prevent the implementation of the land use alternative (project alternative) 4 - Plantation forestry activities without the CDM incentive, considering that;
a) It is not clear how investment barriers such as lack of debt funding, high interest rates and credit constraints in Uganda are faced by the PP which is a subsidiary of the UK based New Forests Company Holdings Limited or other similar investors. Please refer to the Guidelines for objective demonstration and assessment of barriers’, EB 50, Annex 13, guideline 1 and VVM v. 1.2, paragraph 115.
b) Investment barrier further includes that similar activities have only been implemented with grants like the Sawlog Production Grant Scheme, however, the grant received by the PP covers 1,500 hectares only and the total plantation of the PP is over 4,000 hectares. Thus the grant may be used towards the planted areas not currently under the proposed CDM project (Validation report, page 31).
c) Technological barriers such as lack of access to high quality seeds and infrastructure for implementation have been mitigated by the PP by means of additional investments (stated in PDD, page 53). Please refer to VVM v.1.2, paragraph 116.
d) It is not clear how institutional barriers such as illegal use of the reserve and the inability of the Ugandan National Forest Authority to manage the reserve and curb illegal use, prevent the implementation of the project by the PP or similar investors, without CDM revenue.