CITIZENS CONCERN FOR DAMS AND DEVELOPMENT 
IMPHAL MANIPUR NORTH EAST INDIA 795001
E-ADD: ccddne@yahoo.co.in, mangangmacha@gmail.com 
      The 4 May 2012

The Citizens Concern for Dams and Development (CCDD), Manipur, India’s  North East, after an introspection of the Project Design Document submitted for the 60 MW Pachuk II Hydroelectric Project in Kameng District of Arunachal Pradesh, would like to maintain that the project has failed to fulfill the guidelines and criteria for seeking carbon credits from CDM mechanism of the UNFCCC.  CCDD would like to outline the cause of such conclusions:  
Non Recognition of Indigenous Peoples Rights over their land and resources and right in decision making: The decision making process of the Pachuk II HEP is also carried out without the recognition of the indigenous peoples' rights over their land and resources and there is no provision and process to respect their voices and also to ensure their rightful participation in the decision making processes. The affected communities has not been consulted properly in an informed way with due provision of all necessary documents related to the proposed project. Neither a thorough and holistic impact assessment being conducted with the participation of affected communities, nor their consent taken based on the provision of the findings of such studies and consideration in their traditional decision making processes. 
The absence of Free, Prior and Informed Consent (FPIC) of affected communities in Kameng District of Arunachal Pradesh is evident in the series of protests against Hydroelectric Projects in Arunachal Pradesh. This also represents a clear violation of the UN Declaration on the Rights of Indigenous Peoples, 2007, where the Government of India endorsed its adoption at the UN. The absence of affected peoples' participation in decisions making process is also a clear violation of the recommendations of the UN Committee on the Elimination of Racial Discrimination which urged the Government of India in 2007 to take the FPIC of indigenous peoples before construction of all mega dams in India’s North East .   
Absence of a holistic Impact Assessment: The decision making process and pursuance of the Pachuk II HEP is characterized by a clear absence of a detailed impact assessment of the project on wildlife, biodiversity, culture, health, human rights impacts in both upstream and downstream of the proposed dam with the involvement of all affected communities.  With the clear cut absence of a detailed and holistic impact assessment of the proposed Pachuk II HEP and also absence of cumulative impact due to the planned construction together with other mega dams over major Rivers in Kameng District of Arunachal Pradesh, the project authorities has clearly flouted the World Commission on Dams (WCD) and its recommendations. The description from the section E of the PDD makes it clear that there has been NO public hearing or consultation has required under Indian law or under recommendations of WCD.  
The efforts to built Project along other series of dams across the rivers in Kameng District again constitute a complete disregard of the environmental impact, loss of rich and diverse flora and fauna of the region. The project will pose serious threat to rare species which are found in the area. The area is also a home to rare Himalayan Wild Plant species.  The project site of Pachuk II is located in high altitude and the biodiversity is much more vulnerable and the project will have wreaked havoc to the rich biodiversity. 
Social Impacts:  The indigenous peoples of Kameng district will be subjected to displacement, loss of their livelihood and survival sources. They will also face marginalization in their own land due to the uncontrolled migration of workers from other regions, which will have serious health, cultural and social impacts.  The economic benefits to locals as claimed by the project authority is meaningless as the actual benefits will go to the dam developers and other companies, which provides equipments, such as construction company and the turbine companies etc. Moreover, the employment to be provided to the local populations, if little, will still be of the low rung jobs, like runners and guards and there is no specific provision for incorporation of the local populace in high rung and management. Moreover, introduction of mega dams will also destroy the local sustainable economies. 
Pachuk II HEP as a non additional project:  Finance has already been available for the mega dam construction and in fact there are serious records of corruptions, bribery and scandals over Memorandum of Agreement of large hydro projects in Arunachal Pradesh and across the North East India region. The project proponent maintaining that the Pachuk II HEP cannot be completed without CDM money is completely misleading and the intention is only to seek more profits, which in fact constitute a double injustice for the local communities, first due to profiting from the social and environmental impacts envisaged by the proposed Pachuk II project and destruction of the livelihood and future of indigenous peoples but also by further claiming profits through CDM.  The Pachuk II HEP is a business as usual large hydro project and similar projects are already undertaken across India without barriers to financing.  
Misleading Baseline Scenario Projections: In Arunachal Pradesh and in other seven states of India’s North East, there is no fossil fuel based power plant but only generations from hydropower sources.  Interestingly, the  North East region power Grid, dominated by Hydropower has been clubbed with other  Northern Power Grid, Eastern Power Grid and Western Power Grid, which is dominated by Thermal based power generation, to form the NEWNE Grid  so as to facilitate arbitrary claims that the NEWNE is dominated by fossil based generation, when this is not the reality.  The NEWNE grid clustering is with dubious designs to hoodwink the CDM and to create more confusion, only to earn profits for companies. 
Negating Emissions from Pachuk II HEP:  The project proponents of the Pachuk II HEP outlined that the project is emission free stating that the project is not a fossil fuel based. Already studies has indicated that large dams in tropical situation like the proposed dam in Kameng in Arunachal Pradesh has the potential to be one of the worst emitters of Green House Gases (GHGs). Range of emissions, such as the emissions due to the destruction of forests, the emission from dam reservoir due to submergence of forests, the emissions due to boring of tunnels and the emission from sudden release of water from power houses, emissions due to numerous vehicles to be used in the construction of reservoirs and boring of tunnels, are left out deliberately by the project proponent in the PDD submitted for Pachuk II HEP.  
The Citizens Concern for Dams and Development is of the conclusions, because of the aforementioned reasons, that the Pachuk II HEP has failed to fulfill the CDM criteria to seek carbon credits and hence, the project should not be considered by CDM EB as clean and sustainable  project. 
 
(Dr. RK RANJAN)
Chairperson     

1.	Purpose of the project and how the proposed project activity reduces greenhouse gas emissions are not briefed in the PDD. Refer section A.2.
2.	How environmentally safe and sound technology is used for the project and details of technology transfer is not demonstrated adequately. Refer A.4.2
3.	Non- debundling nature of the project activity is not adequately justified as per EB54 Annex 13 (Debundling tool). Refer A.4.5.
4.	Please check the project boundary of the project activity is not based on the guidance of the applicable project category.
5.	Why has option A (Combined margin) been chosen for calculating emission factor is not justified. Refer B.6
6.	The justification of choosing IRR as financial indicator is not adequately justified. Whether it is equity or project IRR, pre-tax or post tax is not mentioned in the PDD. 
7.	The emission factor for the project electricity system can be calculated either for grid power plants only or, as an option, can include off-grid power plants.
8.	Basis of choosing PLR as benchmark is not adequately demonstrated in the PDD 
9.	All the issues of investment analysis guidelines are not discussed in the PDD. Refer B.5. 
10.	Justification of parameters including O&M, insurance, loan, derating, escalation, and tariff are not demonstrated with justification. Refer B.5.
11.	Please provide a proof for proposed debt to equity taken at the investment decision. Refer B.5 
12.	Proof for PLF is not justified. 
13.	Date of offer is not provided  
14.	Project cost is not as per state norms. Refer B.5.
15.	O&M charges and its escalation is not as per  norms 
16.	IT rate assumed is not as per standard practice. 
17.	The application of MAT which is based on tax holiday while calculating WACC is not appropriate. 
18.	The PP has not explained and justified the key assumptions and rationale.
19.	The PP and consultant has not Illustrate in a transparent manner all data used to determine the baseline emissions.
20.	Not demonstrated that the proposed project activity is additional as per options provided under attachment A to Appendix B of the simplified modalities and procedures for small-scale CDM project activities.
21.	National policies and circumstances relevant to the baseline of the proposed project activity are not being summarized clarify.
22.	Explain and justify all relevant methodological choices for the proposed project activity
23.	Data that is calculated with equations provided in the approved category or default values specified in the category should not be included in the compilation.
24.	CER revenue assumed is not consistently applied 
25.	Project cost is not as per  norms, DOE has to check and clarify.
26.	The project cost of the project should be based on offer and not on purchase order or tariff order.
27.	O&M charges considered are on higher side. Pls. clarify. 
28.	Benchmark calculation is not as per WACC tool (EB53 Annex 8)
29.	Whether pre-tax or post tax IRR is selected is not demonstrated in the PDD.
30.	The basis of calculation of benchmark is not documented in the section B.5. PLR is not acceptable benchmark for the project. WACC based on Government bonds, risk premiums should be taken.
31.	Prior consideration of CDM which is important for the determination of additionality is not documented in the section B.5 of the PDD.  
32.	Date of PPA is not mentioned in the prior consideration of CDM 
33.	The selection of simple OM based on low cost/must run resources is not adequately justified. Refer B.6.1
34.	PP has not provided for each parameter the chosen value or, where relevant, the qualitative information.
35.	Please Provide the actual value applied. Where time series of data is used, where several measurements are undertaken or where surveys have been conducted, provide detailed information.
36.	Explain and justify the choice for the source of data.
37.	Ex-ante option of calculating OM is not adequately demonstrated. Step 3 of Refer B.6.1
38.	Power plants registered as CDM project activities should be included in the sample group that is used to calculate the operating margin if the criteria for including the power source in the sample group apply. This argument is not demonstrated. B.6.1
39.	The selection of option (out of two) for calculating OM is not adequately documented with justification. CEA calculation is based on net electricity generation, the average efficiency of each power unit and the fuel types used in each power unit. Step 4 of B.6.1
40.	The argument that CEA data for build margin is calculated as per Emission factor tool is not documented.  B.6.1
41.	Spread sheet is not provided. The data should be presented in a manner that enables reproducing of the calculation of OM, BM, and CM. 
42.	The justification of negligible project emissions for wind project is not as per AMS. I. D ver 16.0 EB 54). 
43.	The emission factor value (Southern grid) for calculating baseline emission is wrong. Refer B.6.3
44.	Net electricity should be continuously monitored, hourly measured and at least monthly recorded. Refer B.7.1
45.	Metering regulations as per CEA norms is not adequately followed in monitoring plan. Refer B.7.2.
46.	 Where the values have been measured, include a description of the measurement methods and procedures that comply with the guidance provided under general guidance.
47.	Provide a detailed description of the monitoring plan, including an identification of the data to be monitored and the procedures that will be applied during monitoring.
48.	The PP should include sources of data that will be actually used for the proposed project activity (e.g. which exact national statistics, actual measurement etc. ).
49.	Where the parameters are to be measured in accordance with the guidance of the approved project category or the general guidance to the indicative methodologies, specify the measurement methods and procedures including accepted industry standards or national or international standards which will be applied, which measurement equipment is used, how the measurement is undertaken.
50.	Which calibration procedures are applied, what is the accuracy of the measurement method, who is the responsible person / entity that should undertake the measurements and what is the measurement interval?
51.	Please provide a detailed description of the monitoring plan. Describe the operational and management structure that the project operator will implement in order to monitor emission reductions.
52.	Clearly indicate the responsibilities for and institutional arrangements for data collection and archiving.
53.	The monitoring plan should reflect good monitoring practice appropriate to the type of project activity. Provide any relevant further background information.
54.	Please describe the process by which comments by local stakeholders have been invited and compiled. An invitation for comments by local stakeholders shall be made in an open and transparent manner, in a way that facilities comments to be received from local stakeholders and allows for a reasonable time for comments to be submitted.
55.	Project participants shall describe a project activity in a manner which allows the local stakeholders to understand the project activity.