Dear UNFCCC team,
I would like to call the attention that this project is well known among specialists of the power sector in Brazil as one of the “Botox” hydro power plants. This expression comes from the fact that those projects (including the 261 MW Dardanelos Hydro Power project) represent old projects, which have been previously conceived, but ended up being treated as brand new projects by the Brazilian regulatory framework. The story of the “Botox”projects has began even before the Brazilian Power sector reform in the 1990’s. These cases reach their final steps in the 2007 auction, already under the revised Brazilian power sector model launched in 2004, which marked the opportunity of the so-called “Botox” projects to participate close deals to sell long term Power in a specially designed auction. The so-called “Botox” power plants are analyzed in details in the study:
REGO, E. R. Usinas Hidrelétricas “Botox”: aspectos regulatórios e financeiros nos leilões de energia. 2007.
The complete study is made available online at the website of the Brazilian Energy Agency (ANEEL): http://www.aneel.gov.br/biblioteca/trabalhos/trabalhos/Dissertacao_Erik%20Eduardo.pdf
I am really surprised that consultants who are known for their deep knowledge about the Brazilian power sector as well for their expertise in the CDM (one of the involved consultants is even a member of the CDM Registration and Issuance Team) could put together a PDD for a 261 MW project which is clearly not additional. How the proposed CDM project can be regarded as additional if it was conceived before the design of the CDM flexible mechanism? More and more I am convinced that several of the CDM projects represent real cherry picking opportunity for some “creative” people.
It is also noteworthy that the whole environmental licensing process for this project faced protests and court actions from several parties. See details at the following articles:
The last article even highlights that the EIA was approved in a secret and not transparent section involving local authorities of Mato Grosso State… What a shame!
Leonor Mendes (UFMT)