Solicitation to reject CDM Project BAESA (HPP Barra Grande)

The Brazilian Forum of NGOs and Social Movements for the Environment and the Development (FBOMS) request the complete rejection of the BAESA CDM Project as a Clean Development Mechanism (CDM) project for reasons of violating its basic underlying principles, notably the sustainability criteria and the additionality criteria. 

Background
The BAESA CDM Project, now currently under validation as of 20th of September 2008, is the CDM branch of the Hydro Power Plant (HPP) Barra Grande already in operation in the Rio Pelotas between the states of Santa Catarina and Rio Grande do Sul in Brazil. Energética Barra Grande S/A (BAESA), a joint venture between Alcoa Alumínio S/A, CPFL, CBA, Camargo Corrêa Cimentos and DME Energética Ltda., has 708 MW of electricity generating capacity, enough to provide 30% of current electricity demand of the State of Santa Catarina.

Environmental Impacts
FBOMS does not believe that a Project of a big HPP should be considered a tool for sustainable development. The project of this HPP was elaborated in 1979, and reached the Core Zone of the Biosphere Reserve of the Atlantic Rainforest, UNESCO Heritage site, eliminating all continuous and exuberant formations of Araucaria Forest in the South of Brazil, between the States of Santa Catarina and Rio Grande do Sul.

During the construction phase of the reservoir of the HPP Barra Grande serious environmental impacts have been observed . A region of excepcional scenic beauty (Municipal Park Estreito dos Encanados, Vacaria) was flooded. In the total extension, the reservoir of the HPP already flooded 8.138 hectares , 90% of which covered by primary forests, forests in various stages of recovery and natural fields, consisting in one of the most biologically diverse fragments of Brazilian Araucaria moist forests in the State of Santa Catarina. 

In more than 2.000 hectares, researchers found one of the last remaining non-disturbed areas of araucaria angustilofa (Brazilian Araucaria or Paraná Pine), a critically endangered tree, according to the IUCN red list, protected by a Resolution of the National Council for the Environment (no. 278 of 2001). Researchers also found the remnants of three populations of an endemic specie of bromeliad named dyckia distachia which has been driven to extinction by the HPP Barra Grande. Furthermore, it is important to highlight that both of these impacts, as well as the type and extension of forest types that existed in the inundated region, were omitted in the studies submitted by the proponent of the project under the official process of environmental impact assessment. This omission, which harmed the public hearing process, is considered one of the biggest frauds in issuance of an environmental license, and made the Brazilian Institute for he Environment and Natural Resources (IBAMA) set up an internal processes in order to discover the culprits behind it.  Likewise, BAESA signed an accord with various public institutions, including the Public Ministry and the Ministry of the Environment, accepting not only its responsibilities in face of the errors, but also a series of correcting steps. Nonetheless, legally, this, as well as other steps in the development of the HPP Barra Grande, have been contested in various civil actions  which defend the invalidity of the license due to the errors committed. 

The involvement of the affected local population during the process of the HPP Barra Grande was restricted to the negotiations on compensations and the search of measures to mitigate social and environmental impacts. Many of the actions in favor of the forest were organized by environmental organizations of the region, and Movement of the Dam-Affected (MAB), which struggled to guarantee the rights of land owners who would be expelled from their lands. The flood provoked by the dam reached 1.600 families, according to MAB, a strong social movement in Brazil. Until today, countless social problems are not still resolved and a lot of families wait for their resettlement. Based on the action, the scandal was made public through the media.   
  
Additionality
We would also like to question the additionality presented in the Project Design Document (PDD). Firstly, hydroelectricity is a common practice in Brazil, with decades of experience and planning having resulted in the heavy presence of hydro sources for electricity generation. According to data from the National Agency for Electric Energy (Aneel), the national electricity regulator of the country, more than 70% of electricity generating capacity comes from hydro sources, even if we exclude the potential found in Itaipu Binacional. Given the amount of experience the hydroelectricity sector has acquired over the years which translates into reduced costs both in capital and labor, it is difficult to fathom a project of this scale which would require carbon credits to be financially viable.

Secondly, it must be highlighted that the Preliminary License of the HPP Barra Grande was originally issued in the year 1999 and the Installation License in 2001. The PDD gives the year 2001 as the date in which carbon considerations were first included in the decision making process of the company. Given the lack of knowledge concerning the future of the Kyoto Protocol and its flexibility mechanisms, making such an important investment decision dependent on carbon credits for the project to be financially viable seems fraught with an amount of risk which would not be accepted by a sensible company board. 

We highlight, still, that the conception that HPP supply clean energy is wrong. In fact, in the case of Barra Grande, a big amount of wood was not removed in spite of the authorization for vegetation removal by IBAMA. Thus, great part of biomass was kept below water level in a large part of the 116 km of the steep valley, with an altitude difference of 180 m, of Rio Pelotas, which contributed a lot for the emission of greenhouse gases, mainly methane.  
  
Considering these elements, we conclude that the approval of this project, and its future seal as “Clean Development Mechanism”, besides motivating the installation of big hydroelectric power plants as desirable technology for energy generation without previous public discussion, puts at risk the implementation of effective programs for the promotion of alternative sources of energy, harms the local and global environment, and does not contribute to sustainable development.  

Conclusion
Therefore, FBOMS, by the reasons above presented, concerning problems with the sustainability and additionality criteria of the project, requests the complete rejection of the BAESA CDM Project as a CDM project.

Yours Sincerely


 

Ivan Marcelo Neves
Executive Secretary

We apologize that we sent the same comment 3 times, please consider the document atteched in word, which included photos and our complete address:
Brazilian Forum of NGOs and Social Movements for the Environment and the Development - Forum Brasileiro de ONGs e Movimentos Sociais para o Meio Ambiente e o Desenvolvimento (FBOMS)
SCS, Quadra 8, Venâncio 2000, Bloco B-50, Sala 105
CEP 70333-900, Brasília (DF)- BRAZIL
Fone/Fax: ++51 61 3033.5535
www.fboms.org.br
coordenafboms@fboms.org.br

Please note that we are cited as interested parties in receving CDM proposals for Brazil through the Resolution 001/2003 of the Brazilian Interministerial Comission on Global Climate Change (CIMGC) - tha National Designated Authority.