Letter to the CDM Policy Dialogue Panel by Civil Society Organizations of Gujarat, India Consultations with stakeholders from India - New Delhi, India - 16 July 2012
Gujarat Forum on CDM
Letter to the CDM Policy Dialogue Panel by Civil Society Organizations of Gujarat, India
Consultations with stakeholders from India - New Delhi, India - 16 July 2012
We welcome the opportunity given by CDM Policy Dialogue Panel to share our comments/ suggestions during stakeholder consultation in New Delhi on 16th July 2012.
Gujarat Forum on CDM – is a network of Individuals/Organisations working on Environmental issue & specifically working on monitoring of CDM projects in Gujarat, India. As the organizers of the stakeholders consultation was not able to invite more participants from civil society, we organized a consultation at local level on 12th July 2012.In that meeting, we discussed the current issues of CDM process and decided to submit written presentation before the CDM Policy Dialogue Panel.
We like to provide our views on following aspects of CDM process,
Ø Violation of Environmental laws of host country
Ø Public participation in the CDM process
Ø Transparency in the process
Ø Sustainable Development
Ø Suggested Measures
Current problems of CDM
1. Lack of transparency (Only between government, companies and International bodies)
2. Cheap option for developed countries to buy carbon credits
3. No transformational effects
4. community impacts (positive or negative)
5. no monitoring at national and state government level
Violation of Environmental laws of host country
The CDM has two principal objectives – achieving cost-effective emission reductions without leakage and achieving sustainable development in the host countries. But the reality is quite different - some CDM projects have caused social and environmental harm and also violating environmental laws of host country. Inefficient monitoring leads to harm the surrounding and also have an effect on livelihood of local people.
Unlike other provisions under the CDM, the assessment of whether a CDM project contributes to sustainable development is the prerogative of the host country government and is not supervised by the CDM Executive Board.
On one hand, project pollutes the environment and on other hand it gets the carbon credits – this is the mere reality of many CDM projects in India.
Public participation in the CDM process
Involving public is important condition in the CDM process cycle, although the stakeholder consultation process has so far been only a mere formality. It is necessary to adopt effective means for stakeholder involvement during the implementation of a CDM project activity. We like to suggest few measures to strengthen public participation in the CDM process:
Ø Awareness regarding the CDM public consultation is very low. Affected people don’t know about the rights given to them and don’t understand importance of the public consultation.
Ø There is no transparency regarding public consultation
Ø Project relevant documents should be made available in the local language for the local stakeholders. Documents including interim technical reports, Environmental Impact Assessments and PDD should be made available to the local people during the consultation.
Ø Presently, the stakeholder consultation in CDM project is conducted by the Project proponent; which is conflict of interest. For neutral consultation, the DNA or its representative state body should conduct the Stakeholders meeting .It is also suggested that the local voluntary organization should also be made a party which will work to create awareness among local affected people regarding the project and stakeholder consultation.
Ø The Designated National Authority should hold capacity building mechanism such as training and workshop to create a pool of organizations who would act as an expert in holding these meeting and ensure public participations in stakeholders meetings.
Ø Public notice of public consultation should be published in at least 2 newspapers – one must be in the local language and 30 days prior to public consultation and notice should also be displayed on the website of the DNA.
Ø The video grapy of the public consultation should be made mandatory and the stakeholder consultation video should be uploaded during the validation period along with the comments received during validation. It should also be displayed on the website of DNA.
Ø Social, Economical, Environmental and Technical well being or benefits mentioned in the PDD should be mentioned in easily interpreted language, so that the local affected people can understand it. Appropriate and measurable data should be provided in the PDD in terms of employment, direct and indirect benefits and any others mentioned benefits.
Transparency in the process
Ø Pro active discloser by project proponent is needed, such as notice of public consultation, CER certification and money transaction information. Money transaction should be transparent and it should also be displayed. Information such as No. of CER generated, Buyer of the CER, money earned by selling of CER should be disclosed on annual basis on the DNA website.
Ø There should be social audit so the local affected people and concerned authority can together monitor the 2% of the money which is spent by project proponent for community welfare and they can monitor sustainable development as well as socio economic development aspects.
Sustainable Development
The CDM has two principal objectives – achieving cost-effective emission reductions without leakage and achieving sustainable development in the host countries. But the reality is different – some CDM projects have responsible to originate social and environmental damage. Important factors like improvement of local air quality, employment generation for local people, distribution of project returns, and decrease in real emission reductions – which are reflecting sustainable development have been not fulfilled.
And contributions to sustainable development are not well reflected in CER prices. Sustainable development contribution has to be counted while deciding CER price – better contribution, premium price!
The assessment of contribution by CDM project to sustainable development is in the purview of the host country – that’s why we are also demanding a CDM notification to be published by the Indian government.
Suggested Measures
Role of Host Country
1. The Indian Government should enact a Notification that necessarily specifies the procedure for implementing and monitoring a CDM project in India. The Notification should specify the manner in which the Public Consultation should be conducted.
2. The government should be aware of projects which are approved and rejected by the UNFCCC, in order to ensure the implementation of its effective monitoring.
3. The authorities should monitor the monetary transactions of the industries that have been granted CERs in order to ensure that large scale projects are obliged to spend at least 2% of its income towards community welfare. NCDMA made mandatory provision for spending 2% for large-scale projects but monitoring part is also important.
4. The State should provide for a Monitoring System after an industry is granted CER from the CDM Executive Body of the UNFCCC.
Role of UNFCCC
Ø Research is needed for every major country like India, China and Brazil after implementation of the many CDM projects. This research should be directed towards the performance of CDM projects, whether they meet the objective of sustainability, social obligations etc. The UNFCCC should take note of these findings and forward it to each stakeholder like the local Government, Project Proponent, Designated Operational Entities (DOEs), Non Government Organizations etc. for their various inputs. This leads to valuable information having been gathered of the lessons learnt to ways and means to mitigate the effects of Climate Change after 2012. (When the Kyoto Protocol expires).
Ø At an UNFCCC level, there should be strict guidelines on how the DOEs function. If more than five projects of same DOEs are rejected at UNFCCC level, these DOEs should be blacklisted.
Sincerely,
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Sr No |
Name |
Organization Name |
E-mail Id |
|
1 |
Ms. Falguni Joshi |
Gujarat Forum on CDM |
|
|
2 |
Mr. Mahesh Pandya |
Paryavaran Mitra |
|
|
3 |
Mr. Himanshu Banker |
Vikalp |
|
|
4 |
Mr. Snehal Satyapanthi |
Environment Engineer |
|
|
5 |
Mr. Vivek Seth |
Environment Engineer |
|
|
6 |
Mr. Tushar Pancholi |
Paryavarniya Vikas Kendra |
Falguni Joshi
Gujarat Forum on CDM