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Projects under consideration that should NOT qualify for registration or issuance of CERs (Newsletter #2)

It has been reported to CDM Watch that there will be couple of projects on the table that do not reduce emissions relative to alternate scenarios and in some cases even relative to the status quo. Moreover, these projects under question would not even contribute to sustainable development. Instead they reduce employment and create environmental health hazards and as a consequence, they should not receive CDM credits.

The projects under question are 3 waste energy projects, two projects, located in China of which are currently under review of registration, and one project – the largest landfill gas project in Brazil – is already registered and awaiting the review of its request of issuance of CERs. Main concerns of these three projects can be summarized as follows:

  • Better alternatives to waste disposal (landfills and incinerators) exist yet are not included in alternate scenarios of the projects. Alternatives increased rates of recycling, municipal composting as well as waste reduction and avoidance programs. These non-disposal technologies have been proven effective and feasible in many parts of the world. They are universally acknowledged to be far superior for the climate. Yet they are not given consideration, and, to the extent that they already exist, may be in competition with the proposed project.
  • Landfills and incinerators compete with wastepickers for waste materials. In many locations around the world, wastepickers have lost access to the waste stream because it has been “privatized” by a waste-to-energy project, including many supported by the CDM. While wastepickers contribute to significant mitigation through increased recycling rates, waste-to-energy increases emissions by reducing recycling rates.
  • The loss of access to the waste stream also translates into a loss of livelihoods for some of the poorest individuals in the community.
  • Both landfills and waste incinerators are serious environmental health hazards. Even with the best of modern technology, they release significant quantities of highly toxic pollutants to the air, land and water. The sites are serious health hazards for decades, if not centuries, to come.
  1. Dalian Maoyingzi Landfill Gas Recovery for Power Generation Project, China

According to the project design document (PDD), the Maoyingzi landfill is the main municipal solid-waste (MSW) disposal place of Dalian city in Northeast China. It was designed to occupy an area of 1.03 km2 with total waste disposal capability of 12.6 million metric tons. It was initial constructed in 1988 and became operational in 1989 with accumulated 8.3 million tons MSW by the end of 2007 with capacity of receiving an average of 2300 tons household waste per day. The project has requested registration in April 2009 but a review of the project due to missing data was requested. The missing data concern the clarification if land fill gas was flared for safety purposes in the baseline and why the equation provided in the methodology was not applied to determine the amount of methane used for power generation…dubious. Credit Buyers: The Netherlands (International Finance Corporation)

  1. 2.   Controlled combustion of municipal solid waste (MSW) and energy generation in Linyi City, Shandong, China

The project activity involves the controlled combustion of municipal solid waste (MSW) to generate electricity and heat in Linyi City, Shandong Province, China. Total emission reductions over the 7-year crediting period are expected to be in the region of 580,000 tCO2e. Further to the request for registration the DOE has received a whole lot of homework since a large amount of data was missing. The clarification addresses inter alia how similar projects have been identified, in particular, what parameters have been considered and essential distinction between the proposed CDM project activity and other similar activities as well as the source of data used in identifying similar projects… doubtful.  Credit Buyers: Portugal (Luso Carbon Fund)


  1. 3.   São João Landfill Gas to Energy Project (SJ), Brazil

This landfill project is located in the metropolitan region of São Paulo, Brazil’s biggest city and financial center of the country and is situated in Aterro Sanitário “Sítio São João” – São João landfill, which is in fact one of the biggest landfills in Brazil. With an estimated population of around 10 million citizens in 2000, São Paulo generates nearly 15.000 tons of waste daily. The project was registered in July 2006 and has so far generated 817 ktCO2e/yr. It has requested the issuance of further credits but is awaiting the approval of the Board since a review of issuance was requested. The review addresses the clarification on how the DOE has verified that the project was implemented and operated in accordance with the descriptions in the registered PDD, since the site has an installed capacity of 25.6 MW instead of 20 MW as stated in the PDD and validation report…questionable. Credit Buyers: Germany (KfW), Switzerland (Mercuria Energy Trading)

Action to be taken by the Board: The Board should refuse the request for registration of Dalian Maoyingzi Landfill Gas Recovery (Project 2523), the Linyi City MSW project (Project 2419 ) as well as refuse the request for issuance of the São João Landfill Gas to Energy Project (SJ), Brazil (Project 0373 ).


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