Additionality Issues – CDM Watch is writing to express our serious concerns about the additionality claims of 4555: Shaanxi Wenjing 48MW Hydropower Project. The project is requesting the issuance of 197,531 tCO2e for the period from 18 April 2011 to 19 April 2012 of the registered CDM project activity. We are urging the CDM Executive Board to request a review. The period to request a review is set to end on 1 November 2012.
According to the registered PDD (p. 12), the additionality of the project is based on the project not being financially viable without CDM revenues, since the project IRR (6.23%) is lower than the benchmark (8%). The additionality of the project in the PDD is mainly built on the assumption that an irrigation dam of 228 meters height (Dongzhuan reservoir) will be completed by 2015, reducing the available water flow to the project and hence the electricity production after 2015.