Putting Public Participation into Practice

The UNFCCC administers the CDM under the Kyoto Protocol. (UNFCCC)

Having helped local communities submit comments against large destructive dam projects applying for carbon credits through the Clean Development Mechanism (CDM), I've gained a certain amount of insight into the CDM's official public participation process. The moral of that story is: official processes look all right on paper but in practice, they do a poor job of promoting transparency and public input.

Here's what happens on our end when a dam goes up for public comment in the CDM:

1. The project developer submits a project design document (PDD) to a validator, which gets posted on the UNFCCC's CDM website. The public is given 30 days to comment on this project.
2. International Rivers does a weekly check on what new hydropower projects have been submitted for public comment, registered, or are being reviewed. This list is sent to a number of our regional partners and campaigners.
3. International Rivers and its partners coordinate over how to submit comments. This may involve translating documents, getting info on the environmental and social impacts of projects (which is seldom expressed or elucidated in the PDDs), and alerting other concerned civil society groups to submit comments as well.
4. We and/or our partners post these comments on the UNFCCC website (which is not at all an intuitive process).

Here's the problem: by the time we get to step two, a project's public comment period deadline may already be only a couple weeks away, which gives us little time to go through steps three and four. On top of that, besides the PDDs, no environmental impacts assessments or other financial analyses are available on the UNFCCC website. This process also assumes that affected communities have access to the internet and can receive RSS feeds...which is a huge assumption.

International Rivers and partners recently submitted comments on Kamchay Dam, Cambodia, which would flood the Kamchay River valley in Bokor National Park.

Luckily, the CDM Executive Board recently decided to review the possibility of providing additional opportunities for public input, through a public appeals process. Our partners at CDM Watch have published a commentary in Point Carbon (May 12, sub req'd), a key carbon industry journal. Here are some of CDM Watch's recommendations:

• Longer comment periods should be designated for larger projects.
• All supporting documents should be uploaded prior to the start of the public comment period.  
• The PDD should be translated into the language(s) of the host country because it is not possible for project area residents to participate meaningfully in a public process if it is conducted in a language they do not understand, or if the key documents are inaccessible.

We hope that the CDM Executive Board will take these recommendations to heart at their next board meeting. It's not much to ask when you taken the realities on the ground seriously, and when you're serious about putting public participation and transparency into practice.