I am astonished to see that this long time ago planned expansion of the Brazilian interconnected grid to isolated systems is being proposed as a CDM project! First of all, as pointed about in the PDD,  the whole implementation, operation and maintenance of the related transmission lines are being promoted under the terms and conditions of earlier signed public concession service contracts. Have CDM benefits been considered at the time the terms and conditions for these  concession contracts were elaborated? Have CDM benefits been considered at the time these concession contracts were signed? Were all the bidders considering to only implement and operate the transmission lines if CDM income could be granted? 

I believe that as per the concession contract, once it was signed, the project developers would have to implement the transmission lines anyway (regardless of the registration of the initiative as a CDM project). Thus, how can it be claimed that without CDM the "project" is considered as too risky? 

Secondly, even if carbon credits were fairly eligible for this venture, the Federal Government of Brazil should be the owner of the carbon credits (otherwise stipulated in the concession contracts). Transmission lines are part of the power system of Brazil. In my opinion, as in the case of the hydraulic energy potentials, transmission lines under concession contracts should be regarded as a public goods (by considering the current regulatory framework of the Brazilian power sector). Thus, in the worse case (carbon credits being issued for this long time ago planned venture), the people from Brazil (represented through the Federal Government) are the ones to have the ownership for these carbon credits. I believe that prior to provide a Letter of Approval to this project, the DNA of Brazil should check the issue with the Federal public attorney of Brazil.       

Helio Villas Boas