12:26 23 Feb 25
Info Report Check
Submission incomplete:
1: The PP/DOE are requested to list the data and parameters used to calculate the emission reductions as per EB 48 Annex 60 paragraph 10 (a).
All parameters that were available at the time of the validation and are fixed at the ex-ante values should be listed in section B.6.2. This includes methane density and grid emission factor, if applicable.
2: The DOE is requested to include validation opinion on the accuracy and completeness of the project description in the validation report as per VVM v1.2 paragraph 64(b).
In particular, the DOE shall clarify if the mine is a new mine as indicated in the project description of the PDD or an existing mine as it can be interpreted in the validation of the baseline identification (validation report pages 19-23).
3: The DOE is requested to describe how each applicability condition of the methodology/ies is fulfilled by the project activity as per VVM v1.2 paragraph 76.
According to the validation report, the project uses "underground boreholes, gas drainage galleries or other goaf gas capture techniques..." while the gas drainage and capture do not seem to be included in the project boundary according to Fig. B.3-1 of the PDD.
4: The DOE is requested to describe how it has validated the project boundary as per VVM v1.2 paragraph 80.
Figure B.3-1 of the PDD describes the project boundary to include the gas treatment system, power generation unit(s), grid and respective emissions while the validation report states that it includes "extraction infrastructure". Please clarify what is included in the "extraction infrastructure" and if the project boundary is in line with the applied methodology.
5: The DOE is requested to describe the steps taken to assess the identification of the baseline scenario of the project activity as per VVM v1.2 paragraph 87.
In particular, the DOE shall clarify whether the identified baseline scenario is the continuation of the current situation at an existing coal mine or a hypothetical scenario at a new coal mine. In doing so, please provide information on when the mine started to be operational.
6: The DOE is requested to confirm the accuracy of the financial calculations carried out for the investment analysis as per VVM v 1.2 paragraph 114 (c).
In particular, the DOE is requested to provide information on how it has validated the inclusion of CDM consulting fees in the calculation of the project IRR (Spreadsheet "IRR Sheet.xls", Sheet "Total Costs", Cell "B16").
7: The DOE is requested to include information on how it has validated the input values to the financial calculations as per VVM v 1.2 paragraph 114 (a).
In particular:
a) CMM price: i) the applicability of the publication used (Publication No. 301, Jincheng City Pricing Bureau, 2003) in terms of the source and the methane concentration of the gas; ii) method used and values applied to adjust the price to the applicable methane concentration of the gas, providing clarification if the publication contains information on how to calculate the incremental cost to account for variable gas concentrations; iii) how the inflation has been calculated and applied; vi) if the price range (0.13-2.9 RMB/m3) for the 6 projects compared to includes gas treatment costs;
b) investment cost: components included in the total investment, particularly in the capital expenditure, providing details of the "ancillary equipment"; and
c) auxiliary power consumption of 10%, which, according to the validation report, is not subtracted from the total power generation for the financial analysis but is subtracted in the IRR calculation spreadsheet.
8: The DOE is requested to provide local and sectoral expertise on the suitability of the input values to the investment analysis as per VVM v 1.2 paragraph 113 (c).
In particular, the DOE shall provide further information on how it has considered the similarities with the "similar registered projects" used for the comparison of the input parameters in terms of the technologies employed.
9: The DOE is requested to provide information on how it has assessed the existence of the similar projects for common practice analysis as per VVM v 1.2 paragraph 121 (b).
In particular, the DOE shall explain how it has considered the source to be comprehensive, i.e. considers all coal mines in the province that utilizes CMM for power generation. In doing so, please provide a list of project found in the source indicated.
10: The DOE is requested to describe the steps undertaken to assess if the monitoring arrangements are feasible to be implemented within the project design as per VVM v1.2 paragraph 124(b).
In particular, the DOE shall clarify if parameters GEN_PJ to grid,y and GEN_PJ to Wujia, y are monitored during the implementation as these are listed as monitored parameters in the validation report but not in the PDD.
1: The PP/DOE are requested to list the data and parameters used to calculate the emission reductions as per EB 48 Annex 60 paragraph 10 (a).
All parameters that were available at the time of the validation and are fixed at the ex-ante values should be listed in section B.6.2. This includes methane density and grid emission factor, if applicable.
2: The DOE is requested to include validation opinion on the accuracy and completeness of the project description in the validation report as per VVM v1.2 paragraph 64(b).
In particular, the DOE shall clarify if the mine is a new mine as indicated in the project description of the PDD or an existing mine as it can be interpreted in the validation of the baseline identification (validation report pages 19-23).
3: The DOE is requested to describe how each applicability condition of the methodology/ies is fulfilled by the project activity as per VVM v1.2 paragraph 76.
According to the validation report, the project uses "underground boreholes, gas drainage galleries or other goaf gas capture techniques..." while the gas drainage and capture do not seem to be included in the project boundary according to Fig. B.3-1 of the PDD.
4: The DOE is requested to describe how it has validated the project boundary as per VVM v1.2 paragraph 80.
Figure B.3-1 of the PDD describes the project boundary to include the gas treatment system, power generation unit(s), grid and respective emissions while the validation report states that it includes "extraction infrastructure". Please clarify what is included in the "extraction infrastructure" and if the project boundary is in line with the applied methodology.
5: The DOE is requested to describe the steps taken to assess the identification of the baseline scenario of the project activity as per VVM v1.2 paragraph 87.
In particular, the DOE shall clarify whether the identified baseline scenario is the continuation of the current situation at an existing coal mine or a hypothetical scenario at a new coal mine. In doing so, please provide information on when the mine started to be operational.
6: The DOE is requested to confirm the accuracy of the financial calculations carried out for the investment analysis as per VVM v 1.2 paragraph 114 (c).
In particular, the DOE is requested to provide information on how it has validated the inclusion of CDM consulting fees in the calculation of the project IRR (Spreadsheet "IRR Sheet.xls", Sheet "Total Costs", Cell "B16").
7: The DOE is requested to include information on how it has validated the input values to the financial calculations as per VVM v 1.2 paragraph 114 (a).
In particular:
a) CMM price: i) the applicability of the publication used (Publication No. 301, Jincheng City Pricing Bureau, 2003) in terms of the source and the methane concentration of the gas; ii) method used and values applied to adjust the price to the applicable methane concentration of the gas, providing clarification if the publication contains information on how to calculate the incremental cost to account for variable gas concentrations; iii) how the inflation has been calculated and applied; vi) if the price range (0.13-2.9 RMB/m3) for the 6 projects compared to includes gas treatment costs;
b) investment cost: components included in the total investment, particularly in the capital expenditure, providing details of the "ancillary equipment"; and
c) auxiliary power consumption of 10%, which, according to the validation report, is not subtracted from the total power generation for the financial analysis but is subtracted in the IRR calculation spreadsheet.
8: The DOE is requested to provide local and sectoral expertise on the suitability of the input values to the investment analysis as per VVM v 1.2 paragraph 113 (c).
In particular, the DOE shall provide further information on how it has considered the similarities with the "similar registered projects" used for the comparison of the input parameters in terms of the technologies employed.
9: The DOE is requested to provide information on how it has assessed the existence of the similar projects for common practice analysis as per VVM v 1.2 paragraph 121 (b).
In particular, the DOE shall explain how it has considered the source to be comprehensive, i.e. considers all coal mines in the province that utilizes CMM for power generation. In doing so, please provide a list of project found in the source indicated.
10: The DOE is requested to describe the steps undertaken to assess if the monitoring arrangements are feasible to be implemented within the project design as per VVM v1.2 paragraph 124(b).
In particular, the DOE shall clarify if parameters GEN_PJ to grid,y and GEN_PJ to Wujia, y are monitored during the implementation as these are listed as monitored parameters in the validation report but not in the PDD.
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