Info Report Check
Submission incomplete:
1: The DOE is requested to provide information on the steps taken to validate the actions taken to secure the CDM status between the project starting date and the start of validation as per EB 49 Annex 22 paragraph 8 b.
The DOE should provide a validation opinion on how the "GUIDELINES ON THE DEMONSTRATION AND ASSESSMENT OF PRIOR CONSIDERATION OF THE CDM" (EB 49, Annex 22) available on 11 September 2009 para. 2 "The Board decided that for project activities with a starting date on or after 02 August 2008, the project participant must inform a Host Party DNA and the UNFCCC secretariat in writing of the commencement of the project activity and of their intention to seek CDM status" have been complied with.

2: The DOE is requested to provide information on how it has validated the suitability of the benchmark as per VVM v 1.2 paragraph 114 (b).
1. The DOE should provide the information on the calculation of the benchmark, considering that page 20 of the VR refers to a file called "WACC UHE FG v2.xls", which was not submitted in line with the requirements of paragraph 8 of the of the "GUIDELINES ON THE ASSESSMENT OF INVESTMENT ANALYSIS". In addition, it was noted that Beta was validated based on data sourced from Aswath Damodaran corresponding to power industry companies in Brazil, however, the link provided contains information from other countries such as U.S., Australia, Japan, etc, except from Brazil. The DOE should also confirm whether the Beta calculation applies the formula shown on page 19 of the VR and clearly report the value of the tax used in the calculation.

3: 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 should clearly indicate the source of evidence used to confirm the analysis conducted by the PP, including a validation opinion on how the "Tool for the demonstration and assessment of additionality" (Version 06.0.0) paragraph 47 step 3 and 4 have been complied with. In addressing this issue, the DOE should describe how it has validated " those that apply technologies different to the technology applied in the proposed project activity were identified" (VR, page 28).