00:22 18 May 25
Info Report Check
Submission incomplete:
1: The PP/ DOE are requested to describe in the PDD how the local stakeholder consultation was conducted as per PS version 09.0 paragraphs 74-80.
The PDD (p 33) provides the invitation to the local stakeholder was done as per "Resolution No. 7 of the Brazilian DNA" and its relevant link. However, 1) the link provided as the footnote 19 is not accessible and 2) the PDD does not provide the date for local stakeholder consultation while para 78 of PS version 9 states that Project participants shall complete the local stakeholder consultation process before the start date of the project activity.
2: The DOE is requested to report the receipt of letter of approvals/ authorization as per VVS version 09.0 paragraphs 47, 48 and 49 (a) (b).
The DOE (p 5) states that "The validation report was updated (Revision 1.4) to reflect the receipt of the letter of approval and that is the only change that has been made compared to the version (Revision 1.3Aa, dated 05/01/2017) listed in the Brazilian DNA letter of approval dated 05/05/2017." However, the LoA submitted in the request for issuance is issued on 15 May 2017.
3: The DOE is requested to describe how it has validated the actions taken to secure the CDM status as per VVS version 09.0 paragraphs 116 (b), 117 and 118.
The validation report (p 10) states that "The notification of prior consideration dated 18/11/2016 was sent to UNFCCC /26/ and Brazilian DNA on 24/11/2015 /38/". The DOE requests to clarify the date sent to UNFCCC as there are more than one year gap between two dates.
4: The DOE is requested to describe how it has validated the suitability of the benchmark as per VVS version 09.0 paragraphs 130 and 132 (b).
The DOE validates that PP used the value from the Table 1 inside the Appendix of the Tool, for Host Country Brazil Group 1 (which includes Energy Industries) the reference value for the Cost of Equity (Benchmark) is 12.32. However, the validation report (p 13) states that "the proposed project activity in absence of the CDM benefits and compared to the benchmark 10.65% is not financially attractive." Therefore,the DOE is required to rectify this inconsistency in the benchmarks referred in the validation report.
5: The DOE is requested to describe how it has assessed the adequacy of the local stakeholder consultation and how comments have taken in due account as per VVS version 09.0 paragraphs 162-165 and 166.
The DOE (p 22) states that "As per the Brazilian DNA Resolution nš 7 /33/, the local stakeholder consultation must start 15 days prior the PDD publication for the Global Stakeholder Consultation. PP has followed the requirements of the Brazilian DNA" and "letters inviting to comment on the project dated 29/04/2016". Further it (p 6) states that "The start date of the project activity is 23/09/2015, which was the signature of the Power Purchase Agreement." The DOE is required to provide further information on how it validated the local stakeholder consultation as per the para 162 (d) of VVS version 9 requires that the consultation process was completed before the start date.
1: The PP/ DOE are requested to describe in the PDD how the local stakeholder consultation was conducted as per PS version 09.0 paragraphs 74-80.
The PDD (p 33) provides the invitation to the local stakeholder was done as per "Resolution No. 7 of the Brazilian DNA" and its relevant link. However, 1) the link provided as the footnote 19 is not accessible and 2) the PDD does not provide the date for local stakeholder consultation while para 78 of PS version 9 states that Project participants shall complete the local stakeholder consultation process before the start date of the project activity.
2: The DOE is requested to report the receipt of letter of approvals/ authorization as per VVS version 09.0 paragraphs 47, 48 and 49 (a) (b).
The DOE (p 5) states that "The validation report was updated (Revision 1.4) to reflect the receipt of the letter of approval and that is the only change that has been made compared to the version (Revision 1.3Aa, dated 05/01/2017) listed in the Brazilian DNA letter of approval dated 05/05/2017." However, the LoA submitted in the request for issuance is issued on 15 May 2017.
3: The DOE is requested to describe how it has validated the actions taken to secure the CDM status as per VVS version 09.0 paragraphs 116 (b), 117 and 118.
The validation report (p 10) states that "The notification of prior consideration dated 18/11/2016 was sent to UNFCCC /26/ and Brazilian DNA on 24/11/2015 /38/". The DOE requests to clarify the date sent to UNFCCC as there are more than one year gap between two dates.
4: The DOE is requested to describe how it has validated the suitability of the benchmark as per VVS version 09.0 paragraphs 130 and 132 (b).
The DOE validates that PP used the value from the Table 1 inside the Appendix of the Tool, for Host Country Brazil Group 1 (which includes Energy Industries) the reference value for the Cost of Equity (Benchmark) is 12.32. However, the validation report (p 13) states that "the proposed project activity in absence of the CDM benefits and compared to the benchmark 10.65% is not financially attractive." Therefore,the DOE is required to rectify this inconsistency in the benchmarks referred in the validation report.
5: The DOE is requested to describe how it has assessed the adequacy of the local stakeholder consultation and how comments have taken in due account as per VVS version 09.0 paragraphs 162-165 and 166.
The DOE (p 22) states that "As per the Brazilian DNA Resolution nš 7 /33/, the local stakeholder consultation must start 15 days prior the PDD publication for the Global Stakeholder Consultation. PP has followed the requirements of the Brazilian DNA" and "letters inviting to comment on the project dated 29/04/2016". Further it (p 6) states that "The start date of the project activity is 23/09/2015, which was the signature of the Power Purchase Agreement." The DOE is required to provide further information on how it validated the local stakeholder consultation as per the para 162 (d) of VVS version 9 requires that the consultation process was completed before the start date.
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