CDM project activity/programme of activities registration request review form (CDM-REGR-FORM) (Version 03.0)

Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration	10295
Title of the proposed CDM project activity/PoA submitted for registration	Wind Power Project by Wires & Fabriks (EKIESL-CDM.February-15-03)
Please indicate, in accordance with paragraphs 37 and 40 of the CDM modalities and procedures, which validation requirement(s) may require review. A list of requirements is provided below. Please provide reasons in support of the request for review. Including any supporting documentation.
The following are requirements derived from paragraph 37 of the CDM modalities and procedures:
The participation requirements as set out in paragraph 28 to 30 of the CDM modalities and procedures are satisfied; Comments by local stakeholders have been invited, a summary of the comments received has been provided, and a report to the designated operational entity (DOE) on how due account was taken of any comments has been received; Project Participants have submitted to the DOE documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts and, if those impacts are considered significant by the project participants or the host Party, have undertaken an environmental impact assessment in accordance with procedures as required by the host Party; The project activity is expected to result in a reduction in anthropogenic emissions by sources of greenhouse gases that are additional to any that would occur in the absence of the proposed project activity, in accordance with paragraphs 43 to 52 of the CDM modalities and procedures; The baseline and monitoring methodologies comply with requirements pertaining to methodologies previously approved by the Executive Board; Provisions for monitoring, verification and reporting are in accordance with decision 17/CP.7, the CDM modalities and procedures and relevant decisions of the COP/MOP; The project activity conforms to all other requirements for CDM project activities in decision 17/CP.7, the CDM modalities and procedures and relevant decisions by the COP/MOP and the Executive Board.
The following are requirements derived from paragraph 40 of the CDM modalities and procedures:
The DOE shall, prior to the submission of the validation report to the Executive Board, have received from the project participants written approval of voluntary participation from the designated national authority of each Party involved, including confirmation by the host Party that the project activity assists it in achieving sustainable development; In accordance with provisions on confidentiality contained in paragraph 27(h) of the CDM modalities and procedures, the DOE shall make publicly available the project design document; The DOE shall receive, within 30 days, comments on the validation requirements from Parties, stakeholders and UNFCCC accredited non-governmental organizations and make them publicly available; After the deadline for receipt of comments, the DOE shall make a determination as to whether, on the basis of the information provided and taking into account the comments received, the project activity should be validated; The DOE shall inform project participants of its determination on the validation of the project activity. Notification to the project participants will include confirmation of validation and the date of submission of the validation report to the Executive Board; The DOE shall submit to the Executive Board, if it determines the proposed project activity to be valid, a request for registration in the form of a validation report including of the project design document, the written approval of the host Party and an explanation of how it has taken due account of comments received.
There are only minor issues which should be addressed by the DOE/project participants prior to the registration of the project.
Additional information
1) The DOE is requested to confirm compliance of the Project with Para 185 of the VVS, Version 09. If the PP confirms that it wishes to register the project as a bundle, in regard to the project start date, the DOE is requested to validate the start date of the project in accordance with the glossary of CDM terms version 08.0 and for this to provide information how it has validated the project start date for each sub-bundle/WTG in accordance with the glossary of CDM terms version 08.0. Please refer to VVS version 09.0 paragraph 114.. 2) The DOE is requested to explain how it has assessed the real and continuing actions for WTG no. J-411 and J-426, in particular: (a) How the DOE has validated the evidences for the contracts with CDM Consultant Asia Carbon Emission Management India Pvt Ltd and CDM Consultant “Ennavoir Consulting” in line with VVS version 09.0 paragraph 117. In doing so, for each WTG J-411 and J-426 the DOE shall also: (i) provide the evidences of the actions listed to demonstrate the real and continuing actions; (ii) explain the deliverables by each of these consultants; (b) How the DOE validate the authenticity of the evidence for the following in line with VVS version 09.0 paragraph 117: (i) For J-411: Email Communication with CDM Consultant Asia Carbon Emission Management India Pvt Ltd expressing interest to get CDM Project Registration (24/07/2007), confirmation from Consultant about offer acceptance (01/08/2007), appointment of CDM consultant (17/03/2008), follow up for project execution from PP to Consultant (18/12/2008 and 29/05/2009), termination of earlier appointed CDM Consultant due to no project movement (16/09/2009), appointment of new CDM Consultant “Ennavoir Consulting” (10/09/2011), follow up with Consultant for non-performance (18/12/2012), termination of appointed CDM Consultant “Ennavoir Consulting” (11/02/2013) and appointment of CDM Consultant EKI Energy Services Ltd (15/07/2013). (ii) For J-426: Appointment of CDM Consultant “Asia Carbon Emission Management Pvt Ltd” (15/07/2008), termination of appointed CDM Consultant due to no project movement (18/05/2010), appointment of new CDM Consultant “Ennavoir Consulting” (10/09/2011), follow up with Consultant for non-performance (18/12/2012), termination of appointed CDM Consultant “Ennavoir Consulting” (11/02/2013), and appointment of CDM Consultant EKI Energy Services Ltd (15/07/2013). Note that as per the paragraph 117 of the VVS, the DOE shall assess letters, e-mail exchanges and other documented communications submitted by the project participants to substantiate the information, and these shall be considered as evidence only after the DOE has assessed the reliability and authenticity of such communications, inter alia through cross-checking (e.g. interviews). 3) The DOE is requested to further substantiate why the evidence from 18/5/2010 “Termination of appointed CDM Consultant due to no project movement” complies with Para 116 b) of the VVS and can be considered for the demonstration of Prior Consideration as an action to secure CDM Status given the time gap between the evidences from 15/7/2008 and 10/9/2011. Similarly, the DOE is requested to substantiate that the action evidenced by “Termination of earlier appointed CDM Consultant due to no project movement” from 16/09/2009 for bundle J-411 can be considered as securing CDM Status as per Para 116 b)and 118 b) of the VVS given the time gap between the evidences from 29/5/2009 “Follow up for project execution from PP to consultant” and 10/9/2011 “Appointment of CDM Consultant “Ennavoir Consultant”. Please refer to VVS version 09.0 paragraph 117. 4) The DOE is requested to explain how it has validated the following input values to the investment analysis: (a)      Each input value (e.g. project cost, O&M cost, PLF, tariff) being available at the time of investment decision as per the paragraph 6 of EB62 Annex 5 for TEJ-25 and AK-28 considering there is no information on the investment decision for these two wind turbines; (b)     The PLF for J411 and J426 being available at the time of investment decision as per the paragraph 6 of EB62 Annex 5 since it is not clear when the PLF was made available; (c)      The administrative expense and its escalation in line with VVS version 09.0 paragraph 129(b); (d)     Each input value to determine the benchmark for TEJ-25 and AK-28 being available at the time of investment decision as per the paragraph 6 of EB62 Annex 5 in the absence of the information of the time of the investment decision; (e)      The risk free rate applied for J-411 and J-426 being available at the time of the investment decision (18/07/2007 and 24/05/2008) in line with paragraph 6 of EB62 Annex 5 as the spreadsheet only shows that it is for year 2007-08. Please refer to EB62 Annex 5 paragraph 6; f) The Market Return rates applied for all sub-bundles as per Para 129 d) of the VVS since these values have been calculated inconsistently throughout the sub-bundles. For TEJ-25 and AK-28, the PP has calculated the Market Return based on the information on market return values for companies listed in Sensex (BSE-30), BSE-100, BSE-200 and BSE-500, whereas for J-411 and J-426 only the data from SBE-500 was used; g) The Betas applied for determining the benchmark as per Para 129 d) of the VVS, since these have been calculated inconsistently throughout the sub-bundles. For TEJ-25 and AK-28 sub-bundles, the Beta was calculated as an average of the Beta values of the 5 leading companies in the power, minerals and infrastructure sectors. In this case is arguable, that companies producing electricity from fossil fuels or with diversified portfolios in infrastructure or the mining sector are representative for calculating the beta value of the wind energy sector in India. Furthermore, whereas for the sub-bundles J-426 and J-411, the beta applied was obtained as the minimum value of the betas calculated for a chosen group of companies, for the sub-bundles TEJ-25 and AK-28 the applied beta was calculated as the average value of the betas listed for a different group of companies chosen for the other sub-bundles. Therefore, in accordance to Para 129 d) of the VVS, the DOE is requested to further substantiate how it was validated the correctness of the calculation of benchmarks used for the four sub-bundles. 5) The DOE is requested to further validate as Para 162 of the VVS, that all relevant local stakeholders were invited to send comments, since the Local Stakeholder Consultation was carried out only once in the Village of Sadiya, district of Jaisalmer in Rajasthan despite the sub-bundles are developed in three different villages. 6) The DOE is requested to substantiate whether the monitoring plan defined in the PDD is compliant to the applied monitoring methodology, since the PDD is ambiguous in which parameter will be applied for calculating the ER. The PDD does not specify whether the calculation of ER will be based on the measurements of net electricity generated carried out at the metering point or at the delivery point.
Date	03 Aug 16