Registration Request for Review Form


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 registration5366
Title of the proposed CDM project activity/PoA submitted for registrationRefurbishment of Enguri Hydro Power Plant, Georgia
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 clarify how it validated the start date of the project activity as 21/12/2005, considering that;
a) normal rehabilitation work resumed at the project site within 5 weeks of a preliminary notice of termination being sent  by the contractor to the project participant (PP), which indicates that project implementation never ceased on the ground. The DOE may also justify how it validated the statement in the validation report (page 17) that project work had already ceased owing to severe financial problems faced by the project activity for over 24 months. 
b) the Board resolution dated 21/12/2005 only considered CDM benefits for units 1 and 2 (PDD page 30), and not units 4 and 5
 
In doing so, the DOE may refer to the definition of start date as clarified by the Board in EB 41 for project activities that are restarted due to consideration of the benefits of the CDM, the cessation of project implementation must be demonstrated by means of credible evidence such as cancellation of contracts or revocation of government permits. Please refer to VVM paragraph 104 (a).

2) The DOE is requested to clarify how it validated prior consideration of CDM for units 2 and 4 considering that the PP obtained a loan for the rehabilitation of these units in December 2001, signed a contract with VSH in November 2002, and without any real termination of the contract, project works continued at the site and were completed by August 2009 for both the units.
 
The DOE is requested to clarify how it validated prior consideration of CDM for unit 5 considering that the Board resolution dated 21/12/2005 does not include CDM consideration to proceed with rehabilitation of unit 5, but only units 1 and 2 (PDD page 30). Please refer to VVM paragraph 104 (b).

3) The DOE is requested to further substantiate how it validated the investement barrier - lack of private capital, considering that the PP had access to both national loan (USD 200,000 from Georgian Procredit Bank) and international loans (approximately USD 30 million from EBRD) as sources of finance for the project activity. In doing so, please refer to the 'Combined tool to identify the baseline scenario and demonstrate additionality', sub-step 2a. Investment barriers, page 7. (EB 60, Annex 7).
 
The DOE is requested to further substantiate how it validated the investment barrier - risks due to level of tariffs, considering that the generation tariff was reduced in June 2006 from 2.13tetri/kWh to 1.187tetri/kWh, which is after the date of investment decision (21/12/2005). Please refer to VVM paragraph 118 (a), (b).
Date 03 Jan 12