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	9108
Title of the proposed CDM project activity/PoA submitted for registration	9.9 MW Biomass based power plant at Khas, Gujarat
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 further substantiate how it has validated the assumed project cost considering that the DOE has not explained why such cost is higher than the cost recommended by the CERC tariff order and the project IRR reach the benchmark by applying the cost recommended by the CERC order.  As a part of sensitivity analysis, the DOE has not validated that a variation in the project cost to the level recommended by CERC order is not likely to occur.  Please refer to VVM v1.2 paragraph 111(a), (b) and (e). 2) The DOE is requested to further validate the suitability of the fixed ex-ante  default value for EFCO2,i.y (CO2 emission factor for fossil fuel (Imported Coal) for year y) in line with the “Tool to calculate project or leakage CO2 emissions from fossil fuel consumption” that requires to use “IPCC default values at the upper limit of the uncertainty at a 95% confidence interval as provided in table 1.4 of Chapter1 of Vol. 2 (Energy) of the 2006 IPCC Guidelines on National GHG Inventories” whereas the assumed value is not at the upper limit as required by the tool.   Please refer to VVM v1.2 paragraph 91. 3) The DOE is requested to further substantiate how it has validated the monitoring details of NCV fossil fuel, y (Net calorific value of imported coal i used in the project activity), in particular, that the monitoring frequency and measurement method are in line with the “Tool to calculate project or leakage CO2 emissions from fossil fuel consumption” which is referred in the applied methodology AMS ID v17. As per the tool, “the NCV should be obtained for each fuel delivery, from which weighted average annual values should be calculated” whereas the PDD (page 38) proposes to monitor the NCV once in the first year of the crediting period.  Furthermore, the PDD also mentiones the following "the Project Participant quarterly will do measurement, taking at least three samples for each measurement and the average value can be used for the rest of the crediting period".  Please refer to VVM v1.2 paragraph 123(a).
Date	10 May 13