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	9210
Title of the proposed CDM project activity/PoA submitted for registration	Punatsangchhu-I Hydroelectric Project, Bhutan
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 shall further explain how it has validated the suitability of the benchmark, in particular: (a) The applied cost of debt (10%), given that the fact that the interest on the loan applied in the project activity is 9% (PDD, page 21 & 22). (b) The applied equity.debt ratio (50%:50%), given that fact that, the equity/debt ratio of the project activity is 40%:60% (PDD, page 21 & 22). Please refer to VVS, version 3, paragraph 120 (a). 2) The DOE shall further explain how it has validated the suitability of the input values applied in the investment analysis, in particular: (a) The investment costs, in particular why the investment costs of projects in Bhutan are not compared and whether the comparison with Indian project is appropriate. (b) The O&M costs and maintenance spares, in particular why the comparison with Indian regulations is appropriate. Please refer to VVS, version 3, paragraph 120 (a) & (b). 3) The DOE shall further explain how it has validated the barriers analysis, in particular: (a) The investment barrier. In doing so, the DOE shall explain: (i) how it has validated that the identified investment barrier considering it can be mitigated by additional financial means, which can be quantified and represented as costs, in accordance with EB 50, Annex 3, paragraph 7; (b) how it has validated the financial information of the company as per EB 50, Annex 3, paragraph 4, how it has validated that the financing of the project was assured only due to the benefit of the CDM as per EB 50, Annex 3, paragraph 9. (b) Other barriers (geological risks and unfavourable conditions, glacial lake outburst floods, glacial retreat, earthquakes, and barrier due to dependence on external resources for managerial, organizational, project and technical skills), considering that the DOE has not validated how the CDM has alleviated those identified barriers. Please also note that if the barrier can be justified, the barrier shall be removed in the PDD. Please refer to EB 50, Annex 3, paragraph 4, 5, 7 & 9.. 4) The DOE shall further explain how it has validated the correctness and appropriateness of the method applied to calculate grid emission factors, considering that: (a) It is not clear whether the OM of 1.005 tCO2/MWh and BM of 0.553 tCO2/MWh are the emission factors for Indian NEWNE grid or for the combined regional grid (i.e. Indian NEWNE grid and Bhutan grid). In case it is the emission factors for NEWNE grid, the DOE shall further explain why all the electricity generated/supplied by the project is used to calculate the emission reductions since only a portion of the electricity generated will be supplied to Indian NEWNE grid and the other portion will be supplied to Bhutan grid. (b) The source of the data on power plants in Bhutan, which is used to calculate the grid emission factors, was not specified. In doing so, the revised spreadsheet shall be provided in which each step to calculate the emission factors shall be clearly illustrated, and the data of Indian NEWNE grid and Bhutan grid shall be specified respectively. Please refer to Tool to calculate the emission factor for an electricity system, version 3.0. 5) The DOE shall further explain how it has validated the feasibility of the monitoring plan, given the fact that the project activity is to supply electricity to India and Bhutan, and the electricity supplied to the two countries may have different tariff whereas only the total electricity supplied by the project activity will be monitored as per the current monitoring plan, Please refer to VVS, version 3, paragraph 132 (b) (i)..
Date	01 Nov 13