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	1933
Title of the proposed CDM project activity/PoA submitted for registration	Reduction in clinker usage in the production of cement through the increase in the use of additives at Lafarge Malayan Cement Berhad (LMCB)
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. As per the applicable methodology, the evidence to demonstrate additionality should be “substantiated through independent surveys and stakeholder interviews”, further evidence is required to determine that the barriers presented are specific to the increase in blending rates achievable in the baseline. In assessing this evidence it should be taken into consideration that Lafarge is an international operating company with broad experience in increasing additives in its cement blends. In addition, claiming barriers while a reduction of clinker will also result in cost savings raises questions about the credibility of the barriers. Finally, the project activity is claimed to be the first-of-its-kind in Malaysia, however, this has not been substantiated with evidence as required by the applicable methodology 2. The start date of project activity should be as per CDM Glossary of Terms. The DOE is requested to clarify the following inconsistency in project activity start date as stated in the PDD and the validation report: The PDD (p31) refers the project start date of 14 June 2006 as the date when the EPCC contractor selection for Tanjung Bin PFA handling facility tender sign was done, however, the VR (p13) refers this date as date when the signing of PFA (Pulverized Fly Ash) supply agreement was done. In addition, the PP Annual Report 2006 (p13) mentions that in 2005 we secured a long term contract with Tanjung Bin power plant for their exclusive supply of all their fly ash production. 3. The DOE is requested to substantiate the appropriateness of the benchmark clinker content of 86.35% for a plant (Rawang) that has historically lower percentages of clinker than the baseline value used.
Date	01 Jan 09