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	3016
Title of the proposed CDM project activity/PoA submitted for registration	Yangquan Nanmei (Group) Co., Ltd. Coalmine Methane Utilization Project
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 ensure that the project description clearly states the differences resulting from the project activity compared to the pre-project situation in compliance to the paragraph 63 of VVM 1.1, in particular, detail information of the consumers of hot water/heating/cooling in the project activity, and use of electricity generation from existing CMM fired power plant and source of hot water/heating/cooling to the consumers in the baseline. 2. The DOE shall further substantiate: (i) appropriateness of the applied benchmark in the context of the project activity given that the project activity is power and heat generation; and (ii) suitability of input values applied in the benchmark calculation, in accordance with paragraphs 12-16 of Guideline on the assessment of investment analysis (annex 58, EB 51). 3. The DOE is requested to substantiate the suitability of input values used in the investment analysis in line with the paragraph 112 (c) of VVM 1.1, in particular, electricity tariff given that the project activity generates electricity using low concentration CMM, total investment, hot water price, annual O&M (each element of the annual O&M should be validated separately), plant load factor, and why the revenue generated by heating and cooling has not been considered as an income to the project activity in the investment analysis. Further the DOE shall substantiate the comparison of the input values of the project activity to the investment analysis with similar projects, in particular, whether these similar projects are low concentration CMM fired power and heat generation projects. 4. The DOE shall clarify if there are any preferential policies on capture and utilization of low concentration CMM such as reducing or waiving taxes and charges, preferential price polices, pre-tax appropriation of safety cost, refund VAT, etc. If so, the DOE shall provide detail information how these preferential policies have been considered in the investment analysis. 5. The DOE should justify the suitability of criteria used to identify the similar projects in common practice analysis and how these criteria have been deployed in identifying the similar projects in line with paragraphs 118-120 of VVM 1.1. 6. The DOE shall further substantiate the identification of the baseline scenario in line with baseline methodology procedure of ACM0008 v6, in particular, how it has been validated that: (i) use of low concentration CMM (<30% CH4) is not systematically enforced and also that non-compliance with this requirement is widespread in the country; (ii) scenario II, utilization of VAM, can be eliminated due to high cost of equipment under step 4 of baseline identification; and (iii) there is no additional demand for CMM as a cooking fuel. 7. The DOE shall further substantiate the applicability of the methodology (ACM0008 v6), in particular, how the ex-ante demand of the low concentration CMM for the project activity has been validated. Further the DOE shall clarify how the specific fuel consumption of the project activity is lower than that of the existing CMM power plant given that the project activity consumes low concentration CMM whereas the existing power plant consumes high concentration CMM. 8. The DOE shall clarify suitability of the applied combined margin emission factor for North China Power Grid given that combined margin emission factor is 0.9928 tCO2/MWh as per the PDD where as it is 1.0549 tCO2/MWh as per the validation report. 9. The project participant shall monitor pre -mining CMM and post-mining CMM destroyed in the project activity separately as required by the monitoring methodology of ACM0008 v6. 10. The DOE should clarify how the project participant makes sure that the pre-existing users received same amount of gas what they received in pre-project scenario or more.
Date	21 Jun 10