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	3020
Title of the proposed CDM project activity/PoA submitted for registration	GHG Emission Reductions through grid connected high efficiency power generation
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 should validate the suitability of the 14% benchmark for the project activity and provide the source/reference used. 2. The DOE should clarify how it has considered the tariff applied as appropriate to assess the additionality, in the context of the tariff policy document issued by the Minister of Power, where it is mentioned CDM benefits would be available to the bidders. 3. The DOE should further substantiate the validation of the sensitivity analysis, as: (a) the results could not be directly replicated with the spreadsheet submitted; (b) why the tariff was not considered. 4. The DOE should explain how it has validated the barriers in line with VVM paragraphs 114 (a), 115 and 116 (a). 5. The DOE should further substantiate the common practice analysis as in other sections of the VR it is mentioned that there might exist other supercritical power plants which are not CDM projects. 6. The DOE should further substantiate how it has considered the arguments for the exclusion of natural gas and liquid fossil fuels among the baseline alternatives as appropriate, in particular, (a) whether the higher cost of liquid fossil fuel) and uncertainties in natural gas prices could not be incorporated in the levelized cost analysis, in line with the requirements from Step 2, p.3 in the methodology; and (b) the unavailability of natural gas given that there are natural gas-based CDM project activities in the same region (applying AM0029; power generation with natural gas) which have established a surplus in natural gas supply. 7. The DOE should explain how it has assessed that the alternatives “500 MW subcritical technology” and “800 MW supercritical technology” provide comparable outputs. In addition, the DOE should confirm: a) the levelized cost generation and the sensitivity analysis (as the results from this analysis could not be replicated); b) the PLF of 85% and the auxiliary consumption of 7.5% which were assumed for both technologies (sub/supercritical); and c) the fuel cost and GCV for the imported coal. 8. The DOE should further substantiate the validation of the sensitivity analysis, as the PDD discusses parameters which are not mentioned by the DOE in the Validation Report (eg. imported coal prices). 9. The DOE should clarify how it has assessed the chosen baseline to be a plausible baseline alternative, taking into account the statement contained in p. 41 of the Validation Report (i.e. “that in the last 10 years not a baseline single sub-critical coal power plant was implemented by the private sector”). 10. The DOE should further discuss the implications of considering different types of coals for the baseline and project activity scenarios in the calculation of emission reductions. 11. The DOE should explain how it has validated the monitoring plan as appropriate, considering that the parameter “EFFF,PJ,CO2,y” was not included in section B.7 in the PDD, as required by the methodology.
Date	16 Apr 10