18:30 16 Aug 24
Registration Request for Review Form
CDM project activity/programme of activities registration request review form (CDM-REGR-FORM) (Version 03.0) |
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Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration | 6242 |
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Title of the proposed CDM project activity/PoA submitted for registration | Yuecheng Coal Mine Methane Power Generation 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: | |
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The following are requirements derived from paragraph 40 of the CDM modalities and procedures: | |
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Additional information | |
1) The DOE is requested to further substantiate the project start date of 29 April 2011 as an earlier action related to the project activity is observed on 17 December 2009 when the gas purchase agreement was signed according to page 3 of the validation report. In case the project start date is revised, the DOE should ensure that the prior considerations are valid for the revised project start date. Please refer to VVM version 1.2 paragraphs 99-103.. 2) The DOE is requested to further substantiate the input values to the investment analysis, in particular: a) The CMM price of 0.11 RMB/m3, considering that: i) it is supplied to other mines in Jincheng group for free of charge and excess is vented to the atmosphere in the baseline, thus has no financial value in the baseline, ii) pre- treatment of the gas is done by the project activity, and not by the mine, iii) the project activity supplies electricity and heat to the mine for free of charge, and iv) based on the DOE's statement, it appears that the reference used only refers to CMM with methane concentration above 40%. b) The VAT refund and/ or tax exemption, by clarifying: i) which tax exemption and/ or VAT refund policies were considered, and ii) how it was confirmed that the project participant is not eligible for any of them, by providing details of the "nature of the project activity" that made them ineligible for tax exemption, and refund schemes. Please refer to VVM version 1.2 paragraph 111.. 3) The DOE is requested to clarify the baseline scenario and pre-project activities, in particular: a) The leakage due to the displacement of baseline thermal energy uses: whether the calculation was made in a conservative manner, in line with pages 14-17 and 28-29 for the following parameters: i) the projection of the extraction rate for the crediting period, ii) the baseline demand of CMM by the other mines, considering the large difference in the demand of 2009, 2010 and 2011; iii) the baseline demand by the local residence, taking into consideration the seasonal demand by using the daily log rather than an annual total; and iv) whether they are reflected to the motoring plan. Please note according to page 16 of the applied methodology, "even when a project’s average annual VAM/CMM/CBM use for electricity generation or other uses is significantly below baseline VAM/CMM/CBM emissions, there may be times due to daily fluctuations in thermal energy demand or in VAM/CMM/CBM extraction rates – that the project will use VAM/CMM that would have been used for thermal energy under baseline conditions". Where regulations require that local thermal demand is met before all other uses, the DOE shall demonstrate that the regulation is systematically enforced by assessing the compliance rate. b) The electricity of 3,600 MWh supplied to the mine, as it is not clear: i) how they are supplied in the pre-project scenario and would be supplied in the baseline in the absence of the project activity, and ii) whether it is correctly and conservatively reflected in the emission reduction calculations. Please refer to VVM version 1.2 paragraph 84, 90 and 91.. 4) The DOE is reuqested to further justify the baseline scenario to vent CMM to the atmosphere in line with the existing regulations, particularly the Emission Standard of Coal Bed Methane/Coal Mine Methane (GB 21522-2008) which was issued on 2nd April 2008, and prohibits venting of CMM with methane concentration above 30% from 1 July 2008 for new mines and 1 Jaunary 2010 for existing mines, as it is not clear how the DOE has concluded that the standard is not enforced based on: a) a disucssion with a local official on 28 June 2009 in response to the request for review of another project activity, considering that at the time of the discussion, the standard was not effective for existing mines, b) a telephone interview in March 2012, as it is not clear whether it was sufficient to examine whether the standard is not systematically enforced and that non-compliance is widespread, and c) various operation permit obtained after the publication of the standard but after the completion of the FSR of the project activity in June 2010. In doing so, please provide a quantitative assessment of the current rate of enforcement of the standard, in line with "Identification of the baseline scenario" Step 2 (page 6) of the applied methodology. Please refer to VVM version 1.2 paragraph 85.. 5) The DOE is requested to further substantiate the baseline identification, in particular, elimination of the alternative scenarios which are economically unattractive. Step 5 of "Identification of the baseline scenario" (page 8 of ACM0008 version 7) requires that Step 2 (investment analysis) of the latest approved version of the “Tool for the demonstration and assessment of additionality” is used to identify the most plausible baseline scenarios by eliminating options which are clearly economically unattractive. However, the DOE has not validate the investment analysis for the elimination of the following alternative scenarios sufficiently: Scenario v, considering the financial savings made in reduced power purchase from the grid as revenue, providing validation of the power purchase price. Scenario vi, providing validation of the investment comparison analysis, comparing with the continuing use and/or replacement of coal fired boilers. Scenario vii, providing validation of the investment analysis of the hypothetical pipeline project. Please refer to VVM version 1.2 paragraphs 83 and 111.. |
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Date | 22 Nov 12 |
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