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	6259
Title of the proposed CDM project activity/PoA submitted for registration	Wujia coalmine 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:
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 is requested to further substantiate the project start date of 5 March 2010 as an earlier action related to the project activity is observed on 15 November 2008 when the gas purchase agreement was signed according to pages 6 and 17 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 0.17 RMB/m3: i) the comparison to other projects, especially PA 4098 and 4534, considering that according to the validation reports of the respective projects, the prices are: PA 4534: 0.15 RMB/m3 pure CH4 gas purchase price (page 28), equivalent to 0.0525 RMB/m3 (35% CH4), and PA 4098: 0.286 RMB/m3 pure methane (page 30), equivalent to 0.1 RMB/m3 (35% CH4); the price applied by the project activity (0.17 RMB/m3 of CMM with 35% CH4) is the highest among the projects compared; ii) the suitability of the value, considering a lower price of 0.11 RMB/m3 was applied for another project activity requested for registration by the same project participant, validated by the same DOE (PA6424), and iii) the value indicated in the FSR which does not appear to be presented in the validation report. 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 further justify the baseline scenario to vent CMM to the atmosphere is in line with the existing regulations, particularly the mission 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 January 2010 for existing mines, as it is not clear how the DOE has concluded that the standard is not enforced based on: a) a discussion with a local official on 28 June 2009 in response to the request for review of another project activity which was implemented at an existing mine, considering that at the time of the discussion, the standard was not effective for existing mines and the proposed project activity is implemented in a new mine, 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 permits 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.. 4) 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 paragraphs 83 and 111..
Date	10 Dec 12