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	8238
Title of the proposed CDM project activity/PoA submitted for registration	Use of Charcoal from Renewable Biomass Plantations as Reducing Agent in Pig Iron Mill of ArcelorMittal Juiz de Fora, Brazil
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 project activity has referenced to three milestone activities (i) start date 12 August 2005, (ii) CDM contract is signed in 2007, and (c) GSC - PDD publication by 6 July 2010.The time period between each milestones activities is 2.4 and 2.7 years respectively. The DOE shall further substantiate how continuing and real actions were taken to secure CDM status for the project in parallel with its implementation considering in particular that (a) activities listed like NM 0110 which are not directly relevant to the project activity mile stone; (b) CDM consultancy contract being signed after physical implementation of the project activity ; (c) the PNM of the methodology (Jul 2008) is submitted eight months later to the physical implementation of the project activity (Dec 2007); Please refer to VVM v.01.2, Para 102 (b) Reliable evidence from project participants that must indicate that continuing and real actions were taken to secure CDM status for the project in parallel with its implementation.. 2) The project activity has demonstrated barrier analysis primarily on the credit lines for the plantation activity and experience of the farmers in Zone Mata region (where new cultivation of sepcies occurs). The DOE shall further substantiate (a) how the barriers validated is in line with the applied methodology i.e if barrier analysis is used,then "the barrier analysis may be applied to the integrated iron ore reduction system including: (1) The production and supply of the renewable reducing agent (establishment of plantations and production of charcoal); and (2) The industrial process (iron ore reduction using a blast furnace technology); (b) furthermore it shall be demonstrated when the project is covering many hectares how barriers like lack of previous experience in eucalypt cultivation and their inability to provide loan related one region (Zone mata) is representative for the whole region and also some piece of land are re-cultivation with same species (eucalyptus). Please refer to VVM v.01.2 ,Para 115 (a), EB 50,Annex 13,para 9, and also the requirements for additionality in the methodology AM 0082,V.0.1.. 3) The DOE shall further substantiate how it has validated that the project activity complies with applicability condition specified in AM 0082,version 01 "Guidance for the situation when the plantation (or part of) is covered under an A/R CDM project activity" in particular (a) considering that the validation report did not specify anything related to this applicability conditions on whether it is integrated project (A/R and AM 0082) or stand alone AM 0082 project ; (b) demonstration of prior CDM consideration includes plantation activities (A/R) and (c) barrier analysis is restricted only to the plantation activities. Please refer to VVM v. 01.2 ,para 71,the DOE shall determine whether the choice of methodology is justified and the project participants have shown that the project activity meets each of the applicability conditions of the approved methodology or any tool or other methodology component referred to therein..
Date	28 Jan 13