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	6548
Title of the proposed CDM project activity/PoA submitted for registration	Gansu Jingyuan Coal Mine Group Jieneng Thermoelectricity Company CMM 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 justify the choice of benchmark of 15% equity IRR (post tax) for coal mining sector as it appears that the project participant, Baiyin Jieneng Thermoelectricity Co Ltd., appears to be purely an egergy generation company.  In doing so, please clarify the core operation of Baiyin Jieneng Thermoelectricity Co Ltd. Please refer to VVM v 1.2 paragraph 112.. 2) The DOE is requested to further substantiate the investment analysis: a) Tax calculation, in particular, to clarify why various taxes (VAT, educational surcharge, urban maintenance and construction tax and income tax) have been accounted as costs in the cash outflow considering that the revenues are based on the avoided costs of electricity and coal.  b) NCV of coal based on China Energy Statistical Yearbook, in particular, whether the value applied is conservative in comparison to the actual NCV of the type of the coal used in the baseline. c) the O&M cost, in particular, what Material purchasing cost of 1,007,500 RMB consists of and if it includes cost of CMM. Please refer to VVM v 1.2 paragraph 111.. 3) The DOE is requested to further substantiate how it has validated that all possible options that are technically feasible were included, for example, retrofitting of the existing system that operated with high concentration CMM between 2004 and February 2008 to operate with the new concentration. Please note that the list of options in the applied methodology are not exhaustive and possible options are not limited to those listed in page 6 of the methodology. Please refer to VVM v1.2 paragraph 83.. 4) The DOE is requested to further substantiate the elimination of scneario 4 Use for additional grid power generation, in particular, to justify how it has validated the discount rate of 15% (post tax equity IRR benchmark) for coal sector, considering that this alternative considers 100% export to the grid.  Please refer to VVM version 1.2 paragraph 83.. 5) The DOE is requested to further substantiate how the electricity consumption by the project activity is monitored by clarifying how the monitoring plan ensures that all electricity consumption that results from the project activity are captured by monitoring the net electricity supply to the Jingyuan Coal Group's grid. Please refer to VVM version 1.2 paragraph 123 (a)..
Date	20 Dec 12