Registration Request for Review Form


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 registration6107
Title of the proposed CDM project activity/PoA submitted for registrationEiamrungruang Waste Water Treatment and Biogas Utilization 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 PDD, page 34, states that “the project proponent was aware of problems in accessing finance for the project activity at the time of investment decision.” However, it appears that the project proponent became aware of the “access to finance” barrier in June-August 2008, when “the project proponent applied for a loan from Kasikorn Bank, which after initial discussions and consideration rejected the loan for the biogas plant.” The DOE is requested to further substantiate how it validated that the access to finance barrier is real at the time of investment decision and prevents the implementation of the project activity. Please refer to VVM v 01.2 paragraph 117.

2) The DOE is requested to further clarify how it assessed that the financing of the project was assured only due to the benefit of the CDM, as per guideline 6 of EB 50 Annex 13, considering:
a) The validation report, page 31, states that “about 13 % of the total project cost was paid to the manufacturer prior to loan approval […] the upfront payment made by the PP has convinced the bank on the seriousness of the PP towards the project activity and approval of the loan”; and
b) The PDD, page 35, states that "the project proponent also obtained a subsidy from the Energy Policy and Planning Office (EPPO), Ministry of Energy in December 2008. The subsidy granted by the government further helped in convincing the banks to approve the loan for the project activity." Please refer to EB 50 Annex 13 paragraph 9.
Date 10 Jul 12