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	9327
Title of the proposed CDM project activity/PoA submitted for registration	Using off gas cogeneration project in PT KPP
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 shall further substantiate how it has validated the suitability of input values, in particular the waste gas tariff (6.08 cent/KWh) considering it appears to be an internal price for the waste gas between the owner of the project activity (PT. Krakatau Poscopower) and the owner of the project facility (PT. Krakatau Posco). In doing so, the DOE shall also explained how it has validated the relationship among the owner of the project activity (PT. Krakatau Poscopower), PT. Krakatau Daya Listrik, the owner of the project facility (PT. Krakatau Posco) and PT. Krakatau Steel. Please refer to EB 60, paragraph 93. 2) The DOE shall further substatiate how it has validated the extent of use of waste gas from the greenfield waste energy generation facility (project facility), given the fact that the alternative designs identified and analyzed under option 2 of Annex 1 are for the project activity rather than the project facility whereas the applied methodology requires the assessment of alternative design of the project facility. Please refer to ACM0012 version 4, Annex 1, option 2.. 3) The DOE shall further explain how it has validated that the use of waste gas in the absence of project activity would not be reduced due to the implementation of project activity, in particular how to verify whether there is any decrease in the utilization of waste gas by other uses at the project facility given that the values for the baseline utilization of waste gas at the project facility is to be monitored instead of being determined prior to the implementation of project activity. In doing so, an energy balance shall be established for the demand and supply of energy in all the applications covered in extended project boundary, and the energy balance shall be provided in the PDD and validated by the DOE. Please refer to ACM0012 version 4, Annex 3. 4) The DOE shall further explain how it has valdiated the baseline scenario for the heat generation, in particular how baseline alternative H9 (A new renewable energy or other waste energy based element process to supply heat) is eliminated since it is not clear whether other waste energy recovery process (e.g. waste gas fired boilers) is a creditable alternative and how the DOE has validated the elimination of that alternative. Please refer to VVM version 1.2, paragraph 83. 5) The DOE shall explain how it has validated the correctness of the formulas applied to calculate baseline emissions given that the waste gas would be partially recovered in steel plant whereas the formula applied is only applicable to the condition of no recovery of waste gas in the absence of project activity. Please refer to ACM0012 version 4, page 24 - 26. 6) The DOE shall further explained how it has validated the capping parameter fcap, in particular the ex-ante parameter Qwcm,BL (quantity of waste energy generated prior to the start of the project activity). Please refer to ACM0012 version 4, page 31.. 7) The DOE shall further substantiate how it has validated the appropriateness and conservativeness of the ex-ante grid emission factor (0.87393 tCO2e/MWh) given the fact that it is not clear whether the emission factor has been calculated based on the latest available data at the time of the validation. Please note that the emission factor of the project activity is based on data from 2007-2009 whereas the emission factor issued by Indonesian DNA on 27 March 2012 is based on data from 2008 to 2010 (as per other registered projects from Indonisia). Please refer to VVM version 1.2, paragraph 91.
Date	30 Jun 13