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	10197
Title of the proposed CDM project activity/PoA submitted for registration	Small Hydro Power Plant Ernestina CEEE
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) 1) Scope: The DOE is requested to describe how it has validated the suitability of the input values used in the financial calculations as per VVS version 09.0 paragraph 129 (a) (b) (c). Issue:  The CAR14 of the validation report states that the electricity tariff has been changed from R$141.93/MWh (sourced from data dated August 2010) in the GSC PDD to R$67.31/MWh (sourced from data dated December 2010) since this is the latest data available before the investment decision date (01/03/2011) and the same has been accepted by the DOE. Further the DOE has crosschecked the applied value of R$67.31/MWh by checking a Brazilian Public document which is available at Brazilian government website which contains auction prices and studies to expansion of auctions for electricity generation during 2010. However, the DOE is requested to provide further information on how it has validated the suitability of the electricity tariff value, in particular how it has concluded that the electricity tariff applied by the PP is relevant to the project activity. (Please refer to the Tool: investment analysis EB 85 Annex 12, para. 12 and the Guidelines on the Assessment of Investment Analysis EB62 Annex 5, para. 6); ii) Issue: The DOE is requested to provide further information on how it has validated the appropriateness of the following input parameters: Income Tax, Social Contribution, Tax on JSCP, TUSD, TFSEE, PIS/PASEP, COFINS, which have been used in the investment analysis. Please refer to VVS version 09.0 paragraph 129 (a) (b) (c)) iii) Issue: The CL 01 of the validation report states that the input parameter value for O&M costs has changed from R$13.40/MWh to R$24.84/MWh. The project participants decided to use the specific historical average O&M cost of SHPP Ernestina, instead of the value R$13.56/MWh as per CCEE’s historical values presented in “Annex 8 – O&M Costs.pdf”, which presents that the average historic value for all CEEE’s power plants. The DOE is requested to further justify how it was validated that this new value is more suitable to the project activity, even though it decreases the value of the IRR and therefore is less conservative. Please refer to VVS version 09.0 paragraph 129 (a) 2) Scope: The DOE is requested to indicate if the latest PDD form is used correctly as per VVS version 09.0 paragraphs 69 and 70. Issue: The PDD (version 5.2, dated 16/May/2016 ) has been submitted using the project design document form for small-scale CDM project activities, while the proposed project activity is a larger scale project. The DOE/PP are requested to submit the PDD using the latest applicable valid PDD form.  Please refer to Please refer to VVS version 09.0 paragraph 129 (a) (b) (c) (Scope 1) and paragraphs 69 and 70 (Scope 2)..
Date	10 Nov 16