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 registration6217
Title of the proposed CDM project activity/PoA submitted for registrationGuizhou Hongguo Coal Mine Methane 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 substantiate the following input values to the investment analysis:
a) The O&M costs of 1.6884 million RMB (969,417 RMB/MW), in particular: i) the power costs, considering that 10% auxiliary consumption has been deducted from the net electricity output, and ii) other costs of 0.3489 million RMB (8% of the total investment), as it is not clear if this cost is directly related to the project activity, and iii) the range of 310,650 RMB/MW-2,343,450 RMB/MW as it is not clear whether any of those projects compared to includes cost of CMM in the O&M costs as the project activity does not.
b) The suitability of the power price of 0.4186 RMB/kWh including VAT: in particular, to clarify: i) whether the "actual tariff" of 0.394 RMB/kWh is a value including VAT or excluding VAT, ii) whether the "actual tariff" of 0.517 RMB/kWh (incl. VAT) for export to the grid includes any subsidies, and if not, how the value lower than the sales price was considered suitable as purchase price; and iii) why the respective tariffs were not applied according to the proportion of the sales to the gird (20%) and captive consumption (80%).
c) Taxes (17% VAT, 25% income tax, 5% City Construction and Maintenance Tax and 3% Educational Surcharge) accounted as "cost" in the cash out flow, considering that the project "revenue" is based on the financial savings made on cost of power purchase from the grid, thus it is not clear if those are considered taxable income.
In addition, the DOE is requested to clarify the assumptions made in the scenarios describing the impact of the delayed implementation and no implementation of the remaining two generator units, in particular, why the electricity output was adjusted by 10/12 to account for two less generators while the electricity output with the full implementation was based on nine generator units with three backup units. Please refer to VVM version 1.2 paragraphs 111..
Date 20 Dec 12