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	9203
Title of the proposed CDM project activity/PoA submitted for registration	CEMEX Panama: Alternative fuels and biomass project at kiln 2 of Bayano cement plant
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 validate the suitability of the input values used in the investment analysis, in particular:   a)The total investment cost, given that the breakdown of the cost shows that the equipment purchasing cost related to RDF processing has been included in the total investment, while RDF is not part of the proposed project activity. Moreover, the DOE shall explain how the comparison done against other three similar CDM projects has been considered appropriate considering that: a) details of the similar activities were not reported and it is therefore not clear whether the comparison was done based on the unit investment cost b) the comparison has been done only against similar cases implemented by the same project participant, and c) the similar activities are not located in the same country as this project. The DOE shall also clarify why the evidence used as source of the total investment was called “offer letter” in reference /42/, while apparently the same source was called “equipment purchase order” in reference /20/.   b)The price of MSW and biomass residues (canal straws and other type of biomass residues) considering that: i) the details of crosschecking with other similar projects have not been provided,  ii) the secretariat noted that the DOE has not explained why the price of MSW and biomass residues used by the similar activity registered in Panama # 4975, which is also located at the project site and developed by this PP, cannot be achieved for this project, and iii) ) the comparison has been done only against similar cases implemented by the same project participant in different countries. It is also observed that a different set of projects was used to crosscheck different input parameters, the prices of MSW and biomass residues were crosschecked with four similar projects (PA 3881, 4569, 4579 and 4975), while only three projects (PA 3881, 4569, 4579) were used to crosscheck  the total investment Please refer to VVM version 1.2, paragraph 111. 2) The DOE shall further validate the technical barriers identified in the PDD considering that no independent evidence has been validated by the DOE to demonstrate the existence of the identified barriers. In doing so, the DOE shall also validate how the CDM will help to alleviate the identified barriers so that the project activity is not prevented by the occurring of the barriers. Please refer to VVM version 1.2, paragraph 117 & 118.
Date	16 May 13