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	10328
Title of the proposed CDM project activity/PoA submitted for registration	Small Hydroelectric Power Plants Projects: São Pedro, Carangola, Calheiros, São Simão, Funil, São Joaquim, Fumaça IV, Jataí, Irara, Bonfante, Monte Serrat, Santa Fé, hereafter referred to as group (“bundling”).
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 CDM Glossary of terms define "Project Start Date" as the earliest date at which either the implementation or construction or real action of a CDM project activity begins. For the proposed project activity, the DOE has validated the project start date as 30/06/2004, date of signature of the PPAs with the power plants included in the project activity. The DOE is requested to further substantiate (a) how the defined project start date as 30/06/2004 i.e. date of signature of the PPAs with the power plants included in the project activity is in line with the definition of project start date as contained under "the CDM Glossary of terms", and (b) whether there were any real action towards the project implementation or construction before the defined start date as signature of the PPAs. Please refer to VVS version 9.0, paragraph 114. 2) The validation report in section D.8.6 contains a table of milestones to demonstrate that continuous and real actions were taken to secure the CDM status for the project activity. However, it appears that the evidences supporting milestones 11 (01/06/2007) to 16 (26/05/2010) are internal communications and related documents from Eletrobrás related to PROINFA and not specific to the power plants included in the project activity. Even milestones 5 to 10 would not be suitable neither for the same reasons. The DOE is requested to substantiate how it has validated that these internal communication evidences meets the requirements as defined under para 29(b), footnote 7, of PS, version 9.0.  In the event that these internal communications not being considered suitable to substantiate the continuous and real actions to secure CDM status for the project activity, there will be gap of more than 4 (four) years, between milestones 10 (17/01/2006) to 17 (31/08/2010). Further, the DOE is also requested to substantiate how it has validated that milestones 11 to 16 are concrete evidences to  support continuous and real actions undertaken to secure the CDM status for the projecte activity, determined for each power plant, and how the time gap between the milestones presented in table D.8.6 of the validation report comply with the requirements from paragraphs 117 to 119 of VVS - version 9.0. Please refer to VVS version 9.0 - paragraphs 117, 118 and 119 PS version 9.0 - paragraph 29(b). 3) The CDM arquitecture was not designed to deal with a Large Scale CDM project consisting on several independent hydropower plants combined together in one PDD. The CDM does explicitly consider only the possibility for binding SSC projects together in one PA, however still having to fulfil the rules for SSC projects. In contrast, there are no rules defined for bundles of projects to form a LSC CDM Project. Same applies to the additionality tool. The methodology ACM0002 in par. 3 stipulates that it is applicable to grid-connected renewable energy power generation project activities that(a) Install a Greenfield power plant. The DOE therefore is requested to further substantiate why the Project as a bundle of different hydropower plants meets the requirements of methodology ACM0002 and additionality tool that has been designed for single Projects only. 4) The tariff used as input parameter for the investment decision as 76.92 R$/MWh is based on an Energy Auction conducted by the Brazilian Government in 2003 and validated by the DOE. However, there is a floor price defined as 117,02 R$/MWh in the Rule MME 45/04of 2004 applicable to all hydroprojects applying PROINFA. Therefore, the DOE has to further substantiate how it has validated the tariff used for the investment analysis to comply with Para 11 of the investment analysis tool, Version 7, i.e., was a valid input parameter applicable at the time of the investment decision
Date	13 Feb 17