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	3690
Title of the proposed CDM project activity/PoA submitted for registration	Greenhouse Gas Emission Reductions Through Super-Critical Technology - Sasan Power Ltd.
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 should further validate the suitability of the electricity tariff in the context of the project activity undertaken without the CDM as a baseline alternative in order to assess the additionality of the project activity, given that the Board Resolution submitted as evidence for the prior consideration of the CDM (VR, p. 64) says that “in view of the proposed reduction in the tariff, earlier assumption of considering CDM benefit for the Sasan project has assumed greater importance for project’s viability” and “Bid has to be submitted with the consideration of CDM revenues”, in line with the VVM v. 01.1, para. 105 (a). 2. The DOE should further explain how it has validated the suitability of the input values to the investment analysis (also used for baseline determination) in line with the VVM v. 01.1para. 110 (b) and para. 95, in particular: a) the project cost, b) the O&M costs, c) the coal price in line with the market price, d) the auxiliary consumption, and e) the debt/equity ratio, loan term, loan interest rate and other financial assumptions, including the evidence used to validate them. 3. The DOE should further validate the sensitivity analysis in line with the VVM para. 110 (e), in particular, (a) why the tariff was not considered in order to determine the robustness of the IRR calculation as the basis of investment decision, which in this case is prior to the awarding of the project, and therefore, the matter of concern is whether the PP could have offered a tariff that would allow the project IRR to reach the benchmark without CDM revenues; and (b) why the variation in the project cost that would make the IRR reach the benchmark is not likely to occur. 4. The DOE should submit a spreadsheet which allows the replication of the investment and sensitivity analyses, in line with EB 51 Annex 58. 5. The DOE should further validate the elimination of alternative 3.1: “Power generation using Natural gas as fuel and Advanced Class combined cycle turbine technology” and alternative 3.2: “Power generation using Natural Gas as fuel with E-Class combined cycle technology” based on natural gas availability, given that there are natural gas based CDM project activities in the country which have established a surplus in natural gas supply. 6. The DOE should further explain why the levelized cost of electricity production for the “Project activity not implemented as a CDM project” (1.14 INR/kWh) is lower than the tariff used in the investment analysis and offered in the bidding (1.19 INR/kWh), which, accordingly, was calculated considering the CDM benefits.
Date	20 Sep 10