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 registration4419
Title of the proposed CDM project activity/PoA submitted for registrationGrid connected 156.1 MW Combined Cycle Power plant at Hazira, Gujarat
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 clarify how the project starting date complies with the Glossary of CDM terms in line with the VVM (v.1.2) para. 99. In doing so, the DOE is requested to transparently report any action taken by the project participant before 10 May 2000 and explain why such actions cannot be deemed the project starting date. Likewise, the DOE should explain how it has validated the prior consideration of the CDM in line with the “Guidelines on the Demonstration and Assessment of Prior Consideration of the CDM”.
2. The DOE is requested further confirm whether the financial indicator used to demonstrate additionality complies with the applicable methodology, which requires a benchmark analysis, and therefore with the “Tool for the demonstration and assessment of additionality” (Sub-step 2b: option III and Sub-step 2c). In addition, the DOE shall further substantiate how the financial indicator and benchmark selected are in line with the “Guidelines on the Assessment of Investment Analysis” EB 51 Annex 58 para. 12.
3. The DOE is requested to further clarify how it has cross-checked the suitability of the input parameters used in the financial calculations in line with paragraph 111 (a) and (b) of VVM v1.2 in particular: a) the cost per MW of the natural gas power plant, b) the cost per MW of the lignite power plant, c) the total project activity cost, d) the cost of natural gas; e) the cost of coal; f) the calorific values of natural gas, coal and lignite; g) the gross heat rate of natural gas, h) the auxiliary consumption of the natural gas power plant; and i) the O&M cost and its escalation for the natural gas option. In doing so, the DOE should include details on the nature and suitability of the sources of evidence in the context of the project activity.
4. The DOE is requested to clarify how it has validated the cost of lignite used in the financial calculations in line with paragraph 111 (b) of VVM v1.2 given that the document is available in May 2003 which is after the project starting date.
5. The DOE is request to clarify how it has validated the the value of 70:30 for the debt equity ratio in line with the paragraph 111 (b) of VVM v1.2 given that the value of 70:30 is not available in the CERC tariff order as mentioned in the validation report.
6. The DOE shall further explain how the evidence used as sourced of the Coal’s gross heat rate, and auxiliary consumption and O&M costs of the Lignite power plant (i.e.Ministry of Power’s tariff notification dated 30th March 1992) was considered suitable and applicable at the time of investment decision. In addition, the DOE shall explain how the source of the return on equity (i.e. Central Electricity Regulation Committee tariff order 1992) is in line with EB 40 para. 40
7. The DOE is requested to explain how it has validated the appropriateness of 13% for the interest in term loan in line with the paragraph 111 (a) of VVM v1.2 given that the reference used for validating such parameter provides a range of lending rates of 9.75% to 17%.
8. The DOE shall further explain how it has validated the “emission factor for upstream fugitive methane emissions occurring in the absence of the project activity electricity generation” (EFBL,upstream,CH4) in line with paragraph 93 of VVM v1.2 given that the value of 12.87 tCO2/GWh is reported in the PDD and ER spreadsheet; while a value of 10.2 tCO2/GWh is mentioned in the validation report.
Date 10 Sep 11