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 registration4807
Title of the proposed CDM project activity/PoA submitted for registrationEnergy Efficient Power Generation by Nabha Power Limited
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 electricity tariff used in the investment analysis 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 dated 22 September 2009 submitted as evidence for the investment decision of the CDM (VR, p. 82, 83) says that “...the company will bid for Rajpura Thermal Power Project and revenue from Clean Development Mechanism (CDM) be considered while deciding bidding amount and the board instructed to proceed with bidding considering revenue from sale of Carbon Credits”, in line with the VVM, version 1.2, paragraph 104. In doing so, please clarify whether the tariff submitted to the bidding, which was applied in the investment analysis has considered the CDM revenue.
2. The DOE shall further substantiate how it has validated that the assumed prime lending rate as the benchmark is applicable for the project activity, in line with paragraph 112 of VVM v1.2 and paragraph 12 of EB 51 Annex 58. In doing so, the DOE shall clarify (a) why the lending rate of other development banks has not been considered as the benchmark; and (b) whether the applied benchmark is also applicable to other projects with similar risks.
3. The DOE shall further substantiate the suitability of the coal transportation cost and corresponding escalation rate applied in the financial analysis as it is not clear whether these costs are already included in the fuel costs, in line with paragraph 111 (a) of VVM v1.2. In addition the DOE shall confirm whether there are no other coal sources available near the project site.
4. The DOE shall explain why a sensitivity analysis on the tariff was not conducted, as this is a key parameter to the IRR calculation. In doing so, please refer to VVM, version 1.2, paragraph 111.e.
Date 01 Aug 11