09:27 04 Apr 25
Registration Request for Review Form
CDM project activity/programme of activities registration request review form (CDM-REGR-FORM) (Version 03.0) |
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Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration | 3225 |
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Title of the proposed CDM project activity/PoA submitted for registration | Energy efficient power generation in Tirora, India |
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: | |
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The following are requirements derived from paragraph 40 of the CDM modalities and procedures: | |
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Additional information | |
1. The DOE shall further substantiate suitability of the identified financial indicator, in particular, how it has validated the availability of the baseline alternative to the project participant in line with additionality section of ACM0013 v2.1. In responding to the ISHC Comment 1.k, the PP has indicated that the PP would have received and assured return of 14% if the PP would have gone for implementation of sub-critical coal power plant, which is not the case for the project activity. The DOE shall justify how they have validated the project participant’s statement. 2. The DOE shall clarify whether the PP has made a performance guarantee or a security deposit to obtain the allotment of coal blocks. In doing so, the DOE shall further substantiate the suitability of the start date of the project activity as per the CDM glossary of terms. 3. The DOE shall further substantiate the suitability of the input values applied in the calculation of the levelised cost of electricity production of each plausible alternative in accordance with paragraph 109 of VVM v1, in particular, specific investment given that the PA has significantly higher specific investment and the baseline alternative has significantly lower specific investment compared to similar CDM projects, return on equity given that the project activity is commissioned through competitive bidding process, price of coal, escalation of O&M price, escalation of fuel price, PLF given that the PA has high thermal efficiency compared to the baseline alternative, auxiliary consumption, GCV of coal given that the GCV in the allocated coal blocks varies from 5343 to 4195 kCal/kg, thermal efficiency given that thermal efficiency of new sub-critical coal power plant can reach to 36% as per the planning commission of India, price of secondary fuel, and why the revenue due to fly ash that will be generated in the project activity and that would have been generated in the baseline have not been considered in calculating levelised cost of the project activity and the baseline. 4. The DOE shall further substantiate the validation of the common practice analysis in line with paragraphs 117-119 of VVM v1, in particular, why Mumbai 6*600 MW super critical Ultra Mega Power project at Sasan and Mumbai 6*600 MW super critical Ultra Mega Power project at Krishnapatnam have not been considered as similar projects. Further the DOE shall clarify difference between the project activity and the projects that are being developed under the umbrella of UMPP. 5. The DOE shall further substantiate exclusion of: (i) alternative 3 given that there are some natural gas projects in the same region applying AM0029, which have indicated surplus of natural gas in the region; and (ii) alternative 4 due to higher fuel cost, which could have incorporated in the levelised cost analysis in line with step 3 of the baseline methodology procedure of ACM0013 v2.1. Further the DOE shall clarify why electricity imports from the Southern grid has not been considered as an alternative to the project activity given that the project activity will be connected to NEWNE grid. 6. The DOE shall further substantiate: (i) contradiction of the spatial extent of the project boundary between the PP (whole India: both NEWNE and Southern grids) and the DOE (NEWNE grid); (ii) why the emission factor of the baseline has been calculated considering the spatial extent of the project boundary as whole India given that the project activity is connected to the NEWNE grid; (iii) use of baseline emission factor calculated in October 2008, which seems to include 2008 energy generation data, given that the investment decision has been made in 02/2008; (iv) suitability of the assumed energy efficiency of the new sub-critical coal power plant (32.63%) in calculating baseline emission factor under option 1 given that the energy efficiency can reach 36% for new sub-critical coal power plant as per planning commission of India; (v) validation of the baseline emission factor calculated under option 2; (vi) validation of weighted average mass fraction of carbon in fuel type (wc,i,y); and (vii) why emission due to the secondary fuel has not been considered as project emission. 7. The DOE is requested to confirm the suitability of the emission reduction calculation in light of clarification by Meth Panel on AM_CLA_0173. 8. The PP and the DOE shall provide further information on similar sub-critical coal power plants implement/or under construction during last few years. Further the DOE shall further clarify whether the project activity is in the capacity expansion plans of the electricity sector. 9. There are some inconsistencies of the SHR and GCV used in calculating CoP and ER, such as, SHR of 2060 kCal/kWh is used when calculating CoP whereas SHR of 2077.6 kCal/kWh is used when calculating ER, GCV of 4895 kCal/kg is used when calculating CoP whereas GCV of 3927 kCal/kg is used when calculating ER. |
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Date | 19 May 10 |
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