Registration Request for Review Form


CDM project activity/programme of activities
registration request review form (F-CDM-RR)
(Version 02.1)

Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration3225
Title of the proposed CDM project activity/PoA submitted for registrationEnergy 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:
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 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 participantís 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.
Date 19 May 10