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	3486
Title of the proposed CDM project activity/PoA submitted for registration	Goiandira, Pedra do Garrafão, Pirapetinga and Sítio Grande Small Hydropower Plants Project Activity
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 is requested to explain how it has validated the suitability of the “discount factor”/inflation rate applied in the four IRR calculations in order to obtain the “Project IRR R$ Constant” reported in the IRR calculation sheets in line with the requirements of the VVM v.1.01 para. 109 (a), (b) and (d). 2. The DOE is requested to justify how it has validated the values used for the WACC calculations were valid and applicable at the time of the investment decision, as per EB 51 Annex 58 para.6. The DOE should further validate the appropriateness of considering the American inflation rate into the WACC calculations, the “other risks” and the calculations presented in the WACC “sensitivity” spreadsheets. 3. The DOE is requested to substantiate the suitability of the net electricity generation of the projects reported, as the values mentioned in the Validation Report and PDD are not consistent with the ones used in the investment analyses (98,105 MWh/y in the spreadsheet versus 98,938 MWh/y for Pedra do Garrafão, 171,723 MWh/y versus 169,979, 170,445 or 27,976 for Sítio Grande, 149.539 MWh/y versus 147,912, 74,159 or 148,317 for Goiandira and 100,690 Mwh/y versus 99,709 or 99,436 for Pirapetinga). 4. The DOE is requested to further substantiate the common practice analysis, in particular: why only projects which started operation from 2005-2007 and with a capacity until 30MW have been included in the analysis and why only three projects have been discussed in Sub-Step 4-b given the results of the previous analysis (where in the regions five have been identified as not receiving incentives).
Date	18 Dec 10