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 registration4301
Title of the proposed CDM project activity/PoA submitted for registration20.8 MW Grid connected wind electricity generation project at Dhule, Maharashtra
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 further substantiate the inflation rates (7.2% and 8.8% for Suzlon and Micon projects respectively) applied to the calculation of the cost of equity as:
a) the inflation rates for 2005-2009 and 2006-2010 (Suzlon and Micon projects respectively) are actual rates sourced from the International Monetary Fund World Economic Outlook published in 2011 which were not available at the time of the investment decision (project starting dates are 2004 and 2005 respectively) while EB 65 Annex 5 requires to apply either a forecast or target inflation rate for the coming five (5) years from the project starting date, and
b) the inflation rates do not appear to be reflected in the respective equity and project IRR calculations as validated by the DOE (Validation Report, page 15) considering that the increment rates applied to the O&M costs or the tariff are not inflation rates. Please refer to VVM version 1.2 paragraph 112 and EB 65 Annex 5 paragraph 7..

2) The DOE is requested to further substantiate the suitability of the input values to the investment analysis, in particular:
a) how the DOE has crosschecked the project cost for both Micon and Suzlon projects considering that: (i) it is stated that they were crosschecked with the actual costs but the values of the actual costs are not provided, and (ii) the DOE has not explained the significant difference in the unit investment cost between Micon and Suzlon projects which are 66 and 50 million INR/MW respectively;
b) the tariff escalation of 0.15 INR/kWh (constant escalation by 4% of the base tariff of 3.5 INR/kWh) and tariff of 3.5 INR/kWh from the 14th year while the benchmark is inflated by 7.2% and 8.8% annually for the Suzlon projects and Micon project respectively; and
c) PLF of 18.03% for the Suzlon project as oppose to 21.37% for the Micon project while both projects are located in Sakri, Dhule district, State of Maharashtra (21°10'00"- 21°11'13", 74°11’49"-74°19'52") and started within one (1) year difference (September 2004 and August 2005 respectively). Please refer to VVM version 1.2 paragraph 111..

3) The DOE is requested to further justify the criteria chosen for the common practice analysis, in particular, why the capacity was limited to above 15 MW considering that the installed capacity of each sub-projects are below 15 MW (1.25 MW-12.5 MW). Please refer to VVM version 1.2 paragraph 120..
Date 11 May 12