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 registration6818
Title of the proposed CDM project activity/PoA submitted for registrationDaegu Metro 3th Urban Railroad
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 reuqested further substantiate the following input values:
a) the discount rate of 5.57 %, considering that two other metro projects (Incheon Line 2, Busan Line 1 extension) with similar financing structure (60% federal and 40% municipal budget) validated by the same DOE have applied 0% discount rate;
b) the total investment: how it has considered the range of 35-89 million USD for metro lines world wide (Bus-systems for the future, IEA, 2002) comparable, considering that: i) the project activity is a mono-rail; and ii) there are several metro projects in the host country and neighboring countries;
c) the operational cost: how it has validated: i) the Operational Cost per Passenger for the project activity, the validation report does not include this information, ii) the selected domestic metro line and overseas metro lines for comparison, and iii) the suitability of the number of employees, salary, electricity cost, electricity consumption and maintenance cost; 
d) the revenue: how it has validated i) the passenger projection, ii) the average fare, in particular, whether the population share of each fare group is likely to represent the passenger share, and iii) whether the non-fare box revenue is included in the revenue, and if so, whether it is subject to the risk rate.
e) the risk rates of 30%, whether all lines in the host country were considered; and
f) the cost of the trial run of 15,600 million KRW, accounted as cash outflow in 2014. Please refer to VVM version 1.2 paragraph 111..

2) The DOE is requested to further substantiate how it has validated the common practice analysis as: a) the set of cities used for comparison includes cities with population less than 1 million while the methodology (page 6) states "If the larger urban zone (LUZ) of the city of the project activity contains more than one million inhabitants, then the set of cities for comparison includes all cities (including the city of the project activity) in the host country with a LUZ that contains more than 1 million inhabitants"; and b) excluding the cities with less than 1 million at the time of the investment decision, there would be  7 cities for comparison out of which 5 cities already have MRTS in place while the methodology states "The proposed project activity is regarded as common practice if MRTS have already been implemented in 50% of the cities in the set of cities for comparison". Please refer to VVM version 1.2 paragraph 120..

3) The DOE is requested to further substantiate how it has validated the identification of the baseline scenario as the DOE has validated only the baseline scenario as per "Step 2:  Investment analysis" of the applied methodology while the methodology (page 5) requires to "conduct an investment comparison analysis for all alternatives that are remaining after Step 1" i.e. "realistic and credible alternative scenario(s) to the project activity that are in compliance with mandatory legislation and regulations. Please refer to VVM version 1.2 paragraphs 83-86, Tool for the demonstration and assessment of additionality version 05.2. Step 1 and 2..

4) The DOE is requested to clarify the value used for the Occupancy Rate of the passenger cars, sourced from Korea Transport Institute, 2010, as it appears that two other similar projects validated by the same DOE have used the same reference but different values of 1.31 and 1.25. Please refer to VVM version 1.2 paragraph 91..
Date 12 Oct 12