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	3044
Title of the proposed CDM project activity/PoA submitted for registration	Jianli Kaidi Biomass Power Project
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. Further clarification is required on how the DOE has validated the suitability of input values in line with the version 1.1 of VVM (paragraphs 109 a, b and 111 c), particularly the: (a) lower operational hours than other similar projects (e.g., project 2230 applies 6,975 hours); (b) net electricity supplied to the grid and auxiliary consumption; (c) heat price; (d) if heat price includes the cost of the pipeline for transportation of steam to offsite location or/and the capital cost of the baseline coal fired boiler; (e) electricity tariff; and (f) higher O&M cost in comparison to the GSP PDD. 2. The DOE is requested to provide further clarifications on how they have validated baseline scenario is appropriate for the project, given that: (i) the DOE has not explained the contradiction that the biomass residues are either dumped or left to decay in absence of the project activity and at the same time carry a purchase price as applied in the investment analysis; (ii) the baseline alternative H6 has not been sufficiently substantiated; (iii) it is not clear that heat, in absence of project activity, would have been generated from coal and not from any other less carbon intensive fossil fuel or renewable sources; (iv) all the users of steam have not been identified and it is not clear whether PP has control over all the users of the steam; and (v) there is an uncertainty that the: (a) heat displaced will not change/vary with the identification of user of the steam; (b) residual life of the boilers displaced in the baseline would be sufficiently large so that they will not be replaced anyway on its own; (c) the project boundary is steady and will not change with the identification of user/ consumer of the steam; and (d) forecasted baseline emissions claimed from heat are conservative. 3. The methodology ACM0006 (version 6) on page 6 and 7 requires the PDD to document the type and capacity of the new/existing boilers and the types and quantities of fuels used/would be used in absence of the project activity. The PDD and the Validation report does not mention how this requirement is complied for both project site as well as end-users of steam in the project boundary. 4. The DOE is requested to further clarify that monitoring of the heat at generation end and not at the user end will result in real, conservative and actual emission reductions.
Date	11 Feb 10