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	10016
Title of the proposed CDM project activity/PoA submitted for registration	Use of biomass as an alternative fuel for the production of Calcium Oxide
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 how it has validated the suitability of the investment costs of the project activity, since: (a) It is not clear whether the investment costs applied in the investment analysis are the incremental investment costs compared with baseline scenario, considering that: (i) for the new 600 tpd kiln, both baseline scenario and project scenario would involve installation of a new kiln; and (ii) the investment analysis has been conducted based on the marginal effect of the project activity (for example, revenue comes from the savings of fuel costs due to the fuel switch from baseline scenario to project scenario). In doing so, a breakdown of the investment costs shall also be provided, in which each component of the investment costs can be illustrated, in particular the investment costs due to the installation of the new 600 tpd kiln. (b) The references used for cross-checking appears to be either same or internal document, which is not in line with paragraph 129(b) of VVS version 9 which requires using third-party or public available sources for cross-checking. Please refer to paragraph 129 (a) & (b) of VVS version 9. (c) Moreover, the investment analysis considers a price for the Agroindustrial Residues of USD 43.84 /ton, which is 40% of the price considered for Petcoke. The PDD states on its page 5 that these residues are otherwise sent to the landfill. Therefore, it has to be further substantiated how realistic is that these residues reach such a high market price (the IRR value when considering a price of cero is 30%). According to the validation report, the reference provided for justifying this price was cited as “quotation of forestry residues”. The DOE is therefore requested to further justified how the price of agroindustrial residues has been validated, considering that the mentioned validation source refers to the price for forestry products and not to agroindustrial residues. Furthermore, the DOE is requested to validate this input value according to paragraph 129(b) of VVS version 9, which requires the use of third party or public available sources. 2) The DOE shall further substantiate how it has validated the suitability of the operational costs (project activity costs) in the investment analysis, as it is not clear whether/how the savings of operational costs in the baseline scenario have been considered in the investment analysis, considering that the investment analysis has been conducted based on the marginal effect of the project activity (for example, revenue comes from the savings of fuel costs due to the fuel switch from baseline scenario to project scenario). In particular, the savings of electricity costs due to fossil fuel preparation in the baseline scenario (e.g. grinding of pet coke) and the savings of transportation costs of baseline fossil fuels. Furthermore the amount of Calcium Oxide considered for the yearly production as stated in the PDD: 340,000 tons, is not consistent with the amount considered for the investment analysis in the excel table submitted: 345,000 tons.Please refer to paragraph 129 (a) of VVS version 9.
Date	12 Nov 15