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	3195
Title of the proposed CDM project activity/PoA submitted for registration	Shaqu Coal mine CMM to power generation Phase 2 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. The DOE is requested to further substantiate how it validated the benchmark of 10%, as the observed benchmark for power sector in China is 8%, in line with VVM v1.1 paragraph 111. 2. The DOE is requested to further substantiate: a) the suitability of the O&M cost as it only crosschecked one component of the cost (water); and b) the suitability of the electricity tariff as it is not clear whether it considered the tariff subsidy of 0.25RMB/kWh, applicable to power generated from CMM. In doing so, please refer to VVM v1.1 paragraph 112 c. 3. The DOE is requested to confirm if all applicable government subsidies have been considered such as tax exemptions (income tax holiday) in line with VVM v1.1 paragraph 112 c. 4. The DOE is requested to further explain how it validated the continuation of CMM venting to be appropriate as the baseline scenario considering the enforcement of the national regulation to utilise CMM from January 2010 (Emission Standard of Coalbed Methane/Coal Mine Gas, 2008). In doing so please refer to VVM v1.1 paragraph 83 and ACM 0008 v6, page 6. 5. The DOE shall further justify the elimination of alternative scenario to utilise CMM for additional heat supply in line with ACM0008 v6, pages 7-8. In doing so, specifically indicate the prohibitive barriers or apply investment comparison.
Date	04 Oct 10