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	4397
Title of the proposed CDM project activity/PoA submitted for registration	LHSF RE 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 clarify the project description by explaining: a) the on-site heat/ electricity demand, how it is met and how much electricity is exported in: i) the pre-project scenario, ii) the baseline, and iii) the project scenario; and b) the amount of bagasse consumed in: i) the pre-project scenario, ii) the baseline, and iii) the project scenario. In doing so, please refer to VVM version 1.2 paragraph 59. 2. The DOE is requested to explain how it has validated: a) the bagasse price; and b) inclusion of bagasse cost in the project IRR calculation to be appropriate, considering that it is generated at the sugar mill. In doing so, please refer to VVM version 1.2 paragraph 111. 3. The DOE is requested to further substantiate the amount of electricity exported, in particular: a) the difference between the installed capacity (26.75MW) and the export capacities (peak season: 21.78 MW, off-peak season: 24.08MW); b) if any of the electricity generated is used at the sugar mill and if the savings made from it can be accounted as revenue; and c) the amount of heat extracted in the extraction mode during the peak season, how it would be supplied in the baseline, and if the savings made from it can be accounted as revenue. In doing so, please refer to VVM version 1.2 paragraph 111. 4. The DOE is requested to explain how it has validated the O&M costs and the administration costs by providing validation of the source used (“certificate from sugar industry experts”) and the suitability of the values. In doing so, please refer to VVM version 1.2 paragraph 111. 5. The DOE is requested to justify the inclusion of cost of financing (interest on the working capital) in the project IRR calculation. In doing so, please refer to EB 51 annex 58 paragraph 9. 6. The DOE is requested to substantiate how it has validated the common practice analysis, in particular the essential distinctions between the proposed project activity (tariff: INR 2.86/kWh) and the five similar projects identified (tariff: INR 2.25/kWh). In doing so, please refer to VVM version 1.2 paragraph 120 (c). 7. The DOE is requested to explain how it has validated the baseline emissions, in particular: a) the net power generation by the project activity, reported as 106,315 MWh/year based on 26.75MW, 230 days/year, while the net power generation in the investment analysis is assumed as 83,934 MWh based on 21.78MW (180 days/year) and 24.08MW (50 days/year); b) the average net energy efficiency of the electricity generation in the other power plants that would use the bagasse in the absence of the project activity; c) the total power generation at the project site; and d) the historic power generation at the project site. In doing so, please refer to VVM version 1.2 paragraphs 90 and 91. 8. The DOE is requested to explain how it has validated the remaining technical lifetime of the existing boilers and turbines, including the ones retired due to the project activity. In doing so, please refer to EB50Annex15.
Date	20 Jul 11