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	5521
Title of the proposed CDM project activity/PoA submitted for registration	Waste Heat Recovery and Utilization for Power Generation at Lucky Cement Limited, Karachi Plant
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) 1.The DOE shall further substantiate the suitability of input values used in the investment analysis, in particular: a)Cost of baseline fuel (NG,HFO,diesel) used in the IRR calculation as there is no information provided in the VR. The DOE is requested to provide the details on the how it validated the same based on  objective evidence  . b)the appropriateness of the methods in determining the escalation rates given that the escalation rate of the O&M costs and overhaul cost is based on historical data (page 36 of the validation report) whereas the escalation rates of the baseline fuel prices are based on future anticipation (page 38 of the validation report); (ii) the source of the yearly inflation rates in the website of inflationdata.com (row 15 of table "Basic Info_AEO06" in spreadsheet "5521_Enclosure.xls") used in calculating the escalation rates of baseline fuel prices is not specified. c) The DOE is also requested to clarify whether these yearly inflation rates are applicable to the baseline fuels in Pakistan; . Please refer to paragraph 111 (a) and (b) of VVM version 1.2.. 2) The DOE shall clarify how it validated the  project to be applicable under A.M.S  III-Q version 4  which states that "A facility that is existing on the starting date of the project activity (see definition in paragraph 67 of the EB 41 meeting report) as per footnote 1 of the methodology given that Kiln G started operation in January 2009 which is after the start date of the project is May 2008. Please refer to Footnote 1,AMS III-Q version 04.. 3) The DOE is requested to clarify how it validated the baseline emissions as per Footnote 1 of AMS III-Q ver 4 which states that “all options for demonstrating the use of waste energy in the absence of a CDM project activity shall be based on historic information and not on a hypothetical scenario” given that the baseline emissions for the kilns is not based on historical data but is a hypothetical figure based on design capacity. Please refer to footnote 1 of AMS III-Q version 04. The PDD and the VR states that Kiln E,F and G  has a clinker production capacity of 3300 Tons per Day (TPD) whereas all excel worksheet calculations refer to the capacity as 3000  Tons per Day (TPD). Please refer to Footnote 1 ,AMS III-Q version 04..
Date	21 Jan 13