Sujiahekou Hydropower Station
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Host party(ies) China
Methodology(ies) ACM0002 ver. 12
Standardised Baselines N/A
Estimated annual reductions* 880,979
Start date of first crediting period. 01 Jan 12
Length of first crediting period. 7 years
DOE/AE ERM-CVS
Period for comments 23 Mar 11 - 21 Apr 11
PP(s) for which DOE have a contractual obligation Carbon Asset Management Sweden Pte Ltd
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (831 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
1.	As per section B.5, CDM Consultancy agreement with new consultant on 16/05/2008 and Local stakeholders’ meeting on 07/2009. But why did it take such a long time i.e., almost 2 years to sign ERPA for sale of CERs on 15/03/2010. This is clear indication that, the PP was not interested in CDM as the project itself was doing well, i.e., financial viable. Only the consultant (with the help of DOE) to get financial benefits from the PP, have created fake documents. I request the EB has to look into this.
2.	Why PLF is not considered for sensitivity analysis?
3.	PLF should be based on EB48 Annex 11guideline which says The plant load factor provided to banks and/or equity financiers while applying the project activity for project financing, or to the government while applying the project activity for implementation approval; (b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company); But PDD doesn’t demonstrate how PLF has been arrived at.
4.	PDD does not clearly describe the stakeholders involved in Project or the information provided to them. The PDD mentions stakeholders have been invited,” but no details which of these stakeholders actually participated in the process. The PDD does not describe the information provided to stakeholders with sufficient clarity, such as whether adverse environmental impacts were described along with the benefits that were mentioned.
5.	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval.
6.	Time schedule of key events does not speak about the status of project activity and why DOE has taken so long days to just web host the PDD. What is the reason for the delay? This kind of delays shows how serious PP in getting CDM benefits.
7.	Also the chronology of events do not mention any offer letter?.. Then how DoE has made due diligence that the project confirms to UNFCCC guidelines?. 
8.	There are neither links nor documents mentioned for proof of the parameters assumed for the IRR? 
9.	How is PLF estimated to be in accordance to UNFCCC guidelines. 
10.	Also the tariff rate has been assumed based on rate existing at investment decision. But does it account for the escalation and why it has been assumed at a flat rate?
11.	When is the board meeting and date of investment decision? It is not explicitly mentioned in the PDD.  
12.	Why barrier analysis is not discussed in the PDD. If there is no barrier, then it should be mentioned in the PDD. 
13.	Interest rate tax has been taken from FSR. Relevant guidance to be applied
14.	The Meth mentions that if investment analysis option is used, apply the following: 

a)	Apply an investment comparison analysis, as per Step 3 of the .Combined tool to identify the baseline scenario and demonstrate additionality., if more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P3;

b)	Apply a benchmark analysis, as per Step 2b of the .Tool for the demonstration and assessment of additionality. If more than one alternative is remaining after Step 2 and if the remaining alternatives include scenarios P1 and P2.
But PP failed to apply like this. Pls. clarify.

15.	The project is claimed to be run of river hydro project. So the calculation of reservoir is wrong. The criterion 3 is applicable only to pumped storage or accumulation hydro projects. What does reservoir refer to as per PP? 
16.	Layout of power transmission lines from the generation to the consumer with the metering system is not shown. It should include the distance of transmission lines. DOE has to check the meters are installed to monitor electricity generated, the power generated will be connected to Yunnan Grid, and finally to the South China Power Grid (SCPG).
17.	What is the basis of calculation for transmission loss, auxiliary consumption and transformer losses? What is the length of transmission line? 
18.	DOE has to check, what is the exact date of Stakeholder meeting, when it was conducted? Where it was organized? what was the media used for stakeholder consultation process?, information provided in time schedule and section E1 are not matching, clarify.
19.	The proposed project is fully cooked documents so that the DOE has to check that for its genuineness. 
20.	Why DOE is taking up this kind of projects? What due diligence and checks the DOE has done prior to accepting this job? Why not take some fresh projects and try to do good work.

Submitted by: dicken

Comment (348 KB) submitted by: eva filzmoser on behalf of International Rivers, Green Watershed, Global Greengrants Fund, CDM Watch


The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs