Dapein(1) Hydropower Project in Union of Myanmar
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Host party(ies) China
Myanmar
Methodology(ies) ACM0002 ver. 12
Standardised Baselines N/A
Estimated annual reductions* 677,937
Start date of first crediting period. 01 May 11
Length of first crediting period. 7 years
DOE/AE JCI
Period for comments 05 Feb 11 - 06 Mar 11
PP(s) for which DOE have a contractual obligation Cleantec Development PCC
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 (436 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
1.	Why barrier analysis is not discussed in the PDD. If there is no barrier, then it should be mentioned in the PDD. 
2.	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.
3.	How benchmark is calculated and how IRR is calculated is not discussed at all in the PDD.
4.	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. 
5.	Whether PLF includes machine shutdown, machine availability. Whether grid availability is accounted for in the calculation of gross generation. To my surprise, critical parameter like PLF is missing from the PDD. How DOE has allowed this. 

6.	Common practice analysis should be based on EB 39 Annex 10 (Additionality tool). Each step of common practice analysis should be fulfilled as per tool.

7.	Emission reduction calculation should be based on EB 50 Annex 14 “Tool for emission factor for the electricity system.


Submitted by: Toni

•	Benchmark has been taken from FSR, it has to be calculated / taken from public domain.

•	Tax rates - both China and Myanmar adopted.

•	Interest rate tax has been taken from FSR. Relevant guidance to be applied.

•	Financial sheets not provided, but from the PDD the following are the indicative queries. Detailed queries can be sent after the receipt of the same.

•	Pre-Tax IRR calculated, Is it Project IRR (or) Equity IRR

•	Basis for taxation to be justified since it involves dual effect
Submitted by: mathew


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