VALIDATION REPORT SAIHANBA EAST MW WINDFARM PROJECT IN CHINA REPORT NO REVISION NO. 01 DET NORSKE VERITAS

Transcription

1 VALIDATION REPORT SAIHANBA EAST MW WINDFARM PROJECT IN CHINA REPORT NO REVISION NO. 01 DET NORSKE VERITAS

2 DET NORSKE VERITAS VALIDATION REPORT Date of first issue: Project No.: Approved by: Organisational unit: Michael Lehmann Technical Director Client: Carbon Resource Management Ltd. DNV Certification, International Climate Change Services Client ref.: Ms Qian Yiwen Summary: Det Norske Veritas Certification Ltd. (DNV) has performed a validation of the Saihanba East 45.05MW Windfarm Project in China on the basis of UNFCCC criteria for the CDM, as well as criteria given to provide for consistent project operations, monitoring and reporting. UNFCCC criteria refer to Article 12 of the Kyoto Protocol, the CDM modalities and procedures and the subsequent decisions by the CDM Executive Board. This validation report summarizes the findings of the validation. The validation consisted of the following three phases: i) a desk review of the project design, baseline and monitoring plan, ii) follow-up interviews with project stakeholders and iii) the resolution of outstanding issues and the issuance of the final validation report and opinion. In summary, it is DNV s opinion that the Saihanba East 45.05MW Windfarm Project, as described in the project design document version 3.2 dated 27 July 2006, meets all relevant UNFCCC requirements for the CDM and correctly applies the approved baseline and monitoring methodology ACM0002 (version 06). Hence, DNV requests the registration of the Saihanba East 45.05MW Windfarm Project as a CDM project activity. Report No.: Subject Group: Environment Indexing terms Report title: Key words Service Area Saihanba East 45.05MW Windfarm Project Climate Change Verification Kyoto Protocol Validation Market Sector Clean Development Renewable Energy Mechanism Work carried out by: Hao Xiang Jiang Xin Wang No distribution without permission from the client or responsible organisational unit Work verified by: Wilson Tang Date of this revision: Rev. No.: Number of pages: free distribution within DNV after 3 years Strictly confidential Unrestricted distribution 2002 Det Norske Veritas AS All rights reserved. This publication or parts thereof may not be reproduced or transmitted in any form or by any means, including photocopying or recording, without the prior written consent of Det Norske Veritas AS. Head Office: Veritasvn. 1, N-1322 HØVIK, Norway

3 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT Table of Content Page 1 INTRODUCTION Validation Objective Scope Description of Proposed CDM Project 1 2 METHODOLOGY Review of Documents Follow-up Interviews Resolution of Clarification and Corrective Action Requests 5 3 VALIDATION FINDINGS Participation Requirements Project Design Baseline Determination Additionality Monitoring Plan Calculation of GHG Emissions Environmental Impacts Comments by Local Stakeholders 11 4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS VALIDATION OPINION REFERENCES Appendix A Validation Protocol Page i

4 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT Abbreviations BM CAR CDM CEF CER CH 4 CL CO 2 CO 2 e DNV DNA EIA IMPG GHG GWP IPCC IRR LoA MP NCV N 2 O NDRC NGO NEPG ODA OM OMM PDD PPA SEPA UNFCCC VAT Build Margin Corrective Action Request Clean Development Mechanism Carbon Emission Factor Certified Emission Reduction Methane Clarification request Carbon dioxide Carbon dioxide equivalent Det Norske Veritas Certification Ltd. Designated National Authority Environmental Impact Assessment Inner Mongolia Power Grid Greenhouse gas(es) Global Warming Potential Intergovernmental Panel on Climate Change Internal Rate of Return Letter of Approval Monitoring Plan Net CaloricValue Nitrous oxide National Development and Reform Committee Non-governmental Organisation Northeast Power Grid Official Development Assistance Operating Margin Operation and Management Manual Project Design Document Power Purchase Agreement State Environmental Protection Administration United Nations Framework Convention on Climate Change Value-added tax Page ii

5 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT 1 INTRODUCTION Carbon Resource Management Ltd. has commissioned Det Norske Veritas Certification Ltd. (DNV) to perform a validation of the Saihanba East 45.05MW Windfarm Project in China (hereafter called the project ). This report summarises the findings of the validation of the project, performed on the basis of UNFCCC criteria for CDM projects, as well as criteria given to provide for consistent project operations, monitoring and reporting. The validation team consisted of the following personnel: Mr. Hao Xiang Jiang Mr. Wilson Tang Ms. Xin Wang DNV Beijing Team Leader, GHG auditor DNV Beijing GHG auditor, Technical Reviewer DNV Beijing GHG auditor Mr. Michael Lehmann DNV Oslo Energy sector expert 1.1 Validation Objective The purpose of a validation is to have an independent third party assess the project design. In particular, the project's baseline, monitoring plan, and the project s compliance with relevant UNFCCC and host Party criteria are validated in order to confirm that the project design, as documented, is sound and reasonable and meets the identified criteria. Validation is a requirement for all CDM projects and is seen as necessary to provide assurance to stakeholders of the quality of the project and its intended generation of certified emission reductions (CERs). 1.2 Scope The validation scope is defined as an independent and objective review of the project design document (PDD). The PDD is reviewed against the criteria stated in Article 12 of the Kyoto Protocol, the CDM modalities and procedures as agreed in the Marrakech Accords and the relevant decisions by the CDM Executive Board, including the approved baseline and monitoring methodology ACM0002. The validation team has, based on the recommendations in the Validation and Verification Manual /6/ employed a risk-based approach, focusing on the identification of significant risks for project implementation and the generation of CERs. The validation is not meant to provide any consulting towards the project participants. However, stated requests for clarifications and/or corrective actions may have provided input for improvement of the project design. 1.3 Description of Proposed CDM Project The Saihanba East 45.05MW Windfarm Project consists of the construction and operation of a wind park located in south tableland of Zhirui Village, Keshiketengqi County, to the northwest of Chifeng city in Inner Mongolia, China. The objective of the project is to generate renewable electricity using wind power resources and to sell the generated output to the NEPG. The project activity will generate greenhouse gas (GHG) emission reductions by avoiding CO 2 emissions from electricity generation by fossil fuel power plants supplying electricity to NEPG. Page 1

6 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT The project will install a total of 53 wind turbines, each with a power output capacity of 850 kw. The total power capacity, therefore, of the Chifeng Saihanba East Windfarm will be 45.05MW. The proposed project is expected to generate MWh electricity per year, at a capacity factor of 28%. The estimated annual average emission reductions for the first crediting period are tco 2 e. Page 2

7 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT 2 METHODOLOGY The validation consists of the following three phases: I a desk review of the project design, baseline and monitoring plan II follow-up interviews with project stakeholders III the resolution of outstanding issues and the issuance of the final validation report and opinion. In order to ensure transparency, a validation protocol was customised for the project, according to the Validation and Verification Manual /6/. The protocol shows in transparent manner criteria (requirements), means of verification and the results from validating the identified criteria. The validation protocol serves the following purposes: It organises, details and clarifies the requirements a CDM project is expected to meet; It ensures a transparent validation process where the validator will document how a particular requirement has been validated and the result of the validation. The validation protocol consists of three tables. The different columns in these tables are described in Figure 1. The completed validation protocol for the Saihanba East 45.05MW Windfarm Project is enclosed in Appendix A to this report. Findings established during the validation can either be seen as a non-fulfilment of validation protocol criteria or where a risk to the fulfilment of project objectives is identified. Corrective action requests (CAR) are issued, where: i) mistakes have been made with a direct influence on project results; ii) iii) validation protocol requirements have not been met; or there is a risk that the project would not be accepted as a CDM project or that emission reductions will not be certified. The term Clarification (CL) may be used where additional information is needed to fully clarify an issue. Page 3

8 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT Validation Protocol Table 1: Mandatory Requirements for CDM Project Activities Requirement Reference usion Cross reference The requirements the project must meet. Gives reference to the legislation or agreement where the requirement is found. Validation Protocol Table 2: Requirement Checklist This is either acceptable based on evidence provided (), a Corrective Action Request (CAR) of risk or noncompliance with stated requirements or a request for Clarification (CL) where further clarifications are needed. Used to refer to the relevant checklist questions in Table 2 to show how the specific requirement is validated. This is to ensure a transparent Validation process. Checklist Question Reference Means of verification (MoV) The various requirements in Table 1 are linked to checklist questions the project should meet. The checklist is organised in seven different sections. Each section is then further sub-divided. The lowest level constitutes a checklist question. Gives reference to documents where the answer to the checklist question or item is found. Explains how conformance with the checklist question is investigated. Examples of means of verification are document review (DR) or interview (I). N/A means not applicable. Comment The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. Draft and/or Final usion This is either acceptable based on evidence provided (), or a Corrective Action Request (CAR) due to noncompliance with the checklist question (See below).a request for Clarification (CL) is used when the validation team has identified a need for further clarification. Validation Protocol Table 3: Resolution of Corrective Action Requests and Requests for Clarification Draft report corrective action requests and requests for clarifications Ref. to Table 2 Summary of project participants response Final conclusion If the conclusions from the draft Validation are either a Corrective Action Request or a Clarification Request, these should be listed in this section. Reference to the checklist question number in Table 2 where the Corrective Action Request or Clarification Request is explained. The responses given by the project participants during the communications with the validation team should be summarised in this section. This section should summarise the validation team s responses and final conclusions. The conclusions should also be included in Table 2, under Final usion. Figure 1 Validation protocol tables Page 4

9 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT 2.1 Review of Documents The PDD /1/ submitted by Carbon Resource Management Ltd. and additional background documents /2/--/15/ related to the project design and baseline were assessed as a part of the validation. 2.2 Follow-up Interviews In the period of May 2006, DNV performed interviews with project stakeholders to confirm selected information and to resolve issues identified in the document review. Representatives of the Chifeng Municipal Development and Reform Committee, Datang Chifeng Saihanba Wind Power Generation Co., Ltd. (Project owner) and Carbon Resource Management Ltd. were interviewed. The main topics of the interviews are summarised in Table 1. Table 1 Interview topics Interviewed organisation Chifeng Municipal Development and Reform Committee: Mr. Mr. Liu Yu Gui, Deputy director of infrastructural industry section office Datang Chifeng Saihanba Wind Power Generation Co., Ltd.: Mr. Hu Yong Sheng, General manager; Mr. Liu Jun, Director of planning department Mr. Zhang Guo He, Deputy director of management department Carbon Resource Management Ltd.: Mr. Liu Jin Ze, Mr. Shi Xiang Feng, project manager Interview topics Relevant policy and regulations in the development of wind power in the local area Tariff policy in the local area The status of the development of wind power projects in the local area Project background information Technology used for the project Project approval status (incl. EIA approval, CDM project approval status) Stakeholder consultation process Electricity tariff of the project Applicability of selected methodology Baseline determination Project boundary Project additionality Emission reductions calculation Emission reduction monitoring plan 2.3 Resolution of Clarification and Corrective Action Requests The objective of this phase of the validation was to resolve any outstanding issues which needed to be clarified for DNV's positive conclusion on the project design. The Corrective action requests and requests for Clarification initially raised by DNV and presented to the project participants in DNV s draft validation report of 26 May 2006 (rev. 0) were resolved during communications between Carbon Resource Management Ltd. and DNV. Page 5

10 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT To guarantee the transparency of the validation process, the concerns raised and responses given are documented in the validation protocol in Appendix A. Since modifications to the Project design were necessary to resolve DNV's concerns, the Client decided to revise the PDD and resubmitted the PDD on 27 July 2006, reviewing the revised PDD, DNV issued this final validation report and opinion. Page 6

11 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT 3 VALIDATION FINDINGS The findings of the validation are stated in the following sections. The validation criteria (requirements), the means of verification and the results from validating the identified criteria are documented in more detail in the validation protocol in Appendix A. The final validation findings relate to the project design as documented and described in the revised and resubmitted project design documentation of 27 July Participation Requirements The project participants are Datang Chifeng Saihanba Wind Power Generation Co., Ltd of China and Carbon Resource Management Ltd of the United Kingdom. The host Party China and the participating Annex I Party the United Kingdom meet the requirements to participate in the CDM. The DNA of China has issued a Letter of Approval (LoA) /2/ on 29 June 2006, authorizing Datang Chifeng Saihanba Wind Power Generation Co., Ltd. as project participant and confirming that the project assists in achieving sustainable development. The DNA of the United Kingdom has issued a LoA /3/ on 19 July 2006 authorizing Carbon Resource Management Ltd as project participant. The project does not involve public funding, and the validation did not reveal any information that indicates that the project can be seen as a diversion of official development assistance (ODA) funding towards China. 3.2 Project Design The project plans to install a total of 53 wind turbines with a unit capacity of 850 kw. The total generation capacity will amount to MW. Being a renewable electricity project, the project activity will generate greenhouse gas (GHG) emission reductions by avoiding CO 2 emissions from electricity generation by fossil fuel power plants. The technology used for the project (Vestas wind turbines) is transferred from Annex I countries. The wind turbines are deemed more advanced than the current available Chinese wind turbine technology and the technology is deemed to reflect current good practice. The project activity started on 1 October 2006 (the expected commissioning date), the lifetime of the project is expected to be at least 21 years. A renewable crediting period (7 years) is selected, starting on 1 November Baseline Determination Being a grid-connected renewable power generation project activity (wind sources), the project can apply the approved methodology ACM0002 (version 06), Consolidated methodology for grid-connected electricity generation from renewable sources. The project boundary is clearly defined as the site of the project activity and the grid electricity system boundary is defined as the NEPG including the Heilongjiang power grid, Jilin power grid, Page 7

12 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT Liaoning power grid and East Inner Mongolia power grid. There are no significant transmission constraints between the power plants of the NEPG, and there is negligible electricity export or import between the NEPG and other connected grids. The baseline scenario is that the electricity delivered to the grid by the project would have otherwise been generated by the operation of grid-connected power plants and by the addition of new generation sources. This is reflected in the combined margin (CM), i.e. the weighted average of the operating margin (OM) emission factor and the build margin (BM) emission factor. The default weights for wind power projects of 75% OM and 25% BM have been selected according to ACM0002. The NEPG is dominated by coal-fired power plants. It is deemed likely that coal-fired power plants will continue to dominate the power sector due to the local availability of low-cost coal. It is expected that renewable capacity additions will not have significant effects on the mix of the NEPG during the first crediting period /12/. The baseline determination is transparent and reasonable. 3.4 Additionality The project additionality is demonstrated by applying the Tool for the demonstration and assessment of additionality issued by EB. Step 0 Preliminary screening based on the starting date of the project activity: This is not applicable because the crediting period of the project will start after the date of registration. Step 1 Identification of alternatives to the project activity consistent with current laws and regulations: Four alternative baseline scenarios to the project have been identified and discussed: The proposed project activity not undertaken as a CDM project activity, The thermal or hydro and other kinds of power plants with comparable capacity or electricity power generation, Comparable capacity or electricity generation addition provided by NEPG, Continuation of the current situation (no project activity or other alternatives undertaken). It has been adequately demonstrated that comparable capacity or electricity generation addition provided by NEPG is the most realistic alternative consistent with current laws and regulations. Step 2 Investment analysis: A benchmark analysis (Option III) is used to assess the financial viability of the project activity. In China, an IRR of 8 % is regarded as benchmark for investing in hydropower plants, fossil fuel fired plants as well as windfarm projects /13/. The project s IRR without CER revenues is 6.81%. This shows that the project is not financially attractive in absence of CDM benefits. A sensitivity analysis has been carried out with regards to the total investment, annual operational costs and electricity tariff. If the total investment decreases by 7.5%, the IRR of the project could exceed the benchmark. Since the majority of the investment is related to the wind turbines and considering the fact that all wind turbine manufacturers have increased their offers in the last few years, it is not likely that the total investment could decrease by 7.5%. Page 8

13 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT If the tariff increases by 7.5%, the IRR of the project could exceed the benchmark. It is not likely that the tariff could increase by 7.5% for the project because the tariff is strictly regulated in NEPG. The investment analysis and sensitivity assessment confirms that the project activity is not the most financially attractive option. Step 3 Barrier analysis: A barrier analysis has been conducted supplementary to the investment analysis. The main barriers to the project activity include: 1) Investment barrier. DNV was able to verify that the investment cost per kw of this project (10587 RMB/kW) is much higher than that of coal fired units (typically around 5000 RMB/kW) in China, which leads to higher investment risk and more difficulty in obtaining commercial loans or attracting foreign capital. 2) Technology barrier. The region where the project is located is isolated and underdeveloped. There is a lack of infrastructure such as roads, reliable electricity, communication and transportation. The project sponsor will have to develop these facilities before the implementation of the project. In addition, since the Chinese wind power industry is still in early stage of development, the domestic technology is not able to entirely meet the requirement of the project. The technology applied in the proposed project is transferred from an Annex I country and is not available in the domestic market. The project developer also needs skilled and trained labour to operate and maintain the technology. 3) Tariff barrier. The variability of the tariff offered by NEPG has been clearly described in the PDD. There was no final approved feed-in tariff when the project activity started construction because the tariff will be regulated finally by NEPG. The project thus faces a financial risk since the tariff is not yet known. Step 4 Common practice analysis: The common practice analysis shows that the most of the existing wind farm projects are demonstration projects funded by international low interest loans or national soft loans or receive favourable electricity tariffs. Besides these, all other similar projects in Inner Mongolia are implemented as CDM activities. Documentation supporting these assertions has been verified /14/. DNV was able to verify that the Saihanba North 45.05MW Windfarm Project was not a common practice in the area. Step 5 Impact of CDM registration: The investment analysis shows that the potential benefit of the CDM will increase the project s IRR from 6.81% to 8.04% and will thus increase investment returns and reduce investment risks. Given the above, it is sufficiently demonstrated that the project is not a likely baseline scenario and that emission reductions are hence additional to what would otherwise have occurred. 3.5 Monitoring Plan The project applies the approved monitoring methodology ACM0002 Consolidated monitoring methodology for zero emissions grid-connected electricity generation from renewable sources. The selected monitoring methodology is justifiably applicable for the project activity as it involves grid-connected renewable power generation using wind energy. Page 9

14 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT The combined margin emission factor is determined ex-ante based on the most recent information available. Hence, only electricity generated and sold to the grid will be monitored. The net electricity generated from the project will be measured on an hourly basis and recorded on a monthly basis. This data will be cross verified against the sales receipt from the grid. Leakage accounting is not required under ACM0002 and thus has not been considered for the project. Monitoring of sustainable development indicators is not required by the Chinese DNA. The environmental impacts are considered minor and will be monitored by the local environmental authority during the project lifetime. The project s operation and management manual includes: /15/ A description of the responsibilities and authorities for project management, Procedures for monitoring and reporting, and QA/QC procedures, A description of the installation of metering equipment, Procedures for the calibration of metering equipment, A description of training and maintenance needs. Detailed procedures have been developed and the implementation of these will likely enable subsequent verification of the project s emission reductions. 3.6 Calculation of GHG Emissions There are no emissions from the project which is a renewable energy project. Auxiliary energy used for the operation of the plant is deducted from the generation of the electricity from the plant itself. For the calculation of the OM emission factor, the simple OM emission factor calculation method is selected due to limited data availability. Following the CDM EB guidance, the average emission factor for the grid for each fuel type is calculated ex-ante based on a 3-year full generation-weighted average of the most recent statistics available (data available for 2002, 2003, and 2004 at the time of PDD submission). The simple OM emission factor is calculated as tco 2 /MWh. For the calculation of the BM emission factor, a value of 320 g standard coal/ kwh is used to calculate the CO 2 factor following the CDM EB guidance on the applicability of AM0005 and AMS-I.D in China. This emission factor represents an appropriate efficiency level of the best technology commercially available in the NEPG and is thus a conservative proxy or determining the BM. The capacity additions of 23.28% from the years 1997 to 2004 have been the basis for determining the BM emission factor. By applying the relative capacity addition of different power generation technologies, the BM emission factor is calculated ex-ante as 0.775t CO 2 /MWh. The local value of GJ/ t standard coal, the IPCC default value of 25.8 tc/tj and carbon oxidation factor of 98% for coal are used to calculate the OM and BM emission factors. The weights ω OM and ω BM are selected as 0.75 and 0.25, respectively, as stipulated for wind project by ACM0002 (version 06). The combined margin of tco2/mwh is fixed ex-ante for the entire first crediting period. Page 10

15 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT The data used to calculate OM is derived from the China Energy Statistical Yearbooks of the years 2002 to The data used to calculate the BM is derived from China Electric Power Yearbooks of the years 1997 to These are the most recent statistics available at the time of PDD submission. The GHG calculations are complete and transparent, and their accuracy has been verified. The NEPG includes the Heilongjiang power grid, Jilin power grid, Liaoning power grid and East Inner Mongolia power grid. While specific generation data is available for the Heilongjiang, Jilin and Liaoning power grid, no specific generation data is available for the East Inner Mongolia grid (Humeng, Tongliao and Chifeng district grids). Since the data presented in the China Energy Statistical Yearbook and the China Electric Power Yearbook is for provinces and not from power grid, there is only data available on electricity generation in the province of Inner Mongolia, which comprises two separate grids, i.e. the East Inner Mongolia grid and the West Inner Mongolia grid. Due to the lack of specific data for the East Inner Mongolia grid, this grid was excluded in the determination of the OM and BM emission factor of the NEPG. The East Inner Mongolia grid predominantly consists of coal-fired power plants with higher CO 2 emission than the other grids. By comparing the calculation results of including and excluding data for the whole Inner Mongolia province, the exclusion of the impact of the East Inner Mongolia grid on the calculation of the grid emissions factor for the project was found to be conservative. 3.7 Environmental Impacts An Environmental Impact Assessment (EIA) has been conducted according to Chinese law & regulation. The potential environmental impacts have been sufficiently elaborated in the PDD. No significant negative environmental impacts are expected from the project activity. The Environmental Protection Bureau of Inner Mongolia Autonomous Region has approved the project activity in April Comments by Local Stakeholders The project developer carried out consultation in December 2005 and January This includes inviting different stakeholders from the local community, the local government and the local villagers. There were no adverse comments on the project activity and all comments are supportive of the project. A summary of comments was provided and reviewed by DNV. 4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS The PDD of 6 April 2006 was made publicly available on DNV s climate change website ( and Parties, stakeholders and NGOs were through the CDM website invited to provide comments during a 30 days period from 8 April 2006 to 7 May No comment was received during this period. Page 11

16 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT 5 VALIDATION OPINION Det Norske Veritas Certification Ltd. (DNV) has performed a validation of the Saihanba East 45.05MW Windfarm Project in China. The validation was performed on the basis of UNFCCC criteria for the Clean Development Mechanism and host country criteria, as well as criteria given to provide for consistent project operations, monitoring and reporting. The review of the project design documentation and the subsequent follow-up interviews have provided DNV with sufficient evidence to determine the fulfilment of stated criteria. The host Party is China and the participating Annex I Party is the United Kingdom. Both Parties fulfil the participation criteria and have approved the project and authorized the project participants Datang Chifeng Saihanba Wind Power Generation Co., Ltd and Carbon Resource Management Ltd. The DNA from China confirmed that the project assists in achieving sustainable development. The project correctly applies ACM0002 Consolidated baseline methodology for grid-connected electricity generation from renewable sources. By generating renewable energy which will displace grid electricity, the project results in reductions of CO 2 emissions that are real, measurable and give long-term benefits to the mitigation of climate change. It is demonstrated that the project is not a likely baseline scenario. Emission reductions attributable to the project are hence additional to any that would occur in the absence of the project activity. The total emission reductions from the project are estimated to be on the average tco 2 e per year over the selected 7 year crediting period. The emission reduction forecast has been checked and is deemed likely that the state amount is achieved given that the underlying assumptions do not change. The monitoring methodology ACM0002 has been correctly applied and the monitoring plan sufficiently provides for collection of data to determine the project s emission reductions. Adequate training and monitoring procedures have been implemented. In summary, it is DNV s opinion that the Saihanba East 45.05MW Windfarm Project in China, as described in the PDD version 3.2 dated 27 July 2006,, meets all relevant UNFCCC requirements for the CDM and all relevant host country criteria and correctly applies the baseline and monitoring methodology ACM0002 (version 06). DNV thus requests the registration of the project as a CDM project activity. Page 12

17 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT REFERENCES Documents provided by the project proponent that relate directly to the project: /1/ Carbon Resource Management and China Datang Corporation: Project Design Document for the Saihanba East 45.05MW Windfarm Project, version 2.7 of 6 April 2006, version 3.1 of 18 July 2006, and version 3.2 of 27 July /2/ Letter of Approval issued by DNA of China on 29 June /3/ Letter of Approval issued by DNA of UK on 19 July /4/ The feasibility study report of Saihanba East 45.05MW Windfarm Project of March 2005 and the approval letter by Provincial Development and Reform Commission of Inner Mongolia in May /5/ Saihanba East 45.05MW Windfarm Project environmental impact assessment report of March 2005 and the approval letter by Environmental Protection Bureau of Inner Mongolia in April Background documents related to the design and/or methodologies employed in the design or other reference documents: /6/ International Emission Trading Association (IETA) & the World Bank s Prototype Carbon Fund (PCF), Validation and Verification Manual, /7/ ACM 0002 Approved methodology, Consolidated methodology for grid-connected electricity generation from renewable sources, version 06 of 3 March /8/ CDM Executive Board, Tool for the demonstration and assessment of additionality, version 02 of 28 November /9/ China Electric Power Yearbook 2001, 2002, 2003, 2004 and /10/ China Energy Statistical Yearbook /11/ Revised 1996 IPCC Guidelines for National Greenhouse Gas Inventories. /12/ China Electric Power Yearbook Pg 474 /13/ State Power Corporation of China. Interim Rules on Economic Assessment of Electrical Engineering Retrofit Projects. Beijing: China Electric Power Press, /14/ /15/ Operation and management manual, issued by Datang Chifeng Saihanba Wind Power Generation Co., Ltd. Persons interviewed during the validation, or persons who contributed with other information that are not included in the documents listed above: /16/ Datang Chifeng Saihanba Wind Power Generation Co., Ltd.: Mr. Hu Yong Sheng, general manager; Page 13

18 DET NORSKE VERITAS Report No: , rev. 01 VALIDATION REPORT Mr. Liu Jun, director of planning department; Mr. Zhang Guo He, deputy director of management department /17/ Chifeng Municipal Development and Reform Committee: Mr. Liu Yu Gui, deputy director of infrastructural industry section office /18/ Carbon Resource Management Ltd.: Mr. Liu Jin Ze, Mr. Shi Xiang Feng, project manager /19/ China DaTang Group: Ms. Yang Si Yun, CDM coordinator of development and planning department /20/ DaTang Cweme CDM Office: Mr. Guo Wei, Ms. Jiang Yu Qi, project manager, DaTang Cweme CDM Office - o0o - Page 14

19 DET NORSKE VERITAS APPENDIX A CDM VALIDATION PROTOCOL

20 Table 1 Mandatory Requirements for Clean Development Mechanism (CDM) Project Activities Requirement Reference usion Cross Reference / Comment 1. The project shall assist Parties included in Annex I in achieving compliance with part of their emission reduction commitment under Art The project shall assist non-annex I Parties in achieving sustainable development and shall have obtained confirmation by the host country thereof 3. The project shall assist non-annex I Parties in contributing to the ultimate objective of the UNFCCC 4. The project shall have the written approval of voluntary participation from the designated national authority of each party involved 5. The emission reductions shall be real, measurable and give long-term benefits related to the mitigation of climate change 6. Reduction in GHG emissions shall be additional to any that would occur in absence of the project activity, i.e. a CDM project activity is additional if anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the registered CDM project activity 7. In case public funding from Parties included in Annex I is used for the project activity, these Parties shall provide an affirmation that such funding does not result in a diversion of official development assistance and is separate from and is not counted towards the financial obligations of these Parties. 8. Parties participating in the CDM shall designate a national authority for the CDM Kyoto Protocol Art.12.2 Kyoto Protocol Art. 12.2, CDM Modalities and Procedures 40a Kyoto Protocol Art Kyoto Protocol Art. 12.5a, CDM Modalities and Procedures 40a Kyoto Protocol Art. 12.5b Kyoto Protocol Art. 12.5c, CDM Modalities and Procedures 43 Decision 17/CP.7, CDM Modalities and Procedures Appendix B, 2 CDM Modalities and Procedures 29 CAR 1 CAR 1 Table 2, Section E.4.1 Table 2, Section A.3 Table 2, Section E.4.1 The Chinese DNA issued a LoA to on 29 June The DNA of United Kingdom issued an LoA on 19 July Table 2, Section E Table 2, Section B.2 No public funding involved in the project China: National Development and Reform Commission of the Page A-1

21 Requirement Reference usion Cross Reference / Comment 9. The host Party and the participating Annex I Party shall be a Party to the Kyoto Protocol 10. The participating Annex I Party s assigned amount shall have been calculated and recorded 11. The participating Annex I Party shall have in place a national system for estimating GHG emissions and a national registry in accordance with Kyoto Protocol Article 5 and Comments by local stakeholders shall be invited, a summary of these provided and how due account was taken of any comments received 13. Documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts, shall be submitted, and, if those impacts are considered significant by the project participants or the Host Party, an environmental impact assessment in accordance with procedures as required by the Host Party shall be carried out. 14. Baseline and monitoring methodology shall be previously approved by the CDM Executive Board 15. Provisions for monitoring, verification and reporting shall be in accordance with the modalities described in the Marrakech CDM Modalities 30/31a CDM Modalities and Procedures 31b CDM Modalities and Procedures 31b CDM Modalities and Procedures 37b CDM Modalities and Procedures 37c CDM Modalities and Procedures 37e CDM Modalities and Procedures 37f People's Republic of China United Kingdom: Department for Environment, Food and Rural Affairs China ratified the Kyoto Protocol on 30 August The United Kingdom ratified the Kyoto Protocol on 31 May The United Kingdom s assigned amount is 92% of the emissions in The validation has not in detail assessed UK s compliance with article 5 and 7 of the Kyoto Protocol. The UK has in place a national system for estimating GHG emissions and annually submits is most recent inventory to the UNFCCC. Table 2, Section G Table 2, Section F Table 2, Section B.1.1 and D.1.1 Table 2, Section D Page A-2

22 Requirement Reference usion Cross Reference / Comment Accords and relevant decisions of the COP/MOP 16. Parties, stakeholders and UNFCCC accredited NGOs shall have been invited to comment on the validation requirements for minimum 30 days, and the project design document and comments have been made publicly available 17. A baseline shall be established on a project-specific basis, in a transparent manner and taking into account relevant national and/or sectoral policies and circumstances 18. The baseline methodology shall exclude to earn CERs for decreases in activity levels outside the project activity or due to force majeure 19. The project design document shall be in conformance with the UNFCCC CDM-PDD format CDM Modalities and Procedures 40 CDM Modalities and Procedures 45c,d CDM Modalities and Procedures 47 CDM Modalities and Procedures Appendix B, EB Decision Parties, stakeholders and NGOs were invited to provide comments through the CDM website during a 30 days period from 8 April 2006 to 7 May Table 2, Section B.2 Table 2, Section B.2 The PDD is in conformance with the CDM-PDD version 02. Page A-3

23 Table 2 Requirements Checklist Checklist Question Ref. MoV* Comments Draft Final A. General Description of Project Activity The project design is assessed. A.1. Project Boundaries Project Boundaries are the limits and borders defining the GHG emission reduction project. A.1.1. Are the project s spatial (geographical) boundaries clearly defined? A.1.2. Are the project s system (components and facilities used to mitigate GHGs) boundaries clearly defined? A.2. Technology to be employed Validation of project technology focuses on the project engineering, choice of technology and competence/ maintenance needs. The validator should ensure that environmentally safe and sound technology and knowhow is used. A.2.1. Does the project design engineering reflect current good practices? A.2.2. Does the project use state of the art technology or would the technology result in a significantly * MoV = Means of Verification, DR= Document Review, I= Interview Page A-4 /1/ DR Yes, the project site is located in the south tableland of Zhirui village, Keshiketengqi county, Chifeng City in Inner Mongolia east longitude, north latitude. /1/ DR The project boundary is defined as the project site and the selected grid electricity system is the NEPG. /1/ DR Yes, 53 V52-850kW turbines are planned to be installed, providing a total capacity of MW generating electricity of MWh. The electricity will be transmitted to Wudan substation of NEPG via 220kV transmission lines. /1/ DR I Yes. The project uses imported technology, which is more advanced than the current

24 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-5 Checklist Question Ref. MoV* Comments better performance than any commonly used technologies in the host country? A.2.3. Is the project technology likely to be substituted by other or more efficient technologies within the project period? A.2.4. Does the project require extensive initial training and maintenance efforts in order to work as presumed during the project period? A.2.5. Does the project make provisions for meeting training and maintenance needs? A.3. Contribution to Sustainable Development The project s contribution to sustainable development is assessed. A.3.1. Is the project in line with relevant legislation and plans in the host country? A.3.2. Is the project in line with host-country specific CDM requirements? A.3.3. Is the project in line with sustainable development policies of the host country? A.3.4. Will the project create other environmental or social benefits than GHG emission reductions? Draft Final Chinese wind turbine technology available domestically. /1/ DR No /1/ DR I /1/ DR I Yes. Since the equipment is imported and highly advanced and skilled-technicians who are able to operate and maintain the equipments are lacking in China, initial training would be required. Yes. Training will be provided to the staff on-site by the wind turbines supplier at the early stage of the project. On-going technical training will also be provided. Maintenance reserves are planned to be maintained as no spare parts are available locally. /1/ DR Yes. The project has been approved by Inner Mongolia Autonomous Region Development & Reform Commission on May /1/ DR A written approval from the DNA of China has to be provided. /1/ DR A written approval from the DNA of China has to be provided. /1/ DR I Yes, it will contribute to the sustainable development in the region by reducing pollution, creating employment opportunities CAR 1 CAR 1

25 Checklist Question Ref. MoV* Comments B. Project Baseline The validation of the project baseline establishes whether the selected baseline methodology is appropriate and whether the selected baseline represents a likely baseline scenario. and improving the livelihoods of local people. Draft Final B.1. Baseline Methodology It is assessed whether the project applies an appropriate baseline methodology. B.2. B.1.1. Is the baseline methodology previously approved by the CDM Executive Board? B.1.2. Is the baseline methodology the one deemed most applicable for this project and is the appropriateness justified? Baseline Determination The choice of baseline will be validated with focus on whether the baseline is a likely scenario, whether the project itself is not a likely baseline scenario, and whether the baseline is complete and transparent. B.2.1. Is the application of the methodology and the discussion and determination of the chosen baseline transparent? /1/ DR Yes, the project applies the approved consolidated baseline methodology ACM0002 (version 6) for grid connected electricity generation from renewable sources. /1/ DR Yes, the chosen baseline methodology ACM0002 (version 6) is applicable for the proposed project involving an electricity capacity addition from wind energy based electricity generation. /1/ DR Yes. The baseline is determined as continued operation of the existing power plants and the addition of new generation sources to meet electricity demand. * MoV = Means of Verification, DR= Document Review, I= Interview Page A-6

26 Checklist Question Ref. MoV* Comments Draft Final B.2.2. Has the baseline been determined using /1/ DR Yes. conservative assumptions where possible? B.2.3. Has the baseline been established on a projectspecific /1/ DR Yes. basis? B.2.4. Does the baseline scenario sufficiently take into account relevant national and/or sectoral policies, macro-economic trends and political aspirations? /1/ DR Yes. The renewable energy law, sectoral policy and development trends in NEPG have been taken into account B.2.5. Is the baseline determination compatible with the available data? B.2.6. Does the selected baseline represent the most likely scenario among other possible and/or discussed scenarios? B.2.7. Is it demonstrated/justified that the project activity itself is not a likely baseline scenario? * MoV = Means of Verification, DR= Document Review, I= Interview Page A-7 /1/ DR In the Step 2 for calculating the Build Margin emission factor, The latest year with available data for BM calculation is However, the China Electric Power Yearbook 2005 is already available. /1/ DR Yes. Comparable capacity or electricity generation addition provided by NEPG can be taken as a realistic alternative and consistent with current laws and regulations. /1/ /13/ DR I Yes. The project additionality is demonstrated by applying the Tool for the demonstration and assessment of additionality issued by EB. Step 0 Preliminary screening based on the starting date of the project activity: This is not applicable because the crediting period of the project will start from the date of registration. Step 1 Identification of alternatives to the project activity consistent with current laws and regulations: Four alternative baseline scenarios to the project have been identified and discussed. The proposed project activity not CAR 2

27 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-8 Checklist Question Ref. MoV* Comments undertaken as a CDM project activity. The implementation of thermal or hydro and other kinds of power plant with the comparable capacity or electricity power generation. Comparable capacity or electricity generation addition provided by NEPG. Continuation of the current situation (no project activity or other alternatives undertaken). It has been adequately demonstrated that comparable capacity or electricity generation addition provided by NEPG is the most realistic alternative consistent with current laws and regulations. Step 2 Investment analysis: A benchmark analysis (Option III) is used to assess the financial viability of the project activity. In China, an IRR of 8 % is regarded as benchmark for investing in hydropower plants, fossil fuel fired plants as well as windfarm projects. The project s IRR is 6.81% which shows that the project is not financially attractive. A sensitivity analysis has been carried out with regards to the total investment, annual operational costs and on-grid tariff. If the total investment decreases by 7.5%, the IRR of the project could exceed the benchmark. Draft Final

28 Checklist Question Ref. MoV* Comments Since the majority of the investment is related to the wind turbines and considering the fact that all wind turbine manufacturers have increased their offers in the last few years, it is not likely that the total investment could decrease by 7.5%. If the tariff increases by 7.5%, the IRR of the project could exceed the benchmark. It is not likely that the tariff could increase by 7.5% for the project because the tariff is strictly regulated in NEPG. The investment analysis and sensitivity assessment confirms that the project activity is unlikely to be the most financially attractive option. Step 3 Barrier analysis: The barrier analysis has been conducted supplementary to the investment analysis. The main barriers to the project activity include: 1) Investment barrier. DNV was able to verify that the investment cost per kw of this project (10587 RMB/kW) is much higher than that of coal fired units (typically around 5000 RMB/kW) in China, which leads to higher investment risk and more difficulty in obtaining commercial loan or attracting foreign capital. Draft Final * MoV = Means of Verification, DR= Document Review, I= Interview Page A-9

29 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-10 Checklist Question Ref. MoV* Comments 2) Technology barrier. The region where the project is located is isolated and underdeveloped. There is a lack of infrastructure such as roads, reliable electricity, communication and transportation. The project sponsor will have to develop these facilities before the implementation of the project. In addition, since the Chinese wind power industry is still in early stage of development, the domestic technology is not able to entirely meet the requirement of the project. The technology applied in the proposed project is transferred from an Annex I country and is not available in the domestic market. The project developer also needs skilled and trained labour to operate and maintain the technology. 3) Tariff barrier. The variability of the tariff offered by NEPG has been clearly described in the PDD. There was no final approved feed-in tariff when the project activity started construction because the tariff will be regulated finally by NEPG. The project thus faces a financial risk since the tariff is not yet known. Step 4 Common practice analysis: The common practice analysis shows that most of the existing wind farm projects are demonstration projects funded by international low interest loans or national soft loans or receive favourable electricity tariffs. Besides these, al other similar Draft Final