VALIDATION REPORT -VOLUNTARY EMISSION REDUCTION-

Transcription

1 VALIDATION REPORT -VOLUNTARY EMISSION REDUCTION- Soil and More International BV LIBRA/SEKEM COMPOSTING PROJECT Report No: /38 TÜV NORD CERT GmbH JI/CDM Certification Program Langemarckstrasse Essen, Germany Phone: Fax: Date: 2007-September-07

2 Date of recommendation: Report No.: /38 Approved by: Organisational unit: Mr. E. Krupp Client: Soil and More International BV Client ref.: Mr. Bandel Summary: Project Title: Project Participant(s): Applied Standard: Libra/ Sekem Composting project (1) Libra (2) South Pole Carbon Asset Management Ltd. (3) Soil and More International BV TÜV NORD Standard for voluntary emission reductions (TN-CC 001), Relevant CDM rules PDD: Draft version dt ; final version dt Methodological approach: Approved CDM Meth; Combined appr. Meths; Project specific Meth Applied methodologies: Validation Opinion: AMS III.E. Avoidance of methane production from biomass decay through controlled combustion (version 7 dt ) AMS III.F.: Avoidance of methane production from biomass decay through composting (version 4 dt ) has validated the project activity as per the relevant requirements of the TÜV NORD Standard TN-CC 001 and CDM applicable for VER project activities, as well as criteria for consistent project operations, monitoring and reporting. The review of the PDD and additional documents related to baseline and monitoring methodology and the subsequent background investigation was conducted to validate the fulfilment of the stated criteria of the relevant CDM criteria and TN-CC 001. The validation is based on the Project Design Document (PDD), draft version (12 th April 2007) and final version dated 01 st August 2007 Version 2, emission reduction calculation spreadsheet and supporting documents made available to the TÜV NORD JI/CDM CP by the project participant. As a result of the validation, the validation team confirms that: The calculation of the project emission reductions is carried out in a transparent and conservative manner, so that the calculated emission reductions can be achieved within the 7 years (renewable) crediting period. The project additionality is sufficiently justified in the PDD. The monitoring plan is transparent and adequate. As the result of the validation, the validator confirms that the project, as it was described in the project documentation, is in line with all criteria applicable for the validation. Baseline Emissions over crediting period 1,028,609 t CO 2eq Leakage 0 t CO 2eq Project Emissions 9,407 t CO 2eq Total Emission Reduction estimated over crediting period 420,000 t CO 2eq Work carried out by: Rainer Winter Martin Saalmann Katja Beyer Date of this revision Rev. No. Number of pages No distribution without permission from the client or responsible organisational unit Limited distribution Unrestricted distribution Page 2 of 44

3 Abbreviations BAU CR CDM CO 2 CO 2e CP CR EB GHG IPCC kw kwh MW MWh NCV PDD QC/QA UNFCCC VER Business as usual Corrective Action / Clarification Action Corrective Action Request Clean Development Mechanism Carbon dioxide Carbon dioxide equivalent Certification Program Clarification Request CDM Executive Board Greenhouse gas(es) Intergovernmental Panel on Climate Change Kilowatt Kilowatt hour Megawatt Megawatt hour Net Calorific Value Project Design Document Quality control/quality assurance United Nations Framework Convention on Climate Change Voluntary Emission Reductions Page 3 of 44

4 Table of Contents Page 1 INTRODUCTION Objective Scope GHG Project Description Project Scope Project Entities Project location Technical project description VALIDATION TEAM METHODOLOGY Validation Protocol Review of Documents On-site visit and follow-up Interviews Resolution of Clarification and Corrective Action Requests Finalising the report VALIDATION FINDINGS General Description of the Project Activity Project Boundaries Participation Requirements Technology to be employed Contribution to Sustainable Development General Topics Application of Baseline and Monitoring Methodology Baseline Methodology Baseline Scenario Determination Additionality Determination Calculation of GHG Emission Reductions Monitoring Methodology Monitoring Plan Project Management Planning Crediting Period Environmental Impacts Comments by Local Stakeholders VALIDATION OPINION REFERENCES...20 ANNEX : VALIDATION PROTOCOL...24 Page 4 of 44

5 1 INTRODUCTION Soil and More International BV has commissioned the JI/CDM Certification Program (CP) of TÜV NORD CERT GmbH to validate the project: Libra/ Sekem Composting project. with regard to the relevant requirements for VER project activities. 1.1 Objective The purpose of this validation is to have an independent third party assess the project design. In particular the project's baseline, the monitoring plan (MP), and the project s compliance with - the contents of relevant requirements of TN-CC 001; and - other relevant rules, including the host country (Egypt) legislation are validated in order to confirm that the project design as documented is sound and reasonable and meets the stated requirements and identified criteria. Validation is seen as necessary to provide assurance to stakeholders on the credibility of the project and its intended generation of Verified Emission Reductions (VERs). This validation also serves as basis of carrying out the verification of the generated VERs. 1.2 Scope The validation scope is given as an independent and objective review of the project design, the project s baseline study and monitoring plan (based on AMS III.E./ Version 7: Avoidance of methane production from biomass decay through controlled combustion and AMS III.F./ Version 4: Avoidance of methane production from biomass decay through composting ), which is included in the PDD and other relevant supporting documents. The items to be covered by the DOE in the validation process are described below: VER Project Description - Project boundaries - Project design - Predicted project GHG emissions Project Baseline - Baseline methodology - Baseline GHG emissions Page 5 of 44

6 Monitoring Plan - Monitoring Plan methodologies and intervals - Indicators/data to be monitored and reported - Responsibilities - External verification Background investigation and follow up interviews Draft validation reporting with s & CRs, if any Final validation reporting Registration of the project by TÜV NORD JI / CDM Certification Program (JI/CDM CP) of TÜV NORD Cert GmbH The information included in the PDD and the supporting documents were reviewed against the requirements and criteria mentioned above. Currently the project activity is meant to generate Verified Emission Reductions (VER). Thus the UNFCCC criteria for CDM are not fully applied. The following items were excluded in the course of the Validation, Verification and Certification (VVC) process: - Global/local stakeholder consultation process - Assessment of Participation Requirements - Host country requirements/ criteria (e.g. approval procedures) - Sustainable development criteria. The validation is not meant to provide any consulting to the project participant. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the project design. 1.3 GHG Project Description Project Scope The considered GHG project can be classified as a small-scale CDM project in the sector given in Table 1-1 (according to List of Sectoral Scopes of UNFCCC). Table 1-1: Project Scope No. Project Scope 13 Waste handling and disposal Project Entities The following entities are involved in the developing of the project: Page 6 of 44

7 Project Proponent 1: Contact person: Project Proponent 2: Contact person: Project Proponent 3: Contact Person: Libra 3 Belbeis Desert Road Cairo, Egypt Mr. Amr Farouk Tel Fax Amr.farouk@sekem.com South Pole Carbon Asset Management Ltd. Technoparkstrasse Zurich, Switzerland Mr. Christian Dannecker Tel Fax c.dannecker@southpolecarbon.com Soil and More International BV PO Box AH Waddinxveen, The Netherlands Mr. Tobias Bandel Tel Tobias@soilandmore.com Project location Table 1-2: Project location No. Host Country Region: Project location address: Latitude: Longitude: Project Scope Egypt 60 km northeast of Cairo Sekem Farm, El-Katiba, Belbeis, Sharkia ,3 N ,4 E Technical project description The project activity entails composting of agricultural waste (plant residues and animal manure). The material is treated at the project site and is accumulated in piles. The aeration of these piles is ensured by rotation. The estimated amount of emission reductions over the chosen 7-years renewable crediting period is 420,000 tco 2 e for the crediting period January 2007 to December Page 7 of 44

8 2 VALIDATION TEAM The Validation Team was led by - Mr. Rainer Winter. Mr. Winter works at TÜV NORD CERT GmbH as ISO 9001/ Auditor and environmental verifier for EMAS. He is also an approved emission verifier within the European Emission Trading Scheme. Mr. Winter is an authorized JI/CDM assessor and is in charge of the TÜV NORD JI/CDM CP. For this validation he was assisted by: - Mr. Martin Saalmann, TÜV NORD CERT GmbH, is an appointed JI/CDM Expert in the JI/CDM Certification Program of TÜV NORD. - Ms. Katja Beyer, TÜV NORD CERT GmbH, Germany. She is an environmental scientist and works as trainee for the JI/CDM Certification Program of TÜV NORD. The validation report is verified by: - Mr. Eric Krupp. Mr. Krupp works at TÜV NORD as an approved emission verifier within the European Emission Trading Scheme. Mr. Krupp is an authorized JI/CDM assessor and deputy head of the JI/CDM Certification Program of TÜV NORD. 3 METHODOLOGY The validation of the project was carried out from May to August 07. It was divided into two phases: the pre-validation and the validation phase. The pre- validation consisted of the following three phases: A desk review of the PDD (incl. annexes) and supporting documents with the use of a customised validation protocol according to the Validation and Verification Manual /VVM/ ; Back ground investigation and follow-up interviews with personnel of the project proponent, the consultant, legal authorities and other stakeholders; Reporting of validation findings. The draft validation report includes Corrective action and Clarification Requests ( and CR) identified in the course of this validation. A Corrective Action Request is established if mistakes have been made in assumptions or the project documentation which directly will influence the project results, the requirements deemed relevant for validation of the project with certain characteristics have not been met or there is a risk that the project would not be registered or that emission reductions cannot be verified and certified. Page 8 of 44

9 A Clarification Request is issued where information is insufficient, unclear or not transparent enough to establish whether a requirement is met. The final validation started after issuance of proposed corrective action (CA) of these and CR by the project proponent. The validator has assessed the proposed CA with a positive result and after the closure of these and CR the project proponent has issued the final version of the PDD. On the basis of this the final validation report and opinion were issued. 3.1 Validation Protocol In order to ensure consideration of all relevant assessment criteria, a validation protocol was used. The protocol shows, in a transparent manner, criteria and requirements, means of verification and the results from pre-validating the identified criteria. The validation protocol serves the following purposes: - It organises, details and clarifies the requirements that a VER project is expected to meet; - It ensures a transparent validation process where the independent entity will document how a particular requirement has been validated and the result of the determination. The validation protocol consists of two tables: Table 1 (Requirement Checklist); and Table 2 (Resolution of Corrective Action and Clarification Request). The validation protocol is enclosed in Annex to this report. 10 Corrective Action Requests and 7 Clarification Requests were identified. Page 9 of 44

10 3.2 Review of Documents The draft PDD submitted by the Soil and More International BV in May 2007 and supporting background documents related to the project design and baseline were reviewed. Furthermore, the validation team used additional documentation by third parties like technical reports referring to the project design or to the basic conditions and technical data. The documents that were considered during the (pre-) validation process are given in chapter 6 of this report. They are listed as follows: Documents provided by the project proponent (Table 6-1) Background investigation and assessment documents (Table 6-2) Websites used (Table 6-3) List of interviewed persons (Table 6-4) In order to ensure the transparency of the decision making process, the reference codes listed in tables 6-1 to 6-4 are used in the validation protocol and as far applicable in the report itself. 3.3 On-site visit and follow-up Interviews On 13 th May 2007, the TÜV NORD JI/CDM CP performed the on-site visit and validation interviews with the project proponent, project developer and plant operating personnel to confirm selected information and to resolve issues identified in the document review. The key interviewed persons and the main topics of the interviews are summarised in Table 3-1. Table 3-1 Interviewed persons and interview topics Interviewed Persons / Entities Interview topics Project proponent representatives (SEKEM, South Pole Carbon Asset Management, Soil and More International BV) - Chronological description of the project activity - Technical details of the project realisation - Baseline scenario, operation of project activity, technical details of project activity. - Monitoring and measurement equipment - Crediting period and its starting date - Project activity starting date - Operational data technical specification, operational lifetime. - Training and competency of the staff members w.r.t project management, monitoring and reporting - Sources of finance for project activity, barrier of Page 10 of 44

11 Interviewed Persons / Entities Interview topics project activity - Socio-economic issues / benefits because of project - Operation and maintenance - Editorial aspects of PDD - Baseline study and additionality - Details of emissions reduction calculation A detailed list including the functions or designations of the interviewed persons is given in chapter 6 (see Table 6-4). This table also includes reference codes to be used in the validation protocol. 3.4 Resolution of Clarification and Corrective Action Requests In order to remedy any mistakes, problems or any other outstanding issues which needed to be clarified for positive conclusion on the project design, s and CRs were raised. These requests can be resolved or closed out by the project proponent by providing the corresponding response in the column 3 of the table two and submission of revised PDD and supporting documents. In the course of the validation 10 s and 7 CRs were raised. The s / CRs are documented in the annex and addressed in section Finalising the report The draft validation report containing a set of s & CRs was submitted to the project proponents. The project design document was revised addressing the s & CRs issued by TÜV NORD JI/CDM CP. After reviewing the revised and resubmitted project documentation /PDD2/ ; resolving the CRs & s raised and outstanding concerns, TÜV NORD JI/CDM CP issues this final validation report and opinion. Page 11 of 44

12 4 VALIDATION FINDINGS In the following protocol the findings from the desk review of the draft PDD, visits, interviews and supporting documents are summarised. The results are shown in table 4-1: Table 4-1: Summary of and CR issued Validation topic 1) No. of No. of CR General description of project activity (A) (4.1) - Project boundaries (4.1.1) - Participation requirements (4.1.2) - Technology to be employed (4.1.3) - Contribution to sustainable development (4.1.4) - General topics (4.1.5) Project baseline and monitoring methodology (B) (4.2) - Baseline Methodology (4.2.1.) - Baseline scenario determination (4.2.2) - Additionality determination (4.2.3) - Calculation of GHG emission reductions (4.2.4) Project emissions Baseline emissions Leakage Emission reductions - Monitoring Methodology (4.2.5) - Monitoring of (4.2.6) Project emissions Baseline emissions Leakage Sustainable development indicators / environmental impacts - Project management planning (4.2.7) Duration of the Project / Crediting Period (C) (4.3) 1 1 Environmental impacts (D) (4.4) 1 1 Stakeholder Comments (E) (4.5) n/a n/a SUM ) The letters in brackets refer to the validation protocol Page 12 of 44

13 4.1 General Description of the Project Activity Project Boundaries The spatial boundary is clearly defined after closure of B2. The project is located in Egypt. Please refer to chapter of this report. The project s system boundary is described in the project documentation under B.3 of the PDD. The project encompasses the project site (composting treatment facility), a landfill site, illegal waste dumping sides within a radius of 50 km around the composting facility, the areas where the produced compost will be delivered and processed (a radius of about 100 km) and the routes of transport of waste and compost. The project activity encompasses only material which originates from outside of the SEKEM farm Participation Requirements As this project activity is a voluntary offset project the participation of parties is not required. The private entities appointed as project participants are: Libra from Egypt South Pole Carbon Asset Management from Switzerland and Soil and More International BV from the Netherlands Technology to be employed In the project activity biogenic wastes from plantation, stock farming as well as food production is used to produce compost as organic fertilizer. The waste is treated aerobically in piles of about one meter height and breadth. The production leads to a so called Controlled Microbial Compost (CMC). The production is carried out under the license of Soil & More acc. to the S&M Standard Operating Procedures /SOP/ Contribution to Sustainable Development The project activity leads to an increase of additional employment. Furthermore additional income for farmers delivering the waste to the project site is generated General Topics In general the PDD has been duly filled. Nevertheless some mistakes had to be corrected and not all information could have been made available to the validation team at the stage of the draft validation. Thus corresponding Clarification Requests had to be raised. Please refer to A1, A2, CR A1, CR B1. Page 13 of 44

14 4.2 Application of Baseline and Monitoring Methodology Baseline Methodology The applied baseline methodologies are the approved small-scale CDM baseline methodologies AMS III.E. (Version 7) entitled Avoidance of methane production from biomass decay through controlled combustion in conjunction with AMS III.F. (Version 4) Avoidance of methane production from biomass decay through composting. Although it is a composting project AMS III.E. was assessed to be applicable to calculate the baseline emissions. The project proponents chose to apply for a small scale methodology approach even if the project activity could also be assigned to large scale methodologies as the emission reductions per year is above the threshold of 60,000 t CO 2e per year. To follow the small scale approach the annual emission reductions were capped according to the above mentioned threshold Baseline Scenario Determination The waste utilized in the composting facility would otherwise been illegal dumped in the surrounding area, openly burned or delivered to municipal landfills. Alternatives 1 and 3 (Illegal dumping and treatment on municipal landfills) were included in calculating the avoided CH 4 baseline emissions. Both scenarios lead to methane emissions as the biomass is partly treated anaerobically. Though the alternative 3 is the only legal opportunity to treat the waste it has been evidenced by means of an independent Third Party investigation that illegal dumping and open burning is still common practice for a large portion of the material. Thus all three scenarios have been included in the baseline. Waste that is produced during production of food at SEKEM is not considered to be part of the project activity. In the course of the validation B1 was raised Additionality Determination The project participants used the Tool for the demonstration and assessment of additionality (Version 3) as used for large-scale CDM project activity. The arguments to justify the additionality were summarised in table 4-2. This table also includes the assessment of the validation team. Page 14 of 44

15 Table 4-2: Additionality assessment Step 1) Argument PP Assessment of the validation team 1 Four alternatives were identified: (1) Implementation without VER (2) Illegal waste dumping and burning (3) Waste dumping at an official landfill (4) Standard Composting Argument not justified Argument not convincing Argument justified but not decisive Argument justified / significant step passed step not passed not applicable 2 The benchmark of % is above the estimated project IRR of app. 4 %. Thus VER are necessary to overcome the above mentioned benchmark. Argument not justified Argument not convincing Argument justified but not decisive Argument justified / significant step passed step not passed not applicable 3 Investment Barrier: Higher investment costs acc. to other composting concepts avoid an implementation without VER benefits. Argument not justified Argument not convincing Argument justified but not decisive Argument justified / significant step passed step not passed not applicable 3 Technology Barrier: The applied compost concept has high maintenance and monitoring requirements. Argument not justified Argument not convincing Argument justified but not decisive Argument justified / significant step passed step not passed not applicable Argument not justified 4 The project is the first of its kind in Egypt. Argument not convincing Argument justified but not decisive Argument justified / significant step passed step not passed not applicable Assessment of the validation team project is additional project is not additional 1) acc. to Additionality Tool (ver. 03) The project participants identified four alternatives to the project activity: (1) Implementation without VER (2) Illegal waste dumping and burning (3) Waste dumping at an official landfill (4) Standard composting technology Alternative 1, 3 and 4 are in compliance with the laws and regulations of Egypt. Although alternative 2 does not comply with the existing regulations it is common practice and thus remains as alternative. Page 15 of 44

16 In step 3 Barrier analysis the investment barrier as well as the technology barrier is well substantiated. As the project activity is a state of the art technology to produce compost, it leads to higher investments as the identified alternatives. The strong effort to maintain and operate the compost facility in comparison to the alternatives is convincing. This could also be assessed during on-site visit. In conclusion the arguments in step 3 are sufficiently described and therefore this step is passed. Under step 4 it is described that the project activity is the first of its kind in Egypt. Any similar composting projects which do not use the same technology lead to higher emissions as they are partly anaerobic. Thus the project is additional. Nevertheless during the draft validation process B2 was raised and successfully closed Calculation of GHG Emission Reductions Acc. to the final PDD the project is expected to reduce emissions of 420,000 tco 2e over the 7 years crediting period. Baseline Emissions The calculation of the baseline emissions is carried out in line with the applied approved CDM methodology AMS III.E. in a complete and transparent manner. According to the methodology the baseline emissions are calculated with the following key parameters and the corresponding values applied by the project participants. The following table shows the key parameters to calculate the baseline emissions. The values are based on a study of an independent Third Party. /COAE/ Managed landfill Page 16 of 44 Illegal dumping Waste fractions MCF = 1.0 MCF = 0.4 Wood (DOC parameter D) 45 % 20 % Straw (DOC parameter D) 45 % 25 % Coffee residues (DOC parameter C) Fresh green (DOC parameter B) 80 % 10 % 40 % 40 % Manure (DOC parameter B) 15 % 20 % DOC F (default value) F (default value) The quantity of biomass treated under the proposed project activity corresponds to the capacity of the composting facility. The global warming potential of CH 4 as per the IPCC guidelines from 1996 is 21. The complete baseline emissions over the chosen 7 years crediting period are 1,028,609 tco 2e.

17 Project Emissions The project emissions consisting of the emissions due to transport and energy consumption of the composting facilities were calculated in accordance with methodology AMS III.F. (Version 4). The transport of the waste to the composting site was considered with a distance of 27.8 km and a Diesel emission factor of kg CO 2e /km. The projected emissions over the 7 years crediting period are 1,472 tco 2e. The transport of the compost to the soil application sites was considered as per AMS III.F. The total project emissions due to transportation over the 7-years crediting period are 3,514 tco 2e. The project emissions produced due to energy consumption are estimated as 4,422 tco 2e over the crediting period. It includes diesel as well as the electricity consumption of the facilities used on-site. The total project emissions are 9,408 tco 2e. Leakage is not to be considered according to AMS III.E. and AMS III.F. In the course of the validation several /CR have been raised. All raised issues could finally be resolved. Please refer to the list below Monitoring Methodology Regarding the monitoring the same rationale as for the selection of the baseline methodologies applies Monitoring Plan The parameters to be monitored are indicated in section B.7.1 of the PDD. The set of parameters was assessed to be complete and in line with the applied methodologies and the specific requirements of this project activity. The monitoring plan provides for the collection an archiving of all relevant data. The measurement equipment and the measurement methods are clearly described in the monitoring plan. The procedure for calibration & maintenance of monitoring equipment is clearly described as per QA/QC procedure of PDD. Monitoring of leakage emissions is not necessary as leakage is not to be considered for this project activity. Nevertheless B4, B5 and CR B2 were raised and successfully closed Project Management Planning All authorities and responsibilities for the project management are clearly defined. Libra, the operator of the composting site, is using guidelines of the technology Page 17 of 44

18 supplier Soil & More. Further procedures are existing which clearly define the responsibilities. 4.3 Crediting Period The intended crediting period of the project is 7 years (2007 to 2013), renewable. The starting date of the crediting period is 01/01/2007. Since the monitoring is fully established the 1 st of January 2007 is appropriate. Regarding the starting date of the project activity the following C1 and CR C1 were raised. The and CR were successfully closed. 4.4 Environmental Impacts Significant environmental impacts are not to be considered. An official statement by the Industrial Development Authority (Arab Republic of Egypt Ministry of Industry and Trade) confirms that the project activity is in line with the environmental laws /SET/. Nevertheless at the stage of draft validation the CR D1 was raised and finally closed. 4.5 Comments by Local Stakeholders A local stakeholder consultation was not conducted. The project participants decided to proceed with the project without a consultation as the project activity is a voluntary offset project. Page 18 of 44

19 5 VALIDATION OPINION Project Title: Project Participant(s): Applied Standard: Libra/ Sekem Composting project (1) Libra (2) South Pole Carbon Asset Management Ltd. (3) Soil and More International BV TÜV NORD Standard for voluntary emission reductions; Relevant CDM rules PDD: Draft version dt ; final version dt Methodological approach: Approved CDM Meth; Combined appr. Meths; Project specific Meth Applied methodologies: Validation Opinion: AMS III.E. Avoidance of methane production from biomass decay through controlled combustion (version 7 dt ) AMS III.F.: Avoidance of methane production from biomass decay through composting (version 4 dt ) has validated the project activity as per the relevant requirements of the TÜV NORD Standard TN-CC 001 and CDM applicable for VER project activities, as well as criteria for consistent project operations, monitoring and reporting. The review of the PDD and additional documents related to baseline and monitoring methodology and the subsequent background investigation was conducted to validate the fulfilment of the stated criteria of the relevant CDM criteria and TN-CC 001. The validation is based on the Project Design Document (PDD), draft version (12 th April 2007) and final version dated 01 st August 2007 Version 2, emission reduction calculation spreadsheet and supporting documents made available to the TÜV NORD JI/CDM CP by the project participant. As a result of the validation, the validation team confirms that: The calculation of the project emission reductions is carried out in a transparent and conservative manner, so that the calculated emission reductions can be achieved within the 7 years (renewable) crediting period. The project additionality is sufficiently justified in the PDD. The monitoring plan is transparent and adequate. As the result of the validation, the validator confirms that the project, as it was described in the project documentation, is in line with all criteria applicable for the validation. Baseline Emissions over crediting period 1,028,609 t CO 2eq Leakage 0 t CO 2eq Project Emissions 9,407 t CO 2eq Total Emission Reduction estimated over crediting period 420,000 t CO 2eq Essen, Rainer Winter Page 19 of 44

20 6 REFERENCES Table 5-1: Reference /ACC/ /AML/ /COAE/ /CP/ /MFC/ Documents provided by the project proponent Document Analysis Certificate of bio-dynamic Compost List of methods of analysis for composting parameters and specific analysis methods (date: ) Study on the content of different fractions in the waste delivered to a municipal solid waste disposal, illegal dumping and other use. (Date ) Calibration Plan Management structure (Flow chart) /MG/ International Monitoring Guidelines issued by Soil and More (date: ) /SET/ /SOM/ /SOP/ /SP/ Draft Project Design Document entitled Libra/Sekem Composting project, version 1, dated Final Project Design Document entitled Libra/Sekem Composting project, version 4, dated Statement of the Industrial Development Authority of Egypt that composting is an environmental-friendly technology. Example for series of measurements of O 2, CO 2 etc. Standard operating procedures for composting, issued by Soil and More (date: ) Site plan Table 5-2: Reference Background investigation and assessment documents Document /AMS III.E./ Avoidance of methane production from biomass decay through controlled combustion (version 07: 28 November 2005) /CPM/ TÜV NORD JI / CDM CP Manual (incl. CP procedures and forms) Page 20 of 44

21 Reference Document /GCP/ UNFCCC: Guidelines for completing CDM-PDD and CDM-NM (Version 05) /IPCC-GP/ /IPCC-RM/ IPCC Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories, Revised 1996 IPCC Guidelines for National Greenhouse Gas Inventories: Reference Manual 2. IPCC Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories, 2006 /KP/ Kyoto Protocol (1997) /MA/ Decision 17/CP. 7 (Marrakesh Accords and Annex to decision 17/CP.7) /TN-VOS/ TUV Nord JI/CDM CP voluntary off-set standard (TN-CC 001). /VVM/ IETA, PCF Validation and Verification Manual (V. 4) Table 5-3: Websites used Reference Link Organisation /bmu/ gastlaender/aegypten/doc/241. php Federal Ministry of the Environment, Nature Conservation and Nuclear Safety of Germany /dna/ Designated National Authority of Egypt /ipcc/ IPCC publications /unfccc/ UNFCCC /ieta/ http :// Website of International Emission trading Association (IETA) Table 5-4: List of interviewed persons Reference MoI 1 Name Organisation / Function /IM01/ V Mr. Ms. Amr Farouk Director, Business Development and Compliance of SEKEM Group Page 21 of 44

22 Reference MoI 1 Name Organisation / Function /IM01/ V Mr. Ms. Tobias Bandel Soil and More International BV /IM01/ V Mr. Ms. Christian Dannecker /IM02/ V Mr. Ms. Dr. Eid Soliman El- Gezawy 1) Means of Interview: (Telephone, , Visit) South Pole Carbon Asset Management Ltd. Consultant and Compost and Plant Bionutration of EBDA Page 22 of 44

23 ANNEX Validation Protocol

24 ANNEX : VALIDATION PROTOCOL Table A-1: Requirements Checklist CHECKLIST QUESTION Ref. MoV* COMMENTS A. General Description of Project Activity The project design is assessed. Draft Final 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 boundaries (geographical) clearly defined? A DR The project is located in Egypt, 60 km northeast of Cairo, near the town Belbeis. However, a unique identification of the project location should be included under A A2 A.1.2. Are the project s system boundaries (components and facilities used to mitigate GHGs) clearly defined? B.3. DR, I The project boundary is described in the PDD. It includes the composting site, municipal landfills in the suburbs of Cairo, the application of the ready-made compost (transported within a radius of 100 km) and the transportation of waste. However, the description of the project boundary should be revised especially as the baseline should be revised. Therefore B1 was raised. B1 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-24

25 CHECKLIST QUESTION Ref. MoV* COMMENTS A.2. Participation Requirements Referring to Part A, Annex 1 and 2 of the PDD as well as the CDM glossary with respect to the terms Party, Letter of Approval, Authorization and Project Participant. A.2.1. Which Parties and project participants are participating in the project? A.3. DR I The project is located in Egypt. However, the party is not involved in the project due to the fact that this project is a voluntary emission reduction project. The project participants are: (1) Libra (2) South Pole Carbon Asset Management (3) Soil and More International BV Draft Final A.2.2. Have all involved Parties provided a valid and complete letter of approval and have all private/public project participants been authorized by an involved Party? A.2.3. Do all participating Parties fulfil the participation requirements as follows: Ratification of the Kyoto Protocol /LOA/ DR, I /LOA/ DR n/a As this project is a voluntary offset activity and the UNFCCC regulations are not applied completely the table under B.3. should be modified. The last column could be deleted as no party is involved. n/a A1 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-25

26 A.2.4. CHECKLIST QUESTION Ref. MoV* COMMENTS Voluntary participation Designated a National Authority Potential public funding for the project from Parties in Annex I shall not be a diversion of official development assistance. A.3. 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 know-how is used. A.3.1. A.3.2. A.3.3. Does the project design engineering reflect current good practices? Does the project use state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in the host country? Does the project make provisions for meeting training and maintenance needs? A.4.4., Annex 2 (A.4.3.) /IM01/ (A.4.3.) /IM01/ (B.7.2.) I DR, I DR I DR, I No public funding from the parties in Annex I is included. Yes, the project activity establishes aerobically decomposition of biomass wastes in a composting system to produce organic fertilizer. The implemented technology of the project is state of the art technology. No, the referenced monitoring plan as well as the Soil and More Standard Operating Procedures (cmp. PDD B.7.2.) do not provide any training and maintenance needs. Clarification is requested. Draft CR B2 Final * MoV = Means of Verification, DR= Document Review, I= Interview Page A-26

27 CHECKLIST QUESTION Ref. MoV* COMMENTS A.4. Contribution to Sustainable Development The project s contribution to sustainable development is assessed. A.4.1. A.4.2. Has the host country confirmed that the project assists it in achieving sustainable development? Will the project create other environmental or social benefits than GHG emission reductions? Small scale project activity Is it assessed whether the project qualifies as small-scale CDM project activity A.4.3. A.4.4. Does the project qualify as a small scale CDM project activity as defined in paragraph 6 I of decision 17/CP.7 on the modalities and procedures for the CDM? Is the small scale project activity not a debundled component of a larger project activity? /LOA/ n/a A.2. The assessment of sustainability issues was not included during validation. However, during on-site visit the high sustainable character of the project activity as well as the whole concept was evident. The agreement between the project participant and the validator is that smallscale criteria are applicable, as the emission reductions are limited to 60,000 t CO 2 per year as defined in the category III of small-scale projects. Therefore the project qualifies as small-scale. Debundling criteria are not applicable as this project activity is the first of its kind in Egypt. Draft Final * MoV = Means of Verification, DR= Document Review, I= Interview Page A-27

28 A.5. General Topics CHECKLIST QUESTION Ref. MoV* COMMENTS Draft Final A.5.1. Has the PDD been duly filled? The table under B.6.4. should be revised. Clarification is requested whether the date of the PDD under A.1 is correct or the date of completion of the baseline under B.8. B3 CR A1 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. The complete passage under section D should be shifted to the relevant subsection D.2. D1 B.1. Baseline Methodology It is assessed whether the project applies an appropriate baseline methodology. B.1.1. Does the project apply an approved methodology and the correct version thereof? (A.4.2., B.1.) DR AMS III.E. (Version 7) is applied to calculate the baseline emissions of the project activity. Although this methodology is related to avoidance of methane through controlled combustion, the baseline calculation does not have any effect on the * MoV = Means of Verification, DR= Document Review, I= Interview Page A-28

29 B.1.2. CHECKLIST QUESTION Ref. MoV* COMMENTS Are the applicability criteria in the baseline methodology all fulfilled? (B.2.) DR emission reductions. Therefore the methodology AMS II.E. is applicable. Furthermore Version 7 was valid till 2 nd March 2006 and thus acc. to CDM rules inactive. Nevertheless the methodology was assessed as applicable for VER projects. However some inconsistencies in the PDD should be closed out: Clarification is necessary from which methodology the calculation of project emissions and the requirements for compost were chosen. Under A.4.2. the justification and description of the applied methodology doesn t correspond to the applied CDM methodology AMS III.E. (Version 7) Avoidance of methane production from biomass decay through controlled combustion. Under section B.1. the title and reference given for the baseline methodology doesn t correspond with any CDM methodology. Clarification is necessary which methodology is applied. Yes, the project leads to avoidance of methane from biomass or other organic matter that would have otherwise been left to decay through composting. A minor Draft CR B3 CR A2 CR B1 Final * MoV = Means of Verification, DR= Document Review, I= Interview Page A-29

30 CHECKLIST QUESTION Ref. MoV* COMMENTS deviation from AMS III.E. is controlled combustion instead of composting which is acceptable. As the emission reductions are limited to 60,000 t CO 2 the small-scale limits are met. Draft Final B.2. Baseline Scenario Determination The choice of the baseline scenario will be validated with focus on whether the baseline is a likely scenario, and whether the methodology to define the baseline scenario has been followed in a complete and transparent manner. B.2.1. What is the baseline scenario? (B.4.) B.2.2. B.2.3. B.2.4. B.2.5. What other alternative scenarios have been considered and why is the selected scenario the most likely one? Has the baseline scenario been determined according to the methodology? Has the baseline scenario been determined using conservative assumptions where possible? Does the baseline scenario sufficiently take into account relevant national and/or sectoral policies, macro-economic trends and political aspirations? (B.4.) (B.4.) (B.4.) (B.4.) DR The description of the applied baseline scenario should be reconsidered. As discussed during on-site visit the baseline should be revised. B1 DR Please refer to B1 B1 DR Please refer to B1 B1 DR Please refer to B1 B1 DR Please refer to B1 B1 B.2.6. Is the baseline scenario determination DR Please refer to B1 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-30

31 B.2.7. CHECKLIST QUESTION Ref. MoV* COMMENTS compatible with the available data and are all literature and sources clearly referenced? Have the major risks to the baseline been identified? B.3. Additionality Determination The assessment of additionality will be validated with focus on whether the project itself is not a likely baseline scenario. B.3.1. Is the project additionality assessed according to the methodology? (B.4.) (B.4.) (B.5.) Draft B1 DR Please refer to B1 B1 DR The justification of additionality should be modified/revised under several aspects: 1. Step 0 and step 5 can be deleted as these steps are not necessary according to the latest additionality tool (Ver. 3). 2. Several alternatives which might also be applicable were not identified, i. e. uncontrolled burning, controlled burning. 3. The investment comparison analysis is neither transparent nor correct. A revision of the provided Excel calculation sheets is necessary. Furthermore all applicable alternatives should be included in the investment comparison analysis. 4. The sensitivity analysis needs further explanations. Especially the B2 Final * MoV = Means of Verification, DR= Document Review, I= Interview Page A-31

32 B.3.2. B.3.3. CHECKLIST QUESTION Ref. MoV* COMMENTS Are all assumptions stated in a transparent and conservative manner? Is sufficient evidence provided to support the relevance of the arguments made? (B.5.) (B.5.) justification acc. to variations of the currency exchange rate is not clear. 5. The barrier analysis should be revised. As per the additionality tool the barriers of the proposed project activity should also embrace the alternatives to the project. 6. Sub-step 4b is missing. This should be included in the PDD. It is recommended to apply either the additionality tool for large-scale projects or the barrier analysis for small-scale projects. Draft DR Please refer to B.3.1. B2 DR Please refer to B.3.1. B2 Final B.4. Calculation of GHG Emission Reductions Project emissions It is assessed whether the project emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified. B.4.1. Are the calculations documented according to the approved methodology and in a complete and transparent manner? (B.6.3) DR Project emissions are considered and indicated in section B.6.3. However the values don t correspond to the data provided in the Annex. Clarification is necessary. B.4.2. Have conservative assumptions been used DR Please refer to B.4.1. B6 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-32

33 B.4.3. Draft CHECKLIST QUESTION Ref. MoV* COMMENTS when calculating the project emissions (B.6.3) B6 Are uncertainties in the project emission estimates properly addressed? (B.6.3) DR Please refer to B.4.1. B6 Final B.5. Calculation of GHG Emission Reductions Baseline emissions It is assessed whether the baseline emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified. B.5.1. B.5.2. B.5.3. Are the calculations documented according to the approved methodology and in a complete and transparent manner? Have conservative assumptions been used when calculating the baseline emissions Are uncertainties in the baseline emission estimates properly addressed? (B.6.3) (B.6.3) (B.6.3) DR As the baseline should be reconsidered and needs further elaboration and discussion the calculation can t be conducted by now. Please refer to B1. B1 DR Please refer to B.5.1. B1 DR Please refer to B.5.1. B1 B.6. Calculation of GHG Emission Reductions Leakage It is assessed whether leakage emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified. B.6.1. Are the leakage calculations documented according to the approved methodology and in a complete and transparent manner? (B.6.3) DR Leakage is not to be considered. n/a * MoV = Means of Verification, DR= Document Review, I= Interview Page A-33

34 B.6.2. B.6.3. Draft CHECKLIST QUESTION Ref. MoV* COMMENTS Have conservative assumptions been used DR Leakage is not to be considered. n/a when calculating the leakage emissions? (B.6.3) Are uncertainties in the leakage emission DR Leakage is not to be considered. n/a estimates properly addressed? (B.6.3) B.7. Emission Reductions The emission reductions shall be real, measurable and give long-term benefits related to the mitigation of climate change. B.7.1. Are the emission reductions real, measurable and give long-term benefits related to the mitigation of climate change. B.8. Monitoring Methodology It is assessed whether the project applies an appropriate baseline methodology. B.8.1. Is the monitoring plan documented according to the approved methodology and in a complete and transparent manner? (B.6.3) DR DR As the baseline is not fully established the emission reductions can t be calculated till now. Please refer to B1. As the applicable approved small-scale methodology is not identified sufficiently (cmp. CR B1), the monitoring plan is pending. However, during on-site visit some parameters which should be monitored were identified. Furthermore some information to parameters provided in the draft PDD are not sufficiently addressed. Therefore the following B4 and B5 were raised: B1 Final PDD, section B.7.1: Q biomass : The time series for the value of B4 * MoV = Means of Verification, DR= Document Review, I= Interview Page A-34

35 CHECKLIST QUESTION Ref. MoV* COMMENTS data should be specified. Ct y and CT y,comp : The table is incomplete, e.g. the description is missing. DAFw: The table is incomplete, e.g. the description is missing. The monitoring of CO 2, O 2 and temperature is missing. The description of the monitoring plan under section B.7.2 is incomplete and should be more detailed. Draft B5 Final B.9. Monitoring of Project Emissions It is established whether the monitoring plan provides for reliable and complete project emission data over time. B.9.1. B.9.2. B.9.3. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for estimation or measuring the greenhouse gas emissions within the project boundary during the crediting period? Are the choices of project GHG indicators reasonable and conservative? Is the measurement method clearly stated for each GHG value to be monitored and DR The monitoring plan of project emissions is not complete. Please refer to B4 & B5 under B.8.1. B4 B5 DR Please refer to B.9.1. B4 B5 DR Please refer to B.9.1. * MoV = Means of Verification, DR= Document Review, I= Interview Page A-35

36 B.9.4. B.9.5. B.9.6. B.9.7. B.9.8. B.9.9. CHECKLIST QUESTION Ref. MoV* COMMENTS deemed appropriate? Is the measurement equipment described and deemed appropriate? Is the measurement accuracy addressed and deemed appropriate? Are procedures in place on how to deal with erroneous measurements? Is the measurement interval identified and deemed appropriate? Is the registration, monitoring, measurement and reporting procedure defined? Are procedures identified for maintenance of monitoring equipment and installations? Are the calibration intervals being observed? Are procedures identified for day-to-day records handling (including what records to Draft B4 B5 DR Please refer to B.9.1. B4 B5 DR Please refer to B.9.1. B4 B5 DR Please refer to B.9.1. B4 B5 DR Please refer to B.9.1. B4 B5 DR Please refer to B.9.1. B4 B5 DR Please refer to B.9.1. B4 Final * MoV = Means of Verification, DR= Document Review, I= Interview Page A-36