Ashok Mammen. VCS Validation Report. Voluntary Carbon Standard Validation Report. 19 November Validation Report:

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1 Voluntary Carbon Standard Validation Report 19 November 2007 Validation Report: Name of Verification company: Bureau Veritas Certification Holding SAS Report Title: Validation Report for ULUABAT Hydroelectric Power Plant Client: Date of the issue: 19 November 2010-version 01. Approved by: Ashok Mammen Project Title: Global Tan Enerji A.S ULUABAT Hydroelectric Power Plant Summary: Bureau Veritas Certification has made the validation of ULUABAT Hydroelectric Power Plant. The project activity involves the installation of a 100 MW hydro electric power plant (HEPP) project located on the lower basin of Orhaneli Creek, in Uluabat district in Bursa-Turkey. The purpose of the project is to generate energy from the running waters of Orhaneli creek which is one of the main branches of Mustafa Kemal Paşa River. The project comes under Type-I Renewable Energy Project as per Appendix B of the procedures for CDM project activities. The expected annual emission reduction is 199,467 tonnes of CO 2 e (tco 2 e). Renewable crediting period is chosen for the project activity. The validation scope is defined as an independent and objective review of the VCS project description, the project s baseline study, monitoring plan and other relevant documents, and consisted of the following five phases: i) desk review of the project design and the baseline and monitoring plan; ii) Review of the baseline methodology by the specialist and the validator; iii) Review of the investment analysis by the specialist and the validator iv) follow-up interviews and on site visit; v) resolution of outstanding issues and the issuance of the final validation report and opinion. The overall validation, from Contract Review to Validation Report & Opinion, was conducted using Bureau Veritas Certification internal procedures. The first output of the validation process is a list of Clarification and Corrective Actions Requests (CL and CAR), presented in Annex II in the Validation Protocol. Taking into account this output, the project proponent revised its VCS project description. In summary, it is Bureau Veritas Certification s opinion that the project correctly applies the baseline and monitoring methodology ACM0002, version 10 and meets the relevant VCS requirements and local legislation. Work carried out by: Number of pages: Bade Cebeci - Team leader 168 Yildiz Arikan Baseline Specialist Murat Gençer Financial Specialist Koray Bilgin Sector Specialist 1

2 TABLE OF CONTENTS: 1 INTRODUCTION Objective Scope and Criteria VCS Project Description Level of assurance METHODOLOGY Review of Document Follow-up Interviews Resolution of any material discrepancy VALIDATION FINDINGS Project Design Baseline Monitoring Plan Calculation of GHG Emissions Environmental Impact Comments by stakeholders VALIDATION CONCLUSION REFERENCES Documents Persons Interviewed ANNEX I Validators Competence...20 ANNEX II - Validation Protocol

3 Abbreviations List: HEPP : Hydro Electric Power Plant CL : Clarification CAR : Corrective Action Request MP : Monitoring Plan VCS : Voluntary Carbon Standard VCU : Voluntary Carbon Unit VER : Voluntary Emissions Reductions / Verified Emissions Reductions : Project Description EMRA : Electricity Market Regulatory Authority (EK) EK : Elektrik Piyasasi Duzenleme Kurulu (EMRA) TEIAS : Turkiye Elektrik Iletim A.S. (Turkish Electricity Transmission Company) DSI : Devlet Su Isleri (State Hydraulic Works) PP : Project Participant CDM : Clean Development Mechanism HES : Hidro Elektrik Santrali (Hydro Electric Power Plant) 3

4 1 INTRODUCTION This report summarizes the findings of the validation of the Uluabat Hydroelectric Power Plant project, performed on the basis of VCS criteria, as well as criteria given to provide for consistent project operations, monitoring and reporting. 1.1 Objective The validation serves as project design verification and is a requirement of all voluntary emission reduction projects. The validation is an independent third party assessment of the project design. In particular, the project's baseline, the monitoring plan (MP), and the project s compliance with relevant VCS criteria which 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 a requirement for all VCS projects and is seen as necessary to provide assurance to stakeholders of the quality of the project and its intended generation of Voluntary Carbon Units (VCUs). 1.2 Scope and Criteria The validation scope is defined as an independent and objective review of the VCS project description, the project s baseline study and monitoring plan, the project s investment analysis and other relevant documents. The information in these documents is reviewed against the methodologies and tools that are given under the Clean Development Mechanism of Kyoto Protocol, VCS rules and associated interpretations. The validation is not meant to provide any consulting towards the client. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the project design. 1.3 VCS Project Description The project activity involves the installation of a 100 MW hydro electric power plant (HEPP) project located on the lower basin of Orhaneli Creek, in Uluabat district in Bursa-Turkey. The purpose of the project is to generate energy from the running waters of Orhaneli creek which is one of the main branches of Mustafa Kemal Paşa River. The project comes under Type-I Renewable Energy Project as per Appendix B of the procedures for CDM project activities. The main purpose of the project is to generate approximately GWh as per the license however due to the use of water for other purposes, it is expected to decrease to GWh in 2021 and GWh in For the first crediting period, it has been assumed that average generation will be GWh and emission reduction has been calculated respectively. Electricity generated by the power plant will be delivered to the grid by an 11.2 km long 154 kv double circuit overhead transmission line. The project activity reduces greenhouse gas (GHG) emissions that would have otherwise occurred in the absence of the project activity by avoiding electricity generation from fossil fuel sources. The expected average annual emission reduction is 199,467 tonnes of CO 2 e (tco 2 e). Renewable crediting period is chosen for the project activity. 1.4 Level of assurance The Level of assurance of the validation report is defined as high. 4

5 2 METHODOLOGY The overall validation, from contract review to validation report & opinion, was conducted using Bureau Veritas Certification internal procedures. In order to ensure transparency, a validation protocol was customized for the project. The protocol shows, in a transparent manner, criteria (requirements), means of verification and the results from validating the identified criteria. The validation protocol serves the following purposes: It organizes, details and clarifies the requirements of a VCS 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. 2.1 Review of Document The Project Description () submitted by Global Tan Enerji A.S and additional background documents related to the project design and baseline, i.e. Host Country Law, VCS Project Description Template, Approved Methodology and tools under the CDM of Kyoto Protocol, Clarifications (CL) and Corrective Action Requests (CAR) on validation requirements were reviewed. To address Bureau Veritas Certification corrective action requests and clarification requests, Global Tan Enerji A.S revised the several times, version 04 being the last version which was submitted to the validation team on All corrective action requests and clarification requests were closed in All documents were reviewed under the requirements of the CDM Methodologies as these methodologies are approved under the VCS. 2.2 Follow-up Interviews Between September 2009 and October 2010 Bureau Veritas Certification performed interviews with Global Tan Enerji A.S and local stakeholders regarding the Grid emission factor, Investment Analysis, project specific questions and Clarification and Corrective Actions Requests documented in the validation protocol. A list of the persons interviewed is given under section 5.2 of this report. After the discussions, the validation team closed on all documented CL and CAR in the validation protocol. 2.3 Resolution of any material discrepancy During the validation there were no material discrepancies that were identified. 3 VALIDATION FINDINGS 3.1 Project Design Bureau Veritas Certification recognizes that Global Tan Enerji A.S which is the project participant is helping the host country in fulfilling its goals of promoting 5

6 sustainable development with this project. The project is in line with host-country specific requirements. In addition, the project highly supports the sustainable economic development in the region. The conclusions of the validation team are as follows: The technology used: Project consists of two horizontal axes turbines and generators which are used to transform the potential energy of water to mechanical energy at the first stage and later into electrical energy. Other characteristics of the project have been given below. LOCATION: ORHANELİ CREEK OF SUSURLUK BASİN DESIGN DISCHARGE: M 3 /SEC LENGTH OF TUNNEL: KM AVERAGE NATURAL FLOW M 3 /SEC GROSS HEAD: 325 M THALWEG LEVEL 333 M CREST HEIGHT M TOTAL INSTALLED CAPACITY: 100 MW RESERVOIR VOLUME HM 3 MAX. RESERVOIR SURFACE AREA KM 2 NUMBER OF UNITS: 2 EACH DERIVATION TUNNEL HORSESHOE TYPE, 0.56KM LONG TURBINE TYPE: FRANCIS TYPE HORIZONTAL AXIS IRRIGATAION LAND 3,000 HA TOTAL WATER DEMAND HM3/YEAR TURBINE MANUFACTURER: VOITH-SIEMENS GENERATOR TYPE: 3 PHASE SYNCRON WİTH EFFİCİENCY LENGTH OF ENERGY KM TRANSMISSION LINE: ENERGY TRANSMISSION LINE 154 KV CAPACITY: NUMBER OF PENSTOCKS: 2 EACH LENGTH OF PENSTOCKS: 838 M AVERAGE ANNUAL POWER BETWEEN AND GWH GENERATION: GRID CONNECTION THE GRID CONNECTION WAS PROVIDED BY MEANS OF A 11.0 KM LONG 2X1272 MCM ENERGY TRANSMISSION LINE TO THE GORUKLE-AKCALAR TRANSFORMER STATION (154/33 KV) WHICH IS OWNED BY TEIAŞ. 6

7 The technology used in the plant is a state-of-the-art technology with extensive automatization. The equipment to be provided is brand new according to the electromechanical equipment agreement. There is no new technology which is expected to replace the plant s technology in the short run. The project does not need extensive initial training and maintenance efforts in order to work as presumed during the project planning period. Necessary trainings to the plant staff will be delivered by the supplier in line with the agreement between the project owner and the supplier. The agreement between the supplier and AKENERJI Elektrik Uretim AS (Project Owner) has been reviewed by the validation team. The related training records shall be verified during the first verification of the project activity. As a result, validation team approves that the technology used in the project activity is state of the art and all the equipment used in the project are new. Project duration, crediting time and project start date Expected starting date of the project activity is Project is expected to start operation 01/11/2010 when the plant commences electricity generation. The carbon crediting period and therefore the monitoring starts when the plant commences electricity generation. The crediting life is a maximum of ten years which may be renewed at most two times. The expected life time of the project starting from 22/06/2007 is 45 years according to duration of the license obtained from EMRA. The indicated project duration corresponds to 42 years starting from the expected starting date of the project activity as given in the. However, the equipments may be renewed (as recommended) during the lifetime of the project activity according to the conditions of the equipments. Ownership The generation license belongs to AKENERJI Elektrik Uretim AS. A copy of the generation license is given in Annex 7 of the. The project did not participate in any other GHG emission reduction program. The validation team approves that there is no double counting involved in this project activity during this validation. Eligibility of the project activity under VCS The project comes under Type I Renewable Energy Project as per Appendix B of the procedures for CDM project activities. The project is a 100 MW HEPP and it uses renewable sources to produce electricity. Since the installed capacity of the planned HEPP is larger than 15 MW; it is a large scale renewable energy project activity according to the Decision 17/ CP.7 Article 6. As per the justifications given above, the project activity is eligible under VCS. The project is not a grouped project. 3.2 Baseline Approval of the baseline methodology: The baseline for Uluabat Hydroelectric Power Plant project is established by using the UNFCCC official methodology ACM0002, version 10, namely Consolidated baseline methodology for grid-connected electricity generation from renewable sources. For the calculation of the grid emission factor, UNFCCC Methodological Tool Tool to Calculate Emission Factor of an Electricity System version 01 is used. 7

8 For the assessment and demonstration of additionality, UNFCCC Methodological Tool Tool for the Demonstration and Assessment of Additionality, Version 05.2 is used. Both of the tools are referred in the applied methodology. Both the tools and the methodology are the latest available versions at the time of submission to the DOE, and are found appropriate by the validation team. Clean Development Mechanism Methodologies are approved under the VCS program. Correct application and justification of baseline methodology: The choice of methodology ACM0002 / Version 10, is justified as the proposed project activity meets relevant applicability criteria: Applicability condition in the ACM0002/Version 10 This methodology is applicable when the project activity is the installation, capacity addition, retrofit or replacement of a power plant/unit of one of the following types: hydro power plant/unit (either with a run-of-river reservoir or an accumulation reservoir), wind power plant/unit, geothermal power plant/unit, solar power plant/unit, wave power plant/unit or tidal power plant/unit. Compliance of the condition The project activity is a Greenfield grid connected hydropower project with a run-of river reservoir. In the case of capacity additions, retrofits or replacements: the existing plant started commercial operation prior to the start of a minimum historical reference period of five years, used for the calculation of baseline emissions and defined in the baseline emission section, and no capacity expansion or retrofit of the plant has been undertaken between the start of this minimum historical reference period and the implementation of the project activity. In case of hydro power plants, one of the following conditions must apply: - The project activity is implemented in an existing reservoir, with no change in the volume of reservoir; or - The project activity is implemented in an existing reservoir, where the volume of reservoir is increased and the power density of the project activity, as per definitions given in the Project Emissions section, is greater than 4 This condition is not applicable to the project activity as it involves the installation of a new hydroelectric power plant. The project activity results in new reservoirs and the power density of the power plant, as per definitions given in the Project Emissions section, is greater than 4 W/m2 The power density () for this reservoir is calculated as follows: = W/ m2 = 9.86 W/m2 > 4 W/m2 Since the is between 4 and 8

9 W/m 2 ; or - The project activity results in new reservoirs and the power density of the power plant, as per definitions given in the Project Emissions section, is greater than 4 W/m 2. This methodology is not applicable to project activities that involve switching from fossil fuels to renewable energy sources at the site of the project activity, since in this case the base line may be the continued use of fossil fuels at the site. This methodology is not applicable to biomass fired power plants. In the case of retrofits, replacements, or capacity additions, this methodology is only applicable if the most plausible baseline scenario, as a result of the identification of baseline scenario, is the continuation of the current situation, i.e. to use the power generation equipment that was already in use prior to the implementation of the project activity and undertaking business as usual maintenance. 10W/m2, the emissions resulting form the reservoir has been calculated according to ACM 002 version 10. This condition is not applicable to the project activity as it does not involve switching from fossil fuel to renewable energy at the site of the project activity. This condition is not applicable to the project activity as it does not involve the installation of a biomass fired power plant. This condition is not applicable to the project activity as it does not involve a capacity addition, retrofit or replacement of existing grid-connected renewable power plant/unit(s). The baseline scenario was applied correctly and the justification for the choice of the baseline methodology is found appropriate by the validation team Appropriate setting of baseline scenario The baseline scenario is defined as follows: 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, as reflected in the Combined Margin (CM) calculations described in the Tool to calculate emission factor for an electricity system The defined baseline scenario is in line with the methodology as the project activity is the installation of a new grid-connected renewable power plant. As the project activity is not a retrofit or replacement of existing grid-connected renewable power plant, the step-wise procedure to identify the baseline given in ACM 0002 version 10 is not used for this project activity. The above setting of the baseline scenario is found appropriate by the validation team. Assessment and demonstration of additionality: The assessment and demonstration of additionality of the project is done by using UNFCCC Methodological Tool Tool for the Demonstration and Assessment of Additionality, Version In applying this tool under Step 1a, the following 9

10 four alternatives are identified as the alternative scenarios that are likely to happen in the absence of the project activity: Alternative 1: Proposed project not undertaken as a VER project activity Alternative 2: Continuation of the current situation-supply of equal amount of electricity by the grid connected power plants. Alternative 3: Construction of a thermal power plant with the same installed capacity or the same annual power output. All three alternatives have been defined as realistic in the. Analyzing the alternatives that are defined as realistic, it is seen that all scenarios are consistent with the baseline definition of ACM0002 / Version 10. All of the alternatives are in compliance with legal requirements as they are practices currently present in the country. The project proponent used Step 2 Investment Analysis for the demonstration of the additionality of the project activity. Under Step 2-Investment Analysis there are four sub-steps. Under sub-step 2a, Benchmark Analysis (Option III) is chosen and the other options are eliminated because, the proposed Project generates financial and economic benefits through the sales of electricity other than Voluntary Emissions Reduction (VCS-VER) related income. Therefore the simple cost analysis (Option I) cannot be taken. Investment comparison analysis (Option II) is only applicable to projects where alternatives should be similar investment projects. Since the baseline of the project is generation of electricity by the grid and there exist no publicly available data for comparison with alternative investment types, no alternative investment is considered for comparison. This method is also assessed to be appropriate by the validation team. Under sub-step 2b, Equity IRR is selected as a financial indicator. As a benchmark, Turkish Eurobond rate increased by a suitable risk premium is used. The Turkish eroubondrate has been selected as 7.25% with a maturity date of The Eurobond rate at the time of investment decision which is the date of purchase agreement (April 2006) is taken. The maturity date of the eurobondrate is also convenient for the investment analysis period which is selected as 20 years. The country risk premium is taken from the study of Prof. Aswath Damodara ( 9.41 %). Hence the benchmark is assessed to be appropriate by the validation team and the financial expert. Under sub-step 2c, the Equity IRR is calculated. Project proponents have also submitted an excel sheet showing the details of the calculations. Some revisions have been made to these calculations until the latest version which was submitted to the validation team together with the final VCS. Majority of the data used in the IRR calculations are taken from the turbine purchase agreement and the proposals & contracts for the construction. Other data has been referred to the feasibility report as summarised below. 10

11 . Parameter s Installed Capacity Grid Connected output Capital Investment Unit Validate d Value Means of Validation MW 100 Production license approved by EMRA as also presented in the D GWh Production license approved by EMRA as also presented in the D and the revised feasibility report for capacity revision approved by State of Hyraulics dated April Million ) Uluabat financial report- prepared by Hydro Design Inc. Co August ) Crosschecked with the contracts for the major costs ( Siemens ; Tinsa Ltd ,Akmanlar Ltd ) Income tax % 20 rate Loan Million The loan agreements. Tariff Cents/kWh 5.5 Law number 5346, enactment date 18/05/ yreources.pdf The electricity sales price is taken as 5.5 Cents/kWh which is the minimum purchase guarantee of offered by the State as an incentive to renewable energy investments. Hence this sales price is accepted by the validation team. The depreciation periods of machinery, equipment and other fixed assets are taken as per the local rules and regulations. The IRR of the project activity is around 7.46 % without the VER revenues and around 8.97 with VER revenues at USD 7 /tco 2 for 20 years both of which are under the benchmark expectation of %. The above analysis shows that the project is not financially attractive without VER revenues for the investor. Under Sub-step 2d, sensitivity analysis is applied to the following items: Total investment Electricity selling price Annual operational costs for a decrease of 2.5 %, 5% and 10% and for an increase of 5% and 10%. The results of the sensitivity analysis have been presented below; Investment Cost Operating Cost Electricity Income The above sensitivity analysis shows that the project is still not financially attractive due to the changes in total investment electricity selling price and annual operational cost. 11

12 The common practice analysis: According to the Tool for the demonstration and assessment of additionality version 05.2, the common practice analysis shall be applied unless the proposed project activity has demonstrated to be first of its kind. Under the common practice analysis section of the, HEPP projects in the host country is compared with the thermal power plants. Also an analysis of the HEPPs in Turkey is given. It has been stated that share of HEPPs in total installed capacity of Turkey is about 32.8% whereas share of HEPPs in total generation is only 18.7%. Also, the distribution of hydro power capacity by utilities has been demonstrated and it has been concluded generation capacity of the hydroelectric power plants owned by generation companies is 1,503 GWh by end of 2007 which corresponds to 0.78% of the total generation capacity(191,558.1 GWh) of Turkey at that time. The statistics on the number of hydro projects those have been under operation have been accessed from the internet site of EMRA and also number of hydroprojects that are under operation in the region have been reviewed with the specialists in the Bursa State of Hydraulics Works during the site visit. The validation team has concluded that the proposed project activity is not common practice in the region due to the reasons that are explained above. 3.3 Monitoring Plan Approval of the monitoring methodology: The consolidated monitoring methodology for grid connected generation from renewable sources named as Approved Monitoring Methodology ACM0002 / Version 10 is applied. All the applicability conditions of the monitoring methodology are the same as the applicability conditions of the baseline methodology which are given under section 3.2 of this validation report. The data will be archived electronically and be kept at least for 2 years after the end of the last crediting period. All measurements will be conducted with calibrated measurement equipment according to relevant industry standards. Correct application and justification of the selected monitoring methodology: The justification of the choice is explained in section 3.2 of this validation report. The monitoring methodology is applied correctly and appropriately. Information about monitoring plan is as follows: The monitoring plan includes the monitoring of several parameters, the main parameter in the monitoring plan is the quantity of the net electricity that is delivered to the grid, this parameter will be the basis for the emission reduction calculations. According to the methodology ACM0002 version 10, the parameters used to calculate the Power Density of HEPPs also need to be monitored. These parameters are also included in the monitoring plan. The below table shows the parameters that are included in the monitoring plan together with their monitoring process. 12

13 Data /Parameter EG facility,y Cap PJ A PJ Description Quantity of net electricity generation supplied by the project to the grid in year y Installed capacity of the HEPP after implementation Source of Data Project activity site/electricity meters Data Unit MWh/y Monitoring Frequency Project site MW Yearly Area of the regulation pond measured in the surface of the water after the implementation of the project activity when the reservoir is full Project site m 2 Yearly Continuous measurement and at least monthly recording QA/QC Procedures to be Applied Cross check measurement results with records for sold electricity. There will be two sets of meters one main meter and one check meter. If there is a measuring difference between these meters, then one of the parties may request calibration. Data will be determined based on recognized standards Measured from topographical surveys, maps, satellite pictures, etc. 13

14 The monitoring will be performed in-house by the project proponent: 1. Plant Manager: Responsibility for running the HEPP plant and compliance with VER monitoring plan 2. Electrical Engineer: Responsible for day electrical operations and recording and monitoring of relevant data and periodic reporting 3. Accounting Manager: Responsible for keeping data about power sales, invoicing and purchasing. 4. Global Tan Energy: Responsible for emission reduction calculations, preparing monitoring report and periodical verification process. Overall the monitoring methodology is found appropriate and suitable for this particular project activity. 3.4 Calculation of GHG Emissions Anthropogenic emission reduction is a function of the expected net amount of electricity produced, for the given project, which amounts to 117 GWh per annum. The annual baseline emissions amount to 63,399 tco 2 e. Over the period of ten years, the total amount of baseline emissions will reach 639,990 tco 2 e. For all calculations, the rounded value of the combined emission factor, is applied. The appropriateness of the source, sink and reservoir: According to ACM0002/Version 10 if the power density () of the hydro power plant is above 10 W/m 2, Project Emissions is 0. The following calculation of the and the assumptions for the Project Emissions and Leakage made afterwards, is found acceptable and suitable for the project activity by the validation team. Years Annual estimation of emission reductions in tones of CO 2 e 2010 (01/11/ /12/2010) 33, , , , , , , , , , (01/01/ /10/2020) 166,223 Total emission reductions (Tones of CO 2 e) 1,994,672 Total number of crediting years 10 Annual average over the crediting period of estimated reductions (tones of CO 2 e) 199,467 14

15 The power density of the project activity is calculated as follows: Where: : Power density of the project activity, in W/m 2 Cap PJ : Installed capacity of the hydro power plant after the implementation of the project activity (W) Cap BL : Installed capacity of the hydro power plant before the implementation of the project activity (W). For new hydro power plants, this value is zero A PJ : A BL : Area of the reservoir measured in the surface of the water, after the implementation of the project activity, when the reservoir is full (m 2 ) Area of the reservoir measured in the surface of the water, before the implementation of the project activity, when the reservoir is full (m 2 ). For new reservoirs, this value is zero For proposed project HEPP, CapPJ = W CapBL = 0.0 W APJ = (m2) ABL = 0.0 (m2) Therefore is calculated as ; =9,86 W/m 2 The correctness and transparency of formulas and factors used, The formulas and factors used in the calculation of GHG emissions are found to be transparent and correct by the validation team. The emission factors of fuels which are used in the calculations are taken from the IPCC default values at the lower limit of uncertainty at a 95% confidence interval as provided in table 1.4 of Chapter 1 of Vol.2 (Energy) of the 2006 IPCC Guidelines on National GHG Inventories, as suggested by the methodology. The assumptions made for estimating GHG emission reductions The only assumption is the one about project emissions which is assumed to be zero as per the methodology. Other unknown parameters like the emission factors of fuels are taken from the IPCC values as mentioned above. Uncertainties There are no uncertainties in the calculations. 15

16 3.5 Environmental Impact Uluabat HEPP and Cinarcik Dam Project have been exempt from the procedure of preparation of an Environmental Impact Assessment Report in 2002, since the project approval date is before However an Environmental Assessment Report was prepared by PRD Planlama, Arastırma, and Gelistirme ve Danısmanlık Sti. In March 2006, in order to evaluate the possible impacts of the Project on the environment and take the necessary steps to mitigate the possible negative impacts. EIA report prepared for the project covers all aspects of the project including capacity, interaction with other plants in the vicinity, natural resources used, waste management, social and economical impacts, technology and materials used, current land use in the region, any historical or protected site within the project boundaries, geological assessment of the project site and any communities affected with the project. The project does not have significant environmental effects and environmental assessment is positive for the project activities. After evaluation of the environmental impacts of the 11 km long electrical transmission line and the renewal of the existing 15 km transmission line, Ministry of Environment and Forestry have declared that Environmental impact Assessment Report is not required for the transmission lines. The respective statements are given in Appendix Comments by stakeholders Initial Stakeholder meeting of the project was organized and held on December 4th, 2008 in Akçalar Village, Bursa. The invitations were sent by mail, newspaper announcements and thorough village heads. The participants comprised representatives from the community, relevant municipalities, public institutions and inhabitants of the surrounding villages. All the aspects of the project including the socio-economic and environmental aspects were presented to the participants by a project developer representative and were discussed by the stakeholders. Clarifications were requested and the overall response to the project was encouraging and positive. All the hearings were held in Turkish. The comments from stakeholder have been stated in the D as positive in general. The concerns raised by the participants indicated in the D were reduction of the oxygen content and the heating of the water outlet of the HEPP, the probable damage of the transmission tunnel to drinking water, closure of the water flowing in the riverbed, probable landslides filling the dam. During the site tour it has been also validated that the necessary explanations have been realised by the project proponent to the stake holders that The outlet water of the dam shall not be heated and the oxygen content shall not be reduced, shall be even above normal. It has also been validated on site that A special boring machine has been bought and boring has been carried out without much damage on the surface. During the site visit by the validation team, it has been observed that the stakeholders generally were positive about the project. 16

17 4 VALIDATION CONCLUSION Bureau Veritas Certification has made the validation of Uluabat Hydroelectric Power Plant The validation was performed on the basis of VCS criteria and host country criteria and also on the criteria given to provide for consistent project operations, monitoring and reporting. The validation consisted of the following three phases: i) Desk review of the project design and the baseline and monitoring plan; (October 2009) ii) iii) Review of the baseline methodology by the specialist and the validator (October 2009 September 2010 ) Review of the investment analysis by the specialist and the validator (October October 2010) iv) Follow-up interviews and on site visit; (December 2009) v) Resolution of outstanding issues and the issuance of the final validation report and opinion (November 2009 November 2010) Project participant/s used the latest tool for demonstration of the additionality. In line with this tool, the provides analysis of prevailing barriers to determine that the project activity itself is not the baseline scenario. By generating electricity using renewable energy, the project is likely to result in reductions of GHG emissions partially displacing the electricity that would have been generated using fossil fuels. Emission reductions attributable to the project are hence additional to any that would occur in the absence of the project activity. Given that the project is implemented and maintained as designed, the project is likely to achieve the estimated amount of emission reductions. The review of the Project Description (Version 01 dated until Version 4 dated , the site visit and the subsequent follow-up interviews (please see the list of the persons interviewed under section 5.2 of this report) have provided Bureau Veritas Certification with sufficient evidence to determine the fulfillment of stated criteria. The Project Description was subsequently revised as Version 04 dated to resolve the issues that have risen during the interviews and subsequent interactions. In our opinion, the project correctly applies and meets the relevant VCS requirements and the relevant host country criteria. The validation is based on the information made available to us and the engagement conditions detailed in this report. 17

18 5 REFERENCES 5.1. Documents Documents provided by Global Tan Energy that relates directly to the GHG components of the project and other reference documents are given below: 1. for Uluabat Hydroelectric Power Plant 2. Baseline Calculation Excel Sheet 3. Investment Analysis IRR Calculation Excel Sheet 4. Revised system connection agreement by TEAIS 5. The related pages of the electromechanical equipment purchase agreement with 6. The related pages of electric works contract 7. The insurance records of the regional employees. 8. Approved consolidated baseline and monitoring methodology ACM 0002 version UNFCCC s Methodological Tool: Tool for the demonstration and assessment of additionality, version UNFCCC s Methodological Tool: Tool to calculate the emission factor for an electricity system, version VCS Template 19 November VCS Validation Report Template 19 November Voluntary Carbon Standard

19 5.2. Persons Interviewed List persons interviewed during the validation and site visit, or persons that contributed with other information that are not included in the documents listed above. M. Kemal Demirkol- Global Tan Energy Yavuz Bilek Fadıllı Villager mukhtar Şükrü Duman Vilager Hasan Güleç Villager Mustafa Göbekoğlu Villager Cengiz Tanrıkulu Villager Sinan Turan Villager 19

20 ANNEX I Validators Competence Lead Verifier : Bade Cebeci Environemtal Engineer Bureau Veritas Certification SAS Verifier Bade Cebeci has over 10 years experience in environmental sicences and auditing. She is an auditor in EMS&QMS&OHS. She is a verifier for GHG Emission Reduction Projects. Baseline Specialist : Mrs. Yildiz Arikan -( Assoc. Professor Dr) Sabancı University, Faculty of Management, Orhanlı, Tuzla, 34956, Istanbul, Turkey. Yıldız Arıkan is an Electrical engineer and is working at Sabancı University. She has supported thesis related with energy. Also she has been conducting research studies on energy including CO 2 Emission Research Studies. Academically, Yıldiz Arıkan is working also on GHG project since 2005 Investment Analysis Specialists: Mr. Murat Gençer Master of Economics RiskTürk Software Development and Consultancy Head of Financial Analysis Team Murat Gençer, consultant and a trainer, has over 11 years of experience in FMCG, software development and banking sectors. He is specialised in project finance, financial modelling, risk management and MS Excel applications. Internal Technical Reviewer : Ashok Mammen - PhD (Oils & Lubricants) Bureau Veritas Certification - Internal Technical Reviewer Over 20 years of experience in chemical and petrochemical field. Dr. Mammen is a lead auditor for environment, safety and quality management systems. He is also a lead verifier and tutor for GHG projects and has been involved in the validation and verification processes of more than 100 CDM/JI/VCS and other GHG projects. 20

21 TABLE 1 GENERAL REQUIREMENTS CHECKLIST ANNEX II - Validation Protocol CHECKLIST QUESTION Ref. item COMMENTS Draft Final 21

22 CHECKLIST QUESTION 1. VCS Program specific issues a. Have the project(s) created another form of environmental credit (for example renewable energy certificates)? b. If yes, have the project participants provided a letter from the program operator that the credit has not been used and has been cancelled from the relevant programthe? c. Are the VCS, monitoring reports, and other documents required under the VCS Program in English? Ref. item COMMENTS VCS 3.1 The project is not eligible for GS crediting as it is a large scale HEPP. It has been stated in section F.2. of the VCS that the project owner confirms that the project activity does not create any other form of environmental credits. VCS 3.1 N/A VCS 3.2 version 1 and the monitoring plan, financial model and the EF calculation sheet have been presented in English. Please present the following documents in english annex 5 and annex 6 ( EIA exemption letter) ( in the ) financial model sheet Draft Final CAR01 2. Project level requirements a. General requirements b. Have the project proponent applied an approved VCS Program methodology or a methodology from an approved GHG Program based on the list of current VCS Program approved GHG Programs and methodologies as set out on c. Is the Project Start Date before 1 January 2002? (If yes, a CAR shall be raised as the Project Start Date for non-afolu projects for the VCS shall not be before 1 January 2002) VCS 5.2 The project proponent has applied CDM approved Methodology ACM0002 version 10 and tools that are referred in ACM0002. VCS The project start date has been estimated to be as stated in C.1.1 of the version 1. During the site visit it has been validated that the project was still in the construction phase. The project start date is after January

23 CHECKLIST QUESTION c. Will this validation be completed within two years of the Project Start Date? If not, was this validation contracted before 19 November 2008? (If yes validation shall be completed by 19 November 2009 and proof of contracting prior to 19 November 2008 shall be provided) d. Is the earliest Project Crediting Period Start Date under the VCS March 2006 for non-afolu projects and 1 January 2002 for AFOLU projects? e. Does the project reduce GHG emissions from activities that are included in an emissions trading program; or take place in a jurisdiction or sector in which binding limits are established on GHG emissions? f. If yes, have the project proponents provided evidence that the reductions or removals generated by the project have or will not be used in the emissions trading program or for the purpose of demonstrating compliance with the binding limits that are in place in that jurisdiction or sector? [Such evidence could include: a letter from the program operator or designated national authority that emissions allowances (or other GHG credits used in the program) equivalent to the reductions or removals generated by the project have been cancelled from the program; or national cap as applicable or; purchase and cancellation of GHG allowances equivalent to the GHG emissions reductions or removals generated by the project related to the program or national cap] Ref. item VCS VCS VCS VCS COMMENTS The project as not been validated according to VCS version 1, hence the question is not applicable. The checklist question is N/A as the Project Crediting Period starts on as indicated in section C.1.2 of the version 1. VCS Validation Report Draft Final The project does not reduce GHG emissions from activities that are included in an emissions trading program; or take place in a jurisdiction or sector in which binding limits are established on GHG emissions. Turkey is not involved in any emission trading program other than the voluntary market and does not have any limits until In addition there is no binding legal limits established in Turkey related to HEPPs. N/A g. Have project proponents claimed GHG credits VCS 5.2. The project proponents have not claimed GHG 23

24 CHECKLIST QUESTION from one project under more than one GHG Program? (If yes, a CAR shall be raised, as Project proponents shall not claim GHG credits from one project under more than one GHG Program) h. Was this project rejected by other GHG Programs? Ref. item i. If yes, have project proponents: VCS i. clearly stated in its VCS all GHG Programs for which the project has applied for credits and why the project was rejected? (Such VCS information shall not be deemed commercially sensitive information ii. provided the VCS Program validator and verifier, VCS Program project database and VCS Program Registry with the actual rejection document(s) including any additional explanations? j. Is this a renewal of the Project Crediting Period? k. If yes have a VCS Program approved validator determined that the original project baseline scenario(s) and additionality is still valid or has been updated taking account of new data and changed VCS Program requirements where applicable? b. Standards and factors Do standards and factors used to derive GHG emission data as well as any supporting data for additionality and baseline scenario(s) meet the following requirements: i. be publicly available from a reputable and recognised source (e.g. IPCC, publishedgovernment data etc)? COMMENTS 1 credits from one project under more than one GHG Program. The project is not eligible for GS crediting as it is a large scale HEPP. The project is not eligible for any of the compliance markets because of the position of the host country. VCS 5.2. The project was not rejected by any other GHG 2 program. Please refer to the above question. VCS VCS VCS VCS 5.5 VCS Validation Report Draft Final N/A N/A N/A N/A VCS 5.5 The standards and factors used to derive GHG emission data as well as any supporting data are taken from the IPCC and TEIAS which are both publicly available. 24

25 CHECKLIST QUESTION Ref. item COMMENTS The source for the reference 10 has not been presented in the Rrev01. Draft CL1 Final Reference 12 given in rev01 is not accessible CL2 Please indicate the page number for the CL3 reference 13. The statement in substep 4a of the version 1 CL4 is as follows: According to the TEIAS statistics, share of HEPPs in total installed capacity of Turkey is about 32.8% whereas share of HEPPs in total generation is only 18.7%. Reference 16 and 17 have been related to the above statement. Please clarify the meaning of the sentence. Additionally please clarify how the values 32.8% and 18.7%. have been derived from the referenced document. Reference 16 is not available through the adress CL5 presented. Please suplly an available adress for the document. The generation amount given for year 2007 is CL6 not parellel with the amount given in reference 18. Please clarify how the amount is calculated from the given reference. The references are linked to the same CL7 documents. Please clarify. The gross electricity generation for CL 8 has been linked to the reference; However, the link is not accesible. Please clarify the reference link. 25

26 CHECKLIST QUESTION Ref. item COMMENTS It has been stated in section B.4. of version 01 that In the absence of the proposed project activity, same amount of electricity is required to be supplied via either the current power plants or by an increased number of thermal power plants, thus increasing GHG emissions. The statement has been justified by indicating that Turkish electricity generation is composed mainly of thermal power plants. The share of hydroelectric power plants has decreased significantly in recent years, due to the reduction of the economically feasible hydraulic resources. Please supply a reference for the above justification. The related satement for the reference 37 could not be seen in the document. Please supply the page number for the reference 37. Under substep1 b in section B.5 of the version this section the reference law number (footnote #9) given for the environmental law is wrong. Please clarify. The Emission Factors used in the calculations are taken from the IPCC minimum values at the lower limit of uncertainty at a 95% confidence interval (table 1.4 of Chapter 1 of Vol. 2 (Energy) of the 2006 IPCC Guidelines for GHG inventories. However, in section B.6.3. of version 1, it has been stated that The emission factors required for calculation of CO2 emission coefficient have been obtained through IPCC 2006 guidelines for GHG inventories for fuels except for coal and lignite. For lignite and coal, the emission factors have been calculated using country specific heating values of fuels consumed and data from National Greenhouse Gas Inventory of Turkey. Please clarify the reference statement. Draft CL 9 CL10 CL 11 CL12 Final 26

27 CHECKLIST QUESTION Ref. item COMMENTS In Table 13 of the version 01, values used for the calculation of the OM have been presented. The reference for the table is given as the National Inventory of Turkey In 2007 inventory; IPCC mid values have been used. However, the EF values given in the table stand for the min IPCC min values. According to the Tool to calculate the emission factor of an electricity system it is convenient to use IPCC min values. So, please clarify the reference for the EF factors. In the version 01 of the, it has been stated that the list of most recent capacity additions to the grid and their average and firm generation capacities are available at the TEİAŞ web page The reference to the given statements are reference number 32, 33,34,35. In the BM calculations worksheet, it is seen that the capacity addition data for the years 2006 and 2007 are taken from the TEIAS website which are given as reference 34 and 35 and in the. However the data that is used in the calculations does not give detailed plant based information on the capacity additions. Please revise your calculations and the references given in the using the detailed lists that are given in the annexes of capacity projection reports that are also available on the TEIAS website. In Table 13 of the version 01, NCV Values used for the calculation of the OM have been presented. The reference for the table is given as the National Inventory of Turkey Documented data sources in national energy statistics should be used for computing NCV values according to Tool to calculate the emission factor of an electricity system. Please revise your data sources for heating values of Draft Final CL13 CAR02 CAR03 27

28 CHECKLIST QUESTION ii. be reviewed as part of its publication by a recognised competent organization? Ref. item COMMENTS fuels and recalculate the NCV value. Please present the calculation transparently in the. Please revise the references and the table 13 in the. TEIAS and IPCC are both reputable sources, and their publication processes are deemed reliable. c. Project grouping 1. Is this a grouped project? VCS 5.6 The project is not a grouped project as validated through the site visit. 2. If yes, was this grouped project described in one VCS? 3. Does this include a description of the central GHG information system and controls associated with the project and its monitoring? 4. What is the sampling carried out by the VCS verifier? 5. Have the sampling of a grouped project taken account of any sub groups and associated activities within each sub group? 6. Do this project, which intends to apply for the VCS Program VCUs as part of a grouped project also comply with the VCS Program requirements for grouped projects, detailed in the most recent version of the Program Guidelines on d. Content of the VCS b. Is the D used as a basis for validation prepared in accordance with the latest template and guidance from the VCS? c. Is there a project title? tem p VCS 5.6 This is not a grouped project. The checklist question is N/A. VCS 5.6 This is not a grouped project. The checklist question is N/A. VCS 5.6 This is not a grouped project. The checklist question is N/A. VCS 5.6 This is not a grouped project. The checklist question is N/A. VCS 5.6 This is not a grouped project. The checklist question is N/A. VCS 5.7 The VCS template given in the web address v- c-s-org.tr has not been used. The D format given in the UNFCC website has been used. Please clarify the assumptions and the reasons in the The project title is Uluabat 100 MW Hydroelectric power plant as stated under section A.2.of the. The date of the document is version 01. Draft CL14 Final 28

29 CHECKLIST QUESTION d. Type/Category of the project tem p i. Is it defined wether the project category is part of a GHG program that has been approved by the VCS Board? Ref. item tem p COMMENTS The Project fits in: Sectoral Scope Number: 1 Sectoral Scope: Energy Industries Renewable Energy Draft Final In section A.2 of the the project category has been specified as the following: CL15 Type I : Renewable energy projects Category I.D. : Renewable Energy Generation for a Grid Sub-category : Hydro Category ID is applicable to small scale projects please clarify the contradiction and revise in accordance. ii. Is it specified if the project is a Grouped project? tem p 1.2 It is not specified if the project is a grouped project. Please specify if the project is a grouped project. CL16 e. Is the amount of emission reductions over the crediting period estimated, including project size? (Micro project: Less than 5,000 tonnes CO2 equivalent emissions reductions per year; Mega Project: More than 1,000,000 tonnes CO2 equivalent emissions reductions per year) tem p 1.3 Under section A.4.4. of the version 1 the amount of emission reductions over the crediting period is estimated as 229,751yearly resulting in a total reduction of 2,229,751 of CO2 for the first crediting period. Annual generation has been defined for three scenarios according to the 2005 dated Feasibility report approved by the State of Hydraulics ( Secenario 1 : ( up to year 2021) when only downstream water demand has been supplied from the dam the total energy production will GWH, CAR04 29

30 CHECKLIST QUESTION Ref. item COMMENTS industrial water supply from the dam ): GWH, Scenario 3 ( after year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH Draft Final f. Is a brief description of the project provided? tem p Please clarify the annual emission reductions according to the above statement. In addition please also clarify the emission reductions according to the changes requested in the EF calculations. Please state the project size in the (Micro project: Less than 5,000 tonnes CO 2 equivalent emissions reductions per year; Mega Project: More than 1,000,000 tonnes CO 2 equivalent emissions reductions per year) 1.4 The brief description of the project activity is provided under section A.2. of the rev01 as the following: CL17 Uluabat HEPP and Cinarcik Dam Project is a hydroelectric power plant project located on the lower basin of Orhaneli Creek, one of the major branches of Mustafa Kemalpasa River. It is built within the scope of Emet Orhaneli Project developed by General Directorate of DSI (State Hydraulic Works) for utilizing the water potential in Marmara Region and has two components. First component, Cinarcik Dam is built by DSI mainly for providing agricultural, industrial and drinking water for Bursa city whereas second component, Uluabat HEPP project has been awarded to Akenerji Elektrik Uretim A.S. for 49 years period after the bidding by the Turkish Energy Market Regulatory Authority (EMRA). The following points given below have been 30

31 CHECKLIST QUESTION Ref. item COMMENTS validated through the feasibility report and during the interview with the Hyraulic States- Bursa ( DSİ Bölge Müdürlüğü ). Draft Final 1) A planning report named Emet Orhaneli Project Çınarçık Dam and Uluabat HEPP Report has been prepared in 1987 by State of Hydraulics Works. The report focused on electricity, irrigation and potable water demand in Bursa areas. During the interviews with the State of Hydraulic Works it has been stated that the primary goal of the project was energy supply and irrigation and water supply aim of the project has been defined as the secondary goal. In the planning report the planned installed capacity of the HEPP has been stated as 120 MW. 2) In 1994 Bursa Water Supply Project Master Plan and Nilufer Dam Feasibility Report, the water demand that will be supplied from the dam has been defined as totally 145 million m3/year in two phases as 2021 and 2028 years. In addition it has been checked through the interviews with the State of Hydraulic Works that there has been no change to the master plan provisions. 3) The construction and the operation of the dam has been decided to carry out by State of Hydraulic Works and the construction of the energy tunnel and the HEPP has been decided to be commissioned by State of Hydraulics. 4) In 2005 Uluabat HEPP and power tunnel feasibility report has been prepared by 31

32 CHECKLIST QUESTION Ref. item COMMENTS Akenerji Elektrik Uretim A.S. and the report has been approved by State of Hydraulics. Draft Final The report defines the Uluabat HEPP project mainly as the following: Installed capacity of HEPP has been defined as 100 MW Annual generation has been defined for three scenarios ( Secenario 1 : ( up to year 2021) when only downstream water demand has been supplied from the dam the total energy production will GWH, Secenario 2 ( up to year 2028 which includes 1 st stage of drinking, usage and industrial water supply from the dam ): GWH, Scenario 3 ( after year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH 5) Production has been awarded to Akenerji Elektrik Uretim A.S. for the following conditions on : Installed capacity is 100 MWe and the estimated annual production is KWh 32

33 CHECKLIST QUESTION Ref. item COMMENTS The brief description of the project activity is provided under section A.2. of the rev01. In line with the Bursa Water Supply Project Master Plan and Nilufer Dam Feasibility Report, Uluabat HEPP and power tunnel feasibility report, Emet Orhaneli Project Cinarcik Dam and Uluabat HEPP Report, Production License and Water Usage Agreement; please clarify The scope of the Emet Orhaneli Project Cinarcik Dam and Uluabat HEPP in the. The brief description of the project activity is provided under section A.2. of the rev01. In line with the Bursa Water Supply Project Master Plan and Nilufer Dam Feasibility Report, Uluabat HEPP and power tunnel feasibility report, Emet Orhaneli Project Cinarcik Dam and Uluabat HEPP Report, Production License and Water Usage Agreement; please clarify the scope of the proposed project that will be carried out by Akenerji Elektrik Uretim A.S. in the. The brief description of the project activity is provided under section A.2. of the rev01. Please clarify the estimated energy production in the, considering the water demand to be supplied from the Cinarcik Dam according to Bursa Water Supply Project Master Plan and Nilufer Dam Feasibility Report and water usage agreement The brief description of the project activity is provided under section A.2. of the rev01. The brief description of the project activity is provided under section A.2. of the rev01. Please clarify the installed capacity and the estimated annual energy generation according to the production license in the. Please include water usage agreement and production license in the as an annex Draft CL18 CL19 CL20 CL21 CL22 Final 33

34 CHECKLIST QUESTION Ref. item COMMENTS In section A.2. of the rev01, it has been stated that The project consists of a rock filled embankment dam at 210 meters riverbed elevation, 556 m long horseshoe shaped derivation tunnel, 11,820 m long transmission tunnel, source and downstream cofferdams, spillway, 838 m long penstock pipe and a power plant with 2 vertical axis Francis turbines. The statement that the project consists of a rock filled embankment dam creates a conflict with that the scope (boundary) of the proposed project is construction of energy tunnel &the HEPP and energy generation. Please clarify the statement in the. Main goals of the project have been included under section A.2. of version 01. Supply of water (for irrigation, usage and drinking) to the Bursa region is not in the scope of the Uluabat Power Tunnel and HEPP project since the dam will be operated by State of Hydraulic works. Please clarify the main goal of the project considering the scope that will be in charge of Ak-enerji. Main goals of the project have been included under section A.2. of version 01. It has been stated that more than 150 people will be employed during the construction phase and about 15 people will be recruited during the implementation phase. During the site visit it has been checked that about 150 people will be employed during the construction phase. Please provide the estimated number of people that will be employed during the operation phase. Please clarify the impact of the project in the share of HEPPs to justify that the project will increase share of HEPPs in electricity generation mix of Turkey. Draft CL23 CL24 CL25 CL26 Final 34

35 CHECKLIST QUESTION g. Is the project location, including geographic and physical information allowing the unique identification and delineation of the specific extent of the project, and including GPS project boundaries, provided? Ref. item tem p COMMENTS Main goals of the project have been included under section A.2. of version 01. Please clearly state the utilization ratio of hydroelectric potential of Turkey in the western part of Turkey to justify that the project will utilize the hydroelectric potential of Turkey in the western part of Turkey. 1.5 The project location has been given as Bursa Province, Uluabat District in A & A.4.14 of the version 01 as validated through the site visit. The detailed information on the project location, including geographic and physical information allowing the unique identification and delineation of the specific extent of the project, and including GPS project boundaries are provided under section A.4.4. of the version 01 as the following. The project site lies between 28º 46' - 28 º 43' E longitudes and 40º 03' - 40º 09' N latitudes. The closest settlement is the Akçalar Village, about 20 km to the project site. Other settlements close to the project site are the towns of Orhaneli and Buyuk Orhan in the south, within the province of Bursa. The project lies between the Emet Creek in the west and Nilufer Creek at the east. Draft CL27 CL28 Final During the site visit, the GPS coordinates ( including altitude) of the surge tank, HEPP building has been checked according to the feasibility report dated However please also include the boundaries that the given coordinates stand for to clarify if the coordinates define a project boundary that starts with the energy tunnel and ends with the connection point to the grid. 35

36 CHECKLIST QUESTION Ref. item COMMENTS The project locations have been given in section A.4.4 of the. Please include the connection point of the transmission line to the grid in the to clarify the unique identification of the project. Draft CL29 Final h. Duration of the project activity/crediting period tem p i. Is the project start date, i.e., the date on which a financial commitment was made to the project and the project reached financial closure, provided? tem p Under Section C.1.2. of the VCS version 01, it is stated that the project construction has started on and the plant is expected to start operation by CL30 ii. Is the crediting period start date, i.e., the date the first monitoring period commenced, provided? (VCS project crediting period: A maximum of ten years which may be renewed at most two times) tem p Please provide a proof to clarify the start date of the construction and a workplan also to clarify the expected start date of the operation. 1.6 Under section C of the version 01; it has been stated the crediting period is expected to start in 01/01/2010. Under section C of the version 01, it has been stated that the project will use a renewable crediting period of 2x10 years. i. Are the conditions prior to project initiation provided? j. Is a description of how the project will achieve GHG emission reductions and/or removal enhancements provided? tem p tem p 1.7 Please include the conditions prior to the project initiation in the. 1.8 In section B.5 of the version 1, a description of how the project will achieve GHG emission reductions have been presented as the following According to the applied methodology (ACM0002) baseline scenario for the project has been defined as generation of equal amount of electricity by the power plants connected to the CL31 CAR5 36

37 CHECKLIST QUESTION Ref. item COMMENTS grid. Emission factor for the baseline scenario has been calculated according to the combined margin approach as defined by the selected methodology. Within this framework, project is expected to generate about 373 GWh of electricity and reduce about 229,751 tco2 annually, through replacing the electricity that would need to be supplied via the National grid in the absence of the project activity. Draft Final Annual generation has been defined for three scenarios according to the 2005 dated Feasibility report approved by the State of Hydraulics ( Secenario 1 : ( up to year 2021) when only downstream water demand has been supplied from the dam the total energy production will GWH, Scenario 2 ( up to year 2028 which includes 1 st stage of drinking, usage and industrial water supply from the dam ): GWH, Scenario 3 ( after year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH Please clarify the annual emission reductions according to the above statement. In addition please also clarify the emission reductions according to the changes requested in the EF calculations. 37

38 CHECKLIST QUESTION k. Are project technologies, products, services and the expected level of activity described? l. Does the VCS include identification of relevant local laws and regulations related to the project and demonstration of compliance with them? Ref. item tem p tem p COMMENTS 1.9 In section A.4.3 of the the technologies and the services have been given as the following Hydroelectric power plants are structures that generate electricity utilizing energy of flowing water. Project consists of two vertical axes Francis turbines and generators which are used to transform the potential energy of water to mechanical energy at the first stage and later into electrical energy. Please clearly describe the characteristics of the project and the technologies to be used in the 1.10 The relevant local laws and related to the project and the alternatives to the proposed project has been listed under substep1 b in section B.5 of the version 1. The relevant local regulations related to the project has not been listed in the. Demonstration of compliance to local laws and regulations have not been included in the D Draft Final CL32 CAR06 CAR07 m. Are risks that may substantially affect the project s GHG emission reductions or removal enhancements idendified? n. Is confirmation that the project was not implemented to create GHG emissions primarily for the purpose of its subsequent removal or destruction demonstred? o. Has the project created another form of environmental credit (for example renewable energy certificates)? p. If yes, has the proponent provided a letter from the program operator that the credit has not tem p tem p tem p tem 1.11 Please clearly state in the ; if there are any risks that may substantially affect the project s GHG emission reductions 1.12 Confirmation that the project was not implemented to create GHG emissions primarily for the purpose of its subsequent removal or destruction has been demonstrated in the VCS section F.1. of the version It has been stated in section F.2. of the VCS that the project owner confirms that the project activity does not create any other form of environmental credits Since the project has not created another form of environmental credit as stated above this CL33 N/A N/A 38

39 CHECKLIST QUESTION been used and has been cancelled from the relevant program? q. Was the project rejected under other GHG programs (if applicable) Ref. item p tem p r. If yes, does the project: tem p i. Clearly state in its VCS all GHG programs for which the project has applied for credits and why the project was rejected? (Such information shall not be deemed commercially sensitive information) tem p COMMENTS checklist question is N/A Please clarify if the project has been rejected under other VCS programs If the answer to the CL 34 is yes ; ( if the project has been rejected under other GHG programs ) please clearly state in its VCS all GHG programs for which the project has applied for credits and why the project was rejected Draft CL34 CL35 Final ii. provide the VCS verifier and Registry with the actual rejection document(s) including explanation? tem p 1.14 If the answer to the CL 34 is yes ; ( if the project has been rejected under other GHG programs ) please supply the DOE and Registry with the actual rejection document(s) including explanation CL36 s. Are project proponents roles and responsibilities, including contact information of the project proponent, other project participants provided? tem p 1.15 In section B.8 of the rev 01; it has been stated that the baseline has been calculated by Kemal Demirkol-GTE. The contact information has been included in the section. In section B.8 of the rev01; it has been stated that the monitoring methodology has been developed by Kemal Demirkol and Ferit Aran.The contact information has been included in the section. In section A.3 of the rev01; Akenerji Elektrik Uretim A.S. and Global Tan Energy Ltd. Has been defined as project participants. Turkey has been defined as the host party in section A.3 of the and it is indicated that the host party is not a project participant. Contact information on participants in the project activity has been included in annex 1 of the rev01. 39

40 CHECKLIST QUESTION t. Is any information relevant for the eligibility of the project and quantification of emission reductions or removal enhancements, including legislative, technical, economic, sectoral, social, environmental, geographic, site-specific and temporal information provided? u. Is there any commercially sensitive information that has been excluded from the public version of the VCS that will be displayed on the VCS Project Database? Ref. item tem p tem p v. If yes, was it listed? tem p w. Are title and reference of the VCS methodology applied to the project activity and explanation of methodology choices provided? x. Does the project use one of the VCS program approved project methodologies and provide information relevant to methodology deviations or methodology revisions? y. Are the choice of the methodology and its applicability to the project activity justified? tem p tem p tem p COMMENTS 1.16 Please supply economic, sectoral, social, environmental, geographic, site-specific information in the 1.17 Please clarify in the if there is any commercial sensitive information that has been excluded from thee public version of the that will be displayed on the VCS Project Data Base If there is any commercial sensitive information that has been excluded from the public version of the VCS, please list. 2.1 Under section B.1. of the VCS, the title and the reference of the methodology are given as follows: The United Nations approved consolidated baseline methodology applicable to this project is ACM0002 Consolidated methodology for gridconnected electricity generation from renewable sources, Version 10. ACM0002 refers to the following tools: Tool for the demonstration and assessment of additionality, Version 05.2, 2and Tool to calculate the emission factor for an electricity system, Version The project uses a Clean Development Mechanism approved methodology without any deviations or revisions to the existing methodology. 2.2 For the justification of the choice of the methodology and its applicability to the project, İt is stated in section B.2. of the ver 01 that Uluabat 100 MW HEPP is a grid connected renewable electricity generation project. The statement is also validated by the DOE from the generation license. Draft Final CAR08 CL37 CL38 40

41 CHECKLIST QUESTION Ref. item COMMENTS For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the rev01 that; the project does not involve switching from fossil fuel use to renewable energy at the site of the project activit. The satement has also been validated by the DOE through the site visit. For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the rev01 that; the geographic and system boundaries for the relevant electricity grid can be clearly identified and information on the characteristics of the grid is available. Please clarify the sources for identification and the charecterics of the grid in the. Draft CL39 Final z. Are GHG sources, sinks and reservoirs identified for the baseline scenario and for the project? tem p 2.3 For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the rev01 that; Project Power density is higher than 4 W/m 2 Please clarify which applicability criteria is applied to the project ( new reservoir, existing reservoir with no change volume or existing reservoir with a change in the volume). Please justify the applicability criteria selected. For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the rev01 that; Project Power density is higher than 4 W/m 2 Please clearly present how the power density has been calculated by also giving references for the data used in calculation. There are no GHG sinks and reservoirs defined in ACM 002 version 10. Under section B.3 of the version 01, the GHG sources are identified for the baseline scenario. CAR09 CL40 41

42 CHECKLIST QUESTION aa. Is it described how the baseline scenario is identified and the identified baseline scenario? bb. Has the project proponent selected the most reasonable baseline scenario for the project? cc. Does it reflect what most likely would have occurred in the absence of the project? Ref. item tem p tem p tem p COMMENTS Under section B.3 of the version 01, the GHG sources are identified for the project in the tabular format. CO 2 emissions have been identified as a major emission source in the tabular format and the methodology is referred for justification. Methane emissions has not been included in the sources and the explanation is given as that the project is zero emission electricity generation. CH 4 emissions has been identified as major emission sources for hydroelectric projects according to ACM 002 version 10. Please reassess the emissions sources and the justifications in the section B Under section B.4 of the VCS version 01, it is stated that the baseline scenario is identified according to the methodology ACM0002 which is as follows: 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, as reflected in the combined margin (CM) calculations described in the Tool to calculate the emission factor for an electricity system. It is also approved by the validation team that the selected baseline scenario is in line with the methodology. 2.4 Yes. The project proponent has selected the most reasonable baseline scenario for the project activity. 2.4 It has been stated in section B.4. of version 01 that In the absence of the proposed project activity, same amount of electricity is required to be supplied via either the current power plants or by an increased number of thermal power plants, thus increasing GHG emissions. Draft Final CAR10 CL9 42

43 CHECKLIST QUESTION Ref. item COMMENTS Draft Final dd. Is it described how the emissions of GHG by source in baseline scenario are reduced below those that would have occurred in the absence of the project activity (assessment and demonstration of additionality)? ee. Has the project proponent demonstated, in the VCS, in addition to describing how the tem p tem The statement has been justified by indicating that Turkish electricity generation is composed mainly of thermal power plants. The share of hydroelectric power plants has decreased significantly in recent years, due to the reduction of the economically feasible hydraulic resources. Please supply a reference for the above justification. 2.5 Under section B.5 of the version 01, it is described how the GHG emissions by source are reduced below those that would have occurred in the absence of the project activity using the latest version (version 05.2) of the UNFCCC Methodological Tool Tool for the demonstration and assessment of additionality as suggested by the methodology ACM0002. The description has been given as the following in section B.5 of the According to the applied methodology (ACM0002) baseline scenario for the project has been defined as generation of equal amount of electricity by the power plants connected to the grid. Emission factor for the baseline scenario has been calculated according to the combined margin approach as defined by the selected methodology. Within this framework, project is expected to generate about 373 GWh of electricity and reduce about 229,751 tco2 annually, through replacing the electricity that would need to be supplied via the National grid in the absence of the project activity. Additionality of the proposed project has been assessed according to the applied tool for demonstration of additionality as shown in the following steps 2.5 The project proponents have used the UNFCCC Approved consolidated baseline and monitoring CAR 5 43

44 CHECKLIST QUESTION project meets the VCS methodology, that the project is additional based on one of the tests, the project test, the performance test, and technology test? ff. Are title and reference of the VCS methodology (which includes the monitoring requirements) applied to the project activity and explanation of methodology choices provided? gg. Is monitoring, including estimation, modelling, measurement or calculation approaches desbride including: Ref. item p tem p tem p i. Purpose of monitoring? tem p ii. Types of data and information to be reported, including units of measurement? iii. Origin of the data? tem p tem p COMMENTS methodology ACM0002 Consolidated baseline methodology for grid-connected electricity generation from renewable sources and the additionality tool referred in this methodology. 3.1 In section B.4 of the version 01; the title and the reference of the VCS methodology applied to the project has been given as the following; This project follows the methodology described in the ACM0002 Consolidated baseline methodology for grid-connected electricity generation from renewable sources. Selected methodology has been applied together with the tool to calculate the emission factor for an electricity system, version 01.1 and tool for assessment and demonstration of additionality, version The monitoring procedures should include purpose of monitoring according to clause 5.11 of VCS 2007:1. Please include the purpose of monitoring in the monitoring procedures or the related section of the. 3.2 Types of data and information to be reported including the units of measurement has been given in section B.7. of the VCS version Origin of data for net electricity generated and delivered to the grid by Uluabat HEPP is given in section B.7. of the version 01 as Metering devices used in power plants and the monthly records signed by TEİAŞ &plant manager. The definition is line with the legislation in Turkey. Origin of data for quantity of fuel combusted in diesel power generator is given in section B.7. of the version 01 as; on site measurements from equipment working hours. Draft Final CAR11 44

45 CHECKLIST QUESTION iv. Monitoring, including estimation, modelling, measurement or calculation approaches? v. Monitoring times and periods, considering the needs of intended users? vi. Monitoring roles and responsibilities? Ref. item tem p tem p tem p COMMENTS In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 namely EG Facility, Cappj, PE ffy, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology. 3.2 Origin of data for quantity of fuel combusted in diesel power generator is given in section B.7. of the version 01 as; on site measurements from equipment working hours. Please clarify the calculation methodology of the fuel combusted in diesel generator in the tabular format 3.2 In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 namely EG Facility, Cappj, PE ffy, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology. Monitoring frequency has been presented as continuously for the FCi,y parameter in section B.7.1. of the version 01. Please clarify the recording period also. 3.2 Monitoring roles and responsibilities have been defined in section B.7.2 of the version as validated during the site visit. Draft Final CAR12 CL 41 CAR12 CL42 45

46 CHECKLIST QUESTION vii. Managing data quality? viii. Managing data quality? hh. Are data and parameters monitored/selecting relevant GHG sources, sinks and reservoirs for monitoring or estimating GHG emissions and removals described in the tabular form including: Ref. item tem p tem p tem p COMMENTS 3.2 Calibration procedures have been defined as the following in section B.7 of the version 01 Calibration of the metering devices will be made by TEIAS and sealed before the commissioning of the power plant. The meters will be calibrated by TEIAS when there is an inconsistency between two devices. Since the procedure is in line with the TEIAS ( Turkish State of Electrical Works) regulations, it has been accepted by the DOE. 3.2 Calibration procedures have been defined as the following in section B.7 of the version 01 Calibration of the metering devices will be made by TEIAS and sealed before the commissioning of the power plant. The meters will be calibrated by TEIAS when there is an inconsistency between two devices. Since the procedure is in line with the TEIAS ( Turkish State of Electrical Works) regulations, it has been accepted by the DOE. According to ACM 002 version 10, All data collected as part of monitoring should be archived electronically and be kept at least for 2 years after the end of the last crediting period. Please include the archiving methodology 3.3 In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 namely EG Facility, Cappj, PE ffy, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring methodology. Draft Final CAR13 CAR12 46

47 CHECKLIST QUESTION i. Data unit? tem p Ref. item 3.3 COMMENTS The parameter, namely EGy, is not required to be monitored according to ACM 002 version 10. However the named parameter has been included in the monitoring parameters in section B.7. of the version 01. Please clarify the reason for including the named parameter. EGy, EGy, total EF CO2, FCi,y, GE, NCV ara Data and parameters selected for estimating GHG emissions and removals. The parameters selected have been checked from the ACM002 version 10. In section B.6.2 of the version 01; the data units used are given as the following: EGy:MWh ; EF CO2 :TC0 2 /TJ; FCi,y:tons or 100 m3 gasses; η:%; NCV:TJ/kt. According to Tool to calculate the emission factor of an electricity system the data units for NCV and EF CO2 are GJ/kt and TCO 2 /GJ. The definition of the data units in TJ are accepted since both of the parameters are defined in the TJ unit. However please clarify the reason for selecting the parameter for the NCV as TJ/ kt where the other parameters are based on the tonnes unit. In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 ; namely EG Facility, Cappj, PEffY, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology. Draft Final CL43 CL44 CAR12 47

48 CHECKLIST QUESTION ii. Description? iii. Source of data to be used? Ref. item tem p tem p COMMENTS In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 ; namely EG Facility, Cappj, PEffY, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology.. Under section B.7. of the, the description for EGy has been defined as the net electricity generated and delivered to the grid by Uluabat power plant in year The description of the the parameter does not match with the indicator according to ACM002 version 10. Please clarify In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 ; namely EG Facility, Cappj, PEffY, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology. Draft Final CAR12 CL45 CAR12 The source of data for the parameter EGy has been defined as the feasibility report in section B.6.2. of the version 01 in the tabular format; please clarify. CL46 48

49 CHECKLIST QUESTION Ref. item COMMENTS IPCC default values at lower limit of 95% confidence interval has been used as the source of data for EF CO2 i,y factors in section B.6.2. of the version 01 in the tabular format Draft Final TEİAS Web page which refers to government records have been referenced as the source for the parameter FCi,y. in section B.6.2. of the version 01 in the tabular format. However the link given only includes data for year Please clarify the source of data for the year 2006 and 2005 also. CL47 iv. Value of data applied for the purpose of calculating expected emissions reductions? tem p For the generation efficiency of coal, the value of present thermal power plants has been used from Türkiye Çevre Atlası prepared by Ministry of Environment and Forestry as indicated in section B.6.2. of the rev 01 and the EF calculation.xls. However, the document has been published in 2004 and refers to data from power plants of all vintages in operation. On the other hand, the BM comprises most recently built power plants which are expected to be of higher efficiency. Hence using the default efficiency factor in the TOOL (for new power plants built after 2000), which is slightly higher, would be more appropriate. TEİAS Web page which refers to national average default values has been referenced for NCV values in B.6.2 of the version In the BM calculations the employed emission factor for fuel oil is the same as the IPCC lower level for residual fuel oil. However according to NIR there is no residual fuel oil usage on that year. Please clarify. CAR14 CL48 49

50 CHECKLIST QUESTION v. Description of measurement methods and procedures to be applied? vi. QA/QC procedures to be applied? Ref. item tem p tem p tem p COMMENTS The table in annex 3 of the version 1 has been referenced as the values applied for the NCV values. However, NIR 2007 has been refenced in the table in Annnex 3. Please clearly present how the NVC values are computed. In the OM&BM calculations the employed emission factor for coal is the same as the IPCC lower level for antracite. However according to NIR there is no value for antracite Please clarify the assumption. 3.3 In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 ; namely EG Facility, Cappj, PEffY, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology. 3.3 In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 namely EG Facility, Cappj, PE ffy, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Draft Final CL49 CL50 CAR12 CAR12 It has been stated that the data recorded by the equipment will be cross checked by the fuel invoices while describing the QA/QC procedures for the FCi,y parameter. 50

51 CHECKLIST QUESTION vii. Any comment? ii. Is the monitoring plan described? jj. Are methodological choices explained? kk. Are GHG emissions and/or removals for the baseline scenario quantified? ll. Are GHG emissions and/or removals for the project quantified? Ref. item tem p tem p tem p tem p tem p COMMENTS 3.3 In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 ; namely EG Facility, Cappj, PEffY, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology. 3.4 The monitoring plan has been defined in section B.7.2 of the version For the FCi,y parameter it has been stated that the gaugaes and reading devices on diesel generators will be used for monitoring of FC,iy parameter in section B.6.2. of the version 01. Please clarify the procedure. Please clarify how the amount of fuel stocked in the tank of the generator will be defined if data will be checked form the invoices provided by the plant operator. 4.2 The GHG emissions have been quantified for the baseline scenario according to ACM002 version In section B.6.3 of the version 01, it has been stated that the only emission source for the project is the diesel generator which is used as a auxiliary power. The calculation methodology has been transparently presented in the. Under section B.3 of the version 01, the GHG sources are identified for the project in the tabular format. CO 2 emissions have been identified as a major emission source in the tabular format and the methodology is referred for justification. Draft Final CAR12 CL51 CAR10 51

52 CHECKLIST QUESTION mm. Are GHG emission reductions and removal enhancements for the GHG project quantified? Ref. item tem p 4.4 COMMENTS Methane emissions has not been included in the sources and the explanation is given as that the project is zero emission electricity generation. CH 4 emissions has been identified as major emission sources for hydroelectric projects according to ACM 002 version 10. Please reassess the emissions sources and the justifications in the section B.3. It has been stated that since the reservoir is mainly built before start of power plant component, emissions from reservoir was not included in emission reductions calculations in section B.6.3 of the version 01. During the site visit, it has been observed that the dam has been built in 2008 and the main purpose of the Orhaneli-Emet Project was to generate electricity. Please clarify the justification. It has been stated that the project emission has been defined as 0 in section B.6.2. of the version 01. Please present the calculation of the power density and justify how the project emission has been defined as 0. ( Note: Please give clear references for the Apj and Capj) The emission reductions for the GHG project has been quantified in section B.6.4. of the version01. The amount of emission reductions over the crediting period is estimated as 229,751yearly resulting in a total reduction of 2,229,751 of CO2 for the first crediting period. Annual generation has been defined for three scenarios according to the 2005 dated Feasibility report approved by the State of Hydraulics ( Secenario 1 : ( up to year 2021) when only downstream water demand has been supplied ca Draft CL52 CL53 Final CAR15 52

53 CHECKLIST QUESTION Ref. item COMMENTS from the dam the total energy production will GWH, Scenario 2 ( up to year 2028 which includes 1 st stage of drinking, usage and industrial water supply from the dam ): GWH, Scenario 3 ( after year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH Draft Final nn. Was a summary of environmental impact assessment, when such an assessment is required by applicable legislation or regulation, provided? ISO , 5.2.k ISO k Please clarify the annual emission reductions according to the above statement. In addition please also clarify the emission reductions according to the changes requested in the EF calculations In section B.6.4 of the version 01, the annual emission reductions have been presented in the tabular format for 10 years. However, total numbers of crediting years have been defined as 7 years please clarify. In section D.1. of the version 01, it has been indicated that the Uluabat HEPP and Cinarcik Dam Project have been exempted from the scope of the EIA report since the project approval date is before The permits that indicated that EIA report is not required according to EIA legislation has been seen by the DOE. The permits have been given for the transmission lines and the dam body separately. The dates of the permits are; and The permits do not include the HEPP, please clarify if EIA report is required for HEPP. In section D.1 of the version 01, it has been stated that an Environmental Impact Assessment Report has been prepared by PRD Planlama Arastirma and Gelistirme ve Danismanlık Sirketi for the International Finance Corporation in order to evaluate the possible impacts of the project. CL54 CL55 CL56 53

54 CHECKLIST QUESTION oo. Were relevant outcomes from stakeholder consultations and mechanisms for on-going communication provided? Ref. item tem p COMMENTS Accordingly, it has been stated that the report stated that the project does not have significant impacts and EIA is positive for the project. The EIA report prepared has been submitted to the DOE by the PP. Please clarify the pages or the sections that, it has been stated that the report stated that the project does not have significant impacts and EIA is positive for the project. 6 Stakeholder consultation meeting is not mandatory for this project according to the legal requirements since it is exempted from EIA. However initial stakeholder consultation was held on in Akçalar Köyü. Stakeholders were invited to the meeting by local newspaper dated Draft CL57 Final Results from the initial stakeholder consultation report were provided in section E.2. of the version 01. It has been stated that the main concerns raised by the participants were reduction of the oxygen content and the heating of water outlet of the HEPP, the damage of transmission tunnel. The replies of the company have also been included in section E.3. of the version 01. pp. Were chronological plan for the date of initiating project activities, date of terminating the project, frequency of monitoring and reporting and the project period, including relevant project activities in each step of the GHG project cycle provided? tem p During the site visits,it has been observed that there were some areas that were/will be expropriated. Please clarify how the compensation was realized on the issue. 7 Please clarify the chronological plan for the date of initiating project activities, date of terminating the project, frequency of monitoring and reporting in the qq. Was evidence of proof of title provided through 8.1 The revised generation license was sent to the CL59 CL 58 54

55 CHECKLIST QUESTION one of the following: Ref. item tem p i. a legislative right? tem p ii. a right under local common law? tem p iii. ownership of the plant, equipment and/or process generating the reductions/removals? iv. a contractual arrangement with the owner of the plant, equipment or process that grants all reductions/removals to the proponent? rr. Does the project reduce GHG emissions from activities that participate in an emissions trading program, or take place in a jurisdiction or sector in which binding limits are established on GHG emissions? ss. If yes, have project proponents provided evidence that the reductions or removals generated by the project have or will not be used in the Program or jurisdiction for the purpose of demonstrating compliance, such as: i. a letter from the Program operator or designated national authority that emissions allowances (or other GHG credits used in the Program) equivalent to the reductions/removals generated by the project have been cancelled from the Program; or national cap as applicable? ii. purchase and cancellation of GHG allowances equivalent to the tem p tem p tem p tem p tem p tem COMMENTS VCS Validation Report Draft Final validation team as a proof of title, and please also present the generation license taken from EMRA as an attachment to the VCS. Please also state who will have the ownership of the emission reductions. 8.1 N/A N/A 8.1 N/A N/A 8.1 N/A N/A 8.1 N/A N/A 8.2 N/A N/A 8.2 N/A N/A 8.2 N/A N/A 8.2 N/A N/A 55

56 CHECKLIST QUESTION reductions/removals generated by the project related to the Program or national cap? e. Additionality a. Has the project proponent demonstrated that the project is additional using one of the following tests: Test 1 - The project test; Test 2 Performance test; Test 3 Technology test? Ref. item p COMMENTS VCS 5.8 The project proponents have used the UNFCCC Approved consolidated baseline and monitoring methodology ACM0002 Consolidated baseline methodology for grid-connected electricity generation from renewable sources and the additionality tool referred in this methodology. According to Frequently Asked Questions sections on the VCS website, the VCS additionality guidance is not a substitute for the additionality requirements set out in the methodology being used. Therefore the checklist question is N/A. The additionality of the project activity is assessed using Table 3: Checklist based on Methodological tool for assessment of additionality (version EB 39 report Annex 10) of this protocol. b. If the project proponent used Test 1: VCS 5.8 i. Step 1 Regulatory Surplus - Is the project be mandated by any enforced law, statute or other regulatory framework? (If yes a CAR shall be issued and the project shall be deemed non additional). VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. ii. Step 2 Implementation Barriers Does the project face one (or more) distinct barrier(s) compared with barriers faced by alternative projects? i. Investment Barrier Does the project face capital or investment return constraints that can be overcome by the additional revenues associated with the VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. Draft N/A N/A N/A Final 56

57 CHECKLIST QUESTION generation of VCUs? ii. Technological Barriers Does the project face technology-related barriers to its implementation? iii. Institutional barriers Does the project face financial, organizational, cultural or social barriers that the VCU revenue stream can help overcome? Ref. item COMMENTS VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. iii. Step 3 Common Practice VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. i. Is project type common practice in sector/region, compared with projects that have received no carbon finance? ii. if it is common practice, have the project proponents identified barriers faced compared with existing projects? iii. Is the demonstration that the project is not common practice based on guidance in the GHG Protocol for Project Accounting, Chapter 7? a. Was data on all baseline candidates within the geographic area collected? b. Was a relative percentage for each different technology or practice calculated? (Common practice refers to the predominant technologies VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. GHG PRO TOC OL GHG PRO TOC OL AND AND 7.6 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. Draft Final 57

58 CHECKLIST QUESTION Ref. item COMMENTS VCS Validation Report Draft or practices in a given market, as determined by the degree to which those technologies or practices have penetrated the market (defined by a specified geographic area). This percentage could be based on the number of plantsor sites using each technology or practice, or could be weighted by the proportion of the total output for the market that is attributed to each technology or practice.) c. If the project proponent used Test 2: VCS 5.8 i. Step 1 Regulatory Surplus - Is the project be mandated by any enforced law, statute or other regulatory framework? (If yes a CAR shall be issued and the project shall be deemed non additional). VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. ii. Step 2: Performance Standard VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. i. Are the emissions generated per unit output by the project below the level that has been approved by the VCS Program for the product, service, sector or industry, as the level defined to ensure that the project is not business-as-usual? ii. Are performance standard based additionality tests approved through the double VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. Final 58

59 CHECKLIST QUESTION Ref. item COMMENTS approval process and by the VCS Board? (The list of approved performance standards is on d. If the project proponent used Test 3: VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. i. Step 1: Regulatory Surplus - Is the VCS 5.8 Please refer to question a above. The checklist project be mandated by any enforced law, question is N/A. The additionality of the project statute or other regulatory framework? (If activity is assessed using Table 3 of this protocol. yes a CAR shall be issued and the project shall be deemed non additional). ii. Step 2: Technology Additionality Are the project and its location contained in the list of project types and applicable areas approved as being additional by the VCS Program? (The approved list is available on VCS 5.8 Please refer to question a above. The checklist question is N/A. The additionality of the project activity is assessed using Table 3 of this protocol. VCS Validation Report Draft f. Identifying GHG sources, sinks and reservoirs relevant to the project a. Refer to Clause 6, under Methodologies. VCS 5.9 Refer to Clause 6, under Methodologies. - - Final g. Determining the baseline scenario a. Has the project proponent selected the most conservative baseline scenario for the project, based on the requirements in the applicable VCS methodology? VCS 5.10 The project proponent has used ACM0002 Methodology. According to ACM0002 for greenfield renewable power plants the only applicable baseline scenario is : Electricity delivered to the grid by the project activity would have otherwise been generated by the operation of grid-connected power plants and by the addition of new generation sources, as reflected in the combined margin (CM) calculations described in the Tool to calculate the emission factor for an electricity system Under section 2.4 of the VCS version 01, the project proponent has stated that the above mentioned baseline scenario for the project. 59

60 CHECKLIST QUESTION b. Does the baseline scenario set out the geographic scope as applicable to the project? c. Has the project proponent selected or established criteria and procedures for identifying and assessing potential baseline scenarios considering the following: i. The project description, including identified GHG sources, sinks and reservoirs; ii. Existing and alternative project types, activities and technologies providing equivalent type and level ofactivity of products or services to the project; iii. Data availability, reliability and limitations; iv. Other relevant information concerning present or future conditions, such as Ref. item VCS ISO ISO ISO ISO ISO 140 COMMENTS 5.10 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the Draft Final 60

61 CHECKLIST QUESTION legislative, technical, economic,sociocultural, environmental, geographic, site-specific and temporal assumptions or projections. d. Has the project proponent demonstrated equivalence in type and level of activity of products or services provided between the project and the baseline scenario and has explained, as appropriate, any significant differences between the project and the baseline scenario? e. Has the project proponent selected or established, explained and applied criteria and procedures for identifying and justifying the baseline scenario? f. In developing the baseline scenario, has the project proponent selected the assumptions, values and procedures that help ensure that GHG emissions reductions or removal enhancements are not over-estimated? g. Has the project proponent selected or established, justified and applied criteria and procedures for demonstrating that the project results in GHG emissions reductions or removal enhancements that are additional to what wouldo ccur in the baseline scenario? h. Has the project participant demonstrated that the project has met all relevant regulations, legislation and project approvals (e.g. environmental permits)? Ref. item COMMENTS 64-2 checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. ISO ISO ISO ISO VCS 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol. 5.4 The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. The appropriateness of the baseline scenario and the calculations are assessed using Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 of this protocol The baseline scenario is determined according to the methodology ACM0002 therefore the checklist question is N/A. protocol. Draft Final 61

62 CHECKLIST QUESTION Ref. item COMMENTS Draft Final h. Monitoring the GHG project a. Has the project proponent shall established and maintained criteria and procedures for obtaining, recording, compiling and analysing data and information important for quantifying and reporting GHG emissions and/or removals relevant for the project and baseline scenario (i.e. GHG information system)? VCS 5.11 The project proponent has established criteria and procedures for obtaining, recording, compiling and analysing data and information important for quantifying and reporting GHG emission reductions relevant for the project and baseline scenario in line with the ACM 002 version. For detailed information system please see Table 2: Baseline and Monitoring Methodologies: ACM0002 Version 10 b. Do the monitoring procedures include? VCS 5.11 Please refer to question ff-i of this checklist. i. purpose of monitoring? VCS 5.11 Please refer to question ff-i of this checklist. ii. types of data and information to be VCS 5.11 Please refer to question ff-i of this checklist. reported, including units of measurement? iii. origin of the data? VCS 5.11 Please refer to question ff-i of this checklist. iv. monitoring methodologies, including VCS 5.11 Please refer to question ff-i of this checklist. estimation, modelling, measurement or calculation approaches? v. monitoring times and periods, considering VCS 5.11 Please refer to question ff-i of this checklist. the needs of intended users? vi. monitoring roles and responsibilities? VCS 5.11 Please refer to question ff-i of this checklist. vii. GHG information management systems, including the location and retention of stored data? VCS 5.11 Please refer to question ff-i of this checklist c. Where measurement and monitoring VCS 5.11 In section B.7.2 of the, it has been stated that equipment is used, does the project proponent ensure the equipment is calibrated according to current good practice? the calibration of the metering devices will be made by TEIAS and sealed before the commissioning of the plant. The explanation has been accepted since it is in compliance with the legal requirements. Please clarify if the reading device on the diesel generator needs calibration. d. Does the project proponent apply GHG monitoring criteria and procedures on a regular basis during project implementation? VCS 5.11 The project is at validation stage therefore the checklist question is N/A. 62

63 CHECKLIST QUESTION i. Monitoring reports for the GHG project a. Do monitoring reports include all the monitoring data, calculations, estimations, conversion factors and others standard factors as defined in the monitoring clause of the applied VCS Program methodology and set out in the VCS? (A list of VCS approved methodologies is available on Ref. item VCS COMMENTS 5.12 The project is at validation stage therefore the checklist question is N/A. VCS Validation Report Draft j. Records relating to the project a. Has the project proponent kept all documents and records in a secure and retrievable manner for at least two years after the end of the project crediting period.? VCS 5.13 The project is at validation stage therefore the checklist question is N/A. k. Information to validator and verifier a. Has the project proponent made available to the validator the VCS, proof of title and any requested supporting information and data needed to evidence statements and data in the VCS and proof of title? VCS 5.14 The revised generation license was sent to the validation team as a proof of title, and please also present the generation license taken from EMRA as an attachment to the VCS. Please also state who will have the ownership of the emission reductions. CL 59 Final b. Has the project proponent made the VCS and validation report available to the verifiers as well as a monitoring report applicable to the period of monitoring and any requested supporting information and data needed to evidence statements and data in the monitoring report? VCS 5.14 N/A 63

64 TABLE 2 BASELINE AND MONITORING METHODOLOGIES: ACM 0002 VERSION 10 CHECKLIST QUESTION 1. Baseline Methodology Ref. MoV COMMENTS Draft Final Applicability Does the project activity generate electricity from a renewable source? ver01 B.1. Yes the project activity generates electricity from a renewable source Is the power connected to the grid? ver01 B If answer to question above is No, whether it displaces the electricity generated in grid? ver Is the baseline methodology used in conjunction with the approved monitoring methodology ACM0002 ver01 B.1. The power is connected to grid as validated through the feasibility report. N/A The project activity is not a capacity addition to an existing plant therefore the checklist question is N/A. N/A N/A Does the project activity relate to electricity capacity additions from renewable sources? ver01 The project is related to electricity capacity additions from renewable sources as which has validated during the site visit Does proposed project activity falls in either of the categories Green filed Power Project, Power capacity expansion, Energy efficiency Improvement / Fuel Switch ver01 The project falls under the category of Green Field project as it involves the construction of a new hydro electric power plant which has been validated during the site visit Can the geographic and system boundaries for the relevant electricity grid be clearly identified? ver01 For the justification of the choice of the methodology and its applicability to the project, it CL39 64

65 CHECKLIST QUESTION Ref. MoV COMMENTS is stated in section B.2. of the rev01 that; the geographic and system boundaries for the relevant electricity grid can be clearly identified and information on the characteristics of the grid is available. Please clarify the sources for identification and the charecterics of the grid in the. Draft Final Is the information on the characteristics of the grid available? ver01 For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the rev01 that; the geographic and system boundaries for the relevant electricity grid can be clearly identified and information on the characteristics of the grid is available. Please clarify the sources for identification and the charecterics of the grid in the. CL Will the Project activity consume in-house biomass or will it be purchased from outside? ver01 Project will not consume biomass in any stage, as it is a hydropower plant Will implementation of Project result in increase in processing capacity of raw input? ver01 Implementation of the Project will not result in increase in processing capacity of raw input Will biomass to be used by Project activity be stored for more than one year? ver01 N/A Will biomass require significant energies (like Processing) other than transportation? ver01 N/A 65

66 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Final Is material and energy balance (heat and steam requirements for the processes) information available and assessed Old plants Proposed plants ver01 N/A Project boundary Did the project participant account for the CO 2 emission from electricity generation in fossil fuel fired power that is displaced due to project activity? ver01 There is no electricity generation fossil fuel fired power that s displaced due to project activity. Hence this the checklist question is N/A Did the project participant account for the CO2 emission from Heat generation in fossil fuel based power that is displaced due to project activity? ver01 N/A Does the spatial extent of the project boundary include the power plant at project site, means of transportation of biomass and all power plants connected physically to the electricity system that the CDM project power plant is connected to? Is Biomass dumped or left to decay or burned in uncontrolled manner without utilizing for energy purposes most likely scenario? ver01 ver01 The project is a HEPP project hence the question not applicable The project is a HEPP project hence the question not applicable If answer to Question is Yes, then are CH4 emissions in the project boundary are included? ver01 The project is a HEPP project hence the question not applicable If answer to Question is Yes, then are CH4 emissions calculated in a conservative manner ver01 The project is a HEPP project hence the question not applicable 66

67 CHECKLIST QUESTION using emission factors for uncontrolled burning of biomass? Ref. MoV COMMENTS Draft Final Whether choice of inclusion/exclusion CH 4 emissions in project and baseline are documented in D? ver01 B.3. Under section B.3 of the version 01, the GHG sources are identified for the project in the tabular format. CO 2 emissions have been identified as a major emission source in the tabular format and the methodology is referred for justification. CAR 10 Methane emissions has not been included in the sources and the explanation is given as that the project is zero emission electricity generation. CH 4 emissions has been identified as major emission sources for hydroelectric projects according to ACM 002 version 10. Please reassess the emissions sources and the justifications in the section B.3. It has been stated that; since the reservoir is mainly built before start of power plant component, emissions from reservoir was not included in emission reductions calculations in section B.6.3 of the version 01. CL52 During the site visit, it has been observed that the dam has been built in 2008 and the main purpose of the Orhaneli-Emet Project was to generate electricity. Please clarify the justification It has been stated that the project emission has been defined as 0 in section B.6.2. of the version 01. Please present the calculation of the power density and justify how the project emission CL53 67

68 CHECKLIST QUESTION Ref. MoV COMMENTS has been defined as 0. Draft Final ( Note: Please give clear references for the Apj and Capj) Is the regional project electricity system identified by the spatial extent of the power plants that can be dispatched without significant transmission constraints? ver01 B.6.3. In section B.6.3 of the D version01, the identification of the relevant electrical power system has been defined as the following: According to the Tool to calculate the emission factor for an electricity system, Version 01, a project electricity system has to be defined by the spatial extent of power plants that are physically dispatched without significant transmission constraints. Therefore, in this project activity the project electricity system includes the project site and all power plants attached to the Interconnected Turkish National Grid. ver01 The definition of the electricity system has been accepted by the DOE since the explanation is in line with the tool. In section B.6.3 of the D the identification of the relevant electrical power system has been defined however please justify the choice of selecting the project electricity system as national grid in relation with the Tool to calculate the emission factor for an electricity system, requirements. CAR Whether N2O has been excluded as GHG source within the project boundary? ver01 According to ACM0002 Version 10 for Hydro power projects N 2 O is a minor emission source and is negligible as an emission source Are the assumptions made in determining the In section B.6.3 of the D the identification of the CAR16 68

69 CHECKLIST QUESTION Ref. MoV COMMENTS project electricity system defined and justified? ver01 relevant electrical power system has been defined however please justify the choice of selecting the project electricity system as national grid in relation with the Tool to calculate the emission factor for an electricity system, requirements Does the application of this methodology result in a clear grid boundary? ver01 Yes the application of this methodology result in a clear grid boundary. The boundary of the grid is the Turkish national grid. Draft Final Does the application of this methodology result in a given country specific variations in grid management policies? ver01 The application of this methodology does not result in a given country specific variations in grid management policies If answer to question is yes then whether DNA of the host country provides the delineation of grid boundaries. ver01 N/A If answer to question is no whether DNA guidance is available for defining the boundary. ver01 There is no DNA in Turkey, therefore the checklist question is N/A If answer to question is no whether the layered dispatch system (e.g. state/provincial/regional/national) the regional grid is used ver01 There is no layered dispatch system in Turkey, therefore the checklist question is N/A If the regional grid is not used whether the national or state grid is used. ver01 The Turkish national grid is used. 69

70 CHECKLIST QUESTION 1.3. Identification of alternative baseline scenarios Ref. MoV COMMENTS Draft Final Are Realistic and credible alternatives separately determined for power, biomass and Heat? Are the various options for alternatives explained in D? ver01 ver01 The baseline scenario is defined as as Electricity delivered to the grid by the project activity would have otherwise been generated by the operation of grid-connected power plants and by the addition of new generation sources, as reflected in the combined margin (CM) described in the Tool to Calculate the emission factor for an electricity system as given in ACM0002 version 10 as the project activity is the installation of a new gridconnected renewable power plant/unit. ACM 002 version defines only the above methodology Is the explanation of these options transparent and complete ver01 The explanation of the alternatives are transparent and complete Did the project participant provide evidence and supporting documents to exclude baseline options that do not comply with legal and regulatory requirements; or depend on key resources such as fuels, materials or technology that are not available at the project site? Are the calculations for baseline are as per latest version of ACM 0002 as required by this methodology? ver01 ver01 N/A Please see section Are transmission & Distribution losses neglected as required by the methodology? ver01 The transmission& distribution losses are neglected as required by the methodology. 70

71 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Final Is quantity of electricity required for operation of plant subtracted? ver01 Yes the electricity supplied to the grid has been taken into consideration as net electricity. However this step will be concluded through verification Where EG-historical is the average of historical electricity delivered by the existing facility to the Grid, whether spanning all data from the most recent available year (or month, week or other time period) to the time at which the facility was constructed, retrofit, or modified in a manner that significantly affected output (i.e., by 5% or more), expressed in MWh per year. A minimum of 5 years (120 months) (excluding abnormal years) of historical generation data is required in the case of hydro facilities Whether a minimum of three years data is referred and used in case the project is non-hydro? ver01 ver01 The project is a Greenfield power plant, therefore the checklist question is N/A. The project is a Greenfield power plant, therefore the checklist question is N/A Is it required to estimate the point in time when the existing equipment would need to be replaced in the absence of project activity? ver01 The project is an installation of a new power plant; hence the question N/A If the answer to question is Yes Whether project participants have taken any of the two approaches, indicated in the ACM0002 into account? ver01 The project is a Greenfield power plant, therefore the checklist question is N/A. N/A N/A 71

72 CHECKLIST QUESTION Whether the typical average technical lifetime of the type equipment is determined and documented taking into account common practices in the sector and country e.g. based on industry surveys, statistics, and technical literature? Ref. ver01 MoV COMMENTS The project is not a retrofit or replacement of an existing renewable energy power plant; hence the checklist question is not applicable. Draft Final Whether the common practices of the responsible company regarding the replacement schedules is evaluated and documented, e.g. based on historical replacement records for such equipment? ver01 The project is not a retrofit or replacement of an existing renewable energy power plant; hence the checklist question is not applicable Whether the baseline emission factor is calculated as a combined margin consisting of the combination of operating margin (OM) and build margin factors according to three steps indicated in the methodology ACM0002? ver01 B.6.3. ver01 The baseline emission factor is calculated as a combined margin consisting of the combination of operating margin and build margin as indicated in step 6 of the section B.6.3 of the rev01. The three steps indicated in the methodology ACM0002 has been applied during the calculations Whether the weighted average applied by project participant is fixed for a crediting period. ver01 The weighted average has been considered for by the PP. The weighed average applied is fixed for the crediting period as verified from the calculation sheet by the DOE Whether operating margin emission factors calculations are based on one of the four methods described in the methodology ACM 0002? ver01 OM emission factor calculations are based on the Option C of the Simple OM (Method (a)) method described in ACM0002 s referred methodological Tool to Calculate the Emission Factor for an Electricity System. 72

73 CHECKLIST QUESTION Ref. ver01 MoV COMMENTS Simple OM method is used for the calculation of the emission factor of the operating margin as described in step 2 of the section B.6.1 of the REV01. Draft Final ver01 ver01 The justification for not selecting the method is given as lack of data for fuel consumption of each power plant in section B.6.1 of the REV01. The statement is also verified from the TEIAS site by the DOE. The justification for not selecting the option B and C are given as due to insufficient data in step 2 of the rev01. ver01 ver01 It has been stated that Option C of the Simple OM method has been selected in step 3 of the section B.6.1 of the rev01. The selection has been justified by stating that fuel consumption and average efficiency data for each power plant/ unit are not available. The statement has also been accepted by the DOE since it has been validated form the TEIAS web site. In Section B.6.1. of the rev 01 share of low cost-must run resources have been presented. The reference given has been checked and is concluded that share of low cost must ru resources is lower than 50 % so; option C is applicable to the project Is the most likely baseline scenario electricity production from other sources feeding into the grid? ver01 Yes the most likely baseline scenario is the electricity production from other sources feeding into the grid If the project activity modifies or retrofits an existing electricity generation facility, is the guidance by EB08 taken into account? ver01 No, the project does not modify or retrofit an existing electricity generation facility. 73

74 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Final 1.4. Additionality Was the additionality of the project activity demonstrated and assessed using the latest version of the Tool for demonstration and assessment of additionality? ver01 The methodolological tool for the demonstration and assessment of the additionality has been defined as Tool for the demonstration and assessment of additionality, Version 5.2. in section B.1 of the rev Project Emissions Are the relevant project emissions indicators have been considered? ver01 It has been stated that the project emission has been defined as 0 in section B.6.2. of the version 01. Please present the calculation of the power density and justify how the project emission has been defined as 0. CL53 ( Note: Please give clear references for the Apj and Capj) Are the project emissions arising out of transportation of biomass and/or on site use of fossil fuel and/or CO 2 emissions due to on site electricity consumption and/or Methane emissions from combustion of biomass residues ver01 It has been stated that in section B.6.3 of the version 01 that the only emission source in the plant is the diesel generator which is used as axuillary source. The assumption is also accepted by the DOE since it is a conservative approach. In section B.6.3 of the version 01; calculation of CO 2 emissions due to the diesel generator which is used as a auxillary power has been transparently presented. 74

75 CHECKLIST QUESTION Is the approach for project emissions conservative and transparent? Ref. ver01 VCS Validation Report MoV COMMENTS Draft Final N/A In case of Methane emissions due to combustion of biomass, are the relevant IPCC values are taken in to account with appropriate uncertainty? ver01 N/A 1.6. Baseline Emissions Are the baseline emissions determined according to the formula BE y = EG y x EF y? Were the Emissions Factor for displaced electricity calculated as in ACM0002? Were the baseline emissions for heat correctly represent the existing situation of heat generation? Whether life time aspects are taken into account if required so by applicable scenario? Does project account for baseline emissions due to natural decay or uncontrolled burning of anthropogenic sources of biomass residues? Does project account for quantity of biomass residues used as a result of the project activity? 1.7. Leakage B.6.3. Yes, the baseline emissions are determined according to the formula: BE y = EG y x EF y B.6.3. As Simple OM method is used calculating the Emissions Factor for displaced electricity is not required. (Only required in Dispatch data analysis OM) B.6.3. N/A B.6.3. No. There is no applicable scenario which requires taking life time aspects into account. Therefore the checklist question is N/A. B.6.3. N/A B.6.3. N/A Are the leakage considered? B.6.3 No leakage has been considered with justification that no equipment has been transferred from or to another activity in section B.6.3. of the version Have any credits been claimed for the project on account of reducing the emissions due to power B.6.3 No. No credits have been claimed for the project on account of reducing the emissions due to power 75

76 CHECKLIST QUESTION plant construction, fuel handling and land inundation below the level of the baseline scenario? Has it been demonstrated that biomass availability from the region is abundant enough & that the use of the biomass residues does not result in increased fossil fuel consumption elsewhere? Is this demonstration done through one of the options L1 to L3 as recommended by the methodology? When either L2 or L3 is chosen as a option, the radius for procurement of biomass is at least 20 km and not more than 200 km in any case? Where Project cannot demonstrate the procurement of biomass in above stated limits, is leakage penalty applied? 1.8. Emission Reduction Did the emissions reductions were determined according to the formula ERy = ER heaty + ER electricity y + BE biomassy PE y L y Are the emission reduction calculations for displacement of power done as appropriate to chosen scenario? Were all values chosen in a conservative manner and was the choice justified? Ref. MoV COMMENTS Draft plant construction, fuel handling and land inundation below the level of the baseline scenario. B.6.3 N/A B.6.3 N/A B.6.3 N/A B.6.3 N/A B.6.3. B.6.3. B.6.3 ER y is calculated as follows: ER y = BE y PE y - LE y Yes the emission reduction calculations for displacement of power done as appropriate to chosen scenario. Generally the values chosen were selected in a conservative manner. The findings that were also indicated in the checklist questions above in this protocol were summarized below. In the OM calculations, an average NCV is computed and then multplied by the emission factor (tco2/tj) for year 2007 (based on the NIR) to obtain an emission factor (tco2/kt) that is in turn multiplied with the total fuel consumption over the three years Although the resulting OM emission factor is within CAR17 Final 76

77 CHECKLIST QUESTION Ref. MoV COMMENTS acceptable limits, it is not in line with the methodology and yields less accurate results. According to the methodological tool Tool to calculate the emission factor for an electricity system, UNFCCC EB35 Report Annex 12 (TOOL), simple OM method (whose formula is also given in the D), a disaggregate approach is necessary. Draft Final In the version 01 of the, it has been stated that the list of most recent capacity additions to the grid and their average and firm generation capacities are available at the TEİAŞ web page The reference to the given statements are reference number 32, 33,34,35. CAR2 In the BM calculations worksheet, it is seen that the capacity addition data for the years 2006 and 2007 are taken from the TEIAS website which are given as reference 34 and 35 and in the. However the data that is used in the calculations does not give detailed plant based information on the capacity additions. Please revise your calculations and the references given in the using the detailed lists that are given in the annexes of capacity projection reports that are also available on the TEIAS website. In Table 13 of the version 01, NCV Values used for the calculation of the OM have been presented. The reference for the table is given as the National Inventory of Turkey Documented data sources in national energy statistics should be used for computing NCV values according to Tool CAR3 77

78 CHECKLIST QUESTION Ref. MoV COMMENTS to calculate the emission factor of an electricity system. Please revise your data sources for heating values of fuels and recalculate the NCV value. Please present the calculation transparently in the. Please revise the references and the table 13 in the. Draft Final For the generation efficiency of coal, the value of present thermal power plants has been used from Türkiye Çevre Atlası prepared by Ministry of Environment and Forestry as indicated in section B.6.2. of the rev 01 and the EF calculation.xls. However, the document has been published in 2004 and refers to data from power plants of all vintages in operation. On the other hand, the BM comprises most recently built power plants which are expected to be of higher efficiency. Hence using the default efficiency factor in the TOOL (for new power plants built after 2000), which is slightly higher, would be more appropriate. CAR14 The Emission Factors used in the calculations are taken from the IPCC minimum values at the lower limit of uncertainty at a 95% confidence interval (table 1.4 of Chapter 1 of Vol. 2 (Energy) of the 2006 IPCC Guidelines for GHG inventories. However, in section B.6.3. of version 1, it has been stated that The emission factors required for calculation of CO2 emission coefficient have been obtained through IPCC 2006 guidelines for GHG inventories for fuels except for coal and lignite. For lignite and coal, the emission factors have been calculated using country specific heating values of fuels consumed and data from National Greenhouse Gas Inventory of Turkey. Please CL12 78

79 CHECKLIST QUESTION Ref. MoV COMMENTS clarify the reference statement. Draft Final In Table 13 of the version 01, values used for the calculation of the OM have been presented. The reference for the table is given as the National Inventory of Turkey In 2007 inventory; IPCC mid values have been used. However, the EF values given in the table stand for the min IPCC min values. According to the Tool to calculate the emission factor of an electricity system it is convenient to use IPCC min values. So, please clarify the reference for the EF factors. CL13 In the BM calculations the employed emission factor for fuel oil is the same as the IPCC lower level for residual fuel oil. However according to NIR there is no residual fuel oil usage on that year. Please clarify. CL48 The table in annex 3 of the version 1 has been referenced as the values applied for the NCV values. However, NIR 2007 has been referenced in the table in Annnex 3. Please clearly present how the NCV values are computed. CL Whether an estimate of likely project emission reductions for the proposed crediting period is prepared as part of the D? Whether the estimate in principle employs the same methodology ACM0006? B.6.4. In the OM&BM calculations the employed emission factor for coal is the same as the IPCC lower level for antracite. However according to NIR there is no value for antracite Please clarify the assumption. An estimate of likely project emission reductions for the proposed crediting period is prepared and shown in Table 11 in section B.6.4. of the. Project is not biomass residue, therefore checklist question is N/A CL50 79

80 CHECKLIST QUESTION Whether the emission factor is determined expost during monitoring? If yes whether project participants have used models or other tools to estimate the emission reductions prior to validation? Ref. MoV B.6.3. COMMENTS VCS Validation Report EF is determined as ex-ante as stated under section B.6.3. Step 2 Draft Final N/A 2. Monitoring Methodology 2.1. Applicability Does the project activity generate electricity from a renewable source? ver01 The project generates electricity from a renewable source Is the power connected to the grid? ver01 The power is connected to grid as validated through the feasibility report Does the project activity relate to electricity capacity additions from renewable sources? ver01 The project activity relates capacity additions from renewable sources Is fuel switch done in the process? ver01 Since the project is the installation a new HEPP, the question is not applicable to the project Can the geographic and system boundaries for the relevant electricity grid be clearly identified? ver01 The geographic and system boundairies for the relevant electricity gird may be clearly identified 80

81 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Final Is the information on the characteristics of the grid available? ver01 The information on the characteristics of the grid is available Monitoring Methodology Does the monitoring plan require monitoring of increased electricity generation from the proposed project activity? ver01 The monitoring plan requires monitoring of increased electricity generation from proposed project activity Does monitoring takes in to account the lower value between (a) the net quantity of electricity generated in the new power unit that is installed as part of the project activity and (b) the difference between the total net electricity generation from firing the same type(s) of biomass at the project site (EG total,y) and the historical generation of the existing power unit(s), (EG historic, 3yr) based on the three most recent years Does the methodology requires monitoring of Data needed to recalculate the operating margin emission factor, if needed, based on the choice of the method to determine the operating margin (OM), consistent with ACM0002? Does the monitoring plan require monitoring of Data needed to recalculate build margin emission factor, if needed, consistent with ACM0002? ver01 ver01 ver01 N/A The ex-ante option has been selected as indicated in section B.6. of the rev01. The ex-ante option has been selected as indicated in section B.6. of the rev Does the monitoring plan require monitoring of data needed to calculate fugitive carbon dioxide and methane emissions and carbon dioxide emissions from combustion of fossil fuels required to operate the geothermal power plant? ver01 The project is a hydro powerplant project. So, the question is not applicable to the project Quality Control (QC) and Quality Assurance 81

82 CHECKLIST QUESTION (QA) Procedures Did all measurements use calibrated measurement equipment that is regularly checked for its functioning? Are frequency of monitoring the parameters defined hourly/daily? Ref. ver01 ver01 MoV COMMENTS VCS Validation Report Draft All the measurements use calibrated equipment. The frequency of monitoring parameters is hourly / daily. Final 82

83 TABLE 3 CHECKLIST BASED ON METHODOLOGICAL TOOL FOR ASSESSMENT OF ADDITIONALITY (VERSION EB 39 REPORT ANNEX 10) CHECKLIST QUESTION Ref. MoV COMMENTS Draft 1. Additionality of a project activity a. Does the VCS- state the latest version of the additionality tool being used? b. Has the tool used the following steps to assess additionality 1. Identification of alternatives to the project activity 2. Investment analysis to determine that the proposed project activity is either: 1) not the most economically or financially attractive, or 2) not economically or financially feasible 3. Barriers analysis; and 4. Common practice analysis. c. In Step 1 have all the sub-steps as below followed 1. Sub-step 1a: Define alternatives to the project activity 2. Sub-step 1b: Consistency with mandatory laws and regulations ver0 1 ver0 1 ver0 1 However the steps followed in section B.5 of the rev 01 is in line with the steps of the tool Tool for the demonstration and assessment of additionality. In the all of the relevant steps are used. The PPs have chosen to use both the investment analysis and the barrier analysis. The PPS have realised investment analysis to determine that the proposed project activity is not economically or financially feasible. ( It has been written in the as not the most economically attractive ) Final Both of the sub-steps of step 1 are used 83

84 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Three alternatives have been defined by the PP in sub-step 1 a of section B.5 of the rev 01. d. Have the following alternatives been included while defining alternatives as per sub-step 1a 1. (a) The proposed project activity undertaken without being registered as a CDM project activity 2. (b) Other realistic and credible alternative scenario(s) to the proposed CDM project activity scenario that deliver outputs services or services with comparable quality, properties and application areas, taking into account, where relevant, examples of scenarios identified in the underlying methodology 3. (c) If applicable, continuation of the current situation (no project activity or other alternatives undertaken). e. Has the project participant included the technologies or practices that provide outputs or services with comparable quality, properties and application ver0 1 ver0 1 The defined alternatives and the discussion about credibility of the secenarios are given below: 1)Proposed project not undertaken as a VER project activity 2) Continuaation of the current situation-supply of equal amount of electricity in the grid. 3) Construction of a thermal powerplant with the same installed capacity or the same annual power output The first scenario defined by the PP in sub-step 1 of section B.5 of the rev 01 is : The proposed project not undertaken as a ver project. As an altenative it is found realistic and credible by the DOE also; since it has been defined in the Addtionality tool ver The second alternative has been defined as current situation-supply of equal amount of electricity in the grid. The justification has been defined as that the second alternative is the baseline scenario. The justification is also accepted by the DOE. Last alternative has been defined as a construction of a thermal power plant with the same installed capacity or the same annual power output in section B.5. of the rev01. Please supply references of for thermal power plant or justify that the investor has sufficient technical background in thermal power plant operations. Last alternative has been defined as a construction of a thermal power plant with the same installed capacity or the same annual power output in section B.5. of the rev01. Please supply references of for thermal power CL60 CL60 Final 84

85 CHECKLIST QUESTION Ref. MoV COMMENTS Draft areas as the proposed CDM project plant or justify that the investor has sufficient activity and that have been technical background in thermal power plant implemented previously or are operations. currently being introduced in the relevant country/region. f. Has the outcome of Step 1a: Identified realistic and credible alternative scenario(s) to the project activity done correctly? Please briefly mention the outcome. ver0 1 In the outcome of step 1 a of section B.5. it has been stated that continuation of the current situation supply of equal amount of electricity in the grid has been defined as a non realistic alternative. Please clearly state the realistic alternatives in the out come of Step 1.a. CL61 Final g. Is the alternative(s) in compliance with all mandatory applicable legal and regulatory requirements, even if these laws and regulations have objectives other than GHG reductions, e.g. to mitigate local air pollution. h. If an alternative does not comply with all mandatory applicable legislation and regulations, has it been shown that, based on an examination of current practice in the country or region in which the law or regulation applies, those applicable legal or regulatory requirements are systematically not enforced and that noncompliance with those requirements is widespread in the country. i. Has the outcome of Step 1b: Identified realistic and credible alternative scenario(s) to the project activity that are in compliance with mandatory legislation and regulations taking into ver0 1 ver0 1 ver0 1 It has been stated in section sub step 1 b of the version 01 that all the alternative scenarios defined in the VCS are in line with all the mandatory applicable legal and regulatory requirements. Please clarify the justification by presenting a small summary of the requirements of the related legislation for the alternatives construction of a thermal power plant and the continuation of the current situation. If the answer to CL is no please show that, based on an examination of current practice in the country or region in which the law or regulation applies, those applicable legal or regulatory requirements are systematically not enforced and that noncompliance with those requirements is widespread in the country. In step 1.b. of the version 01, the out come of step 1.b. has been defined as the following; Mandotory legislation and regulations for each alternative are taken into account in sub step 1.b.. Based CL62 CL63 CL64 85

86 CHECKLIST QUESTION Ref. MoV COMMENTS Draft account the enforcement in the region or country and EB decisions on national and/or sectoral policies and regulations done correctly? Please state the outcome. on the above analysis, the proposed project activity is not the only alternative amongst the project participants that is in compliance with the mandatory regulations. Therefore, the proposed VER project activity is considered as additional. Final j. Has PP selected Step 2 (Investment analysis) or Step 3 (Barrier analysis) or both Steps 2 and 3.) k. In step 2 have all the sub-steps as below followed? 1. Sub-step 2a: Determine appropriate analysis method 2. Sub-step 2b: Option I. Apply simple cost analysis 3. Sub-step 2b: Option II. Apply investment comparison analysis 4. Sub-step 2b: Option III. Apply benchmark analysis 5. Sub-step 2c: Calculation and comparison of financial indicators (only applicable to Options II and III): 6. Sub-step 2d: Sensitivity analysis (only applicable to Options II and III): ver0 1 ver0 1 Please clearly include which alternatives are in line with the applicable legislation The PP selected both step 1 and step2. In step 2 the following sub-steps have been followed as the below: 1. Determine appropriate analysis method. 2. OptionIII. Apply benchmark analysis 3. Calculation and comparison of financial indicators 4. Sensitivity analysis l. In sub-step 2a has the determination of appropraite method of analysis done as per the guidance as below 1. Simple cost analysis if the CDM project activity and the alternatives identified in Step 1 generate no financial or economic benefits other than CDM related income ver0 1 In substep 2a simple cost analysis has been elected and the justification has been documented as below; Since the project activity generates economic benefits from sales of electricity, the simple cost analysis is not applicable. The justification is found appropriate by the DOE by benchmarking with the similar projects. 86

87 CHECKLIST QUESTION Ref. MoV COMMENTS Draft (Option I). 2. Otherwise, use the investment comparison analysis (Option II) or the benchmark analysis (Option III). Specify option used with justification Final ver0 1 In substep II a of section B.5 of the version 01; it has been stated that benchmark analysis has been selected. The justification is given as below: Since the baseline scenario of the project is generation of electricity by the grid, no alternative investment is considered at issue. m. Has the below guideline followed for sub-step 2b Option I. Apply simple cost analysis 1. Document the costs associated with the CDM project activity and the alternatives identified in Step1 and demonstrate that there is at least one alternative which is less costly than the project activity. n. Has the below guideline followed for sub-step 2b Option II. Apply investment comparison analysis 1. Identify the financial indicator, such as IRR, NPV, cost benefit ratio, or unit cost of service most suitable for the project type and decision-making context. Please specify ver0 1 ver0 1 N/A N/A 87

88 CHECKLIST QUESTION Ref. MoV COMMENTS Draft o. Has the below guideline followed for The discussions have been summarized below using Sub-step 2b: Option III. Apply the same numeric order with question list ( left hand ver0 benchmark analysis column) for traceability Identify the financial/economic indicator, such as IRR, most suitable for the project type and decision context. 2. When applying Option II or Option III, the financial/economic analysis shall be based on parameters that are standard in the market, considering the specific characteristics of the project type, but not linked to the subjective profitability expectation or risk profile of a particular project developer. Only in the particular case where the project activity can be implemented by the project participant, the specific financial/economic situation of the company undertaking the project 1. The financial indicator has been identified as IRR as the financial / economic indicator as stated in substep 2 b of section B.5. IRR has also been found a suitable indicator for the project by the DOE in comparison with the similar projects. Final 88

89 CHECKLIST QUESTION Ref. MoV COMMENTS Draft 2. The financial / economic analysis has not been based on to the subjective profitability expectation or risk profile of a particular project developer. Final 3. Discounts rates have been selected as given below: a.1) Government bond rates, increased by a suitable risk premium as indicated substep 2b of section B.5 of the rev 01 have been used for equity IRR. a.2) Government bond rates used as a benchmark has been presented in table 3 of the rev01. The selected bencmarks have maturity date as Please select a bond with the maturity date same as the last year of the IRR period. CL65 a.3.) Government bond rates used as a benchmark has been presented in table 3 of the rev01. Please clearly state the year that government bond rates have been accessed. Please present the government bond rates based on the investment decision date CL66 a.4) In substep II b of the section B.5 of the version 01, it has been stated that Acceptable IRR values for energy investments in Turkey are, given the present global financial crisis and CL67 89

90 CHECKLIST QUESTION Ref. MoV COMMENTS Draft economic uncertainty, are expected at yields in excess of 15% per annum. Final Please clearly state how the assumed value ( %15 ) is computed in the. Please clearly state in the the value assumed for the bond rate and the risk premium b) In the v.01 B.5 selection of appropriate benchmark for project IRR is not defined and justified. CAR 18 p. Has the below guideline followed for Sub-step 2c: Calculation and comparison of financial indicators (only applicable to Options II and III): 1. Calculate the suitable financial indicator for the proposed CDM project activity and, in the case of Option II above, for the other alternatives. Include all relevant costs (including, for example, the investment cost, the operations and maintenance costs), and revenues (excluding CER revenues, but possibly including inter alia The discussions have been summarized below using the same numeric order with question list ( left hand column) for traceability 1.1 The IRR value which has been considered as as the suitable financial indicator has been calculated by the main financial parameters given in Table 4 of the version The installed capacity of Power plant is 100 MW as indicated in the generation license issued by EMRA. 90

91 CHECKLIST QUESTION Ref. MoV COMMENTS Draft The grid connected output is presented as CAR GWh in the table 4 of the rev01. Annual 9 generation has been defined for three scenarios according to the 2005 dated Feasibility report approved by the State of Hydraulics ( Secenario 1 : ( up to year 2021) when only downstream water demand has been supplied from the dam the total energy production will GWH, Scenario 2 ( up to year 2028 which includes 1 st stage of drinking, usage and industrial water supply from the dam ): GWH, Scenario 3 ( after year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH. Please correct the value in table 4 and the revise the calculations in accordance Capital investment has been considered defined as 128,891,000 Million Euros in table 4 of the D version 01. Details of the capital investment has been presented in the Uluabat Financial Model.xls- Budget Sheet The constructions works has been defined as in construction budget sheet of Uluabat Financial Model.xls There are three values identified in the same sheet for the constructions. The values standing for the construction works in the cells D13, C23 and G22 are not the same, please clarify Please include details the construction works as a separate explanation in the budget sheet of Uluabat Financial Model.xls budget sheet of Uluabat Financial Model.xls and submit proofs for each sub item of the construction works Please justify the budget for the electromechanical works presented in cell D12 of the budget sheet of Uluabat Financial Model.xls CL68 CL69 CL70 Final 91

92 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Please justify the budget for the CL71 transmission line in cell D11 of the budget sheet of Uluabat Financial Model.xls ( Please present the assumption in the excel sheet & if any) Please justify the budget for the expropriation works presented in cell D10 of the budget sheet of Uluabat Financial Model.xls Please justify the budget for the engineering works presented in cell D10 of the budget sheet of Uluabat Financial Model.xls Please clearly include the justification of the assumption in the Uluabat Financial Model.xls and the for the contingency item identified in cell D15 of the of the budget sheet of Uluabat Financial Model.xls The VAT value presented in cell B11 of the budget sheet of Uluabat Financial Model.xls includes the powerhouse also. The imported machines are excluded of VAT according to the regulations. Please clarify the VAT amount Please justify the tender cost presented in cell B12 of the budget sheet of Uluabat Financial Model.xls Please justify the ncome tax rate by presenting clear reference in the version Please present the loan agreement to the DOE to justify the loan amount ( CL72 CL73 CL74 CL75 CL76 CL77 CL78 Final 92

93 CHECKLIST QUESTION Ref. MoV COMMENTS Draft 000 Million Euro ) that is presented in table 4 of the version 1 and the value presented in cell C21 of the cash flow sheet of the Uluabat Financial Model.xls Please clearly state the reference for the tariff presented in table 4 of the version Please clearly justify the assumption for the expected VERs price value defined in table 4 of the ver The operations cots have been presented in Operation Expenses Details Sheet in Uluabat Financial Model.xls Staff cost has been presented in cell C4 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls and the details of the salaries have been presented in cells C7-C45 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls. The amount has been found reasonable in comparison with the similar projects. However, please justify the amount by presenting proofs for accuracy Staff meal cost has been presented in cell C8 of the of the Operation Expenses Details Sheet in Uluabat Financial Model.xls which has been found appropriate by the DOE in comparison with the similar projects Rental cost for staff has been presented in cell A13 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls. Please justify the amount. CL79 CL80 CL81 CL82 Final 93

94 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Phone-Stationay-fuel costs have been CL83 presented in cells C22-C24 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls which has been found appropriate by the DOE in comparison with the similar projects. However please justify the assumption for the unexpected cost presented in cell C25 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls Distribution system charge has been calculated in cells G3-G5 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls. Please clearly state the assumptions in the and relate to the references Zero residual correction item has been defined as 0.9 of the Total generation has been 172 GWh in cells G9 and F3. Please justify the assumption The annual maintenance cost has been calculated in cells B32-B34 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls Please clearly present the justification for the values for B32&B34. Please also indicate the currency The equity IRR values have been presented in cash flow sheet of Uluabat Financial Model.xls The equity ratio has been defined as %30. in cell B22 of the cash flow sheet of Uluabat Financial Model.xls. Please justify the assumption. CL84 CL85 CL86 CL87 CL88 Final 94

95 CHECKLIST QUESTION Ref. MoV COMMENTS Draft The interest on loan has been defined in cell CL89 B28 of the cash flow sheet of Uluabat Financial Model.xls. Please justify the assumption by presenting the loan agreement to the DOE The investment amount presented in cell C4-C10 of the cash flow sheet of Uluabat Financial Model.xls is not the same as the presented investment amount in D16 of the budget sheet of the Uluabat Financial Model.xls.Please clarify The exchange ratio has been defined as / $ for year Please clarify the investment decision date years have been assumed for depreciation in cash flow sheet of the Uluabat Financial Model.xls. Please clarify and reassess the Please justify the insurance amount presented in cell D6 of the cash flow sheet of the Uluabat Financial Model.xls The annual maintenance value presented in cell D4 of the cash flow sheet of the Uluabat Financial Model.xls is not the amount maintenance amount presented in cell B34 of the Operation Expenses Details sheet The grid fee presented in cell D4 of the cash flow sheet is not the same grid fee amount presented in cell G12 Operation Expenses Details Please justify the amount presented in cell D14 of the cash flow sheet. CL90 CL91 CL92 CL93 CL94 CL95 CL96 Final 95

96 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Please justify the investment interest amount CL97 indicated in cell D19 of cash flow sheet of the Uluabat Financial Model.xls by presenting the loan agreement The depreciation formulae presented in cell J7 of the cash flow sheet of the Uluabat Financial Model.xls includes also the tender cost. Please clarify The operation expenses have changed after the 11 th year of operation ( cells S8- T8) in cash flow sheet of the Uluabat Financial Model.xls. Please clarify The development fee in cell E 26 has been included into financial flow after income before tax has been computed. Please clarify the reason for not including the development fee into cash flow before income before tax has been computed In equity IRR calculations only the portion of investment costs which is financed by equity has been considered as cashoutlow in cells G28-I28 of cash flow sheet of the Uluabat Financial Model.xls However the sum of cells G28-I28 is different from the equity amount presented in cell B20 of the same sheet. Please clarify lease justify the reason for assuming the cash outflow will be equal to each other in three years of construction period as presented G28-I28 cash flow sheet of the Uluabat Financial Model.xls ( for example by providing the construction plan) The depreciation has been added back as a cash inflow as an income of 21th year in cell CL98 CL99 CL10 0 CL10 1 CL10 2 CL10 3 Final 96

97 CHECKLIST QUESTION Ref. MoV COMMENTS Draft AD28 of the cash flow sheet of the Uluabat Financial Model.xls. Please clarify. 2. Present the investment analysis in a transparent manner and provide all the relevant assumptions, preferably in the CDM-D, or in separate annexes to the CDM-D. ver The fair value of the project assets has not been included as a cash inflow. Please clarify Loan interests ( cell E10) has been considered in cash flow before income before tax however loan payback cell (E 25) in cash flow sheet of the Uluabat Financial Model.xls CL10 4 CL Please supply the payback plan for the loan. CL It has been stated in version 01 CL10 that the project IRR has been calculated. 7 Please present the project IRR transparently in the excel sheet. Please present the Investment analysis with carbon credit in a transparent manner in the Calculation sheet. CL 108 Final 3. Justify and/or cite assumptions. ver0 1 Please clarify the assumptions and present the justifications in the D and the excel sheets. CL In calculating the financial/economic indicator, the project s risks can be included through the cash flow pattern, subject to project-specific expectations and assumptions ver0 1 The grid connected output is presented as GWh in the table 4 of the. Annual generation has been defined for three scenarios according to the 2005 dated Feasibility report approved by the State of Hydraulics ( Scenario 1 : ( up to year 2021) when only downstream water demand has been supplied from the dam the total energy production will GWH, Scenario 2 ( up to year 2028 which includes 1 st stage of drinking, usage and industrial water supply from the dam ): GWH, Scenario 3 ( after CAR1 9 97

98 CHECKLIST QUESTION Ref. MoV COMMENTS Draft year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH. Please correct the value in table 4 and the revise the calculations in accordance 5. Assumptions and input data for the investment analysis shall not differ across the project activity and its alternatives, unless differences can be well substantiated. ver0 1 The operation expenses have changed after the 11 th year of operation ( cells S8-T8) in cash flow sheet of the Uluabat Financial Model.xls. Please clarify. CL99 Final 6. Present in the CDM-D a clear comparison of the financial indicator for the proposed CDM activity Please specify details for above ver0 1 In section sub step 2.b. of the section B.5. in version 01; The calculated equity IRR ( without carbon revenue) has been compared with the Eurobond rates or Turkish bond rates currently yielding in excess of 18 and concluded that the project is not financially attractive. Please recalculate the equity IRR based on the CARs and CL in table 3 of this protocol and present the comparison again. CL 110 In section sub step 2.b. of the section B.5. in version 01; The calculated equity IRR ( 7.34%) without carbon revenue) has been compared with the IRR benchmark which is 15%. CL67 Please clearly state how the assumed value ( %15 ) is computed in the. Please clearly state in the the value assumed for the bond rate and the risk premium It has been stated in section B.5 of the version 01 that the with the carbon revenue the equity IRR increases to 8.67% and the project becomes more attractive. Please recalculate equity IRR based on the CARs and CL and present the comparison again. CL 111 In section sub step 2.b. of the section B.5. in version 01; the project IRR without carbon revenue ( 7.49%) has been compared with project IRR CL

99 CHECKLIST QUESTION Ref. MoV COMMENTS Draft benchmark which is referenced to ref 12. The reference could not be reached and the date of validation. Please supply a scanned copy. q. Has the below guideline followed for Sub-step 2d: Sensitivity analysis (only applicable to Options II and III): 1. Include a sensitivity analysis that shows whether the conclusion regarding the financial/economic attractiveness is robust to reasonable variations in the critical assumptions. r. Has the outcome of Step 2 clearly mentioned with justification? ver0 1 ver0 1 Please supply the calculations for the Project IRR with and without carbon revenue in a transparent manner and conclude if the project is financially attractive based on the project IRR calculations. A sensitivity analysis have been carried in sub-step 2.d. of the section B.5. of the version 1. Please clearly state how the parameters selected for the sensitivity analysis. Please recalculate the sensitivity analysis according to the CLs and CARs raised in table 3 of this protocol and present in the and the financial model The outcome of Step 2 has been defined in substep 2- b of the version 01 as the following: The investment and sensitivity analysis shows that the VER revenues will improve the financial indicators of the project and make the investment more reasonable for investors. Considering that figures above are based on highest guaranteed price rather than average price, optimistic estimations for yearly generation and that those figures do not reflect the risk for investment, role of carbon income is a significant number to enable the project to proceed and favorable investment and funding decision taken. Based on the above information, it is seen that project is not the most attractive option. Therefore project is considered as additional to the baseline scenario. CL 113 CL11 4 CAR2 0 CL11 5 Final Please revise the outcome of step 2 s needed according to the CARs and CLs raised in table 3 of this 99

100 CHECKLIST QUESTION Ref. MoV COMMENTS Draft protocol Final s. In step 3: Barrier analysis have all the sub-steps as below followed? 1. Sub-step 3a: Identify barriers that would prevent the implementation of the proposed CDM project activity 2. Sub-step 3 b: Show that the identified barriers would not prevent the implementation of at least one of the alternatives (except the proposed project activity): t. Has the below guideline followed for Sub-step 3a: Identify barriers that would prevent the implementation of the proposed VCS project 1. (a) Investment barriers: For alternatives undertaken and operated by private entities: Similar activities have only been implemented with grants or other non-commercial finance terms. No private capital is available from domestic or international capital markets due to real or perceived risks associated with investment in the country where the proposed CDM project activity is to be implemented, as demonstrated by the credit rating of the country or other country investments reports of reputed origin. 2. (b) Technological barriers: Skilled and/or properly trained labour to operate and maintain the technology is not available in the relevant country/region, which leads to an unacceptably high risk of equipment disrepair and malfunctioning or other underperformance; Lack of infrastructure for implementation and logistics for maintenance rev0 1 B.5 rev0 1 B.5 Barrier analysis have all the substeps as below in step 3 of the the version 01: 1. Sub-step 3a: Identify barriers that would prevent the implementation of the proposed CDM project activity 2. Sub-step 3 b: Show that the identified barriers would not prevent the implementation of at least one of the alternatives (except the proposed project activity): In step 3 of the section B.5. of the version 01; only investment barriers have been defined. In step 3 of the section B.5 of the version 01; high level of financing and long pay back period has been identified as a barrier under the investment barrier title. High level of financing and long pay back period is related with finance which has already been included in the investment analysis. Please amend. In step 3 of the section B.5. of the version 01; limited incentives for renewable energy has been defined as a barrier under investment barrier title. Please clarify the how the named barrier is related with the investment barrier given in Tool for the demonstration and assessment of additionality and presented below..if Similar activities have only been implemented with grants or other non-commercial finance terms. No private capital is available from domestic or international capital markets due to real or perceived risks associated with investment in the country where CAR 21 CL

101 CHECKLIST QUESTION Ref. MoV COMMENTS Draft the proposed CDM project activity is to be implemented, as demonstrated by the credit rating of the country or other country investments reports of reputed origin. of the technology, Risk of technological failure: the process/technology failure risk in the local circumstances is significantly greater than for other technologies that provide services or outputs comparable to those of the proposed CDM project activity, as demonstrated by relevant scientific literature or technology manufacturer information, The particular technology used in the proposed project activity is not available in the relevant region. 3. (c) Barriers due to prevailing practice: The project activity is the first of its kind. 4. (d) Other barriers, preferably specified in the underlying methodology as examples. In step 3 of the section B.5 of the version 01; construction barriers have been presented under investment barriers. Please clarify the how the named barrier is related with the investment barrier given in Tool for the demonstration and assessment of additionality and presented below..if Similar activities have only been implemented with grants or other non-commercial finance terms. No private capital is available from domestic or international capital markets due to real or perceived risks associated with investment in the country where the proposed CDM project activity is to be implemented, as demonstrated by the credit rating of the country or other country investments reports of reputed origin. CL 117 Final u. Has the outcome from Step 3a clearly mentioned in D? The outcome from Step 3 a has not been clearly mentioned in the version 01. CAR 22 v. Has the below guideline followed for It has been stated in section B.5 of the version 01, 101

102 CHECKLIST QUESTION Ref. MoV COMMENTS Draft Sub-step 3 b: Show that the identified rev0 that the presented barriers are largely specific to barriers would not prevent the 1 hydroelectric power plans and have minimal impacts implementation of at least one of the B.5 on the base scenario of ACM 002, the addition of CL11 alternatives (except the proposed thermal power plants. 8 project activity): 1. If the identified barriers also affect other alternatives, explain how they are affected less strongly than they affect the proposed CDM project activity. In other words, demonstrate that the identified barriers do not prevent the implementation of at least one of the alternatives. Any alternative that would be prevented by the barriers identified in Sub-step 3a is not a viable alternative, and shall be eliminated from consideration. 2. provide transparent and documented evidence, and offer conservative interpretations of this documented evidence, as to how it demonstrates the existence and significance of the identified barriers and whether alternatives are prevented by these barriers. 3. The type of evidence to be provided should include at least one of the following: (a) Relevant legislation, regulatory information or industry norms; (b) Relevant (sectoral) studies or surveys (e.g. market surveys, technology studies, etc) undertaken by universities, research institutions, industry associations, companies, bilateral/multilateral institutions, etc; (c) Relevant statistical data from Please reassess if the identified barriers ( specific to the proposed project) would not prevent the implementation of at least one of the alternatives according to CLs raised above Final 102

103 CHECKLIST QUESTION Ref. MoV COMMENTS Draft national or international statistics; (d) Documentation of relevant market data (e.g. market prices, tariffs, rules); (e) Written documentation of independent expert judgments from industry, educational institutions (e.g. universities, technical schools, training centres), industry associations and others. Please specify. w. Has the outcome from Step 3 clearly mentioned in D? x. In step 4: Common practise analysis have all the sub-steps as below followed? 1. Sub-step 4a: Analyze other activities similar to the proposed project activity 2. Sub-step 4b: Discuss any similar Options that are occurring rev0 1 B.5 The out come of the step3 has not been defined in the. Both of the steps have been used in sub step 4-b of the section B.5 of the version 01. In substep 4 a in section B.5 of the project, it has been stated that share of HEPPS in total installed capacity of Turkey is about 32.8 % where as share of HEPPS in total generation is only 18.7 %. Additionally, it has been stated that the installed capacity of thermal power plants has shown a rapid growth where as that of hydroelectric powerplants decrease from %40 to 32.8 % historically. The statement has been justified by the statistics of TEIAS which show the annual development of Turkeys installed capacity and annual development of Turkeys gross electricity generation by primary sources. It has been agreed that the electricity generation by hydropowerplants is not diffused to country wise in comparison with thermal powerplants considering the potential of turkeys hydroelectric potential. CAR 23 Final 103

104 CHECKLIST QUESTION Ref. MoV COMMENTS Draft y. Has the below guideline followed for CL Sub-step 4a: Analyze other activities 119 similar to the proposed project activity 1. Provide an analysis of any other activities that are operational and that are similar to the proposed project activity. Other CDM project activities are not to be included in this analysis. Provide documented evidence and, where relevant, quantitative information. On the basis of that analysis, describe whether and to which extent similar activities have already diffused in the relevant region. rev0 1 B.5 The project activity is generation of electricity by hydroelectric power plant. Accordingly please clarify the assessment of other activities similar to the project activity as the following; Please supply an analysis of hydroelectrical power plants that are operational and that are in the same country/region and or rely on a similar technology, are of similar scale, and take place in a comparable environment according to the sub step 4.a of the additionality tool version Please consider that CDM project activities are not to be included in this analysis. Provide documented evidence and, where relevant, quantitative information. On the basis of that analysis, describe whether and to which extent similar activities have already diffused in the relevant region. Final z. Has the below guideline followed for Sub-step 4b: Discuss any similar Options that are occurring: 1. If similar activities are identified, then it is necessary to demonstrate why the existence of these activities does not contradict the claim that the proposed project activity is financially/economically unattractive or subject to barriers. This can be done by comparing the proposed project activity to the other similar activities, and pointing out and explaining essential distinctions between them that explain why the similar activities enjoyed certain benefits that rendered it financially/economically attractive (e.g., subsidies or other financial flows) and which the proposed rev0 1 B.5 Please demonstrate why the existence of these activities ( if any according to the sub step 4.a for Clarification has been requested ) does not contradict the claim that the proposed project activity is financially/economically unattractive or subject to barriers. CL

105 CHECKLIST QUESTION Ref. MoV COMMENTS Draft project activity cannot use or did not face the barriers to which the proposed project activity is subject. In case similar projects are not accessible, the D should include justification about non-accessibility of data/information. æ. Has the outcome from Step 4 clearly The outcome of step4 has not been presented in the CAR mentioned in D? rev0 version B.5 Final ø. Has it been proved that the porject is additional? A number of CLs and CARs have been raised on table 3 of this protocol based on rev 01 of the. The conclusion will be realized after the CLs and CARs have been closed. 105

106 TABLE 4 LEGAL REQUIREMENTS CHECKLIST QUESTION 1. Legal requirements 1.1. Is the project activity environmentally licensed by the competent authority? 1.2. Are the conditions of the environmental license being met? 1.3 Are the conditions of the Designated National Authority being met? Ref. MoV * COMMENTS Yes project activity is environmentally licensed by the competent authority The conditions of the environmental license have been met. Draft N/A Final 106

107 TABLE 5 RESOLUTION OF CORRECTIVE ACTION AND CLARIFICATION REQUESTS Draft report clarifications and corrective action requests by validation team CL1 The source for the reference 10 has not been presented in the ver01. CL2 Reference 12 given in ver01 is not accessible CL3 Please indicate the page number for the reference 13. Ref. to checklist question in table 1 and 2 Table 1 2.b.i. Table 1 2.b.i. Table 1 2.b.i. Summary of project owner response Reference was corrected in ver.2 The page has been replaced during updating however, a print screen of related page has been provided to DOE. The section (barrier analysis) has been removed from D therefore reference 13 is deleted. Validation team conclusion Reference 10 stood for the source of the eurobond rates used in benchmark analyssis. The source for the erobond rates have been given under reference 16 in version 2 of the. The reference given belongs to the official site of ziraat bankası ( Ziraat Bank) which is publicly available and a reputable source. The source of the reference has been checked from the internet by the DOE. The CL has been closed. The reference has been checked. The CL has been closed. The barrier analyssis have been removed form the version2. The additionality has been argued by the investment analyssis hence the arguement has been accepted by the DOE. The CL has been closed. CL4 The statement in substep 4a of the version Table 1 2.b.i. The sentence has been added to show that although the share of hydros seem high in installed capacity, their share in In the version 02 the explanation has been clarified. The CL has been closed. 107

108 Draft report clarifications and corrective action requests by validation team 1 is as follows: According to the TEIAS statistics, share of HEPPs in total installed capacity of Turkey is about 32. 8% whereas share of HEPPs in total generation is only 18.7%. Reference 14 has been related to the above statement. Please clarify the meaning of the sentence. Additionally please clarify how the values 32.8% and 18.7%. have been derived from the referenced document. Ref. to checklist question in table 1 and 2 Summary of project owner response overall generation is low due to many reasons including change in flow regime. The sentence hasbeen clarified and the reference has been updated. 32.8% is share of hydro which is simply the ratio of installed capacity of hepps (Cell:F90) in updated reference to total installed capacity (Cell:H90) whereas 18.7% shows share of electricity generated by HEPPs calcualted similarly (using ratio of Cell:K90 to M90) Validation team conclusion CL5 Reference 16 is not available through the adress presented. Please suplly an available adress for the document. Table 1 2.b.i. A copy of reference is provided to DOE. Thre refenced document has been also reviewed by the DOE. The CL is closed. CL6 The generation amount given for year 2007 is not parellel with the amount given in reference 18. Please clarify how the amount is calculated from the given reference. Table 1 2.b.i. The paragraph has been revised and updated. In the references given, the share of hydro is given separately untill 2005 whereas for 2006 and 2007, share of hydro,geothermal and wind is given together as onefigure. Therefore, in order to calculate share of hydros in 2007, generation units put into operation in 2006 and 2007( and was amount in 2005 was added to figure in Review 1: The references were reviewed by the DOE, however for thermal generation the value given in the version 02 does not match with the values given in the references. Please make sure that you also include the power plants that are taken out of operation. The CL is still open. Review2. The Clarification has been accepted 108

109 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response PP Response 18/05/2010 The tool requires inclusion of newly added capacity therefore plants taken out of operation are not included. Validation team conclusion by the DOE. CL is closed. CL7 The references are linked to the same documents. Please clarify. Table 1 2.b.i. Replication was corrected. Reference 29 has been changed as reference 27; hence the replication has been corrected. CL has been closed. CL8 Table 1 The gross electricity generation for has been linked to the reference ; However, the link is not accesible. Please clarify the reference link. 2.b.i. Link was upadted as The link is updated in the version 02. The CL has been closed. CL9 It has been stated in section B.4. of version 01 that In the absence of the proposed project activity, same amount of electricity is required to be supplied via either the current power plants or by an increased number of thermal power plants, thus increasing GHG emissions. The statement has been justified by indicating that Turkish electricity generation is composed mainly of thermal power plants. The share of hydroelectric power plants has decreased significantly in recent years, due to the Table 1 2.b.i. The paragraph has been improved and additional references have been added. PP Response 18/05/2010 Statement was corrected in D v3 Review 1: In version 02 it is stated that Distribution of installed power according to primary resources is given in figure below. However the referred figure shows the Peak Load and consumption projection for Turkish electricity system between Please clarify The CL is still open. 109

110 Draft report clarifications and corrective action requests by validation team reduction of the economically feasible hydraulic resources. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion Review 2: Cl has been closed. Please supply a reference for the above justification. CL10 The related satement for the reference 37 could not be seen in the document. Please supply the page number for the reference 37. CL11 Under substep1 b in section B.5 of the version this section the reference law number (footnote #9) given for the environmental law is wrong. Please clarify. Table 1 2.b.i. Table 1 2.b.i. Page number is 405 (given in page 24 of preivous version of D. Statement in the reference is The BAT electrical efficiency (at the alternator terminals) ranges from about 40 to 45 % (depending on engine size) calculated based on the lower heating value of the fuel. The law number seems correct? CL has been closed. The CL has been closed. CL12 The Emission Factors used in the calculations are taken from the IPCC minimum values at the lower limit of uncertainty at a 95% confidence interval (table 1.4 of Chapter 1 of Vol. 2 (Energy) of the 2006 IPCC Guidelines for GHG inventories. However, in section B.6.3. of version 1, it has been stated that The emission factors required for calculation of CO2 emission coefficient have been obtained through IPCC 2006 guidelines for GHG inventories for fuels except for coal and lignite. For lignite and coal, Table 1 2.b.i. IPCC value sha been used for all EF values. The reference and wording has been updated. In the version 02 the referred phrase has been corrected. The CL has been closed. 110

111 Draft report clarifications and corrective action requests by validation team the emission factors have been calculated using country specific heating values of fuels consumed and data from National Greenhouse Gas Inventory of Turkey. Please clarify the reference statement. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion CL13 In Table 13 of the version 01, values used for the calculation of the OM have been presented. The reference for the table is given as the National Inventory of Turkey In 2007 inventory; IPCC mid values have been used. However, the EF values given in the table stand for the min IPCC min values. According to the Tool to calculate the emission factor of an electricity system it is convenient to use IPCC min values. So, please clarify the reference for the EF factors. Table 1 2.b.i. Reference has been updated. The reference has been revised in version 02. The CL has been closed. CL14 The VCS template given in the web address v-c-s-org.tr has not been used. The D format given in the UNFCC website has been used. Please clarify the assumptions and the reasons in the. CL15 In section A.2 of the the project category has been specified as the following: Table 1 2.d.a. Table 1 2.d.c.i. The CDM template is used as it is allowed by VCS. We don t think that it is required to explain it in D. Project category has been revised. The CL has been closed. In version 02 the category of the project activity has been revised under section A.4.2. Type I : Renewable energy projects 111

112 Draft report clarifications and corrective action requests by validation team Category I.D. : Renewable Energy Generation for a Grid Sub-category : Hydro Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion The CL has been closed. Category ID is applicable to small scale projects please clarify the contradiction and revise in accordance. CL16 It is not specified if the project is a grouped project in the. Please specify if the project is a grouped project. Table 1 2.d.c.ii It has been stated in D that project is not a grouped project. Under section A.4.2 of the version 02, it is stated that the project is not a grouped project. The CL has been closed. CL 17 Please state the project size in the (Micro project: Less than 5,000 tonnes CO 2 equivalent emissions reductions per year; Mega Project: More than 1,000,000 tonnes CO 2 equivalent emissions reductions per year) CL 18 The brief description of the project activity is provided under section A.2. of the ver01. In line with the Bursa Water Supply Project Master Plan and Nilufer Dam Feasibility Report, Uluabat HEPP and power tunnel feasibility report, Emet Orhaneli Project Cinarcik Dam and Uluabat HEPP Report, Production License Table 1 2.d.d. Table 1 2.d.e It is added to D that it is not a micro or mega project. Scope of the project is given in more detail in section A.2 The project size has been defined in the version 02 according to VCS definitions. The CL has been closed. The scope of the project is given in detail in version 02. The CL has been closed. 112

113 Draft report clarifications and corrective action requests by validation team and Water Usage Agreement; please clarify the scope of the Emet Orhaneli Project Cinarcik Dam and Uluabat HEPP in the. CL 19 The brief description of the project activity is provided under section A.2. of the ver01. In line with the Bursa Water Supply Project Master Plan and Nilufer Dam Feasibility Report, Uluabat HEPP and power tunnel feasibility report, Emet Orhaneli Project Cinarcik Dam and Uluabat HEPP Report, Production License and Water Usage Agreement; please clarify the scope of the proposed project that will be carried out by Akenerji Elektrik Uretim A.S. in the. Ref. to checklist question in table 1 and 2 Table 1 2.d.e Summary of project owner response Scope of the Uluabat HEPP project is given in more detail in section A.2 Validation team conclusion Scope of the project activity is explained in more detail in version 02. The CL has been closed. CL 20 The brief description of the project activity is provided under section A.2. of the ver01. Please clarify the estimated energy production in the, considering the water demand to be supplied from the Cinarcik Dam according to Bursa Water Supply Project Master Plan and Nilufer Dam Feasibility Report and water usage agreement Table 1 2.d.e Estimated energy production and how it will change is given in section A.2 of D. PP Response 18/05/2010 The statement has been corrected as GWh in CL21 Table 1 Installed capacity and generation is clarified referring to generation license. Review 1: In version 02 it is stated as follows: Uluabat HEPP project has installed capacity of 100 MW and expected to generate GWh as per the license however due to the use of water for other purposes, it is expected to decrease to GWh in 2021 and GWh in 2028 in parallel to GWh. Please clarify. The CL is still open. Review 2: CL is closed. Review 1: In version 02 it is stated as 113

114 Draft report clarifications and corrective action requests by validation team The brief description of the project activity is provided under section A.2 of the ver01. Please clarify the installed capacity and the estimated annual energy generation according to the production license in the. CL22 The brief description of the project activity is provided under section A.2. of the ver01. Please include water usage agreement and production license in the as an annex in Turkish-English language CL23 In section A.2. of the ver01, it has been stated that The project consists of a rock filled embankment dam at 210 meters riverbed elevation, 556 m long horseshoe shaped derivation tunnel, 11,820 m long transmission tunnel, source and downstream cofferdams, Ref. to checklist question in table 1 and 2 2.d.e Table 1 2.d.e Table 1 2.d.e Summary of project owner response Generation License was added to D. PP Response 18/05/2010 We haven t seen any water right utilization agreement attached to D so far, even in other projects validated by BV or other DOEs. There exist many other agreements and it is not appropriate to include them all in D. Cınarcık Dam is built by DSI whereas tunnel and powerhouse is built by akenerji. Responsibility of akenerji is limited to HEPP part of the project whereas Dam is an integal part of the project as defined in feasibility report. Therefore it does not form a conflict. Validation team conclusion follows: Uluabat HEPP project has installed capacity of 100 MW and expected to generate GWh as per the license however due to the use of water for other purposes, it is expected to decrease to GWh in 2021 and GWh in 2028 in parallel to GWh. Please clarify. The CL is still open. Review 2: The statement has been clarified in D v3 hence the CL is closed. Review 1: The generation license and its English translation is attached to version 02. However the water usage agreement is not attached. The CL is still open. Review 2: CL is closed. CL is closed. 114

115 Draft report clarifications and corrective action requests by validation team spillway, 838 m long penstock pipe and a power plant with 2 vertical axis Francis turbines. The statement that the project consists of a rock filled embankment dam creates a conflict with that the scope (boundary) of the proposed project is construction of energy tunnel &the HEPP and energy generation. Please clarify/correct the statement in the. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion CL24 Main goals of the project have been included under section A.2. of version 01. Supply of water (for irrigation, usage and drinking) to the Bursa region is not in the scope of the Uluabat Power Tunnel and HEPP project since the dam will be operated by State of Hydraulic works. Please clarify the main goal of the project considering the scope that will be in charge of Ak-Enerji. CL25 Table 1 2.d.e Table 1 2.d.e This comment conflicts withthe request that reservoir emissions should also be included. CL is closed. Main goals of the project have been included under section A.2. of version 01. It has been stated that more than 150 people will be employed during the construction phase and about 15 people will be recruited during the implementation phase. During the site visit it has been checked that about 150 people will be employed during the construction phase. Please provide the estimated number of people that will be employed during the operation phase. according to the job descriptions. Estimation about number of people planned to be recruited during operaiton was added together with their job description. In version 02 estimation about number of people planned to be recruited is given. The CL has been closed. 115

116 Draft report clarifications and corrective action requests by validation team CL26 Main goals of the project have been included under section A.2. of version 01. Please clearly state the impact of the project in the share of HEPPs to justify that the project will increase share of HEPPs in electricity generation mix of Turkey. CL27 Main goals of the project have been included under section A.2. of version 01. Please clearly state the utilization ratio of hydroelectric potential of Turkey in the western part of Turkey to justify that the project will Utilize the hydroelectric potential of Turkey in the western part of Turkey. Ref. to checklist question in table 1 and 2 Table 1 2.d.e Table 1 2.d.e Summary of project owner response It has been indicated that uluabat generation constitutes 1.2% of hydroelectrical generation and 0.22% of total generation in PP Response 18/05/2010 Reference has been updated in v3 of D. Justification was added and reference 1 was included in D. Validation team conclusion Review 1: A footnote number 15 is given as a reference related to the projects contribution. However footnote 15 does not exist in the version 02. Please clarify. The CL is still open. Review2 : The CL is closed. In version 02 the justification is added to section A.2. The CL has been closed. CL28 Table 1 2.d.f The project location has been given as Bursa Province, Uluabat District in A & A.4.14 of the version 01 as validated through the site visit. PP Response 18/05/2010 The coordinates given in section A414 defines the project boundaries. The clarification is closed. The detailed information on the project location, including geographic and physical information allowing the unique identification and delineation of the specific extent of the project,

117 Draft report clarifications and corrective action requests by validation team and including GPS project boundaries are provided under section A.4.4. of the version 01 as the following. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion The project site lies between 28º 46' - 28 º 43' E longitudes and 40º 03' - 40º 09' N latitudes. The closest settlement is the Akçalar Village, about 20 km to the project site. Other settlements close to the project site are the towns of Orhaneli and Buyuk Orhan in the south, within the province of Bursa. The project lies between the Emet Creek in the west and Nilufer Creek at the east. During the site visit, the GPS coordinates (including altitude) of the surge tank, HEPP building has been checked according to the feasibility report dated However please also include the boundaries that the given coordinates stand for to clarify if the coordinates define a project boundary that starts with the energy tunnel and ends with the connection point to the grid. CL29 The project locations have been given in section A.4.4 of the. Please include the connection point of the transmission line to the grid in the to clarify the unique identification of the project. Table 1 2.d.f Figure of connection point was added to Section A The connection point figure and the explanation was added to the version 02. The CL has been closed. 117

118 Draft report clarifications and corrective action requests by validation team CL30 Under Section C.1.2. of the VCS version 01, it is stated that the project construction has started on and the plant is expected to start operation by Please provide a proof to clarify the start date of the construction and a work plan also to clarify the expected start date of the operation. CL31 Please include the conditions prior to the project initiation in the. CL32 In section A.4.3 of the the technologies and the services have been given as the following Hydroelectric power plants are structures that generate electricity utilizing energy of flowing water. Project consists of two vertical axes Francis turbines and generators which are used to transform the potential energy of water to mechanical energy at the first stage and later into electrical energy. Please clearly describe the characteristics of the Ref. to checklist question in table 1 and 2 Table 1 2.d.g.i. Table 1 2.d.h Table 1 2.d.j Summary of project owner response Agreements and timeline provided to DOE can serve as proof for start date of construction. It has been added to section B.2 that project involves a new projet activity. PP Response 18/05/2010 Conditions prior to project implementation was added to D v3. Chracteristics of the project has been given in more detail. Validation team conclusion The proofs have been seen by the validation team. Clarificatio has been closed. Review 1: Under section B.2 of the version 02 it is stated that the project activity involves the construction of a new grid connected renewable power plant, however the conditions prior to project initiation is not clearly identified. The CL is still open. Review 2: CL is closed. A detailed table showing the characteristics of the project activity is given in version 02. The CL has been closed. 118

119 Draft report clarifications and corrective action requests by validation team project and the technologies to be used in the CL33 Please clearly state in the ; if there are any risks that may substantially affect the project s GHG emission reductions CL34 Please clarify if the project has been rejected under other VER programs CL 35 If the answer to the CL 34 is yes ; ( if the project has been rejected under other GHG programs ) please cclearly state in its VCS all GHG programs for which the project has applied for credits and why the project was rejected Ref. to checklist question in table 1 and 2 Table 1 2.d.l Table 1 2.d.p Table 1 2.d.q.i. Summary of project owner response Risks have been added to section A.4.4 Declaration exists in Section F of. N/A. Project has not applied or rejected by other GHG programs. Validation team conclusion The risks are given in version 02. The CL has been closed. Under section F.2 of the it is stated as follows: Project owner confirms that the project activity does not create any other form of environmental credits. The CL has been closed. The CL has been closed. CL 36 If the answer to the CL 34 is yes ; ( if the project has been rejected under other GHG programs ) please supply the DOE and Registry with the actual rejection document(s) including explanation Table 1 2.d.q.ii. N/A The CL has been closed. CL 37 Please clarify in the if there is any commercial sensitive information that has been excluded from thee public version of the Table 1 2.d.t There exists no commercially sensitive information exluded from D. PP Response 18/05/2010 The satement has been added to section Review 1: According to section 1.17 of the VCS template it should be stated in the whether there is any commercially sensitive 119

120 Draft report clarifications and corrective action requests by validation team that will be displayed on the VCS Project Data Base. Ref. to checklist question in table 1 and 2 Summary of project owner response f also. Validation team conclusion information or not. As the VCS template is not used, this statement should also be given in the as per the rules of VCS. The CL is still open. Review2: The CL is closed. CL38 If there is any commercial sensitive information that has been excluded from the public version of the VCS, please list. Table 1 2.d.u PP Response 18/05/2010 N/A. D does not contain any commercially sensitive information. The satement has been added to section f also. Review 1: According to section 1.17 of the VCS template it should be stated in the whether there is any commercially sensitive information or not. As the VCS template is not used, this statement should also be given in the as per the rules of VCS. The CL is still open. Review 2: CL is closed. CL39 For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the ver01 that; the geographic and system boundaries for the relevant electricity grid can be clearly identified and information on the characteristics of the grid is available. Please clarify the sources for identification and Table 1 2.d.x Clarification has been added to section B.2 In version 02, the sources for identification and the characteristics of the grid is given in detail. The CL has been closed. 120

121 Draft report clarifications and corrective action requests by validation team the charecterics of the grid in the. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion CL40 For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the ver01 that; Project Power density is higher than 4 W/m 2 Please clearly present how the power density has been calculated by also giving references for the data used in calculation. Table 1 2.d.x Calculation of power density has been added to D section B.6.3 PP Response 18/05/2010 We don t understand the reason for confusion however, further clarification has been added to D section B.2 about conditions applied to the project. Replication for heasing B.6.3 has been corrected in V3 of D. Reference for reservoir area has been added. If the PE is meant, the unit should be right (38.03 kt). It has been also given as t/yr for clarification. Review 1: According to ACM0002 version 10, for hydro power plants, one of the following conditions must apply: The project activity is implemented in an existing reservoir, with no change in the volume of reservoir; or The project activity is implemented in an existing reservoir, where the volume of reservoir is increased and the power density of the project activity, as per definitions given in the Project Emissions section, is greater than 4 W/m 2 ; or The project activity results in new reservoirs and the power density of the power plant, as per definitions given in the Project Emissions section, is greater than 4 W/m 2. However it is not clearly identified in the whether the project results in a new reservoir or implemented in an existing reservoir. In version 02 there are two sections entitled B.6.3 (Ex-ante Calculation of emission reductions). 121

122 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion Please clarify. The details of the Power Density Calculations are given in the second section named B.6.3. However the references of the data used in the calculation of the power density is not given in the version 02. Also for the project emission calculations the unit of the annual project emissions is wrong. The CL is still open. Review 2: The reference for the lake area and the calculation of the project emissioıns has been checked. The clarification has been closed. CL41 Origin of data for quantity of fuel combusted in diesel power generator is given in section B.7. of the version 01 as; on site measurements from equipment working hours. Please clarify the calculation methodology of the fuel combusted in diesel generator in the tabular format Table 1 2.d.ff.iv. The tool referred in themethodology will be used to calculate amount and emissions from diesel fuel combustion. In the it is stated that the emissions of the diesel generator will be calculated According to the Tool to calculate project or leakage CO 2 emissions from fossil fuel combustion The CL has been closed. CL42 Table 1 It has been added that recording will be Review 1: 122

123 Draft report clarifications and corrective action requests by validation team Monitoring frequency has been presented as continuously for the FCi,y parameter in section B.7.1. of the version 01. Please clarify the recording period also. Ref. to checklist question in table 1 and 2 2.d.ff. v. Summary of project owner response annually. PP Response 18/05/2010 Statements about monitoring auxiary fuel consumption has been removed since it is not required by meth. anymore. Validation team conclusion In version 02 under QA / QC procedures it is stated as follows: Data recorded by the equipment will be cross-checked by the fuel invoices annually. However the data/parameter name is given as FC i,j,y. Please correct the parameter name according to the tool. The CL is still open. Review 2: Cl is closed. CL43 The parameter, namely EGy, is not required to be monitored according to ACM 002 version 10. However the named parameter has been included in the monitoring parameters in section B.7. of the version 01. Please clarify the reason for including the named parameter. CL44 In section B.6.2 of the version 01; the data units used are given as the following: EGy: MWh; EF CO2 :TC0 2 /TJ; FCi,y:tons or 100 m3 gasses; η:%; NCV:TJ/kt. According to Tool to calculate the emission factor of an electricity system the data units for Table 1 2.d.gg. Table 1 2.d.gg.i The EGy in previous version has been revised as EGy,facility for clarification and compliance with meth. applied. Parameter should be section B.7 but not in B.6.2 as it is monitored. It has been removed from B.6.2 in revised version of D. Since NCV values of some fuels(like lignite) are very low, they would not represent exact values due to rounding if expressed in terms of TJ/ton. Therefore, they have been given in TJ/kt The CL has been closed. The explanation is found acceptable. The CL has been closed. 123

124 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion NCV and EF CO2 are GJ/kt and TCO 2 /GJ. The definitions of the data units in TJ are accepted since both of the parameters are defined in the TJ unit. However please clarify the reason for selecting the parameter for the NCV as TJ/ kt where the other parameters are based on the tonnes unit. CL45 Under section B.7. of the, the description for EGy has been defined as the net electricity generated and delivered to the grid by Uluabat power plant in year The description of the parameter does not match with the indicator according to ACM002 version 10. Please clarify Table 1 2.d.gg.ii Definition in previous version was Net Electricity generated and delivered to the grid by Uluabat power plant in year y In revised D description in meth. applied has been added to prevent any confusion and for compliance. PP Response 18/05/2010 Statement has been extended to include 2005 and 2006 also. Review 1: In the version 02, the parameter EGy,total is defined as Net Electricity generated by power plants in Turkey in year 2007 However this parameter is not only used for the year 2007, it is also used for the years 2006 and 2005 for the OM calculations. Please clarify. The CL is still open. Review 2: The CL is closed. CL46 The source of data for the parameter EGy has been defined as the feasibility report in section B.6.2. of the version 01 in the tabular format; please clarify. Table 1 2.d.gg.iii EGy parameter has been removed from as it has been mistakenly added to section B.6.2. Parameter is defined in under monitoring paramters. The CL has been closed. C47 TEİAS Web page which refers to government records have been referenced as the source for Table 1 2.d.gg.iii Link for 2005 and 2006 has also been added to revised version. The CL has been closed. 124

125 Draft report clarifications and corrective action requests by validation team the parameter FCi,y. in section B.6.2. of the version 01 in the tabular format. However the link given only includes data for year Please clarify the source of data for the year 2006 and 2005 also. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion CL48 In the BM calculations the employed emission factor for fuel oil is the same as the IPCC lower level for residual fuel oil. However according to NIR there is no residual fuel oil usage on that year. Please clarify. CL49 The table in annex 3 of the version 1 has been referenced as the values applied for the NCV values. However, NIR 2007 has been referenced in the table in Annnex 3. Please clearly present how the NCV values are computed. Table 1 2.d.gg.iv Table 1 2.d.gg.iv Baseline calculation considers period which means only 2007 is common with the NIR mentioned. The reference for source of data used is given in baseline calculation which is web page of the relevant government authority for power generation. This is not within the scope of PP to clarifify if there is any inconsistency. The reference to National inventory has been removed. Details of the NCV calculation is available as an excel sheet in baseline calculation provided to DOE. The CL has been closed. The reference NIR has been removed from the data given in Annex 3. The CL has been closed. CL50 In the OM&BM calculations the employed emission factor for coal is the same as the IPCC lower level for anthracite. However according to NIR there is no value for anthracite. Please clarify the assumption. Table 1 2.d.gg.iv Anthracite is a type of coal also. Value used is NIR for coal (25.8 tc/tj) corresponds to EF of anthracite (94.6 tco 2 /TJ) in IPCC value. PP Response 18/05/2010 EF calculation has been revised and D Anthracite is not the most commonly used coal type in thermal power generation. Also the values in the NIR are the default carbon content values of fuels, however the EF of Anthracite is the lower EF. The default value given in the NIR equals to default carbon content of 125

126 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response has been updated accordingly. Validation team conclusion other bituminous coal and coking coal, the default carbon content of Anthracite is Please correct your calculations accordingly. The CL is still open. Review 2: The clarificarion is closed. CL51 For the FCi,y parameter it has been stated that the gauges and reading devices on diesel generators will be used for monitoring of FCi,y parameter in section B.6.2. of the version 01. Please clarify the procedure. Please clarify how the amount of fuel stocked in the tank of the generator will be defined if data will be checked form the invoices provided by the plant operator. CL52 It has been stated that; since the reservoir is mainly built before start of power plant component, emissions from reservoir was not included in emission reductions calculations in section B.6.3 of the version 01. Table 1 2.d.gg.iv Table 1 2.d.kk Since reading device of generator will be the main source, invoices will be used for justification of the value.. In practice it has never casued a problem during verification of other projects so far as it can be easily seen how long the equipment has worked and how much fuel has been purchased. As the expected value of amount mentioned is already minor (1-2 tons per year), we ll solve the issue with verification DOE if necessary and take the maximum value for emission calculation. Reservoir emission has been included in revised version. The clarification is found satisfactory. The CL has been closed. In version 02 the project emissions resulting from the reservoir is included in the calculations. The CL has been closed. 126

127 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion During the site visit, it has been observed that the dam has been built in 2008 and the main purpose of the Orhaneli-Emet Project was to generate electricity. Please clarify the justification CL53 It has been stated that the project emission has been defined as 0 in section B.6.2. of the version 01. Please present the calculation of the power density and justify how the project emission has been defined as 0. ( Note: Please give clear references for the Apj and Capj) Table 1 2.d.kk Calculation of power density is included in revised version. Capj information already exist in generation license and feasiblity report whereas Apj is available in feasibility report. PP Response 18/05/2010 References have been included in D. Review 1: Please also include these references in the. The CL is still open. Review 2: The clarification has been closed. CL54 In section B.6.4 of the version 01, the annual emission reductions have been presented in the tabular format for 10 years. However, total numbers of crediting years have been defined as 7 years please clarify. Table 1 2.d.ll It has been corrected as 10 years in revised version. PP Response 18/05/2010 Table has been updated. Review 1: In version 02 the total number of crediting years is corrected as 10 years. Please also use the table (page 14) given in EB 41 report Annex 12 Guidelines for completing the project design document(cdm- D) and the proposed new baseline and monitoring methodologies (CDM-NM) To be able to show the project 127

128 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion emissions and emission reductions seperately. The CL is still open. Review 2: The table as been reviewd and the clarification has been closed. CL55 In section D.1. of the version 01, it has been indicated that the Uluabat HEPP and Cinarcik Dam Project have been exempted from the scope of the EIA report since the project approval date is before The permits that indicated that EIA report is not required according to EIA legislation has been seen by the DOE. The permits have been given for the transmission lines and the dam body separately. The dates of the permits are; and Table 1 2.d.mm Since the project approval date is before 07/02/1993, project has been exempted from EIA upon the assessment of Min. Of Env. And Forestry and Min. Of Energy. The issue has also been explained in Environmental assessment report prepared for the project which is not requried by regulations but prepared for the project upon request of investor. The clarification has been closed. The permits do not include the HEPP; please clarify if EIA report is required for HEPP. CL56 In section D.1 of the version 01, it has been stated that an Environmental Impact Assessment Report has been prepared by "PRD Planlama Arastirma and Gelistirme ve Danismanlik Sirketi" for the International Finance Corporation in order to evaluate the Table 1 2.d.mm The report will be submitted to DOE. Environmental impacts are assessed in section E.1 of document. PP Response 18/05/2010 Page numbers were added to D v3 Review 1: Please indicate in the the precise references (the page numbers) of the statements taken from the Environmental Assessment Report. 128

129 Draft report clarifications and corrective action requests by validation team possible impacts of the project. Accordingly, it has been stated that the report stated that the project does not have significant impacts and EIA is positive for the project. The EIA report prepared has been submitted to the DOE by the PP. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion The CL is still open. Review 2: The pages were also reviewed by the DOE and the clarification has been closed. Please clarify the pages or the sections that, it has been stated that the report stated that the project does not have significant impacts and EIA is positive for the project. CL57 Stakeholder consultation meeting is not mandatory for this project according to the legal requirements since it is exempted from EIA. However initial stakeholder consultation was held on in Akçalar Köyü. Stakeholders were invited to the meeting by local newspaper dated Results from the initial stakeholder consultation report were provided in section E.2. of the version 01. It has been stated that the main concerns raised by the participants were reduction of the oxygen content and the heating of water outlet of the HEPP, the damage of transmission tunnel. The replies of the company have also been included in section E.3. of the version 01. Table 1 2.d.nn As per the laws and regulations, expropriation for other utililities will be decided and conducted by government agencies. The company will only pay the amounts declared by governmetn to land owners. Decision of EK for expropriation and relevant documents will be submitted to DOE together with revised version. The expropriation documents have been reviewd by the DOE. CL has been closed. During the site visits, it has been observed that there were some areas that were/would be 129

130 Draft report clarifications and corrective action requests by validation team expropriated. Please clarify how the compensation was realized on the issue. CL 58 Please clarify the chronological plan for the date of initiating project activities, date of terminating the project, frequency of monitoring and reporting in the Ref. to checklist question in table 1 and 2 Table 1 2.d.oo Summary of project owner response Timeline for main project activities have been added to D annex 8. PP Response 18/05/2010 Commissioning date is given in table, operation period is defined by the license. Monitoring frequency will be decided later during operation stage. Validation team conclusion Review 1: The timeline of the project activity has been given in Annex 8 of version 02 The CL is closed. CL 59 The revised generation license was sent to the validation team as a proof of title, and please also presents the generation license taken from EMRA as an attachment to the VCS. Table 1 2.d.pp Generation license has been included in revised D. PP Response 18/05/2010 VER rights is ruled by agreement btw Akenerji and GTE. It is not common to include it in D. The statement about ownership is provided to VCS during registration request. Review 1: The generation license has been attached to the version 02. The CL is closed. CL60 Last alternative has been defined as a construction of a thermal power plant with the same installed capacity or the same annual power output in section B.5. of the ver 01. Please supply references for thermal power plant or justify that the investor has sufficient technical background in thermal power plant Table3. 1.d. /Faaliyetlerimiz.aspx /BasinBultenleri/Akenerji%E2%80%99nin %209%20ayl%C4%B1k%20net%20sat% C4%B1%C5%9F%20geliri% The references were reviewed by the DOE. The CL has been closed. 130

131 Draft report clarifications and corrective action requests by validation team operations. Ref. to checklist question in table 1 and 2 Summary of project owner response 9.pdf Validation team conclusion Company has several other thermal power plants commissioned and at investment stage as in references given above. CL61 In the outcome of step 1 a of section B.5. it has been stated that continuation of the current situation supply of equal amount of electricity in the grid has been defined as a non realistic alternative. Please clearly state the realistic alternatives in the out come of Step 1.a. Table 3.1.f. Wording has been revised and clarified. PP Response 18/05/2010 Alternatives were given more clearly. Review 1: According to the Tool for the demonstration and assessment of additionality the outcome of substep 1a shall be Identified realistic and credible alternative scenario(s) to the project activity Please define clearly which alternatives are identified to be realistic and credible. The CL is still open. Review 2: The clarification is closed. CL62 It has been stated in section sub step 1 b of the version 01 that all the alternative scenarios defined in the VCS are in line with all the mandatory applicable legal and regulatory requirements. Please clarify the justification by presenting a small summary of the requirements of the related legislation for Table3 1.g Summary of compliance with laws has been applied. A summary of how the project activity and the defined alternatives are in compliance with the laws and regulations are given in the version 02. The CL has been closed. 131

132 Draft report clarifications and corrective action requests by validation team the alternatives construction of a thermal power plant and the continuation of the current situation. CL63 If the answer to CL is no please show that, based on an examination of current practice in the country or region in which the law or regulation applies, those applicable legal or regulatory requirements are systematically not enforced and that noncompliance with those requirements is widespread in the country. CL64 In step 1.b. of the version 01, the out come of step 1.b. has been defined as the following; Ref. to checklist question in table 1 and 2 Table3 1.h. Table3 1.i. Summary of project owner response N/A Validation team conclusion N/A Mandotory legislation and regulations for each alternative are taken into account in sub step 1.b.. Based on the above analysis, the proposed project activity is not the only alternative amongst the project participants that is in compliance with the mandatory regulations. Therefore, the proposed VER project activity is considered as additional. Clarification has been added to step 1.b In version 02 it is defined more clearly how the project activity and the defined alternatives are in compliance with the applicable laws and regulations. The CL has been closed. Please clearly include which alternatives are in line with the applicable legislation CL65 a.2) Government bond rates used as a benchmark has been presented in table 3 of Table3 1.i. Bond maturity date has been given in investment analysis section of D In the version 02 the eurobond maturity date has been revised. The CL has been closed. 132

133 Draft report clarifications and corrective action requests by validation team the ver01. The selected bencmarks have maturity date as Please select a bond with the maturity date same as the last year of the IRR period. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion CL66 a.3.) Government bond rates used as a benchmark has been presented in table 3 of the ver01. Please clearly state the year that government bond rates have been accessed. Please present the government bond rates based on the investment decision date Table3 1.i. Reference for government bond rate available at time of investment decision have been given. Eurobond rate of 7.25% (US900123AW05) as of is verified by the given link. The CL has been closed. CL67 In substep II b of the section B.5 of the version 01, it has been stated that Acceptable IRR values for energy investments in Turkey are, given the present global financial crisis and economic uncertainty, are expected at yields in excess of 15% per annum. Please clearly state how the assumed value ( %15 ) is computed in the. Please clearly state in the the value assumed for the bond rate and the risk premium Table3 1.i. Clarification has been added to substep 2.b PP Response 02/08/2010 Reference for risk premium has been added. Statements about project IRR has been removed. Review 1: The value assumed for the eurobond rate and the risk premium applied is given in the version 02, however there is no reference in the showing where the applied risk premium is derived from. Also two different benchmarks have been identified for the project activity. One benchmark identified for equity IRR and another benchmark is identified for project IRR however project IRR is not calculated. Please revise the accordingly. The CL is still open. Review 2: 133

134 Draft report clarifications and corrective action requests by validation team CL 68 The constructions works has been defined as in construction budget sheet of Uluabat Financial Model.xls There are three values identified in the same sheet for the constructions. The values standing for the construction works in the cells D13, C23 and G22 are not the same, please clarify. Ref. to checklist question in table 1 and 2 Summary of project owner response Table 3 1.o Values shows the investment figures at updated at different times. To prevent confusion, figures at financial feasiblity have been given. Also, Updated figures in 17/09/2009 has been given as a background information VCS Validation Report Validation team conclusion Project IRR is removed and reference for the risk premium is given (page 17, Uluabat D_17_05_10_track changes). So. The CL has been closed. The total investment cost ( k ) is verified from both D and IRR analyis documents. The CL has been closed.. CL 69 Please include details the construction works as a separate explanation in the budget sheet of Uluabat Financial Model.xls budget sheet of Uluabat Financial Model.xls and submit proofs for each sub item of the construction works. ( Please relate the sub items with the proofs ) Table 3 1.o The details of the cosntruction works have been included in the financial analysis model..the financial report and the contracts have been reviewd. Clarification has been closed CL70 Please justify the budget for the electromechanical works presented in cell D12 of the budget sheet of Uluabat Financial Model.xls. Table 3 1.o EM Equipment purchase agreement (Voith Siemens) is available within the contracts folder provided to DOE. PP Response 25/06/2006 The amount has been changed as 18.1M Review 1: Altough the agreement notes that the purchase amount is 18.1m (File: New Scan ), 18.4m is used in the IRR analysis. Please use the figure as it is indicated in the agreement. 134

135 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion The CL has not been closed yet. Review 2: The clarification has been closed. CL71 Please justify the budget for the transmission line in cell D11 of the budget sheet of Uluabat Financial Model.xls ( Please present the assumption in the excel sheet & if any) Table 3 1.o The transmission line agreement has been submitted. The clarification has been closed. CL72 Please justify the budget for the expropriation works presented in cell D10 of the budget sheet of Uluabat Financial Model.xls Table 3 1.o Figure has been updated and although the expropriation is not completed, documents for expected amounts, permissions and amounts paid have been provided to DOE. The figures have been justified. The clarification has been closed. CL73 Please justify the budget for the engineering works presented in cell D10 of the budget sheet of Uluabat Financial Model.xls CL74 Please clearly include the justification of the assumption in the Uluabat Financial Model.xls and the for the contingency item identified in cell D15 of the of the budget sheet of Uluabat Financial Model.xls Table 3 1.o The contracts for the enginnering works have been submitted. Table 3 1.o Justification has been added to excel sheet as explanation and in. The figures have been justified. The clarification has been closed. 10% for the contingency is acceptable and it is stated both in D and IRR analysis documents. So, the CL has been closed. CL75 Table 3 VAT figure was updated in revised. The correction is. 135

136 Draft report clarifications and corrective action requests by validation team The VAT value presented in cell B11 of the budget sheet of Uluabat Financial Model.xls includes the powerhouse also. The imported machines are excluded of VAT according to the regulations. Please clarify the VAT amount. Ref. to checklist question in table 1 and 2 1.o Summary of project owner response Validation team conclusion CL76 Please justify the tender cost presented in cell B12 of the budget sheet of Uluabat Financial Model.xls Table 3 1.o Explanation for tender cost and development fee has been given in D. The explanation is. The CL has been closed. CL77 Please justify the income tax rate by presenting clear reference in the version 01. Table 3 1.o Reference has been added ( gi_oranlari.doc) Section III page 4 The reference is. The CL has been closed. CL78 Please present the loan agreement to the DOE to justify the loan amount ( Million Euro ) that is presented in table 4 of the version 1 and the value presented in cell C21 of the cash flow sheet of the Uluabat Financial Model.xls. Table 3 1.o Since the loan agreement had not been signed at time of investment decision, it has been excluded from D and financial analysis. PP Response 02/08/2010 The project investor is one of the largest groups of Turkey and has recently made a JV with a foreign company. Hence, they have financial resources to complete investment with own resources. The use of loan is a business decision and depends on market conditions. For uluabat, so far about 39,870 loan has been used ( Euro and USD). These values have been included in Review 1: Although the loan agreement was not signed at the time of investment decision, it is not realistic and conservative to assume that a HEPP investment with such a huge capacity will be realized without any loan. Therefore, please include the loan conditions in the and also please reflect the loan conditions to the calculations. The CL is still open. 136

137 Draft report clarifications and corrective action requests by validation team CL79 Please clearly state the reference for the tariff presented in table 4 of the version 01. CL80 Please clearly justify the assumption for the expected VERs price value defined in table 4 of the version 01 Ref. to checklist question in table 1 and 2 Summary of project owner response financial model and calculations upon request of DOE and included in D v3. PP Response 02/08/2010 Figure has been updated Table 3 1.o Reference is added 5.5 is max. Price in Renewable Energy Law (article 6) PP Response 25/06/2010 Footnote has been updated Table 3 1.o Page for Certification agreement btw akenerji and GTE will be submitted as evidence to DOE. VCS Validation Report Validation team conclusion Review 2: 28% current level loan ratio can be accepted. Increase in loan ratio would increase the IRR value. Max IRR would be 13.17% with 100% loan usage. In the loan payment sheet, the sum of withdraws is but the amount of loan taken in cell A1 is Please do the correction so that they become equal. The CL has not been closed yet. Review3: The clarification has been closed. Review 1: Although a reference to the renewable energy law is given in the project proponents response, in the the refence (footnote #10) belongs to the electricity market law. Please correct accordingly. The CL is still open. The agreement has been reviewed and accepted. The CL has been closed. CL81 Table 3 Payroll for similar positions for other The payrolls have been reviewd and 137

138 Draft report clarifications and corrective action requests by validation team Staff cost has been presented in cell C4 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls and the details of the salaries have been presented in cells C7-C45 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls. The amount has been found reasonable in comparison with the similar projects. However, please justify the amount by presenting proofs for accuracy. Ref. to Summary of project owner response checklist question in table 1 and 2 1.o power plants of the company will be submitted to DOE as evidence. VCS Validation Report Validation team conclusion accepted by the validation team. The CL has been closed. CL82 Rental cost for staff has been presented in cell A13 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls. Please justify the amount. Table 3 1.o As it is the cost that will occur after commissioning of the plant, it is just an estimate based on common practice. Rental cost has been removed in revised version. The clarification has been closed. CL84 Distribution system charge has been calculated in cells G3-G5 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls. Please clearly state the assumptions in the and relate to the references. Table 3 1.o References for Grid Fee component have been given in more detail as hyperlink and calculations have been updated accordingly. For region 1, 16,917 YTL/MW Yıl is justified from the link given The CL has been closed. CL85 Table 3 1.o Zero Residual adj. Coef. has been explained in excel sheet and references links have been provided as hyperlink for The explanation has been accepted by the validation team. The clarification request has been 138

139 Draft report clarifications and corrective action requests by validation team Zero residual correction item has been defined as 0.9 cent/kwh. Please supply the reference and the state the reference in or in the annxes of the. Ref. to checklist question in table 1 and 2 VCS Validation Report Summary of project owner response Validation team conclusion related cells and included in revised D. closed. CL86 Total generation has been 172 GWh in cells G9 and F3. Please justify the assumption CL87 The annual maintenance cost has been calculated in cells B32-B34 of the Operation Expenses Details Sheet in Uluabat Financial Model.xls Please clearly present the justification for the values for B32&B34. Please also indicate the currency. Table 3 1.o Table 3 1.o Grid Fee calculation has been updated and figures have revised in financial analysis sheets and v2 Reference link has been given for justification of the maintenance cost. Maint. Cost has been assumed as 0,5% of investment cost as expert judgement whereas given reference result in higher figure. The grid fee calculation has been checked and accepted by the validation team. The clarification request has been closed. Maintenance expense is calculated in sheet Cash flow with carbon cell D5 which is 0.5% of total investment value. The clarification request has been closed. CL88 The equity ratio has been defined as %30. in cell B22 of the cash flow sheet of Uluabat Financial Model.xls. Please justify the assumption by presenting the loan agreement to the DOE. Table 3 1.o As there has been no loan agreement at time of investment decision, and negotiations for additional loans continue, statements about loan have been removed from D. PP Response 02/08/2010 The project investor is one of the largest groups of Turkey and has recently made a JV with a foreign company. Hence, they have financial resources to complete investment with own resources. The use of loan is a business decision and Review 1: Although the loan agreement was not signed at the time of investment decision, it is not realistic and conservative to assume that a HEPP investment with such a huge capacity will be realized without any loan. Therefore, please include the loan conditions in the and also please reflect the loan conditions to the calculations. 139

140 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response depends on market conditions. For uluabat, so far about 39,870 loan has been used ( Euro and USD). These values have been included in financial model and calculations upon request of DOE and included in D v3. Validation team conclusion The CL is still open. Review 2: The clarification has been closed. CL89 The interest on loan has been defined in cell B28 of the cash flow sheet of Uluabat Financial Model.xls. Please justify the assumption by presenting the loan agreement to the DOE. Table 3 1.o As there has been no loan agreement at time of investment decision, and negotiations for additional loans continue, statements about loan and interest rate have been removed from D and investment analysis sheets. PP Response 02/08/2010 The project investor is one of the largest groups of Turkey and has recently made a JV with a foreign company. Hence, they have financial resources to complete investment with own resources. The use of loan is a business decision and depends on market conditions. For uluabat, so far about 39,870 loan has been used ( Euro and USD). These values have been included in financial model and calculations upon request of DOE and included in D v3. PP Response 02/08/2010 The loan has been included in model Review 1: Although the loan agreement was not signed at the time of investment decision, it is not realistic and conservative to assume that a HEPP investment with such a huge capacity will be realized without any loan. Therefore, please include the loan conditions in the and also please reflect the loan conditions to the calculations. The CL is still open. Loan is taken in 2 different currencies but the loan rate charged for them are equal, which is 7%. Please, clarify why the rates are equal for both 2 loans. The CL has not been closed. Review 2: 140

141 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response upon request of DOE but this is in cotradiction with the tool. The statement that a project of this size is subjective. Considering the turnover of the project investor, it is not realistic to say that project can not be implemented without loan. The model submitted simulates the conditions at time of investment decision and based on many assumptions and subject to many variation. An average and conservative rate has been estimated for the finance cost and included in the model for simplicity. Besides, the main reason in two currency loan is source of funds does not necessarily mean that it should have different rates. Validation team conclusion The clarification has been accepted by the validation team since 7% of interest rate can be accepted for both 2 currencies so the CL can be closed. CL90 The investment amount presented in cell C4-C10 of the cash flow sheet of Uluabat Financial Model.xls is not the same as the presented investment amount in D16 of the budget sheet of the Uluabat Financial Model.xls.Please clarify. Table 3 1.o Cell D16 represents the cost figure for another project(burcbendi HEPP). It has been removed in revised version in order to prevent confusion. Review 2: Clarification has been closed. CL91 The exchange ratio has been defined as / $ for year Please clarify Table 3 1.o Investment Decision date has been selected as turbine purchase agreement date(07 april 2006) and exchange ratios Review1: The exchange ratio at the exact date of the investment decision will 141

142 Draft report clarifications and corrective action requests by validation team the investment decision date. Ref. to checklist question in table 1 and 2 Summary of project owner response have been updated accordingly. PP Response 18/05/2010 The request is against the common practice and requests of registration bodies and other DOEs. Besides, when we average the currency rates for for 18months period (April 2005-September 2006), we ll see that the difference is only 4.8% hence there exist no significant impact considering that part of the investment is in already. Validation team conclusion not reflect the general condition in the country as Turkey has a very volatile economy and exchange rates vary from day to day. Therefore please use a min. 1 year average value as an exchange rate. The CL is still open. Review2 : When 18 months average /$ rate is used (1.31), IRR would decrease around 1% which is in line with the approach of conservativeness. CL is closed. CL92 40 years have been assumed for depreciation in cash flow sheet of the Uluabat Financial Model.xls. Please clarify and reassess the depreciation by giving references from Tax Procedural Law Communiques (Vergi Usul Kanunu Tebliğleri) as an objective evidence Table 3 1.o The cash flow presented shows the estimation of project return and does not constitute a legal document to be represented to legal authrities for tax amount or accounting. 40 years depreciation period is appropriate for similar project. Since investors do not assume differenet depreciation rates for different components of the plant during investment decision, an overall depreciation period is assumed for the investment. Otherwise, we should have included new turbine cost in 25th years of investment or new transmission line in Review 1 : Applying the correct depreciation period is just an accounting issue which has an impact on the financial gain thus corporate tax and cash flow. Weighted average amortisation period is found nearly 30 years and this would decrease the IRR by 0.2% which can be ignored. So, the CL could be closed for this issue. However, there is one more issue to be solved. In cell j7 of sheet Cash flow with carbon VAT is substracted from the value in cell b12 but the 142

143 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response 30th year of investmnet etc. Which is not the case in practice. First of all, there is no need to include new asset costs after full depreciation is realised. Renewing the asset doesn t depend on the economic life but operational life. Validation team conclusion value in cell b12 doesn t already include VAT. Please do not substract the VAT amount from the total asset value. The CL hasn t been closed yet. Review 2: The clarification has been closed. PP Response 02/08/2010 VAT has been excluded from calculation of residual value. CL93 Please justify the insurance amount presented in cell D6 of the cash flow sheet of the Uluabat Financial Model.xls. Table 3 1.o As the construction is not finished, there exist no agreement of quotations for insurance cost during operaiton phase. However, insurance cost for construction has been added for justication of the cost. In the financial analysis, insurance cost has been assumed as 200,000 which corresponds to about 0,15% of investment cost whereas in similar projects, insurance cost is usually assumed as 0,3-0,4% on investment cost. 0.15% of investment cost is acceptable. The CL has been closed. CL94 The annual maintenance value presented in cell D4 of the cash flow sheet of the Uluabat Financial Model.xls is not the amount maintenance amount presented in cell B34 of the Operation Expenses Table 3 1.o Reference link has been given for justification of the maintenance cost. Maint. Cost has been assumed as 0,5% of investment cost (Cell D4)as expert judgement whereas given reference(b33 in revised version) result in higher figure. 0.5% of investment cost is acceptable. The CL has been closed. 143

144 Draft report clarifications and corrective action requests by validation team Details sheet. Ref. to checklist question in table 1 and 2 Summary of project owner response Therefore lower value has been used for conservativeness. Validation team conclusion CL95 The grid fee presented in cell D4 of the cash flow sheet is not the same grid fee amount presented in cell G12 Operation Expenses Details of the Uluabat Financial Model.xls. Table 3 1.o Grid fee figure was updated and corrected in revised version of calculation. The CL has been closed. CL96 Please justify the amount presented in cell D14 of the cash flow sheet of the Uluabat Financial Model.xls. CL97 Please justify the investment interest amount indicated in cell D19 of cash flow sheet of the Uluabat Financial Model.xls by presenting the loan agreement. Table 3 1.o Table 3 1.o Residual Value is the value of investment (excluding VAT, DSI cost, exprop. Etc) at the end of depreciation period calculated. PP Response 02/08/2010 VAT has been excluded from calculation of residual value. As there has been no loan agreement at time of investment decision, and negotiations for additional loans continue, statements about loan have been removed from D and financial model. PP Response 02/08/2010 The loan has been included in model upon request of DOE but this is in contradiction with the tool. The statement that a project of this size is subjective. Review 1: Since, there is a mistake in the depreciation amount (it is referred to the CL 92), residual value must be updated accordingly. So, the CL has not been closed yet. Review2: Review1 : Loan is taken in 2 different currencies but the loan rate charged for them are equal, which is 7%. Please, clarify why the rates are equal for both 2 different type of loans. The CL hasn t been closed yet. Review2: CL has been closed. 144

145 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Considering the turnover of the project investor, it is not realistic to say that project can not be implemented without loan. The model submitted simulates the conditions at time of investment decision and based on many assumptions and subject to many variation. An average and conservative rate has been estimated for the finance cost and included in the model for simplicity. Besides, the main reason in two currency loan is source of funds does not necessarily mean that it should have different rates. Validation team conclusion CL98 The depreciation formulae presented in cell J7 of the cash flow sheet of the Uluabat Financial Model.xls includes also the tender cost. Please clarify. Table 3 1.o Company pays an initial amount(33,8milliontl) after tender and 75million TL in 10 installments starting after 5 years of commissioning as a development fee. PP Response 02/08/2010 Tender fee is also included in depreciation in revised model. Review 1: Please clarify why tender fee is not amortised. The CL has not been closed yet. Review2: Clarification has been closed. CL99 The operation expenses have changed after the 11 th year of operation ( cells S8-T8) in cash flow sheet of the Uluabat Financial Table 3 1.o The value has been updated in revised version so that investmnet cost is same during analysis period.. The CL has been closed 145

146 Draft report clarifications and corrective action requests by validation team Model.xls. Please clarify. CL100 The development fee in cell E 26 has been included into financial flow after income before tax has been computed. Please clarify the reason for not including the development fee into cash flow before income before tax has been computed. CL101 In equity IRR calculations only the portion of investment costs which is financed by equity has been considered as cashoutlow in cells G28-I28 of cash flow sheet of the Uluabat Financial Model.xls However the sum of cells G28-I28 is different from the equity amount presented in cell B20 of the same sheet. Please clarify. Ref. to checklist question in table 1 and 2 Summary of project owner response Table 3 1.o Development Fee has been deducted before tax in revised version. Table 3 1.o PP Response 02/08/2010 Tender cost is paid for the DAM construction. The development fee is paid in 10 installments during operation. The difference was due to investment interest paid during cosntruction period. It has been removed in revised version. VCS Validation Report Validation team conclusion Review 1: As far as it is understood, development fee is paid for the DAM project. So, it has to be counted as an investment cost to be amortised instead of expensing in the financial tables. The CL has not been closed. Review 2: The clarification has been closed. The CL has been closed. CL102 Please justify the reason for assuming the cash outflow will be equal to each other in three years of construction period as presented G28-I28 cash flow sheet of the Uluabat Financial Model.xls ( for example by providing the construction plan) Table 3 1.o The investment takes three years and it has been assumed that % will be realized respectively during these years. The assumption is available in cell :G28 The CL has been closed. 146

147 Draft report clarifications and corrective action requests by validation team CL103 The depreciation has been added back as a cash inflow as an income of 21th year in cell AD28 of the cash flow sheet of the Uluabat Financial Model.xls. Please clarify. Ref. to checklist question in table 1 and 2 Table 3 1.o Summary of project owner response As per the tool, residual value at the end of analysis period should be added as income therefore value of assets have been included in last year. Validation team conclusion The CL has been closed. CL104 The fair value of the project assets has not been included as a cash inflow. Please clarify. Table 3 1.o Value of assets have been included already in financial model. The value mentioned in previous CL represents the residual value of the investment calculated by subtracting depreciation from initial investment. The CL has been closed. CL105 Loan interests ( cell E10) has been considered in cash flow before income before tax however loan payback cell (E 25) in cash flow sheet of the Uluabat Financial Model.xls Table 3 1.o As there has been no loan agreement at time of investment decision, and negotiations for additional loans continue, statements about loan have been removed from D and financial analysis. PP Response 02/08/2010 The project investor is one of the largest groups of Turkey and has recently made a JV with a foreign company. Hence, they have financial resources to complete investment with own resources. The use of loan is a business decision and depends on market conditions. For uluabat, so far about 39,870 loan has been used ( Euro and USD). These values have been included in financial model and calculations upon request of Review 1: Although the loan agreement was not signed at the time of investment decision, it is not realistic and conservative to assume that a HEPP investment with such a huge capacity will be realized without any loan. Therefore, please include the loan conditions in the and also please reflect the loan conditions to the calculations. The CL is still open. Review 2: The clarification has been closed. 147

148 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response DOE and included in D v3. Validation team conclusion CL106 Please supply the payback plan for the loan. Table 3 1.o As there has been no loan agreement at time of investment decision, and negotiations for additional loans continue, statements about loan have been removed from D and financial analysis. PP Response 02/08/2010 The project investor is one of the largest groups of Turkey and has recently made a JV with a foreign company. Hence, they have financial resources to complete investment with own resources. The use of loan is a business decision and depends on market conditions. For uluabat, so far about 39,870 loan has been used ( Euro and USD). These values have been included in financial model and calculations upon request of DOE and included in D v3. Review 1: Although the loan agreement was not signed at the time of investment decision, it is not realistic and conservative to assume that a HEPP investment with such a huge capacity will be realized without any loan. Therefore, please include the loan conditions in the and also please reflect the loan conditions to the calculations. The CL is still open. CL107 It has been stated in version 01 that the project IRR has been calculated. Please present the project IRR transparently in the excel sheet. Table 3 1.o Project IRR argumentation has been removed from D. The CL has been closed. CL108 Please present the Investment analysis with carbon credit in a transparent manner in the Calculation sheet. Table 3 1.o The cells in red represents dynamic parameters that can be changed to see the change in IRR for relevant inputs. Impact of carbon revenue can monitored simply by entering the expected price for There is no seperate sheet included in the analysis file. But, clarification about the red cells are. The CL has been closed. 148

149 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response carbon. However, a separate sheet will be included in revised version with input figure for carbon. Validation team conclusion PP Response 02/08/2010 The file dated 18/05/2010 contains three sheets named cash flow benchmark, cash flow without carbon and cash flow with carbon. CL109 Please clarify the assumptions and present the justifications in the D and the excel sheets. Table 3 1.o The assumptions have been given as comment in cells for figures in excel sheet. The CL has been closed. CL 110 In section sub step 2.b. of the section B.5. in version 01; The calculated equity IRR ( without carbon revenue) has been compared with the Eurobond rates or Turkish bond rates currently yielding in excess of 18 and concluded that the project is not financially attractive. Please recalculate the equity IRR based on the CARs and CL in table 3 of this protocol and present the comparison again. Table 3 1.p. Relevant section has been updated according to revised calculations. PP Response 02/08/2010 Irr has been updated considering cars indicated. Since equity IRR should be recalculated after the CLs and CARs indicated in this VCS validation report are closed. So, the CL has not been closed. Review 2: The clarification has been closed. CL111 It has been stated in section B.5 of the version 01 that the with the carbon revenue the equity IRR increases to 8.67% and the project becomes more attractive. Please recalculate equity IRR based on the CARs and CL and Table 3 1.p. Relevant section has been updated according to revised calculations. PP Response 02/08/2010 Irr has been updated considering cars Review 1: Since equity IRR should be recalculated after the CLs and CARs indicated in this VCS validation report are closed. 149

150 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response VCS Validation Report Validation team conclusion present the comparison again. indicated. So, the CL has not been closed. Review 2: The clarification has been closed. CL112 In section sub step 2.b. of the section B.5. in version 01; the project IRR without carbon revenue ( 7.49%) has been compared with project IRR benchmark which is referenced to ref 12. The reference could not be reached and the date of validation. Please supply a scanned copy. Table 3 1.p. Project IRR has discussions have been removed in revised version. PP Response 02/08/2010 Statement about project IRR benchmark is removed. Review 1: Although the project IRR discussions have been taken out in the version 02, project IRR is still referred in the benchmark argument. Please clarify. The CL is still open. Review 2: CL is closed. CL113 Please supply the calculations for the Project IRR with and without carbon revenue in a transparent manner and conclude if the project is financially attractive based on the project IRR calculations. Table 3 1.p. Project IRR has discussions have been removed in revised version. The project IRR discussions have been taken out in the version 02. The CL has been closed. CL114 A sensitivity analysis has been carried in substep 2.d. of the section B.5. of the version 1 Please clearly state how the parameters selected for the sensitivity analysis. Table 3 1.q. Parameters have been selected according to the tool applied. PP Response 02/08/2010 Table heading was corrected. Review 1: Please clarify in the how these parameters are selected in detail. Also in the version 02 Table 6 is titled Sensitivity analysis for Bayramhacili HEPP project please clarify. The CL is still open. Review 2: 150

151 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion Sensitiviy figures presented in the D files are verified from the IRR analysis. The CL has been closed. CL115 The outcome of Step 2 has been defined in substep 2-b of the version 01 as the following: Table 3 1.q. The investment and sensitivity analysis shows that the VER revenues will improve the financial indicators of the project and make the investment more reasonable for investors. Considering that figures above are based on highest guaranteed price rather than average price, optimistic estimations for yearly generation and that those figures do not reflect the risk for investment, role of carbon income is a significant number to enable the project to proceed and favorable investment and funding decision taken. Based on the above information, it is seen that project is not the most attractive option. Therefore project is considered as additional to the baseline scenario. Further clarification was added to section 2b Clarification was added to version 02. The CL has been closed. Please revise the outcome of step 2 s needed according to the CARs and CLs raised in table 3 of this protocol. CL116 In step 3 of the section B.5. of the version Table 3 1.t. Barrier analysis section is removed from D The CL has been closed. 151

152 Draft report clarifications and corrective action requests by validation team 01; limited incentives for renewable energy has been defined as a barrier under investment barrier title. Please clarify the how the named barrier is related with the investment barrier given in Tool for the demonstration and assessment of additionality and presented below Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion..if Similar activities have only been implemented with grants or other noncommercial finance terms. No private capital is available from domestic or international capital markets due to real or perceived risks associated with investment in the country where the proposed CDM project activity is to be implemented, as demonstrated by the credit rating of the country or other country investments reports of reputed origin. CL117 In step 3 of the section B.5 of the version 01; construction barriers have been presented under investment barriers. Please clarify the how the named barrier is related with the investment barrier given in Tool for the demonstration and assessment of additionality and presented below Table 3 1.t. Barrier analysis section is removed from D The CL has been closed...if Similar activities have only been implemented with grants or other noncommercial finance terms. No private capital is available from domestic or international capital markets due to real or perceived risks associated with investment in the country 152

153 Draft report clarifications and corrective action requests by validation team where the proposed CDM project activity is to be implemented, as demonstrated by the credit rating of the country or other country investments reports of reputed origin. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion CL 118 It has been stated in section B.5 of the version 01, that the presented barriers are largely specific to hydroelectric power plans and have minimal impacts on the base scenario of ACM 002, the addition of thermal power plants. Please reassess if the identified barriers ( specific to the proposed project) would not prevent the implementation of at least one of the alternatives according to CLs raised above. CL119 The project activity is generation of electricity by hydroelectric power plant. Accordingly please clarify the assessment of other activities similar to the project activity as the following; Please supply an analysis of hydro electrical power plants that are operational and that are in the same country/region and or rely on a similar technology, are of similar scale, and take place in a comparable environment according to the sub step 4.a of the additionality tool version Please consider that CDM project activities are not to be included in this analysis. Provide documented evidence and, where relevant, quantitative information. On the basis of that analysis, Table 3 1.v. Table 3 1.y. Barrier analysis section is removed from D Information about other HEPPs that are operational or planned have been included in common practice section together with statistics about ownership or trends in share of hydros. PP Response 18/05/2010 The share has been written as 8.5% instead of 85.5% in previous version and has been corrected. The common practice analysis has also been extended. 85.5% is sum of capacity by 2005, plus capacity additions in 2006 and The sum will correspond to 85.5% when also The CL has been closed. Review 1: The information about the hydro electric power generation in Turkey is given in more detail in the version 02. However it is stated under sub-step 4b that, in 2007, 8.5% of the total installed hydroelectric capacity is owned by the government. Please check the calculations and revise this statement. Also the reference given for this statement gives only the data until the year Please revise the reference. The CL is still open. 153

154 Draft report clarifications and corrective action requests by validation team describe whether and to which extent similar activities have already diffused in the relevant region. CL120 Please demonstrate why the existence of these activities ( if any according to the sub step 4.a for Clarification has been requested ) does not contradict the claim that the proposed project activity is financially/economically unattractive or subject to barriers. Ref. to checklist question in table 1 and 2 Table 3 1.z. Summary of project owner response VCS Validation Report Validation team conclusion consider Review 2: Please clarify On the basis of that analysis, describe whether and to which extent similar activities have already diffused in the relevant region. The CL is still open. Review 3: There exist no similar activity in the region built by private sector and without carbon revenue. This explanation has been added to D also. PP Response 18/05/2010 IT is not clear which plants are referred but EK only shows licenses, not the status (whether they are implemented, or investment model(bot, autoproducer etc) By end of 2008, there exist no other operational power plant in the region build by private sector. Common practice In annex 9 of the D version 04, the list of power plants have been given namely that are under oparation at the time of the investment decision date. The data gven has been validated from the EMRA website and through the interibviews with the specialists form the State of Hyraulics Works in Bursa. Review 1: When the website of EMRA has been checked it is seen that there are several other projects that are in the same region which are owned by the private sector. Please clarify why the existence of these projects does not contradict with the claim that the proposed project activity is additional. The CL is still open. 154

155 Draft report clarifications and corrective action requests by validation team CAR 1 version 1 and the monitoring plan, financial model and the EF calculation sheet have been presented in English. Please present the annex 5 and annex 6 ( EIA exemption letter) in English also. Ref. to checklist question in table 1 and 2 Table 1 1.c. Summary of project owner response analysis has been extended to give a list of plants operational and owned by private companies. Translations of documents have been included in annex of D also. Validation team conclusion Review 2: Clarification has been closed. The English translations have been attached to the version 02. The CAR has been closed. CAR 2 In the version 01 of the, it has been stated that the list of most recent capacity additions to the grid and their average and firm generation capacities are available at the TEİAŞ web page The reference to the given statements are reference number 32, 33,34,35. In the BM calculations worksheet, it is seen that the capacity addition data for the years 2006 and 2007 are taken from the TEIAS website which are given as reference 34 and 35 and in the. However the data that is used in the calculations does not give detailed plant based information on the capacity additions. Please revise your calculations and the references given in the using the detailed lists that are given in the annexes of capacity projection reports that are also available on the TEIAS website. Table 1 2.b.i. Data about details of capacity addition are taken from capacity project reports( and respectively) of TEIAS. Reference for 2007 was available in BM calculation (cell:b5) for Also, reference pf report for 2006 data was added to BM calculation sheet cell:b10. References were also included in D. PP Response 1805/2010 The calculation method used is not in contradiction with the tool. Also, values for NCV are calculated and used as weighted average therefore they are also in line with the tool and requested revision. Review 1: In the revised it is stated that the data for the capacity additions have been taken from the capacity projection reports, however in the excel sheet that was submitted to the DOE there is no reference to this data and there is no plant specific information. The CAR is still open. The BM formula is as follows: Obviously, the EF for each year has to be calculated separately whereas 155

156 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion in the computations the formula is used over totals. Please also calculate the BM as a generation weighted average as suggested by the tool. Review 2: Cthe Corrective action request has been accepted. CAR3 In Table 13 of the version 01, NCV Values used for the calculation of the OM have been presented. The reference for the table is given as the National Inventory of Turkey Documented data sources in national energy statistics should be used for computing NCV values according to Tool to calculate the emission factor of an electricity system. Please revise your data sources for heating values of fuels and recalculate the NCV value. Please present the calculation transparently in the. Please revise the references and the table 13 in the. Table 1 2.b.i. The link to NIR has been removed in revised version as it has been left unintentially from previous version. Using NIR figures is in line with the Tool applied. NCV values and calculations is available in the excel file provided to DOE previously. PP Response 1805/2010 The NCV has simply been calculated by dividing heating values of fuels consumed in thermal power plants with the amount of fuels consumed, both taken from TEIAS web site as referred in D. Review 1: The link to NIR has been removed in version 02. It is stated in the that the NCV values have been calculated using data from the TEIAS website. Please explain the calculation of the NCV in more detail. Which data are used for the calculation and how it is calculated. For the calculation of the OM The Simple OM Option C has method been used. This requires application of the following formula: NCV has been calculated using weighted average values, hence requested revision already considered in calculations. For OM, since weighted average is used Obviously, each year s (y) NCV has to be multiplied with the same year s FC and EF. 156

157 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response for NCV values and since EF values are same for each year, calculating each year sepately and averaging them would result in the same value. Validation team conclusion However, in the calculations three year s average NCV and total FC has been used. Although correcting this point will imply minimal change in the results, it should be corrected in order to be fully consistent with the methodology. Similarly, in calculating the average OM emission factor, instead of annual calculations the three-year total values (of emissions and generations) have been employed. Again, impact on the results will be minimal but correction is necessary to comply with the methodology. Also the OM shall be calculated as a generation weighted average. Please correct accordingly. The CAR is still open. Review 2: The corrective aciton request has been closed. CAR4 Under section A.4.4. of the version 1 the amount of emission reductions over the crediting period is estimated as 229,751yearly resulting in a total reduction of 2,229,751 of Table 1 2.d.d. Average electricity generation had been assumed as 373GWh in v1. Figures in feasiblity reflects estimation and as stated in water right utilization agreement, amount of water allocated for electricity The emission reduction units have been reviewd. The CAR has been closed. 157

158 Draft report clarifications and corrective action requests by validation team CO2 for the first crediting period. Annual generation has been defined for three scenarios according to the 2005 dated Feasibility report approved by the State of Hydraulics ( Secenario 1 : ( up to year 2021) when only downstream water demand has been supplied from the dam the total energy production will GWH, Scenario 2 ( up to year 2028 which includes 1st stage of drinking, usage and industrial water supply from the dam ): GWH, Scenario 3 ( after year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH Ref. to checklist question in table 1 and 2 Summary of project owner response generation can be changed by DSI anytime as per the agreement. It has been updated in revised version and emission reduction data has been updated accordingly. Validation team conclusion Please clarify the annual emission reductions according to the above statement. In addition please also clarify the emission reductions according to the changes requested in the EF calculations. CAR5 In section B.5 of the version 1, a description of how the project will achieve GHG emission reductions have been presented as the following According to the applied methodology (ACM0002) baseline scenario for the project has been defined as generation of equal amount of electricity by the power plants Table 1 2.d.d. Electricity generation has been assumed as GWh for the first crediting period and calculations have been revised accordingly. ER figures have also been calculated considering GWh generation and reservoir emission calculated in section B.6.3 of D. CAR 5 has been closed. 158

159 Draft report clarifications and corrective action requests by validation team connected to the grid. Emission factor for the baseline scenario has been calculated according to the combined margin approach as defined by the selected methodology. Within this framework, project is expected to generate about 373 GWh of electricity and reduce about 229,751 tco 2 annually, through replacing the electricity that would need to be supplied via the National grid in the absence of the project activity. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion Annual generation has been defined for three scenarios according to the 2005 dated Feasibility report approved by the State of Hydraulics (Scenario 1 : ( up to year 2021) when only downstream water demand has been supplied from the dam the total energy production will GWH, Scenario 2 ( up to year 2028 which includes 1st stage of drinking, usage and industrial water supply from the dam ): GWH, Scenario 3 ( after year 2028 which includes the whole drinking, usage and industrial water supply from the dam) : GWH Please clarify the annual emission reductions according to the above statement. In addition please also clarify the emission reductions according to the changes requested in the EF calculations. CAR 06 The relevant local laws and related to the project and the alternatives to the proposed project has been listed under substep1 b in Table 1 2.d.j. We have listed main laws relevant to the project. In order to list relevant local regulations, a few months should spent to review all valid regulations which is not Corrective action request has been closed. 159

160 Draft report clarifications and corrective action requests by validation team section B.5 of the version 1. The relevant local regulations related to the project has not been listed in the. CAR 07 Demonstration of compliance to local laws and regulations have not been included in the D. Ref. to checklist question in table 1 and 2 Table 1 2.d.j. Summary of project owner response within the scope of the certification project as the project is already monitored by relevant institutions. To our knowledge there is no source that lists the relevant regulations for similar projects and similarly there exist no project that has reviewed all valid regulations listed in the project document. This issue has been included in necessary detail in D already. Validation team conclusion Corrective action request has been closed. CAR 08 Please supply economic, sectoral, social, environmental, geographic, site-specific information in the. Table 1 2.d.s. All relevant and necessary information have already been included D. Corrective action request has been closed. CAR 09 For the justification of the choice of the methodology and its applicability to the project, it is stated in section B.2. of the ver01 that; Project Power density is higher than 4 W/m 2 Please clarify which applicability criteria is applied to the project ( new reservoir, existing reservoir with no change volume or existing reservoir with a change in the volume). Please justify the applicability criteria selected. Table 1 2.d.x. The issue about power density of the project has been revised upon discussion with DOE and relevant information has been added to D. PP Response 18/05/2010 It has been clearly stated that project results in a new reservoir. Review 1: According to ACM0002 version 10, for hydro power plants, one of the following conditions must apply: The project activity is implemented in an existing reservoir, with no change in the volume of reservoir; or The project activity is implemented in an existing reservoir, where the volume of reservoir is increased and the power density of the project activity, as per definitions given in the Project Emissions section, 160

161 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion is greater than 4 W/m 2 ; or The project activity results in new reservoirs and the power density of the power plant, as per definitions given in the Project Emissions section, is greater than 4 W/m 2. However it is not clearly identified in the whether the project results in a new reservoir or implemented in an existing reservoir. The CAR is still open. Review 2. Corrective action request has been closed. CAR10 Under section B.3 of the version 01, the GHG sources are identified for the project in the tabular format. CO2 emissions have been identified as a major emission source in the tabular format and the methodology is referred for justification. Methane emissions has not been included in the sources and the explanation is given as that the project is zero emission electricity generation. Table 1 2.d.y. Reservoir emissions have been included in revised D. PP Response 18/05/2010 The methane emission has also been included in table Review 1: Under section B.3 of the version 02 in Table 3 CH 4 emissions from the reservoir is still shown to be not included. The reason behind this selection is given as the project activity being a zero emission electricity generation activity. The CAR is still open. Revşew 2 : The table has been reviewd anf the corrective action has been closed. 161

162 Draft report clarifications and corrective action requests by validation team Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion CH4 emissions has been identified as major emission sources for hydroelectric projects according to ACM 002 version 10. Please reassess the emissions sources and the justifications in the section B.3. CAR11 The monitoring procedures should include purpose of monitoring according to clause 5.11 of VCS 2007:1. Please include the purpose of monitoring in the monitoring procedures or the related section of the. Table 1 2.d.ff.i Statement about monitoring is added in section B.7 The purpose of monitoring has been added to section B.7 of the version 02. The CAR has been closed. CAR12 In section B.7. of the version 01 the parameters EGy and FCi,j,y have been presented for monitoring in the tabular format. However, the parameters which are included in ACM 002 version 10 ; namely EG Facility, Cappj, PE ffy, Cappj, Apj are not included in the tabular format. The tabular format shall include data unit, description, source of data to be used, measurement procedures, monitoring frequency, QA/QC procedures. Please include the relevant parameters in the monitoring as required by the methodology. Table 1 2.d.ff.iii Monitored parameters section has been updated and mentioned parameters have been added. The parameters have been added to the monitoring plan. The CAR has been closed. CAR13 According to ACM 002 version 10, All data Table 1 2.d.ff.viii Clarification has been added to section B.7 about archiving. The archiving of the monitoring data is described under section B.7 of the 162

163 Draft report clarifications and corrective action requests by validation team collected as part of monitoring should be archived electronically and be kept at least for 2 years after the end of the last crediting period. Please include the archiving methodology in the. Ref. to checklist question in table 1 and 2 Summary of project owner response Validation team conclusion version 02. The CAR has been closed. CAR14 For the generation efficiency of coal, the value of present thermal power plants has been used from Türkiye Çevre Atlası prepared by Ministry of Environment and Forestry as indicated in section B.6.2. of the ver 01 and the EF calculation.xls. However, the document has been published in 2004 and refers to data from power plants of all vintages in operation. On the other hand, the BM comprises most recently built power plants which are expected to be of higher efficiency. Hence using the default efficiency factor in the TOOL (for new power plants built after 2000), which is slightly higher, would be more appropriate. Table 1 2.d.gg.iii Using local source is inline with the tool and have been used and approved by many DOEs and standard institutions also therefore PP has preferred to use the same source. In addition, considering that most of the power plants mentioned are built before 2000 and inpractice most of them work well under their designed value, the figures applied should already be considered as conservative. The analysis of efficiencies of thermal power plants have been made comparing calorific values of the fuels consumed in Turkey and electrical output for each type of fuel and it has been determined that the generation efficiencies used are more conservative for those calculated for NG and close to the value calculated for coal(inc. Lignite) as shown in table below. Confidential _Thermal Generation Review 1: According to the tool the generation efficiencies of the plants shall be taken from: Documented manufacturer s specifications (if the efficiency of the plant is not significantly increased through retrofits or rehabilitations); or Data from the utility, the dispatch center or official records if it can be deemed reliable; or The default values provided in the table below in annex 1. The data given in the Environmental Map of Turkey corresponds to power plants built before the year 2001 and does not reflect the capacity additions for the years 2004, 2005, 2006 and The power plants that are used in the BM calculations are all built in or after As the efficiency of the power plants will be higher for the newer plants the use of this data can not be 163