Determination Report

Transcription

1 Determination Report Determination of Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden JI Program of Activities in Germany (Track 1) Report No TÜV SÜD Industrie Service GmbH, Carbon Management Service Westendstr Munich GERMANY TÜV SÜD Industrie Service GmbH

2 Report No. Date of first issue Revision No. Date of this revision Certificate No Subject: Executing Operational Unit: Client: Contract approved by: Report Title: Determination of a JPoA TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstr Munich Germany Bayerngas GmbH, Poccistr. 9, München, Germany Javier Castro Determination of the JI-PoA: Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Number of pages 19 (excluding cover page and annexes) Summary: The Certification Body Climate and Energy of TÜV SÜD Industrie Service GmbH has been ordered by Bayerngas GmbH to determine the above mentioned JI Program of Activities (JPoA) in Germany. The determination of this JPoA has been performed by document reviews, interviews by and interviews at the office of the JPoA owner. Furthermore, a JPA for hot water generation has been visited in Laufen, Bavaria. As result of this procedure, it can not yet finally be confirmed that the submitted JPoA documentation is in line with all requirements set by the Marrakech Accords and the Kyoto Protocol. This opinion is caused by the solely remaining outstanding issue regarding the Letter of Approvals of the involved Annex-I-Party, which are Germany and France. Apart of this requirement, TÜV SÜD can recommend this JPoA for acceptance as JI Track 1 PoA according to the German rules. The German D DEHSt communicated already on November 9, 2007 a positive signal of acceptance as JI Track 1 PoA under certain conditions. Additionally the assessment team reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of tons CO 2e (to be issued as ERUs) in the intended first crediting period from (the first Commitment Period of the Kyoto Protocol lasts from ), resulting in annual emission reductions of tons CO 2e, represents a reasonable estimation using the assumptions given by the PoA documents. However, the amount of emission reductions is strongly dependent on the number of project activities JPAs. Work carried out by: Thomas Kleiser (project manager, lead auditor) Robert Mitterwallner (GHG auditor) Internal Quality Control by: Javier Castro TÜV SÜD Industrie Service GmbH

3 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 2 of 19 Abbreviations CAR CDM CPA CR DOE DFP DP EIA / EA ER ERU GHG IRR JI JPoA JPA KP LoA MP MS NGO PDD PoA SC Corrective action request Clean Development Mechanism CDM Project Activity Clarification request Designated Operational Entity Designated Focal Point Determination Protocol Environmental Impact Assessment / Environmental Assessment Emission reduction Emission Reduction Unit Greenhouse gas(es) Internal Rate of Return Joint Implementation JI Program of Activity JI Project Activity Kyoto Protocol Letter of Approval Monitoring Plan Management System Non Governmental Organisation Project Design Document Program of Activity Supervisory Commitee TÜV SÜD Industrie Service GmbH

4 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 3 of 19 Table of Contents Page 1 INTRODUCTION Objective Scope GHG PoA Description 5 2 METHODOLOGY Review of Documents Follow-up Interviews Resolution of Clarification and Corrective Action Requests 9 3 DETERMITION FINDINGS PoA Design Baseline / Additionality Duration of the JPoA Monitoring Plan Calculation of GHG Emissions Environmental Impacts Local stakeholder process 12 4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS DETERMITION OPINION TÜV SÜD Industrie Service GmbH

5 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 4 of 19 1 INTRODUCTION 1.1 Objective The private company Bayerngas GmbH has commissioned TÜV SÜD Industrie Service GmbH to conduct a determination of the Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden JPoA in Germany with regard to the relevant requirements for JI project activities and JPoAs. The determination serves as a conformity test of the PoA design and is a requirement for all JI projects or JPoAs. In particular, the PoA's baseline, the monitoring plan (MP), and the PoA s compliance with relevant UNFCCC and host country criteria are validated in order to confirm that the PoA design as documented is sound and reasonable and meets the stated requirements and identified criteria. Determination is considered necessary to provide assurance to stakeholders of the quality of the PoA and its intended generation of emission reductions (in particular ERUs - in the first commitment period under the Kyoto Protocol). UNFCCC criteria refer to the Kyoto Protocol Article 6 criteria and the Guidelines for the implementation of Article 6 of the Kyoto Protocol as agreed in the Marrakech Accords. 1.2 Scope The determination scope is defined as an independent and objective review of the JPoA s design documents (JPoA-DD, JPA-DD) and other relevant documents. The information in these documents is reviewed against Kyoto Protocol requirements, UNFCCC rules and associated interpretations. The rules for track 1 have to be defined by the DFP (DEHSt). TÜV SÜD has, based on the recommendations in the Validation and Verification Manual (see for further information employed a risk-based approach in the determination, focusing on the identification of significant risks for JPoA implementation and the generation of emission reductions. This report is based on the JPoA-DD version of July 4, 2008 (version 04) and the two JPA-DDs (version 04 of July 4, 2008). Initial versions of these documents were published in the context of the Global Stakeholder Process (GSP) on the website of (link see chapter 4). Potential stakeholders have been invited for commenting. According to CARs and CRs indicated in the audit process the client decided to revise the JPoA-DD and JPA-DD. Furthermore, participation information for the selected real case was submitted to the AIE. The final versions for JPoA-DD and for JPA-DD and real case PDD serves as the basis for the final conclusions presented herewith. Studying the existing PoA documentation, it was obvious that the competence and capability of the validation team has to cover at least the following aspects: Knowledge of Kyoto Protocol and the Marrakech Accords Environmental and Social Impact Assessment Skills in environmental auditing (ISO 14001) Quality Assurance Technologies, processes and operation of energy efficiency TÜV SÜD Industrie Service GmbH

6 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 5 of 19 Fuel switch Baseline concepts Monitoring concepts Political, economical and technical random conditions in host country According to these requirements TÜV SÜD has assembled a project team in accordance with the appointment rules of the TÜV certification body Climate and Energy : Thomas Kleiser is a lead auditor for CDM and JI projects at TÜV SÜD Industrie Service GmbH and head of CDM/JI division within TÜV SÜD. In this position he is responsible for the implementation of validation and certification processes for GHG mitigation projects. He has participated in more than 90 CDM and JI project assessments. Robert Mitterwallner is a GHG-A with a background as auditor for environmental management systems (according to ISO 14001) and expert in environmental permit procedures. He is located at the headquarter of TUV SÜD Industrie Service GmbH in Munich. He has received training in the JI determination as well as CDM validation process and applied successfully as GHG Auditor for several scopes. The audit team covers following requirements: Knowledge of Kyoto Protocol and the Marrakech Accords (All) Environmental and Social Impact Assessment (All) Skills in environmental auditing (ISO 14001) (All) Quality Assurance (All) Technologies, processes and operation of fuel switch and energy efficiency (All) Baseline concepts (All) Monitoring concepts (All) Political, economical and technical random conditions in host country (All) In order to have an internal quality control of the PoA, a team of the following persons has been composed by the certification body climate and energy : Javier Castro Head of the Certification Body Climate and Energy 1.3 GHG PoA Description The core part of the JPoA is to convert the existing boilers of private, commercial and industrial customers running with fuel oil, coal, natural gas or liquid gas to electric powered heat pumps as well as to install the electric powered heat pumps in new buildings. The criteria for participation to the JPoA, listed in chapter A.2 of the JPoA-DD, were verified by the AIE. TÜV SÜD Industrie Service GmbH

7 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 6 of 19 Each JPA participant has to sign the gas supply agreement with Bayerngas GmbH confirming the criteria for participation of PoA. Generally all JPA participants located in Bavaria, State of the Federal Republic of Germany are eligible (JPoA boundary). Based on the implementation of fuel switch or energy efficiency measures, the JPoA leads to a significant reduction of CO 2 emissions in the PoA scenario in comparison to the baseline scenario. The starting date of the JPoA was November 30, The starting date of the crediting period will be January 1, 2008 that can be accepted under the pre-condition that DEHST as Nartional Focal Point does agree with it. The crediting period will end on December 31, 2012 with the end of the first commitment period of the Kyoto protocol. The JPoA has two project participants: Bayerngas GmbH as project applicant and an investor which still needs to be defined. 2 METHODOLOGY In order to ensure transparency, a determination protocol was customised for the PoA, according to the Validation and Verification Manual (VVM). The protocol shows, in a transparent manner, criteria (requirements), means of verification and the results from validating the identified criteria. The determination protocol serves the following purposes: It organises, details and clarifies the requirements a JPoA is expected to meet; It ensures a transparent determination process where TÜV SÜD has documented how a particular requirement has been validated and the result of the determination. The determination protocol consists for this PoA of three tables. The completed determination protocol is enclosed in Annex 1 to this report. TÜV SÜD Industrie Service GmbH

8 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 7 of 19 Determination Protocol Table 1: Mandatory Requirements Requirement Reference Conclusion Cross reference The requirements the PoA must meet. Gives reference to the legislation or agreement where the requirement is found. Determination Protocol Table 2: Requirement checklist This is either acceptable based on evidence provided (OK), or a Corrective Action Request (CAR) of risk or non-compliance with stated requirements. The corrective action requests are numbered and presented to the client in the determination report. O is used in case of an outstanding, currently not solvable issue, AI means Additional Information is required. Used to refer to the relevant checklist questions in Table 2 to show how the specific requirement is validated. This is to ensure a transparent determination process. Checklist Question Reference Means of verification (MoV) The various requirements in Table 1 are linked to checklist questions the PoA should meet. The checklist is organised in six different sections. Each section is then further subdivided. The lowest level constitutes a checklist question. Gives reference to documents where the answer to the checklist question or item is found. Explains how conformance with the checklist question is investigated. Examples of means of verification are document review (DR) or interview (I). N/A means not applicable. Comment The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. Draft and/or Final Conclusion This is either acceptable based on evidence provided (OK), or a Corrective Action Request (CAR) due to non-compliance with the checklist question (See below). Clarification or Additional Information is used when the independent entity has identified a need for further clarification or more information. Determination Protocol Table 3: Resolution of Corrective Action and Clarification Requests Draft report clarifications and corrective action and additional Information requests Ref. to checklist question in table 2 Summary of PoA owner response Determination conclusion If the conclusions from the draft determination are either a Corrective Action Request or a Clarification or Additional Information Request, these should be listed in this section. Reference to the checklist question number in Table 2 where the Corrective Action Request or Clarification or Additional Information Request is explained. The responses given by the Client or other PoA participants during the communications with the independent entity should be summarised in this section. This section should summarise the independent entity s responses and final conclusions. The conclusions should also be included in Table 2, under Final Conclusion. TÜV SÜD Industrie Service GmbH

9 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 8 of Review of Documents The project developer submitted a JPoA-DD, a JPA-DD and real case PDD as well as additional background documents related to the JPoA design and baseline. A review for all these documents has been performed in order to identify all issues for discussion during the follow-up interviews on-site and by phone or Follow-up Interviews On December 20, 2007, and April 22, 2008 the audit team of TÜV SÜD performed interviews in Munich with the coordinating/managing entity and the JPoA developer respective in Laufen with a JPA to resolve issues identified in the document review. The main topics of the interviews are summarised in Table 4. The complete and detailed list of all persons interviewed is enclosed in Appendix 2 to this report. Table 4: Interview topics Interviewed organisation FutureCamp GmbH, München Bayerngas GmbH Interview topics PoA design, baseline, additionality, monitoring plan, environmental impacts, stakeholder comments, monitoring procedures, calibration of the measurement equipment, archiving of data, electricity use, approval of the JPoA, JI- Guidelines, national and regional policy, social issues (stakeholder) PoA design, baseline, monitoring plan, environmental impacts, stakeholder comments, monitoring procedures, calibration of the measurement equipment, archiving of data, electricity use, approval of the JPoA, JI-Guidelines, national and regional policy, social issues (stakeholder) AWO, Laufen JPA design, baseline, additionality, monitoring procedures TÜV SÜD Industrie Service GmbH

10 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 9 of Resolution of Clarification and Corrective Action Requests The objective of this phase of the determination is to resolve the requests for corrective actions and clarification and any other outstanding issues, which need to be clarified in order to achieve a positive conclusion during the assessment process. Clarification Requests raised by TÜV SÜD have been resolved in all parts in the answers to the draft determination protocol, prepared by the JPoA developer FutureCamp GmbH and Bayerngas GmbH from January to July A revised final JPoA-DD, dated July 4, 2008 and a number of additional documents have been submitted to the EIA in order to provide the required evidences. To guarantee the transparency of the determination process, the concerns raised and the response given are summarised in chapter 3 below. The whole process is documented in more detail in the final determination protocol in Annex 1. The determination 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 JPoA design. 3 DETERMITION FINDINGS In the following sections the findings of the final determination are stated. The determination findings for each determination subject are presented as follows: 1) The findings from the desk review of the PoA design document and the findings from interviews during the follow up interview are summarised. A more detailed record of these findings can be found in the Determination Protocol in Annex 1. 2) Where TÜV SÜD has identified issues that needed clarification or that represented a risk to the fulfilment of the PoA objectives, a Clarification or Corrective Action Request, respectively, has been issued. The Clarification and Corrective Action Requests are stated, where applicable, in the following sections and are further documented in the Determination Protocol in Annex 1. In total 13 Corrective Action Requests, 34 clarification requests and 7 open issues have been raised. 3) Where Clarification and Corrective Action Requests have been issued, the response by the JPoA developer to resolve these requests are summarized in the final determination protocol. 4) The final conclusions of the determination are presented consecutively. 3.1 PoA Design General Findings The JPoA-DD as well as the JPA-DD correctly adopts the current valid format for PoAs and CPAs according to the CDM. The JPoA design fulfils all current requirements for PoAs. The foreseen technology does reflect current good practice for fuel switch and energy efficiency measures for steam or hot water boilers. The JPoA will use technology that can be considered as advanced technology in the host country for this kind of small or medium sized boilers. Moreover it is unlikely that the foreseen PoA technology will be substituted during the crediting period by a more efficient technology. Germany is a Party to the Kyoto Protocol and already has installed national procedures for the approval of JPoAs. One of the requirements for the approval of a JPoA is a positive TÜV SÜD Industrie Service GmbH

11 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 10 of 19 determination opinion in this determination report. The German DEHSt has issued a Letter of Support on November 9, As this a track 1 determination there is no need to issue a Letter of Approval (LoA) for this JPoA. However, for the transfer of ERUs the participating country Germany and another country of the investor that still needs to be defined have to provide a LoA. The JPoA description is clear, transparent, re-traceable and fulfils all the requirements for a well-developed JPoA. The JPoA starting date that is clearly defined in the JPoA-DD. The indicated starting date of the crediting period of January 1, 2008 can be accepted under the pre-condition that DEHST as Nartional Focal Point accepts it Issued CARs/CRs See Annex 1, table 1 and 2, CR 1 to CR 12 and CAR Conclusion All given responses to the indicated CARs and CRs are resolving the relevant issues. 3.2 Baseline / Additionality Findings Approved CDM methodologies are not available for this JPoA. Therefore, the baseline methodology for this JPoA is developed by using a PoA specific approach that uses partly criteria of the CDM small scale methodologies AMS.II.E, AMS.II.D and AMS.III.B. Possible baseline alternatives have been plausibly and re-traceably elaborated and transparently discussed. The final baseline scenario is the status quo alternative. It is assumed, that the JPoA participants do not switch their existing heating system to natural gas or to refurbish it by energy efficiency measures. Therefore the baseline scenario assumes that the relevant old heating systems would be operating at least as long as they are allowed to take part in the climate bonus project (Business As Usual). The necessary data to calculate the baseline are available. All assumptions for the baseline calculation are proven, defined and sourced correctly. The additionality of the PoA is proven by using step 3 of the Additionality Tool, here investment barriers analysis, and step 4 which is the common practice analysis. It has been concluded in the JPoA-DD that according to the 2005 KFW survey on disabling and enabling factors in corporate energy efficiency the replacement of small and medium boilers without legal requirements is not common practice. The evidence has been checked by the AIE and the conclusion can be confirmed. With regard to German legislation (EnEV), participation in this project is restricted to fuel oil and liquid gas heating systems and commissioned after 1978, meanwhile coal fired heatings and fuel oil and liquid gas heatings with an installed power of more than 400 kw are not restricted since fuel switch or energy efficiency measures are not legally required. This participation restriction has been checked by AIE and can be confirmed by AIE. Furthermore, there is a need to demonstrate additionality on programme level as well as participant level and to ensure that the remaining lifetime of existing installations does not end before the end of the crediting period. Stipulated but not required by EnEV, the lifetime has been limited by the PP for fuel oil and liquid gas heatings with an installed power of less than 400 kw to 30 years. This is following conservative approach. If the end of the expected lifetime will be within the crediting period, ERUs can only be generated until the end of the lifetime. This TÜV SÜD Industrie Service GmbH

12 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 11 of 19 time limitation is implemented in the monitoring plan in Annex 3 of the JPoA and will be ensured by a monitoring software Issued CARs/CRs See Annex 1, table 1 and 2, CR 13 to CR 20 and CAR 2 to CAR Conclusion Finally, the additionality of the programme and each selected participant has been demonstrated in a transparent manner. The issue with the remaining lifetime of existing installation is sufficiently covered by the participation declaration that has to be signed by each programme participant and the monitoring plan. The JPoA fulfils the criteria on baselines and additionality as set for the approval of JI-PoAs. 3.3 Duration of the JPoA The JPoA starting date in November 2007 is defined as date of starting gathering potential JPA participants. The crediting period is demonstrated as the five years from January 1, 2008 to December 31, The starting date of the crediting period can be accepted under the pre-condition that DEHST as Nartional Focal Point accepts it Findings None Issued CARs/CRs See Annex 1, table 1 and 2, see CAR Conclusions Since evidence was available for the AIE that DEHSt accepts to start the crediting period before the approval of the JPoA, the JPoA fulfils the criteria of the Kyoto Protocol. 3.4 Monitoring Plan Findings The JPoA uses a project-specific approach for the monitoring. As far as possible guidance from approved CDM methodologies is used for the monitoring concept. The monitoring methodology reflects current good practice and is supported by the monitored and recorded data. The monitoring provisions are in line with the JPoA boundaries. Indicators for JPoA emissions and baseline emissions have been defined and will be monitored. According to the Letter of Support of DEHSt, for most of these parameters data given in the supplementary agreement to the gas supply contract will be annually verified and a sample of at least 10 % will be taken for comparison with Excel data. Leakage emissions are not monitored according to the monitoring plan as there are no emissions to be expected. The registration, monitoring, measurement and reporting will be under the responsibility of Bayerngas GmbH. It is considered necessary that, once the JPoA is implemented, standard operating procedures need to be defined in line with the specific technical outline of the PoA. TÜV SÜD Industrie Service GmbH

13 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 12 of Issued CARs/CRs See Annex 1, table 1 and 2, see CR 21 to CR 28 and CAR 6 to CAR Conclusion The monitoring plan fulfils all requirements for such type of JPoA. The discussed issues can be considered to be resolved. 3.5 Calculation of GHG Emissions Findings The JPoAs spatial boundaries are correctly described. All necessary parameters to monitor JPoA emissions have been defined. The most relevant and likely operational characteristics and indicators to calculate JPoA emissions and baseline emissions have been chosen. Thus, the JPoA will result in fewer GHG emissions than the baseline scenario Issued CARs/CRs See Annex 1, table 1 and 2, see CR 29 and CR 30 as well as CAR Conclusion The GHG calculations are documented in a complete and transparent manner. Conservative assumptions have been used when calculating baseline emissions. The JPoA thus does fulfil all the relevant requirements for JPoAs. 3.6 Environmental Impacts Findings The analysis of the environmental impacts is sufficient. Relevant environmental impacts are listed sufficiently in the JPoA-DD. It is considered reasonable that the JPoA will improve the current environmental situation. Trans-boundary impacts are not expected. No EIA is requested Issued CARs/CRs none Conclusion The JPoA fulfils all prescribed requirements completely. The open issue has been clarified sufficiently. 3.7 Local stakeholder process Findings There are no PoA-specific requirements how to conduct a Local Stakeholder Process for this JPoA. The JPoA developer has demonstrated to have consulted mainly with interested JPAs, NGOs, equipment manufactures, financial service providers, business and consumer organisations, installation engineers and academics. It is indicated by the JPoA developer that mostly positive comments have been received. Local newspaper has been used for publishing and / or systematic stakeholder identifications. TÜV SÜD Industrie Service GmbH

14 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 13 of Issued CARs/CRs See Annex 1, table 1 and 2, see CR 31 and CR Conclusion The contacting meets the basic requirements of stakeholder consultation under the Kyoto Protocol and the Marrakech Accords. TÜV SÜD Industrie Service GmbH

15 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 14 of 19 4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS TÜV SÜD published the PoA design documents on its website for 30 days from April 1, 2008 to April 30, Documents have been public available for commenting under the following link &mode=5 Received Comments: No comments have been received. TÜV SÜD Industrie Service GmbH

16 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Page 15 of 19 5 DETERMITION OPINION TÜV SÜD has performed a determination of the Bayerngas Ökobonusprogramm Gewerbeund Industriekunden JPoA in Germany on the basis of all currently valid and relevant JI criteria of the host country. The review of the JPoA design documentation and the subsequent follow-up interviews have provided TÜV SÜD with sufficient evidence to determine the fulfilment of stated criteria. It has been verified that the requirements of the Letter of Support of German DNF (DEHSt) have been considered in the JPoA documentation. Additionally the assessment team reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of tons CO 2e (to be issued as ERUs) in the intended first crediting period from (the first Commitment Period of the Kyoto Protocol lasts from ), resulting in annual emission reductions of tons CO 2e, represents a reasonable estimation using the assumptions given by the JPoA documents. The determination is based on the information made available to us and the engagement conditions detailed in this report. The determination has been performed using a risk-based approach as described above. The only purpose of the report is its use during the registration process as JPoA. Hence, TÜV SÜD can not be held liable by any party for decisions made or not made based on the determination opinion, which will go beyond that purpose. Munich, Munich, Javier Castro Head of Certification Body Climate and Energy Thomas Kleiser Assessment Team Leader TÜV SÜD Industrie Service GmbH

17 Determination Report: JPoA Bayerngas Ökobonusprogramm Gewerbe- und Industriekunden Annex 1 of 2 Determination Protocol TÜV SÜD Industrie Service GmbH

18 Page / Number of Pages: 1 / 57 CHECKLIST TOPIC / QUESTION Ref. COMMENTS A. General description of the programme of activities (JPoA) A.1. A.1.1. Title of the JPoA: Does the used project title clearly enable to identify the unique JI programme? 1 The indicated programme title: enables to identify clearly the unique JI programme of activity. PDD in GSP Final PDD A.1.2. Are there an indication of a revision number and the date of the revision? 1 Yes, the version and date are clearly indicated in the JPoA-PDD. The version serving as basis for the Initial PDD review and the first on-site audit was Version 01, A second on-site audit with real cases will be scheduled immediately after receipt of the real cases for the hot water; steam boiler and heat pump JPAs which are part of the project. Real cases are currently still under preparation. A.1.3. Is this in consistency with the time line of the project s history? 1, 2, 3 A first project document for an Ökobonusprogramm with the objective of fuel switch from fuel oil to natural gas and energy efficiency for small sized heating installations has been issued on 8 th of September This PDD only served as description for a potential VER- or JI-project and was basis for the negotiations with the project partners. The current project integrates to some point includes the concept of this draft PDD but there are also some major changes. New in the recent JPoA-DD is the implementation of heat pumps in the programme, the replacement of the combustibles coal and liquid as well as the focus only on commercial and industrial application of heat installations. Furthermore the project now uses the PoA (Programme of Activities Approach) from CDM). This approach was agreed on Cop13 in 2006 and was not known when developing the first project idea in there was also a decision by the project proponents to go for JI 1 instead of JI track 2 or VER-standards. The main reason to go for JI track 1 is that PoA still is not finally approved for JI track 2. Page A-1

19 Page / Number of Pages: 2 / 57 CHECKLIST TOPIC / QUESTION Ref. COMMENTS PDD in GSP Final PDD A.2. Description of the (JPoA): A.2.1. Is the description of the policy or stated goal delivering a transparent overview of the programme of activities? 1, 2, 3 The design of the JPoA-DD is not consistent with the design of the published CDM-PoA-DD, version 01. However, all subjects of the CDM-PoA-DD are covered by the available JPoA-DD thus the applied approach can be accepted by the determinator. The programme measures that shall result in a reduction of GHG emissions are as following: higher efficiency and therefore a lower fuel consumption by using modern condensation or low-temperature boilers for hot water and steam generation; Lower CO 2 emissions due to higher hydrogen quantity and lower carbon quantity of the fuel related to the heating value (fuel switch to natural gas) Substituting fossil fuels by using the solar energy stored in ground, air and water by means of gas-powered heat pumps leads to reduction of GHG emissions and/or to its complete avoidance in the case of new installations. Clarification Request No. 1: There is a need to give evidence and a clear verbal statement in the JPoA-PDD that the incentive programme quoted in chapter A.2 of the JPoA-DD is exclusively valid for private costumer and not for commercial or industrial costumer. CR 1 A.2.2. Is it confirmed that the proposed JPoA is a voluntary action by the coordination/managing entity? 1, 2, 3 Yes, it is clearly stated in the JPoA-DD that the participation of each JPA is voluntary. A.2.3. Are the criteria for participation of the dif- 1, 2, A list of criteria for participation is indicated in the JPoA-DD. Page A-2

20 Page / Number of Pages: 3 / 57 CHECKLIST TOPIC / QUESTION Ref. COMMENTS ferent JI programme activities (JPA) clearly defined? 3 The minimum installed capacity is 50 KW. This list is supposed to be part of the gas supply agreement with the JPA (see Annex 4 of the JPoA-DD). Corrective Action Request No. 1: The participation of installations that need an approval related to the German Regulation 4.BImSchV (similar to IPPC permit) should be defined in more detail considering: - the demonstration that the new technology is beyond state-of-the-art which is defined in the German technical instruction TA Luft - the influence of the JPA onto the permit procedure (all mayor modifications of installations as fuel switch need a new permit) and a clear statement who is responsible to ensure that all permits/licenses are available for installations being included in the project and how a smooth licensing process can be ensured I parallel to the process to include new installations in the project - a statement whether installations with need of public participation (so-called Spalte 1 in the Annex of 4.BimSchV) are generally included and how the results of the public hearing are implemented in the local stakeholder process of the JPoA. Clarification Request No. 2: How can it be ensured that the expected lifetime of a JPA boiler is not exceeded before the end of the crediting period, please clarify! Clarification Request No. 3: The agreement in Annex 4 shall be consistent with the list of criteria in the JPoA-DD, e.g. the criteria of EnEV are missing and the minimum capacity can be indicated more clearly, please clarify. PDD in GSP CAR 1 CR 2 CR 3 Page A-3 Final PDD

21 Page / Number of Pages: 4 / 57 CHECKLIST TOPIC / QUESTION Ref. COMMENTS PDD in GSP Final PDD A.2.4. Is a design document according to No. 5b) of Annex 39 (see B.1.1) or a comparable documentation for the JPA with generic information relevant to all JPAs available and is this documentation linked with the PDD of the JPoA? 1, 4, 5 JPA documentation separately for heat pump, hot water boilers and steam boilers are available. Fuel switch to natural gas and energy efficiency measures are covered by each of these documents. Clarification Request No. 4: The explanation on page 3 of the PDD concerning CPA and JPA is a little bit confusing and should be worked without mixing explanations from CDM and JI. CR 4 A.2.5. Is a design document according to No. 5c) of Annex 39 (see B.1.1) or a comparable documentation for the which is to be based on the application of the JPoA to one real case available and is this documentation linked with the PDD of the JPoA and the document mentioned in A.2.4? 1, 4, 5 Clarification Request No. 5: The documentation for a real case is still missing. After receipt of real cases- one for each measure under the JPoA an additional on-site visit (interviews of real case participants) will be conducted and open issues which mightappear in the context of JPAs can be discussed. CR 5 A.2.6. Is all information provided in consistency with details provided by further chapters of the PDD? 1, 4, 5 In principle, yes. But the PDD gives no information concerning the funding for the private project participants under this JPoA. As this san important point in discussing the Additionality of the project this information has to be provided to the determinator, Clarification Request No. 6: Please submit details of the funding (benefits for participants in the programme for each included group of measures) to the determinator. CR 6 A.3. Project participants: A.3.1. Is the form required for the indication of 1, 4, Yes, Page A-4

22 Page / Number of Pages: 5 / 57 CHECKLIST TOPIC / QUESTION Ref. COMMENTS project participants correctly applied? 5 Bayerngas GmbH as coordinating/managing entity will be the official project applicant and the responsible body for all administrative affairs of the involved parties. Whereas, the JPoA participants are regional energy suppliers and municipal utilities who are supplied preliminarily by Bayerngas GmbH and their individual household customers. PDD in GSP Final PDD A.3.2. Is the participation of all listed entities or Parties confirmed by each of them? 1, 2, 3 No. Clarification Request No. 7: Signed contracts between the regional energy suppliers and municipal utilities and Bayerngas on the other hand are not yet available. There is a need to submit exemplary contracts for at least one energy supplier and one municipal utility and to submit exemplarily for he different measures covered by the project. CR 7 A.3.3. Is all information provided in consistency with details provided by further chapters of the PDD (in particular annex 1)? 1, 4, 5 Clarification Request No. 8 Regarding the participation of the DFP of Germany and the purchasing country the table of project participants in chapter A.3 is not consistent with the information given in Annex 1, please clarify with German DFP (DEHST) whether it is possible to let the name of the second project participant open. This is an important question as the project needs not only the German letter of Approval but also the French letter of approval. CR 8 Page A-5

23 Page / Number of Pages: 6 / 57 A.4. A.4.1. Technical description of the JPoA: Location of the project activity: Page A-6

24 Page / Number of Pages: 7 / 57 A A A.4.2. Does the information provided on the location of the project activity allow for a clear identification of the site(s)? How is it ensured, that the project proponents can implement the project at this site (ownership, licenses, contracts etc.)? 1, 2, 3 1, 2, 3, 8, 9, 10, 16, 20 No, according to the PDD the programme is limited to the area of the gas distribution grid of Bayerngas GmbH mainly in Southern Bavaria. But in principle as discussed during the on-site visit and considering the inclusion of distribution of gas to/via further regional gas providers and distributors - the location of the project activity can be extended to the whole area of Federal republic of Germany. This aspect must be elaborated much more detailed. Clarification Request No. 9 The question of project location/area should be discussed and explained more transparently and re-traceably. The maximum potential area/number of regions should be described as project location in the PDD. Furthermore a list of all distributors/regional gas providers which are considered to participate in the project should be included in the PDD. In case this is not possible at the moment it should be highlighted that the project owner then will install an opening clause for further companies which can join the programme. It is also important that a procedure will be established to exclude a participation of households in different but comparable programs as this could lead to double funding for the same activity. A Framework Agreement of Bayerngas with network partners is available. Additional agreements and information are available for AIE, e.g. with Erdgas Südbayern. Clarification Request No. 10 The question of ownership, licenses, permits and contracts has to be worked out more detailed in the PDD. The following issues should be explained: How does the payment work, who keeps the rights, over which time period, what happens in case the participants changes the gas provider; how is it ensured that all licenses and permits are available at the date of project start for the individual participant under the programme etc.. Technology(ies) to be employed, or measures, operations or actions to be implemented by the project activity: CR 9 CR 10 Page A-7

25 Page / Number of Pages: 8 / 57 A To which category(ies) is the progamme of activity belonging to? Is it correctly identified and indicated? 1 The category of the programme as indicated in the JpoA-DD is Energy demand (Scope Number 3) and Manufacturing industries (Scope Number 4). A A Does the design engineering of the JPoA reflect current good practices? Does the description of the technologies to be applied provide sufficient and transparent input to evaluate its impact on the greenhouse gas balance? 1 Yes, the design of the JPoA PDD as well as the quality and retraceability of information given in the PDD reflects current good practice. But see CAR 1 of A.2.3 above additional information should be provided that the new technology applied in the project must be beyond state-of-the-art which is defined in the German technical instruction TA Luft. The innovative character of the project and the intention to accelerate the market penetration of new and not widespread technologies should be highlighted. 1 Currently this aspect is not worked out finally and detailed enough see CAR 1 under A.2.3. CAR 1 CAR 1 A A Is the technology implemented by the project activity environmentally safe? Does the JPoA use state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in the host country? 1, 2, 3 1, 2, 3 Yes but additional information should be provided especially for the installation of heat pumps (types, fluids used for the system). See also CAR 1 of A.2.3. Yes, the project will use a technology beyond state-of-the-art which is defined in the German technical instruction TA Luft. This should be highlighted see CAR 1 1 under A.2.3. CAR 1 A Is the programme likely to be substituted by other or more efficient technologies within the project period? 1 No. It can excluded by technological as well as financial reasons that the programme will be substituted by other or more efficient technologies within the 5 year crediting period furthermore contractual regulations (ex-post payment) help to bind the project to this programme. CAR 1 A.4.3. Brief explanation of how the anthropogenic emissions of greenhouse gases by sources are to be reduced by the proposed JPoA, including why the emission reductions would not occur in the absence of the proposed JPoA, taking into account national and/or sectoral policies and circumstances: Page A-8

26 Page / Number of Pages: 9 / 57 A A A A Is it clearly demonstrated that in the absence of the JI project the proposed voluntary measures would not be impelemented? Is the form required for the indication of projected emission reductions correctly applied? Are the figures provided consistent with other data presented by the PDD? Is all information provided consistent with the details given in remaining chapters of the PDD (in particular annex 2)? 1, 2, 3 Yes, the experiences and market analysis from previous years show that there are no sufficient and effective financial (or other) incentives to lead to a widespread implementation of the voluntary measures included in the project (pre-term modernization of still operational, not outdated steam boilers; installation of more efficient heating boilers; installation of gas powered heat pumps). For the sector installation of new (gas-powered) heat pumps additional and more recent information (years 2005 up to mid of 2007) should be provided by the project developer whether there was a significant increase of number of installed heat pumps in the household sector. 1 Yes, the form is correctly applied. The PDD in A.4 shows a prognosis of emission reductions in each individual year as well as the annual average emission reductions over all 5 years of the first commitment period. 1, 2, 3 Yes, the information in the table is identical with the information in table in chapter E.6.. But in the table in E.6 the annual average is missing please include this information there, too. Corrective Action Request No. 2: Please include the information about the annual average of estimated emission reductions in the table in chapter E.6, too. And it is advisable to give all tables, figures. Drawings always a name and number. 1 Yes. Clarification Request No.11: Please explain in annex 2 in a footnote in which way old oil-boilers older than 1978 can become part of the project. Please give evidence for the value 1.4 for annual utilization ratio of Gas powered heat pumps as well as the calculated values how were the calculations done in general in this table? CAR 2 CR 12 A.5. Project approval by the Parties involved: A.5.1 Is the project approved by the parties involved? 1, 2, The project is designed as bi-lateral JI Track project. The Freench project participant current is not indicated it should be clarifed CAR 12 Page A-9

27 Page / Number of Pages: 10 / 57 3, 7 whether German DEHST can accept this and issue a LoA without knowing exactly the French counterpart. For Germany: A written announcement of support for this project from the DEHSt by is available. It is not likely that an LoA will be issued before the determination of the project by an AIE. The final signed Determiantion Report of the determinator will serve as one basis for DEHST s decision about the German LoA. Clarification Request No.12: It should be clarified with German DEHST whether it is necessary in the process of issuing the German LoA to know the French counterpart. For the later transfer of ERUs LoAs from both involved parties need to be available. A.6. Public funding: A.6.1 Is information about public funding of the programme available? 1, 11 Yes, as outlined in chapter B.2 step 3 public subsidies are available in the form of low-interest loans as part of the KfW s CO2 Building Refurbishment programme, as part of the KfW s Housing Modernisation or Ecological Building programmes. They are mainly intended to subsidise the building works and therefore have no negative effect on public subsidies for new heating installations and heat pumps. This was discussed and can be confirmed after the on-site visit. B. Baseline B.1. Description and justification of the baseline chosen B.1.1. Are reference number, version number, and title of the baseline and monitoring methodology clearly indicated? 1 Corrective Action Request No. 2: Number and version of the applied methodologies shall be indicated in the JPoA-DD. CAR 2 Page A-10

28 Page / Number of Pages: 11 / 57 B.1.2. B.1.3. B.1.4. B.1.5. Is the applied version the most recent one or still applicable? Is the methodology for JPAs sufficiently described? Is the applied methodology considered being the most appropriate one? Are typical JPAs described, covering the technology or measure to be used, justification of the choice of an approved baseline and monitoring methodology and application of an approved baseline and monitoring methodology? 1 See above and CAR 3 below. CAR 2 1 See above and CAR 3 below. CAR 2 1, 2, 3 1, 2, 3, 4, 5 The CDM methodologies AMS II.D as well as II.E are applied here. According to the letter of support of the German DFP the methodology II.D is recommended. Clarification Request No. 13: The methodology II.E is applicable also for residential buildings which are excluded in this programme, please clarify. Corrective Action Request No. 3: According to the discussion during the on-site visit and during the intensive assessment of the application of the two listed methodologies in the PDD it became obvious that these methodologies only serve as auxiliary means and as guidance in this project. In reality the project developer used his own project specific approach. This does not become clear from the PDD and has to be corrected. Furthermore it should be highlighted that where and how - the approach is conservative and how the recommendations of DEHST related to methodological issues are considered in the current (and finally revised) PDD. In principle, yes, but for a final assessment of this question a realcase has to be presented to the determinator. Clarification Request No. 14: Please include real cases for all measures part of this project and demonstrate via these real cases that the JPA covers the technology/measures to be used und er the program and that the choosen methodological approach fro baseline and monitoring is justified, reasonable, applicable and practicable. CR 13 CAR 3 CR 14 Page A-11

29 Page / Number of Pages: 12 / 57 B.2. Description of how the anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the JPoA B.2.1. Is a description of the baseline scenario, (b) a description of the JPoA scenario, and (c) an analysis showing why the emissions in the baseline scenario would likely exceed the emissions in the JPoA scenario. 1, 2, 3, 4, 5 The Additionality Tool of the CDM Executive Board, Vers. 3, EB 29 is applied here for the demonstration of additionality. The status quo alternative is the baseline of the JI programme. Clarification Request No. 15: Methodology II.D requires the following baseline condition: The point in time when the existing equipment would need to be replaced in the absence of the project activity should be chosen in a conservative manner, i.e. if a range is identified, the earliest date should be chosen. Please clarify how this requirement is covered by the JPoA-DD. See also CAR 3 and consider the adjustments requested there under this point, too. CR 15 B.2.2. B.2.3. B.2.4. B.2.5. Have all technically feasible baseline scenario alternatives (at least all scenarios listed under step 1a in the additionality tool) to the JPoA been identified and discussed by the PDD? Does the JPoA identify correctly and excludes those options not in line with regulatory or legal requirements? Have applicable regulatory or legal requirements been identified? In case of applying step 2 of the additionality tool: Is the analysis method appropriately identified (step 2a)? 1, 2, 3 Yes. The feasible and realistic baseline scenario alternatives are identified and discussed. 1 Yes. 1, 2, 3 Yes. Not Applicable Page A-12

30 Page / Number of Pages: 13 / 57 B.2.6. In case of applying step 3 (barrier analysis): Is a complete list of barriers developed that prevent alternatives to occur? 1, 2, 3 Clarification Request No. 16: The barriers discussed are not complete. The barriers due to prevailing practice (see additionality tool) have not been discussed yet in the PDD, please clarify and include this especially also with a special focus here on the heat pumps. CR 16 B.2.7. In case of applying step 3 (barrier analysis): Is transparent and documented evidence provided on the existence and significance of these barriers? 1, 2, 3 See CR 16 of B.2.6 above. CR 16 B.2.8. In case of applying step 3 (barrier analysis): Is it transparently shown that at least one of the alternatives is not prevented by the identified barriers? 1, 2, 3, 11 Yes. Clarification Request No. 17: But at the end of this step 3 the fact that at least one of the alternatives is not prevented by the identified barriers - shall be highlighted verbally after including also the discussion of barriers due to prevailing practice. CR 17 B.2.9. Have other activities in the host country / region similar to the project activity been identified and are these activities appropriately analyzed by the PDD (step 4a)? 1, 2, 3 Yes. Clarification Request No. 18: It shall be discussed in short and clarified how it is ensured that project participants cannot participate or switch to other current running or envisaged comparable JI track 1 programmes from the perspective of the project owner. And it should has to be highlighted that currently no comparable programme is set up without including JI revenues thus it is not to be realistic and to be expected that - under the current frame conditions of incentives a comparable programme could run outside of the JI regime. CR 18 Page A-13

31 Page / Number of Pages: 14 / 57 B If similar activities are occurring: Is it demonstrated that in spite these similarities the project activity would not be implemented without the JI (step 4b)? 1, 2, 3 See CR 18 of B.2.9 above. Corrective Action Request No. 4: Prior to the on-site visit no information was available about any funding from project owner s side of the project measure Implementation of gas-powered heat pumps. During the on-site audit it appeared that there is fixed subvention of such gas-powered heat pumps envisaged. This currently planned subvention lies in a level of 40-times up to 100-times the pre-calculated (by the determinator and project developer) potential revenues from selling the emission reductions achieved by the implementation of gas powered heat pumps in this project. This proportion between fixed subvention and potential JI revenues leads to important doubts whether for the part gas-powered heat pumps the aspect JI has any relevancy at all for participants and thus whether this part still can be considered as additional. This has to be clarified on project owner s side as well as together with German DEHST. The main question is whether a subvention given under a combined programme which is overall additional can be accepted also per se - as additional for parts/measures of the programme although these single are not considered as additional in the understanding of the Kyoto-protocol. One reason could be the argument that these incentives are not paid without participating in this programme. Final decision/guidance on this issue can come from German DEHST as approval authority for JI Track 1 projects. CAR 4 B.3. Description of how the definition of the project boundary is applied to the JPoA: B.3.1. Do the spatial and technological boundaries as verified on-site comply with the discussion provided by the PDD? 1, 4, 5 Clarification Request No. 19: The graphic with the boundary of a JPA covers only steam generation and not hot water generation, please clarify and complete CR 19 Description of the sources and gases included in the project boundary (Fill in the required amount of sub checklists for sources and gases as given by the methodology applied and comment at least every line answered with No ) Page A-14

32 Page / Number of Pages: 15 / 57 B.3.2. Source: emissions from. 1, 4, 5 Clarification Request No. 20: A list with sources and considered gases inside and outside of the project boundaries should be included in the PDD. CR 20 B.4. Further baseline information, including the date of baseline setting and the name(s) of the person(s)/entity(ies) setting the baseline Emissions reductions B.4.1. B.4.2. B.4.3. B.4.4. Is there any indication of a date when determining the baseline? Is this in consistency with the time line of the PDD history? Is information of the person(s) / entity(ies) responsible for the application of the baseline methodology provided in consistency with the actual situation? Is information provided whether this person / entity is also a project participant? 1 Yes. The necessary information is given in chapter B.4 and should be updated during the determination process. 1 Yes. 1 Yes, the baseline was developed by Mrs. Gruss from German project developing company Future-Camp. She also presented and discussed together with the determinator the baseline concept and will be responsible for updates, changes and adjustment during the determination process according to the information received in the on-site audit. 1 Yes. Page A-15

33 Page / Number of Pages: 16 / 57 C. Duration of the JPoA / crediting period C.1. Are the project s starting date and operational lifetime clearly defined and reasonable? 1, 2, is the starting date of the programme. C.2. Is the assumed crediting time clearly defined and reasonable (crediting period between 2008 and 2012)? 1, 7 Yes, the crediting period is defined as from January 1 th, 2008 to December 31 th, Corrective Action Request No. 5: CAR 5 The indicated start of the crediting period is not realistic. It should be defined to February 1 th, 2008 or the approval date of the DFP of the host and the buyer country. Alternatively we advise to speak and discuss with German DEHST as national approval authority whether they also accept as it is currently custom under JI track 1 due to reasons of delays in receipt of LoAs emission reductions from the period after implementation until receipt of the LoA. D. Monitoring plan D.1. Description of monitoring plan chosen: Is the applied methodology considered being the most appropriate one? D , 2, 4, 5 Clarification Request No. 21: The methodology II.D contains monitoring requirements. There is a need to clarify the statement in chapter D.1 of the JPoA-DD that monitoring methodology does not exist for this type of JI project. See also discussion on methodological issues under other CRs above. Monitoring of the emissions in the project scenario and the baseline scenario: CR 21 Page A-16

34 Page / Number of Pages: 17 / 57 In the following data checklists are shown for all data which are fixed at determination time, and monitoring checklists for all data which have to be monitored during the life-time of the project. D Data to be collected in order to monitor emissions from the project and how these data will be archived Is the list of parameters presented by chapter 1, See also. D considered to be complete with regard to 4, Clarification Request No. 22: the requirements of the applied methodology? 5, This table cannot be fully answered at this stage as we need to 14 compare this with information of the real cases. Please submit. As far as possible the table is filled-in. Please ensure that all points to be checked by us are included in your list. too. Corrective Action Request No. 6: The parameter installation and commissioning date of the boiler is missing in the list in the PDD and has to be included. Year of boiler construction is not concrete enough. CR 22 CAR 6 Annotation: below means Not applicable or Currently no information available the tables have to be updated after the onsite visit in the real-cases which still need to be submitted. ID 1: Name of the participant 1, 4, 5, 14 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No /. Yes. Yes. The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. Page A-17

35 Page / Number of Pages: 18 / 57 ID 2: Measure / Technology type of the new installation 1, 4, 5, 14 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No. Yes. Yes. The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. ID 3: Emission factor EF CO2 1, 4, 5, 14 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No Yes. Yes. Yes. Yes. Yes Yes Yes Yes The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. ID 4: Fuel consumption 1, 4, 5, 14 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Yes / No / No. Yes. Yes. CAR 7 Page A-18

36 Page / Number of Pages: 19 / 57 Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Corrective Action Request No. 7: The Data unit is wrong. Please correct. ID 5: heat production 1, 4, 5, 14 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No No No Yes No No Yes. CAR 8 Corrective Action Request No. 8: The Data unit is wrong. Please correct. Also the title of the parameter is wrong installed heating output (capacity?) might be also an additional parameter, but it is important that the individual consumption is included here. ID 6: standard annual utilisation 1, 4, 5, 14 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No No Yes Yes No No No No CAR 9 Page A-19

37 Page / Number of Pages: 20 / 57 Corrective Action Request No. 9: There are some inconsistencies and uncertainities in this section. it is unclear whether the standard annual utilization rate of the heat pumps must be and will be monitored, too the data units of parameter 12 is wrong as the data unit for volume is not kg please clarify and correct furthermore it is unclear why the parameters are estimated they are either fixed in advance recorded or recalculated/measured the cooling liquid should be really monitored (not estimated) D Description of formula used to estimate emissions from the JPoA Are formulae required for the estimation of project 1 The formulae are presented and are correct in the PDD. emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? D Data to be collected in order to determine the baseline emissions within the project boundary how these data will archived Fill in the required amount of sub checklists for fixed data parameter and comment any line answered with No. ID 1: year of boiler construction 1, Data Checklist Yes / No CR 22 4, Data unit correctly expressed? Yes. and 5 Appropriate description? Yes CR 23 Source clearly referenced? Yes Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? See so CR 22 of D and Clarification Request No. 23: Page A-20

38 Page / Number of Pages: 21 / 57 The purpose why and the procedure how (data source, reporting) the parameter year of boiler construction are monitored should be explained more detailed in the column comment. Important also for this whole section: Under comment or in a footnote the source of information o be provided in this section should be listed. See so CR 22 of D ID 2: installed heating output (old system) 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No Yes. Yes Yes The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. Advice: It might be more transparent to call this installed capacity instead of output as this might be misleading. ID 3: type of old system 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? Yes / No Yes. Yes Yes Page A-21

39 Page / Number of Pages: 22 / 57 QA/QC procedures described? QA/QC procedures appropriate? The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. ID 4: type of fuel (old system) 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No Yes. Yes Yes The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. ID 5: type of new system 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No Yes. Yes Yes The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. ID 6: legal criterias, e.g. permit according to 4.BImSchV available and installed thermal power < 1, Data Checklist Yes / No / CR 24 Page A-22

40 Page / Number of Pages: 23 / MW 4, 5 Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? No No No Clarification Request No. 24: This parameter legal criterias. should be discussed and argued - concerning responsibilities and duties under the project - in the PDD. Please add further information under the rubric column. ID 7: compliance with emission limit values in permit according to 4.BImSchV or of 1.BImSchV and otherss 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No / Yes Yes No CR 25 Clarification Request No. 25: This parameter compliance with emission limit values. should be discussed and argued - concerning responsibilities and duties under the project - in the PDD. Please add further information under the rubric column. Page A-23

41 Page / Number of Pages: 24 / 57 ID 8: other incentive criteria than the JPoA, e.g. by regional programmes 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No / No No No CR 26 See parameters with ID numbers 15/16. Clarification Request No. 26: This parameter/question are there other incentive criteria than the JPoA. should be discussed and argued - concerning responsibilities and duties under the project - in the PDD. Please add further information under the rubric column. ID 9: standard annual utilisation of old system 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No Yes. Yes Yes Yes CR 27 Clarification Request No. 27: The term of the old system should be added for this parameter. Furthermore under comment a reference should be added how many years are the basis for this parameter (3 or 5 years in the past). Page A-24

42 Page / Number of Pages: 25 / 57 ID 10: standard annual utilisation of new system 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No Yes. Yes Yes Yes The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. ID 11: Emission factor EF CO2 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No Yes. Yes Yes Yes The parameter is listed in the PDD and there is sufficient information available on this factor in the PDD. ID 12: Fuel consumption 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Yes / No No Yes Yes Yes CAR 10 Page A-25

43 Page / Number of Pages: 26 / 57 Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Corrective Action Request No. 10: The data unit for the parameter Fuel consumption is wrong as this parameter is measured probably is measured in t or kg/year (in case of coal) or m3 per year in case of gas. The data unit should be adjusted. Necessary additional calculations linked to the measurement should be explained. ID 13: heat production 1, 4, 5 Data Checklist Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? Yes / No No No No No CAR 11 Corrective Action Request No. 11: The information according to the list of parameters to be monitored (to re-calculate the baseline emissions and later on to calculate the emission reductions) is Installed heating output.. - see parameter with ID No. 11. But this is wrong, also the data unit is wrong - as not the Installed heating output, but the real annual heat output is relevant and has to be measured. This must be corrected. Pleae add also under comment additional information how this will be done in practice. ID 14: auxiliary fossil fuel 1, Data Checklist Yes / No CAR Page A-26

44 Page / Number of Pages: 27 / 57 4, 5 Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? No No No No 12 Corrective Action Request No. 12: This parameter is missing, but should be included and it should be explained when it will become relevant to monitor this parameter and how this will and can be done. Please add also additional information in column/section comment. Is the list of parameters presented by chapter D considered to be complete with regard to the requirements of the applied methodology? 1, 4, 5 Yes, the list is considered to be complete under the pre-condition that the CRs and CARs mentioned above under D are solved. But the final confirmation only can be given after the on-site visits in the context of receipt of real cases (JPAs) for the measures (new heat pumps, fuel switch and installation of more efficient boilers for heat, steam and/or hot water). D Description of formula used to estimate baseline emissions Are formulae required for the estimation of baseline emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? 1 Yes, but see also CR 22 under D Advice: The determinator advises, although the formulae are presented correctly to add a more detailed explanation how the monitoring and further calculations of project and re-calculation of baseline works in practice (this is related to the chapters D.1.2 and D.1.2) as in the presented way the presented formulae appear difficult to understand for persons not fully involved in the project. Some additional sentences to give a more clear explanation would be helpful. Page A-27

45 Page / Number of Pages: 28 / 57 D.1.2 Option 2 Direct monitoring of emissions from the project D.1.3 Treatment of leakage in the monitoring plan Is it explained how the procedures provided by the methodology are applied by the proposed project activity? 1, 14 Not applicable in this project. Yes, but see CR 22 under C.1.1. D.1.4 Description of formula used to estimate emission reductions for the project (for each gas, source etc., emisions/emission reductions in CO 2 equivalent) Are the relevant gases, sources and formulae provided correctly in this chapter. 1, 14 Clarification Request No. 28: The issue Gases relevant for and considered in this project inside and outside of the project boundaries and their sources should at least be discussed in the PDD. The formulae are presented correctly but some additional sentences for a better understanding for the information included in the PDD would make the calculation process more understandable, transparent, re-traceable and plausible. CAR 28 D.2. Quality control (QC) and quality assurance (QA) procedures undertaken for data monitored: This aspect is covered for the relevant data in section D and D a final statement on this issue only can be given after the on-site visit in the real cases. D.3. D.3.1. Please describe the operational and management structure that the project operator will apply in implementing the monitoring plan: Is the operational and management structure clearly described and in compliance with the envisioned situation? 1, 2 As outlined in chapter D.3 of JPoA-DD the specific fuel consumption of each customer is measured ex-post by each project partner every year and filed in the Excel evaluation spreadsheet. The relevant heating system data for calculation of the emission reductions for those installations, which fulfil all the criteria and Page A-28

46 Page / Number of Pages: 29 / 57 have not exceeded the participation period, are evaluated in the Marketing department of Bayerngas GmbH. D.3.2. Are responsibilities and institutional arrangements for data collection and archiving clearly provided? 1 Yes see also information given under chapter D.2 D.3.3. D.3.4. D.4. D.4.1. D.4.2. Does the monitoring plan provide current good monitoring practice? Does annex 3 provide useful information enabling a better understanding of the envisioned monitoring provisions? Name of person(s)/entity(ies) establishing the monitoring plan: Is information of the person(s) / entity(ies) responsible for the monitoring methodology provided in consistency with the actual situation? Is information provided whether this person / entity is also a project participant? E. Estimation of greenhouse gas emission reductions E.1. Estimated JPoA emissions and formulae used in the estimation E.1.1. Are formulae required for the estimation of programme emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? 1 Yes, but a final statement on this issue only is only possible can be given after the on-site visit in the real cases. 1 Yes, but a final statement on this issue only is only possible can be given after the on-site visit in the real cases. 1 FutureCamp is the name of entity determining the monitoring plan. 1 Yes according to the information given in the PDD and received during the on-site visit Future Camp is no project participant in this project. 1 Ex-ante calculations for the programme emissions are considering a participation of about 340 participants yearly. The formulae are correctly applied considering the consumption of natural gas, the corresponding emission factor as well as the lea- Page A-29

47 Page / Number of Pages: 30 / 57 kages of the heat pumps. E.2. Estimated leakage and formulae used in the estimation, if applicable: E.2.1. Are formulae required for the estimation of leakage emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? 1 Clarification Request No. 29: In case of when the project activity involves fossil fuel switching measures and/or the replacement of equipment the methodology II.D requires the consideration of leakages for programmes of activities, please clarify. Please discuss this also in the context of the discussion of the methodological approach. As already mentioned here and discussed during the on-site visit the project uses a project specific approach and is only taking some elements from/methodological approaches on basis of the CDM small-scale methodologies. Thus on on-side the aspect leakage can be treated more flexible in comparison to the requirements of the methodology on the other side it needs to be discussed how periods where the new installed equipment is not operational (maintenance or much less to be expected breakdowns) are treated. Do they also fall under leakage or how is this considered in the calculations of project emissions? CR 29 E.2.2. Why are the leakage emissions not constant over the years? E.3. The sum of E.1. and E.2.: E.3.1. Is the data provided under this section in consistency with data as presented by other chapters of the PDD? E.4. Estimated baseline emissions and formulae used in the estimation: 1 See questions under CR 29 CR 29 1 In principle, yes, but see CR 29. CR 29 E.4.1. Ex-ante calculation of emission reductions Is the projection based on the same procedures as used for later monitoring? 1, 2 Corrective Action Request No. 13: There is a need to provide a legend for the applied parameters in CAR 13 Page A-30

48 Page / Number of Pages: 31 / 57 the formula for calculation of baseline emissions or refer to corresponding paragraph in Annex. The concrete values given in third chapter are not understandable without any further explanation. E.4.2. E.4.3. Is the data provided under this section in consistency with data as presented by other chapters of the PDD? Are formulae required for the estimation of baseline emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? 1 See CAR 13 of E.4.1 above CAR 13 1 See CAR 13 of E.4.1 above CAR 13 E.5. Difference between E.4. and E.3 representing the emission reductions of the project: E.5.1. Are formulae required for the determination of emission reductions correctly presented? 1 In principle, yes, but see CAR 13 of E.4.1 above CAR 13 E.6. Table providing values obtained when applying formulae above: E.6.1. E.6.2. E.6.3. Will the project result in fewer GHG emissions than the baseline scenario? Is the form/table required for the indication of projected emission reductions correctly applied? Is the projection in line with the envisioned time schedule for the project s implementation and the indicated crediting period? 1, 2, 15 1, 2, 15 1, 2, 15 Yes, the project definitely will lead to fewer emissions than the baseline (business-as-usual) scenario. In principle, yes, but see CAR 13 and CR 29 above, which still need to be solved. No. Clarification Request No. 30: Due to the long-lasting decision, clearance and approval process the project is currently not fully in line with the envisaged time CR 30 Page A-31

49 Page / Number of Pages: 32 / 57 schedule. This will affect the prognosis of the emission reductions given in this project. Thus with the final revised PDD an updated time-schedule for the project as well as adjusted corrections should be provided. E.6.4. Is the data provided under this section in consistency with data as presented by other chapters of the PDD? 1, 2, 15 Yes, under the pre-conditions that the issue mentioned above and that the average annual emission reductions are included in this chapter. F. Environmental impacts F.1. F.1.1. F.1.2. Documentation on the analysis of the environmental impacts of the project, including transboundary impacts, in accordance with procedures as determined by the host Party: Has an analysis of the environmental impacts of the project activity been sufficiently described? Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, is an EIA approved? 1, 2 Yes. 1, 2 In case of participation of installations with need for IPPC permit the need of EIA could be possible, see CAR 1. F.1.3. Will the JPoA create any adverse environmental effects? 1, 2 The effects of leakages of heat pumps on the environment are deemed to be minor. But see CRs and CARs concerning the issue mentioned in the prior sections. F.1.4. Are transboundary environmental impacts considered in the analysis? 1 No F.2. If environmental impacts are considered significant by the project participants or the host Party, provision of conclusions and all references to supporting documentation of an environmental impact assessment undertaken in accordance with the procedures as required by the host Party: F.2.1. Have identified environmental impacts Page A-32

50 Page / Number of Pages: 33 / 57 F.2.2. been addressed in the project design? Does the JPoA comply with environmental legislation in the host country? 1 See CAR 1 CAR 1 G. Stakeholders comments G.1. G.1.1. G.1.2. G.1.3. G.1.4. G.1.5. Information on stakeholders comments on the project, as appropriate: Have relevant stakeholders been consulted? Have appropriate media been used to invite comments by local stakeholders? If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws? Is the undertaken stakeholder process described in a complete and transparent manner? Is a summary of the stakeholder comments received provided? (participant list, minutes of meeting) 1, 2, 13 1, 2, 13 1, 2, 13 1, 2, 13 1, 2, 13 Clarification Request No. 31: Please submit evidence for invitation of stakeholders according to G.1.2. Announcement has been done by post, via a web announcement and partly additional by announcements in a local daily newspaper. CR 31 See CAR 1 Ýes. The stakeholder process can be considered as complete, transparent and appropriate for this type of project. Clarification Request No. 32: There is a need to provide information about the participants, e.g. participation list, agenda and minutes. CR 32 G.1.6. Has due account been taken of any stakeholder comments received? 1, 2, 13 There have been only positive comments or questions concerning organization of the project. As far as the suggestions have been appropriate, feasible and constructive they have been considered in the final PDD. Page A-33

51 Page / Number of Pages: 34 / 57 H. Annexes 1 3 Annex 1: Contact Information 1. Is the information provided in consistency with the one given under section A.3? 2. Is information on all private participants and directly involved Parties presented? 1 See CR 8 of A.3.3 CR 8 1 Yes, but see above. CR 8 Annex 2: Baseline study 1. If additional background information on baseline data is provided: Is this information in consistency with data presented by other sections of the PDD? 1 Yes. There is deepened information available in Annex 2 and the information is in line with data presented in other sections of the PDD. CR 33 Clarification Request No.33: Some sources are missing in annex 2 such as emission factors, basis of calculation value in the annual utilization ratio (table 3) and the medium capacity load of 0.3 to 0.5 on page 44. This information should be added. 2. Is the data provided verifiable? Has sufficient evidence been provided to the validation team? 3. Does the additional information substantiate statements given in other sections of the PDD? 1 Most data are directly verifiable and presented correctly in the PDD. But see CR 33 above. 1 Yes, the additional information in annex 3 substantiates and clarifies information given in previous chapters of the PDD. CR 33 Annex 3: Monitoring information 4. If additional background information on monitoring is provided: Is this information in consistency with data presented by other sections of the PDD? 1 Yes. There is deepened and information provide in Annex 3 and the information is in consistency with data presented in other sections of the PDD. CR 34 Clarification Request No.34: The data flow from regional electricity providers to the project owner has to be described more detailed, transparently- re- Page A-34

52 Page / Number of Pages: 35 / 57 traceably and logically. Where do the data finally go to and where are they stored. Please clarify. Furthermore the calculation tools which are envisaged for utilization under the monitoring plan have to be presented to the determinator. The statement..these boilers are very often older than 30 or 40 ears should be justified/presented using an official source. 5. Is the information provided verifiable? Has sufficient evidence been provided to the validation team? 6. Do the additional information / procedures substantiate statements given in other sections of the PDD? 1 In most cases the information is verifiable and it can be confirmed that the given information is correct but see CR 34 above. 1 Yes. The additional information / procedures substantiate statements given in other sections of the PDD? Page A-35

53 Page / Number of Pages: 36 / 57 Table 2 Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests by validation team Clarification Request No. 1: There is a need to give evidence and a clear verbal statement in the JPoA-Pdd that the incentive programme quoted in chapter A.2 of the JPoA-DD is exclusively valid for private costumer and not for commercial or industrial costumer. Ref. to table 1 Summary of project owner response A.2.1 See additional information in the PDD (Page 3) Closed Validation team conclusion Page A-36

54 Page / Number of Pages: 37 / 57 Corrective Action Request No. 1: The participation of installations that need an approval related to the German Regulation 4.BImSchV (similar to IPPC permit) should be defined in more detail considering: a. the demonstration that the new technology is beyond state-of-the-art which is defined in the German technical instruction TA Luft b. the influence of the JPA onto the permit procedure (all mayor modifications of installations as fuel switch need a new permit) and a clear statement who is responsible to ensure that all permits/licenses are available for installations being included in the project and how a smooth licensing process can be ensured I parallel to the process to include new installations in the project c. a statement whether installations with need of public participation (so-called Spalte 1 in the Annex of 4.BimSchV) are generally included and how the results of the public hearing are implemented in the local stakeholder process of the JPoA. A.2.3 a. From our point of view it isn t necessary to give more information on that, because that is the task of the approving authority. b. See additional information in the PDD (Page 5). Normally the licensing process is already finished by signing the gas delivery contract. Therefore is there no need for a description of this process in the PDD. c. From our point of view no Spalte 1 installations can participate at the program due to size restrictions (only installations < 20MW) Open Issue No. 1: a. According to our information a fuel switch for boilers that need a permit according to 4.BImSchV is business as usual. Hence, additionality needs to be demonstrated for these medium and large size boilers. b. Closed c. Closed Answer of PP: See KFW survey indicating that such program is not financially attractive for small and medium sized JPAs. Furthermore, the program is voluntary and implementation of corresponding measures is not legally required. AIE: closed Page A-37

55 Page / Number of Pages: 38 / 57 Clarification Request No. 2: How can it be ensured that the expected lifetime of a JPA boiler is not exceeded before the end of the crediting period, please clarify! A.2.3 By asking for the commissioning year of the old installation in the supplementary agreement and restricting participation in this project commissioned after 1978 for installations with an installed capacity up to 400 kw. The expected lifetime of such an installation is years. Taking into account the crediting period, there is no risk that the expected lifetime is exceeded. Open Issue No. 2: This comment and the statement in PDD, bullet 7 of the criteria for participation is partly not consistent. Are only coal fired boilers, commissioned before 1978 eligible? If applicable, there is a need to demonstrate as well for the installations > 400 kwth that the expected lifetime of a JPA boiler is not exceeded before the end of the crediting period (see also PDD, page 51 on top). Furthermore, please clarify the maximal lifetime of participant installation, can it be more than 30 years? Answer of PP: Yes, only coal fired boilers older than 1978 are eligible for the programme since fuel switch or energy efficiency are not legally required. The participant declaration to be signed by each participant ensures that the remaining lifetime is not exceeded during the crediting period. AIE: OI 2 is closed Page A-38

56 Page / Number of Pages: 39 / 57 Clarification Request No. 3: The agreement in Annex 4 shall be consistent with the list of criteria in the JPoA-DD, e.g. the criteria of EnEV are missing and the minimum capacity can be indicated more clearly, please clarify. A.2.3 See additional information in the PDD (Page 5). The criteria of EnEV is already included in the agreement in question 4. Because installations with an installed capacity up to 400 kw with a commissioning year after 1978 only are allowed to take part in this project. See OI 1 Clarification Request No. 4: The explanation on page 3 of the PDD concerning CPA and JPA is a little bit confusing and should be worked without mixing explanations from CDM and JI. A.2.4 See additional information in the PDD (Page 3). Closed Clarification Request No. 5: The documentation for a real case is still missing. After receipt of real cases- one for each measure under the JPoA an additional on-site visit (interviews of real case participants) will be conducted and open issues which might appear in the context of JPAs can be discussed. A.2.5 See added Real Cases PDD. Closed, the documentation for real cases has been submitted to the AIE. Page A-39

57 Page / Number of Pages: 40 / 57 Clarification Request No. 6: Please submit details of the funding (benefits for participants in the programme for each included group of measures) to the determinator. Clarification Request No. 7: Signed contracts between the regional energy suppliers and municipal utilities and Bayerngas on the other hand are not yet available. There is a need to submit exemplary contracts for at least one energy supplier and one municipal utility and to submit exemplarily for he different measures covered by the project. A.2.6 See added information on page 17 in the PDD. Open Issue No. 3: The BAFA support programmes quoted in the revised PDD is not clear enough, please explained the abbreviation. Answer of PP: Done, see page 17 of JPoA- DD. AIE: closed A.3.2 The contracts between Bayerngas and the regional energy suppliers are now available and will be distributed to TÜV Süd. Closed, a framework agreement between Bayerngas and the network partners (regional energy supplier) is available. Page A-40

58 Page / Number of Pages: 41 / 57 Clarification Request No. 8 Regarding the participation of the DFP of Germany and the purchasing country the table of project participants in chapter A.3 is not consistent with the information given in Annex 1, please clarify with German DFP (DEHST) whether it is possible to let the name of the second project participant open. This is an important question as the project needs not only the German letter of Approval but also the French letter of approval. Clarification Request No. 9 The question of project location/area should be discussed and explained more transparently and re-traceably. The maximum potential area/number of regions should be described as project location in the PDD. Furthermore a list of all distributors/regional gas providers which are considered to participate in the project should be included in the PDD. In case this is not possible at he moment it should be highlighted that the project owner then will install an opening clause for further companies which can join the programme. It is also important that a procedure will be established to exclude a participation of households in different but comparable programs as this could lead to double funding for the same activity. A.3.3 A See added information on page 6 and deleted information on pages at the PDD: Has to be done at least by registration of the project and by delivering the first verification report. Was clarified by the DFP on 25 Jan by an from the DFP. That e- mail was already forwarded to TÜV SÜD. See added information on page 7 in the PDD Households are not part of this JI project, because of the capacity requirements of above 50 respectively 100 kw. In the supplementary contract is stated, that each participant may not get any substitution from other support programms. Closed, the reception of this clarification can be confirmed. According to the clarification it is sufficient that the investor country is stated in the JPoA- DD in this determination phase. Closed Page A-41

59 Page / Number of Pages: 42 / 57 Clarification Request No. 10 The question of ownership, licenses, permits and contracts has to be worked out more detailed in the PDD. The following issues should be explained: How does the payment work, who keeps the rights, over which time period, what happens in case the participants changes the gas provider; how is it ensured that all licenses and permits are available at the date of project start for the individual participant under the programme etc Corrective Action Request No. 2: Please include the information about the annual average of estimated emission reductions in the table in chapter E.6, too. And it is advisable to give all tables, figures. Drawings always a name and number. Clarification Request No.11: Please explain in annex 2 in a footnote in which way old oil-boilers older than 1978 can become part of the project. Please give evidence for the value 1.4 for annual utilization ratio of Gas powered heat pumps as well as the calculated values how were the calculations done in general in this table? A See for added details on page 34 and pages 52ff in Annex 4. Closed A done Open Issue No. 4: Closed for the situation with HP, but needs to be recalculated since Heat Pumps are withdrawn. Answer of PP: Done AIE: closed A Is already explained on page 49 in annex 3. Closed See OI 2 about eligibility of See the corrected figure 1.2/1,25 in Table 3 for the boilers older than coefficient of performance for Heat pumps (COP). The explanation of the Calculation value is already added in brackets. Page A-42

60 Page / Number of Pages: 43 / 57 Clarification Request No.12: It should be clarified with German DEHST whether it is necessary in the process of issuing the German LoA to know the French counterpart. For the later transfer of ERUs LoAs from both involved parties need to be available. Corrective Action Request No. 2: Number and version of the applied methodologies shall be indicated in the JPoA-DD. A.5.1 See added information on page 10 at the PDD: Has to be done at least by registration of the project and by delivering the first verification report. Was clarified by the DFP on 25 Jan by an from the DFP. That was already forwarded to TÜV Süd. Closed B.1.1 Is done on page 10 at the PDD. Closed, small scale methodologies are now correctly indicated in the PDD: AMS.II.E, version 10 AMS.II.D, version 11 AMS.III.B, version 12 Clarification Request No. 13: The methodology II.E is applicable also for residential buildings which are excluded in this programme, please clarify. B.1.4 The residential buildings are not excluded from this project as far as the residential building cooperative has installations with a capacity >100 kw (see page 5 at the PDD for details) Closed Page A-43

61 Page / Number of Pages: 44 / 57 Corrective Action Request No. 3: According to the discussion during the on-site visit and during the intensive assessment of the application of the two listed methodologies in the PDD it became obvious that these methodologies only serve as auxiliary means and as guidance in this project. In reality the project developer used his own project specific approach. This does not become clear from the PDD and has to be corrected. Furthermore it should be highlighted that where and how - the approach is conservative and how the recommendations of DEHST related to methodological issues are considered in the current (and finally revised) PDD. Clarification Request No. 14: Please include real cases for all measures part of this project and demonstrate via these real cases that the JPA covers the technology/measures to be used und er the program and that the choosen methodological approach fro baseline and monitoring is justified, reasonable, applicable and practicable. B.1.4 See added information on page 10 in the PDD Closed, the baseline is established on a project specific basis using selected elements or combinations of approved CDM baseline and monitoring methodologies (see comment in CAR 2). B.1.5 See added Real Cases for heat pumps and hot water boiler. The Real case steam boiler is in the pipeline. Closed All real cases, including that one for steam boiler are available now. Page A-44

62 Page / Number of Pages: 45 / 57 Clarification Request No. 15: Methodology II.D requires the following baseline condition: The point in time when the existing equipment would need to be replaced in the absence of the project activity should be chosen in a conservative manner, i.e. if a range is identified, the earliest date should be chosen. Please clarify how this requirement is covered by the JPoA-DD. See also CAR 3 and consider the adjustments requested there under this point, too. B.2.1 See added information on page 10 in the PDD Open Issue No. 5: The answer, at least in page 10 of the PDD, does not cover completely CR 15, please clarify. Answer of PP: See Answer to OI 2 AIE: closed Clarification Request No. 16: The barriers discussed are not complete. The barriers due to prevailing practice (see additionality tool) have not been discussed yet in the PDD, please clarify and include this especially also with a special focus here on the heat pumps. B.2.6 It is not obligatory to include each barrier type in the additionality discussion. The assessment tool states such realistic and credible barriers may include, among others... Therefore we don t add this barrier because this project activity is not the first of its kind. Closed The comment to CR 16 is plausible. Clarification Request No. 17: But at the end of this step 3 the fact that at least one of the alternatives is not prevented by the identified barriers - shall be highlighted verbally after including also the discussion of barriers due to prevailing practice. B.2.8 See the commentary above. Closed Page A-45

63 Page / Number of Pages: 46 / 57 Clarification Request No. 18: It shall be discussed in short and clarified how it is ensured that project participants cannot participate or switch to other current running or envisaged comparable JI track 1 programmes from the perspective of the project owner. And it should has to be highlighted that currently no comparable programme is set up without including JI revenues thus it is not to be realistic and to be expected that - under the current frame conditions of incentives a comparable programme could run outside of the JI regime. B.2.9 See added information on page 19 at the PDD. Closed, the issue is going to be covered by each project participant by a corresponding statement in the supplementary agreement. Page A-46

64 Page / Number of Pages: 47 / 57 Corrective Action Request No. 4: Prior to the on-site visit no information was available about any funding from project owner s side of the project measure Implementation of gas-powered heat pumps. During the on-site audit it appeared that there is fixed subvention of such gas-powered heat pumps envisaged. This currently planned subvention lies in a level of 40-times up to 100-times the pre-calculated (by the determinator and project developer) potential revenues from selling the emission reductions achieved by the implementation of gas powered heat pumps in this project. This proportion between fixed subvention and potential JI revenues leads to important doubts whether for the part gas-powered heat pumps the aspect JI has any relevancy at all for participants and thus whether this part still can be considered as additional. This has to be clarified on project owner s side as well as together with German DEHST. The main question is whether a subvention given under a combined programme which is overall additional can be accepted also per se - as additional for parts/measures of the programme although these single are not considered as additional in the understanding of the Kyotoprotocol. One reason could be the argument that these incentives are niot paid without participating in this programme. Final decision/guidance on this issue can come from German DEHST as approval authority for JI Track 1 projects. B.2.10 We are in ongoing discussion with DEHSt regarding that issue; see to DEHSt (copy to TÜV Süd). Therefore the additional information sent to DEHSt are not included in the PDD yet. Obsolete, since heat pumps have been withdrawn from the JPoA. Page A-47

65 Page / Number of Pages: 48 / 57 Clarification Request No. 19: The graphic with the boundary of a JPA covers only steam generation and not hot water generation, please clarify and complete Clarification Request No. 20: A list with sources and considered gases inside and outside of the project boundaries should be included in the PDD. B.3.1 See added information on page 20. Closed B.3.2 See added information on page 20. Closed Corrective Action Request No. 5: The indicated start of the crediting period is not realistic. It should be defined to February 1 th, 2008 or the approval date of the DFP of the host and the buyer country. Alternatively we advise to speak and discuss with German DEHST as national approval authority whether they also accept as it is currently custom under JI track 1 due to reasons of delays in receipt of LoAs emission reductions from the period after implementation until receipt of the LoA. C.2 It s clarified with DEHSt that the starting point of the project is defined by 5 paragr. 5 ProMechG. Therefore we didn t change the crediting period in the PDD. Closed, the indicated starting date of the crediting period has been confirmed by the German DFP, evidence is available (see also CR 8). Page A-48

66 Page / Number of Pages: 49 / 57 Clarification Request No. 21: The methodology II.D contains monitoring requirements. There is a need to clarify the statement in chapter D.1 of the JPoA-DD that monitoring methodology does not exist for this type of JI project. See also discussion on methodological issues under other CRs above. Clarification Request No. 22: This table cannot be fully answered at this stage as we need to compare this with information of the real cases. Please submit. As far as possible the table is filled-in. Please ensure that all points to be checked by us are included in your list. too. D.1 See added information on page 23. Closed, the revised PDD refers correctly to the project specific monitoring approach. D See added information in table D Closed Corrective Action Request No. 6: The parameter installation and commissioning date of the boiler is missing in the list in the PDD and has to be included. Year of boiler construction is not concrete enough. D This information is already included in table D The commissioning date of the boiler has to be written down with the exact date (see also Annex 4) Closed Corrective Action Request No. 7: The Data unit is wrong. Please correct. ID 4 (D.1.1.1) See added information in table D Closed, whereas fuel consumption is ID 5 in the PDD. Page A-49

67 Page / Number of Pages: 50 / 57 Corrective Action Request No. 8: The Data unit is wrong. Please correct. Also the title of the parameter is wrong installed heating output (capacity?) might be also an additional parameter, but it is important that the individual consumption is included here. ID 5 (D.1.1.1) See added information in table D Closed, whereas fuel consumption is ID 6 in the PDD. Corrective Action Request No. 9: There are some inconsistencies and uncertainties in this section. it is unclear whether the standard annual utilization rate of the heat pumps must be and will be monitored, too the data units of parameter 12 is wrong as the data unit for volume is not kg please clarify and correct furthermore it is unclear why the parameters are estimated they are either fixed in advance recorded or recalculated/measured the cooling liquid should be really monitored (not estimated) ID 6 (D.1.1.1) See added information in table D Closed, whereas fuel consumption is ID 7 in the PDD. Page A-50

68 Page / Number of Pages: 51 / 57 Clarification Request No. 23: The purpose why and the procedure how (data source, reporting) the parameter year of boiler construction are monitored should be explained more detailed in the column comment. Important also for this whole section: Under comment or in a footnote the source of information o be provided in this section should be listed. ID 1 (D.1.1.3) See added information in table D Closed, whereas the order of this parameter is another in the revised PDD. Clarification Request No. 24: This parameter legal criterias. should be discussed and argued - concerning responsibilities and duties under the project - in the PDD. Please add further information under the rubric column. ID 6 (D.1.1.3) See added information in table D Closed, whereas the order of this parameter is another in the revised PDD. Clarification Request No. 25: This parameter compliance with emission limit values. should be discussed and argued - concerning responsibilities and duties under the project - in the PDD. Please add further information under the rubric column. ID 7 (D.1.1.3) See added information in table D Closed, whereas the order of this parameter is another in the revised PDD. Page A-51

69 Page / Number of Pages: 52 / 57 Clarification Request No. 26: This parameter/question are there other incentive criteria than the JPoA. should be discussed and argued - concerning responsibilities and duties under the project - in the PDD. Please add further information under the rubric column. ID 8 (D.1.1.3) See added information in table D Closed, whereas the order of this parameter is another in the revised PDD. Clarification Request No. 27: The term of the old system should be added for this parameter. Furthermore under comment a reference should be added how many years are the basis for this parameter (3 or 5 years in the past). ID 9 (D.1.1.3) See added information in table D Closed, whereas the order of this parameter is another in the revised PDD. Corrective Action Request No. 10: The data unit for the parameter Fuel consumption is wrong as this parameter is measured probably is measured in t or kg/year (in case of coal) or m3 per year in case of gas. The data unit should be adjusted. Necessary additional calculations linked to the measurement should be explained. ID 12 (D.1.1.3) The historical fuel consumption of the old installation is not relevant for the calculation of the baseline emissions. Therefore there is no need to add these Data units in the table. Closed, it has been demonstrated in chapter D that the historical fuel consumption is not necessary for the calculation in favour of a more conservative approach. Page A-52

70 Page / Number of Pages: 53 / 57 Corrective Action Request No. 11: The information according to the list of parameters to be monitored (to re-calculate the baseline emissions and later on to calculate the emission reductions) is Installed heating output.. - see parameter with ID No. 11. But this is wrong, also the data unit is wrong - as not the Installed heating output, but the real annual heat output is relevant and has to be measured. This must be corrected. Pleae add also under comment additional information how this will be done in practice. ID 13 (D.1.1.3) See added information in table D Closed, whereas the order of this parameter is another in the revised PDD. Corrective Action Request No. 12: This parameter is missing, but should be included and it should be explained when it will become relevant to monitor this parameter and how this will and can be done. Please add also additional information in column/section comment. ID 13 (D.1.1.3) See added information in table D Closed, whereas the order of this parameter is another in the revised PDD. Page A-53

71 Page / Number of Pages: 54 / 57 Clarification Request No. 28: The issue Gases relevant for and considered in this project inside and outside of the project boundaries and their sources should at least be discussed in the PDD. The formulae are presented correctly but some additional sentences for a better understanding for the information included in the PDD would make the calculation process more understandable, transparent, retraceable and plausible. D.1.4 Is already done in chapter B.3. Closed Page A-54

72 Page / Number of Pages: 55 / 57 Clarification Request No. 29: In case of when the project activity involves fossil fuel switching measures and/or the replacement of equipment the methodology II.D requires the consideration of leakages for programmes of activities, please clarify. Please discuss this also in the context of the discussion of the methodological approach. As already mentioned here and discussed during the on-site visit the project uses a project specific approach and is only taking some elements from/methodological approaches on basis of the CDM small-scale methodologies. Thus on one side the aspect leakage can be treated more flexible in comparison to the requirements of the methodology on the other side it needs to be discussed how periods where the new installed equipment is not operational (maintenance or much less to be expected breakdowns) are treated. Do they also fall under leakage or how is this considered in the calculations of project emissions? Corrective Action Request No. 13: There is a need to provide a legend for the applied parameters in the formula for calculation of baseline emissions or refer to corresponding paragraph in Annex. The concrete values given in third chapter are not understandable without any further explanation. E.2.1 This is already explained in chapter D.1.3. Open Issue No. 6: The comment of PP does not answer sufficiently to the CR 29. Answer of PP: Chapter D.1.3 of JPoA-DD has been revised accordingly. AIE: closed E.4.1 See corrected PDD Open Issue No. 7: The answer to CAR 13 is still missing. Answer of PP: The JPoA-DD has been revised accordingly. AIE: closed Page A-55

73 Page / Number of Pages: 56 / 57 Clarification Request No. 30: Due to the long-lasting decision, clearance and approval process the project is currently not fully in line with the envisaged time schedule. This will affect the prognosis of the emission reductions given in this project. Thus with the final revised PDD an updated time-schedule for the project as well as adjusted corrections should be provided. E.6.3 See corrected calculation in the PDD. See OI 4 Clarification Request No. 31: Please submit evidence for invitation of stakeholders according to G.1.2. Clarification Request No. 32: There is a need to provide information about the participants, e.g. participation list, agenda and minutes. Clarification Request No.33: Some sources are missing in annex 2 such as emission factors, basis of calculation value in the annual utilization ratio (table 3) and the medium capacity load of 0.3 to 0.5 on page 44. This information should be added. G.1.1 Will be send to TÜV with the current PDD. Closed, all evidences. E.g. invitations, participation list and agenda of local stakeholder consultation meeting are available. G.1.5 Will be send to TÜV with the current PDD. Closed, see comment to CR 31 Annex 2 The sources are named already (ZuV, Recknagel) in the PDD. Closed Page A-56

74 Page / Number of Pages: 57 / 57 Clarification Request No.34: The data flow from regional electricity providers to the project owner has to be described more detailed, transparently- re-traceably and logically. Where do the data finally go to and where are they stored. Please clarify. Furthermore the calculation tools which are envisaged for utilization under the monitoring plan have to be presented to the determinator. The statement..these boilers are very often older than 30 or 40 ears should be justified/presented using an official source. Annex 3 See added information in Annex 3. The excel calculation tool will be send to TÜV SÜD at the beginning of the next week. Closed Table 3 Unresolved Corrective Action and Clarification Requests (in case of denials) Clarifications and / or corrective action requests by validation team Id. of CAR/CR Explanation of Conclusion for Denial Page A-57