Gold Standard Validation Report

Transcription

1 Gold Standard Validation Report AL-YEL ELEKTRIK ÜRETIM A.S. Gold Standard version 2 Validation of the GS-VER Geycek Wind Farm Project Report No GS November 2009 TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstr Munich GERMANY

2 GS Validation of the Geycek Wind Farm Project Page 1 of 19 Report No. Date of first issue Revision No. Date of this revision Certificate No GS608 Subject: Gold Standard Validation of a GS-VER Project Executing Operational Unit: TÜV SÜD Industrie Service GmbH, Carbon Management Service, Westendstr Munich, Germany Contact: Client: Al-Yel Elektrik Üretim ASHollanda Caddesi No. 4/ Yildiz, Ankar Contract approved by: Report Title: Number of pages Javier Castro Gold Standard Validation of the GS-VER Geycek Wind Farm Project 19 (excluding annexes and cover page) Summary: The Certification Body Climate and Energy has been ordered by Perfect Wind Enerji A.Ş (majority shareholder of the PP Al-YEL Elektrik Üretim A.S.) to perform a validation based on Gold Standard version 2 of the above mentioned GS-VER project in a regular cycle. In summary, it is TÜV SÜD s opinion that the GS VER project Geycek Wind Farm Project, as described in the PDD of 30 July 2009 (version 1.4) and GS passport of 31 July 2009 meets all relevant Gold Standard version 2 requirements for GS-VER projects. All the UNFCCC requirements have been met as set by the Kyoto Protocol, the Marrakech Accords and relevant guidance by the CDM Executive Board and that the project furthermore meets all relevant host country criteria and correctly applies the UNFCCC baseline and monitoring methodology ACM0002 Approved Consolidated baseline methodology for grid connected electricity generation from renewable sources version 09, EB45. Hence, TÜV SÜD will recommend the project for registration as a Gold Standard GS-VER project activity by the Gold Standard Advisory Board. Additionally, the assessment team reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of 1,435,980 tonnes CO 2equivalent over a crediting period of seven (7) years, resulting in a calculated annual average of 205,140 tonnes CO 2equivalent represent a reasonable and conservative estimation using the assumptions given by the project documents. Work carried out by: Klaus Nürnberger Robert Mitterwallner Dr. Nuri Mol Internal Quality Control by: Thomas Kleiser Certification Body climate and energy

3 GS Validation of the Geycek Wind Farm Project Page 2 of 19 Abbreviations AIE CAR CER CDM CPA CR DNA DOE EIA ERU GHG GS GS-VER JI MP NGO ODA PDD PoA PP SD TAC TEIAS UNFCCC VER VVM Accredited Independent Entity Corrective Action Request Certified Emission Reductions Clean Development Mechanism CDM Programmes of Activities Clarification Request Designated National Authority Designated Operational Entity Environmental Impact Assessment Emission Reduction Unit Greenhouse gas(es) Gold Standard Gold Standard Voluntary Emissions Reduction credits Joint Implementation Monitoring Plan Non-Governmental Organisations Official Development Assistance Project Design Document Programme of Activities Project Participant Sustainable Development Technical Advisory Committee Turkish public grid operator United Nations Framework Convention on Climate Change Voluntary Emission Reductions Validation and Verification Manual

4 GS Validation of the Geycek Wind Farm Project Page 3 of 19 Table of Contents Page 1 OBJECTIVE AND SCOPE OF THE VALIDATION ACTIVITY Objective Scope 4 2 METHODOLOGY OF VALIDATION Requirements/Regulations Document Reviews On-site visit Qualification of the Audit team 6 3 PROJECT DESCRIPTION BASELINE AND MONITORING METHODOLOGY CHECK PROJECT ELIGIBILITY ADDITIONALITY GHG EMISSION REDUCTION ESTIMATION SUSTAINABILITY ASSESSMENT STAKEHOLDER CONSULTATION PRE-FEASIBILITY ASSESSMENT MONITORING REQUIREMENTS AND MONITORING PLAN ENVIRONMENTAL IMPACT ASSESSMENT VALIDATION OPINION ANNEX 1: WORK PLAN ANNEX 2.1: CARBON PROTOCOL ANNEX 2.2: GS PROTOCOL ANNEX 3: INFORMATION REFERENCE LIST... 23

5 GS Validation of the Geycek Wind Farm Project Page 4 of 19 1 OBJECTIVE AND SCOPE OF THE VALIDATION ACTIVITY 1.1 Objective Perfect Wind Enerji A.Ş (representing AL-YEL) has commissioned TÜV SÜD Industrie Service GmbH (TÜV SÜD) to validate the GEYCEK Wind Farm Project in accordance with the Gold Standard version 2. The purpose of a validation is to have an independent Third Party perform a compliance test against the additional requirements as set by the Gold Standard for GS-VER projects. Perfect Wind Enerji Üretim ve Ticaret A.S. owns 95% shares of the license owner Al-Yel Elektrik Üretim A.S. As a majority shareholder, Perfect Wind Enerji A.S. is entitled by the executive of AL-YEL Elektrik Üretim A.S. for representing the company as PP in this GS-VER project. 1.2 Scope The validation scope is defined as an independent and objective review of the passport, the PDD, the project s baseline study, monitoring plan, stakeholder consultation reports, SD matrix and other relevant documents. The information in these documents is reviewed against the Gold Standard version 2 requirements. The audit team has been provided with supporting documents comprehensively listed in Annex 2, the most important of them are listed below: a) the passport of 31July 2009 (IRL-No. 40) b) the PDD of 30 July 2009, version 1.4 (final version, IRL-No. 37), c) the Local Stakeholder Consultation Report of 30 June 2009 (IRL-No. 39) d) the Stakeholder Feedback Round Report of 10 April 2009 (IRL-No. 38) Since the operation start date of the project activity will be after the start of validation that was in October 2008 it is a regular registration procedure. These four documents serve as the basis for the final assessment presented herewith.

6 GS Validation of the Geycek Wind Farm Project Page 5 of 19 2 METHODOLOGY OF VALIDATION 2.1 Requirements/Regulations Before starting the validation TÜV SÜD uploaded the validation workplan for the project under validation to the GS on 30 October All requirements of chapter 3.3 of the GSv2 toolkit chapters are covered by the work plan (see Annex 1 for more information). The GS validation of the project must be seen in combination with the protocol for the carbon track (see Annex 2.1), the GS protocol (see Annex 2.2) and the information reference list (see Annex 3). The Gold Standard validation criteria are divided into the following tasks/steps in the assessment framework indicated in the official GS requirements and GS toolkit (chapters and Annexes): Baseline and Monitoring Methodology Check Project Eligibility Additionality Check Conservative Approach Check of the Baseline Scenario Sustainable Development Assessment Environmental Impact Assessment Stakeholder Consultation Stakeholder Feedback Round Monitoring 2.2 Document Reviews In order to ensure transparency, apart from the standard carbon validation protocol (see Annex 2.1) a special GS validation protocol was customised for the project (see Annex 2.2). According to the GS requirements TÜV SÜD developed a template covering a general and methodologyspecific checklist. The protocol shows, in a transparent manner, criteria (requirements), the discussion of each criterion by the assessment team and the results from validating the identified criteria. The validation protocol serves the following purposes: It organises, details and clarifies the requirements a GS project is expected to meet; It ensures a transparent validation process where the validator will document how a particular requirement has been validated and the result of the validation.

7 GS Validation of the Geycek Wind Farm Project Page 6 of 19 The objective of this phase of the validation is to resolve the requests for corrective actions and clarifications and any other outstanding issues which needed to be clarified for TÜV SÜD`s positive conclusion on the project design. The Corrective Action Requests and Clarification Requests raised by TÜV SÜD were resolved during communication between the client and TÜV SÜD. 2.3 On-site visit An on-site visit of the project activity is mandatory and it has been conducted from 17 to19 November, 2008 by the Audit team (Robert Mitterwallner and Dr. Nuri Mol),during the Stakeholder Feedback Round. The meeting was organised in the project region Geycek Village, in the primary school, with the national and local stakeholders and project developer s representative. During the on site audit all the sustainable aspects of the project (socio-economic and environmental) raised during the Local Stakeholder Consultations have been repeated and commented by stakeholders. The documents that were made available during the meeting are: final PDD (IRL No.36); GS Passport (IRL No 40), Non-technical project summary in Turkish (IRL No 46), local stakeholder consultation report (IRL-No. 39). Additional questions on the subject of noise production by project activity as well as impact of shadow effect in the project area have been made by Audit team. Two studies have been done by Akuo Energy that have provided the answers to these requests Micro-sitting (IRL No. 45) and Shadow effect (IRL No.34), both available to TÜV SÜD. The environmental impact of the project activity on the endemic fauna and flora in the project site was also questioned by the Audit team. During the on site audit it was mentioned by PP that it is not likely to have the presence of endemic species in the project site. An Environmental Impact Assessment study dealing with these aspects has been submitted to the audit team (IRL No.9). Following the Stakeholder Feedback Round Meeting the audit team was onsite the project area uphill and took notice of various installed wind measuring devices in linkage with the project. A desk review was held on 19 November 19 th 2008 in the headquarters of Perfect Wind Enerji A.S. in Ankara. Various aspects of the project were discussed with the project participant and the engineering company Akuo Enerji. The project was assessed according to a checklist regarding both VER and GS aspects. Issues not clarified onsite were notified in the protocol and were the basis document for futher steps Qualification of the Audit team According to the work plan in Annex 1 the audit team qualification regarding Gold Standard is ensured. The sectoral scope (Energy industries (renewable - / non-renewable sources) as well

8 GS Validation of the Geycek Wind Farm Project Page 7 of 19 as the technical area (Renewable energies) are covered by the Assessment Team Leader (Thomas Kleiser) and the auditors (Robert Mitterwallner and Dr. Nuri Mol). The latter ones have country experience by other voluntary projects. 3 PROJECT DESCRIPTION The project activity takes place in the Republic of Turkey, 210 km south-east of Ankara, in the Kirşehir region, 20 km east of Kirşehir City, on the rocky hill near the following communities: Geycek, Küçükburunagil, Obruk, Kiranköy, Tataryegenaga, Gökçeören, Büyükburunagil, Tataryeniyapan, Satiroglu. The site is located within the area of 30 km 2. Geycek Wind Farm project can be described as renewable energy project with the purpose to build and operate a wind farm with the total installed capacity of 115 MW (46 wind turbines, type N90/2500, Nordex, each with a capacity of 2.5 MW). The annual net electricity generation of the project is estimated at 325, 000 MWh, and the power output will be fed to the Turkish public grid and sold to the Turkish Electricity Transmission Company (TEIAS) under the Law no or to wholesalers, eligible consumers or to the spot market. The project s operational hours are 2,826 per annum, which correspond to the load factor of 32.26%. The project directly contributes to reduction of the greenhouse gas emissions for an average estimated 205,140 tco2 per year. In addition, the project activity will contribute to the regional and national environmental and socio-economic conditions, generating the electricity from renewable energy source and reducing the same amount of energy produced by fossil-fuelled thermal plants, reducing the country s external energy dependency as well as creating new employment opportunities. Project participant is: Al-YEL Elektrik Üretim A.Ş. is the license holder for the Geycek 115 MW Wind Farm Project. 95% of the Al-YEL shares are hold by Perfect Wind Enerji A.Ş Name Host Party of the project activity is the Republic of Turkey. The category of the project activity is in Scope 1: Energy Industries (Renewable energy). The applied baselines and monitoring methodology is ACM0002 Consolidated baseline methodology for grid connected electricity generation from renewable sources version 09, EB45. According to the PDD the starting date of the project activity is 14 May This is the issuance date of the electricity generation licence with a concession period of 25 years. A renewable crediting period with the length of the first crediting period of 7 years (84 months) has been chosen.

9 GS Validation of the Geycek Wind Farm Project Page 8 of 19 4 BASELINE AND MONITORING METHODOLOGY CHECK GS-VER emission reductions are real, measurable and verifiable. This has been assured by using the approved UNFCCC baseline and monitoring methodology ACM0002 Approved Consolidated baseline methodology for grid connected electricity generation from renewable sources version 09, EB 45 for this large scale project. The baseline and monitoring has been validated according to the guidance of the VVM There are no Gold Standard requirements that go beyond the UNFCCC methodology or are otherwise stated. According to Gold Standard version 2 requirements, it has to be assessed whether the baseline has been constructed in a conservative manner. a) The PDD clearly demonstrates that the most convincing baseline scenario has been chosen, and that all assumptions and parameters comply with the conservativeness criteria, e.g.: o PP uses the latest version of the methodology and the latest interpretation from the EB at the time of first submission to the Gold Standard (as defined in the Gold Standard Requirements). o Describes the baseline methodology used o Describes the quantified baseline scenarios o Substantiates the choice of baseline scenario o Includes an overview of the current and known future legally binding regulatory instruments and assesses whether the project would be implemented anyway because of these o Provides evidence so that it can be assessed whether or not the technology used is considered common practice. o Addresses leakage issues as part of the baseline and project boundary b) It has been ensured in the PDD that all likely baseline scenarios are developed and quantified. Furthermore, the baseline emissions are conservative because: - there is no material uncertainty over the numerical data sets applied (e.g. generator efficiencies, and fuel types and resulting emission factors, etc.) and - there is systematic referencing to publicly available information. It has been checked

10 GS Validation of the Geycek Wind Farm Project Page 9 of 19 that information is verifiably presented with a sufficient degree of detail and transparency and - It has been checked that full transparency is applied with regard to which sets of data were selected based on the prerogative of conservativeness. This included full references to sources of data used. It has been ensured that data uncertainties are clearly stated, if possible, with associated margins of error c) Since similar project activities in the region of this project (GS 352 Yuntdag 42.5 MW Wind Power Project (registered); GS 367 Catalca 60MW Wind Farm Project (registered); GS 388 MAZI-3 30 MW Wind Power Plant Project (registered)) have been registered with the following baseline: electricity delivered to the Turkish grid system have been generated by the operation of grid-connected power plants, mainly composed of thermal power plants, this baseline has been selected. 5 PROJECT ELIGIBILITY The assessed project is a Renewable energy supply project that generates and delivers energy services from non-fossil and non-depletable energy sources The project eligibility has been checked by taking into account the following criteria: a) The right project size has been selected. (Geycek Wind Farm project is a large size project). There is incosistency regarding the capacity of the project due to change of the turbine manufactorer ( IRL No. 32), but as the current capacity is lower than the initial one, is not inducing impact on the environement and society. According to the EB 48, Annex 66, it is assessed by the audit team that the change in the instaled capacity did not impact the project scale, additionality and applicability of the adequate methodology (IRL No.2). b) According to the expert opinion (Dr. Nuri Mol), until now the cap&trade scheme in the host country is not developed. c) The project is eligible for the Gold Standard (see Annex C of GS requirements) d) The project reduces the applicable GHG. (Project activity reduces CO2 emissions). e) The project does not receive ODA under the condition that the credits coming out of the project are transferred to the donor country (Annex 1 of the GS Passport from 31 July 2009 Declaration of financier of Non-Use of Official Development Assistance) f) The project applies the correct project cycle regular project cycle. g) No double counting occurs with other certification schemes.

11 GS Validation of the Geycek Wind Farm Project Page 10 of 19 Hence, the project type is eligible for the Gold Standard. 6 ADDITIONALITY According to the Gold Standard Documentation submitted (GS Passport), there has been no public announcement of the project going ahead without the VER, prior to the starting date of the project activity that is defined in the PDD as Electricity Market Licence Regulation issued by EMRA on 14 May 2008 (IRL No.13). According to the Approved Consolidated Baseline methodology ACM0002, the baseline determination is applicable as the proposed project activity meets its applicability criteria: - GEYCEK Wind Farm project involves electricity capacity additions of a renewable energy source to an electricity grid - The proposed project activity does not involve an on-site switch from fossil fuels to a renewable source. - The geographic and system boundaries for the relevant electricity grid, the Turkish public grid, can be clearly identified and information on the characteristics of the Turkish energy system as well as the energy exports and imports are publicly available and can be found at TEIAS (grid operator) web site : or Global Energy Network Institute website: The baseline determination is done by analyzing alternative scenarios which are applicable to the current laws and regulations, and using barrier analysis. If it is demonstrated via this transparent barrier analysis process that the baseline is different from the proposed project activity not undertaken as a VER project activity, it may be concluded that the project is additional. The audit team is of the opinion that the barrier analysis process as described by ACM0002 Approved Consolidated baseline methodology for grid connected electricity generation from renewable sources version 09 EB45 and Tool for the demonstration and assessment of additionality (Version 05.2, EB39) is actually in accordance with the Gold Standard requirements.. The barrier analysis of the baseline scenario description and identification as per ACM0002 version 09 can be summarized as follows. The identification and description of the alternatives to the project activity are consistent with the current laws and regulations, which are : Scenario 1: The proposed project activity not undertaken as a VER project activity. As described in PDD, this Scenario 1 is not realistic due to financial barriers which would be present if the project would be implemented under the business as usual scenario.

12 GS Validation of the Geycek Wind Farm Project Page 11 of 19 Scenario 2: A thermal power project (natural gas, lignite). This scenarion involves the construction of a fosile fuel-fired power plant, which for the same power output as the proposed project activity requires less than 115 MW instaled capacities. Scenario 3: Equivalent annual electricity supplied by Turkish grid (continuation of the current situation). As Turkey has experienced the significant growth rates in electricity demand, the supply through the Turkish grid system is based on the existing power plants and by addition of new plants, which are mostly thermal. The PDD clearly demonstrates using this barrier analysis process that the most likely baseline scenario is: Scenario 2: A thermal power project (natural gas, lignite) and Scenario 3: An equivalent annual electricity output supplied by the Turkish grid (continuation of the current situation) since all other alternatives face legal, investment and/or technological barriers. To ensure that the project also demonstrates additionality, the Additionality Tool version 05.2, which is the most recent one, has been applied in the PDD. Its 4 steps are: Step 1: Identification of alternatives to the project activity consistent with mandatory laws and regulations o The PDD correctly identifies all alternative scenarios and the consistence with the laws and regulations. Step 2: Investment Analysis o The PDD demonstrates the additionality via the Barrier Analysis and the Investment analysis is not applied. Step 3: Barrier Analysis o The PDD clearly demonstrates the barriers faced by this project activity, and that the identified baseline scenario Electricity delivered to the grid by the project would have otherwise been generated by the operation of grid-connected power plants and by the addition of new generation sources, as reflected in the combined margin (CM) calculations is not prevented by any of the identified barriers. According to the GS Toolkits additionality check, the project activity has to be in compliance with the normal practice in the region. Three similar reference projects with barrier analysis approach in Turkey were identified by the audit team on the GS Project Registry : o GS 352 Yuntdag 42.5 MW Wind Power Project (registered)

13 GS Validation of the Geycek Wind Farm Project Page 12 of 19 o o GS 439 Burgaz Wind Farm Project (registered) GS 367 Catalca 60 MW Wind Farm Project (registered) Step 4: Common Practice Analysis The common practice in the Republic of Turkey in the energy generation industry is generation of energy by fossil-fuelled thermal power plants. According to the PDD Chapter B4, there are a lot of projects of wind farm as listed, but only 15 projects are currently operating. This has been checked by our local expert. Only three projects of the 15 operating projects commissioned before enactment of law no (IRL No.7) and one very small (Ertürk s 0.85 MW at Đstanbul- Silivri) are not using the carbon market to enable implementation of their projects. We TÜV SÜD confirm that the information is correct and the law No.5346 Law on Utiliziation of Renewable Energy Sources was implemented from 10 May 2005 on. This law enables the project participants to sell their generated electricity to the grid operator TEIAS for guaranteed price of Eurocent/kWh for a period of 10 years. All projects started after the date of 10 May 2005 have applied for the use of the carbon revenues. The mentioned 3 projects were not included in the framework of this law, because they were built and operative before this date. The project owner did not apply for any carbon credits. In conclusion, the PDD correctly demonstrates the additionality using the most recent CDM Additionality Tool. 7 GHG EMISSION REDUCTION ESTIMATION According to Gold Standard version 2 requirements, it must be assessed whether a sufficiently conservative baseline scenario is chosen based on the baseline information in the PDD and gathered during on-site visit. The PDD very clearly demonstrates that the most convincing baseline scenario has been chosen, and that all assumptions and parameters comply with the conservativeness criteria. To show how the calculation of emission reductions has been carried out in a conservative manner, the following examples are given: - Geycek Wind Farm Project uses the more conservative baseline scenario than other - similar projects in Turkey:

14 GS Validation of the Geycek Wind Farm Project Page 13 of 19 Project title Grid emission factor in tco 2 /MWh Mare Manastır 39.2 MW Wind Farm Project Sayalar 30.4 MW Wind Farm Project Çatalca 60 MW Wind Power Project Yuntdağ 42.5 MW Wind Power Project MAZI-3 30 MW Wind Power Plant Project Akbük Wind Farm Project Burgaz Wind Farm Project GEYCEK Wind Farm Project In the calculation of the build margin emission factor the highest efficiency has been chosen for all natural gas power plants (i.e. 60% for combined cycle power plants instead of 39.50% for open cycle or 37.50% for steam turbine). In addition, the PP has calculated the plant load factor for the project activity which is 32.26%, as stated in the PDD (IRL No.40). According to the report of the Garrad Hassan (IRL No.16), the net electricity output for the project s activity is 325 GWh. Moreover, according to the expert opinion of Dr. Nuri Mol, the range of load factor for the wind farms in the region of Turkey is in average 30%. In conclusion, the calculated Emission Reductions are significantly lower than the expected actual emission reductions due to the project activity. Hence, the project does comply with the methodology and the GS conservativeness principles. 8 SUSTAINABILITY ASSESSMENT The parameters for the Do not harm assessment have been discussed by the PP. An assessment by TÜV SÜD if the statements of the PP are credible cannot be part of the validation since no assessment criteria are available. Therefore TÜV SÜD has checked the formal complete-

15 GS Validation of the Geycek Wind Farm Project Page 14 of 19 ness of the all 11 safeguarding principles, following the guidance of Annex H. The project has used the sustainable development assessment matrix as required by the Gold Standard version 2. The total score obtained is positive (+) x, where the scoring for each category is as following: Local/global environment sustainability has a subtotal of + (positive) Social sustainability and development has a subtotal of 0 (neutral) Economic and technological development has a subtotal of + (positive) None of the sub-total scores is negative and at least 2 of 3 categories have a positive scoring. All the assumptions used in defining the score values have been reviewed by the validator based on the submitted documentation and the on-site visit made during the validation of the project. Hence, the project activity complies with this Gold Standard criterion. The GS Documentation also includes all non-neutral parameters to be monitored to further confirm that it is in line with sustainable development. These parameters are: - Indicator: Air quality; chosen parameters: tso2 avoided/kwh and tnox avoided/kwh(category: Local/global environmental sustainability) - Indicator: Water quality and quantity; chosen parameter: Amount of discharged cooling water per MWh (category: Local/global environmental sustainability) - Indicator: Other pollutants; chosen parameter: Emission of Particulate Matter (PM) (category: Local/global environmental sustainability) - Indicator: Quantitative employment and income generation; chosen parameter: Certificates of employees (category: Economic and technological development) - Indicator: Technology transfer and technological self-reliance; chosen parameter: Number of training hours mentioned in the contract with the manufacturer (category: Economic and technological development) These non-neutral parameters will be monitored as outlined in the GS documentation, even though the sustainable development matrix did not result in any crucial SD indicators. Nonetheless, these five parameters will help verify that the project contributes to sustainable development in the region.

16 GS Validation of the Geycek Wind Farm Project Page 15 of 19 9 STAKEHOLDER CONSULTATION The project proponent has carried out a local stakeholder consultation (IRL No 39). and a stakeholder feedback round (IRL No. 38). as required by the Gold Standard. A list of participants from both meetings has been submitted to the validator. The range of stakeholders is appropriate. The stakeholders were invited by a number of methods: - Via mail (post) and fax - Personally or by phone - Local people were invited by newspaper announcements and written announcements in Geycek municipality and village s head office, as well as through oral announcements through loudspeakers In both meetings, a non-technical summary of the PDD was presented (in local language - Turkish version) (IRL No. 46).. Several presentations were made explaining GS and VER in general and the proposed project activity in particular. This was followed by a question and answer session. The questions/comments rose in both meetings and the answers given are clearly described in the summaries of the two meetings submitted by the project participant. Mainly general questions on the project, on VER, or on the carbon market were asked. Comments were received relating to project activity s possible impact on livestock feeding, bird population as well as on employment and development possibilities in the region. The impact of the project activity is not regarded to be negative. No objections or negative comments were raised about the project. Local Stakeholder Consultation 1) The local stakeholder consultation (IRL No.39) was carried out on 21 March,2008 at the Geycek Village Head s Office and the total of 36 stakeholders attended this meeting 2) Personal consultations were held with ENCEV (Enerji Cevre Yatirimlari ve Danismanligi LTD. STI) representatives in the Turkish National Parliament. Gold Standard supporting NGOs in Turkey have also been consulted by personal visits. Filiz Demirayak from WWF-Turkey, and Hilal Atici from Greenpeace have been visited by the ENCEV representatives to give a brief on the project and to invite them to attend the stakeholder meeting No significant impacts were identified which require the preparation of an EIA.. In addition, the Ministry of Forestry and Environment of the Kirsehir Province concluded that the project do not

17 GS Validation of the Geycek Wind Farm Project Page 16 of 19 have significant negative impact on biodiversity as a No EIA is required certificate has been delivered on May, 26 th 2008 (IRL No.10). Eventough an EIA was carried out by the PP and presented to the audit team. Stakeholder Feedback Round The stakeholder feedback round (IRL No. 38) was carried out on 18 November 2008 and 51 people attended this meeting. Following documents were made available for the meeting: GS passport, PDD, Non-technical project summary in local language Turkish, and Local Stakeholder Consultation meeting report. A number of six questions have been raised in the meeting and the sufficient answers were provided. Questions as well as answers are documented in the report. The PDD was available for 2 months as required by Gold Standard. 10 PRE-FEASIBILITY ASSESSMENT Not applicable here, as the project follows the regular cycle (see chapter 1.2) and is not applying for the retroactive registration, it does not require the preliminary GS assessment of the project eligibility. 11 MONITORING REQUIREMENTS AND MONITORING PLAN The Sustainability Monitoring Plan in the Passport (IRL No.40) should be validated according to guidance provided in section T The monitoring requirements of the methodology and the MP have been checked, including the sustainability MP. The validator has verified that the Monitoring Plan is in accordance with the applied monitoring methodology ACM0002 Version 9 Approved Consolidated baseline methodology for grid-connected electricity generation from renewable sources. All parameters that are deemed necessary for the estimation of emission reductions have been already included in the PDD. In addition, the following non-neutral voluntary parameters will be monitored to further confirm that the project is contributing positively to sustainable development: - Indicator: Air quality; chosen parameters: tso2 avoided /kwh and tnox avoided/kwh(category: Local/global environmental sustainability) - Indicator: Water quality and quantity; chose parameter: Amount of dischared cooling water per MWh (category: Local/global environmental sustainability)

18 GS Validation of the Geycek Wind Farm Project Page 17 of 19 - Indicator: Other pollutants; chosen parameter: Emission of Particulate Matter (PM) xxxx (category: Local/global environmental sustainability) - Indicator: Quantitative employment and income generation; chosen parameter: Certificates of employees (category: Economic and technological development) - Indicator: Technology transfer and technological self-reliance; chosen parameter: Number of training hours mentioned in the contract with the manufacturer (category: Economic and technological development) These non-neutral parameters will be monitored even though the sustainable development matrix did not result in any crucial SD indicators. Hence, the project complies with the Gold Standard requirements. 12 ENVIRONMENTAL IMPACT ASSESSMENT No Environmental Impact Analysis is required for such projects in the Republic of Turkey, as this is evidenced with the document No EIA is required certificate (IRL No.10) that has been issued by The Ministry of Forestry and Environment of the Kirsehir Province on May, 26 th According to the GS an EIA should be performed if any sustainable development indicator is rated negatively (-). Since this is not the case in this project activity, an EIA is not necessary in order to comply with GS requirements. Nevertheless, the PP has discussed the potential environmental impacts in the PDD -Section D (IRL No.37), and assessed that the project activity will have no negative imapcts on humans, plant, animal life and biodiversity in general. In addition, PP have carried out the detailed EIA and provided the report to TÜV SÜD (IRL_No.9), where the possible impacts of the project activity on the flora and fauna in the project site region have been assessed, together with the species inventory of the project s site, identifying that the occurrence of endemic species in not likely to be found. The audit team have verified the formal completeness of the safeguarding principle Environmental Protection (IRL No.40). The assessment of the correctness of statement provided by PP on the project impact is not possible by TÜV SÜD since the assessment criteria are not available. Furthermore, the environmental indicators which have been identified and scored as positive in the Sustainable Development Matrix, implicating that the project activity will bring the positive change in comparison to the baseline, are to be monitored. The monitoring plan of all non-neutraly scored indicators attributed to the project activity is described in the Sustainability Monitoring Plan, Section G of the Passport (IRL No.40). The project is expected to contribute positively to the environment as fossile fuel based electric-

19 GS Validation of the Geycek Wind Farm Project Page 18 of 19 ity will be avoided and wind based electricity will be introduced. Thus the reduction of the GHG emissions as well as improvement of the air quality will be achieved. In addition, the project will create new employment opportunities. The number of new jobs created will also be monitored during the crediting period. It can be concluded, that the EIA was not required according to the host country national legislations, described in the PDD -Section D, and the requirements of Gold Standard implicating that the PP has to fulfill the country requirements concerning EIA. However, PP has carried out the EIA.

20 GS Validation of the Geycek Wind Farm Project Page 19 of VALIDATION OPINION The Certification Body Climate and Energy has been ordered by Perfect Wind Enerji A.Ş to perform a validation based on Gold Standard version 2 of the above mentioned project in a regular cycle. In summary, it is TÜV SÜD s opinion that the project Geycek Wind Farm Project, as described in the passport of 31 st July 2009, and in the PDD of 30 th July 2009 (version 1.4), meets all relevant Gold Standard version 2 requirements for GS VER projects. Therefore, all the UNFCCC requirements have been met as set by the Kyoto Protocol, the Marrakech Accords and relevant guidance by the CDM Executive Board and that the project furthermore meets all relevant host country criteria and correctly applies the baseline and monitoring methodology ACM0002- Approved Consolidated baseline methodology for grid connected electricity generation from renewable sources (Version 09, EB45). Hence, TÜV SÜD will recommend the project for registration as a Gold Standard VER project activity by the Gold Standard Advisory Board. Additionally, the assessment team reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of 1,435,980 tonnes CO 2equivalent over a crediting period of seven years, resulting in a calculated annual average of 205,140 tonnes CO 2equivalent represent a reasonable and conservative estimation using the assumptions given by the project documents. The validation is based on the information made available to TÜV SÜD Industrie Service GmbH and the engagement conditions detailed in this report. The only purpose of this report is its use during the registration process as a GS VER project. Hence, TÜV SÜD can not be held liable by any party for decisions made or not made based on the validation opinion, which will go beyond that purpose. Munich, 20 November 2009 Munich, 20 November 2009 Thomas Kleiser Certification Body climate and energy TÜV SÜD Industrie Service GmbH Klaus Nürnberger Assessment Team Leader

21 Validation of the Geycek Wind Farm Project ANNEX 1: WORK PLAN

22 TÜV SÜD Industrie Service GmbH Munich Germany Gold Standard Foundation P.O. Box Basel - Switzerland DAP-PL DAP-IS DAP-PL DAP-PL-2722 DAP-IS DPT-ZE ZLS-ZE-219/99 ZLS-ZE-246/99 Your reference/letter of Our reference/name Tel. extension/ Fax extension Date/Document Page IS-CMS-MUC/JC of 4 Javier Castro javier.castro@tuev-sued.de Work Plan for the validation of GS 608 Dear Sirs, Please find below our Work Plan for the validation of a VER Gold Standard v2 project. Headquarters: Munich Trade Register: Munich HRB Supervisory Board: Dr.-Ing. Axel Stepken (Chairman) Board of Management: Dr. Peter Langer (Spokesman) Dipl.-Ing. (FH) Ferdinand Neuwieser Telefon: Telefax: TÜV SÜD Industrie Service GmbH Niederlassung München Carbon Management Service Westendstrasse Munich Germany

23 Page 2 of 4 Our reference/date: IS-CMS-MUC/JC / Work Plan of TÜV SÜD Industrie Service GmbH for validation of Geycek Wind Farm Project (GS 608) in Turkey Subject Description Comment Composition of the audit team and their experience. Robert Mitterwallner GHG Auditor, GS experience v1; GS focal point of TÜV SÜD Nuri Mol GHG Auditor based in Turkey; country experience Time frame See time schedule in the Annex days of validation Documents to review PDD, Passport, Stakeholder consultation report, additionality proofs, baseline docs, etc envisaged On-site audit planning and tentative programme. Interaction with the project developer, detailing the way of communication (for example via the registry) and the number of iterations for questions and requests. Reporting, detailing procedures and responsibilities for quality control. Communication of final validation opinion to the Gold Standard. See Audit schedule in the Annex 2 Communication via registry (project documentation from PP and protocol/report from DOE) Internal Certification Body ensures quality control of validation Via registry On-site Audit combined with Stakeholder Feedback Round! maximum 2 loops as indicated in the time schedule in Annex 1

24 Page 3 of 4 Our reference/date: IS-CMS-MUC/JC / Annex 1

25 4/16/2009 Wind Farm Geycek Perfect Wind, Turkey In order to organise the activities for the validation of this project we suggest the following schedule: Step Activity working days Envisaged closing Responsible date 1 Submission of order + PDD and PP Confirmation of publishing = Start Date 2 Upload to the UNFCCC website TÜV SÜD 3 Initial desk review incl. First draft TÜV SÜD validation protocol 4 On-site audit TÜV SÜD - PP 5 Submission of first validation protocol TÜV SÜD 6 Submission of answers to the PP protocol 7 Revision of answers TÜV SÜD 8 Submission of draft report to client and certification body TÜV SÜD 9 Acceptance of report from certification body TÜV SÜD 10 Submission for registration to GS TÜV SÜD Step 2: It will only be done if the documents complies with the minimum requirements of the UNFCCC (layout, methodology, etc) if not the cycle will restart by step 1. If the situation is repeated more than twice the additional effort will be billed. Step 4: the on-site audit can be organised only if the quality of the documents (PDD and additional documents) provide enough information to continue the validation If not a new PDD has to be submitted and the cycle will re-start by step 3. If the situation is repeated more than twice the additional effort will be billed. Step 6 and Step 7: Answers to the CAR and CR have to be send complete,if not we can officially not accept the response (revise and resend); if time delay to time schedule identified, then either postpone envisaged closing date (new time line to be agreed) or stop of validation process Step 9: in case the certification body needs additional information this will lead to a time delay.

26 Page 4 of 4 Our reference/date: IS-CMS-MUC/JC / Annex 2

27 No. IS-CMS-Z-PB 01/05 Process Description Process and audit description Annex 05: Audit schedule Certification Body climate and energy GENERAL Order no. Audited company Perfect Wind / ecosur UNFCCC Reg. No. PDD / Project title Contact person Geycek WIND FARM (100 MW), Turkey Fabrice LE SACHE ATL Klaus Nürnberger Audit period Audit language English/ Turkish SCHEDULE Date (Time) Audited person / Audited unit None 15/ Gwenael Jestin ET/OU Gazi Kalkan of AY-EL Electrik (the project developer and project owner) Topics Arrival at Ankara Airport with LH3360 Opening Session with Introduction, Roles of participants, Audit schedule, Validation Process, Global Stakeholder Process; General Presentation of the project AY-EL Electrik Project Planning - investors - location (detailed map, pictures) - feasibility study - time schedule, starting date - risks for delays - Long term service agreement - socio economic aspects Local Stakeholder, municipality of Geycek, AY-EL Electrik - possible impacts on environment - construction permit - Local stakeholder process, schedule - Announcement of project, invitation - Public meeting - comments/impacts on implementation of the project - Minutes/results/record, presentations - Socio economic aspects Local Stakeholder, municipality of Geycek, On-site visit AY-EL Electrik AY-EL Electrik - technical information - technology transfer - assembling of technology AY-EL Electrik Baseline / Verification of data and assumptions - methodology GS-VER - explanation of baseline scenario - alternative scenarios AY-EL Electrik, M. Pierre POCHET (financial aspects) Additionality - date of management decision, evidence - project barriers - risks, key factors prepared / changed: IS-CMS-MUC , Manja Welzel File: PB01_05_Audit schedule rev. 4 / Copyright TÜV SÜD Industrie Service GmbH approved: IS-CMS-MUC Werner Betzenbichler page 1 of 1

28 No. IS-CMS-Z-PB 01/07 Process Description Process and audit description Annex 7: Audit schedule Certification Body climate and energy AY-EL Electrik Project boundaries and Monitoring Plan - Explaining Monitoring parameters - envisioned implementation - Operational and management structure - Training of staff and monitoring personnel quality assurance procedures AY-EL Electrik Estimation of GHG emissions AY-EL Electrik GS requirements as SD Matrix AY-EL Electrik Miscellaneous, possibly remaining issues, possibly handing out of documents, communication rules; Closing session (summary of the achieved results / conclusions / next steps) /00 None Departure from Ankara Airport with LH3361 Documents / Data for submission Type Title or Content Feasibility Study Report (Finance Analysis Complementary Material, if available) and approval, if applicable Environment Impact Assessment, if applicable, and approval, if applicable Legal Approval (authorization) of the Project Activity (such as construction field and so on) Technical Data for turbines and generators Scheme of the Project Activity Business Plan: Financing mode, Credit Agreement, ODA Training evidence / training records: Client Training Plan, Training Evidence, Staff Management Standard, Staff Work Standard Documents that justify the chosen barriers (especially for the benchmarks if used) Purchasing agreements of the key equipment (technical description) Directorate Decision, if applicable All documents that are referred to in the PDD (foot notes etc.) Layout plan, Map of site Evidence for non previous public announcement For PPs information: You get this Audit schedule together with the Draft protocol in advance. Datei: Rev3_PB01_07_Audit schedule page 7 of 14 Copyright TÜV SÜD Industrie Service GmbH TÜV

29 No. IS-CMS-Z-PB 01/06 Process Description Process and audit description Annex 06: List of participants Certification Body climate and energy GENERAL Order no. Audited company Perfect Wind / ecosur UNFCCC Reg. No. PDD / Project title Geycek WIND FARM (100 MW), Turkey Audit period PARTICIPANTS Name Function Signature prepared / changed: IS-CMS-MUC , Manja Welzel File: PB01_06_Participants list rev. 4 / Copyright TÜV SÜD Industrie Service GmbH approved: IS-CMS-MUC Werner Betzenbichler page 1 of 1

30 Validation of the Geycek Wind Farm Project ANNEX 2.1: CARBON PROTOCOL

31 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Table 1 Conformity of Project Activity and PDD A. General description of project activity A.1. Title of the project activity A.1.1. A.1.2. A.1.3. Does the used project title clearly enable to identify the unique CDM activity? Are there any indication concerning the revision number and the date of the revision? Is this consistent with the time line of the project s history? A.2. Description of the project activity A.2.1. Is the description delivering a transparent overview of the project activities? 37. The project title GEYCEK Wind Farm Project clearly indicates to identify the GS VER activity. 37 The revision number and the date of the issuance of this revision we received is indicated (version 1.2, October 28, 2008). Based on the Validation Protocol s findings (submitted in ) and other new aspects, the PDD has been revised ans submitted for review (V1.3, ). 12;1 3;37 16;3 7. The dates in the project documents are in consistency with the time line of the project development. The project owner AL-YEL Enerji Üretim A.Ş. applied on to EMRA for the production license. The license has been issued on 14 May 2008 by EMRA. The startup operation is planned on 01 March Due to modifications, the operation startup date is given as October 2010 (PDD V1.3, table5).. Feasibility reports by different companies (Garrad Hassan, Suzlon, Re-Consult) on wind measurement and the energy generation capacity indicate to a possible capacity of 115 MW. The Wind Farm consists of 55 units with 2.1 MW capacity each. The project owner decided to switch to the turbine supplier NOR- DEX, instead of the initially contacted supplier SUZLON (55 turbines with 2.1 MW each). According to the explanation, this switch was due to commercial reasons. Keeping the same capacity of PDD in GSP PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-1

32 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: MW, the NORDEX offer consists of 46 turbine with 2.5 MW capacity each. PDD in GSP PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-2

33 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 A.2.2. What proofs are available demonstrating that the project description is in compliance with the actual situation or planning? 13;1 5;16; 17;3 8;39; Several documents were submitted to the audit team : - Production License - Wind measurement feasibility reports (some in progress) - Turbine feasibility report - Wind energy capacity report - Financial feasibility report - Stakeholder consultation reports - There are some open issues considering the actual project planning. The negotiations on the project finance have not been completed yet, also no agreement on purchase of WTG has been signed. According to the audit team, the projected startup of the Wind power plant on 01 March 2009 is not likely. The delay should be considered in an updated project timeline. Clarification Request #1 : Relevant documents regarding the project implementation have to be submitted : Turbine purchase and delivery agreement by the supplier Agreement on Project Finance data on the wind measurement (Re-Consult) Single line diagram of the electrical system Most of the relevant documents were submitted. The project owner has modified the project details due to changing commercial and technical project conditions. The operation startup is planned for October The wind capacity is now reduced to 325 GWh (instead of 346 GWh). The offer by NORDEX has been submitted. Note : - The feedback roundup meeting report should be submitted. - The final wind report by Re-Consult should be submitted. PDD in GSP CR1 PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-3

34 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 A.2.3. A.2.4. Is the information provided by these proofs consistent with the information provided by the PDD? Is all information presented consistent with details provided by further chapters of the PDD? A.3. Project participants A.3.1. Is the form required for the indication of project participants correctly applied? 37, the information provided by these proofs is consistent with the information provided by the PDD. 37, all information presented is consistent with details provided by further chapters of the PDD. 37 AL-YEL Elektrik Üretim Anonim A.Ş. is the license owner of the generic Geycek Wind Energy Project. AL-YEL (or the main shareholder Perfect Wind Enerji A.Ş.) is the project owner in terms of Clean Development Mechanisms under Kyoto Protocol. ECOSUR is the project developer and consultant company responsible for the completion of the PDD. Corrective Action Request #1 : Please define the role, function and title of stakeholders precisely. AL-YEL Elektrik Üretim A.Ş. (It is not a Ltd Company, as indicated in the PDD) is the project participant. 95% share of AL-YEL is hold by Perfect Wind Enerji A.Ş. The management underlines, that Perfect Wind Enerji A.Ş. should not be confused as a branch office of former French Perfect Wind company. The management cooperates closely with the French Akuoenergy Group. The issue has been clarified. Clarification Request #2: Please provide official documents indicating the 95 % share takeover of AL-YEL by Perfect Wind Enerji A.Ş.. (e.g., announcement in official commercial newspaper). The owners of the 5% share should be indicated clearly. Further the registration of the company Perfect Wind Enerji A.Ş. in the official commercial newspaper PDD in GSP CAR1 CR2 PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-4

35 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 A.3.2. A.3.3. Is the participation of the listed entities or Parties confirmed by each one of them? Is all information on participants / Parties provided in consistency with details provided by further chapters of the PDD (in particular Annex 1)? A.4. Technical description of the project activity has to be submitted. Also any cooperation agreements with the Akuo Energy Group should be submitted. Corresponding documents have been submitted. PDD in GSP 37 There is one project participant : AL-YEL Elektrik Üretim A.Ş. 37. See CAR#1 PDD A.4.1. A A A.4.2. A Location of the project activity Does the information provided on the location of the project activity allow for a clear identification of the site(s)? How is it ensured and/or demonstrated, that the project proponents can implement the project at this site (ownership, licenses, contracts etc.)? Category(ies) of project activity To which category(ies) does the project activity belonging to? Is the category correctly identified and indicated? 37 The location of the project activity is sufficiently described. 13;3 7 See CR 1. Corresponding documents (EPDK licence a.o.) have been submitted. 37 The project belongs to the category grid-connected renewable power generation project activities. This is correctly identified and indicated. Even if the project will generate VERs, CDMmethodology has been applied to be prepared for a time, where a registration of Turkish projects as JI or CDM activity is possible. ACM0002 is the most appropriate CDM-methodology for gridconnected hydro power plants, version 07. According to Annex A of Kyoto Protocol the project is in category 1 Energy Industries. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-5

36 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 A.4.3. A A A A A A Technology to be employed by the project activity Does the technical design of the project activity reflect current good practices? Does the description of the technology to be applied provide sufficient and transparent input/ information to evaluate its impact on the greenhouse gas balance? Does the implementation of the project activity require any technology transfer from annex-i-countries to the host country(ies)? Is the technology implemented by the project activity environmentally safe? Is the information provided in compliance with actual situation or planning? Does the project use state of the art technology and / or does the technology result in a significantly better performance than 37 Corrective Action Request #2 : Please correct the unit kw to MW in Table 2, chapter A.4.3. The units have been corrected. 37. The project reflects a professional standard scale Wind Power Plants as it can be found in many European countries. As part of the new energy strategy of the host country, renewable energy sources will be exploited intensively. 14;1 5;37 9;10; 37 The purchase agreement for wind turbines generators has not been signed yet. SUZLON seems to be the supplier. According to the project participant, SUZLON has acquired a danish wind turbine company and could supply from Denmark. This issue will be resolved upon the final purchase agreement. Clarification Request #3 : Please provide evidence on the origin of applied technology.. The turbine supplier NORDEX is based in an Annex-I country. (See also remarks in A.2.1 and A.2.2).. The project complies with the directives on environment. This is supported by the approval letter of the Ministry of Environment and Forestry. 37 See CAR#1. The PDD and other corresponding documents have been updated. See also remarks See also remarks in A.2.1 and A.2.2). 37. The technology actually applied in the host country is state of the art. PDD in GSP CAR2 CR3 PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-6

37 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 A A A any commonly used technologies in the host country? Is the project technology likely to be substituted by other or more efficient technologies within the project period? Does the project require extensive initial training and maintenance efforts in order to be carried out as scheduled during the project period? Is information available on the demand and requirements for training and maintenance? A Is a schedule available for the implementation of the project and are there any risks for delays? A.4.4. A A PDD in GSP PDD 37 No, the project technology is not likely to be substituted by other or more efficient technologies within the project period. 37. The project participant has already contacted wind turbine generator supplier for training and maintenance procedures. Estimated amount of emission reductions over the chosen crediting period Is the form required for the indication of projected emission reductions correctly applied? Are the figures provided consistent with other data presented in the PDD? See A , a schedule has been submitted to the audit team. This indicates 01 March 2009 for the operation startup. The onsite assessment indicates a delay in startup date. Corrective Action Request #3 : The project participant should update the timeline according to the actual progress of the project. See also CR1. The timeline has been updated. See remarks in A.2.1 and A.2.2) As will be discussed later, there are some errors in calculating the Emission Factors, and this also leads to wrong emission reduction data. Corrective Action Request # 4 : Please follow the calculation procedure for Emission Reductions CAR3 CAR4 Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-7

38 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 A.4.5. A A Public funding of the project activity Is the information provided on public funding provided in compliance with the actual situation or planning as available by the project participants? Is all information provided consistent with the details given in remaining chapters of the PDD (in particular annex 2)? B. Application of a baseline and monitoring methodology in chapter B.6. and correct the estimated emission data in chapter A.4.4 (Table) accordingly. 37 No public funds are required for the financing of the project. Note : The new Energy Efficiency Law from April 2007 stipulates a purchase obligation for a period of 10 years and a price of cent/kwh, if the operator agrees to sell to the state gris operator TEDAS. 37 All information provided is consistent with the details given in remaining chapters of the PDD. B.1. Title and reference of the approved baseline and monitoring methodology PDD in GSP PDD B.1.1. Are reference number, version number, and title of the baseline and monitoring methodology clearly indicated? 2;3;3 7 The methodology ACM0002, version 07 is clearly indicated in section B1 and B.2 of the PDD. In the updated PDD, ACM0002, version 09, Tool for additionality, version 05.2, Tool to calculate EF, version 01.1 are utilized. B.1.2. B.1.3. Is the applied version the most recent one and / or is this version still applicable? Does the methodology refer to the following tools with its latest approved versions: - Tool to calculate the emission factor for an electricity system - Tool for the demonstration and as- 2;37 ACM0002, version 09, is applicable to determine the baseline and the monitoring. See remarks above. 2;3; Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-8

39 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 sessment of additionality - Tool to calculate project or leakage CO 2 emissions from fossil fuel combustion B.2. Justification of the choice of the methodology and why it is applicable to the project activity B.2.1. Is the applied methodology considered the most appropriate one?. 2;37 Even if the project will generate VERs, a CDM-methodology has been applied to be prepared for a time where a registration of Turkish projects as JI or CDM activity is possible. ACM0002 is the most appropriate CDM-methodology for gridconnected electricity generation from renewable sources. PDD in GSP Fill in the required amount of sub checklists for applicability criteria as given by the methodology applied and comment at least every line answered with No B.2.2. Criterion 1: Type of electricity capacity addition by grid-connected renewable power generation The following types are possible: hydro power plant/unit (either with a run-of-river reservoir or an accumulation reservoir), wind power plant/unit, geothermal power plant/unit, solar power plant/unit, wave power plant/unit or tidal power plant/unit. B.2.3. Criterion 2 (in the case of hydro plants): -The project activity is implemented in an existing reservoir, with no change in the volume of reservoir or -The project activity is implemented in an existing reservoir, where the volume of reservoir is increased and the power density 37 Applicability checklist Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? Not applicable / No PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-9

40 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 of the project activity is greater than 4 W/m2 or PDD in GSP PDD B The project activity results in new reservoirs and the power density of the power plant is greater than 4 W/m2. Criterion 3 (in the case of modification/retrofit in existing power plants): 5 years of historical data (or 3 years in the case of non hydro project activities) are available B.2.5. Criterion 4: Defined electricity grid boundaries 37 Not applicable. Applicability checklist Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? / No B.2.6. Criterion 5: Approved inclusion in other methodologies (if applied only) B.2.7. Criterion 6: Exclusion of fuel switching activities B.2.8. Criterion 7: Applicability checklist Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? Applicability checklist Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? / No / No Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-10

41 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Exclusion of biomass fired power plants Applicability checklist / No Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? B.2.9. Criterion 8: Exclusion of hydro power plants that result in new reservoirs or in the increase in existing reservoirs where the power density of the power plant is less than 4 W/m2. Not applicable B.3. Description of the sources and gases included in the project boundary PDD in GSP PDD Integrate the required amount of sub-checklists for sources and gases as given by the methodology applied and comment on at least every line answered with No B.3.1. B.3.2. B.3.3. Source: Fugitive Emissions from non-condensable gases contained in geothermal steam (geothermal power plants only) Gas(es): CO 2, CH 4 Type: Project Emissions Source: Emissions from combustion of fossil fuels required to operate the geothermal power plant (geothermal power plants only) Gas(es): CO 2 Type: Project Emissions Source: Emissions from the reservoir (hydro power plants only) Gas(es):, CH 4 Not applicable Not applicable Not applicable Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-11

42 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B.3.4. Type: Project Emissions Source: Emissions from electricity generation in fossil fuel fired power plants that is displaced due to the project activity Gas(es): CO 2 Type: Baseline Emissions Not applicable PDD in GSP PDD B.3.5. Source: Emissions from electricity generation in fossil fuel fired power plants of any connected electricity system Gas(es): CO 2 Type: Baseline Emissions Boundary checklist Source and gas(es) discussed by the PDD? Inclusion / exclusion justified? Explanation / Justification sufficient? Consistency with monitoring plan? / No No CAR5 CAR1 Emissions from diesel engine for emergency cases is not disscussed. Corrective Action Request #5 : Emissions from diesel engine for emergency cases should be disscussed and justified. Contrary to the remark in chapter B.6.1, diesel generators should be installed for electricity supply in emergency cases. If the plant operator insists on not using a diesel generator onsite, he should provide alternative energy sources for continuous energy supply of instruments and data safety systems. The diesel generator emissions may be negligibile. Corrective Action Request #1 : Please adjust the text on diesel generator in B.6.1 accordingly. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-12

43 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 PDD in GSP PDD B.3.6. Source: Emissions from electricity generation in fossil fuel fired power plants of imported electricity (project electricity consumption) Gas(es): CO 2 Boundary checklist / No Source and gas(es) discussed by the PDD? Inclusion / exclusion justified? No Explanation / Justification sufficient? No Consistency with monitoring plan?? CAR6 Corrective Action Request #6 : It has to be explained how imported electricity is considered. B.3.7. Do the spatial and technological boundaries as verified on-site comply with the discussion provided by the PDD? The PP has used the data sources published by the grid operator TEIAS. The fraction of (directly) imported electricity seem negligilble and set to zero (see chapter B.3). 37. B.4. Description of how the baseline scenario is identified and description of the identified baseline scenario B.4.1. B.4.2. B.4.3. Is it clearly described that the baseline is represented by the combined margin of the grid the activity will be connected to? In case of any modification or retrofit of existing facilities: Is data available to determine the historic production level? In case of any modification or retrofit of existing facilities: Have conservative assumptions been applied in order to estimate the point in time when the existing equipment needs to be 37 Combined margin approach is used. Not applicable. Not applicable. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-13

44 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 replaced? Changes required for methodology implementation in 2 nd and 3 rd crediting periods B.4.4. Has the continued validity of the baseline been correctly assessed? Not applicable. B.4.5. Has the baseline been updated with new Not applicable. data? PDD in GSP B.5. Description of how the anthropogenic emissions of GHG by sources are reduced below those that would have occurred in the absence of the registered CDM project activity (assessment and demonstration of additionality): B.5.1. B.5.2. B.5.3. B.5.4. Is evidence provided, that CDM/VER has been considered seriously in the decision to proceed with the project activity (climate change project decision before project start)? Have realistic and credible alternatives been identified providing comparable outputs or services? (step 1a) Is the project activity without VER included in these alternatives? (step 1a) Is a discussion provided for all identified alternatives concerning the compliance 15;3 0 According to the submitted documents, no clear evidence could be identified regarding the Carbon Revenues and Clean Development Mechanisms. Clarification Request # 4 : Please provide the respective evidence of considering the clean development mechanisms in the framework of climate change projects. Respective documents showing CDM / VER consideration in the project have been submitted : - Project Memo Geycek Wind Farm (October 2007) - LOI reference on VER revenues (October 2008) CR PDD 37. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-14

45 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B.5.5. B.5.6. with applicable laws and regulations? (step 1b) In case the PDD argues that specific laws are not enforced in the country or region: Is evidence available concerning that statement? (step 1b) In case of applying step 2 / investment analysis of the additionality tool: Is the analysis method identified appropriately (step 2a)? PDD in GSP PDD Not applicable. 37 Note : The PDD refers to barrier analysis (step 3) by skipping the investment analysis (step 2), as mentioned in chapter B5, pp 16. Further in the financial feasibility analysis, step 2 is still applied for the financial feasibility considerations. Clarification Request #5 : The Tool for the demonstration and assessment of additionality should be implemented clearly. The chosen approach for this project is to be defined clearly. The barrier analysis has been applied. CR5 CR1 B.5.7. B.5.8. In case of Option I (simple cost analysis): Is it demonstrated that the activity produces no economic benefits other than CDM income? In case of Option II (investment comparison analysis): Is the most suitable financial indicator clearly identified (IRR, NPV, cost benefit ratio, or (levelized) unit cost)? Clarification Request #1 : The IRR calculation with 3 case studies additionally submitted should be evaluated together with the barrier analysis. Not applicable. Not applicable. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-15

46 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B.5.9. B B B B In case of Option III (benchmark analysis): Is the most suitable financial indicator clearly identified (IRR, NPV, cost benefit ratio, or (levelized) unit cost)? In case of Option II or Option III: Is the calculation of financial figures for this indicator correctly done for all alternatives and the project activity? In case of Option II or Option III: Is the analysis presented in a transparent manner including publicly available proofs for the utilized data? In case of applying step 3 (barrier analysis) of the additionality tool: Is a complete list of barriers developed that prevent the different alternatives to occur? In case of applying step 3 (barrier analysis): Is transparent and documented evidence provided on the existence and significance of these barriers? PDD in GSP PDD Not applicable. Not applicable. Not applicable. 37 Step 3 (Barrier Anlaysis) has been applied. Corrective Action Request #7 : The technological barrier analysis has to be added to the list and discussed. Please change the title access to finance barrier by investment barrier according to Tool for the demonstration and assessment of additionality, Annex 10, EB 39. The technological barrier analysis has been added to the barrier analysis , 32 As discussed during the onsite audit, the barrier analysis is performed by the calculation of equity IRR together with bank statement ensuring the financial non-attractiveness of the project without VERs. Corrective Action Request #8 : The SUZLON offer from September 2008 has been provided to the auditing team together with the corresponding . Please provide evidence for equity and bank statement (e.g., interest let- CAR7 CAR8 Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-16

47 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B In case of applying step 3 (barrier analysis): Is it transparently shown that the execution of at least one of the alternatives is not prevented by the identified barriers? B 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)? ter of german bank) ) of how to cover the investment costs. Additionally, it has to be demonstrated in the PDD, that the financial non-attractiveness of the project without VERs is justified. Please include sensitivity analysis that showes the conclusion, that the financial attractiveness is robust enough for reasonable variation of : - Investment costs - Operation and Maintenance costs - Power Sales revenues (conservative approach) - Operating hours The project participant has presented a new supplier (NORDEX) instead of the initial supplier (SUZLON). The initial finance institute LBBW remained the same, an LOI considering the new supplier was issued by LBBW. Nonetheless, 3 alternative case studies considering the project IRR and equity IRR were presented based on important assumptions, i.e. reduced energy generation capacity, low sale/purchase prices. See remarks in CR#1 PDD in GSP Corrective Action Request #9 : Please discuss the issue, if the 3 planned wind farms in the vicinity of of the Geycek wind farm influence the common practice analysis. This issue has been discussed in detail in step 4 (Common Prac- CAR9 PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-17

48 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B B If similar activities are occurring: Is it demonstrated that in spite of these similarities the project activity would not be implemented without the VER component (step 4b)? Is it appropriately explained how the approval of the project activity will help to overcome the economic and financial hurdles or other identified barriers? tice Analysis). 37 See also CAR9 Note : The utilization of Carbon revenues in the country has started earlier (2006) than This issue needs further explanation. If the VER does not alleviate the identified barriers that prevent the proposed project activity from occurring, then the project activity is not additional., the barrier analysis has been explained considering the aspects indicated in the Tool. But the presented 3 cases should be evaluated together with the barrier analysis, please see remarks in B PDD in GSP See CAR 9 See CAR 9 PDD B.6. Emissions reductions B.6.1. Explanation of methodological choices B B B Is it explained how the procedures provided in the methodology are applied by the proposed project activity? Is every selection of options offered by the methodology correctly justified and is this justification in line with the situation verified on-site? Are the formulae required for the determination of project emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? 37 it is explained Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-18

49 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B Are the formulae required for the determination of baseline emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? 37 The emission factor for the operation margin is calculated as Corrective Action Request #10 : The emission factor for OM is instead as indicated in Annex 3., according to the tool Annex 12, EB35. The OM emission factor has been correctly recalculated. There is statistical data available for the Turkish generation mix, in the form of the Turkey s Statistical Yearbook that is released every year by the State Institute of Statistics within the Prime Ministry. It holds data on annual CO2 emissions by sector as well as on electricity generation by sources and electricity imports. This data is more reliable, up-to-date and conservative than own calculations of OM. According to the expertise of the auditing team, the OM margin for the turkish grid system is appr instead The corrected factor has been considered in the calculations (OM = ) PDD in GSP CAR10 CAR11 PDD 8 Corrective Action Request #11 : Please include the TEIAS data for the year 2007 (see Annex3) in the calculations and recalculate again. The operating margin is expected to be in the range of The TEIAS energy data of 2007 has been included in the calculations The CM EF is calculated to EF= CAR12 Operating Margin Calculations : Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-19

50 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 The calculation for Annual electricity generation (MWh) by fuel types or imported electricity in Turkey is not conservative. The listed fuel amounts include quantities which are combusted in CHP plants. Corrective Action Request #12 : The fuel amount equivalent for heat production has to be excluded from the calculation. Only generated electricity amounts have been considered in the revised calculations, heat production has been exluded from the balances. PDD in GSP CAR13 PDD Furthermore the calculation considers the total (gross) produced electricity amount and not only the amount of current that was effectively fed to the grid. Corrective Action Request #13 : The electricity consumption of the plant has to be excluded. Only net electicity production can be used for the calculation. This has been indicated in the the balance equations. Note : Additionally by summing up figures of OM emission factor all products should be rounded in a conservative way. CAR14 Build Margin BM Calculation: In other projects the required data of capacity additions are readily available. Results from other projects differ considerably from the chosen approach. According to our expertise the last 20% of capacity addition go back to mid 2003, but not 1999, and much more Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-20

51 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 than 8 power units are involved. According to the expertise of the auditing team, the emission factor for BM is appr instead Corrective Action Request #14 : More conservative emission factor assumptions for the BM has to be used, at least according to the 2006 IPCC Guidelines. Also the used efficiencies for the different technologies are not consistent with values for best-available-technologies. PDD in GSP PDD B B B B B Is the choice of options to determine the emissions factor (OM, BM) justified in a suitable and transparent manner? Are the six steps as defined per the Tool for calculation of emission factor for electrical systems correctly applied by the project participants? In case of alternative weighing factors for the Combined Margin: Is the quantification of the alternative weighing factor justified in a suitable and transparent manner? In case of alternative weighing factors for the Combined Margin: Is the guidance for the PDD concerning the acceptability of alternative weights considered in the discussion? Are the formulae required for the determination of leakage emissions correctly pre- The emission factors (OM,BM, CM) are corrected after a reevaluation of data and sticking to the chosen approach Not applicable 37 Not applicable 37 Not applicable Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-21

52 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 sented, enabling a complete identification of parameter to be used and / or monitored? Tool to calculate project or leakage CO2 emissions from fossil fuel combustion B Is the formula required for the determination of CO2 project emissions from fossil fuel combustion correctly presented, enabling a complete identification of parameter to be used and / or monitored B Is option A (preferred approach) or option B chosen for the determination of the CO2 emission coefficient COEFi,y and is COE- Fi,y correctly determined? PDD in GSP No. See CARs in section B CAR PDD B Are formulae required for the determination of emission reductions correctly presented? 37 No. See CARs in section B B.6.2. Data and parameters that are available at validation B B Is the list of parameters presented in chapter B.6.2 considered to be complete with regard to the requirements of the applied methodology? Is the choice of ex-ante or ex-post vintage of OM and BM factors clearly specified in the PDD? CAR , ex-ante vintage is chosen. Fill in the required amount of sub checklists for monitoring parameter and comment any line answered with No B Parameter Title: GWP CH4 Global warming potential of methane valid for the relevant Not applicable Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-22

53 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B commitment period (tco2/tch4) Parameter Title: EG historical (only applicable to modification/retrofit of an existing gridconnected renewable power plant/unit) Average of historical electricity delivered by the existing facility to the grid (MWh) PDD in GSP PDD Not applicable B Parameter Title: DATE BaselineRetrofit (only applicable to modification/retrofit of an existing grid-connected renewable power plant/unit) Point in time when the existing equipment would need to be replaced in the absence of the project activity Not applicable B B Parameter Title: EF Res (only applicable to hydro-power plants with reservoir) Default emission factor for emissions from reservoirs (kgco2e/mwh) Parameter Title: CAP BL (W) (only applicable to modification/retrofit of an existing grid-connected renewable power plant/unit) Installed capacity of the hydro power plant before the implementation of the project activity. For new hydro power plants, this value is zero. Not applicable Not applicable Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-23

54 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B Parameter Title: A BL (only applicable to hydropower plant projects with reservoir) Area of the reservoir measured in the surface of the water, before the implementation of the project activity, when the reservoir is full (m2). For new reservoirs, this value is zero (m 2 ). PDD in GSP PDD Not applicable B Parameter Title: Emission factor of the grid (EF CM in tco2/mwh) 37 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No B Parameter Title: Operating margin (EF OM in tco2/mwh) emission factor of the grid 37 Corrective Action Request #15 : The list of parameters which are not monitored, has to be completed. Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? / No CAR15 Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-24

55 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Choice of data correctly justified? Measurement method correctly described? PDD in GSP PDD B Parameter Title: Build margin (EF BM intco2/mwh) emission factor of the grid 37 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No B Parameter Title: FC i,m,y, FC i,y, FC i,j,y, FC i,k,y, FC i,n,y and FC i,n,h Amount of fossil fuel type i consumed by power plant / unit m,j,k or n (or in the project electricity system in case of FC i,y ) in year y or hour h (mass or volume unit) 37 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-25

56 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B Parameter Title: NCV i,y Net calorific value (energy content) of fossil fuel type i in year y (GJ / mass or volume unit) 37 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No PDD in GSP PDD B Parameter Title: EF CO2,i,y and EF CO2,m,i,y CO2 emission factor of fossil fuel type i in year y (tco2/gj) 37 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No B Parameter Title: EG m,y, EG y, EG j,y, EG k,y and EG n,h Net electricity generated and delivered to the grid by power plant / unit m,j,k or n (or in the project electricity system in case of EGy) in year y or hour h (MWh) 37 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? / No Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-26

57 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B Parameter Title: EG PJ,h Electricity displaced by the project activity in hour h of year y (in MWh) Choice of data correctly justified? Measurement method correctly described? Not applicable PDD in GSP PDD (only applicabe for the dispatch data OM) B Parameter Title: η m,y Average net energy conversion efficiency of power unit m in year y 37 Data Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? / No Parameter Title: A PJ (only applicable to hydropower plant projects with reservoir) Area of the reservoir measured in the surface of the water, after the implementation of the project activity, when the reservoir is full. B Parameter Title: fraction of time with low costs /must run plant at the margin (for simple adjusted OM only) Not applicable Not applicable B.6.3. Ex-ante calculation of emission reductions Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-27

58 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B Is the projection based on the same procedures as used for future monitoring? PDD in GSP 37. B Are the GHG calculations documented in a complete and transparent manner? B Is the calculation of the operating margin 35 Corrective Action Request #16 : and build margin emission factors The calculation spreadsheet for OM and BM should be submitted documented electronically in a also in electronic form. spreadsheet with the relevant information This has been done. as defined per the Tool for calculation of emission factor for electrical systems? Has this spreadsheet been submitted to the validation team? B Is the data provided in this section 35;3 See CAR 16 consistent with data as presented in other 7 chapters of the PDD? B.6.4. Summary of the ex-ante estimation of emission reductions B B B B 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? Is the data provided in this section in consistency with data as presented in other chapters of the PDD? 37. CAR16 See CAR PDD 37. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-28

59 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B.7. Application of the monitoring methodology and description of the monitoring plan B.7.1. Data and parameters monitored B Is the list of parameters presented by chapter B.7.1 considered to be complete with regard to the requirements of the applied methodology? 37 Partly. The electricity supplied from grid and electricity from fossil fuel for emergency cases is not considered in balance equations. Corrective Action Request #17 : The electricity required from the grid and electricity from the fossil fuel for emergency cases should be considered. The electricity supplied from the grid is considered. The fuel consumption of a diesel generator is not yet considered in the balances. See remarks in B.3.5 Integrate the required amount of sub-checklists for monitoring parameter and comment on any line answered with No B Parameter Title: EGy Electricity supplied by the project activity to the grid (in MWh) 37 Monitoring Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? / No PDD in GSP CAR17 PDD Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-29

60 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B Parameter Title: TEGy Total electricity produced by the project activity, including the electricity supplied to the grid and the electricity supplied to internal loads, in year y (in MWh). 37 Corrective Action Request #18 : The measurement procedure for EGy and TEGy has to be indicated. This has been described (Annex4 of PDD). The electricity supplied to the grid and electricity supplied from the grid will be registered by 2-way meters. The record contains both data and allows net electricity calculations. Monitoring Checklist Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? / No PDD in GSP CAR18 PDD B Parameter Title: EF grid,cm,y Combined margin CO2 emission factor for grid connected power generation in year y calculated using the latest version of the Tool to calculate the emission factor for an electricity system (tco2/mwh) See CAR above. The gross electricity and net electricity measurements are considered. 37 Monitoring Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-30

61 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? PDD in GSP PDD B Parameter Title: PEFC,j,y CO2 emissions from fossil fuel combustion in process j during the year y (tco2/yr). Calculated as per the latest version of the Tool to calculate project or leakage CO2 emissions from fossil fuel combustion B Parameter Title: Cap PJ (only applicable to hydropower plant projects) Installed capacity of the hydro power plant after the implementation of the project activity (W). Corrective Action Request #19: The correct form of the table of the respective methodology has to be applied. The value is not conservative (see CAR above.). The measurement procedures, monitoring frequency and QA/QC procedures have to be indicated. The values have been calculated. The monitoring procedures are described. Not applicable, as this protocol refers to the ex-ante determination of CM. CAR19 Not applicable B Parameter Title: A PJ (only applicable to hydropower plant projects with reservoir) Area of the reservoir measured in Not applicable Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-31

62 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 B B the surface of the water, after the implementation of the project activity, when the reservoir is full (m 2 ). Parameter Title: w Main,CO2 Average mass fraction of CO 2 in the produced steam tco2/t steam (for geothermal projects only) Parameter Title: w Main,CH4 Average mass fraction of CH 4 in the produced steam (tch4/t steam). for geothermal projects only) PDD in GSP PDD Not applicable Not applicable B Parameter Title: M S,y Quantity of steam produced during the year y. Not applicable (for geothermal projects only) Parameters related to the Tool to calculate project or leakage CO2 emissions from fossil fuel combustion B Parameter Title: Quantity of fuel type i combusted in process j during the year y FCi,j,y B Parameter title: Weighted average mass fraction of carbon in fuel type i in year y Not applicable Not applicable W C,I,y B Parameter title: Weighted average density of fuel type i in year y Not applicable Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-32

63 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 PDD in GSP PDD ρ i,y B Parameter title: Weighted average net calorific value of fuel type i in year y NCVi,y B Parameter title: Weighted average CO2 emission factor of fuel type i in year y Not applicable Not applicable EF CO2,i,y B.7.2. Description of the monitoring plan B Is the operational and management structure clearly described and in compliance with the envisoned situation? 2;3;3 7;42 According to the PDD, a project specific monitoring standard will be defined for the monitoring. Clarification Request #6 : Please clarify, to which extent this specific standard differs from the approved monitoring methodology ACM0002, EB45. CR6 The monitoring plan follows the requirements of ACM0002, version 9. The structures on operational management are not defined clearly. The management has not sufficiently planned the monitoring phase. Corrective Action Request #20 : CAR20 The project participant should describe the monitoring procedures in detail. The monitoring procedures should define responsibility and qualification of the personnel. Furthermore a management plan should be completed and implemented. The monitoring plan follows the requirements of ACM0002, ver- Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-33

64 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 sion 9. A monitoring spreadsheet has been introduced.. PDD in GSP PDD B B B Are responsibilities and institutional arrangements for data collection and archiving clearly provided? Does the monitoring plan provide current good monitoring practice? If applicable: Does annex 4 provide useful information enabling a better understanding of the envisoned monitoring provisions? 42 No. See B See CAR20 42 See B See CAR See B See CAR20 B.8. Date of completion of the application of the baseline study and monitoring methodology an the name of the responsible person(s)/entity(ies) B.8.1. B.8.2. B.8.3. B.8.4. Is there any indication of a date when the baseline was determined? Is this consistent with the time line of the PDD history? Is the information on the person(s) / entity(ies) responsible for the application of the baseline and monitoring methodology provided consistent with the actual situation? Is information provided whether this person / entity is also considered a project participant? 37, 28 October The timeline has been updated, see remarks above Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-34

65 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 C. Duration of the project activity / crediting period C.1. Duration of the project activity PDD in GSP PDD C.1.1. Are the project s starting date and operational lifetime clearly defined and reasonable? 37. The project starting date is 1 May 2008 (Issuance of License for 25 years). The operational lifetime of the plant is expected for 20 years. C.2. Choice of the crediting period and related information C.2.1. Is the assumed crediting time clearly defined and reasonable (renewable crediting period of max 7 years with potential for 2 renewals or fixed crediting period of max. 10 years)? D. Environmental impacts 37 The crediting period is set to 7 years (84 months, starting 1 March 2009 and ending 29 February Note : : According to TÜV SÜD VER+ standard, the project has to be reviewed latest together with verification of the year 2013, due to maybe changed status of Turkey regarding Kyoto-Protocol. Turkey has ratified the Kyoto Protocol at , but has not yet defined any caps. D.1. Documentation on the analysis of the environmental impacts, including transboundary impacts D.1.1. D.1.2. Has the 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, has an EIA been approved? 37. 9;10; 37 AL-YEL submitted a pre-eia feasibility report for the GEYCEK Wind PP project to the Ministry of Forestry and Environment (MoEF). The legislation requests EIA for capacities greater than 50MW. Actually no EIA was requested by the MoEF. CR7 Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-35

66 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 PDD in GSP PDD D.1.3. D.1.4. Will the project create any adverse environmental effects? Were transboundary environmental impacts identified in the analysis? Clarification Request #7 : Please provide the pre EIA study also in electronic form. The pre EIA has been submitted. 40 It is not expected. See comments in the GS checklist. 9;31 There is an issue on the seasonal bird migration over the region. The surroundings of the nearby Seyfe lake are being used as a reservoir during this migration. Clarification Request #8 : Please provide more evidence on possible effects towards the bird migration. A prediction model on bird migration has been provided. The plant seems in a fairly distance form the migration routes. CR8 D.2. If environmental impacts are considered significant by the project participants or the host Party, please provide conclusions and all references to support documentation of an environmental impact assessment undertaken in accordance with the procedures as required by the host Party D.2.1. D.2.2. Have the identified environmental impacts been addressed in the project design sufficiently? Does the project comply with environmental legislation in the host country? 9 Partly. See CR above. Note : Some historic graves are on the hills alone the wind farm route. It must be clarified, that the windfarm will not prevent people from visiting that sites. 10. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-36

67 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 E. Stakeholders comments E.1. Brief description how comments by local stakeholders have been invited and compiled PDD in GSP PDD E.1.1. E.1.2. E.1.3. E.1.4. 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 that was carried out described in a complete and transparent manner? 37; The public stakeholder meeting was announced by a local newspaper. A meeting was held 14 March 2008 with stakeholders on site GEYCEK wind PP. The stakeholder round up meeting was held on 18 November 2008 in Geycek village. The audit team was present. 37 There are no regulations regarding the stakeholder consultation process (SCP) in the host country. This may change soon, if Turkey joins the Kyoto Protocol. The SCP has been organized due to the CDM mechanisms. 37. E.2. Summary of the comments received E.2.1. Is a summary of the stakeholder comments received provided? 37. E.3. Report on how due account was taken of any comments received E.3.1. Has due account been taken of any stakeholder comments received? 37. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-37

68 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 F. Annexes 1 4 Annex 1: Contact Information PDD in GSP PDD F.1.1. F.1.2. Is the information provided consistent with the one given under section A.3? Is the information on all private participants and directly involved Parties presented? See also CR1. Annex 2: Information regarding public funding F.1.3. F.1.4. Is the information provided on the inclusion of public funding (if any) in consistency with the actual situation presented by the project participants? If necessary: Is an affirmation available that any such funding from Annex-Icountries does not result in a diversion of ODA? 37 There is no public funding. Not relevant Annex 3: Baseline information F.1.5. F.1.6. If additional background information on baseline data is provided: Is this information consistent with data presented by other sections of the PDD? Is the data provided verifiable? Has sufficient evidence been provided to the validation team? This issue has to be checked onsite.. F.1.7. Does the additional information substan- 37 Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-38

69 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 tiate / support statements given in other sections of the PDD? Annex 4: Monitoring information PDD in GSP PDD F.1.8. F.1.9. F If additional background information on monitoring is provided: Is this information consistent with data presented in other sections of the PDD? Is the information provided verifiable? Has sufficient evidence been provided to the validation team? Do the additional information and / or documented procedures substantiate / support statements given in other sections of the PDD? 37 An organigram with the responsibilities has been provided. 37 See F See F1.8. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-39

70 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Table 2 Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests by validation team Clarification Request #1 : Relevant documents regarding the project implementation have to be submitted : Turbine purchase and delivery agreement by the supplier Agreement on Project Finance data on the wind measurement (Re- Consult) Single line diagram of the electrical system Corrective Action Request #1 : Please define the role, function and title of stakeholders precisely. Ref. to table 1 A.2.2 A.3.1 Summary of project owner response Most of the relevant documents were submitted in February 2009, together with the revised PDD. Note : - The feedback roundup meeting report ( ) should be submitted. - The final wind report by Re-Consult should be submitted. The function and the business relations of AL-YEL, Perfect Wind Enerji and Akuo Enerji are well described. Validation team conclusion The mentioned documents have been submitted to the audit team. The status of the license holder AL-YEL, the main shareholder Perfect Wind and the engineering company Akuo have been sufficiently described. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-40

71 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Clarification Request #2: Please provide official documents indicating the 95 % share takeover of AL-YEL by Perfect Wind Enerji A.Ş.. (e.g., announcement in official commercial newspaper). The owners of the 5% share should be indicated clearly. Further the registration of the company Perfect Wind Enerji A.Ş. in the official commercial newspaper has to be submitted. Also any cooperation agreements with the Akuo Energy Group should be submitted Corrective Action Request #2 : Please correct the unit kw to MW in Table 2, chapter A.4.3 Clarification Request #3 : Please provide evidence on the origin of applied technology Corrective Action Request #3 : The project participant should update the timeline according to the actual progress of the project. See also CR1 Corrective Action Request # 4 : Please follow the calculation procedure for Emission Reductions in chapter B.6. and correct the estimated emission data in chapter A.4.4 (Table) accordingly. A.3.1 Corresponding documents have been submitted. Note : The cooperation agreement of the project participant with Akuo Enerji should be submitted. This issue has been clarified, see also remarks in CAR#1. A The units have been corrected. The correction has been done. A A A The turbine supplier NORDEX is based in an Annex-I country. See also remarks in A.2.1 and A.2.2). The timeline has been updated. See remarks in A.2.1 and A.2.2) This has been done and and indicated in the updated PDD. The WTG supplier NORDEX is based in Germany, which is listed in Annex-I. The update of the timeline seems to be reasonable. The calculations on emission reductions and combined margin EF have been corrected and found to be consistent. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-41

72 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Corrective Action Request #5 (= CAR#1) : Emissions from diesel generator for emergency cases should be discussed and justified. Corrective Action Request #6 : It has to be explained how imported electricity is considered. Clarification Request # 4 : Please provide the respective evidence of considering the clean development mechanisms in the framework of climate change projects. B 3.5. B 3.6 B 5.1 Please adjust the text on diesel generator in B.6.1 accordingly. The fraction of (directly) imported electricity seem negligilble and set to zero (see chapter B.3). Respective documents showing CDM / VER consideration in the project have been submitted : - Project Memo Geycek Wind Farm (October 2007) - LOI reference on VER revenues (October 2008) The project emissions caused by the emergency diesel generator have been mentioned. The expected emission amount will be less than 1% of the total ER generated by the project and therefore negligible. This assumption is reasonable and has been accepted by the audit team. The project participant AL- YEL has applied on for the electricity production license. The license was issued on by EPDK (Energy Market Regulation Authority). The project memo (dated from October 2007) and the LOI (dated from October 2008) indicate earliy VER consideration for project implementation. This seems to be reasonable for the audit team. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-42

73 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Clarification Request #5 : The Tool for the demonstration and assessment of additionality should be implemented clearly. The chosen approach for this project is to be defined clearly. Clarification Request #1 : The IRR calculation with 3 case studies additionally submitted should be evaluated together with the barrier analysis. B 5.6 The barrier analysis has been applied. The project participant has chosen Barrier Analysis for the additionality issue. The described barriers have been evaluated by the audit team. They were found reasonable. This is being done by the TUV expert. The project participant has chosen Barrier Analysis of the Tool for the demonstration and assessment of additionality and has not desribed the Investment Analysis (Step2) in the PDD (see chapter B.5). Some submitted documents on project finance and IRR calculations will therefore not be considered as part of the additionality issue. If the project participant insists on integrating the investment analysis in the additionality issue, further details on the finances would be required by the audit team. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-43

74 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Corrective Action Request #7 : The technological barrier has to be added to the list and to be discussed. Please change the title access to finance barrier by investment barrier according to the Tool for the demonstration and assessment of additionality, Annex 10, EB 39. Corrective Action Request #8 : The SUZLON offer from September 2008 has been provided to the auditing team together with the corresponding . Please provide evidencve for equity and bank statement (e.g., interest letter of german bank) )of how to cover the investment costs. Additionally it has to be demonstrated in the PDD, how to ensure the financial nonattractiveness of the project without VERs. Please include sensitivity analysis that showes the conlusion regarding the financial attractiveness is robust enough for reasonable variation of : - Investment costs - Operation and Maintenance costs - Power Sales revenues (conservative approach) - Operating hours B 5.12 B 5.13 The technological barrier analysis has been added to the barrier analysis. The project participant has presented a new supplier (NORDEX) instead of the initial supplier (SUZLON). The initial finance institute LBBW remained the same, an LOI considering the new supplier was issued by LBBW. Nonetheless, 3 alternative case studies considering the project IRR and equity IRR were presented based on important assumptions, i.e. reduced energy generation capacity, low sale/purchase prices. See remarks in CR#1 This issue has been added in to the Barrier Analysis considerations. The project participant has chosen the Barrier Analysis to handle the additionality issue. The investment analysis has not been considered in the PDD, the explanatory calculations won t be considered in this issue (see remarks in CR#1). The project participant described various barriers that would prevent him in favour of an investment decision. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-44

75 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Corrective Action Request #9 : Please discuss the issue, if the 3 planned wind farms in the vicinity of of the Geycek wind farm influence the common practice analysis. Corrective Action Request #10 : The emission factor for OM is instead as indicated in Annex 3., according to the tool Annex 12, EB35 Corrective Action Request #11 : Please include the TEIAS data for the year 2007 (see Annex3) in the calculations and recalculate again. The operating margin is expected to be in the range of Corrective Action Request #12 : The fuel amount equivalent for heat production has to be excluded from the calculation. Corrective Action Request #13 : The electricity consumption of the plant has to be excluded. Only net electricity production can be used for the calculation. B 5.15 This issue has been discussed in detail in step 4 (Common Practice Analysis). B B B B The OM emission factor has been correctly recalculated. The corrected factor has been considered in the calculations (OM = ) The TEIAS energy data of 2007 has been included in the calculations The CM EF is calculated to EF= This has been indicated in the the balance equations. Common Practice Analysis has been included in Step 4. Actually, fossil fuell energy sources would be easy to install and operate than the wind farm project. The recalculation of OM-EF has been done correctly. This calculation of corrected factor has been done correctly. The data has been used in the calculations. The electricity purchased from the grid has been added in the calculations. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-45

76 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Corrective Action Request #14 : More conservative emission factor assumptions for the BM has to be used, at least according to the 2006 IPCC Guidelines. Also the used efficiencies for the different technologies are not consistent with values for best-available-technologies. Corrective Action Request #15 : The list of parameters which are not monitored, has to be completed. Corrective Action Request #16 : The calculation spreadsheet for OM and BM should be submitted also in electronic form. Corrective Action Request #17 : The electricity required from the grid and electricity from the fossil fuel for emergency cases should be considered. Corrective Action Request #18 : The measurement procedure for EGy and TEGy has to be indicated. Corrective Action Request #19: The correct form of the table of the respective methodology has to be applied. The value is not conservative (see CAR above.). The measurement procedures, monitoring frequency and QA/QC procedures have to be indicated. B B B B B B The emission factors (OM,BM, CM) are corrected after a reevaluation of data and sticking to the chosen approach. This has been done. This has been done. See remarks in B.3.5 This has been described (Annex4). The values have been calculated. The monitoring procedures are described. This correction of EF has been done correctly. This PDD has been revised correctly. This PDD has been revised correctly.. This has been done correctly, see also remarks above. This PDD has been revised correctly.. This PDD has been revised correctly. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-46

77 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Clarification Request #6 : Please clarify, to which extent this specific standard differs from the approved monitoring methodology ACM 0002, EB36. Corrective Action Request #20 : The project participant should describe the monitoring procedures in detail. The monitoring procedures should define responsibility and qualification of the personnel. Furthermore a management plan should be completed and implemented. Clarification Request #7 : Please provide the pre EIA study also in electronic form. Clarification Request #8 : Please provide more evidence on possible effects towards the bird migration. Corrective Action Request #2 : There are some small mistakes in the revised PDD, which should be also adjusted : - p. 8 (bottom): were -> will be B B D 1.2 D 1.4 general The monitoring plan follows the requirements of ACM0002, version 8. The monitoring plan follows the requirements of ACM0002, version 8. A monitoring spreadsheet has been introduced. The pre EIA has been submitted. A prediction model on bird migration has been provided. The plant seems in a fairly distance form the migration routes. Corrections have been done. This PDD has been revised correctly.. The spreadsheet is appropriate. The EIA has been submitted to the audit team. The pre EIA submitted to the audit team handles this issue in detail and clearly. The corrections have been done. - p. 11 (top): realized -> provided - p. 16 (footnote) : Law > Law p. 18 (project specific barriers) : Akuo Enerji is the shareholder of Al-YEl - > Perfect Wind Enerji is the shareholder. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-47

78 VER Validation Protocol Project Title: GEYCEK Wind Power Plant Date of Completion: Number of Pages: 48 Corrective Action Request #3 : A non-technical summary of PDD in Turkish would make the plant staff understand the approach of the clean development mechanisms. general The issue has been mentioned in the PDD. This issue has been mentioned in the PDD (chapter B.7.2). It will be checked during first verification onsite. Table 1 is applicable to ACM0002, version 07 with ex-ante determination of CM Page A-48

79 Validation of the Geycek Wind Farm Project ANNEX 2.2: GS PROTOCOL

80 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 A. Project Title - Toolkit 1.6 A.1.1. Is project title in the Passport the same as in the PDD? First Passport Pass-port 37;40, the project title of the passport Geycek Wind Farm Project is consistent with that one of the PDD. A.1.2. Does the project Passport comply with the Passport template published by GS? 40, in general it does comply; the additional Annexes 2, 3, 4 and 5 in the passport give more detailed information about the project. B. Project Description - Toolkit 1.6 B.1.1. Is the project description consistent with the non-technical summary which has been presented to the stakeholders and consistent with the project summary in section A of the PDD? 37;39; 46, the project description in a non-technical summary in English language provided in the local stakeholder consultation meeting report, is consistent with the Section A of the PDD. Corrective Action Request No 1 CAR 1 a) The name of the project owner who is the project developer is not indicated in the passport. The max. installed power and the list of power clients in the non-technical summary do not comply with the information in the passport and PDD; this has to be clarified in the passport and PDD. Table 1 is applicable to Gold Standard version 2 (Passport) Page A-1

81 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 C. Proof of Project Eligibility C.1. Scale of the Project - Toolkit 1.2.a C.1.1. Has the right project size and the project type been selected? Does the project proponent has a written statement (e.g. in the PDD) against de- bundling of the project? Debundling of small- and large-scale projects to create micro-scale projects is not allowed. 40 De-bundling is generally not applicable for this large scale project. Corrective Action Request No 2 The selected scale large scale is correct, but it is not CDM, it is VER, please correct. First Passport CAR 2 Pass-port C.2. Host Country - Toolkit 1.2.b C.2.1. If there is an applicable cap & trade scheme in the project s host country, has an arrangement been made to cancel allowances (as back up for issued GS VER credits) in the applicable cap & trade scheme? C.3. Project Type - Toolkit 1.2.c and Annex C C.3.1. Is the project activity listed in Annex C of the toolkit and hence eligible for the Gold Standard? C.3.2. Has the project been previously announced and is there a state- 40 No, a cap & trade scheme is not applicable in Turkey. According to our local expert it is supposed to be developed in the next years. 40, it is a renewable project. 12;13;15; Clarification Request No. 1. In order to check that the project has not been announced before CR 1 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-2

82 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 ment available? deciding to start with the VER credits, the evidences Project memo Geycek Wind Farm and license according to page 6 of the passport have to be submitted to the DOE. First Passport Pass-port C.4. GHG - Toolkit 1.2.d C.4.1. Does the project reduce an applicable GHG? 40, as indicated in the passport, the project reduces the eligible GHG CO 2 by substituting fossil fuel generated by grid connected power plants. C.5. Project Registration Type - Toolkit 1.2.f C.5.1. Is it ensured that the project does not receive ODA under the condition that the credits coming out of the project are transferred to the donor country? 40 Corrective Action Request No 3 The ODA declaration(s) are not indicated in the Passport (see Annex 1). CAR 3 C.5.2. Does the project apply the correct project cycle (regular vs. prefeasibility assessment)? 40, since construction and operation did not start yet, it is a regular project cycle and this has been correctly indicated in the passport. C.5.3. Is it excluded that double counting occurs with other certification schemes? 40 Clarification Request No. 2. Please clarify how double counting can be excluded. CR 2 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-3

83 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 D. Unique Project Identification D.1. GPS-coordinates of Project Location - Toolkit 1.6 D.1.1. Are the exact GPS coordinates of the project location for point source activities and the boundaries for projects spread over a broader area stated? 40 Corrective Action Request No 4 The GPS coordinates of each turbine have to be indicated in the passport. First Passport CAR 4 Pass-port D.1.1. Is this description sufficiently accurate as mistakes are easily made and could lead to double counting of credits? D.1.2. For Programme of Activity projects, is the reasoning behind the definition of the project location and coordinates carefully explained? D.2. Map - Toolkit 1.6 D.2.1. Are the coordinates illustrated with a map, i.e See CAR 4 See CAR 4 24;25; 40; Not applicable for this project. Corrective Action Request No 5 The detailed map of the turbines, indicated in the Passport does not cover the villages in the vicinity, neither three wind speed measuring masts, nor the location of the sub-station CAR 5 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-4

84 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 E. Outcome Stakeholder Consultation Process E.1. Assessment of Stakeholder Comments - Toolkit Annex J E.1.1. Does the report on the local stakeholder consultation meeting follow the template which is presented on the GS web page?. 39, apart from the following issue it does comply with the template. Corrective Action Request No 6 The table in C.1 does not comply with the template, and the parameter human and institutional capacity is missing. The template topic Score in table C.3 has been substituted by Preliminary Score. First Passport CAR 6 Pass-port E.1.2. Has the report been uploaded separately? E.1.3. Is the non-technical summary provided in the local language? 23;39;, it has been uploaded separately to the GS registry. 46, the non-technical summary is provided in Turkish language in the stakeholder consultation meeting report. Clarification Request No. 3. Has a non-technical summary been provided for participants of the stakeholder consultation meeting? CR 3 E.1.4. How stakeholders have been invited, were NGO s covered and was there 39;43; Stakeholders have been invited by a letter of EN-CEV from March 3, Furthermore, Local newspaper announcement has been Table 1 is applicable to Gold Standard version 2 (Passport) Page A-5

85 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 tracking on the invited stakeholders? done on March 14, Filiz Demirayak of WWF and Hilal Atici of Greenpeace have been invited personally by EN-CEV to attend the local stakeholder consultation meeting. Clarification Request No. 4. a) The functions of AL-YEL and ENCEV as well as all other used abbreviations have to be explained in the report. b) The list of stakeholders invited by the EN-CEV letter is not available, please clarify. c) The table in chapter A.1 is not filled yet, please clarify. a) Are evidences about the invitation and comments of NGOs documented/recorded? First Passport CR 4 Pass-port E.1.5. for Have DNA/DFP been notified at the same time as inviting stakeholders the local stakeholder consultation meeting? 39, Mr. Mustafa Sahin from the Ministry of Environment and Forest (=DNA/DFP), has been invited personally by EN-CEV to attend the local stakeholder consultation meeting. See CR 4 for evidence about the time of personal invitation. See CR 4 E.1.6. About the local stakeholder consultation meeting itself: - was the agenda appropriately? 39 The local stakeholder consultation meeting took place on March 21, 2008 in the village Geycek. The agenda was not completely according to GS requirements, Table 1 is applicable to Gold Standard version 2 (Passport) Page A-6

86 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 - participation list provided? but the main issues have been covered. A participation list has been provided in the report. First Passport Pass-port E.1.7. Follow-up after the meeting: - evaluation of the comments - actions for negative comments - minutes of meeting - have comments been taken into account for development of the project - finalize SD-Matrix (still negative comments)? 9;31;34; 39 No negative comments have been raised during the local stakeholder consultation process. Minutes of the meeting are provided in the report. Clarification Request No. 5. a) The subject of possible impact of turbines on bird migration roots, noise impact, shadow effect and electromagnetic impacts by power lines have not been discussed, please clarify. b) Annex 2 is not part of the report, please clarify. CR 5 E.2. Stakeholder Feedback Round - Toolkit 2.11 E.2.1. Has the documentation listed below been made publicly available for a period of two month prior to completion of the validation in a readily accessible form including: - The latest version of the complete PDD (including the EIA, if applicable); - A non-technical summary of the project (in appropriate local language(s)); 38 The stakeholder feedback round took place on November 18, 2008 in Geycek village. The Audit team of TÜV SÜD attended to the meeting as observer. Clarification Request No. 6. The feedback round report has to be provided to the DOE as soon as it is available after the comment period. CR 6 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-7

87 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 - All relevant supporting information (if available, in appropriate local language(s)); - Additional, non-translated information must be made available as well and shall be translated to the local language upon any justified request of a stakeholder? First Passport Pass-port E.2.2. Has a physical meeting been per formed as Stakeholder Feedback Round or any other, e.g. by telephone? The site visit is mandatory for retroactive projects! 38, the physical meeting was performed for the Stakeholder feedback round E.2.3. Have all issues raised on the local stakeholder consultation meeting been covered in the Stakeholder Feedback Round? 38, all issues have been covered E.2.4. Have all stakeholders invited for the local stakeholder consultation meeting been invited for the Stakeholder Feedback Round? 38 See CR 6, all people invited for the LSC meeting have been contacted and invited for the SFR as well. See CR 6 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-8

88 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 E.2.5. Were the following documents available for the participants of the Stakeholder Feedback Round: - Local Stakeholder Consultation Report - Passport - Others, e.g. EIA? 38;39; 40 See CR 6, named documents were available for the participants of the Stakeholder Feedback Round First Passport See CR 6 Pass-port E.2.6 Does the final passport include the report of the Stakeholder Feedback Round, taking into account: - A description of the procedure followed to invite comments, including addressing all the details of the oral hearing such as place, date, participants, language, local or national Gold Standard NGO supporters, etc. 40 See CR 6, the final Passport includes report on the Stakeholder Feedback round with the short description on how people were invited for the meeting, what questions were raised and how they were answered. In addition in Annex 5 of the Passport are examples of the questionnaires fulfilled by stakeholders attached. See CR 6 - All written or oral comments received - The argumentation on whether or not comments are taken into account and the respective changes to the project design? Table 1 is applicable to Gold Standard version 2 (Passport) Page A-9

89 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 First Passport Pass-port F. Outcome Sustainability Assessment F.1. Do no harm assessment - Toolkit and Annex H F.1.1. Has a Do no harm assessment been carried out? 40, but Corrective Action Request No 7 a) The assessment of do not harm has to be done by the PP and not by the stakeholders (see passport page 13). b) The table in the passport is not completely filled, please revise. c) Not all of the 11 categories of Annex H are listed in the passport, please clarify. The wording initial stakeholder consultation meeting has to be avoided for the GSv2, that is applicable here. CAR 7 F.1.2. Have following safeguarding principals been assessed by PP? Human Rights: Does the project respects internationally proclaimed human rights including dignity, cultural property and uniqueness of indigenous people. Is the project involved in involuntary resettlements? Is the project involved in alteration, dam- 40 See CAR 7 See CAR 7 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-10

90 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 age or removal of any cultural heritage? F.1.3. Have following safeguarding principals been assessed by PP? Labour standards: Does the project respect the employees freedom of association and their right to collective bargaining and is the project not complicit in restrictions of these freedoms and rights? Is the project involved in any form of forced or compulsory labour? Is the project involved in any form of child labour? Is the project involved in any form of discrimination based on gender, race, religion, sexual orientation or any other basis? Does the project provide workers a safe and healthy work environment? F.1.4. Have following safeguarding principals been assessed by PP? Environmental protection: Does the project takes a precautionary approach in regard to environmental challenges and is it not complicity in practices contrary to the precautionary principle? First Passport 40 See CAR 7 See CAR 7 40 See CAR 7 See CAR 7 Pass-port Table 1 is applicable to Gold Standard version 2 (Passport) Page A-11

91 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 Is the project involved in significant conversion or degradation of critical natural habitats, including those that are (a) legally protected, (b) officially proposed for protection, (c) identified by authoritative sources for their high conservation value or (d) recognised as protected by traditional communities? F.1.5. Have following safeguarding principals been assessed by PP? Anti-Corruption: Is the project involved or complicit in corruption? F.1.6. Has the do no harm assessment table 2.7 been included to the project passport? First Passport 40 See CAR 7 See CAR 7 9;31;40 Pass-port, but Corrective Action Request No 8 a) Noise and Visual Impacts with high scored, but that does not correspond to the SD-matrix and to the results of the feedback round. According to the wind rose in Annex 2 wind from South could impact Geycek, please clarify. CAR 8 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-12

92 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 b) EMC conclusion is not correct, there is investigation result available in the literature that needs to be discussed. c) As for shadow effect, the results of the model calculation by Perfect Wind have to be assessed here. d) The project impact on bird migration roots have to be discussed as well. e) A discussion with civil aviation about limiting number of beacons is not a mitigation measure, please clarify. First Passport Pass-port F.2. Sustainable Development assessment - Toolkit and Toolkit Annex J F.2.1. Have clear benefits in terms of SD been demonstrated? - Local/global environment sustainability - Social sustainability and development - Economic and technological development 40, every category itself is scored positively. F.2.2. The indicators within these three components are set out in the Sustainable Development Assessment Matrix. They do not provide yes or no an- 40 Clarification Request No. 7. a) For all indicators clear evidence has to be given, e.g. in CR 7 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-13

93 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 swers, but a rating of how the project performs against a series of parameters, based on quantitative and/or qualitative assessment. The project s performance must be assessed using the following scoring system (-,0,+): - : Negative impacts, in case negative impact is not fully mitigated. i.e. where there is damage to ecological, social and/or economic systems that cannot be mitigated through preventive (not remedial) measures. 0 : in case impact is planned to be fully mitigated. 0 : no change in impacts + : positive impact terms of references, sources, studies. b) Category 1: Shadow effects and noise impact are not discussed here and the discussion of impact of electromagnetic interferences form power piles is not evident (see CAR 8). c) Category 1: Bird migration is not discussed (see CAR 8). d) Category 3: +2 is not possible for GSv2, furthermore, clear evidence for + scoring is needed, taking into account the low number of employees. First Passport Pass-port F.2.3. Has the Sustainable Development Matrix been included to the document? 40, SDM in correct format was included in the Passport Have the following parameters been included to the passport? Table 1 is applicable to Gold Standard version 2 (Passport) Page A-14

94 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 F.2.4. Air quality Has a mitigation measure identified? Has the relation of the indicator to MDG been described? Has a parameter for indicator been identified? Has a preliminary score been identified? Are justification choices mentioned? Have data sources been mentioned? Have references been provided? 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG parameter for indicator preliminary score justification choices data source provision of references yes F.2.5. Water quality and quantity 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG parameter for indicator preliminary score justification choices data source provision of references yes First Passport Pass-port F.2.6. Soil condition 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG NA parameter for indicator NA preliminary score NA justification choices Table 1 is applicable to Gold Standard version 2 (Passport) Page A-15

95 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 data source NA provision of references NA First Passport Pass-port F.2.7. Other pollutants 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG parameter for indicator preliminary score justification choices data source provision of references yes F.2.8. Biodiversity 40 Data checklist yes/no/na mitigation measure No relation of indicator to MDG No parameter for indicator No preliminary score justification choices No data source provision of references yes See CAR 8 F.2.9. Quality of employment 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG NA parameter for indicator NA preliminary score justification choices yes Table 1 is applicable to Gold Standard version 2 (Passport) Page A-16

96 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 data source provision of references NA F Livelihood of the poor 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG NA parameter for indicator NA preliminary score justification choices data source NA provision of references NA F Access to affordable and clean energy services 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG NA parameter for indicator preliminary score justification choices data source provision of references yes F Human and institutional capacity 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG NA parameter for indicator preliminary score justification choices data source NA provision of references NA F Quantitative employment and income generation 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG parameter for indicator preliminary score justification choices First Passport Pass-port Table 1 is applicable to Gold Standard version 2 (Passport) Page A-17

97 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 F Balance of payments and investments F Technology transfer and technological self-reliance F Matrix: Check all data and statements: Check that existing data and input from the stakeholder consultations and, where necessary, that independent local expert opinions and judgments has been used. data source provision of references NA 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG NA parameter for indicator NA preliminary score justification choices data source NA provision of references NA 40 Data checklist yes/no/na mitigation measure NA relation of indicator to MDG parameter for indicator preliminary score justification choices data source provision of references NA First Passport 40 See CR7 See CR7 Pass-port F Matrix: Public Consultation: 40 See CR7 See CR7 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-18

98 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 Check that the SD indicators are discussed during the stakeholder consultations, as the opinions of people and communities affected by the project represent a key input into the SD assessment. First Passport Pass-port F Matrix: Point of Reference: Check that all changes are to be considered relative to the baseline situation (i.e. without the proposed project) as defined in the project documents. 40 See CR7 See CR7 F Matrix: Scoring Requirements: - Each of the components must have a sub-total score that is non-negative - The total score must be positive - Pre-Screen Checklist to determine necessity of an EIA 40 See CR7 Each of the main categories has a sub-total score that is nonnegative. The total score is positive. There is no necessity to perform EIA, as there is certificate in Annex 5 of PDD NO EIA is required See CR7 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-19

99 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 G. Sustainability Monitoring Plan Toolkit and Annex I - Not for voluntary projects/programs! G.1.1. Has a monitoring plan to monitor all non-neutral parameters, as well as all mitigation measures from the SD assessment been included to the document? G.1.2. Has table I.5 been used for documentation of the parameters? A table has to be included to the passport for each non-neutral indicator and parameter. 40 Clarification Request No. 8. Project specific monitoring standard, as indicated on page 30 of the PDD, is generally not allowed for the GS, please clarify. First Passport CR 8 Pass-port 40 G.1.3. Air quality If the indicator is not included, is justification given? 40 Data checklist yes/no/na No. 1 Indicator Mitigation measure NA Chosen parameter Current situation of parameter No Estimation of baseline situation of parameter no Future project target for parameter NA How Monitoring When By who yes G.1.4. Water quality and quantity 40 Data checklist yes/no/na No. 2 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-20

100 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 If the indicator is not included, is justification given? G.1.5. Soil condition If the indicator is not included, is justification given? G.1.6. Other pollutants If the indicator is not included, is justification given? Indicator yes Mitigation measure NA Chosen parameter yes Current situation of parameter no Estimation of baseline situation of parameter no Future project target for parameter NA How yes Monitoring When yes By who yes 40 Data checklist yes/no/na No. Indicator NA Mitigation measure Chosen parameter Current situation of parameter Estimation of baseline situation of parameter Future project target for parameter How Monitoring When By who 40 Data checklist yes/no/na No. 3 Indicator yes Mitigation measure NA Chosen parameter yes Current situation of parameter No Estimation of baseline situation of parameter No Future project target for parameter NA How Monitoring When By who yes G.1.7. Biodiversity 40 Data checklist yes/no/na No. First Passport See CR7 See CR7 Pass-port Table 1 is applicable to Gold Standard version 2 (Passport) Page A-21

101 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 If the indicator is not included, is justification given? G.1.8. Quality of employment If the indicator is not included, is justification given? G.1.9. Livelihood of the poor If the indicator is not included, is justification given? G Access to affordable and clean energy services Indicator NA Mitigation measure Chosen parameter Current situation of parameter Estimation of baseline situation of parameter Future project target for parameter How Monitoring When By who 40 Data checklist yes/no/na No. Indicator NA Mitigation measure Chosen parameter Current situation of parameter Estimation of baseline situation of parameter Future project target for parameter How Monitoring When By who 40 Data checklist yes/no/na No. Indicator NA Mitigation measure Chosen parameter Current situation of parameter Estimation of baseline situation of parameter Future project target for parameter How Monitoring When By who Table 1 is applicable to Gold Standard version 2 (Passport) Page A-22 First Passport Pass-port 40 Data checklist yes/no/na No.

102 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 If the indicator is not included, is justification given? G Human and institutional capacity If the indicator is not included, is justification given? Indicator NA Mitigation measure Chosen parameter Current situation of parameter Estimation of baseline situation of parameter Future project target for parameter How Monitoring When By who 40 Data checklist yes/no/na No. Indicator NA Mitigation measure Chosen parameter Current situation of parameter Estimation of baseline situation of parameter Future project target for parameter How Monitoring When By who G Quantitative employment and income generation 40 Data checklist yes/no/na No. 4 Indicator yes If the indicator is not included, is justification Mitigation measure NA given? Chosen parameter Current situation of parameter Estimation of baseline situation of parameter No Future project target for parameter How Monitoring When By who G Balance of payments and invest- 40 Data checklist yes/no/na First Passport See CR7 Pass-port Table 1 is applicable to Gold Standard version 2 (Passport) Page A-23

103 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 ment If the indicator is not included, is justification given? G Technology transfer and technological self-reliance If the indicator is not included, is justification given? H. Additionality and Conservativeness H.1. H.1.1. Additionality been Has the correct tool for the demonstration of additionality selected and applied by the PP? No. Indicator NA Mitigation measure Chosen parameter Current situation of parameter Estimation of baseline situation of parameter Future project target for parameter How Monitoring When By who 40 Data checklist yes/no No. 5 Indicator yes Mitigation measure NA Chosen parameter Current situation of parameter Estimation of baseline situation of parameter No Future project target for parameter NA How Monitoring When By who yes 40 Corrective Action Request No. 9: The additionality of the project has to be assessed according to chapter 2.3 of the toolkit. Justify in detail why this step is not applicable here. First Passport CAR 9 Pass-port Table 1 is applicable to Gold Standard version 2 (Passport) Page A-24

104 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 First Passport Pass-port H.1.2. Is the project additional, using the following guidance: 40 See CAR 9 See CAR 9 - Identify the main arguments that have been used by the project proponent to demonstrate additionality - Assess the correctness of the line of argumentation - The argumentation shall also be addressed during the interviews with project stakeholders. - References; check that the references used to demonstrate additionality are up-to-date and reliable - Normal practice in the region; check that the project proponent has compared the proposed project activity to normal practice in the region. This is particularly relevant if similar projects have already been implemented on a commercial basis in the region - Conservative assumptions; check that assumptions (quantitative or qualitative) used to demonstrate additionality Table 1 is applicable to Gold Standard version 2 (Passport) Page A-25

105 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 are conservative? First Passport Pass-port H.2. Conservativeness H.2.1. Can it be confirmed that the baseline has been constructed in a conservative manner? 40 Corrective Action Request 10: See CAR 9 analogous for the subject of conservatives. All factors, default values, approaches, assumptions in the PDD resulting in a conservative approach to define the baseline have to be listed, if applicable. CAR 10 Annex 1 ODA Declaration - Toolkit Annex D Does the Passport include the declaration of non-use of ODA by the PP and the Financier(s)? 40 No, ODA declarations are still missing (see CAR3)., two ODA declarations are included in the last version of Passport See CAR 3 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-26

106 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 Table 2 Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests by validation team CAR1: a) The name of the project owner who is the project developer is not indicated in the passport. b) The max. installed power and the list of power clients in the nontechnical summary do not comply with the information in the passport and PDD; this has to be clarified in the passport and PDD.. CAR2: The selected scale large scale is correct, but it is not CDM, it is VER, please correct. Ref. to table 1 B.1.1 Summary of project owner response Validation team conclusion a) The name of the project owner has been added in the last version of the passport. Project owner and project developer are the same entities. b) A non-technical summary has been drafted for the stakeholder consultation (March 27 th 2008). From this date, new technical data and financial considerations have led the project developer to modify the project configuration (power generation, installed capacity, number of wind turbines and turbine manufacturer). As the total power generation, the number of wind turbines and the installed capacity are lower than those mentioned in the non-technical summary; we considered that these changes have no negative impact for the stakeholders compared to the larger initial configuration. Last versions of PDD and GS passport are now consistent regarding project configuration. Closed. - The name of the project owner is the same as the name of the project developer. - Last version of the PDD and Passport are consistent due to the technical data and project configuration. C.1.1 The GS passport has been modified accordingly. Closed. The type and scale of the project were correctly selected. CR1: In order to check that the project has not been announced before deciding to start C.3.2 Please find here attached again Project Memo GEYCEK Wind Farm (GEY_Bank Memo1) and License (W-GEYE_Received Licence_080623). Closed. The two documents are available to TÜV SÜD, Table 1 is applicable to Gold Standard version 2 (Passport) Page A-27

107 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 with the VER credits, the evidences Project memo Geycek Wind Farm and license according to page 6 of the passport have to be submitted to the DOE. Reply of DOE: The two documents are available to TÜV SÜD, but the technical information in the Project Memo GEYCEK Wind Farm are not identical with the information in the Passport or PDD (example: it is 115MW project, not 150 MW, and there are 46 turbines, not 60). and since the current total installed capacity is lower than the initial one, this change has no significant negative impact on the stakeholders. Answer of PP: After Project Memo GEYCEK Wind farm publication (15 October 2007), new technical data and financial considerations have led the project developer to modify the project configuration (power generation, installed capacity, number of wind turbines and turbine manufacturer). As the total power generation, the number of wind turbines and the installed capacity are lower than those mentioned in the nontechnical summary; we considered that these changes have no negative impact for the stakeholders compared to the larger initial configuration. CAR3: The ODA declaration(s) are not indicated in the Passport (see Annex 1). C.5.1 The two ODA declarations have been added in Annex 1 of the last version of the Passport. Closed. The two ODA declarations are included in the Annex 1 of the GS Passport. CR2: Please clarify how double counting can be excluded. C.5.3 GEYCEK project do not claim Green or White Certificates, or equivalents. Closed. The project does not claim green, white or any other type of renewable energy certificates therefore there is no require- Table 1 is applicable to Gold Standard version 2 (Passport) Page A-28

108 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 CAR4: The GPS coordinates of each turbine have to be indicated in the passport. CAR5: The detailed map of the turbines, indicated in the Passport does not cover the villages in the vicinity, neither three wind speed measuring masts, nor the location of the sub-station. D.1.1 The GPS coordinates of each turbine have been indicated in the last version of the passport D.2.1 Please find here attached the document named W- GEYE_Micrositting. One of the maps introduced in this document has been extracted and added at page 11 of the Passport: ment for the PP, according to the GS rules, to submit any further documents Closed. The GPS coordinates for each of 46 turbines are indicated in the GS Passport. Closed. The sources for both maps are correct, and the maps are proving the information on villages in the project vicinity, three wind speed measuring masts, and substations. Figure 1:Access Center with storage area (yellow), roads (green, blue and orange), substation (red) and electrical lines (brown and black) Please find below a view of page 14/70 of the Wind Guard report (already submitted to TUV-SUD) covering the villages in the vicinity and highlighting the location of the three wind speed measuring masts. Table 1 is applicable to Gold Standard version 2 (Passport) Page A-29

109 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-30

110 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 CAR6: The table in C.1of the Local Stakeholder Consultation Report does not comply with the template, and the parameter human and institutional capacity is missing. The template topic Score in table C.3 has been substituted by Preliminary Score. E.1.1 The table in C.1 has been modified accordingly. The parameter human and institutional capacity is not missing in the current version. Preliminary score has been substituted by score. Closed. Correct template have been used in the in table in the C1 section of the Local Stakeholder Consultation report, as well as parameter Human and institutional capacity have been added. CR3: Has a non-technical summary been provided for participants of the stakeholder consultation meeting? CR4: d) The functions of AL-YEL and ENCEV as well as all other used abbreviations have to be explained in the report. e) The list of stakeholders invited by the EN-CEV letter is not available, please clarify. f) The table in chapter A.1 is not filled yet, please clarify. b) Are evidences about the invitation and comments of NGOs docu- E.1.3 E.1.4, please find attached: - the non-technical summary provided for participants of the stakeholder consultation meeting ( W-GEYE_ISC RNT ). an showing that this document was sent to the GS standard in November ( to Gold Standard about Nontechnical Summary in Turkish language ) a) The functions of AL-YEL and EN-CEV as well as all other used abbreviations are now explained in the new version of the report. a) b) The name of Mikail ARSLAN is mentioned in the letter and this name is the third row of the Invitation tracking table. Please also refer to the column Way of invitation (the wording mail means that a letter has been sent). b) c) The table in chapter A.1. Invitation tracking table has been filled. d)there is no specific evidence about the invitation and comments/recorded of NGOs documented/recorded. Closed. Both documents were provided to TÜV SÜD supporting that the Nontechnical summary in Turkish language was available for the participants of the stakeholder consultation meeting. Closed. a)the AL-YEl and EN CEV abbreviations and functions are explained. b)the list of stakeholders invited is available. c)the table in chapter A1 is filled. d) Filiz Demirayak from WWF and Hilal Atici from Greenpeace have been Table 1 is applicable to Gold Standard version 2 (Passport) Page A-31

111 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 mented/recorded? invited to the meeting. Note: in the sample invitation (p.8 of LSC) there is the mistake on the total installed capacity of the project it is 115MW instead of 150 MW, but as the current installed capacity is lower than the one originally described in the project (150MW), this is to be neglected. CR5: a) The subject of possible impact of turbines on bird migration roots, noise impact, shadow effect and electromagnetic impacts by power lines have not been discussed, please clarify. b) Annex 2 is not part of the report, please clarify. E.1.7 a) Comments related to possible impact of turbines on bird migration rootshave, noise impact and agricultural/live-stock activities around the turbines have been added in Section E.1. Shadow effect and electromagnetic impacts by power lines have not been addressed by stakeholders. Please find attached a document showing the probable migration routes of birds during their migration. Note: this issue has been closed in the Validation protocol. The conclusion was the following: a prediction model on bird migration has been provided. The plant seems in a fairly distance from the migration routes. Moreover the Pre-Assessment Report of Environmental Impact of Ayyıldız and the Document of EIA is not necessary licensed by Ministry of Environment and Forestry confirmed that the project has no significant negative impact. Closed. As the W- GEYE_EIAReport-1 : Environmental Impact Assessment Report of the Geycek Project Site (in Turkish language) done by the company EN CEV in May, 2008 is available to TÜV SÜD, where the detail reseach and discussion on the flora and fauna with the species inventory in the project site area is done, as well as sesonal migration paths for the birds, showing that the position of the turbines is not affecting birds migration routes, and the distance Table 1 is applicable to Gold Standard version 2 (Passport) Page A-32

112 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 The objective of Annex 2 was to be transparent as the stakeholder consultation meeting was held on March 21 st 2008, the sustainable development matrix with the own score of the project participant (introduced after the blind exercise) followed the Gold Standard Version 1 requirements. But as suggested, we deleted Annex 2. Reply of DOE: a) The document showing the probable migration routes of birds is missing. b) Response of the PP is not in the correlation with the request. Annex 2 (containing the participation list to the Stakeholder feedback round) should not be part of the LSC report and have to be deleted from the LSC report. between the turibines is sufficient for the birds to pass throught, the subject of the possible negative effect of the project activity on bird migration can be considered as closed. The study related to the shadow effect is available to TÜV SÜD and the results have been assessed and discussed by the client. Answer of PP: a) Please find here attached the document showing the probable migration routes of birds W-GEYE_ Probable Migration Routes ppt (2 slides). b) Please find attached the last version of the LSC report. Annex 2 of the LSC report has been deleted. Additional request of DOE: Please provide information on the following: - Information on the company which made the study W- GEYE Probable Migration Routes ppt. Akuo Energy - Date of the study - Evidence that the company was hired to do the independent Table 1 is applicable to Gold Standard version 2 (Passport) Page A-33

113 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 study - Comments of the results - Conclusion of the study Additional answer of PP: M. Pierre Pochet confirms Akuo Energy has made this study Saturday 3 January Considering the close relationship between Akuo Energy and Al YEL, Akuo Energy has not been formely hired. The conclusion of the study is that potential birds flying across the Geycek site will have two clear options to avoid the wind turbines. Moreover, please refer to the attached document (W-GEYE_BirdsMigrationRoutes) which show that the Geycek project is not on a bird migration route. Additonal request of DOE on shadow effect: Please provide evidences that the impact of the possible shadow effect by the project activity was considered and assessed. Additional answer of PP: Please find here attached a study related to shadow effect CR6: The feedback round report has to be provided to the DOE as soon as it is available after the comment period. E.2.1 Please find here attached the stakeholder feedback round report. Reply of DOE: The Stakeholder Feedback Round Report has been provided, but it has to be proved that all documents listed in E 2.1 of the protocol were at least for two months publicly available. Closed. Revised documents available on the GS Projects registry are: PDD, Passport, Stakeholder consultation report and stakeholder feedback round report. Table 1 is applicable to Gold Standard version 2 (Passport) Page A-34

114 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 Answer of PP: The Project Participant will upload this week: The last version of the PDD submitted for validation, GS Passport, Non-technical project summary (in Turkish and English Version), Local stakeholder consultation report. Stakeholder feedback Round Report. CAR7: a) The assessment of do not harm has to be done by the PP and not by the stakeholders (see passport page 13). b) The table in the passport is not completely filled, please revise. c) Not all of the 11 categories of Annex H are listed in the passport, please clarify. d) The wording initial stakeholder consultation meeting has to be avoided for the GSv2, that is applicable here.. F.1.1 a) The assessment of do not harm done by the PP has been added in the passport. (Explanation: The stakeholder consultation meeting followed the Gold Standard Version 1 requirements as it was held on March 21 st Appendix E of Manual for project developer (GS-V1) stated about Environmental and Social Impacts Checklist: This list is a guideline on how to do the Initial Stakeholder Consultation and should be completed by the stakeholders. That is why the do not harm (the equivalent of the Environmental and Social Impacts Checklist ) was done initially by the stakeholders.) b) The table in the passport is now completely filled. c) Now all of the 11 categories of Annex H are listed in the passport. The wording initial stakeholder consultation meeting has been avoided from the Passport and the Stakeholder feedback round. Closed. All points from CAR7 have been fulfilled. Do no harm assessment was carried out by PP, following the requirements from the Annex H and including all 11 categories. However TÜV SÜD can only check the formal completeness of the list of the safeguarding principles, an assessment of the PP statements in the Passport is not possible in the lack of guidance/requirements. CAR8: a) Noise and Visual Impacts with F.1.6 Please refer to the last version of the Local Stakeholder Consultation report and to the new version of the GS Passport. The Closed. a) W-GEYE_EIAReport-1 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-35

115 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 high scored, but that does not correspond to the SD-matrix and to the results of the feedback round. According to the wind rose in Annex 2 wind from South could impact Geycek, please clarify. b) EMC conclusion is not correct; there is investigation result available in the literature that needs to be discussed. c) As for shadow effect, the results of the model calculation by Perfect Wind have to be assessed here. d) The project impact on bird migration roots have to be discussed as well. e) A discussion with civil aviation about limiting number of beacons is not a mitigation measure, please clarify. sentence in bold has been added: Generally, noise-related concerns are likely to occur at residences particularly those sheltered from prevailing winds. In the proposed project activity, the nearest village is not sheltered from prevailing winds a major part of the year (north wind in summer). Only the west part of the village could be sheltered from prevailing winds in winter (south wind) but it is not an issue taken into account the distance to the wind farm (cf. Annex 2 and project s micrositing report, available for DOE). (Please refer to Pre-Assessment Report of Environmental Impact of GEYCEK and Document of EIA is not necessary licensed by Ministry of Environment and Forestry.) Please find here attached a document showing the probable migration routes of birds during their migration. Note: this issue has been closed in the Validation protocol. The conclusion was the following: a prediction model on bird migration has been provided. The plant seems in a fairly distance from the migration routes. Please refer to the last version of the Local Stakeholder Consultation report and to the new version of the GS Passport. (This part has been deleted). Reply of DOE: a) Noise and visual impacts have been sufficiently discussed but the document Pre Assessment Report of environmental impact : Environmental Impact Assessment Report of Geycek is now availabe to TÜV SÜD b)information on the impact of Electromagnetic Interference have been provided, and supported with references. c)the study on the impact of shadow effect of the Geycek project activity is now availabe to TÜV SÜD and the results have been commented and discussed by the client. d) The document showing probable migration routs of birds WGEYE_probable migration routes ppt have been delivered to TÜV SÜD, and results commented and discussed. e) Part on the discussion with civil aviation has been deleted from the Passport. Table 1 is applicable to Gold Standard version 2 (Passport) Page A-36

116 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 of Geycek is not available to TÜV SÜD. b) EMC (evidence needed) c) Shadow effect (provide results of modelling) d) The document Probable routs of bird migration is not available to TÜV SÜD e) This is not a mitigation measure in the last version of the Passport Please provide evidence for not existence of endemic species in the project boundary and that there is no habitat disturbance by the project. Answer of PP: a) Please find attached the Pre-assessment Report of environmental impact of GEYCEK. b) Please refer to the new version of the Passport. c) No modelling of shadow effect has been carried out. d) Please find attached the document showing the probable migration routes of birds W-GEYE_ Probable Migration Routes ppt (2 slides). e) The following paragraph has been deleted: All existing Turkishwind farms are painted in red on the previous 6-meters blades to markup daytime and a red light for the night. Nevertheless, AL-YEL Elektrik Üretim A.Ş.discuss with the civil aviation authorities the possibility to limit the number of beacons to avoid the "daisy chain" effect. Additional request of DOE: Please provide evidences that the impact of the possible shadow effect by the project activity was considered and assessed. Table 1 is applicable to Gold Standard version 2 (Passport) Page A-37

117 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 Additional answer of PP: Please find here attached a study related to shadow effect. CR7: a) For all + scorings clear evidence has to be given, e.g. in terms of references, sources, studies. b) Category 1: Shadow effects and noise impact are not discussed here and the discussion of impact of electromagnetic interferences form power piles is not evident (see CAR 8). c) Category 1: Bird migration is not discussed (see CAR 8). d) Category 3: +2 is not possible for GSv2, furthermore, clear evidence for + scoring is needed, taking into account the low number of employees. F.2.2 a) Please refer to the last version of the Local Stakeholder Consultation report and to the new version of the GS Passport. (This part has been deleted). b) Please refer to the last version of the Local Stakeholder Consultation report and to the new version of the GS Passport. (This part has been deleted). c) Please refer to the last version of the Local Stakeholder Consultation report and to the new version of the GS Passport. (This part has been deleted). Please refer to the last version of the Local Stakeholder Consultation report and to the new version of the GS Passport. (This part has been deleted). The proposed project will contribute to the creation of indirect jobs that are hard to estimate. Reply of DOE: a) Evidences in the term of references have been provided for all + scorings b) EMC (evidence needed) c) Bird migration is not discussed (See CAR 8) d) The scoring in the last version of Passport (SD matrix) is done according to the requirements of the GS Ver. 2 Closed. All points from the CR7 have been fulfilled. The references for all + scorings have been provided, EMI have been discussed, as well as bird migration (see CAR8, d). Answer of PP: Please refer to the new version of the Passport. Please find here attached the document showing the probable migration routes of birds W-GEYE_ Probable Migration Routes ppt (2 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-38

118 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 slides). CR8: Project specific monitoring standard, as indicated on page 30 of the PDD, is generally not allowed for the GS, please clarify. CAR9: The additionality of the project has to be assessed according to chapter 2.3 of the toolkit. Justify in detail why this step is not applicable here. G.1.1 Please refer to the last version of the PDD. Closed. Monitoring plan refers to ACM0002. H.1.1 Please refer to the last version of the PDD. Reply of DOE: The answer provided in the last version of the Passport on the issue of additionality is not correct. The additionality has been assessed in the VER protocol. Closed. The statement on the additionality and choice of baseline in the Passport follows the GS rules. Answer of PP: The sentence Not applicable to the proposed project activity. has been replaced by Additionality and the choice of baseline follow Gold Standard guidance. CAR10: See CAR 9 analogous for the subject of conservatives. All factors, default values, approaches, assumptions in the PDD resulting in a conservative approach to define the baseline have to be listed, if applicable. H.2.1 Please refer to the last version of the PDD. Reply of DOE: The answer provided in the last version of Passport on the issue of conservativeness is not correct. Please provide evidences or examples of conservative approach. Closed. The evidences and examples for the conservative approach in the determination of baseline has been demonstated and listed in the Passport. Answer of PP: Table 1 is applicable to Gold Standard version 2 (Passport) Page A-39

119 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 Please refer to the last version of the GS Passport. The following part has been added: GEYCEK Wind Farm Project use a more conservative baseline than all other similar registered project activities in Turkey : Project title Mare Manastır 39.2 MW Wind Farm Project Sayalar 30.4 MW Wind Farm Project Çatalca 60 MW Wind Power Project Yuntdağ 42.5 MW Wind Power Project MAZI-3 30 MW Wind Power Plant Project Grid emission factor in tco 2 /MWh Akbük Wind Farm Project Burgaz Wind Farm Project GEYCEK Wind Farm Project Example of conservativeness: To determine the build margin emission factor, the highest efficiency has been chosen for all natural gas power plants (i.e. 60% for combined cycle power Table 1 is applicable to Gold Standard version 2 (Passport) Page A-40

120 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 plants instead of 39.50% for open cycle or 37.50% for steam turbine). Additional CAR 11: Table 1.5. in the Passport for all nonneutral parameters does not completely comply with the template, missing is Estimation of baseline situation of parameter G.1.2. Table in Section G of the GS Passport template does not mention Estimation of baseline situation of parameter. No Indicator Mitigation measure Repeat for each parameter Chosen parameter Current situation of parameter Future target for parameter Way of monitoring How When Closed. There is incosistency in the Gold Standard templates for the very same table in Section G of the Passport, and Annex I, Table I.5. Therefore, CAR 11 will be closed, as client was following the table template in the Passport template, where the parameter Estimation of baseline situation of parameter is missing. By who Additional CR 9: For the parameters Air quality, Water quality and quantity and Other pollutants, there are missing statements in the line for the Current situation. In the light of this fact it should be clarified how to monitor the positive effect of the project on these indicators. (scoring in the Matrix was positive) G.1.3. & G.1.6. Please refer to the last version of the GS Passport ( ). Additional request of DOE: In the Section G of the GS Passport, Sustainability Monitoring Plan, please provide the following information: Indicator Air quality, line Current situation of the parameter: for the both parameters SO2 and NOx, please clarify the calculations (annual reduction due to project activity) of the impacts of the project activity Indicator Other pollutants, line Current situation of the parameter: for the parameter Particulate matter (PM), please clarify the Closed. The calculations of the annula reductions for the non-neutral indicators Air quality and Other pollutants and their parameters haven been clarified and explained. Table 1 is applicable to Gold Standard version 2 (Passport) Page A-41

121 Gold Standard v2 Validation Protocol Project Title: Geycek Wind Farm Project Date of Completion: Number of Pages: 42 calculations (annual reduction due to project activity) of the impacts of the project activity. Note: please use term Particulate matter not Particle matter. Answer of PP: Please refer to the last version of the GS Passport ( ) 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 Table 1 is applicable to Gold Standard version 2 (Passport) Page A-42

122 Validation of the Geycek Wind Farm Project ANNEX 3: INFORMATION REFERENCE LIST