VALIDATION REPORT. The Republic of Turkey

Transcription

1 VALIDATION REPORT for the GS-VER Project Activity Kocaeli Landfill Gas to Electricity Project in The Republic of Turkey Report No Version No. 01, 10/10/2012

2 I. Project description: Project title: Kocaeli Landfill Gas to Electricity Project Report No.: Host Country: Republic of Turkey Current revision No.: 01 Methodology: ACM0001 Flaring or Use of Landfill Gas, version Annual average emission reductions (estimate): Large Scale Small Scale Date of current revision: 10/10/2012 Date of first issue: 10/10/ ,746 tco 2 e/year GHG reducing measure/technology: Recovery of LFG gas on landfill and utilization of the recovered LFG through gas engines to generate electricity Party Project Participants Party considered a project participant Turkey (Host) Körfez Enerji A.Ş. (PO) No Contract party II. Validation Team: Validation Team Role Full name Affiliation TÜV Rheinland Appointed for Sectoral Scopes (Technical Areas) Team leader Acting Team Leader Local Expert Team Member (Auditor) Technicla Expert Acting Tech. Expert Trainee Auditor Technical Reviewer Expert to TR Trainee TR Yuriy Lozynskyy Germany 1.2, 13.1, 7.1 X Andrea Nüsse Germany n/a X Mr. Gürhan Bahadir Germany n/a X You Cui Germany 1.2, 13.1 X Validation Phases and Validation Status: Desk Review Follow up interviews Resolution of outstanding issues Corrective Actions / Clarifications Requested Full Approval and Submission for Registration Rejected III. Validation Report: Final approval Released Distribution Date: 10/10/2012 TÜV Rheinland No distribution without permission from the Client or responsible organizational unit Unrestricted distribution Version 01 Page 2

3 Executive Summary Validation Opinion The validation team of TÜV Rheinland has been assigned by Körfez Enerji A.Ş. (part of Ortadogu Enerji A.S) to perform the validation of the GS-VER project Kocaeli Landfill Gas to Electricity Project (GS1013). The validation was performed based on UNFCCC criteria for the Clean Development Mechanism (CDM), as well as on requirements of Gold Standard Foundation for GS-VER certification. The scope of the validation is defined as an independent and objective review of the project design document, the project s baseline study, monitoring plan, sustainability assessment, stakeholder consultation and other relevant documents. The information in these documents is reviewed against CDM Validation and Verification Manual (Version 01.2), Kyoto Protocol requirements, CDM Executive Board/UNFCCC rules, Gold Standard Toolkit 2.1 and Gold Standard Requirements 2.1. The report is based on the assessment of the project design document, the Gold Standard passport and the Local Stakeholder Consultation Report and is performed through stakeholder consultations, application of standard auditing techniques including but not limited to document reviews, site visit, and stakeholder interviews, review of the applicable methodology and its underlying formulae and calculations. Validation methodology and process - The validation has been performed as described in the Gold Standard Toolkit 2.1 and constitutes the following steps: - Delivery of initial documents o PDD Kocaeli Landfill Gas to Electricity Project, Version 1 (Date: 08/02/2012) o Local Stakeholder Consultation Report Kocaeli Landfill Gas to Electricity Project Turkey, Version 2 (Upload date to GS Registry: 28/12/2011) o Gold Standard Passport Kocaeli Landfill Gas to Electricity Project, Version 1 (Date: 08/02/2012) o Spreadsheets for Emission reduction calculations, Version 1 (Date: 08/02/2012) - Offer of preliminary validation work plan - Desk review of the initial documents and other relevant documents, which has been provided to the validation team - Audit plan (Date: 17/02/2012) - On-site assessment (Date: 03/04/2012) - Check of essential permits and further documents during the on-site assessment - Communication of initial list of CARs and CLs (Date: 26/03/2012) - Responses to the list of CARs and CLs (Date: 05/06/2012) - Submission of revised documents in accordance to the CARs and CLs (Date: 05/06/2012) - Revision of PP s responses to the CARs and CLs and communication of list of outstanding CARs and CLs, (Date: 16/07/2012) - Submission of revised documents in accordance to the CARs and CLs (Date: 13/08/2012) - Issuance of Draft Validation Report (Date: 04/10/2012) based on outline presented in Annex K of GS Annexes to Toolkit version Issuance of this final validation report version 1 dated 10/10/2012 Validation criteria: The following CDM and GS requirements have been considered: Version 01 Page 3

4 - Article 12 of the Kyoto Protocol, - Modalities and procedures for CDM (Marrakech Accords) - Subsequent decisions by the COP/MOP and CDM Executive Board - Gold Standard Requirements (Version 2.1) - Gold Standard Toolkit (Version 2.1) - Host country criteria - Host country legislation - Criteria given to provide for consistent project operations, monitoring and reporting. - Validation Methodology: The procedures as described in the Clean Development Mechanism (CDM) Validation and Verification Manual (Version 01.2 ) Annex 1 to EB 55 Report and the Gold Standard Toolkit 2.1 for the regular project cycle have been applied by the validation team The host part is the Republic of Turkey, which has ratified Kyoto Protocol on 28/05/2009 and is considered as Annex I party to the United Nations Framework Convention on Climate Change. As the project activity is designed as a voluntary emission reduction project, there will be no other Annex I Party involved in the project. By installing of system for collection of LFG, recovery of LFG gas and utilization of the recovered LFG through gas engines to generate electricity and LFG flaring the project activity will result in reductions of greenhouse gas (GHG) emissions that are real, measurable and give long-term benefits to the mitigation of climate change. The total emission reductions from the project are estimated to be 635,221 t of CO 2e over 7 years of crediting period (to be renewed twice), averaging 90,746 t of CO 2e annually. The emission reduction forecast has been checked and it is deemed likely that the stated amount is achieved given the underlying assumptions do not alter. It is demonstrated that the project is not a likely baseline scenario. Emission reductions attributable to the project are hence additional to any that would occur in the absence of the project activity. The validation did not reveal any information that indicates that the project can be seen as a diversion of ODA funding towards the Republic of Turkey. The monitoring plan provides correct procedures for the monitoring of the project s emission reductions. The monitoring arrangements described in the monitoring plan are feasible within the project design and on the opinion of the validation team the project participants are able to implement the monitoring plan. The validation protocol describes a total of findings which include: 26 Corrective Action Requests (CARs); 10 Clarification Requests (CLs); 0 Forward Action Requests (FARs); and all findings have been closed satisfactorily. TÜV Rheinland concludes that the GS-VER Project Kocaeli Landfill Gas to Electricity Project in the Republic of Turkey, as described in the PDD (Version 3 dated 13/08/2012), meets all relevant requirements for Voluntary Offset Projects under the UNFCCC and the Gold Standard including article 12 of the Kyoto Protocol, the modalities and procedures for CDM (Marrakesh Accords) and the subsequent decisions by the COP/MOP and CDM Executive Board as well as Gold Standard Requirements 2.1 and Toolkit 2.1. Version 01 Page 4

5 The selected baseline and monitoring methodologies (ACM0001, version ) and corresponding tools are applicable to the project and are correctly applied. Therefore TÜV Rheinland requests the registration of the project as a Gold Standard VER project activity. 10/10/2012 Date Mr. Yuriy Lozynskyy Team Leader TÜV Rheinland Energie und Umwelt GmbH Version 01 Page 5

6 Abbreviations CAR CDM CDM EB CER CH 4 CL CO 2 CO 2 e DNA DOE GHG GS IPCC LoA N 2 O NGO ODA PO PP PDD tco 2 e TR UNFCCC VER Corrective Action Request Clean Development Mechanism CDM Executive Board Certified Emission Reduction(s) Methane Clarification request Carbon dioxide Carbon dioxide equivalent Designated National Authority Designated operational entity Greenhouse gas(es) Gold Standard Intergovernmental Panel on Climate Change Letter of approval Nitrous oxide Non-governmental Organisation Official Development Assistance Project Owner Project proponent Project Design Document Tonnes of CO 2 equivalents TÜV Rheinland United Nations Framework Convention on Climate Change Voluntary Emission Reduction(s) Version 01 Page 6

7 TABLE OF CONTENTS 1 INTRODUCTION Objective Scope 8 2 METHODOLOGY Desk Review of the Project Design Documentation Follow-up Interviews with Project Stakeholders Resolution of Outstanding Issues Internal Quality Control Validation Team 17 3 VALIDATION FINDINGS Approval and Participation Project eligibility under Gold Standard Project Description Baseline and Monitoring Methodology Additionality GHG Emission Reductions Sustainability Assessment Environmental Impact Assessment Stakeholder Consultation Monitoring 35 APPENDIX A Table 1: Validation requirements (based on the GS Toolkit, GS Requirements and their relevant Annexes) Table 2: List of Requests for Corrective Action (CAR) and Clarification (CL) APPENDIX B: Certificates of Competence Version 01 Page 7

8 1 INTRODUCTION Körfez Enerji A.Ş. (project owner) has commissioned TÜV Rheinland to perform a validation of the Gold Standard VER Project Activity Kocaeli Landfill Gas to Electricity Project (hereafter called the project ) in the Republic of Turkey. This report summarises the findings of the validation of the project, performed on the basis of UNFCCC criteria, Gold Standard criteria for Voluntary Emission Reduction (VER) Projects and host country criteria, as well as criteria given to provide for consistent project operations, monitoring and reporting. The term UNFCCC criteria refers to Article 12 of the Kyoto Protocol, the Clean Development Mechanism (CDM) modalities and procedures or the simplified modalities and procedures for small-scale CDM project activities (as applicable) and the subsequent decisions by the CDM Executive Board (EB). 1.1 Objective The purpose of a validation is to have an independent third party assessment of the project design. In particular, the project's baseline, monitoring plan, and the project s compliance with relevant UNFCCC, Gold Standard and host Party criteria are validated in order to confirm that the project design, as documented, is sound and reasonable and meets the identified criteria. Validation is a requirement for all voluntary emission reduction projects under the Gold Standard and is seen as necessary to provide assurance to stakeholders of the quality of the project and its intended generation of verified emission reductions (VERs). 1.2 Scope The validation scope is defined as an independent and objective review of the project design document (PDD), the local stakeholders consultation report (LSC report) and the Gold Standard passport (GS passport). The PDD is reviewed against the relevant criteria (see above) and decisions by the CDM Executive Board, including the approved baseline and monitoring methodology. The LSC report and the GS passport are reviewed against the relevant criteria released by the Gold Standard Foundation. The validation team, based on the recommendations in the Clean Development Mechanism Validation and Verification Manual (Version 01.2) and the Gold Standard Toolkit 2.1, has employed a risk-based approach, focusing on the identification of significant risks for project implementation and the generation of VERs. The validation is not meant to provide any consulting towards the project participants. However, stated requests for clarifications and/or corrective actions may have provided input for improvement of the project design. 2 METHODOLOGY The validation consists of the following four phases: (1) Desk review of the project design documents. (2) On-site visit and follow-up interviews with project stakeholders and local stakeholders. (3) Resolution of outstanding issues and the issuance of a draft validation report and opinion. (4) Internal review and issuance of the final validation report and opinion The following sections outline each step in more detail. Version 01 Page 8

9 2.1 Desk Review of the Project Design Documentation The following table outlines the documentation reviewed during the validation: Ref No. Reference Document /1/ CDM Project Standard Version 01.0 EB 65 Annex 5 /2/ CDM Project Cycle Procedure Version 01.0 EB 65 Annex 32 /3/ PDD Form for CDM Project Activities version 3 - EB 25, Annex 15, 26 July 2006 /4/ ACM0001 Flaring or Use of Landfill Gas, version /5/ Combined tool to identify the baseline scenario and demonstrate the additionality, version /6/ Tool to determine project emissions from flaring gases containing methane, version 01 /7/ Tool to determine the mass flow of a greenhouse gas in a gaseous stream, version /8/ Tool Emissions from solid waste disposal sites, version /9/ Tool to calculate the emission factor for an electricity system, Version /10/ Tool to calculate baseline, project and/or leakage emissions from electricity consumption, version 01 /11/ Guidelines on Common Practice version 01.0, Annex 12 of EB 63 /12/ CDM Validation and Verification Standard (Version 02.0, EB 65, Annex 4). /13/ EB47 Glossary of CDM terms, Version 5.0 /14/ EB7, Annex 4 Report of the seventh meeting of the executive Board /15/ Gold Standard Requirements Version 2.1 /16/ Gold Standard Toolkit Version 2.1 /17/ Gold Standard Annex C Guidance on Project Type Eligibility to Toolkit Version 2.1 /18/ Gold Standard Annex D ODA Declaration Template to Toolkit Version 2.1 /19/ Gold Standard Annex H Guiding questions for Do No Harm Assessment to Toolkit Version 2.1 /20/ Gold Standard Annex I Guidance on Sustainability Assessment to Toolkit Version 2.1 /21/ Gold Standard Annex J Guidance on Stakeholder Consultation to Toolkit Version 2.1 /22/ Gold Standard Annex K Outline of the Validation and Verification Report to Toolkit Version 2.1 /23/ Gold Standard Annex Q Gold Standard Local Stakeholder Consultation Report Template to Toolkit Version 2.1 /24/ Gold Standard Annex R Gold Standard Passport to Toolkit Version 2.1 /25/ /26/ PDD of Kocaeli Landfill Gas to Electricity Project i. Version 01, Date 07/02/2012 ii. Version 02, Date 04/06/2012 iii. Version 03, Date 13/08/2012 Gold Standard Passport of Kocaeli Landfill Gas to Electricity Project i. Version 1, Date 08/02/2012 Version 01 Page 9

10 /27/ /28/ ii. Version 2, Date 04/06/2012 iii. Version 3, Date 06/08/2012 Gold Standard LSC report of Kocaeli Landfill Gas to Electricity Project i. Version 1, Date 07/03/2011 ii. Version 2, Date 08/02/2012 iii. Version 3, Date 04/06/2012 iv. Version 4, Date 06/08/2012 Emission reduction calculation of Kocaeli Landfill Gas to Electricity Project Version 1, Date 08/02/2012 Version 2, Date 04/06/2012 Version 3, Date 06/08/2012 Document /29/ Board Decision on consideration of carbon assets dated 01/06/2010 /30/ EMRA generation licence dated 06/10/2011 /31/ Container purchase agreement dated 22/03/2011 /32/ Letter from TÜRK Ekonomi Bankasi A.S. regarding project financing dated 03/02/2012 /33/ /34/ /35/ /36/ /37/ /38/ /39/ Declaration of Non-use of Official Development Assistance by Project Owner (ODA Declaration) Distribution System Usage Agreement between Körfez Enerji A.Ş. and Sakarya Elektrik Dagitim A.S. dated 07/12/2011 Distribution System Connection agreement between Körfez Enerji A.Ş. and Sakarya Elektrik Dagitim A.S. dated 07/12/2011 Right use agreement with IZAYDAS A.S. regarding Sloklar landfill in Kocaeli dated 13/07/2010 Municipal Zoning approval, Kocaeli Metropolitan Municipality Housing and Urban Development (Construction permit) dated 17/03/2011 State Acceptance Permit for Solaklar LFG plant issued by Built Ministry of energy and natural resources, Directorate for energy works dated 02/03/2012 Directorate of Environment and Forestry (CED and Planning Branch Office): Letter of compliance with local environmental regulations (exemption letter) dated 02/06/2011 /40/ EIA certificate dated 17/09/2010 /41/ Set of calibration protocols for measuring equipment (electricity meters etc) /42/ /43/ Lay-out of LFG plant installed on Solaklar landfill and electricity distribution system dated November 2011 LFG evaluation report prepared by HAASE Energietechnik AG & Co. KG for Solaklar and Dilovası landfill sites in Kocaeli. /44/ Engine Technical Specification for 1200 kw el, MWM /45/ /46/ Environmental Map published by Environmental Inventory Head Department under Ministry of Environment and Forestry, 2004 Yenice, M.K.,, Doğruparmak, S. C., Durmuşoğlu, E. (2009) Kocaeli Province Waste Charaterisation Report. Published on TÜRKAY 2009 Türkiye de Katı Atık Yönetimi Sempozyumu /47/ List Power plants connected to the national grid under the capacity range of 1.2 MW- 3.6 MW Version 01 Page 10

11 /48/ /49/ /50/ /51/ Annual Production Capacity of Turkey in , prepared by TEIAS, dated October 2010 Annual Production Capacity of Turkey in , prepared by TEIAS, dated November 2011 Annual Development of Electricity generation consumption and losses in Turkey ( ) prepared by TEIAS Annual Development of Turkey s electricity generation by primary energy sources ( ) prepared by TEIAS /52/ Photos of Flow meter for flare and gas analyzer /53/ Copy of the local newspaper Kocaeli Gazetesi, dated 23/11/2010 /54/ Copy of the local newspaper Özgür Kocaeli, dated 24/11/2010 /55/ Pictures of the 1st LSC meeting, dated 01/12/2010 /56/ Pictures of the 2nd LSC meeting, dated 08/07/2011 /57/ /58/ Copy of Non-Technical Summary of the Kocaeli landfill gas to electricity project presented on LSC meetings Set of stakeholders invitation s, relevant letters and fax to relevant stakeholders to 1st and 2nd LSC meeting, dated 12/11/ /11/2010 /59/ Set of copies of evaluation forms from participants of 1st and 2nd LSC meeting /60/ Copy of blind sustainable development matrix /61/ Participant List of 1st LSC meeting, dated 01/12/2010 /62/ Participant list 2nd LSC meeting, dated 08/07/2011 /63/ Documents related to SFR (GS passport, PDD and LSC report) published on /64/ sent to stakeholders during SFR, dated 01/05/2012 /65/ Türkiye Cumhuriyet Merkez Bankasi (2011) Financial Stability Report, Volume 12, Chapter II /66/ Turkish Electricity Transmission Corporation; Research Planning and Coordination Department (2011) Turkish electrical energy 10-year generation capacity projection ( ) /67/ Turkish National Grid Line Diagram ( /68/ /69/ Turkish electricity transmission corporation research planning and coordination department (2009) Turkish electrical energy 10-year generation capacity projection ( ) TEIAS Electricity generation & transmission statistics of turkey 2012; Annual Development of Turkey s Gross Electricity Generation of Primary Energy Resources ( ) /70/ Turkish Constitutional Law, Materials in English by Kemal Gözler /71/ Labour Law, Law No: 4857, Date of adoption 22/05/2003 /72/ Trade Unions Act, Law No. 2821, Date of enactment 05/05/2003 /73/ Law on Protection of Cultural and Environmental Assets, Law No: 2863, Date of adoption 21/07/1983 /74/ Universal Declaration of Human Rights /75/ Communiqué Regarding the Meters to be used in the Electricity Market, TEIAS /76/ ELECTRICITY MARKET BALANCING AND SETTLEMENT REGULATION (2004) TEIAS Version 01 Page 11

12 /77/ /78/ /79/ Electricity Market Law [Law Number: 4628 Ratification Date: Enactment Date: ] Law on Utilization of Renewable Energy Resources for the Purpose of Generating Electricity Energy [Law Number: 5346 Ratification Date: Enactment Date: ] Environmental Law [Law Number: 2827 Ratification Date: Enactment Date: ] /80/ Regulation on Solid Waste Control [Last updated on ] /81/ Regulation on Managed Waste Land Filling [Regulation number Enactment Date: ] /82/ Turkish Statistics Institute / Main solid waste indicators of municipalities /83/ /84/ World Bank 2007: Landfill Gas Capture; Design and Actual Performance and the Future for CDM Projects Kose, Ayaz, Koruglu 2007: Waste Management in Turkey National Regulations and Evaluation of Implementation Results: (Accessed 13/06/2012) /85/ TEIAS Generation and Transmission Statistics of Turkey 2010 /86/ IPCC 2006 Guidelines for National Greenhouse Gas Inventories /87/ Kocaeli Provincial Environment Annual Report (2006) /88/ /89/ /90/ /91/ TEIAS (Turkish Electricity Transmission Company) The distribution of gross electricity generation by primary energy resources and the electricity utilities in Turkey (2008, 2009, 2010). TEIAS (Turkish Electricity Transmission Company) Fuels consumed in thermal power plants in Turkey by the electricity utilities ( ) TEIAS (Turkish Electricity Transmission Company) Heating values of fuels consumed in thermal plants in Turkey by the electricity utilities ( TEIAS (Turkish Electricity Transmission Company) Generation units put into operation in 2008; 2009; 2010 Version 01 Page 12

13 2.2 Follow-up Interviews with Project Stakeholders TÜV Rheinland validation team carried out an on-site visit of the project on 03/04/2012 and performed interviews with project representatives, carbon consultant, local authorities and relevant local stakeholders: Date Name Organization Topic 03/04/2012 Ömer Akyürek OakDanısmanlık Project start; Project implementation; Local permits and local requirements Status of project preparation and permits; Applied project technology Physical conditions Project history Project barriers Project status Discussion on additionality, baseline scenario and emission reduction calculation; Feasibility study; Environmental and social impacts and/or community benefits; Environmental impact assessment requirements Information on stakeholders consultation process Meetings with local stakeholders and visit to construction site; Financial issues; Supporting documents; 03/04/2012 Mr. Ata Ceylan, Chairman Yusuf K. Gülüt, Consultant Fatih Özgün, Project Manager Mr. Ilker Sel, Project Manager Ortadogu Group General project perception; Project implementation; Local permits and local requirements; Licensing procedure; Financial issues and project additionality; Supporting documents; Awareness of local stakeholders and environment; Meeting with local stakeholders and visit construction site; Contribution to the regional sustainable development; Training of the employees during the construction as well as operation phase Calibration of monitoring equipment Version 01 Page 13

14 03/04/2012 Ali Uysal Hüseyin Dincel Orhan Ilhan Sebakan Ataman Inhabitants of Durhasan Village 03/04/2012 Burhan Tuğtekin Muhtar (Headmen) of Durhasan village 03/04/2012 Murat Şener Operator engineer at Solaklar LFG plant Knowledge on and perception about renewable energy generation and in particular electricity generation from LFG plant Community opinion on this type of project; Awareness about the project and involvement in LSC meetings Sustainable contribution from the PO to the municipality; Personal attitude to the proposed project; Comments and concerns of the local people Follow up local stakeholder consultation process; Attitude of the village residents to the project; Impacts to the village residents, Concerns about project impacts to the environment Impact of the project on the regional development Comments and concerns of the local people; Measures of project owner to contribute to sustainability of the region Local circumstances Experience of the village residents with the existing hydro power plants (upstream); Communication between the PP and the headman; Communication between the PP and village residents Knowledge about the project and the renewable energies; Attitude to the project; Project s impact on the residents of the near villages; Project impact on the regional environment and economy; Projects contribution to the sustainable development of the region; LSC meeting; Health and safety trainings. Version 01 Page 14

15 2.3 Resolution of Outstanding Issues The objective of this phase of the validation is to resolve any outstanding issues which need to be clarified prior to TÜV Rheinland s positive conclusion on the project design. In order to ensure transparency a validation protocol is customised for the project. The protocol shows in transparent manner criteria (requirements), means of verification and the results from validating the identified criteria. The validation protocol serves the following purposes: - It organises, details and clarifies the requirements, which a Gold Standard project is expected to meet; - It ensures a transparent validation process where the validator will document how a particular requirement has been validated and the result of the validation. The validation protocol consists of three tables. The different columns in these tables are described in the figure below. The completed validation protocol for this project, consisting of CDM validation checklist and GS specific checklist, is enclosed in Appendix A to this report. Findings established during the validation can either be seen as a non-fulfilment of Gold Standard criteria or where a risk to the fulfilment of project objectives is identified. Corrective action requests (CAR) are issued, where: i) Mistakes have been made with a direct influence on project results; ii) CDM, GS and/or methodology specific requirements have not been met; or iii) There is a risk that the project would not be accepted as a GS-VER project or that emission reductions will not be certified. A request for clarification (CL) may be used where additional information is needed to fully clarify an issue. A forward action request (FAR) is raised during validation to highlight issues related to project implementation that require review during the first verification of the project activity. FARs shall not relate to the GS requirements for registration. Version 01 Page 15

16 Validation Protocol Table 1: Validation requirements Checklist Question Reference Means of verification (MoV) The various UNFCCC as well as GS requirements as specified in the VVM and Chapter 3 Validate of the GS Toolkit 2.1, respectively, are linked to checklist questions the project should meet. The checklist is organised in different sections, following the logic of the VVM and of the Chapter 3 Validate of the GS Toolkit 2.1 Gives reference to documents where the answer to the checklist question or item is found. Explains how conformance with the checklist question is investigated. Examples of means of verification are document review () or interview (I). N/A means not applicable. Comment The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. Draft and/or Final Conclusion This is either acceptable based on evidence provided (), or a corrective action request (CAR) due to noncompliance with the checklist question (See below). A request for clarification (CL) is used when the validation team has identified a need for further clarification. Validation Protocol Table 2: List of Requests for Corrective Action (CAR) and Clarification (CL) Draft report clarifications and corrective action requests Ref. to checklist question in table 2 Summary of project owner response Validation conclusion If the conclusions from the draft Validation are either a CAR or a CL, these should be listed in this section. Reference to the checklist question number in Table 2 where the CAR or CL is explained. The responses given by the project participants during the communications with the validation team should be summarised in this section. This section should summarise the validation team s responses and final conclusions. The conclusions should also be included in Table 2, under Final Conclusion. Table 3: List of forward action requests (FARs) FAR number Forward action request (FAR) to be raised during validation to highlight issues related to project implementation that require review during the first verification of the project activity. FARs shall not relate to the GS requirements for registration. Reference Reference to the checklist question number in Table 2 where the CAR or CL is explained. Summary of project owner response The responses given by the project participants during the communications with the validation team should be summarised in this section. Validation team conclusion This section should summarise the validation team s responses and final conclusions. The conclusions should also be included in Table 2, under Final Conclusion. 2.4 Internal Quality Control The draft validation report including the initial validation findings and their handling by the audit team underwent a technical review before being submitted to the project participants. The technical review was Version 01 Page 16

17 performed by a technical reviewer qualified in accordance with TÜV Rheinland s qualification scheme for CDM validation and verification that meets the criteria of EB guidelines for qualification. The final validation report underwent a technical review by a qualified independent reviewer before requesting registration of the project activity if the validation opinion is positive and recommends such an action. 2.5 Validation Team Validation Team Role Full name Affiliation TÜV Rheinland Appointed for Sectoral Scopes (Technical Areas) Team leader Acting Team Leader Local Expert Team Member (Auditor) Technicla Expert Acting Tech. Expert Trainee Auditor Technical Reviewer Expert to TR Trainee TR Mr. Yuriy Lozynskyy Germany 1, 7, 13 X Ms. Andrea Nüsse Germany N/A X Mr. Gürhan Bahadir Germany N/A X Mr. You Cui Germany 1,13 X 3 VALIDATION FINDINGS The findings of the validation are stated in the following sections. The validation criteria (requirements), the means of verification and the results from validating the identified criteria are documented in more detail in the validation protocol in Appendix A. The final validation findings relate to the project design as documented and described in the revised and resubmitted Project Design Documentation, LSC report and GS Passport, and corresponding emissison reductions spreadsheet. 3.1 Approval and Participation The below table summarizes the project participants and parties involved. Despite of the previous ratification of the Kyoto Protocol by Turkey on 28 May 2009 Turkey has not yet set up a Designated National Authority or Focal Point, which issues official Letter of Approvals for greenhouse gas emission reduction projects. In addition, the project participants provided a written and signed declaration that no financing provided in connection with the proposed project has come from or will come from ODA (see Declaration of Non-use of Official Development Assistance by Project Owner /33/) Version 01 Page 17

18 Project participants Parties involved Körfez Enerji A.Ş. The Republic of Turkey (host) APPROVAL LoA received Date of LoA Reference to document LoA received from Validation of authenticity PARTICIPATION Party is party to Kyoto Protocol Voluntary participation Project contribution to SD N/A N/A N/A N/A N/A Yes Date of ratification: 28/05/2009 Date of entry into force: 26/08/2009 Yes Yes Refer to the SD matrix (GS Passport /26/) 3.2 Project eligibility under Gold Standard Project eligibility for the Gold Standard All Gold Standard projects must be additional, contribute to sustainable development and result in real, measurable and verifiable permanent emission reductions. Criteria fulfilled Yes No Determination by the validation team The proposed project activity is additional, what is demonstrated by the additionality analysis presented in PDD in Section B.4. and the review by validation team of appropriate supporting evidences listed in PDD. The emission reductions are calculated in a traceable and transparent matter, applying conservative default values and assumptions and correct data. This can be confirmed by the validation team via inspection of emission reductions calculation sheet Version 3. After the review of supporting evidences- PDD, LSC report, Gold Standard Passport and supporting evidences (/53/-/64/) and the interviews hold as specified in Section 2.2. the validation team confirms that the project contributes to sustainable development. Version 01 Page 18

19 Project eligibility for the Gold Standard Previous announcement statement Host country - Gold Standard VER project activities may be located in any host country or state. Where host countries or states have caps on GHG emissions, projects shall only be eligible if the Project Proponent has provided the Gold Standard Foundation with satisfactory assurances that an equivalent amount of allowances will be retired to back-up the GS VERs issued. Eligible project gases - Only Carbon Dioxide (CO 2 ), Methane (CH 4 ) and/or Nitrous Oxide (N 2 O) are eligible for Gold Standard crediting. Project type Only two categories of project activities are eligible for Gold Standard registration: 1) Renewable Energy Supply and 2) End-use Energy Efficiency Improvement project activities. Project scale - Gold Standard VER project activities may be large-scale every project exceeding the small scale boundary, small-scale - renewable energy project, capacity < 15MW, or micro-scale any eligible project, reduction <5,000 tco 2,eq per annum). Project cycle regular project cycle retroactive project cycle Criteria fulfilled Yes No Yes No Yes No Yes No Yes No Yes No Determination by the validation team The proposed project activity was not previously announced to go ahead without the revenues from carbon credits. The prior consideration of the project, which also regards revenues from carbon credits is dated to 01/06/2010 as per Board Decision on Consideration of Carbon Assets /29/ The Republic of Turkey is the host country, and it has ratified the Kyoto Protocol on 28 May 2009; however it has no cap for GHG emissions. Proposed project activity reduces CO 2 - emissions from electricity generation, as demonstrated within the spreadsheets on emission reductions calculation /28/ and stated in the PDD /25/. The proposed project activity refers to renewable energy supply since it is utilizes renewable energy landfill gas (LFG) of ca. 2,4 MW e, as confirmed by the EMRA generation licence /30/ and observed during the on-site visit. Based on the feasibility study report /43/, EMRA generation licence /30/ and EIA certificate /40/, the validation team confirms that the proposed project activity corresponds to large-scale GS-VER activity, since there is a possibility that the emission reductions will exceed the 60k CO 2e threshold set under the CDM rules for the small scale project activities. PP follows the regular project cycle for GS registration. It is proved that the start of construction (22/03/2011) took place after the initial Local Stakeholders Consultation meeting (01/12/2010). Version 01 Page 19

20 Project eligibility for the Gold Standard Project activity finance - ODA declaration Criteria fulfilled Yes No Determination by the validation team The signed ODA declaration /33/ is attached to the GS Passport as Annex 1 and provided to the validation team. 3.3 Project description The description of the project is provided in the PDD for the project. The Project Design Document is based on the currently available CDM-PDD template Version 3 in affect as of 22/12/2006 and is completed in accordance with the applicable guidance documents. Kocaeli Landfill Gas to Electricity Project (hereafter referred to as the Proposed Project ) developed by Körfez Enerji A.S. (hereafter referred to as the Project Participant ) is a landfill gas recovery and utilization project at the site of Solaklar Landfill Area in Solaklar District, Kocaeli Province, Turkey. Coordinates of the project are: Latitude: 40 47'14.83"N, Longitude: 30 1'33.60"E. It is estimated that the LFG will support approximately 2 MW of installed capacity, which will be covered by installing two gas engines with a nominal capacity of 1.2 MW each. Any excess of LFG gas will be flared in an enclosed flare system. It is expected that the electricity generation will reach approximately to 15,000 MWh/year and will be delivered to the national electricity system through a transformer substation. 2 sets of gas engines with a 1.2 MW capacity each will be installed within the scope of the project activity. The gas engines are TCG2020 type engine manufactured by the Berman Company MWM GmbH, specifically used for electricity generation from landfill gas. An enclosed flare system will be installed to burn the excess LFG in a controlled environment. Solaklar Landfill Area, on which the project s LFG plant is constructed, has been built in 1997 as a sanitary landfill area under the responsibility of the company IZAYDAS and is the biggest landfill area in Kocaeli Municipality. With a total area of approximately 3 million square meters, the landfill accepts municipal wastes since operated. The landfill area has received an average of 630 ton/day municipal solid waste (MSW), with an accumulated waste storage of approximately 3 million ton. The landfill gas (LFG) is released into the atmosphere without any collection, flaring or utilization till the project activity. On , IZAYDAS has transferred the right of use of the closed lots to the project developer Ortadoğu Enerji. GHG emission reductions will be achieved by three means: - By collection and destruction of methane by power generation, and; - Displacing an equal amount of electricity generated by power plants connected to the electricity System - Methane destruction in enclosed flare system The installed capacity of engines can be confirmed during on-site visit of the project on 03/04/2012, as well via inspection of engine specifications Technical Specification for 1200 kw el, MWM /44/ and interviews hold on-site. The project proponent posses all necessary permits for project construction and operation accordingly to Turkish legislation, what can be confirmed by validation team via desk-review of the documents /29/-/40/ specified in Section 2.1. In addition, Körfez Enerji A.Ş. was confirmed as project participant via inspection by validation team of company registration certificate on-site in the office of the company. Version 01 Page 20

21 PP claims an operational lifetime of the project of 16 years, which is determined as the period between the start date of the the project (22/03/2011) and the validity of the EMRA generation license /30/ (20/10/2026). In accordance with EB47 Glossary of CDM term /13/, the starting date of the project activity is assigned to 22/03/2011, which refers to the agreement on containers purchase /31/, i.e. the first actual commitment to expenditures of PO to the proposed project. The date was confirmed by personal interview with Mr. Ömer Akyürek and Mr. Fatih Özgün during the project on-site visit on 03/04/2012 in Istanbul/ Turkey. The project duration and crediting period is summarized as following: Starting date of the crediting period of the project Expected project operational lifetime Crediting period years 7 years (renewable) In accordance with EB65 Clean Development Mechanism project standard /1/, PP claims a renewable crediting period with length of 7 years with an option to renew the project twice by 7 years, which however naturally shall not extend beyond the operation of the project activity. The starting date of crediting period is appointed to be 01/03/2012. Project description given in the PDD as well as any assumptions related to the PDD and GS passport, incl. assessment of project additionality, estimation of baseline emissions, proper assignment of project boundaries and fulfillment of UNFCCC and GS requirements have been validated on hand of project specific documentation, publicly available studies, reports and data, and personal interviews with responsible people and authorities by implementation of eligible and relevant methodologies, tools and forms and guidance at the time of PDD submission for registration. Based on the preceding statement, TÜV Rheinland validation team considers the project description of the project contained in the PDD and GS Passport to be complete and accurate. 3.4 Baseline and Monitoring Methodology Applicability of the selected methodology to the project activity In the course of validation process, i.e. desk review and on-site-visit, the validation team assessed the information contained in PDD regarding baseline selection and applicability by examining of the following documents: PDD /25/, EMRA Generation License /30/, Feasibility study report /43/, Particularly selected and applied baseline methodology, i.e. ACM0001 Flaring or Use of Landfill Gas, version /4/ Relevant methodological tools Additionally, interviews with project owner (PO) and contracted carbon consultant were performed in order to confirm the outcomes and respond to findings from the initial desk review. Version 01 Page 21

22 The indicative simplified baseline and monitoring methodologies for selected CDM project activity - ACM0001 Flaring or Use of Landfill Gas, version /4/ and underlying tools - Tool to determine project emissions from flaring gases containing methane, version 01 /6/, Tool to determine the mass flow of a greenhouse gas in a gaseous stream, version /7/, Tool Emissions from solid waste disposal sites, version /8/, Tool to calculate the emission factor for an electricity system, Version /9/, Tool to calculate baseline, project and/or leakage emissions from electricity consumption, version 01 /10/ have been selected by the PP as the most relevant ones and have been correctly applied for the proposed project activity. The validation team determined the applicability of methodology ACM0001 (Version ) /4/ and underlying tools to the proposed project considering the methodology- and tools specific conditions, as specified by PP in the final version of PDD version 3 /25/ on pp The validation team has reviewed the Justification criteria listed by project developer in PDD in order to address all applicability criteria of ACM0001 Flaring or Use of Landfill Gas, version /4/ and of applicability criteria of underlying tools. The validation team comes to the conclusion that all appropriate criteria for the usage of ACM0001 (Version ) methodology and underlying tools are met by the project activity and the PP provides sound justification for the methodology and underlying tools application in PDD. Taking into consideration the above mentioned, it is the validation team s opinion that the underlying project meets the applicability conditions of the selected ACM0001 (Version ) methodology and underlying tools. The baseline scenario was defined as following: consolidation of electricity delivered to the grid by the project activity and electricity generated by the operation of grid-connected power plants in Turkey and electricity produced by the new generation sources as reflected in the combined margin (CM) calculations as per emission reduction calculation Tool, ver Additional Greenhouse gas (GHG) emissions within the proposed GS-VER project activity boundary as a result of the implementation of the proposed GS-VER project activity will not occur and thus will in no way contribute to more than 1% of the overall expected average annual emissions reductions, which are addressed by the applied methodology Project Boundary The validation team affirms that the spatial extent of the proposed project boundary was clearly identified to include the landfill area, LFG extraction system, engines, enclosed flare system and grid connection in accordance with the applied methodology ACM0001 (Version ) /4/. The System Connection Agreement for Solaklar LFG plant and electricity network operator /35/ was provided to the validation team. During the on-site visit, PP proved once again that the generated electricity is delivered to the national grid. The geographical and physical project boundary of the project activity was determined by the validation team during the on-site assessment. The coordinates of the project were correctly documented in the PDD. The spatial coordinates of the Solaklar landfill and the Solaklar LFG plant were confirmed by the validation team during the on-site visit through check of coordinates in Internet. After the inspection of Table 1: Summary of greenhouse gases and sources included in and excluded from the project boundary as specified in ACM0001 /4/ methodology and the appropriate assessment of emissions to be included in the project boundary provided by PP in the PDD version 3 on p. 13 the validation team Version 01 Page 22

23 opinion is that all GHG emissions attributable to the baseline and project emissions are identified correctly in PDD. The major source of emissions included in the project boundary in the baseline have been identified CH 4 emissions from decomposition of waste at the SWDS site and CO 2 emissions from electricity consumption. The major source of emissions included in the project boundary in the project have been identified CO 2 emissions from on-site electricity use. The identified project boundary and selected sources of emissions are justified for the project activity. The validation of the project activity did not reveal other greenhouse gas emissions occurring within the proposed GS-VER project activity boundary as a result of the implementation of the proposed project activity which are expected to contribute more than 1% of the overall expected average annual emission reduction, with respect to the methodology applied. In summary, the project boundary was correctly identified in accordance with the methodology ACM0001 (Version ) /4/. All assumptions are appropriately addressed in the PDD Baseline Identification According to ACM0001 Flaring or Use of Landfill Gas version , the baseline scenario is identified using the Combined tool to identify the baseline scenario and demonstrate additionality. In line with the requirements of ACM0001, PP identified following alternatives to project activity, as defined below: - LFG 1: The project activity implemented without being registered as a VER project activity; - LFG 2: Atmospheric release of the LFG or partial capture of LFG and destruction to comply with regulations or contractual requirements, or to address safety and odor concerns; - LFG 3: LFG is partially not generated because part of the organic fraction of the solid waste is recycled and not disposed in the SWDS; - LFG 4: LFG is partially not generated because part of the organic fraction of the solid waste is treated aerobically and not disposed in the SWDS; - LFG 5: LFG is partially not generated because part of the organic fraction of the solid waste is incinerated and not disposed in the SWDS. Since LFG is used for generating electricity for export to the grid, the following alternatives have been also analyzed: E1: Power generated from LFG undertaken without being registered as a VER project activity; E2: Electricity generation in existing or new on-site or off-site renewable based captive power plant; E3: Electricity generation in existing and/or new grid connected power plants; The validation team has reviewed the justification presented by the PP in PDD on the choice of alternatives and confirms that all alternatives for the project were identified and addressed in appropriate and transparent manner. Justifications presented by PP on the exclusion of alternatives from the list presented on p. 15 of PDD were made in complete and correct manner. The PP has identified finally two realistically alternative scenario combinations applicable to the project activity: Version 01 Page 23

24 - Project activity including power generation from LFG without being registered as a GS VER project activity - Atmospheric release of the LFG and electricity would have been generated by the existing grid connected power plants as continuation of the situation before the project activity. Taking into account Turkish legislation and business situation in the country, both alternatives were identified to be in consistency with mandatory laws and regulations and were further analyzed as credible and realistic alternative scenarios to the proposed project activity for further evaluation on identification of the baseline scenario. Since the Combined tool to identify the baseline scenario and demonstrate the additionality version is used to identify the baseline scenario, a barrier analysis has to be conducted to assess which alternative scenarios are prevented by defined barriers. When applying this step, Guidelines for objective demonstration of and assessment of barriers version 01 has been correctly taken into account by PP. As result of analysis of alternatives, the PP has clearly, complete and correctly identified that only one alternative scenario to project activity has not been prevented by barriers: Atmospheric release of the LFG and electricity would have been generated by the existing grid connected power plants as continuation of the situation before the project activity. This scenario also represents the continuation of the situation before the implementation of the proposed project activity. Therefore, in accordance with Combined tool to identify the baseline scenario and demonstrate the additionality version , this alternative as identified in PDD /25/ was correctly identified as the baseline scenario to project activity. The validation team took cognizance of 105 of VVM (version 01.2). The identified baseline scenario most reasonably represents what would occur in the absence of the proposed CDM project activity. All the assumption and data used by the project participants are listed in the PDD and/or supporting documents are provided to the validation team. All documentation relevant for establishing the baseline scenario are correctly quoted and interpreted in the PDD. Assumptions and data used in the identification of the baseline scenario are justified appropriately, supported by evidence and can be deemed reasonable. Relevant national and/or sectoral policies and circumstances are taken into consideration and listed in the PDD. 3.5 Additionality Assessment of additionality, in accordance to the selected methodology ACM0001 (version ) /4/ has to be performed referring to Combined tool to identify the baseline scenario and demonstrate additionality /5/. As per additionality tool /5/, main components of the assessment are: STEP 1. Identification of alternative scenarios; STEP 2. Barrier analysis; STEP 3. Investment analysis (if applicable) STEP 4. Common practice analysis which are thoroughly explored in section B.5 of the PDD /25/. The project proponent has correctly identified two alternatives for the project activity: 1) Project activity including power generation from LFG without Version 01 Page 24

25 being registered as a VER project activity and 2) Atmospheric release of the LFG and electricity would have been generated by the existing grid connected power plants as continuation of the situation before the project activity. Usually in Turkey there is no destruction of methane on the landfills. The municipalities face technological and economical problems, as specified by Kose, Ayaz, Koruglu 2007 /84/. Taking into account also financial risks of the project due to the risks related to estimation of LFG which could be captured, the opinion of the validation team is that the project activity 1) as specified above faces barriers to the implementation. In addition, only carbon revenues have made possible the realization of the project. This opinion of audit team is based on the inspection of agreement between Ortadoğu Enerji and IZAYDAS dated on the use of Solaklar and Dilovası landfills, where the parties will share the amount of emission reductions, and also based on the interviews hold as specified in Section 2.2. Since only one scenario has remained 2) Atmospheric release of the LFG and electricity would have been generated by the existing grid connected power plants as continuation of the situation before the project activity, according to the Combined tool to identify the baseline scenario and demonstrate the additionality version , Step 3 Investment Analysis was not performed. TÜV Rheinland validation team considers that the selected baseline is selected in credible and complete manner. Step 4 of common practice analysis is performed by the PP correctly in line with The Guidelines on Common Practice version Based on the inspection of data in Turkish Electricity System, 10 Year Projection on Electricity Generation Report, and the calculation procedure presented in PDD version 3 (pp ) it can be stated that calculation of factor F (calculated as 0) was made in correct and transparent manner. The choice of applicable geographical area, measures, output and different technologies was made in correct manner. Since project s calculated factor F is 0 and is less than 0,2 and N all N diff is 0 and is less than 3, the validation team concludes that the project activity is not a common practice in Turkey. Based on the above information it is clear that there are no similar project activities in Turkey to the proposed project activity, and LFG extraction and utilization projects are not common practice or the technology is diffused in Turkey, the validation team concludes that proposed project activity is additional. GS VCS consideration As per Glossary of CDM terms /12/, starting date of project activity is the earliest date at which either the implementation or construction or real action of a project activity begins. The starting date shall be identified as the date of commitment to expenditures related to the implementation or related to the construction of the project activity, whereas minor pre-project expenses should not be considered in the determination of the start date. The starting date of the proposed project activity corresponds to the Container purchase agreement dated to 22/03/2011 /31/. The last was confirmed by the analysis of the content of copy of agreement provided to the validation team in the course of the on-site visit, and by the interview with project manager Fatih Özgün. Obviously, the starting date of project activity, as defined under Glossary of CDM terms /13/ and Gold Standard Requirements 2.1 /15/, is not prior to the time of the first LSC meeting (see table on implementation schedule of the project below). Version 01 Page 25

26 The project proponent has indicated, by means of reliable evidence (i.e. Board Decision on consideration of carbon assets /29/), that real actions were taken to secure VER status for the project before project implementation. The early consideration of the VER component has additionally been substantiated by copy of the Letter from TÜRK Ekonomi Bankasi A.S. regarding project financing dated 03/02/2012 which stated that income of VERs is included in the financial model for the project investment analysis and also by further follow-up interviews with PO in the course of the validation process. The presented evidences for early consideration of VER are traceable and thus have been assessed by the audit team as sufficient. Timeline Milestone Determination by the validation team Contract signed between Ortadoğu Enerji and IZAYDAS Inspection of the content of the Right use agreement with IZAYDAS A.S. regarding Saloklar landfill in Kocaeli dated 13/07/2010 /37/ st LSC meeting Inspection of the evidences confirming that LSC took place and the appropriate stakeholders were invited, LSC took in accordance with GS rules and the comments of stakeholders were collected in appropriate manner and addressed. Cf. evidences /53/-/55/, /57/-/61/. In addition, the validation team has hold interviews with local villagers as specified in Section First submission of the LSC Meeting report to GS nd Local Stakeholders Consultation Meeting Inspection of LSC and Gold Registry dates Inspection of the evidences confirming that 2nd LSC took place (as requested by GS) and the appropriate stakeholders were invited, 2nd LSC meeting took in accordance with GS rules and the comments of stakeholders were collected in appropriate manner and addressed. Cf. evidences /56/-/55/, /57/-/61/. In addition, the validation team has hold interviews with local villagers as specified in Section 2.2. April 2011 Start of construction Start of construction date can be confirmed via analysis of the content of copy of Container purchase agreement provided to the validation team in the course of the on-site visit, and by the interview with project manager Fatih Özgün. March 2012 Expected commissioning date Commissioning of the LFG plant and start of operation took place on 02/03/2012, which is confirmed by audit team by inspection of the content of copy of State Acceptance Permit for Solaklar LFG plant issued by Built Ministry of energy and natural resources, Directorate for energy works dated 02/03/2012 and interviews hold on-site with project stakeholders, as specified in Section 2.2. Version 01 Page 26

27 Timeline Milestone Determination by the validation team Stakeholders feedback Round The start of SFR round can be confirmed by the inspection by audit team of content of the /64/ to stakeholders during SFR, dated 01/05/2012 and the documents published on Ortadogu Grup web-site /63/. In conclusion, the staring date of the project activity, as well as the date of publication of the PDD for global stakeholder process was after 02/08/2008, which in accordance with the EB 62 Annex 13 Guidelines on the demonstration and assessment of prior consideration of the CDM (version 04), defines the proposed project activity as new project activity. 3.6 GHG Emission Reductions In summary, the calculation of emission reductions was correctly demonstrated by the PP according to the methodology ACM0001 Flaring or Use of Landfill Gas, version /4/ and its corresponding tools. The table below summaries validation team s determination of emission reduction: All assumptions made for estimating GHG are listed in the PDD All data used by project participants are listed in the PDD Their references and sources are also listed in the PDD Yes No Yes No Yes No PP follows properly the procedure provided by the selected ACM0001 (version ) methodology /4/ and corresponding tools /5/-/10/. Validation team proved by cross-check, that all assumptions made and choice taken are listed, described and evidenced in the PDD /25/ For the calculation of GHG emission reduction, spreadsheets with traceable and referenced cells were provided to the Validation team. The consistency of the PDD and emission calculations spreadsheets was examined by the validation team, who was finally able to confirm that data included in the PDD are correct and sufficient for the replication of project induced emission reductions. For the calculation of GHG emission reduction, excel sheets with traceable and referenced cells were provided to the Validation team. The last confirms that the same data have been listed in the PDD as well. Version 01 Page 27

28 Formulas, parameters, values are complete, accurate, transparent and conservative All the references and documents used are correctly quoted and conservatively interpreted in the PDD Methodology has been applied correctly to calculate project emissions, baseline emissions, leakage emissions and emission reductions All the emissions of baseline scenario can be replicated using information provided in the PDD Yes No Yes No Yes No Yes No The validation team examined formulas, parameters and values, which are employed in GHG emission calculation, on accuracy, transparency and conservativeness, by referring to selected methodology and tools, performing cross check to comparable projects and evaluating the reliability of provided sources. The provided sources of references and documents are tracked so that correctness and proper interpretation are ensured. As a result of the review of PDD /25/ and supplementary emission reduction worksheets /28/, it is confirmed that the selected ACM0001 (version ) methodology /4/ is followed step-wise and applied correctly to calculate project- and baseline emissions as well as emission reductions. Assessing section B and Annex 3 of the PDD /25/ and the supplementary emission reduction worksheets /29/ confirmed the completeness and correctness of data relevant for baseline emissions calculation provided in the PDD /25/ Based on the calculations and results presented in the sections above the implementation of the project activity will result in conservative average ex-ante estimation of emission reduction calculated to be 90,746 tco 2e per year on average during the first crediting period. All assumptions and data used by the project participants are listed in the PDD and/or supporting documents, including their references and sources. All documentation used by the project participants as the basis for assumptions and source of data is correctly quoted and interpreted in the PDD. All values used in the PDD are considered reasonable and conservative in the context of the proposed CDM project activity. The simplified methodology has been applied correctly to calculate project emissions, baseline emissions, leakage and emission reductions. All estimates of the baseline, project and leakage emissions can be replicated using the data and parameter values provided in the PDD. As result, it can be confirmed, making conservative assumptions and with the reasonable, but not absolute, level of assurance, that the indicated below amount of emissions reductions ist estimated in reliable and conservative mannercan and can be achieved by the project activity over the first crediting period: Version 01 Page 28

29 3.7 Sustainability Assessment The proposed project activity is a voluntary emission reduction project and as such no letter of Approval (LoA) is required in order to confirm that the project contributes to the sustainable development of the host country, i.e. the Republic of Turkey. Even though the host country has no relevant national authority to issue the LoA, it is required by the Gold Standard that the National Authority for Environment and Forestry is formally informed about the proposed project activity. In accordance with the GS Requirement 2.1, PP provided accurately filled and referenced Do-No-Harm matrix in the LSC Report. The relevance of the 11 proposed safeguarding principles to the project are discussed and it was demonstrated by means of national and international legislation that the project activity is not in abuse to the human rights, labour standards, environmental protection, anti-corruption or any other additional critical issue. The appropriateness of the principles and scoring was discussed during the on-site assessment with PP. The validation team confirms the low risk of the proposed project activity to previously mentioned principles. The assessment was supported by references to national laws, such as the Turkish Constitutional Law /45/, Labour Law /46/ Trade Union Act of Turkey /47/ and Law on Protection of Cultural and Environmental Assets /48/, Law on environmental protection as well as to international declarations such as the Universal Declaration of Human Rights /49/ and others. Sustainable development caused or advantaged by the proposed project is crucial issue of the Gold Standard Principles. As per Gold Standard Toolkit 2.1 and Annex I, PP completed sustainable development matrix (SDM), complemented by scoring of the chosen parameters and explanation on their appropriateness and record. In the course of review of GS passport /26/ and LSC report /27/, it was observed that sustainable development matrix is thoroughly explored. All indicators predefined by the Gold Standard are scored and justification of Version 01 Page 29

30 the scores is provided. For the development of sustainability monitoring plan PP considers all non-neutral and mitigated indicators and indicated the most relevant parameter for each indicator, the baseline and the target. The appropriateness of selected parameters for assessing the impact of project on the indicators, the frequency of monitoring and the feasibility of the proposed plan was thoroughly discussed with the PP during the on-site assessment. The validation team attests that the consolidated sustainability matrix reflects accurately the local stakeholders and the PP s own assessment of the project activity against the 12 indicators grouped in 3 categories as prescribed in Annex I of the Gold Standard. All the assumptions used to define the score values have been reviewed by the validator, based on submitted documentation and the on-site visit made during the validation of the project. These criteria are correctly demonstrated by the PP in a conservative way without any overestimation of any of the indicators and are supported with appropriate data. The results of the consolidated sustainable development matrix are summarized as following: Indicator Scoring Validation of the indicators by the validation team Air quality Water quality and quantity Soil condition Other pollutants (i.e. Noise) The project activity collect and destroy LFG, which, according to the ACM0001, leads to CH 4 destruction and, correspondingly, causes CO 2e emission reductions. Also, during on-site visit validation team has asked the inhabitants of the Durhasan village (see Section 2.2) whether any improvements in air quality were observed, and most of them agreed that the amount of days on which they noted unpleasant odour from the landfill was reduced after the implemntation of the project activity. In the project activity, the leachate built up in the gas collection wells will be extracted with pneumatic pumps, which will then be transferred to the water treatment plant for processing. There will be no change in the baseline situation this can be confirmed by interviews by the validation team with Mr. Murat Şener, Operator engineer at Solaklar LFG plant and Mr. Fatih Özgün, Project Manager of Ortatogu Group. No other impacts of project activity on Water quality and quantity was observed by validation team. It can be confirmed by the interview with Mr. Murat Şener, Operator engineer at Solaklar LFG plant and Mr. Fatih Özgün, Project Manager of Ortatogu Group that, similar to the baseline situation, exist leachate collection system prevents contamination of the soil layers below the landfill. This is also confirmed by visual observation of the landfill body on-site. Besides leachate, no other impacts of project activity on soil conditions was observed by validation team. The project has no significant emissions of other pollutants. Althogh some noise from generator sets, which will be created by project activity is not dignificant, and the nearest houses are located too far away to be impacted in any significant manner. This can be confirmed by the validation team by the interviews hold with Mr. Murat Şener, Operator engineer at Solaklar LFG plant and Mr. Fatih Özgün, Project Manager of Ortatogu Group and the inhabitants of the Durhasan village (see Section 2.2), as well by observations Version 01 Page 30

31 made during on-site visit of the project. Biodiversity Quality of employment Livelihood of the poor Access to affordable and clean energy services Human and institutional capacity Quantitative employment and income generation The project does not demand new space and is based on the territory of exsited LFG area. No specific or significant natural habitat is present in close proximity of the project. This is confirmed by the interviews hold with Mr. Ömer Akyürek, consultant and Mr. Fatih Özgün, Project Manager of Ortatogu Group, and inspection of Map of natural parks in Turkey. In addition, the validation team has inspected the lay-out of the LFG plant. The project activity created job opportunities during construction,operation and maintenance. This can be confirmed by the validation team via interviews hold with Mr. Ömer Akyürek, consultant and Mr. Fatih Özgün, Project Manager of Ortatogu Group, Mr. Murat Şener, Operator engineer at Solaklar LFG plant and Mr. Burhan Tuğtekin, headmen of the Durhasan village. As result, the workers at LFG plant will be more skilled via the trainings provided, which is monitored parameter. The project has positive impact on employment rates of the poor local communities, which already has been mentioned under quality of umployment. The validation team via the inspection of the content of Annual Developmnet of Turkey s Electricity Generation by Primary Energy Sources ( ) Report and TEIAS data can confirm that the electricity of Turkey is produced largely by the usage of fossil fuels. Therefore, substituting electricity in the grid by generated by the project energy from renewable sources the project will provide access to more clean energy services. However, it is very hard to monitor and to quantify this indicator, therefore is is scored conservatively as 0. During the stakeholders meeting held on , the locals have requested the project owners help with regards to the primary school library. This can be confirmed by the validation team via the interviews hold with Mr. Burhan Tuğtekin, headmen of the Durhasan village, inhabitants of Durhasan village, as specified in the Section 2.2. In October November 2011 the renovation work of the Solaklar Primary School has been finalized by the Project Participant. This was confirmed by the validation team via inspection of the library in Solaklar Primary School during on-site visit. It can be confirmed that 4 descs, 1 computer, 1 teacher desc, and several chairs were installed in the library. This indicator is scored pisitively as due to the fact that some employment opportunities are created by the project activityon construction and operation phase of the project. This was confirmed by the validation team via interviews hold with Mr. Ömer Akyürek, consultant and Mr. Fatih Özgün, Project Manager of Ortatogu Group, Mr. Murat Şener, Operator engineer at Solaklar LFG plant and Mr. Burhan Tuğtekin, headmen of the Durhasan village. Exact number of jobs sreated shall be verified on the verification stage of the project. Version 01 Page 31

32 Balance of payment and investment Technology transfer and technological self-reliance 0 0 The project does not lead to any significant changes with regards to balance of payments and investment. The reduction of fossil fuel imports due to the project is too insignificant to be monitored. This is confirmed by the validation team via inspection of Turkish Statistic Institute Statistical Year Book 2009 Section 14, Energy. The validation team has examined the data presented by the Turkish Statistics Institute in section Main solid waste indicators of municipalities, as referenced in PDD. It comes to the conclusion that the LFG utilization is not a common practice in Turkey. Under these circumstances, the introduction of a modern landfill management technology will eventually contribute to a change in energy sector s perception of alternative investment opportunities demonstrating the viability of the technologies relatively new to the country and region. Thus, - Category Environment has a subtotal of 1 x + and 4 x 0 - Category Social development has a subtotal of 2 x + and 2 x 0 - Category Economic and technological development has a subtotal of 1 x + and 1 x 0 It is validators observation that no negative scoring was obtained and total scoring of + 4 was achieved. All three categories have some positive indicators, thus the project has positive impact on the environment, social development and economic and technological development. Project owener and carbon consultant has identified correctly 4 indicators that will be examined once per crediting period, since there are 4 non-neutral indicators identified for the project. The PP is aware of their responsibility to perform monitoring, assure accuracy of the measurement and store the records in appropriate manner for at least 2 years after the crediting period. The validation team comes to the conclusion that the requirement and recommendations regarding the development of sustainability monitoring plan stipulated by the Gold Standard are followed strictly and the performance of feasible and unambiguous monitoring of non-neutral indicators and those which have been neutralized by implementation of mitigation measures, of the sustainable development matrix is guaranteed. Besides, the PP intends to contribute to the sustainable development of the local community. The topic was also considered during the on-site visit and the needs of the locals were queried and assessed. PP committed by investing in the library repair and modernization, new school desks were purchased. This can be confirmed by the visiting of the school by the validation team during on-site assessment and interview hold with the mukhtar of the Durhasan village Mr. Burhan Tuğtekin. 3.8 Environmental Impact assessment The impact of the proposed project activity on environment and on sustainable development of the region is sufficiently discussed with the local authorities and with local stakeholders during the local stakeholder meeting, which took place on 01/12/2010 and 08/07/2011 in Solaklar Village. The evaluation is based on the Version 01 Page 32

33 guiding notes of the GS Toolkit 2.1 /16/ and GS Annex I /20/. Every of the prescribed indicators which impacted the enviormnet is clearly elaborated in the project relevant documents. The comprehensive outcomes are released to the public in the LSC report /27/, and after conduct of the feedback round reflected in the GS Passport /26/ With reference to the LSC report /27/ and the GS passport /26/ the validation team confirms that PP conducted comprehensive analysis of the impact of proposed project on environment and regional development. During the on-site visit subsequent interviews were conducted with Mr. Fatih Özgün (PO representative), Mr. Ömer Akyürek (project consultant), headmen of the nearest to the project activity Durhasan village Mr. Burhan Tuğtekin and local people in order to prove the correctness of the information reported in the previously mentioned documents. As result, as evaluated by the validation team in Validation of the indicators by the validation team column in SDM matrix evaluation table presented above, the proposed project activity does not have negative impact on the environment and only positively contributes to the air quality through the GHG emissin reductions. In line with the requirements of Regulation on Environmental Impact Assessment, the proposed project has been exempted from performing an Environmental Impact Assessment. This can be confirmed by Letter of compliance with local environmental regulations (exemption letter) /39/ and EIA certificate /40/ (i.e. No EIA Required Certificate ÇED). 3.9 Stakeholder Consultation Local Stakeholder Consultation According to GS rules, LSC round was performed. First local stakeholder meeting was organized on the 01/12/2010 in Solaklar village, which is situated close to the Solaklar LFG area. In accordance with the GS Requirement 2.1 /15/, the identified stakeholders were appropriately invited to participate to the LSC meeting. As per GS Toolkit 2.1 /16/, PP invited representatives of each category of invitees in appropriate manner, namely Invitees Category Method of invitation Residents of Kayapınar, Durhasan, Karadenizliler villages, incl. headman of the village Representatives of Ministry of Enviroment and Forestry, Izaydas, Izmit Municipality (Directorate of Utilies and Construction, Environment Protection and Control Department) Representative of the Ministry of Environment and Forestry, Air Management Department A Local people impacted by the project or official representatives B Local policy makers and representatives of local authorities C Official representative of the DNA of the host country Announcement in the local newspaper. Personal invitation by hand. Via Via Fax Version 01 Page 33

34 Representatives of Chamber of Environmental Engineers, Kocaeli University,CEVKO (Environmental Protection Association) Gold Standard foundation Greenpeace, WWF Turkey, REC Turkey D Local non-governmental organisations working on topics relevant to your project E The local Gold Standard expert who is located closest to your project location F Relevant international nongovernmental organisations (NGOs) supporting the Gold Standard Via Via Via The invitation of local stakeholders by hand can be confirmed by the validation team via the inerview hold with Mr. Burhan Tuğtekin, mukhtar of Durhasan village and Mr. Fatih Özgün, Project Manager. In addition, first LSC was announced in local newspapers in order to invite broad range of stakeholders. The validation team has examined the content of those newspapers (the announcement published on LSC meeting) - newspaper Kocaeli Gazetesi, dated 23/11/2010 and newspaper Özgür Kocaeli, dated 24/11/2010. It can be confimed that LSC was announced in those newspaper as described in LSC report. Second LSC meeting was organized on in Solaklar Village in order to strengthen the first LSC meeting and to reach local stakeholders, which are directly impacted by the project activity. The meeting was announced in a verbal way by Mr. Burhan Tuğtekin, who is the muchtar of the Durhasan village (also participated the LSC meeting held on ). Hardcopies of the non-technical description of the project activity along with the explanation of the sustainable development indicators and evaluation forms were made available one week before the meeting for the locals and were also delivered during the meeting to participants. This can be confirmed by the validation team via the interview hold with Mr. Burhan Tuğtekin. Copies of sent invitations ( s) and fax including the details of the appointed meeting /58/ and nontechnical description of project activity /57/ were visually observed and checked by validation team in the headquarter of Ortadogu Group in Istanbul during on-site visit. It can be concluded that all appropriate stakeholders were contacted by PP in appropriate manner. In the headquarter, the validation team also have examined the pictures from two LSC meeting /55/56/, original list of participants, copies of blid stakeholder matrix, meetings minutes and set of copies of evaluation forms from participants of the first and second LSC meeting, as relevant, as material proof and can confirm that LSC meetings took place in line with requirements of GS. Via interviews hold with Mr. Burhan Tuğtekin, headmen of the village Durhasan, Mr. Fatih Özgün, Project Manager and Mr. Ömer Akyürek, consultant, it can be confirmed that the consolidated final sustainable development matrix was developed during the LSC meeting preliminary scoring and based on the matrix from the outcome of the blind stakeholder exercise. It can be also confirmed that project developer took into account all relevant comments from all stakeholders during the LSC meetings and fully depicted all stakeholders comments and concerns in the project documentation (GS passport and LSC report) and provided satisfactory answers to those comments and concerns in project documentation. The LSC meetings encompassed an introduction to the project activity and relevant regulations and priorities, discussion on project phases and aim, question & answer session, and explanation on the evaluation forms. Version 01 Page 34

35 Meeting s participants were welcomed to express their opinion and concerns regarding the proposed project activity. Finally the questioners were filled, signed and collected. The validation team considers the local stakeholder consultation was carried out adequately and all comments are handled accordingly SFR - Comments by Parties, Stakeholders and NGOs According to the GS rules, the PP has performed Stakeholder feedback round (SFR) of the project. The procedure of how SFR was conducted is clearly described in the final version 3 of the GS passport of the project. SFR has started on 01/05/2012, when the project manager Fatih Özgün communicated via to the relevant stakeholders PDD, LSC Report and GS Passport of the project and requested the feedback on the project from them. Validation team can confirm this statement via examination of copy of this in GS passport and communication with Mr. Ömer Akyürek. Same documents were delivered to the headmen (mukhtar) of Durhasan village in order to be communicated to the broad audience, what has been confirmed via interview with him by phone. Also, project s PDD, LSC report and GS Passport have been made available on the webpage and the validation team confirms this via the assessment of the web-site content. Two month after the start of SFR, till 01/07/2012, no feedback was received from the stakeholders via or phone. As result, validation team comes to the conclusion that SFR process was conducted by PP in accordance with GS rules in appropriate manner. SFR is closed Pre-feasibility assessment (has Gold Standard feedback been followed up) N/A. The project as such does not require pre-feasibility assessment and the project is under regular cycle Monitoring Emission reductions The emission reductions resulting from the proposed project are calculated according to ACM0001 Flaring or Use of Landfill Gas version Emission reductions for the project are calculated as the difference beetween the the baseline emissions and project emisisons. Taking into account the nature of the project, only baseline emissions from methane emissions from SWDS (A) and electricity generation (B) shal be taken into account. The validation team has cross-checked the calculation procedures of calculation of baseline emissions from methane emissions from SWDS with applied ACM 0001 version methodology, Tool to determine the mass flow of a greenhouse gas in a gaseous stream version , Tool to determine project emissions from flaring gases containing methane, Tool Emissions from solid disposal sites version and baseline emissions calculated from electricity generation presented in PDD with applicable Tool to calculate baseline, project and leakage emissions from electricity consumption version 1. Version 01 Page 35

36 It can be confirmed by the validation team that all calculation procedures applied for the calculation of estimated amount of emission reductions, baseline emissions and project emisisons are made in appropriate manner in accordance with applicable ACM0001 Flaring or Use of Landfill Gas version methodology and supporting tools using conservative assumptions and are based on verifiable data supported with sources of information. All data resources used for the estimation of baseline and project emissions is correctly referenced in the PDD, and the validation team can confirm that all parameters were used correctly. No material deviations were observed. Also, all calculation procedures for the ex-ante (i.e. on monitoring stage) estimation of emission reductions are elaborated appropriately, and appropriate monitored parameters are presented in the monitoring plan for the project, together with the procedures for the estimation of baseline and project emissions Parameters determined ex-ante All data and parameters that was available at validation and will be not monitored were validated as follows: Under ACM0001 Flaring or Use of Landfill Gas version : Fraction of methane that would be oxidized in the top layer of the SWDS in the baseline (OX top_layer ) was validated as to be correctly applied by inspection of default value set in ACM0001 version GWP CH4- Global Warming Potential of CH 4 was validated as to be correctly applied by inspection of default value in 2006 IPCC Guidelines on National GHG Inventories n PJ - Efficiency of the LFG capture system that will be installed in the project activity was validated as to be correctly applied by inspection of default value set in ACM0001 version Under Tool to determine the mass flow of a greenhouse gas in a gaseous stream version : ID.4 / R u - Universal ideal gases constant - was validated as to be correctly applied by inspection of default value set in Tool to determine the mass flow of a greenhouse gas in a gaseous stream version MM CH4 - Molecular mass of CH 4 - was validated as to be correctly applied by inspection of default value set in Tool to determine the mass flow of a greenhouse gas in a gaseous stream version Under the Tool to determine project emissions from flaring gases containing methane n flare,h - Flare efficiency in hour h - was established as be 90% in line with the Tool to determine project emissions from flaring gases containing methane version 01. According to the tool, continuous monitoring of compliance with manufacturer s specification of flare (temperature, flow rate of residual gas at the inlet of the flare) must be performed during the monitoring. The validation team observed the flare instalation during the on-site visit and can confirm that it is enclosed and the 90% efficiency was taken appropriately. p CH4,n - Density of methane under normal conditions was validated as to be correctly applied by inspection of default value set in the Tool to determine project emissions from flaring gases containing methane. Under Emissions from solid disposal sites version Version 01 Page 36

37 Default value for the model correction factor to account for model undertainties 0.75 was validated as to be correctly applied by inspection of default value applicable to option A as set in Tool Emissions from solid disposal sites version OX- Oxidation factor (reflecting the amount of methane from SWDS that is oxidized in the soil or other material covering the waste) - was validated as to be correctly applied by inspection of default value in 2006 IPCC Guidelines on National GHG Inventories. F - Fraction of methane in the SWDS gas (volume fraction) - was validated as to be correctly applied by inspection of default value in 2006 IPCC Guidelines on National GHG Inventories. DOC,f,default - Default value for the fraction of degradable organic carbon (DOC) in MSW that can decompose in the SWDS - was validated as to be correctly applied by inspection of default value in 2006 IPCC Guidelines on National GHG Inventories. MCF default - Methane correction factor was taken as 1, since the Solaklar landfill falls under the definition anaerobic managed solid waste disposal site. It was validated as to be correctly applied by inspection of default value in 2006 IPCC Guidelines on National GHG Inventories. DOC j - Fraction of degradable organic carbon in waste type j (weight fraction) - the values were validated as to be correctly applied by inspection of default value in 2006 IPCC Guidelines on National GHG Inventories. k j - Decay rate for the waste type j - the values were validated as to be correctly applied by inspection of appropriate default values in 2006 IPCC Guidelines on National GHG Inventories, as for the Boreal and Temperate (MAT < 200C) and WET (MAP/PET >1) conditions. Conditions on temperature and WET definition were verified by the validation team as being correctly defined based on the inspection of Kocaeli Provincial Environment Annual Report (2006). W x - Amount of solid waste type j disposed or prevented from disposal in the SWDS in the year x (t) - the values were validated as to be correctly applied by inspection of appropriate values specific on wste type in Kocaeli province in Kocaeli University, Kocaeli Province Waste Charaterisation Report (table 2.1 and 3.2), Under Tool to calculate the emission factor for an electricity system EG gross Gross electricity production by fossil fuel power sources ( ) - the values applied in the calculations were validated as to be correctly applied by inspection of appropriate data on the distribution of gross electricity generation by primary energy resources and the electricity utilities in Turkey (2008, 2009, 2010) published by TEIAS. FC i,y - Amount of fossil fuel type i consumed in the project electricity system by generation sources in year y ( ) - the values applied in the calculations were validated as to be correctly applied by inspection of appropriate values on fuels consumed in thermal power plants in Turkey by the electricity utilities published by TEIAS (Turkish Electricity Transmission Company) ( ). NCV i,y - GJ/tonnes (m 3 for gaseous fuels) - Net calorific value (energy content) of fossil fuel type i in year y - the values applied in the calculations were validated as to be correctly applied by inspection of appropriate values of Heating values of fuels consumed in thermal plants in Turkey by the electricity utilities ( ) calculated based on TEIAS (Turkish Electricity Transmission Company). EF CO2,i,y - CO 2 emission factor of fossil fuel type i used in power unit min year y - the values applied in the calculations were validated as to be correctly applied by inspection of IPCC default values at the lower limit of the uncertainty at a 95% confidence interval as provided in table 1.4 of Chapter 1 of Volume 2 (Energy) of the 2006 IPCC Guidelines for National Greenhouse Gas Inventory. Version 01 Page 37

38 EG m,y - Net electricity generated by power plant/unit m - the values applied in the calculations were validated as to be correctly applied by inspection of data published by TEIAS (Turkish Electricity Transmission Company) on Generation units put into operation in 2008; 2009; ηm,y - Average net energy conversion efficiency of power unit m in year y - The average values of thermal plants in Turkey were validated as to be correctly applied by inspection of the content of report Environmental Map published by the Ministry of Environment and Forestry. The validation team confirms that all relevant parameters have been sufficiently considered and the values of the parameters are real, measureable and conservative Parameters monitored ex-post The project proponent has established monitoring plan specifying correctly in line with applicable ACM0001 Flaring or Use of Landfill Gas version methodology monitored parameters in order to estimate amount of emission reductions on the monitoring stage. This can be confirmed by the validation team after the inspection of the established monitoring plan in PDD version 3 and parameters to be monitored in ACM0001 Flaring or Use of Landfill Gas version and supporting tools, as applicable. The monitoring consists of monitoring of: Amount of landfill gas combusted in power generation units Temperature of the landfill gas sent to power generation to ensure compliance regarding dry basis for measurement Amount of landfill gas flared Temperature in the exhaust gas of the enclosed flares to determine the flare efficiency Concentration of methane of the landfill gas Total amount of electricity exported to the grid Operating hours of power generation units Total amount of the electricity imported from the grid Data and parameters under ACM0001 Flaring or Use of Landfill Gas version , that are monitored: Hr - Operation of the energy plant Hourly - Each engine have its own internal counting device. This can be confirmed by the validation team on-site. Data and parameters under the Tool to determine the mass flow of a greenhouse gas in a gaseous stream version , that are monitored: V t,db - Volumetric flow of the gaseous stream in time interval t on a dry basis this will be mesured continously. The parameter will be monitored on-site with flow meter, calibration and frequency of calibration is according to manufacturer s specifications what is confirmed by the validation team during on-site visit. v CH4,t,db - Volumetric fraction of CH 4 in a time interval t on a dry basis. This will be monitored continuously by gas analyzer operating in dry-basis, installed on-site. This can be confirmed by the validation team during onsite inspection of gas analyzer during on-site visit and inspection monitoring equipment specification. Version 01 Page 38

39 T t - Temperature of the gaseous stream in time interval t. This will be monitored by the temperature sensors installed, this can be confirme by validation team during inpection of installation on-site. Calibration and frequency of calibration is according to manufacturer s specifications. Data and parameters under the Tool to calculate baseline, project and/or leakage emissions from electricity consumption version 01, that are monitored: EC BL,y - The electricity generated using LFG is measured continuously with a electricity meters. The validation team can confirm that this paramter will be measured by bi-directional electricity meters, which are installed on-site by TEIAS (Turkish Electricity Transmission CO). During on-site inspection the validation team can confirm that the electricity meters are available on-site and that these are appropritely sealed and have valid calibration. For the monitoring purposes monthly protocols on electricity generation will be prepared based on the electricity meter s readings, that will be confirmed by both TEIAS and the project participant by the end of each month, and will be stored. This is confirmed by the verification via the intervie hold with project manager Mr. Fatih Özgün and consultant Mr. Ömer Akyürek. According to Turkish law the Turkish Electricity Transmission Company (TEIAŞ) is responsible for the continuous measurement of the electricity fed to the grid. The measurement procedure, conditions and accuracy are defined in the Electricity Market Balancing and Settlement Regulation /76/. EC PJ,y - Quantity of electricity consumed by the project activity. The validation team can confirm that this parameter will be measured by bi-directional electricity meters, which are installed on-site by TEIAS (Turkish Electricity Transmission CO). During on-site inspection the validation team can confirm that the electricity meters are available on-site and that these are appropritely sealed and have valid calibration. For the monitoring purposes will be prepared monthly protocols based on the readings, that will be confirmed by both TEIAS and the project participant by the end of each month and stored. This is confirmed by the validation team via the intervie hold with project manager Mr. Fatih Özgün and consultant Mr. Ömer Akyürek. According to Turkish law the Turkish Electricity Transmission Company (TEIAŞ) is responsible for the continuous measurement of the electricity fed to the grid. The measurement procedure, conditions and accuracy are defined in the Electricity Market Balancing and Settlement Regulation /76/. TDL y - Average technical transmission and distribution losses. Will be estimated for the distribution and transmission networks of the electricity grid of the same voltage as the connection where the project activity is connected. Data and parameters under the Tool to determine project emissions from flaring gases containing methane that are monitored: FV RG,h - Volumetric flow rate of residual gas in dry basis in the hour h. The validation team can confirm that the flow meters will be used for monitoring purposes which are installed on-site. f V,CH4,RG,h - Volumetric fraction of methane in the residual gas on dry basis. The validation team can confirm that the continuous gas analyser will be used for monitoring purposes which are installed on-site. T flare - Temperature in the exhaust gas of the enclosed flare. The validation team can confirm that the continuously measurement by thermocouple will be used for monitoring purposes which are installed on-site. Version 01 Page 39

40 Management system and quality assurance During on-site visit, the representative of PO explained that measurement of electricity generation is performed by 2 TEIAS metering devices, which are installed and calibrated by TEIAS. It was explained that the electricity generation is measured continuously, since they are used for billing purposes and recorded on monthly basis by the production operator of the power plant, who also compares the records with the respective electricity sales receipts. In accordance with the Tool to calculate the emission factor for an electricity system /9/, it is mandatory that all data collected as part of the monitoring should be archived electronically and kept for at least 2 years after the end of the last crediting period. It was communicated during the on-site visit and reflected in PDD that PP is aware of the requirement and will act accordingly. This can be confirmed by the validation team via the interviews with project manager Mr. Fatih Özgün and consultant Mr. Ömer Akyürek. As specified in monitoring plan, the project owner is responsible for the operation and maintenance of the landfill and the installed equipment (except electricity meters, which are under responsibility of TEIAS) and for the administration of the data, setting up a GS VER monitoring team who will be responsible for monitoring all data required to estimate emission reductions. The project s GS VER monitoring team will be responsible for quality assurance and quality control of the monitoring equipment. The data measured by the monitoring equipment will be stored and will be processed into a monitoring report, which will be submitted by the project owner. Strong quality assurance and quality control procedure will be taken to monitor the equipment and data collection. Equipment and facilities will be subject to a regular maintenance and testing regime to ensure accuracy following supplier s manual. This can be confirmed by the validation team via the interviews with project manager Mr. Fatih Özgün and consultant Mr. Ömer Akyürek. The feasibility and accuracy of the suggested monitoring plan was widely discussed with the PO and the carbon consultant during the on-site visit. The validation team believes that the established monitoring plan will deliver accurate monitoring records of the proposed project activity. The Kocaeli GS VER-Team will be responsible for quality assurance and quality control of the monitoring equipment. The data measured by the monitoring equipment will be stored and will be processed into a monitoring report, which will be submitted by the project owner. All the monitored data will be stored during the crediting period for at least two years after the end of the crediting period. In summary, the validation team is convinced of compliance of the monitoring plan with the requirements of the indicative simplified baseline and monitoring methodology ACM001 version During the on-site assessment, the validation team interviewed the PP that the monitoring arrangements described in the monitoring plan are feasible within the project design. The emission reductions resulting from the proposed GS-VER project activity are to be reported ex ante and verified. Version 01 Page 40

41 APPENDIX A VALIDATION PROTOCOL - FOR GOLD STANDARD VOLUNTARY EMISSION REDUCTION PROJECT - KOCAELI LANDFILL GAS TO ELECTRICITY PROJECT REPORT NO Rev 00 ( ), Version No.: 01 Page 41

42 Table 1: Validation requirements (based on the GS Toolkit, GS Requirements and their relevant Annexes) MoV=Means of Validation =document review, I=Interview, OA=on-site assessment Checklist question Reference MoV Findings, comments, references, data sources Final conclusion 1.1 Has the correct project size been selected? GS Passport C1 PDD A.1/2 As per Gold Standard Toolkit 2.1 /11/, although the installed capacity of the proposed project activity is below the threshold of 15MW, there is a possibility that the emission reductions will exceed the 60kt CO 2e threshold rules for the small scale project activities. Therefore the project activity will be developed as a large scale project activity. 1.2 Does a written statement (e.g. in the PDD) clearly describe that the project is not a de-bundled part of a large or small scale project? PDD A.4.5 The project is identified and justified of not being a debundled component of a large scale project activity. 1.3 If there is an applicable cap-andtrade scheme in the project s host country, has an arrangement been made to cancel allowances in the applicable scheme? GS Passport C.2 The host country ratified the Kyoto protocol already on 28/05/2009 with the accession status. The country has no CAP and trade scheme developed yet. 1.4 Does the project clearly demonstrate its eligibility under Gold Standard? GS Passport C.3 It is clearly declared that the project fulfills the 7 project eligibility criteria postulated under Gold Standard Requirements2.1, i.e.1) size large scale 2) type - renewable energy supply 3) host country - Turkey 4) GHG gasses - CO2 5) ODA declaration is signed 6) & 7) project time frame - regular project, that was not previously announced under other carbon schemes. In addition, the project contributes to the sustainable development of the region, as demonstrated in the Sustainability Matrix. Rev 00 ( ), Version No.: 01 Page 42

43 1.5 Does the project reduce an applicable GHG? GS Passport C.4 PDD B3 The project activity is renewable energy supply i.e. LFG project, which would substitute the electricity generate by fossil fueled power plant. Thus the project contributes to the reduction of CO 2 emissions from energy generation sector. 1.6 Does the project clearly demonstrate that no ODA has been used under the condition that the credits coming out of the project are transferred to the donor country? GS Passport, Annex 1 /I Körfez Enerji A.S., provided a signed Declaration of Non-Use of Official Development Assistance by Project Owner, which clearly states that the project does not profit from any donation. 1.7 Does the project apply the correct project cycle (regular vs. prefeasibility assessment)? GS Passport C.5 / I Regular project cycle is identified as applicable for the project activity, since the time of first submission and start date of construction or implementation are dated to March 2011 and April 2011 respectively. 1.8 Is the project being registered under any other certification scheme for the same or overlapping crediting periods? It was confirmed during the on-site visit and cross-check of UNFCCC project database that the project is not being registered under any other certification scheme. 2.1 Has the baseline scenario been constructed in a conservative manner (i.e. assumptions are made explicitly and choices are substantiated)? PDD B.4 /I/OA The baseline, which is in line with the applied Combined tool to identify the baseline scenario and demonstrate the additionality version , is selected for the proposed project as "Atmospheric release of the LFG and electricity would have been generated by the existing grid connected power plants as continuation of the situation before the project activity in a conservative way and all assumptions and data used for justification of the baseline are defined correctly and in conservative manner. 2.2 Does the PDD use the latest version of the methodology and the latest interpretation form the EB at the time of first submission to the GS? PDD B.1 The version of the methodology ACM0001 which was used for the development of PDD from the time of first submission of LSC to VCS, as well as the supplementary tools available at that time are used for the completion of the PDD version 3. Version of the methodology ACM0001 has its validity till January Does the PDD describe the baseline methodology? PDD B.2, B.3, B.4 B1 The application of the selected baseline methodology ACM0001 and Combined tool to identify the baseline scenario and demonstrate the additionality version is clearly described in PDD, together with the description of its applicability and justification of the selected criteria. 2.4 Does the PDD describe the quantified baseline scenario? PDD B.4 The PDD correctly applied the ACM0001 methodology and provides quantified amount of baseline emissions. Since there is no heat generation or natural gas usage in the baseline scenario, Rev 00 ( ), Version No.: 01 Page 43

44 only baseline emissions from methane emissions from SWDS and electricity generation were taken into account. 2.5 Does the PDD include and overview of the current and known future legally binding regulatory instruments and assess whether the project would be implemented anyway because of these? 2.6 Does the PDD provide evidence based on which common practice of the technology used can be assessed? PDD Up to the knowldge of the validation team, there are no legally binding regulatory instruments in Turkey, which will lead to mandatory implementation of the projcet. PDD correctly describes that the project activity is facing numerous barriers for project implementation and is not a common practice in Turkey. PDD B5 step 4 The Guidelines on Common Practice version 01.0 was correctly applied by the project proponent in order to demonstrate that the project is not a common practice. TEIAS data on existing power plants was used in correct manner for the common practice analysis and have been checked by the validation team. 2.7 Does the PDD address leakage issues as part of the baseline and project boundary? PDD B.6.3 step 6 In accordance with ACM0001 Flaring or Use of Landfill Gas version , no leakage effects are accounted. 2.8 Does the project apply the methodology that results in the lowest baseline emission? PDD, Section B.6.3 /I The application of the Approved ACM0001 methodology and relevant tools is correctly applied for the calculation of baseline emissions. The methodology is applied accurately and the conservative principle is obeyed, since the conservative default factors were used for the estimation of baseline emissions. 2.9 Are all likely baseline scenarios developed and quantified in the PDD? PDD B.5 5 alternatives to the project activity were identified in line with ACM0001 Flaring or Use of Landfill Gas version and were evaluated against criteria, prescribed by the selected methodology in PDD Are there any material uncertainties over the numerical data sets applied (e.g. generator efficiencies, and fuel types and resulting emission factors, etc.)? PDD, VERs calculation sheet The numerical data provided in the PDD and all other additional documents reflect the most recent knowledge of the PP and are assessed by the validation team as adequate. In case of expected uncertainties, the most conservative assumption is adopted in order to be in line with the Gold Standard principles of conservativeness Is there a systematic referencing to publicly available information or to expert or expert opinions? PDD, VERs calculation sheet All used data and information are correctly referenced. The provided sources are accessible and proved as accurate and reliable at the time of validation. Rev 00 ( ), Version No.: 01 Page 44

45 2.12 Is information verifiably presented with a sufficient degree of detail and transparency? PDD, VERs calculation sheet References of the used data are provided as a footnote. The provided sources are accessible and proved as accurate and reliable at the time of validation Is it fully transparent from the PDD which sets of data were selected based on the prerogative of conservativeness? PDD All data relevant to the emission reduction calculations and assumptions are provided in the PDD, incl. List of the units most recently put into operation, List of VER projects in Turkey, and any values of other relevant parameters. All provided information can be transparently re-traced through footnotes and relevant links. Some of the information has been submitted as hard copy and/or soft copy Does the PDD include full references to sources of data used? PDD References of the used data are provided as a footnote. The provided sources are accessible and proved as accurate and reliable at the time of validation. 3.1 Has the PP selected and applied the correct tool for demonstrating additionality? PDD B2 PDD B5 / I PP demonstrated the additionality of the proposed project by performing barrier analysis and Common practice Analysis as per Combined tool to identify the baseline scenario and demonstrate the additionality version According to the Combined tool to identify the baseline scenario and demonstrate the additionality version , Step 3 Investment Analysis was not conducted, since there is only one alternative scenario left (Scenario 2) after barrier analysis. The validation team confirms that the demonstration of additionality was done in line with the selected and applicable Combined tool to identify the baseline scenario and demonstrate the additionality version Is the line of argumentation used by the PP to demonstrate additionality correct? PDD B5 The argumentation follows exactly the steps described in the additionality tool and justified by appropriate evidences. 3.3 Are the references used to demonstrate additionality up-to-date and reliable? PDD The data and references used for the demonstration of additionality are justified by the sources provided in PDD and are plausible. All assumptions are proved to be reliable and reasonable. 3.4 Has the PP compared the proposed project activity with normal practice in the region (especially if similar projects have already been implemented on a commercial basis in the region)? PDD / I The common practice analysis has been conducted by PP. It is determined that there are very few operational LFG plants in the Republic of Turkey and investment in renewable energy project is not a common for the region. The analysis in PDD provided on common practice was made correctly in line with applicable Guidelines on Common Practice version 01.0 and has showed that the project activity is not common practice in Turkey. Rev 00 ( ), Version No.: 01 Page 45

46 3.5 Are assumptions (qualitative or quantitative) used to demonstrate additionality conservative? PDD / I The conservativeness principle is strictly followed throughout the demonstration of barrier analysis and common practice. 4.1 Is Do no harm assessment based on accurate information? GS Passport F.1 LSC Report D.1 (i) /I The GS Annex H is followed precisely. It is clearly shown that the proposed project is not in conflict with any aspects of the Do-No-Harm assessment. The statements are substantiated with international agreements and national law, which are obligatory for the proposed project activity in Turkey. Interview with locals confirm that the project activity provides low/none risk of affecting the safeguarding principles 4.2 Has a sustainable development matrix been developed? If yes, is it prepared according to the guidance under GS Toolkit Section 2.4.2, Table 3.2 and Annex I? GS Passport F.2 LSC Report D.1 (ii) / I Sustainable development matrix is developed in accordance with the guidance provided under GS Toolkit 2.1. The template in Annex I is adopted accordingly. 4.3 Is the matrix based on existing sources of information (data from existing reports, results from stakeholder consultation, experiences with similar projects in similar situations, expert judgment if data are unavailable or are of poor quality, etc)? GS Passport F.2 LSC Report D.1 (ii) / I The SD matrix was filled out once by the PP and once by the local stakeholders (blind matrix) and the consolidated SD matrix was developed. Local stakeholders provided their comments and scores to indicators and PP scored the SD matrix based on their experience and considering data from existing reports. Besides, indicators and selected parameters are discussed and justified in additional table, referring to published reports, feasibility study for the proposed project and official reports on regional data. 4.4 Are data and expert opinions presented in a sufficient degree of detail and transparency? Are they verifiable? GS Passport F.2 LSC Report D.1 (ii) / I The implemented data and expert opinion are presented in a sufficient manner. They are traceable and are easily accessed by the validation team. Thus transparency of the information is ensured. 4.5 Are data uncertainties clearly stated with associated margins of error? GS Passport, LSC Report Data uncertainties are not discussed within the documents. Nevertheless the PP committed to perform all assumptions and decisions in conservative manner. Rev 00 ( ), Version No.: 01 Page 46

47 4.6 Is scoring reproducible and verifiable? GS Passport F.2 LSC Report D.1 (ii) / I Each indicator is described and references, mainly in footnote, and its scoring is justified. 4.7 Are at least two of the sub-totals (categories) positive? Is the third sub-total at least neutral? GS Passport F.2 LSC Report D.1 (ii) An overall scoring of + 4 is achieved. No category is scored negative, which means that the project poses no adverse effect on the regional sustainable development. Positive indicators can be found in each of the three categories. 4.8 Is there a clear explanation on how the matrix was completed together with the stakeholders? GS Passport F.2 LSC Report D.1 (ii) I It is explained that the local stakeholder were informed about the project and introduced to the SD matrix. The blind matrix was filled out during the LSC meeting, where the local stakeholders had the possibility to interact with the PP and to benefit from PP s assistance. 5.1 Does the project activity conform to host country (local, regional or national) requirements concerning environmental impact assessment? LSC Report D.1 (ii) I Turkey s requirement and procedures regarding the EIA (i.e. Turkish national EIA regulations- EIA required projects, Article 7-1-b) has been followed for the proposed project activity. As required a project description file (PDF) was prepared. In consequence the Ministry of Environment and Forestry approved the EIA report for the project on 17/09/2010 (see EIA Exemption certificate) Have PPs fulfilled the GS requirements, set out in GS Toolkit Section 2.6 and 2.11, regarding stakeholder consultation? LSC Report / I The GS requirements are taken under consideration. In order to achieve participation of all stakeholders, PP organized 2 LSC meetings and followed precisely the requirements for organization and performance of the consultation. Records of the invitation process, the meeting and the received comments and questions have been included in the report. Copies of original questionnaire forms and list of participant with signature are included in the LSC report as well. Rev 00 ( ), Version No.: 01 Page 47

48 6.1.2 Has an Invitation tracking table been filled out? LSC report B.1 LSC report C.2 I Invitation tracking table including invitees from all stakeholder categories, incl. headmen of the nearest villages. The table includes also the means of invitation and a confirmation. Additionally, the villages residents were invited to the LSC meeting through announcement in the local newspaper and through the villages headmen and PP Are copies of invitations published/sent out available? LSC report B.1 LSC report C.2 / I /OA Copies of invitations send via , fax or by hand and translation in English are published in the LSC report. A copy of the newspaper announcement is also available. During the on-site visit, it is determined that locals were sufficiently informed and invited in appropriate manner to the Local stakeholders consultation Is a non-technical summary included in the Local Stakeholder Consultation report? LSC report B.1 A comprehensive non-technical summary, incl. Project description, place of project, explanation of the electricity generation by LFG plant and definition of the project phases, was provided to the stakeholders in Turkish during the LSC meeting Is a participant list available? LSC report C.1 LSC report Annex 1 / I /OA List of participants, incl. signature is included in the LSC report. It was explained during the onsite visit that apparently not all participant to the meeting felt reluctant to sign in. The handwritten forms are available in Annex 1 of LSC report; originals were checked by validation team during on-site visit of the project Are stakeholder evaluation forms available? LSC report C.1 The filled evaluation forms are presented in the LSC report. The handwritten forms are available as Annex 2 as well Are minutes of the meeting(s) available? LSC report C.3 / I The minutes of the physical meetings are incorporated in the report. Comments and contributions are assessed. Local stakeholders expressed their positive attitude to the project and are pleased with the working opportunities created by the proposed project activity Has due account been made on comments received? LSC report C.3 All comments raised by local stakeholders on two LSC meetings were addressed by PP and the answers are provided by PP in LSC report. All comments from the stakeholders were mainly related to explanation of the project, its structure and impact on the employment, society and environment. The validation team considers the answers provided by PP to all applicable Rev 00 ( ), Version No.: 01 Page 48

49 questions raised as satisfactory and as those which do not require mitigation actions. The PP has asked what it can do for the community, and the response was to support the library renovation in the local school. PP took this into account and has contributed to the renovation, which is also considered as one of the parameters to be monitored If stakeholders required a revisit of the sustainable development assessment, has this been done? - No demand for revisiting the SD assessment has been communicated Is the consolidated sustainable development matrix presented based on own preliminary scoring and the matrix from the outcome of the blind stakeholder exercise? LSC report D The consolidated SD matrix is based on the preliminary PP scoring and the Stakeholders scoring (Blind SD Matrix). The scoring form the stakeholders represent their attitude to the project activity, where it is important not to affect their opinion. Since the consolidated SD matrix shall represent an objective scoring of the project activity, PP s knowledge as real, country specific knowledge and data dominated the scoring evaluation and consolidation of the tables. The conservative principle is perceived Is there evidence clearly showing that the latest version of the complete PDD (including the EIA, if applicable) was made publicly available for a period of two months prior to completion of the validation in a readily accessible form? LSC Report F GS Passport E.2 The design of the feedback round, which is described in the LSC report, has been followed. SFR has started on 01/05/2012, when the project manager Fatih Özgün communicated via to the relevant stakeholders PDD, LSC Report and GS Passport of the project and requested for the feedback. In order to increase the possibility feedbacks, the same information has been made publicly available since on the webpage of Ortadogu Group (Körfez Enerji A.S belongs to Ortadogu Group) ( Local stakeholders were also provided with mentioned documents Is there evidence clearly showing that the non-technical summary of the project (in appropriate local language(s)) was made publicly available for a period of two months prior to completion of the validation in a readily accessible form? GS Passport Refer to the non-technical summary is part of document package which is distributed to the stakeholders and made publically available on the webpage of the PP. The feedback round lasted for 2 months and the information provided on the webpage is still available. Rev 00 ( ), Version No.: 01 Page 49

50 6.2.3 Is there evidence clearly showing that all relevant supporting information (if available, in appropriate local language(s)) was made publicly available for a period of two months prior to completion of the validation in a readily accessible form? GS Passport Idem Does the Passport include 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 GS NGO supporters, etc.? GS Passport E.2 Interview The feedback process is described in the GS Passport, including comments and response to the last. Physical meeting for collecting the feedbacks was not organized. Nevertheless PP collected locals feedbacks personally. No comments from national or local NGOs, or municipality or other local stakeholders has been received during SFR Does the Passport include all written or oral comments received? GS Passport E.2 Idem Does the Passport include the argumentation on whether or not comments are taken into account and the respective changes to the project design? GS Passport Idem Rev 00 ( ), Version No.: 01 Page 50

51 7.1 Are chosen parameters relevant to the indicators? GS Passport G I All non-neutral indicators are subject to monitoring. The parameters provided for each indicator under Annex I are adopted accordingly to the proposed project activity. Four positive indicators were identified for the project, and corresponding monitored parameters are identified in LSC report and GS Passport. 7.2 Is the sustainability monitoring plan unambiguous about who will monitor with what frequency? GS Passport G LSC Report Section E I Monitoring will be performed by the PP (Ortadoğu Enerji) annually, in addition Improvements to the school library will be also monitored by the Mukhtar. As per Gold Standard Toolkit 2.1, the monitoring of each parameter is described; indicating who, when and how would perform the monitoring. The indicated frequency of monitoring deems to be accurate. 7.3 Is there any concern regarding the feasibility of the plan? GS Passport G LSC Report Section E I The presented monitoring plan is judged as feasible and reliable. Rev 00 ( ), Version No.: 01 Page 51

52 Table 2: List of Requests for Corrective Action (CAR) and Clarification (CL) Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by validation team Reference Summary of project owner response Validation team conclusion CAR 1. There is only 1 project participant in the project (c.f. PDD p.2, p.3). Please correct Annex 1. CAR 2. Please recheck the footnote 6, and the page number. Link seems to be broken. Correct version might be content/uploads/2011/10/gsv2.1_toolkit_clean- 11.pdf CAR 3. Please add to Section A.4.3. description of technology, i.e. producer and type of engines and flare CAR 4: Please extend the Step 1.b., PDD p.17: include some other laws relevant to the LFG and electricity marker, e.g. Air Quality Control Regulation, Soil Protection Law Electricity Market Grid Regulation etc. PDD, Annex 1 PDD, p.6 PDD, Section A.4.3 PDD p.17 Contact information of OakDanışmanlık has been extracted from Annex 1 of the PDD for consistency. The link and the page number has been corrected. The flare system is an enclosed flare system as already mentioned under the PDD. With regards to the engines two MWM gas engines. The model is TCG2020V12LF with an output of 1200kWe with V type 12 cylinders. An explanation has been provided under the PDD. Under the Turkish juristic system, the regulations are based and linked to the related laws. There are several regulations that could be considered as relevant to the proposed project activity however all of the regulations are based on three major laws as identified under the PDD. Step 1.b of the Combined tool to identify the baseline scenario and demonstrate the additionality aims to assess whether or not the alternatives are PDD has been updated accordingly. PDD has been updated accordingly. PDD has been updated with the description of technology. PDD has been updated with the description of laws, as applicable. Rev 00 ( ), Version No.: 01 Page 52

53 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by Reference Summary of project owner Validation team conclusion validation team response in compliance with all mandatory applicable legal requirements. Providing a statement that the alternatives are in line with these laws means it is in compliance with all the regulations and to its communiques under these laws as well. The reason to include the two specific regulation namely; Regulation on Solid Waste Disposal Control and Regulation on Managed Waste Landfilling to the PDD is to provide transparency on the most relevant regulations that are directly related to the landfill areas. CAR 5: PDD, p.18: In practice none of the landfill areas comply with these regulations, as indicated in statistics on landfill areas 21. Please provide source of information justifying this sentence and to what exact source footnote is referring. No source can be found for the statistics in section B,5, Step 4. PDD, p.18, PDD, p. 24 The common practice analysis under the PDD has been revised in accordance with Annex 12 of EB 63 Guidelines on Common Practice version Ref: PDD version 2, p. 24: Step 4: In accordance with the Guidelines on Common Practice, the factor F=1-N diff /N All has to be calculated representing the share of plants using the technology similar to the technology used in the proposed project activity in all plants that deliver the same output or capacity as the proposed project activity. The factor F has been calculated as 1. The factor 1 is calculated wrong F=1-52/52=0 Therefore F is then <0.2 and is in line with argumentation presented. Open Respond Round 2:F has been revised as 0 in the PDD. The project activity is not common practice Rev 00 ( ), Version No.: 01 Page 53

54 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by validation team Reference Summary of project owner response Validation team conclusion since N all -N diff <3. Conclusion: F has been revised accordingly. CAR 6. Please provide source indicated in footnote 31. Please also indicate the source of information for the sentence Moreover, nearly 20% of the population does not receive solid waste services at all, meaning that around 7 million tons are not officially registered and most likely are dumped or buried in illegal waste dumps. CAR 7: PDD, p.28: As could be seen from the above table all project activities are developed as a GS VER project activity and therefore excluded from common practice analysis in line with the requirements of the Combined tool to identify the baseline scenario and demonstrate the additionality version Outcome of Step 4: Based on the above information it is clear that there are no similar project activities and LFG extraction and utilization projects are not a common practice nor the technology is diffused in Turkey, and therefore the proposed project activity is additional. Please correct to: it is clear that there are no similar project activities in Turkey to Kocaeli Landfill gas to electricity project developed other as considering carbon revenues (GS VER projects). CAR 8. Footnote 44. Please indicate specifically that F CH4 sent to flare is calculated in same manner as parameter FC CH4 CAR 9: Please indicate units for FV RG,h and fv CH4,RG,h in formula 9 on p.33 in PDD PDD, p.25 PDD, p.28 The common practice analysis under the PDD has been revised in accordance with Annex 12 of EB 63 Guidelines on Common Practice version The common practice analysis under the PDD has been revised in accordance with Annex 12 of EB 63 Guidelines on Common Practice version PDD has been updated accordingly. PDD has been updated accordingly. PDD, p. 32 The PDD has been revised accordingly. PDD has been updated accordingly. PDD, p. 33 The PDD has been revised to include the unit of FV RG,h and fv CH4,RG,h. Units were indicated in PDD. Rev 00 ( ), Version No.: 01 Page 54

55 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by validation team Reference Summary of project owner response Validation team conclusion CAR 10: values for kj in Table 13 for glas and textiles are not indicated (cf. also type of wastes used for the definition of DOC j ). Please explain and correct if applicable. PDD, p.34 Textile is listed together with pulp, paper and cardboard in line with the methodological tool emissions from solid waste disposal site version The PDD has been revised accordingly. Since glass is an inert waste type it has no decay rate. PDD and VER calculation sheet have been updated accordingly. CAR 11. Please provide description of how TDL k,y was calculated, (formula 12), in PDD p.37, and based on which references ex-ante value of 1% was applied. CAR 12: VER calc. sheet, EFOM sheet, calc. of EF (tons/gj) please indicate tco2/gj as unit. Also, use full figure (not rounded) from IPCC, e.g. for natural gas- 0,0543 PDD, p. 37 VER calc. sheet, EFOM sheet Both textile and glass is mentioned under table 13 of the PDD version 1. The Average Technical Transmission and Distribution Losses (TDL) is a monitoring parameter. During the expost calculations, the applicable tool requires either a calculation or to be based on reference from utilities, network operators or any other official document. The Project Participant preferred to determine the TDL based on reference from utilities, network operators or any other official document. For ex-ante calculations the TDL has been estimated as 1%. Taking into account that the actual emission reductions will be based on the actual monitored value of the TDL, the approach of estimating TDL for the purpose of ex-ante calculations should be considered conservative. The VER calc. excel sheet has been revised as well as the PDD accordingly. Please indicate source of information for used value of 1% for TDL and provide it (if it is not on-line available) to the verifier. Open Respond Round 2: The 1% is an estimation just for the purpose of ex-ante calculations. The parameter TDL is a monitored parameter and the source of value will be provided to the verifier during the verification process. Conclusion: TDL parameter will be monitored The VER calc. excel sheet has been revised as well as the PDD accordingly Rev 00 ( ), Version No.: 01 Page 55

56 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by Reference Summary of project owner Validation team conclusion validation team response t CO2/GJ. CAR 13: Table 33 and Table 17: calculation of emission reductions does not match for 2012, 2017 and Please correct. CAR 14: please check the calculation of the field Textile in Input - Waste LFG calc. Sheet 6% from non food organics are used for calculation. Correct if appropriate. CAR 15. Please be consistent with the usage of correct abbreviations for parameters: e.g. FE CH4,BLy in Table 19, p. 51 PDD shall be F CH4,Bly, also Table 18 etc. PDD; Table 33 and Table 17 VER calc. sheet PDD, Table 18,19 PDD has been revised accordingly. W j,x has been revised in accordance with the values based on the report of Kocaeli Province Waste Characterisation. Based on the report the textile fraction is 0.1% and not taken into account in the calculations. This is conservative since it leads to a lower Emission Reduction. FE CH4,Bl,y has been corrected as F CH4,BL,y under the PDD. Rev 00 ( ), Version No.: 01 Page 56 The VER calculations has been revised, incl. Figures in PDD accordingly The revision of W j,x is substantiated with the study - Kocaeli Province Waste Characterisation Report. Abbreviations of parameters have been corrected in PDD accordingly. CAR 16: ID.25=ID.26 PDD, p.59. Please correct. PDD, p.59 PDD has been revised accordingly. PDD was corrected as requested. CAR 17: Please remove parameter ID.33 - it is not project specific. CAR 18- Please indicate how the training of the personal involved in the project activity will be performed and safety issues addressed. CAR 19: Indicator Access to affordable and clean energy services in final SDM is scored + shall be either PDD, p.61 ID.33 has been removed from the PDD. ID.33 has been removed from the PDD. LSC Report, Section E, All technical staff will be provided a training on health and occupational safety. This has been include into the monitoring plan and will be followed via certificates during the crediting period and therefore is more relevant to verification rather than validation. The scoring of the sustainable indicator Access to affordable and clean energy Description of training of personal has been provided. Final SDM matrix has been revised in appropriate and correct manner.

57 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by Reference Summary of project owner Validation team conclusion validation team response monitored as result or scored conservatively as 0 in Final GS Passport services has been revised to 0. SDM matrix. p.21, 25 CAR 20: Indicator 4 Human and Institutional Capacity it is not clear how this will be monitored ( visual is not specific), what measures shall be made in the library- please specify what kind of renovations work have been made. Same is for GS, p.14 CAR 21: Please indicate in GS Passport, p. 10 which organization represents Mr. Demircan and Mr. Gülüt. CAR 22: Please indicate in SDM matrix relevant MDG goals for some indicators, such as e.g. Soil condition - MDG- 7: Ensure Environment Sustainability) CAR 23: Please for parameter No. 2 state number of provided trainings and specify what kind of trainings shall be provided. CAR 24: GS passport, p. 28, parameter air quality A conservative approach of 0.5% is set for the sulphide LSC report, Section E GS Passport, p. 10 GS Passport, p. 21 GS passport, p.28 LSC report For the monitoring of the indicator Human and Institutional Capacity, an interview with the muchtar has been added to the monitoring plan. Both Mr. Yusuf Gülüt and Mr. Fethullah Demircan is representing Körfez Enerji A.Ş., which is the Project Participant. An explanation has been provided under the GS Passport. The millennium Development Goals are eight international development goals and not all of the SDM Matrix indicators are related with the MDGs. All the relevant MDGs have been identified under the Passport. The number of provided trainings are dependent on several issues including the total number of the staff within the project and their specific training needs during the operational lifetime and based on the experience of the company and their employees. In practice it is impossible to provide an exact figure on how much training will be provided at this stage. However all the technical personal will be provided training on occupational health and safety. This has been included in the GS Passport. Monitoring Plan has been revised accordingly. Rev 00 ( ), Version No.: 01 Page 57 Additional information, as requested, was added to GS Passport. MDG goals were amended in SDM matrix. Decsription on trainings was added to GS passport GS passport, Reference has been added to the GS Reference has been added to the GS Passport and

58 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by Reference Summary of project owner Validation team conclusion validation team response content. Please indicate the source for 0,5% figure applied. p.28 Passport and the LSC Report. According to the literature, the concentration of the LSC Report as requested. non-methane organic compounds LSC report (NMOCs), that causes odour are present at amounts smaller than %1. Therefore it is conservatively taken as %0.5. CAR 25: GS passport, Section G. Sustainability Monitoring Plan. Compare indicators number 2 and 5. In both cases number of contracts is mentioned there. For parameter 2 therefore number of trainings will be applicable only. GS passport, p.28 LSC report The contracts has been excluded from the monitoring parameter of Indicator 2. In SECTION G. Sustainability Monitoring Plan of GS passport and in SECTION E. DISCUSSION ON SUSTAINABILITY MONITORING PLAN of GS LSC Report please correct the numbering of indicators 4 and 5 shall be 3 and 4. Open Respond Round 2: Documents have been revised. Conclusion: Corrections were performed as requested. CAR 26: Please recheck the figures in tables 2 and Table 33 for 2019 different values are presented. Please indicate in Table 33 the total estimated amount of emission reductions and integrate to Table 33similar to Table 2 footnotes 11 and 12 (it will also be good to indicate in the footnotes that the adjustment to start and end date of crediting period was made based on calculations for 2012 and 2019 presented in table 17) Clarification Requests (CLs) PDD, Table 2 and 33 The PDD has been revised accordingly. Respond Round 1: The PDD has been revised accordingly. Rev 00 ( ), Version No.: 01 Page 58

59 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by validation team Reference Summary of project owner response Validation team conclusion CL 1. Please indicate in C Length of the first crediting period 3x7 crediting period CL 2: Please clarify where the equation 19 can be found (see p. 44, PDD: Since there are no consumption of fossil fuels due to the project activity, for the purpose other than electricity generation, there are no emissions from fossil fuel consumption and therefore PE FC,y is equal to 0 and has not been included in equation (19). Maybe equation 17 is meant here? CL 3: please explain why Relation between gross/net generation is calculated for , and not for , as the rest of analysis? Please also indicate the source for the data on Electricity Imports (MWh) for the year 2010? CL 4. Please explain why it is not envisaged to deposit any waste in ?? Please add short comment on this in PDD. CL 5: Please explain why in VER calc.file, sheet Input - Waste LFG fields L and W (deposited waste in t/year) has differens values? PDD, p.65 PDD, p. 44 CER calc. sheet, EFOM calc. sheet Table 22, PDD p. 53 The first crediting period is 7 years while the total renewed crediting period is 21 years with two times renewal (3x7). The statement under section C is correct under version 1 of the PDD. Equation number has been corrected accordingly. TEĐAŞ, has changed the format and content of its published statistics in 2010 and there is no available data for 2010, which could be used for correlation between net / gross for this year. Therefore a three years average of net / gross ratio for years has been adopted for calculations. Taking into account that the deviation through years for net/gross ratio is as small as 0.1% this could be considered as conservative. There will be no waste dumping to the waste lots that falls under the project activity after This explanation has been inserted under table 22 as a footnote. VER calc.file VER calc. file has been revised. Section C Length of the first crediting period has been revised as 3x7 years in accordance with the request. Rev 00 ( ), Version No.: 01 Page 59 Equation number has been corrected accordingly. In PDD. Clarification is clear and accetable. Conservative pincple is followed. The explanation is sufficent. VER calc. file has been revised accordingly.

60 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by validation team Reference Summary of project owner response Validation team conclusion CL 6: please clarify the source of data on the waste composition (line 15) in VER calc.file, sheet Input - Waste LFG CL 7: Please clarify how the parameter EC PJ (p.45, formula 18) was estimated - C.f. PDD p.57 For exante purposes the electricity consumption of the proposed project activity is estimated to be approximately 24 MWh/yr. CL 8 - please explain why the starting date of activity is chosen as CL 9. Please inform the validation team with the information on planned stakeholder feedback round (SFR) dates please note that the validation can be finished only 2 month after the start date of SFR process. The SFR results shall be indicated in SFR. VER calc.file The source of data on the waste composition is the Report on Kocaeli Province Waste Characterisation by Kocaeli University ( yc/poster/senayc _ poster. pdf). The reference has been made within the PDD under the relevant section. PDD, p.44 PDD, p.65 The estimation is based on the previous experience on Istanbul Landfill area, which is another LFG Project activity operated by the Project Participant. Taking into account that the actual emission reductions will be based on the actual monitored value of the EC PJ, the approach of estimating EC PJ for the purpose of ex-ante calculations should be considered conservative. As discussed during the site visit of the DOE, refers to the container purchase document. The container is purchased for the accommodation of the construction team and could be referred as the earliest action regarding construction. GS Toolkit The SFR has been started on by sending out the PDD, GS Passport and the LSC report to the stakeholders. The SFR will be closed on and the PDD and the GS Passport will be updated in accordance with the results of the SFR round. The reference is provided correctly in PDD. The explanation is sufficent. Explanation is sufficent. Please describe the means of SFR: -How it was conducted : to whom exactly the reports were sent, to which stakeholders? -In which way electronically/per post? -How it was assure that stakehoders can address their open issues to PP, if any will appear? Rev 00 ( ), Version No.: 01 Page 60

61 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by validation team Reference Summary of project owner response Validation team conclusion - Were any comments raised by stakeholders during GS feed backround? If yes, please provide exlanation Please provide evidences of SFR round performed copy of s, post receipts, fax receipts, comments from stakeholders in written form (if relevant), etc. Please note that: All stakeholders invited for participation in the Local Stakeholder Consultation have to be included in the Stakeholder Feedback Round. (GS Toolkit, p.54) Please follow the requirements to the SFR process specified on pp of GS Toolkit and update final version of GS Passport appropriately. Respond Round 2: The documents including the LSC report, the GS Passport and the PDD has been delivered to the stakeholders who have been selected as stakeholders to the project activity. The main communication method has been through s and delivery of hard copies of the mentioned documents for those who don t have an address (specifically the locals through the muchtar). Also the documents has been made available under the project participant s webpage ( The feedback round has started on Rev 00 ( ), Version No.: 01 Page 61

62 Table 2: Initial List of Requests for Corrective Action (CAR) and Clarification (CL) for GS-VER project Kocaeli Landfill Gas to Electricity Project Turkey Clarifications and corrective action requests by validation team Reference Summary of project owner response Validation team conclusion with sending out the documents to the stakeholders and no feedback has been received till Conclusion: SFR was conducted in appropriate manner and described in GS Passport. CL 10. Please explain how the EC BL,k,y (Net amount of electricity generated using LFG in year y) was estimated, i.e. based on which parameters/assumptions/sources? VER calc. sheet, sheet Emission Reductions The electricity generation is estimated based on the technical feasibility study. Please refer to the sent to the DOE on Explanation is sufficent. Relevant data can be found in feasibility study. Rev 00 ( ), Version No.: 01 Page 62

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