Voluntary Carbon Standard Project Description Template

Transcription

1 Voluntary Carbon Standard Project Description Template 19 November /11/2009 CONTENTS PAGE NOS. 1. Description of Project VCS Methodology Monitoring GHG Emission Reductions Environmental Impact Stakeholders comments Schedule Ownership 66 Annex 1: Baseline information Annex 2: Monitoring Information Annex 3: Data & Parameters available at validation Annex 4: Note on Cooperative Structure Annex 5: Abbreviations Annex 6: Description of calculation approach for auxiliary consumption of existing plants Annex 7: Details of Bagasse generated in Sugar Plant & consumption Annex 8- Project Implementation History 1

2 1 Description of Project: 1.1 Project title 16.0 MW bagasse based cogeneration project at Ahmadnagar, Maharashtra by M/s Mula Sahakari Sakhar Karkhana Ltd. 1.2 Type/Category of the project Sectoral Scope:1-Energy Industries (renewable - / non-renewable sources) Methodology No: ACM0006, Version 09 Title: Consolidated methodology for electricity generation from biomass residues The Project is not a grouped project. 1.3 Estimated amount of emission reductions over the crediting period including project size: Project: t CO 2 -e/yr Years Estimation of annual emission reductions in tons of CO 2 e Total estimated reductions Total number of crediting years A brief description of the project: The present VCS project activity is undertaken by M/s Mula Sahakari Sakhar Karkhana Ltd. in Ahmadnagar district of Maharashtra state, India. The project involves installation of a new 16 MW capacity steam turbine to generate electricity and export surplus power to the regional grid. The project activity will use bagasse, a by-product of sugar production, as fuel. The project activity thus proposes to reduce GHG emissions by displacing the fossil fuel dominated Integrated NEWNE grid based electricity with biomass residues based renewable electricity. The project activity will be operated in season as well as during off-season period of the sugar industry. The bagasse requirement for the project during the crushing season (180 days) is approximately 1,33,676 MT and during offseason( 15 days) is approximately 11,139 MT of biomass. A Power Purchase Agreement (PPA) has been signed between the project promoter, Mula Sahakari Sakhar Karkhana Ltd and the state electricity utility, Maharashtra State Electricity Board (MSEB). The power output from the turbo generator will be at 11 kv and this will be stepped up to 132 kv at the local step-up sub-station before being connected to grid. 2

3 Detailed description of the project has been provided in the section 1.9 of the document. 1.5 Project location including geographic and physical information allowing the unique identification and delineation of the specific extent of the project: Located on the bank of the river Pravara, Nevasa khurd, popularly known as Nevasa, is the head-quarters of the taluka bearing the same name. It covers an area of 13.2 square miles. Nevasa is twenty miles from Shrirampur railway station and is connected with it by road. The location of Village Sonai in this Taluka is north latitude and east longitude Figure 1: Map of India Figure 2: Map of Maharashtra showing Ahmadnagar 3

4 Figure 3: Sonai 1 in Ahmadnagar District 1.6 Duration of the project activity/crediting period: Project start date: 11/12/2006(Commissioning of the power plant) Duration of project activity: 25 years Crediting period start date: 11/12/2006(Commissioning of the power plant). Duration of crediting period: 10 years 1.7 Conditions prior to project initiation: (a) Scenario existing prior to the start of project activity Before project initiation, there was a 4 MW cogen plant which consisted of 3 boilers - 2X25, 1X35 TPH and 2 turbines and 2.5 MW installed capacity. This plant was fulfilling the steam and electricity requirements of the sugar plant. 1http:// 4

5 Figure 4: Pre Project Scenario Description of equipments operational in the pre-project scenario TG sets Type Capacity Residual Life Steam Turbine-Back Pressure Make: APE Bellis India Limited Type: MST Inlet Steam Pressure: 18/21 Kg/cm 2 Inlet Steam Temperature: C 2500 KW years (as on 02/07/2007) Generator Make:- Kirloskar Elect. Co. Ltd. Capacity: 3125 KVA Steam Turbine- Back Pressure Make- : Bellis & Morcom India Limited Type: MST Inlet steam pressure: 18.55/21.95 Kg/cm 2 Inlet Steam Temperature: C 1500 KW years (as on 02/07/2007) Generator Make: Jyoti Limited Capacity: 1875 KVA Boilers Type Capacity Fuel Type Fuel Quantity Residual Life Make: Texmaco Limited Design Pressure: 24 Kg/cm 2 Working Pressure: 21 Kg/cm 2 Working Temperature: 360 C Registration No: MR Make: Texmaco Limited Design Pressure: 24 Kg/cm 2 Working Pressure: 21 Kg/cm 2 Working Temperature: 360 C Registration No: MR TPH Bagasse MT years (as on 02/07/2007) 25 TPH Bagasse years (as on 02/07/2007) 5

6 Make: Texmaco Limited Design Pressure: 24 Kg/cm 2 Working Pressure: 21 Kg/cm 2 Working Temperature: 360 C Registration No: MR TPH Bagasse years (as on 02/07/2007) (b) Baseline Scenario With the plan to expand the crushing capacity of the mill from 2500 TCD to 3500 TCD in the year , the unavoidable need to expand the cogeneration facility was also felt. In view of this situation, there is a need to install additional new equipments. As per standard industry practice 2 existed then, for any sugar mill going for such an expansion would have implemented medium pressure steam technology i.e., 45 kg/cm2. The document to support this is provided in the foot note. Hence in the present case, the baseline scenario will be new power plants with the same thermal firing capacity as the project plant but with a lower efficiency (medium pressure technology). To corroborate this, the management had given purchase order for 55 TPH boiler with medium steam pressure technology (45 kg/cm2) and 3 MW turbine with a plan 3 to implement additional new equipments i.e., 25 TPH boiler(45 kg/cm2)and 1.5 MW TG in near future. The existing 35 TPH boiler and one of the existing TG(1.5 MW) would be operational with the above reference plant and all other boilers and TG would be kept as stand by plant as is the case in the project plant.. The configuration of the reference plant is represented in figure no As evident from the Resolution 15, of Board of Directors annual meeting, dated 04/10/1999, copy of the same has been submitted to the DOE. 6

7 25 TPH (45 kg/cm2) 1.5 MW Turbine Steam to process 55 TPH (45 kg/cm2) 3 MW Reference Plant Turbine Steam to process 35 TPH (21 kg/cm2) 1.5 MW 25 TPH (21 kg/cm2) Turbine Steam to process 25 TPH (21 kg/cm2) Standby Turbine Standb 2.5 MW Steam to process Figure no. 5: Baseline scenario Description of equipments that would have been operational in the reference plant. TG set 1 Type Capacity Residual life Steam Turbine-Back Pressure Make: M/s Bellis India Limited. Type: Inlet Steam Pressure: 45 Kg/cm 2 Inlet Steam Temperature: 440 +/-5 ºC C 3000 KW Minimum years as this would be a new TG. Generator Make:-M/s BHEL Capacity: 3750 KVA 7

8 TG set 2 Type 4 Capacity Residual life Steam Turbine-Back Pressure 1500KW Minimum years as this would be a new TG. Boiler 1 Type Capacity Fuel Type Fuel Quantity Residual life Supplier: Walchandnagar Industries 55 TPH Bagasse MT Minimum Ltd. Type: Natural Circulation bi drum years as this would be a new boiler. Water tube boiler Super heater outlet pressure: 45Kg/cm 2 Super heater outlet temperature: 440 +/-5 ºC Boiler 2 Type 5 Capacity Fuel Type Fuel Quantity Residual life Super heater outlet pressure: 25 TPH Bagasse MT Minimum Kg/cm 2 Super heater outlet temperature: 440 years as this would be a new boiler. +/-5 ºC 1.8 A description of how the project will achieve GHG emission reductions and/or removal enhancements: The present project activity utilizes bagasse to produce million KWh of electricity annually. In view of the present electricity generation scenario in India and in particular NEWNE grid to which the project activity is connected, the same amount of electricity, in absence of the project activity would otherwise be generated in the existing thermal power plants. The prevailing condition of electricity generation is apparent from the table 6 below, where the total installed capacity is MW and the share of thermal is Hence almost 65% of the total generation in the NEWNE grid comes from thermal power plants. Thus it can be safely concluded that the project activity leads to GHG emission reduction that would have occurred had the same amount of electricity been generated in grid connected thermal power plants. 4 Since purchase order was not placed, technical specification for the plant is not available. 5 Since purchase order was not placed, full technical specification for the plant is not available

9 Region wise installed capacity (MW) as on Project technologies, products, services and the expected level of activity: Technology 80 TPH (67 kg/cm2) 16 MW Project Plant Turbine Steam to process 35 TPH (21 kg/cm2) 1.5 MW 25 TPH (21 kg/cm2) Turbine Steam to process 25 TPH (21 kg/cm2) Standby Turbine Standb 2.5 MW Steam to process Figure no.6: Post Project Scenario The project activity uses bagasse, a by product of the sugar manufacturing process, to generate thermal and electrical energy. While the thermal energy is required by the mill for sugar processing, the electrical energy generated, after fulfilling the plants needs is evacuated to the state grid. The project activity involves the installation of a new bagasse fired power plant( co-generation) consisting of following equipments, which are operated next to the existing bagasse fired power plant( as 9

10 depicted in diagram 6) for approximately 195 days in a year and is based on regenerative Rankine cycle. It consists of the following major components: 1. Boiler & its Auxiliaries 2. Steam Turbine & Generator 3. Condenser 4. The Main Transformer Boiler: The Plant has installed one 80 TPH, water tube, travelling gate type, bagasse fuelled boiler from which steam is generated at 67 Kg/cm 2 at 495 c. Steam Turbine Generator: A double extraction cum condensing turbo set of capacity 16 MW has been installed at the plant site. The steam from boiler is used to drive the turbine. The extracted steam of the turbine at 8 kg/cm 2 pressure is supplied for sugar processing operations such as centrifugal washing, sulphur burner, sugar and feed water heating etc. and the other extracted steam at 2.5 kg/cm 2 pressure is supplied to the boiling house and for de-aeration. Condensate System: The condensate system includes a surface condenser, which condenses exhaust steam from the steam turbine, as well as other in-plant sources. Condensate from the sugar mill (process steam condensate) is piped directly to the deaerator. Transformer: The MSSKL complex in-houses one power turbine generator at 11 KV, to meet the electrical power requirements of the complex and export the balance to Maharashtra State Electricity Distribution Company Ltd. (MSEDCL). Power is stepped down to 433 V for supplying to sugar mill and cogen auxiliaries. Where as for export to the grid, it is stepped up to 132 KV. Equipment Specification TG Set Type Double Extraction cum condensing Inlet Steam Pressure: 64 Kg/cm2 Inlet Steam Temperature: 490 C Capacity KW Generator Type: Horizontal shaft three phase alternating current, synchronous generator of nominal capacity 20,000 kva based on normal steam flows, 11kV, 50 Hz at site condition of 45 degree C ambient, brush less exciter, automatic voltage regulators. Boiler Type Capacity Fuel Type Fuel Quantity 80 TPH Supplier: Walchandnagar Industries Ltd. Type: Natural Circulation bi drum Water tube boiler Super heater outlet pressure: 67Kg/cm2 Super heater outlet temperature: 495 +/-5 ºC 80 TPH Bagasse MT 10

11 No technology transfer has taken place with respect to the present project activity. Product The energy generated will be in terms of KWh of electricity and Tones of steam Service This cogeneration project generates both thermal & electrical energy. While the thermal energy is required for sugar mill operations, the electrical energy generated, after fulfilling the plants requirement is evacuated to the local grid. Expected level of activity Mode of operation Days /year Generation Capacity (MW) 7 Gross Generation (MWh) Auxiliary Consumption (MWh) 8 Net Generatio n capacity (MWh) Season ( hrs/day) Off- Season (24 hrs/day) Total Annual Generation Compliance with relevant local laws and regulations related to the project: The present project activity is in compliance with all the relevant local laws and regulation as discussed in the later section of the PD (section 2.5, Sub-step 1B) Identification of risks that may substantially affect the project s GHG emission reductions or removal enhancements: Cane availability- As bagasse is an agricultural crop residue, any fluctuations in the avaibility of sugar cane will directly affect the availbity of bagasse and so power generation potential of the project. The Indian cane production is subject to cyclic 9 forces, a typical cycle consisting of two good years followed by two bad years and then an average year. This cycle repeats every five years. The same can be verified by a more or less regular pattern of cane production peaks and troughs in the graph below for the past 13 years. 7 As per Appendix XI a and b of the Detailed Project Report, Prepared by Mitcon Consultancy Services Ltd, January As per Appendix XI a and b of the Detailed Project Report, Prepared by Mitcon Consultancy Services Ltd, January Auxiliary consumption during season is 1.5 MW & 1.4 MW is during off-season. 5www.dwarikesh.com/downloads/dsil_presentation.ppt 11

12 Production of Sugarcane in Maharashtra Lakh Tons Years Graph No. 7-Sugarcane production in entire Maharashtra Demonstration to confirm that the project was not implemented to create GHG emissions primarily for the purpose of its subsequent removal or destruction. The project activity was proposed to be implemented with the primary objective of meeting the increased energy requirements of the sugar plant. The project activity uses bagasse which is a by product of the Mill s core production process. Bagasse being a biomass residue is considered as carbon neutral on account of it releasing an equivalent amount of carbon that the plant stored in its lifetime. Thus its combustion does not alter the carbon pool. Hence, it can be safely concluded that, the project was not implemented to create GHG emissions primarily for the purpose of its subsequent removal or destruction Demonstration that the project has not created another form of environmental credit (for example renewable energy certificates). The present project activity has not created any other form of environmental credit. The declaration from the PP is submitted to the DOE 1.14 Project rejected under other GHG programs (if applicable): The project has not been rejected under any other GHG programs Project proponents roles and responsibilities, including contact information of the project proponent, other project participants: Roles and responsibilities: The project promoter has the ownership of the project and is ensuring operation and maintenance of all the equipments for their efficient functioning. The PP will record the entire data required for the calculation of GHG emission reduction due to the project and will be made available to the DOE during the verification process. 6SUGARINDIA, Year book 07; & 2007 (Sugar Statistics Table 3) 12

13 Organization: M/s Mula Sahakari Sakhar Karkhana Ltd. Street/P.O.Box: Sonai, Taluka Newasa, District Ahmednagar City: Sonai State/Region: Maharashtra Postfix/ZIP: Country: India Telephone: to Fax: Represented by: Mr. S. T. Choudhary 1.16 Any information relevant for the eligibility of the project and quantification of emission reductions or removal enhancements, including legislative, technical, economic, sectoral, social, environmental, geographic, site-specific and temporal information.): The following information pertains to the eligibility of the project and quantification of emission reductions or removal enhancements: Legislative: Policy support for grid interactive renewable power Electricity Act Section 86. (1): The State Commission shall discharge the following functions. (e):promote cogeneration and generation of electricity from renewable sources of energy by providing suitable measures for connectivity with the grid and sale of electricity to any person, and also specify, for purchase of electricity from such sources, a percentage of the total consumption of electricity in the area of a distribution licensee; National Electricity Policy The National Electricity Policy 2005 stipulates that progressively the share of electricity from nonconventional sources would need to be increased; such purchase by distribution companies shall be through competitive bidding process; considering the fact that it will take some time before nonconventional technologies compete, in terms of cost, with conventional sources, the commission may determine an appropriate deferential in prices to promote these technologies. Tariff Policy The Tariff Policy announced in January 2006 has the following provision: Pursuant to provisions of section 86 (1) (e) of the Act, the Appropriate Commission shall fix a minimum percentage for purchase of energy from such sources taking into account availability of such resources in the region and its impact on retail tariffs. Such percentages for purchase of energy should be made applicable for the tariffs to be determined by the SERCs latest by April 01, Technical: Grid emission factor used for calculating emission reduction values has been referred from CO 2 Baseline Database for the Indian Power Sector; User Guide Version 4.0 published by Central Electricity Authority List of commercially sensitive information (if applicable):

14 Not applicable. 2 VCS Methodology: 2.1 Title and reference of the VCS methodology applied to the project activity and explanation of methodology choices: Title: Consolidated methodology for electricity generation from biomass residues Reference: Approved consolidated baseline and monitoring methodology ACM0006 (Version 09) The methodology also refers to ACM0002 Consolidated baseline methodology for grid-connected electricity generation from renewable sources (Version 09, EB 45) and the Combined tool to identify the baseline scenario and demonstrate additionality (Version 02.2). 2.2 Justification of the choice of the methodology and why it is applicable to the project activity: The selected methodology ACM0006 version 09 is applicable to grid-connected and biomass residue fired electricity generation project activities, including cogeneration plants. Under this methodology, following project activities are included: Applicability Criteria The selected methodology ACM0006 (Version 09) is applicable to biomass residue fired electricity generation project activities, including cogeneration plants The project activity may include the following activities or combination of these: Installation of a new biomass residue fired power plant at a site where currently no power generation occurs (Greenfield power projects) The installation of a new biomass residue fired power plant, which replaces or is operated next to existing power plants fired with either fossil fuels or the same type of biomass residue as in the project plant (power capacity expansion projects) The improvement of energy efficiency of an existing power plant e.g. by retrofitting the existing plant or by installing a more efficient plant that replaces the existing plant (energy efficiency improvement projects) Replacement of fossil fuels by biomass residues in an existing power plant (fuel switch projects) Project case The Project activity utilizes bagasse which is an agricultural residue to generate thermal as well as electrical energy. As MSSKL is implemented the 16 MW project activity which is operated next to existing power plants fired, leading to an increase in power/heat generation capacity, it is covered under the second category that is, Power Capacity Expansion Projects. The plant also meets the applicability conditions specified under ACM0006 (Version 09) 14

15 No other biomass types than biomass residues, as defined in the methodology are used in the project plant and these biomass residues are the predominant fuel used in the project plant The project activity fires only bagasse in the boilers hence this criteria is fulfilled. The project activity is installed in a sugar mill where bagasse is a by product of core production process. Hence bagasse is available free of cost. For projects that use biomass residues from a production process (e.g. production of sugar or wood panel boards), implementation of the project shall not result in an increase of the processing capacity of raw input (e.g. sugar, rice, logs, etc.) or in other substantial changes (e.g. product change) in this process The project activity will not alter the production process in any way. Albeit its common practice in sugar mills to keep expanding their capacity, however any increase in capacity will never result because of the project activity. The biomass residues used by the project facility should not be stored for more than a year. No significant energy quantities, except from transportation or mechanical treatment of biomass residues, are required to prepare the biomass residues for fuel combustion, i.e. projects that process the biomass residues prior to combustion. The bagasse saved during season is used completely during the following off season hence there is no question of storing the bagasse for more than a year. No energy is required for the preparation of biomass residue. In season the bagasse generated by the sugar plant manufacturing process directly fired in the boiler. For off-season operation, the saved bagasse during seasonal operation will be used. The project activity meets all the applicability conditions of the methodology and hence justifies the selection of approved consolidated baseline methodology ACM0006 version 09 for the proposed project activity. 2.3 Identifying GHG sources, sinks and reservoirs for the baseline scenario and for the project: Project boundary assumed for calculating emission reduction includes Cogeneration power project, the metering equipment and substation, and the part of grid which is used for the transmission of generated electricity 15

16 Gases included within the Project Boundary Figure 8: Sources included Within the Project Boundary 16

17 Source Gas Status Justification/Explanation Baseline Project activity Grid electricity generation CO2 Included Main emission source CH4 Excluded Excluded for simplification. This is conservative N2O Excluded Excluded for simplification. This is conservative Heat generation CO2 Excluded Excluded for simplification. This is conservative CH4 Excluded Excluded for simplification. This is conservative Uncontrolled burning or decay of surplus biomass residues On-site fossil fuel and electricity consumption due to the project activity (stationary or mobile) Off-site transportation of biomass residue Combustion of biomass residues for electricity generation and/or heat generation N2O Excluded Excluded for simplification. This is conservative CO2 Excluded Excluded for simplification. This is conservative CH4 Excluded The biomass prior to the project activity was being used in the existing boilers. It was not burnt or left to decay naturally. N2O Excluded Excluded for simplification. This is conservative CO2 Included In the event of firing fossil fuels or use of electricity, this forms the main emission source. CH4 Excluded Excluded for simplification. This emission source is assumed to be very small. N2O Excluded Excluded for simplification. This emission source is assumed to be very small. CO2 Excluded The Project does not import fuel from outside hence not required. CH4 Excluded Excluded for simplification. This emission source is assumed to be very small. N2O Excluded Excluded for simplification. This emission source is assumed to be very small. CO2 Excluded It is assumed that CO2 emissions from surplus biomass do not lead to changes of carbon pools in the LULUCF sector. CH4 Excluded Excluded for simplification. N2O Excluded Excluded for simplification. This emission source is assumed to be small. Storage of biomass residues CO2 Excluded Since the biomass is stored for not longer than 1 year, this emission source is assumed to be small. CH4 Excluded Since the biomass is stored for not longer than 1 year, this emission source is assumed to be small. N2O Excluded Excluded for simplification. This emission source is assumed to be very small Waste water from the treatment of biomass residues CO2 Excluded It is assumed that CO2 emissions from surplus biomass residues do not lead to changes of carbon pools in the LULUCF sector. CH4 Excluded Project activity does not lead to generation of waste water and hence there is no need for anaerobic treatment. N2O Excluded Excluded for simplification. This emission source is assumed to be small. 2.4 Description of how the baseline scenario is identified and description of the identified baseline scenario: Determination of Baseline Scenario As per the consolidated methodology ACM0006, Version 09 the selection of most plausible alternative must be based on the latest approved version of the Combined tool to identify the baseline scenario and demonstrate additionality version Step 1: Identification of alternative scenarios This Step serves to identify all alternative scenarios to the proposed CDM project activity(s) that can be the baseline scenario: In applying Step 1 of the combined tool, realistic and credible alternatives should be separately determined regarding: 17

18 How power would be generated in the absence of the CDM project activity; What would happen to the biomass residues in the absence of the project activity; In case of cogeneration projects: how the heat would be generated in the absence of the project activity POWER GENERATION Scenario/ Alternative P1 P2 P3 Description The proposed project activity not undertaken as a CDM project activity The continuation of power generation in an existing biomass residue fired power plant at the project site, in the same configuration, without retrofitting and fired with same type of biomass residues as co-fired in the project activity. - The generation of power in an existing captive power plant, using only fossil fuels-. (Included/Excluded) Comments Included- This can be considered as a plausible alternative. Excluded-In absence of the proposed project activity, MSSKL would have operated the reference plant for which part of the purchase order for boiler and turbine had already been undertaken at the time of decision on the project activity, hence this option cannot be considered as an alternative. Excluded-This is not the common practice in the sugar sector 14. In general sugar plants meet their electricity requirement through cogeneration plant during season and if necessary, import electricity from the grid for off-season requirements. Hence this does not form a viable option P4 The generation of power in the grid.- Included-In absence of project activity, an equivalent amount of power, which is exported by project activity, would be generated in existing and/or new grid-connected power plants. Hence this may be considered as a possible baseline scenario. P5 The installation of a new biomass residue fired power plant that is fired with the same type and with the same annual amount of biomass residues as the project activity, but with a lower efficiency of electricity generation (e.g. an efficiency that is common practice in the relevant industry sector) than the project plant and therefore with a lower power output than in the project case. Included-In absence of the proposed project activity, MSSKL would have operated the lower efficiency reference plant as described in figure 5 of section 1.7 b, the purchase orders for part of the equipments were already placed. This reference plant would have lower efficiency of electricity generation as compared to the project activity. Thus this can be considered as a credible alternative to the project activity Page 27 of 44 18

19 P6 P7 P8 P9 P10 The installation of a new biomass residue fired power plant that is fired with the same type but with a higher annual amount of biomass residues as the project activity and that has a lower efficiency of electricity generation (e.g. an efficiency that is common practice in the relevant industry sector) than the project plant. Therefore the power output is the same as in the project case. The retrofitting of an existing biomass residue fired power, fired with the same type and with the same annual amount of biomass residues as the project activity, but with a lower efficiency of electricity generation (e.g. an efficiency that is common practice in the relevant industry sector) than the project plant and therefore with a lower power output than in the project case. The retrofitting of an existing biomass residue fired power plant that is fired with the same type but with a higher annual amount of biomass residues as the project activity and that has a lower efficiency of electricity generation (e.g. an efficiency that is common practice in the relevant industry sector) than the project activity.- The installation of a new fossil fuel fired captive power plant at the project site. The installation of a new single- (using only biomass residues) or co-fired (using a mix of biomass residues and fossil fuels) cogeneration plant with the same rated power capacity as the project activity power plant, but that is fired with a different type and/or quantity of fuels (biomass residues and/or fossil fuels). The annual amount of biomass residue used in the baseline scenario is lower than that used in the project activity; Excluded- At current levels of operation, the electrical and thermal requirement of the mill could be adequately addressed by reference plant complemented with the existing cogen unit. Hence installation of a plant with higher annual firing capacity would not be required. Moreover, MSSKL had already placed part of the order for the reference plant plant. Because of reasons stated above, this option is ruled out. Excluded-This option cannot be considered as in the absence of project activity, a lower efficiency reference plant as discussed in section 1.7bwould have come up. Excluded-This option cannot be considered as in the absence of project activity, reference plant as discussed in section 1.7b would have come up. Excluded-This is not a common practice in the sugar sector. In general sugar plants meet their electricity requirement through cogeneration plant during season and import electricity from the grid for off-season requirements. Moreover in the absence of project activity, a lower efficiency reference plant would have come up. Hence this does not form a viable option Excluded-The core business of MSSKL is sugar production. Bagasse is a by-product of this process hence is available to the plant free of cost. With a calorific value of 3550 Kcal/Kg, it forms an excellent fuel for generation of electricity required by the sugar mill complex and its auxiliaries. Use of any other fuel is not economically viable for the plant 19

20 P11 The generation of power in an existing fossil fuel fired cogeneration plant co-fired with biomass residues, at the project site. and hence cannot be considered as a plausible option. Excluded-This option can not be considered as a plausible alternative for the present case as prior to the present project activity, bagasse was used for the generation of electricity and heat. Hence credible options for power generation are: P1, P4 and P5 HEAT GENERATION Scenario/ Description Alternative H1 The proposed project activity not undertaken as a CDM project activity H2 The proposed project activity (installation of a cogeneration power plant), fired with the same type of biomass residues but with a different efficiency of heat generation (e.g. an efficiency that is common practice in the relevant industry sector). H3 The generation of heat in an existing captive cogeneration plant, using only fossil fuels (Included/Excluded) Comments Included- This can be considered as a plausible alternative. Included-In absence of the project activity, PP had planned to install two boilers of55 and 25 TPH, 45 Kg/cm 2 pressure, part investment for which had already been undertaken, hence this can be considered as a plausible alternative. Excluded-The mill does not have any captive cogeneration plant using only fossil fuels hence this option cannot be considered for the promoter. H4 H5 H6 H7 The generation of heat in boilers using the same type of biomass residues. The continuation of heat generation in an existing biomass residue fired cogeneration plant at the project site, in the same configuration, without retrofitting and fired with the same type of biomass residues as in the project activity. The generation of heat in boilers using fossil fuels The use of heat from external sources, such as district heat Excluded-The cogeneration process as a whole is more efficient than separate generation of electricity and heat Besides this generation of heat in separate boilers is not the common practice 15 in the sugar industry in India. Excluded-In absence of the proposed project activity, MSSKL would have installed a reference plant( as discussed in section 1.7b), purchase order for the part of reference plant was already in place. Hence this can not be considered as plausible alternative. Excluded-Use of fossil fuels exclusively, for heat generation in sugar industries is not the common practice in this region and will also lead to higher baseline emissions. Hence, it cannot be taken as baseline scenario. Excluded-There is no district heating system in the region; hence it cannot be taken as baseline scenario Page no 9(In India, almost all sugar mills have been practising some form of cogeneration) 20

21 H8 H9 H10 Other heat generation technologies (e.g. heat pumps or solar energy) The installation of a new single- (using only biomass residues) or co-fired (using a mix of biomass residues and fossil fuels) cogeneration plant with the same rated power capacity as the project activity power plant, but that is fired with a different type and/or quantity of fuels (biomass residues and/or fossil fuels). The annual amount of biomass residue used in the baseline scenario is lower than that used in the project activity; The generation of power in an existing fossil fuel fired cogeneration plant cofired with biomass residues, at the project site. Excluded-Sugar mills need both steam and electricity. Use of other heat generation technologies (e.g. heat pumps or solar energy) is not the common practice in sugar industry in India 16. Excluded-The core business of MSSKL is sugar production. Bagasse is a by-product of this process hence is available to the plant free of cost. With a calorific value of 3550 Kcal/Kg, it forms an excellent fuel for generation of electricity required by the sugar mill complex and its auxiliaries. Use of any other fuel is not economically viable for the plant and hence cannot be considered as a plausible option. Excluded-This option can not be considered as a plausible alternative for the present case as prior to the present project activity, bagasse was used for the generation of electricity and heat. Hence the credible options for heat generation are: H1 and H2. For the use of biomass, the realistic and credible alternative(s) may include, inter alia: Scenario/ Alternative B1 B2 Description The biomass residues are dumped or left to decay under mainly aerobic conditions. This applies, for example, to dumping and decay of biomass residues on fields. The biomass residues are dumped or left to decay under clearly anaerobic conditions. This applies, for example, to deep landfills with more than 5 meters. This does not apply to biomass residues that are stock piled or left to decay on fields. B3 The biomass residues are burnt in an uncontrolled manner without utilizing it for energy purposes. B4 B5 The biomass residues are used for heat and/or electricity generation at the project site. (Included/Excluded) Comments Excluded-Bagasse generated by sugar mills in the region is a useful resource and is not dumped or left to decay in fields. Hence, it cannot be taken as baseline scenario. Excluded-As stated above bagasse is a useful resource and is not left to decay in landfills. Hence this option is not financially viable. Excluded-This option is not viable because bagasse is a useful resource and is not burnt in uncontrolled manner without utilizing it for energy purposes. Included-In the absence of project activity, the reference plant with following specifications would have come up -3MW & 1.5 MW TG along with 55 TPH and 25 TPH boilers of 45 Kg/cm 2 pressure. The bagasse generated at site would have been used as fuel for this reference plant; hence this forms a plausible alternative. The biomass residues are used for power Excluded-In the absence of project activity, 16http:// page 27 of 44 21

22 B6 B7 B8 generation, including cogeneration, in other existing or new grid connected power plants. The biomass residues are used for heat generation in other existing or new boilers at other sites. The biomass residues are used for other energy purposes, such as the generation of bio fuels. The biomass residues are used for non-energy purposes, e.g. as fertilizer or as feedstock in processes (e.g. in pulp and paper industry). the bagasse that would be generated in the sugar mill complex would have been used in the reference plant. The same quantity is now fired in the project activity; hence diversion of biomass from other power plants to the project activity is not taking place. Excluded-The project activity will utilize the bagasse available from cane crushing in the sugar mill complex. Pre- project case, the same quantity would have been fired in the reference plant. MSSKL does not intend to buy bagasse from outside. Hence this cannot be considered as a plausible option. Excluded-Generation of bio fuels from bagasse is not the prevalent use of bagasse in this region hence this option cannot be considered as a plausible scenario. Excluded-Whatever amount of bagasse the mill would have used for its cogen plant in the pre project scenario will be required for post project operations as well. Even in the absence of the project activity the mill would have required this amount of bagasse for its reference plant hence this cannot be considered as a possible option. Hence the only credible alternative would be B4. Outcome of Sub Step 1a: List of plausible alternative scenarios to the project activity Following individual alternatives (for power, heat and biomass) have emerged from the above mentioned analysis. Power Heat Biomass P1- The proposed project activity H1- The proposed project activity B4- The biomass residues are not undertaken as a CDM project not undertaken as a CDM project used for heat and/or electricity activity. activity generation at the project site P4- The generation of power in H2- The proposed project activity the grid. (installation of a cogeneration P5- The installation of a new power plant) industry sector. biomass residue fired power plant the project case. Sub-step 1b: Consistency with mandatory applicable laws and regulations All the alternative scenario for the present case pertains to the generation of heat and electricity from the renewable energy source i.e. Bagasse. The relevant laws and regulation pertaining to generation of energy from renewable sources are: 22

23 Electricity Act National Electricity Policy Tariff Policy The above mentioned laws and regulations do not restrict the alternatives in any way. Outcome of Step 1b: All the plausible alternative scenarios for the proposed project activity under the heads power generation, heat generation and biomass as listed above are in compliance with mandatory legislation and regulations under existing practices. Based on the plausible alternatives mentioned above, in line with ACM0006 version 09 the credential combination(s) of baseline scenarios for power, heat and biomass is (are): S.N Scenari Baseline Scenario Description of Situation o. o Power Heat Biomass P5: and P4: H2 B4 The project activity involves the installation of a new biomass residue fired power plant, which is operated next to (an) existing biomass residue fired power plant(s). The existing plant(s) are only fired with biomass residues and continue to operate after the installation of the new power plant. In the absence of the project activity, a new biomass residue fired power plant (in the following referred to as reference plant ) would be installed instead of the project activity at the same site and with the same thermal firing capacity but with a lower efficiency of electricity generation as the project plant (e.g. by using of a low-pressure boiler instead of a highpressure boiler). The same type and quantity of biomass residues as in the project plant would be used in the reference plant. Consequently, the power generated by the project plant would in the absence of the project activity be generated(a) in the reference plant and since power generation is larger in the project plant than in the reference plant (b)partly in power plants in the grid. In case of cogeneration projects, the following conditions apply: The reference plant would also be a cogeneration plant; The heat generated by the project plant would in the absence of the project activity be generated in the reference plant P5: and P4: H2 B4 The project activity involves the replacement of an existing biomass residue fired power plant by a new biomass residue fired power plant. The replacement increases the power generation capacity. In the absence of the project activity, the existing plant would also be replaced by a new biomass residue fired power plant (referred to as reference plant ), however, this reference plant would have a lower

24 efficiency of electricity generation than the project plant (e.g. by using a low-pressure boiler instead of a high-pressure boiler). The same type and quantity of biomass residues as in the project plant would be used in the reference plant. Consequently, the power generated by the project plant would in the absence of the project activity be generated (a) in the reference plant and since power generation is larger in the project plant than in the reference plant (b) partly in power plants in the grid. The new project plant has the same technical lifetime as the reference plant. In case of cogeneration projects, the following conditions apply: The reference plant would also be a cogeneration plant; The heat generated by the project plant would in the absence of the project activity be generated in the reference plant. In scenario 18, the existing plant is completely replaced by the PA, whereas in 13 it continues to operate along with the project plant; which is the case here. Hence, the only plausible alterative to the project activity is scenario 13, which also describes the actual situation of project activity The other alternative to the project activity is The proposed project activity not undertaken as a CDM project activity. Thus the plausible alternative scenarios to the project activity are: 1. Scenario 13 of Consolidated methodology for electricity generation from biomass residues ACM0006 version 09 i.e. the implementation of the reference plant. 2. The proposed project activity not undertaken as a CDM project activity. 2.5 Description of how the emissions of GHG by source in baseline scenario are reduced below those that would have occurred in the absence of the project activity (assessment and demonstration of additionality): ADDITIONALITY Additionality of the project has been demonstrated by using Combined tool to identify the baseline scenario and demonstrate additionality. Following diagram represents the steps to be undertaken for demonstration of additionality for the present case. 24

25 Step 1 has already been undertaken in section 2.4. In this section the project activity is being tested against the rest of the steps. As stated in the section 2.4 of the PD, alternative scenarios identified in Step 1 are 1. Project Activity undertaken without CDM 2. Scenario 13 of Approved consolidated baseline and monitoring methodology ACM0006. Proceed to Step 2 (Barrier analysis) Step 2: Barrier analysis This Step serves to identify barriers and to assess which alternatives are prevented by these barriers. Apply the following Sub-steps: Sub-step 2a: Identify barriers that would prevent the implementation of alternative scenarios 25

26 Barriers Alternative 1- Project Activity undertaken without CDM Alternative 2- Scenario 13: Installation of a new biomass residue fired reference plant A. Investment barriers, other than insufficient financial returns I. Access to finance (debt from the FIs was only assured after considering the CER Revenues). The implementation of project activity faces Investment barrier in particular access to finance (debt from the FIs). Due to the implementation of the project plant, MSSKL had to invest substantial incremental cost to the tune of Rs Million. The break up the project cost and the reference plant is presented in the subsequent section. As per the debt: Equity ratio (75:25) decided by the board for the implementation of the project activity, the additional debt component was in the tune of Rs million. For this the PP has applied for taking a loan from the bank. This loan was sanctioned by the bank only after considering the revenues from carbon credit, whereas the loan for the reference plant was already in place. The certification by the bank mentioning that the loan appraisal process for the project activity took account explicitly of the revenues from carbon credit has been submitted to the DOE. Hence it is concluded that the project activity faces investment barrier which does not prohibit the implementation of the reference plant. For implementation of the reference plant, MSSKL would need a mere Rs Million as equity and requires only Million as debt from the FIs. The debt component from the FIs was already in place for the implementation of reference plant. Hence this barrier is not prohibitive for the reference plant. 26

27 B. Technological barriers Departing from the conventional practice at that time when high pressure (67 kg/cm 2 ) and double extraction cum condensing turbines were being used for bagasse based cogeneration only in few cooperative sugar mills in the country, MSSKL decided to proceed with this high pressure technology, and became the first mill in Maharashtra (as per data from Vasantdada 20 Sugar Institute, Pune, India) to have opted for this high-pressure double extraction cum condensing cogeneration technology. At that point of time the high pressure technology had neither penetrated the market significantly nor was tested. Hence the cooperative mills were more comfortable working with the lower pressure systems operating at Kg/cm 2. As high-pressure cogeneration configurations are not widely used in the sugar industries, The existence of the technological barrier for this high pressure steam technology is further confirmed by the fact that the use of this technology in the considered sector (i.e. co-operative sugar mill in Maharashtra) was almost nil at the time of project conceptualization. e.g. 0%. At the time when MSSKL conceptualised this project activity, cogen boilers operating at 45 kg/cm 2, which is the reference plant configuration, had penetrated already y to the tune of 12 % as presented below. Hence this barrier is not prohibitive for the implementation of the reference plant. Outcome of Step 2a: List of barriers that may prevent one or more alternative scenarios to occur. It is thus evident from the above analysis that the reference plant is not prohibited by any of the above mentioned barriers and can be considered as the baseline scenario. On the other hand the barriers that prevent project activity to be undertaken without CDM benefits are: 1. Investment barriers (Access to finance i.e. debt from the FI was assured only after considering revenue from carbon credit into account)- The total cost of the project was estimated at Rs Million. Out of this 25% was to be raised by equity and rest 75% to be procured as loan from FIs as decided by the board. 20 As per the letter of Vasantdada Sugar Institute which is an Autonomous Institute dedicated to the cause of research and other scientific work in connection with the trade or industry related to sugarcane/ sugar beet or other sugar bearing plants, sugar by-products and allied industries in India. 27

28 The cost break up for the project activity and the reference plant is summarized in table below: Particulars Project Plant 21 Reference Plant 22 Civil Work Rs. Lacs Site Development Rs. Lacs Other Civil Costs Major Plant & Machinery Misc. Fixed Assets Preliminary Expenses Preoperative Expenses ( Excl IDC) Contingencies Working Capital margin Total Project Cost A comparison of the project cost (with break-up of means of finance) incurred by the PP in undertaking the project activity as against their original plan of reference plant has been detailed below: Project Activity Reference Plant Estimated Project Cost Rs Million Rs Million Means of Finance- Debt Equity Ratio 75:25 75:25 Estimated Debt component Rs. 360 Million Rs Million Estimated Equity Component Rs. 120 Million Rs Million Reserve in Rs Million It is evident from the above tables that for the implementation of the project plant, MSSKL had to borrow Rs. 360 Million from the FIs, where as for the reference plant only Rs Million was required from the FIs. This debt of Rs Million for the implementation of the reference plant was already in place. Hence this barrier is not prohibitive for the implementation of the reference plant. In Maharashtra, a majority of the cooperative sugar mills have limited potential to raise loans because of poor financial and liquidity positions 24. MSSKL is a co-operative sugar factory and the above mentioned barrier is cumulated to a large scale due to the ownership structure of the co-operative sugar factory (explained in annex 4). The major barrier for any sugar mill to undertake cogeneration with high-pressure configuration (which is more capital intensive as compared to low pressure configuration) is access to finance as demonstrated above. 21 As per Schedule A of the DPR prepare by Mitcon Consultancy Services Limited January For reference plant the entire project cost is not available. On the basis of available project cost. on the basis of available project cost i.e.boiler (55 TPH) and TG (3MW), the entire project cost of the reference plant is determined. This bifurcation of the project cost is certified by Registered by Charted Engineer (IEI), reference no and evidence for the same is submitted to the DOE. 23 As per the Annual Report of MSSKL for the year , page no Standing Committee on Energy ( ), Eighth report Non-conventional energy sources biomass power/co-generation programme an evaluation.(ministry of non-conventional energy sources ). (Paragraph 2.6) 28

29 The above mentioned claim can be further substantiated by the Eighth Report 25 of The Standing Committee on Energy clearly spells out that main hurdles in the programme exist in the fact that in some states particularly in Maharashtra, the sugar mills are in the cooperative sector and they face difficulties in limited access to funds and also in raising equity component of the investment in the programme. Also, there is heavy management risk in the projects as the cooperative sector is subject to frequent changes in the management and perception of risk in the Biomass Cogeneration Projects is high. It is further supported by the statement from a union minister of India 26 the sugar co-operative sector in Maharashtra has not been able to raise funds for setting up cogeneration plants, as they never had balance funds. Profit made by the cooperatives was passed on to the member of the cooperative in the form of higher rate for sugarcane. Consequently, they could not raise funds or debts for cogeneration plants.. As per the GUIDELINES FOR OBJECTIVE DEMONSTRATION AND ASSESSMENT OF BARRIERS EB 50, annex 13 guideline 6 In case the PPs make the claim for investment barriers, they should demonstrate in the PDD that the financing of the project was assured only due to the benefit of the CDM. Therefore, it should be demonstrated that the loan approval (or other significant financing decision(s)) by the lender takes explicitly the CDM registration into account. In present case bank had borrowed the loan only after considering the CDM registration into account. Certificate from the Ahmednagar District Co-operative Bank has submitted to the DOE, which explicitly demonstrate the above claim. Hence it can be safely concluded that the investment barrier is prohibitive barrier for the implementation of the project activity, where as it would not affect the implementation of reference plant. The above mentioned barrier can be summarized as: Access to finance- The financial institutions were reluctant to finance the project and have sanctioned the term loan only after considering revenues from sale of carbon credits. 2. Technological barriers MSSKL had faced technological barrier due to non-availability of the high pressure steam technology in the relevant geographical area and the sector. The geographical area is selected as the state of Maharashtra and the industry sector is selected as co-operative sugar industries. Geographical area has been considered as Maharashtra because circumstances (like regulatory policies, investment environment & sugar cane crop cycle) differ from each state across India. This is further explained in common practice analysis. Industry sector has been selected as co-operative sector, as the structure & ownership of co-operative is different as compare to the private sugar industries. The ownership structure of the co-operative sugar industry is explained in annex 5. The co-operative sugar mills typically distribute their profits as dividends through the cane price to members (sugar cane farmers). The hallmark of a cooperative sector, which is different from a private sector, is the inclusion of all farmers as shareholders of the processing unit regardless of the size of their holding. A typical mill caters to 20,000 shareholding farmers. The revenue, after deducting collection and processing costs is distributed among the members depending on individual contribution. Hence any project activity coming up in a cooperative sector cannot be compared to that in a private sector. As the present project activity is being undertaken by a cooperative sugar mill, the demonstration is being limited to other cogeneration projects of cooperative. 25 Standing Committee on Energy ( ), Eighth report Non-conventional energy sources biomass power/co-generation programme an evaluation. (Ministry of non-conventional energy sources ). (Section 2.19)

30 When MSSKL conceptualized this project, it was the first 27 cooperative sugar mill in Maharashtra to have gone for 67 Kg/cm 2 pressure boiler which enabled it to export surplus power to grid. Following publically available data represents the boiler pressure configuration of cooperative sugar mills operating in the year 2000 in Maharashtra. Pressure ( Kg/Cm 2 ) Number of Industries The same data is presented in the chart below. Source 28 : Cooperative Sugar Directory & Year book published in the year 2000 by National Sugar Federation of cooperative sugar factories Ltd., New Delhi. It is apparent from the above mentioned table and the chart that at the time of conceptualization there were 8 plants operated at the pressure similar to the reference plant and none of them have opted for the pressure similar to the project plant. Thus the standard pressure configuration of the boiler during this period was 21, 32 and 45 Kg/cm 2 and the percentage penetration of high pressure boiler i.e. 67 kg/cm 2 was nil. Hence it can be safely concluded that this low or nil penetration of high pressure boilers in the co-operative sugar mills in Maharashtra was due to the technological barriers associated with them. It is imperative to mention here that MSSKL is co-operative sugar mill (detailed of co-operative framework is given in annex 4of the PD) and the technological know how in the co-operative sugar mills are very poor. Also the financial (discussed in investment barrier) status of the mill was also not good at the time of decision making. Thus, these technological barrier (discussed above) becomes more prohibitive. Existence of technological barrier to the implementation of the project plant can be confirmed by the stipulations made under the GUIDELINES FOR OBJECTIVE DEMONSTRATION AND ASSESSMENT OF BARRIERS EB 50, annex 13, where a example has been given which states that The existence of a 27 As per VSI letter 28 Hard copy of the same has been submitted to the DOE. 30

31 technological barrier for high pressure steam technology is confirmed by showing evidence that the use of this technology in the considered sector is marginal e.g. below10%.. For the present case the operation of this high pressure boiler in relevant sector (i.e. co-operative sugar mill in Maharashtra) was almost nil. Thus it fulfills the stipulation made under this guidance. Hence it can be safely concluded that implementation of the project plant faced technological barrier, which did not prohibit the implementation of the reference plant. Sub-step 2b: Eliminate alternative scenarios which are prevented by the identified barriers The alternative which is prevented by the identified barriers is the implementation of project without CDM. Outcome of Step 2b: List of alternative scenarios to the project activity that are not prevented by any barrier- This alternative is the implementation of the reference plant. Step 3: Investment analysis As per the paragraph 4, page 7 of the Combined tool to identify the baseline scenario and demonstrate additionality Version 02.2 the PP may proceed directly to the step 4 if the following points are demonstrated: 1) If there is only one alternative scenario that is not prevented by any barrier, and if this alternative is not the proposed project activity undertaken without being registered as a CDM project activity: From the justification described above it is evident that the alternative which is not prevented by the barriers identified is the reference plant not the present project activity without CDM. 2) Explain using qualitative or quantitative arguments how the registration of the CDM project activity will alleviate the barriers that prevent the proposed project activity from occurring in the absence of CDM. Revenue from carbon credits will help in alleviating the identified barriers in the following way Facilitate access to the capital requirements of the project activity since loan was sanctioned only with the consideration of revenues from carbon credits The expected VCU revenues will be in tune of Rs Million /year, which is significant and would definitely help to overcome the increased risk associated with the technological barrier as demonstrated above. Hence for the present case step 3 has not been carried out. Step 4: Common practice analysis According to Combined tool to identify baseline and demonstrate additionality, common practice analysis should demonstrate: The analysis to which extent similar activities to the proposed CDM project activity have been implemented previously or are currently underway. Similar activities are defined as activities (i.e. technologies or practices) that are of similar scale, take place in a comparable environment, inter alia, with respect to the regulatory framework and are undertaken in the relevant geographical area, as defined in Sub-step 1a above. Other registered CDM project activities are not to be included in this analysis. Provide documented evidence and, where relevant, quantitative information. 29 Considering a rate of 6 Euros per VER. The present transaction rate for Euro to INR is 68 i.e. 1 Euro= Rs. 68 INR 31

32 Geographical scope of common practice analysis has been restricted to Maharashtra because of following reasons: 1. There are only six to seven sugar producing states in India, hence common practice analysis of entire India is not appropriate. Moreover the states differ widely in terms of regulatory policies 30, hence comparison with sugar mills from other states will not give a realistic picture. 2. Maharashtra has the maximum 31 number of cooperative sugar factories in India. The total percentage of co-operatives working in Maharashtra is 90 % as compared to private entities in the State. The hallmark of a cooperative sector, which is different from a private sector, is the inclusion of all farmers as shareholders of the processing unit regardless of the size of their holding. A typical mill caters to 20,000 shareholding farmers. The revenue, after deducting collection and processing costs is distributed among the members depending on individual contribution. Hence any project activity coming up in a cooperative sector cannot be compared to that in a private sector. As the present project activity is being undertaken by a cooperative sugar mill, the demonstration of common practice is being limited to other cogeneration projects of cooperative. When MSSKL decided to go ahead with the high pressure boiler 32, none of the co-operative sugar mill in Maharashtra had implemented such high pressure boiler. Pressure ( Kg/Cm 2 ) Number of Industries The following table gives an overview of the potential for Bagasse-based Cogeneration in Major Sugar Producing States in India and the installed capacity till December State Potential (in Commissioned till MW) 34 December 31, 2002 (in MW) Maharashtra 1, % Uttar Pradesh 1, % Tamil Nadu % Percentage of the Potential 30 Each of these states have their own regulatory commission.. This reference website provides details (link) of different, State Electricity Regulatory Commissions in India. Hence each SERC have the right to regulate the purchase of power and hence investment environment differs across each state. 31 Refer to First Quarter report on Feasibility Study for Standalone renewable energy biomass cogeneration plants in the cooperative sugar sector. Published by Agrienergy, Page no.-09. Hardcopy of the same has been submitted to the DOE ata and above pressure boiler is considered as high pressure boiler. Page no. 1 of the report. UKL /ReviewInitialComments/QGYACESPRFWRNUIHHLOXCK63UOOUUS 33 Cooperative Sugar Directory & Year book published in the year 2000 by National Sugar Federation of cooperative sugar factories Ltd., New Delhi. Hard copy of the same has been submitted to the DOE

33 Karnataka % Andhra Pradesh % Bihar % Gujarat % Punjab % Others % Total 3, % Thus cogeneration based on bagasse in sugar mill is not a common practice in Maharashtra and only 2.45% of the potential was harnessed as on 31 st December 2002 against a potential of 1000 MW. While other states like Uttar Pradesh, Tamil Nadu, Karnataka, Andhra Pradesh, Punjab had a percentage of 4.65%, 30.29%, 36.49%, 80.03% and 14.67% respectively. The above mentioned 2.45% harnessed till 31 st especially in co-operative sugar mill. December 2002 consists mainly of low pressure system This is evident from the Letter of Vasantdada Sugar Institute, Pune, where it has been certified that the present project activity is the second project in the state of Maharashtra having a co-generation system with 67 Kg/cm 2 boiler in co-operative sector. The only other similar activity 35 to that of the Project activity with comparable environment, which was implemented in a co-operative sugar mill in Maharashtra, is that of Pandurang SSKL which was commissioned in July 2006 and is in the process of availing 36 CDM benefits. Hence as per the Combined tool to identify baseline and demonstrate additionality it can not be considered in the list and it can be concluded that the project is not a common practice. This clearly shows that investing in projects of this nature is not a common practice and the project activity of MSSKL is additional. 35 Refer to the letter from Vasantdada Sugar Institute, Pune

34 Flow chart of the steps followed for the demonstration of additionality in present case: This diagram is sourced from combined tool 37 and is representative of the steps followed for identification of baseline scenario and demonstration of additionality in this particular case. 3 Monitoring: 3.1 Title and reference of the VCS methodology (which includes the monitoring requirements) applied to the project activity and explanation of methodology choices:

35 The approved consolidated monitoring methodology ACM0006 version 09: Consolidated methodology for electricity generation from biomass residues, Version 09 is used. 3.2 Monitoring, including estimation, modelling, measurement or calculation approaches: As per the VCS PD Template following details should be included in this section. Separate tables for each of the monitored parameter considering the following requirements are described in this section. Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality Parameter- EG project plant,y Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modeling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality Net quantity of electricity generation from the cogeneration plant To monitor the net quantity of electricity generation as a result of the project activity during the year y. It is measured and calculated data and unit is MWh MSSKL log book details. Calculation will be done based on the gross electricity generation minus auxiliary consumption. Monitoring will be done on daily basis. MSSKL Plant operators and shift engineer. Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Parameter- EG Total,y Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modeling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality Net quantity of electricity generation from all power plants at the site. To monitor the net quantity of electricity generation from all power plants at the site. It is a measured and calculated value and unit is MWh MSSKL log book details. Calculation will be done based on the gross electricity generation minus auxiliary consumption. Monitoring will be done on daily basis. MSSKL Plant operators and shift engineer. Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Parameter- EG historic,3yr Net quantity of electricity generated during the most 35

36 Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality recent three years in all power plants at the project site, generated from firing the same type(s) of biomass residues as in the project plant. It is measured and calculated data and unit is MWh. MSSKL log book details. Calculation will be done based on the gross electricity generation minus auxiliary consumption from all power plants operated in the last three years. Monitoring will be done on daily basis. MSSKL Plant operators and shift engineer. Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. To monitor net quantity of electricity generated during the most recent three years in all power plants at the project site during the year y. Parameter- BF k,y Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Quantity of biomass residue type k combusted in the project plant during the year y To monitor the Quantity of biomass residue type k combusted in the project plant during the year y Calculated based on the procedure described in the annex 3 of the PD. Unit- MT Records maintained at the plant Indirect measurement based on the universally practiced model in the Sugar industry. This model is based on the following formula: Weight of Bagasse (MT) produced from the sugar industry = Weight of cane (MT) +Weight of added water (MT) Gross weight of juice (MT) For individual boiler, steam to fuel ratio has been used to determine the quantity of bagasse combusted in that particular boiler. Steam to fuel ratio for different boilers is given in the annex 3 of the PD. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality Monitoring will be done on daily basis. Plant operators and shift engineers in co-ordination with the production in-charge. Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Parameter- BF all power plants, k,y Purpose of monitoring Quantity of biomass residue type k combusted in all power plants at the project site during the year y To monitor the quantity of biomass residue type k combusted in all power plants at the project site during 36

37 Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modeling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality the year y. Calculated based on the model described in the annex 3 of the PD. Unit- MT MSSKL record books. Monitoring is based on the following model: Total Bagasse fired in all power plants (MT) = Total bagasse generated (MT) Saved Bagasse (MT). Monitoring will be done on daily basis. Cogen- Manager in co-ordination with shift engineers and Plant operators. Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Parameter- NCV k Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modeling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality Parameter- Moisture Percentage Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality Net calorific value of bagasse To determine the Net calorific value of bagasse. Calculated based on the indirect measurement described in the annex 3 of the PD. Unit- KJ/Kg MSSKL Record Books. Calculation is based on the model prescribed in the Handbook 38 of Cane Sugar Engineering by E. Hugot and System of Technical control for cane sugar factories in India. Monthly Basis Chief Chemist Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Moisture Percentage in the Bagasse. To calculate the dry weight of the bagasse fired in the co-generation plant. Measurement based on the laboratory analysis by using moisture meter. Unit: % MSSKL Record book. Monitoring is based on the laboratory analysis. Monitoring will be done on monthly basis. Chief Chemist Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Parameter- Q Tot,proj,y 38 The hard copy of the reference has been submitted to the DOE. 37

38 Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality Total quantity of heat that is generated in the project plant during the year y To determine the total quantity of heat generated by the project plant. It is measured and calculated data and unit is TJ. MSSKL Log book. Calculation will be done based on the Steam enthalpy of the superheated steam minus enthalpy of feed water. Monitoring will be done on daily basis. MSSKL Plant operators and shift engineer. Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Parameter- EF CO2,FF,i CO2 emission factor for fossil fuel type I i.e. coal Purpose of monitoring To calculate the project emissions occurring from the present project activity. Types of data and information to be Data will be taken from the official source. For the reported, including units of measurement. present case IPCC default emission factor has been used. Origin of Data IPCCC default value Monitoring including estimation, -- modelling, measurement or calculation approaches. Monitoring times and periods, considering Will be updated on the recent available version of IPCC. the needs of intended user Monitoring roles and responsibilities -- Managing data quality -- Weight of cane Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality To calculate total bagasse generated in the sugar plant in a year. Data will be measured, unit is MT/year MSSKL Record book Weigh Bridge has been used to measure weight of cane on daily basis (in crushing season). Daily MSSKL Sugar Plant Personel Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Weight of added water Purpose of monitoring Types of data and information to be reported, including units of measurement. To calculate total bagasse generated in the sugar plant in a year. Data will be measured, unit is MT/year 38

39 Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality MSSKL Record book Weight of water added to bagasse in the mills will be measured by weighing tank. Daily MSSKL Sugar Plant Personnel Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Gross weight of juice Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality To calculate total bagasse generated in the sugar plant in a year. Data will be measured, unit is MT/year MSSKL Record book Weight of mix juice coming out of mills will be measured by using weighing tank installed at the plant. Daily MSSKL Sugar Plant Personnel Data will be archived in hard copy and the monthly report will be archived in the electronic form as well. Saved Bagasse Purpose of monitoring Types of data and information to be reported, including units of measurement. Origin of Data Monitoring including estimation, modelling, measurement or calculation approaches. Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality To calculate total bagasse generated and quantity of bagasse fired in different boilers at the site in the sugar plant in a year. Data will be calculated, unit is MT/year MSSKL Record book The quantity of saved bagasse can be calculated by using the following enumeration. Saved Bagasse (MT) = Total bagasse generated (MT) Total bagasse fired (MT). Yearly at the end of crushing season MSSKL Sugar Plant Personnel Data will be archived in hard copy and the yearly report will be archived in the electronic form as well. 3.3 Data and parameters monitored / Selecting relevant GHG sources, sinks and reservoirs for monitoring or estimating GHG emissions and removals: Data / Parameter: Data unit: Description: EG project plant,y MWh The net quantity of electricity generation as a result of the project activity during the year y. 39

40 Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: MSSKL log book Monitored will be done through energy meters installed at the project site. Calculated from gross electricity generated after deducting auxiliary consumption. The energy meters installed at the project site will be calibrated at regular intervals. Any comment: Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Any comment: Data / Parameter: Data unit: Description: EG Total,y MWh Net quantity of electricity generated in all power plants at the project site, generated from firing the same type(s) of biomass residues as in the project plant, including the new power plant installed as part of the project activity and any previously existing plants, during the year y. Individual meters & log book Monitored through meters.calculated from gross electricity generated after deducting auxiliary consumption. For project plant there is dedicated meter to monitor the auxiliary consumption. The existing boilers and TG are not equipped with the meters to monitor the auxiliary consumption. The conservative estimation of the auxiliary consumption has been provided in annex 6 of this document. All the meters will be periodically calibrated to avoid any redundancy in the results. All the meters will be calibrated as per national standard or manufacturers recommendation. In case Fossil Fuel is used in the project site, then the calculation will be done on the basis of foot note 17 of the applied methodology. EG historic,3yr MWh Net quantity of electricity generated during the most recent three years in all power plants at the project site, generated from firing the same type(s) of biomass residues as in the project plant (MWh) 40

41 Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Any comment: Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Any comment: Individual meters & log book Monitored through meters.calculated from gross electricity generated after deducting auxiliary consumption. For project plant there is dedicated meter to monitor the auxiliary consumption. The existing boilers and TG are not equipped with the meters to monitor the auxiliary consumption. Detail description of the auxiliary consumption has been provided in annex 6 of this document. All the meters will be periodically calibrated to avoid any redundancy in the results. All the meters will be calibrated as per national standard or manufacturers recommendation. In case Fossil Fuel is used in the project site, then the calculation will be done on the basis of foot note 17 of the applied methodology. BF k,y Tons Quantity of biomass residue type k combusted in the project plant during the year y Calculated Monitoring of the quantity of bagasse combusted in the project plant is different during season as well as off-season. During season the bagasse quantity is calculated based on the procedure explained in the annex 3 of the PD. During off-season weighed bagasse will be used. Bagasse will be weighed in weigh bridge. Cross check the measurements with an annual energy balance that is based on the generated quantities and stock changes. The quantity should be cross checked with the quantity of electricity (and heat) generated. The daily bagasse consumption will be calculated & stored both in electronic & paper form. The weigh bridge, and necessary instruments required to measure the heat generation will be calibrated annually. Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions BF all power plants, k,y Tons Quantity of biomass residue type k combusted in all power plants at the project site during the year y. Calculated

42 Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Any comment: Monitoring of the quantity of bagasse combusted in the project plant is different during season as well as off-season. During season the bagasse quantity is calculated based on the procedure explained in the annex 3 of the PD. During off-season weighed bagasse will be used. Bagasse will be weighed in weigh bridge. Cross check the measurements with an annual energy balance that is based on the generated quantities and stock changes. The quantity should be cross checked with the quantity of electricity (and heat) generated. The daily bagasse consumption will be calculated & stored both in electronic & paper form. The weigh bridge, and necessary instruments required to measure the heat generation will be calibrated annually. Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: NCV k GJ/Tonne Net calorific value of biomass residue type k Calculated Indirect measurement is carried out at MSSKL laboratory. The details of the procedure has been explained in the annex 3 of the PD. The procedure followed is as per System of Technical control for cane sugar factories in India. Consistency of the measurements may be cross checked by comparing the measurement results with previous years, relevant data sources (e.g. values in the literature, values used in the national GHG inventory) and default values by the IPCC. Any comment: -- Data / Parameter: Moisture content of the biomass residues Data unit: % Description: Moisture content of each biomass residue type k Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: Lab measurement at MSSKL laboratory 50% The measurement will be carried out by using standard procedure described in System of Technical control for cane sugar factories in India, detailed has been provided in annex 3 of the PD. 42

43 QA/QC procedures to be applied: Any comment: Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Any comment: Value can be Cross checked with the average values of the relevant sector. Q Tot,proj,y GJ/year Total quantity of heat that is generated in the project plant during the year y On-site measurements Net heat generation is determined as the difference of the enthalpy of the steam generated by the project cogeneration plant minus the enthalpy of the feed water and any condensate return. The respective enthalpies should be determined based on the mass (or volume) flows rate of steam, steam temperatures (in case of superheated steam), steam pressure. Steam tables or appropriate thermodynamic equations may be used to calculate the enthalpy as a function of temperature and pressure. The fraction of heat generated from firing biomass residues should be determined by dividing the quantity of biomass residues fired by the total quantity of all fuels fired, both expressed in energy quantities All the instrument will be calibrated as per national law or manufactures recommendation. Data will be archived until 2 years after the end of the crediting period. Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Any comment: FF project plant,i,y Tons Quantity of fossil fuel type i combusted in the project plant during the year y On-site measurements 0 Onsite measurements by using weigh bridges. Weigh bridges will be periodically calibrated (annually). The quantity of coal can be cross verified by the coal receipts of the supplier. The PP does not intend to use coal, however in case of emergency and if and when it is used, the emission from this will be deducted from the Emission Reduction. 43

44 Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: EF CO2,FF,i tco2/gj CO2 emission factor for fossil fuel type I i.e. coal PP will use accurate and reliable local or national data where available. Where such data is not available, IPCC default emission factors (country-specific, if available) will be used if they are deemed to reasonably represent local circumstances. Choose the value in a conservative manner and justify the choice. IPCC default value 2006 Value of data The used data will be calculated from data of official source. The data will be monitored annually if coal is used. -- Any comment: PP does not intend to use coal, however in case of emergency and if and when it is used, the emission from this will be deducted from the Emission Reduction. Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: NCV i GJ/kg Net Calorific Value of fossil fuel type I i.e. coal Either obtained from the supplier or will use accurate and reliable local or national data where available. Where such data is not available, IPCC default emission factors (country-specific, if available) will be used if they are deemed to reasonably represent local circumstances. Choose the value in a conservative manner and justify the choice. IPCC default value 2006 The used data will be calculated from data of official source. The data will be monitored annually if coal is used. -- Any comment: Data / Parameter: Data unit: Description: Source of data to be used: PP does not intend to use coal, however in case of emergency and if and when it is used, the emission from this will be deducted from the Emission Reduction. Weight of cane MT/year Total weight of sugar-cane crushed in a year On site measurement. 44

45 Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Weigh Bridge has been used to measure weight of cane on daily basis(in crushing season). Weigh bridges used to monitor this parameter will be calibrated annually. Any comment: This parameter will be used for the calculation of total bagasse generated in a year. Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Weight of added water MT/year Weight of water added to bagasse in the mills. On site measurement. -- Weight of water added to bagasse in the mills will be measured by weighing tank. The weighing tank will be calibrated annually as per the manufactures specification. Any comment: This parameter will be used for the calculation of total bagasse generated in a year. Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Gross weight of juice MT/year Weight of mix juice coming out of mills. On site measurement. -- Weight of mix juice coming out of mills will be measured by using weighing tank installed at the plant. The weighing tank will be calibrated annually as per the manufactures specification. Any comment: This parameter will be used for the calculation of total bagasse generated in a year. 45

46 Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: Saved Bagasse MT/year Quantity of saved bagasse in a year. Calculated -- The quantity of saved bagasse can be calculated by using the following enumeration. Saved Bagasse (MT) = Total bagasse generated (MT) Total bagasse fired (MT). Total bagasse generated and total bagasse fired in different boiler will be calculated by using the approach described in annex-2 of the document. QA/QC procedures to be applied: The quantity of saved bagasse can be cross checked by verifying the bagasse sell receipts and the balance bagasse available for the off-season. Any comment: -- Data / Parameter: GCVi,y ( for the calculation of grid emission factor) Data unit: Kcal/kg Description: Gross Calorific Value of differ fossil fuels used in a year y Source of data to be used: Central Electricity Authority 39 Value of data applied for the Coal 3,755 purpose of calculating Gas 8,800 expected emission reductions Oil Diesel Description of measurement methods and procedures to be applied: Naphtha 11,300 Simple OM,: Once for each crediting period using the most recent three historical years for which data is available at the time of submission of the CDM-PDD to the DOE for validation (ex-ante option). BM: For the first crediting period, either once ex-ante. For the second and third crediting period, only once exante at the start of the second crediting period. QA/QC procedures to be applied: CEA Database version 4, 46

47 Any comment: The gross calorific value (GCV) of the fuel has been used instead of NCV, as gross calorific values has used for the calculation of emission factor by Central Electricity Authority. The value of the same is publically available. 3.4 Description of the monitoring plan As per the ISO , monitoring of GHG project means continuous and periodic assessment of GHG emissions and removals or other GHG related data. Monitoring plan has been developed to trace following requirement/information for the present project. Origin of Data Monitoring times and periods, considering the needs of intended user Monitoring roles and responsibilities Managing data quality The proposed project activity is equipped with Distributed Control System and energy meters installed to measure export (to grid), import (from grid) & for all auxiliary consumption for the project. The operators 40 & the attendants of the plant are appointed for the monitoring of all desired parameters in the power plant and they used to record all the parameters in log-books on hourly basis. Online monitoring is carried out by means of Distributed Control System (DCS) & the daily records will be stored in electronic form. The roles and responsibility of different plant personnel is described in the following table: Plant Personnel Managing Director/ Head CDM team Chief Engineer Cogeneration Manager Shift Engineers Chief Chemist Operators at plant site working in different shifts Roles & Responsibility Managing Director will monitor the performance of entire CDM team Chief Manager will be entitled to do co-ordinate between the technical team and management. Cogen Manager will be entitled to look over the entire monitoring and will prepare a annual monitoring report for the project. In case of any problem, cogen manager will report to the CDM head. Shift engineer of the first shift in a day will review all the data of previous day and report to the Cogen manager. Chief Chemist will look after the monitoring of certain parameters like moisture content and NCV in coordination with the co-gen manager. Operators working in different shift will record the data in log books and report on a daily basis to the shift engineers. The management of the plant will designate persons who will be responsible for the monitoring of data as per the applied baseline and monitoring methodology i.e. ACM0006, version 09. The designated person will collect all data to be monitored as mentioned in the tables in section 3.3 of VCS PD and will report to the Managing Director (MD) of the plant. The overall VCS project management responsibility will remain with the MD of MSSKL. The Cogeneration plant will be managed by Power Plant Manager. The Deputy Chief Engineer, will be maintaining all records pertaining to electricity generation and bagasse procurement. The hourly recording of data will be done by shift operators that will be checked and verified by the shift in-charge 40 The competency certificates of all the operators & Engineers has been submitted to the DOE. 47

48 at the end of each shift. This data will be compiled as a daily report in the formats developed at the site by the Deputy Cogen Manager. This daily report will be sent to Cogen manager for verification. The daily reports will be used collectively to prepare a monthly report. The monthly report will be prepared by Cogen Manager and send to plant MD for verification. The monthly reports will become a part of the Management Information System (MIS) and will be reviewed by the management during the quarterly review meeting. The data recorded will be archive both in electronic and paper form. Training will be conducted each year for all the employees working in the project plant.qa/qc procedure will be applied to each of the parameter (mentioned in section 3.3) of the PD. All the monitoring equipments will undergo periodic calibration (as per the schedule (discussed in section 3.3 of the report) and in case of malfunctioning it will be replaced immediately or sent for calibration. The Co-gen manager will report such events to the VCS head Operation and Management Structure and The hierarchy of origin of data, and its subsequent flow are given below:- Operation and Management Structure The meters used for data recording will be calibrated at regular intervals, as per the national standard or manufacturer s recommendations and they will be maintained as per the instructions provided by their suppliers. Hence there are no uncertainties or adjustments associated with data to be monitored. The calibration and maintenance of equipments will be looked over by the Instrument Engineer. In case of malfunctioning of the energy meters, it will replaced by a pre-calibrated energy meter or will be subjected to repair if possible. All the data and reports will be kept at the offices of the sugar mill until 2 years after the end of the crediting period or the last issuance of VCUs for the project activity, whichever occurs later. 4 GHG Emission Reductions: 4.1 Explanation of methodological choice: The project activity mainly reduces CO 2 emissions through substitution of power generation from fossil fuels by energy generation with biomass. The emission reduction ERy by the project activity during a given year y is - 48