FINAL VALIDATION REPORT

Transcription

1 FINAL VALIDATION REPORT LODOS ELEKTRĐK ÜRETĐM A. Ş. KEMERBURGAZ WIND FARM PROJECT: EMISSION REDUCTIONS FROM GRID CONNECTED RENEWABLE ELECTRICITY GENERATION. Report No: /95 TÜV NORD CERT GmbH JI/CDM Certification Program Langemarckstrasse Essen, Germany Phone: Fax: Date:

2 P-No.: /95 Abbreviations BAU CA CDM CER CO 2 CO 2 e CP CR DNA EB EIA GHG GS HCA IRR SC LoA MP NCV ODA PDD PLF PP QC/QA SD UNFCCC VER VO VVM WTG Business as usual Corrective Action / Clarification Action Corrective Action Request Clean Development Mechanism Certified Emission Reduction Carbon dioxide Carbon dioxide equivalent Certification Program Clarification Request Designated National Authority CDM Executive Board Environmental Impact Assessment Greenhouse gas(es) Gold Standard Host Country Approval Internal Rate of Returns Stakeholder Consultation Letter of Approval Monitoring Plan Net Calorific Value Official Development Assistance Project Design Document Plant Load Factor Project Proponent Quality control/quality assurance Sustainable Development United Nations Framework Convention on Climate Change Verified Emission Reduction Voluntary Offset Validation Verification Manual Wind Turbine Generators Page 2 of 84

3 P-No.: /95 Table of Contents Page 1 INTRODUCTION Objective Scope GHG Project Description Project Scope Project Parties Project Entities Project location Technical project description 7 2 VALIDATION TEAM METHODOLOGY Validation Protocol Review of Documents Follow-up Interviews Resolution of Clarification and Corrective Action Requests Stakeholder Comments Finalising the report 11 4 VALIDATION FINDINGS Participation Requirements/ Host Country Check Project type eligibility screen Project design 14 5 VALIDATION OPINION REFERENCES...16 ANNEX: VALIDATION PROTOCOL...21 SUMMARY TABLE: PRE-FEASIBILITY ASSESSMENT...59 VALIDATION FINDINGS...63 Page 3 of 84

4 P-No.: /95 1 INTRODUCTION Lodos Elektrik Üretim A.Ş. has commissioned the TÜV NORD JI/CDM Certification Program (CP) to validate the project: Kemerburgaz wind farm project: Emission reductions from grid connected renewable electricity generation. with regard to the relevant requirements of the Gold Standard for Gold Standard VER project activities. 1.1 Objective The purpose of this validation is to have an independent third party assess the project design. In particular the project's baseline, the monitoring plan (MP) and the project s compliance with - the requirements of the Gold Standard for Voluntary Offset Projects, - relevant decisions and requirements by the UNFCCC - other relevant rules, including the host country (Turkey) legislation and sustainability development criteria are validated in order to confirm that the project design as documented is sound and reasonable and meets the stated requirements and identified criteria. Validation is seen as necessary to provide assurance to stakeholders on the quality of the project and its intended generation of voluntary emission reductions (VERs). 1.2 Scope The validation scope is given as an independent and objective review of the project design, the project s baseline study and monitoring plan (based on ACM0002/ Version 7: Consolidated baseline methodology for grid-connected electricity generation from renewable sources ) which are included in the PDD and other relevant supporting documents. The items covered in the validation are described below: Gold Standard & Host Country Criteria - Gold Standards requirements, as stated in the Gold Standard Validation and Verification Manual for Voluntary Offset Projects (June 2007) and following documents - Host country requirements / criteria VER Project Description Page 4 of 84

5 P-No.: /95 - Project design - Project boundaries - Predicted VER project GHG emissions Project Baseline - Baseline methodology - Baseline GHG emissions - Additionality Monitoring Plan - Monitoring methodology - Indicators/data to be monitored and reported - Responsibilities Background investigation and follow up interviews Stakeholder consultation - Initial stakeholder consultation as per GS - Review of comments Draft validation reporting with s & CRs, if any Final validation reporting. The information included in the PDD and the supporting documents were reviewed against the requirements and criteria mentioned above. The TÜV NORD JI/CDM CP has, based on the recommendations in the Validation and Verification Manual /VVM/,/GS- VVM/, employed a risk-based approach in the validation, focusing on the identification of significant risks for project implementation, sustainability criteria and the generation of VERs. The validation is based on the information made available to TÜV NORD JI/CDM CP and on the contract conditions. TÜV NORD JI/CDM CP can not be held liable by any entities for making its validation opinion based on any false or misleading information supplied to it during the course of validation. The validation is not meant to provide any consulting to the project participant. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the project design. 1.3 GHG Project Description Project Scope The considered GHG project can be classified as a VER project in the sector given in Table 1-1 (according to List of Sectoral Scopes of UNFCCC). Page 5 of 84

6 P-No.: /95 Table 1-1: Project Scope(s) No. Project Scope 1 Energy industries (renewable - / non-renewable sources) Under the GS the project qualifies under type A.1 renewable energy Project Parties Turkey and Switzerland are the two parties involved in the project activity. Both of them are not considered as project participants Project Entities The following entities are involved in the developing of the project: Project Participant 1 LODOS ELEKTRðK ÜRETðM A. Ş. Ucarlar Han. No. 10 Istanbul Bankalar Yanikapi Tenha Sk Turkey Contact person: Project Participant 2 Contact Person: Mr. Mehmet Ucar Director Tel No: Fax No: altoholding@altoholding.com ESSENT Trading International A.S. Glacis-de-Rive Geneva Switzerland Ms. Natalia Gorina Emission Portfolio Manager Tel No: Fax No: natalia.gorina@essenttrading.com Project location The proposed project is implemented at Kemerburgaz, approximately 35 km northwest from Istanbul. The unique identification is provided in table 1-2. However, please refer to A1. Page 6 of 84

7 P-No.: /95 Table 1-2: Project Location Host Country Turkey Region: Bankalar Yanikapi Tenha Sk. Coordinates Latitude: Longitude: Technical project description The proposed project activity is a wind power project. The project activity encompasses the erection of 12 WTGs with each 2 MW capacity made of ENERCON. According to the prevailing wind class the WTG type E-82 with a rotor diameter of 82 m and a hub height of 78m was chosen. The expected annual generated electricity is 85.3 GWh and the net exported electricity to the Turkish national power grid is assumed to be GWh/y. The annual GHG emission reductions from this project activity account for 49,690 tco 2eq. The electricity generated will be jointly stepped up at 34.5kV via a Transformer Substation and connected to Turkish National Grid. The key parameters for the Project are given in table 1-3: Table 1-3: Key parameters of the proposed VER project activity Wind Turbine Type: E-82 Manufacturer: ENERCON Quantity: 12 Rated Power per unit: 2 MW Equivalent annual operating 3346 hours: Capacity factor 38.2 % Transmission line length 3.5 km Transmission line voltage 34 kv Wind farm output transformer 34.5 kv Turbine concept Gearless, variable speed, variable pitch control Rotor type Upwind rotor with active pitch control Direction of rotation Clockwise Number of blades 3 Swept area m 2 Blade material Fibreglass (epoxy resin); integrated lightning protection Rotational speed Variable, 6 19,5 rpm Pitch control ENERCON blade pitch system, one independent pitching system per rotor blade with allocated emergency supply Page 7 of 84

8 P-No.: /95 2 VALIDATION TEAM On the basis of a competence analysis and individual availabilities a validation team, consistent of one team leader and 3 additional team members, were appointed. Furthermore also the personnel for the technical review and the final approval was determined. The list of involved personnel, the tasks assigned and the qualification status are summarized in the table (3-2) below. Table 3-2: Involved Personnel Name Company Function 1) Qualification Status 2) Sectoral competence Technical competence Host country Competence Controlling competence Mr. Ms. Saalmann, Martin TÜV NORD CERT, Germany TM A x x - x Mr. Ms. Karan, Sinan External Expert TE T - x x - Mr. Ms. Krupp, Eric TÜV NORD CERT, Germany FA SA x x - x Mr. Ms. Richter, Alexander TÜV NORD CERT, Germany TM E x x - - Mr. Ms. Winter, Rainer Mr. Ms. Beyer, Katja TÜV NORD CERT, Germany TÜV NORD CERT, Germany TL SA x x - x TR A x x - x 1) TL : Team Leader; TM : Team Member, TR: Technical review; FA: Final approval; TE Technical Expert 2) GHG Auditor Status: A : Assessor; E : Expert; SA: Senior Assessor; T : Trainee Certificates of appointment for the above mentioned team members are enclosed in annex 6 of this report. Page 8 of 84

9 P-No.: /95 3 METHODOLOGY The pre-validation of the project was carried out from September 08 to November 08. The pre-validation consisted of the following three phases: A desk review of the PDD (incl. annexes) and supporting documents with the use of a customised validation protocol according to the Validation and Verification Manual /VVM/, /GS-VVM/ ; Back ground investigation and follow-up interviews with personnel of the project proponent, the consultant, legal authorities and other stakeholders; Reporting of validation findings taking into account the public comments received on TUV NORD website. The draft validation report includes Corrective action and Clarification Requests ( and CR) identified in the course of this validation. A Corrective Action Request is established if mistakes have been made in assumptions or the project documentation which directly will influence the project results, the requirements deemed relevant for validation of the project with certain characteristics have not been met or there is a risk that the project would not be registered by the UNFCCC or that emission reductions cannot be verified and certified. A Clarification Request is issued where information is insufficient, unclear or not transparent enough to establish whether a requirement is met. 3.1 Validation Protocol In order to ensure consideration of all relevant assessment criteria, a validation protocol was used. The protocol shows, in a transparent manner, criteria and requirements, means of verification and the results from pre-validating the identified criteria. The validation protocol serves the following purposes: - It organises, details and clarifies the requirements that a CDM resp. VER GS project is expected to meet; - It ensures a transparent validation process where the independent entity will document how a particular requirement has been validated and the result of the determination. The validation protocol consists of three tables: Table 1 (Requirement Checklist), Table 2 (summary table: pre-feasibility assessment) and Table 3 (Gold Standard Page 9 of 84

10 P-No.: /95 Specific Checklist). The draft validation report finally provides a summary of all findings made during the pre-validation process. The completed validation protocol is enclosed in the annex to this report, identifying 19 Corrective Action Requests and 7 Clarification Requests. Validation Protocol Table 1 and 2: Requirement checklist Checklist Question Reference Means of verification (MoV) Comment Draft and/or Final Conclusion The various requirements in Table 1 are linked to checklist questions the project should meet. The checklist is organised in seven different sections. Each section is then further sub-divided. The lowest level constitutes a checklist question. Gives reference to documents where the answer to the checklist question or item is found. Explains how conformance with the checklist question is investigated. Examples of means of verification are document review () or interview (I). N/A means not applicable. The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. This is either acceptable based on evidence provided (), or a Corrective Action Request () due to non-compliance with the checklist question (See below). Clarification is used when the validation team has identified a need for further clarification. Figure 1: Validation protocol tables Page 10 of 84

11 P-No.: / Review of Documents The draft PDD submitted by Lodos Elektrik Üretim A.Ş. in August 2008 and supporting background documents related to the project design and baseline were reviewed. Furthermore, the validation team used additional documentation by third parties like host party legislation, technical reports referring to the project design or to the basic conditions and technical data. The documents that were considered during the validation process are given in chapter 6 of this report. They are listed as follows: Documents provided by the project proponent (Table 6-1) Background investigation and assessment documents (Table 6-2) Websites used (Table 6-3). In order to ensure the transparency of the decision making process, the reference codes listed in tables 6-1 to 6-3 are used in the validation protocol and as far applicable in the report itself. 3.3 Follow-up Interviews On 24 th and 25 th September 2008, the TÜV NORD JI/CDM CP performed on-site interviews with the project owner/ participant, project developer and plant operating personnel to confirm selected information and to resolve issues identified in the document review. The key interviewee and main topics of the interviews are summarised in Table 3-1. Table 3-1 Interviewed persons and interview topics Interviewed Persons / Entities Interview topics Project participant representatives - Chronological description of the project activity - Technical details of the project realisation and Project Design Report - Approval procedures and status - Monitoring and measurement equipment - Crediting period and its starting date - Project activity starting date - Power purchase agreement with grid operator - Sustainable development benefits because of the project - Operational data technical specification, start-up power supply, wind speed, plant load factor. Page 11 of 84

12 P-No.: /95 Interviewed Persons / Entities Interview topics - Training & competency of the staff members w.r.t project management, monitoring and reporting Local Stakeholders - Job opportunities - Concerns related to the projects 3.4 Resolution of Clarification and Corrective Action Requests In order to remedy any mistakes, problems or any other outstanding issues which needed to be clarified for positive conclusion on the project design, s and CRs were raised. In this validation report 19 s and 7 CRs are raised. The s / CRs are documented in Annex and addressed in section Stakeholder Comments A consultation meeting with local stakeholders has been carried out on 7 th of July 2008 at the project site near Tayadin and Baklali village, belonging to the municipality of Kemerburgaz. Invitations have been sent to the two mayors of the villages surrounding the project site, to the Science Affairs Manager of Tasoluk municipality, the Deputy Mayor of Tasolugi village, the Operational Manager of Istanbul province water and sewerage, the Commander at Gaziosmanpasa district gendarmerie, the Head of Gaziosmanpasa district Forest Management as well as to staff members of WWF and Greenpeace Turkey. However, according to the GS pre-feasibility assessment this meeting was not accepted and accordingly a second round of stakeholder consultation has been conducted on The revised PDD and the stakeholder consultation report were published on TÜV NORD JI/CDM CP website for invitation of public comments for 60 days. Please refer to Table 2 and Table 3 for further details. 3.6 Finalising the report The draft validation report was submitted to the project participants. After reviewing the revised and resubmitted project documentation; resolving the CRs & s raised and outstanding concerns TÜV NORD JI/CDM CP issued this final validation report. Page 12 of 84

13 P-No.: /95 4 VALIDATION FINDINGS In the following protocol the findings from the desk review of the draft PDD, visits, interviews and supporting documents are summarised. The results are shown in table 4-1: Table 4-1: Summary of and CR issued Validation topic 1) No. of No. of CR General description of project activity (A) - Project boundaries - Participation requirements - Technology to be employed - Contribution to sustainable development Project baseline (B) - Baseline Methodology - Baseline scenario determination - Additionality determination - Calculation of GHG emission reductions Project emissions Baseline emissions Leakage - Emission reductions - Monitoring Methodology - Monitoring of Project emissions Baseline emissions Leakage Sustainable development indicators / environmental impacts - Project management planning Duration of the Project / Crediting Period (C) 1 - Environmental impacts (D) 1 - Stakeholder Comments (E) - - Project Eligibility (A) - - SUM ) The letters in brackets refer to the validation protocol, coloured parts are acc. GS checklist For an in depth evaluation of all validation items it should be referred to the validation protocol (Annex). A detailed summary of the validation findings can be found in the last chapter of this report. Page 13 of 84

14 P-No.: / Participation Requirements/ Host Country Check Since this project activity is under the GS VER scheme a letter of approval is not a prerequisite for the registration. However, Mr. Mustafa Sahin, representing the Turkish UNFCCC National Focal Point has been informed about the project. Turkey has not a quantitative target for emission reductions under the Kyoto Protocol; hence the country is eligible for voluntary offset projects. 4.2 Project type eligibility screen The project activity is a large scale wind power project and falls under CDM sectoral scope 1, Energy Industries (renewable - / non-renewable sources). In the GS scheme it is eligible under type A.1 renewable energy. The project represents a large scale project activity and meets the applicability criteria of CDM methodology ACM0002 (version 10) /ACM002/ ; because of its installed capacity of 24 MW the emission reductions exceed the limit of 15,000 t CO 2e per year. Environmental impacts as specified in Appendix C of the GS Validation & Verification Manual for CDM Projects have been assessed in an appropriate manner within the framework of the EIA /EIA/. Accordingly the project type is eligible for the Gold Standard. 4.3 Project design The proposed GS VER project is the erection of 12 WTGs in the region of Kemerburgaz in Turkey. The construction was done by Lodos Elektrik Üretim A.Ş. a duly owned subsidiary of ALTO Holding A.Ş. and is operating under the name Kemerburgaz wind farm project: Emission reductions from grid connected renewable electricity generation. The project activity is connected to the 5 km near transformerstation, where the generated electricity is stepped up to 34.5 kv. The project started construction in March 2007 and was fully operational at 15 th August 2008 /TOC/. It is estimated that the annual electricity generation amounts to 85.3 GWh. The project activity contributes to the sustainable development of the region, due to technology transfer from Germany to Turkey and creation of employment opportunities during construction and operation as well. The project developer has applied and received all necessary approvals from government bureaus, such as local environment and forestry commission office /EIA/, traffic bureau, military and building authority /SD/. However, in the course of the project validation, the following - A1, A2; A4, A5, A6 and CR A1, regarding the project design and the correct completion of the PDD - were raised and successfully closed in the final validation stage. Page 14 of 84

15 P-No.: /95 5 VALIDATION OPINION Essent Trading International S.A. has commissioned the TÜV NORD JI/CDM Certification Program (CP) to validate the project: Kemerburgaz wind farm project: with regard to the relevant requirements of the Gold Standard for VER project activities, as well as criteria for consistent project operations, monitoring and reporting. GS criteria include article 12 of the Kyoto Protocol, the modalities and procedures for CDM (Marrakech Accords) and the relevant decisions by COP/MOP and CDM Executive Board. In the course of the validation 19 Corrective Action Requests (s) and 7 Clarification Requests (CRs) were raised and successfully closed. The review of the project design documentation and additional documents related to baseline and monitoring methodology; the subsequent background investigation, follow-up interviews and review of comments by parties, stakeholders and NGOs have provided TÜV NORD JI/CDM CP with sufficient evidence to validate the fulfilment of the stated criteria. In detail the conclusions can be summarised as follows: The project is in line with all relevant host country criteria (Turkey) and all relevant GS requirements for VER projects. The project additionality is sufficiently justified in the PDD. The monitoring plan is transparent and adequate. The calculation of the project emission reductions is carried out in a transparent and conservative manner, so that the calculated emission reductions of 333,761 tco2 eq are most likely to be achieved within the 1 st renewable crediting period. The conclusions of this report show, that the project, as it was described in the project documentation, is in line with all criteria applicable for the validation. Essen, Essen, Rainer Winter TÜV NORD JI/CDM Certification Program Validation Team Leader Eric Krupp TÜV NORD JI/CDM Certification Program Senior Assessor Page 15 of 84

16 P-No.: /95 6 REFERENCES Table 6-1: Reference /ADD/ Documents provided by the project proponent Document Documents evidencing the additionality arguments ENVECO consulting service for the project activity Sales Agreement with ENERCON (signed version) Loan contract and conditions ( ) /TDE/ Technical Description of ENERCON E-82 /DSE/ /EYE/ /OCL/ /IIE/ /IGE/ /CME/ /TDM/ /WD/ /TOC/ /COM/ /BP/ ENERCON E-82 Data Sheet Energy Yield Estimation by Deutsche WindGuard GmbH Organizational Chart LODOS Invoice for Imported Electricity Invoice for Gross Electricity Guaranty Certificate for Meter Technical Data Sheet for Meter Wiring Diagram Taking Over Certificate, confirming the erection of WTGs according to the ENERCON contract and functionality of the plant. Acceptance protocols of the WTGs business plan Project Design Document entitled: Kemerburgaz wind farm project: Emission reductions from grid connected renewable electricity generation., Version 02, dated (draft) Project Design Document entitled: Kemerburgaz wind farm project: Emission reductions from grid connected renewable electricity generation., Version 02, dated Project Design Document entitled: Kemerburgaz wind farm project: Emission reductions from grid connected renewable electricity Page 16 of 84

17 P-No.: /95 Reference Document generation., Version 03, dated Project Design Document entitled: Kemerburgaz wind farm project: Emission reductions from grid connected renewable electricity generation., Version 04, dated Project Design Document entitled: Kemerburgaz wind farm project: Emission reductions from grid connected renewable electricity generation., Version 05, dated /SD/ /GP/ Sustainable Development List Of Employees Qualification Certificates Approval from Turkish Ministry of Environment and Forestry commission office, proving environmentally and socially sound operation of the plant Governmental permissions Approval from traffic bureau Approval from military and building authority Table 6-2: Reference Background investigation and assessment documents Document /ACM0002/ Consolidated baseline methodology for grid-connected electricity generation from renewable sources (Version 10), EB 47 /CPM/ TÜV NORD JI / CDM CP Manual (incl. CP procedures and forms) /GSDM/ The Gold Standard Developers Manual, Version 5, dated May 2006 /GSPDD/ /GSPFA/ /GS-VVM/ /IPCC-GP/ Gold Standard Project Design for Gold Standard Voluntary Offset Projects (GS-VER-PDD) with explanation to fulfilment. Gold Standard Pre-feasibility Assessment The Gold Standard Validation and Verification Manual for Voluntary Offset Projects, dated June 2007 IPCC Good Practice Guidance & Uncertainty Management in National Greenhouse Gas Inventories, 2000 Page 17 of 84

18 P-No.: /95 Reference /IPCC-RM/ Document Revised 2006 IPCC Guidelines for National Greenhouse Gas Inventories: Reference Manual /KP/ Kyoto Protocol (1997) /MA/ Decision 17/CP. 7 (Marrakesh Accords & Annex to decision 17/CP.7) /TA/ Tool for the demonstration and assessment of additionality (Ver 5.2) /TEF/ Tool to calculate the emission factor for an electricity system (Version 1.1) /TSYB/ Turkish statistical yearbook 2007 /VVM/ IETA, PCF Validation and Verification Manual (V.4) /TECP/ Turkish Electrical Energy 10-Year Generation Capacity Projection ( ) Table 6-3: Websites used Reference Link Organisation /bdb/ User data base for wind and solar power plants /eia/ Energy Information Administration /enveco/ Enveco GmbH /epdk/ efault.asp Energy Market Regulatory Authorithy /GS/ The Gold Standard /ipcc/ IPCC publications /teias/ Turkish Electricity Transmission Company /unfccc/ UNFCCC Page 18 of 84

19 P-No.: /95 Tabelle 6-4: List of interviewed persons Reference MoI 1 Name Organisation / Function /IM01/ V Mr. Ms. /IM01/ V Mr. Ms. /IM02/ V Mr. Ms. /IM02/ V Mr. Ms. /IM03/ V Mr. Ms Mustafa Ilhan Ismail Bahcwan Mustafa Burc Alexandros Cotanidis Veysel Düven Lodos Elektrik Üretim A.Ş., General Coordinator Technical manager for the project activity Project manager of Windcom GmbH; Consultant Enveco GmbH, consulting company Local shepherd 1) Means of Interview: (Telephone, , Visit) Page 19 of 84

20 P-No.: /95 ANNEX Validation Protocol Page 20 of 84

21 ANNEX: VALIDATION PROTOCOL Table 1: Requirements Checklist CHECKLIST QUESTION Ref. MoV* COMMENTS A. General Description of Project Activity The project design is assessed. Draft Final A.1. Project Boundaries Project Boundaries are the limits and borders defining the GHG emission reduction project. A.1.1. Are the project s spatial boundaries (geographical) clearly defined? (A 4.1.4), The coordinates, i.e. longitude and latitude in HH/MM/SS of the project activity should be mentioned in section A of the PDD. Unique identification of each WTG needs to be mentioned (preferable with serial numbers). A1 A.1.2. Are the project s system boundaries (components and facilities used to mitigate GHGs) clearly defined? (A 4.1.4) The project system boundaries include the project site and all plants that are physically connected to the electricity system where the VER project supplies electricity to. As described under B.3. of the PDD the power plants outside Turkey supplying electricity imports into the Turkish grid are part of this spatial boundary. * MoV = Means of Verification, = Document Review, I= Interview Page A-21

22 CHECKLIST QUESTION Ref. MoV* COMMENTS A.2. Participation Requirements Referring to Part A, Annex 1 and 2 of the PDD as well as the CDM glossary with respect to the terms Party, Letter of Approval, Authorization and Project Participant. A.2.1. Which Parties and project participants are participating in the project? (A.3.), (Annex 1),, I As the project activity is a VER project, no parties or host country approvals are necessary. The project participants are LODOS Elektrik Üretim A.S. (owner) and Essent Trading International S.A.. Draft Final A.2.2. Have all involved Parties provided a valid and complete letter of approval and have all private/public project participants been authorized by an involved Party? A.2.3. Do all participating Parties fulfil the participation requirements as follows: Ratification of the Kyoto Protocol Voluntary participation Designated National Authority (A.3.) /GS/ /unfccc/ A.2.4. Potential public funding for the (A.4.5), I Not applicable., I Turkey as well as Switzerland have ratified the Kyoto Protocol. However, Turkey has no emission reductions commitments so far and for Gold Standard VER projects an approval of the host Party s DNA is not required. Clarification is requested whether or not ODA was considered/granted within the business plan. The CR B5 * MoV = Means of Verification, = Document Review, I= Interview Page A-22

23 CHECKLIST QUESTION Ref. MoV* COMMENTS project from Parties in Annex I shall not be a diversion of official development assistance. A.3. Technology to be employed Validation of project technology focuses on the project engineering, choice of technology and competence/ maintenance needs. The validator should ensure that environmentally safe and sound technology and know-how is used. A.3.1. Does the project design engineering reflect current good practices? A.3.2. Does the project use state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in the host country? (A.4.3.) (A.4.3.) explanation shall be substantiated by written confirmation of the project developer., I Yes, the project encompasses the installation of 12 * 2 MW Enercon-82 Wind Turbine Generators (WTGs) which use the wind speed to generate electricity. The emission reductions result due to the displacement of the grid based power. Wind power is a technology to generate GHG emission free electricity. The components utilized are new and state of the art. Draft Final A.3.3. Does the project make provisions for meeting training and (A.2.), I The GS requirement w.r.t. identifying and explaining significant sustainable development indicators within the A4 * MoV = Means of Verification, = Document Review, I= Interview Page A-23

24 CHECKLIST QUESTION Ref. MoV* COMMENTS maintenance needs? sustainable development matrix and to overtake the identified parameters into the monitoring plan is not fulfilled. The table in Annex 5 of the PDD is not entitled and does not give information to the selection of questions. The table shall be entitled and the selection of question shall be transparently and sufficiently documented. Please refer to section 3.4 of the GS VER VVM. It shall be complied with the requirement to fill the EIA-Pre-Screen Checklist. Please refer to section 3.4 of the GS VER VVM. Section B.7.1 needs to be revised according to the GS / UNFCCC requirements with respect of the demonstration of QA/QC measures, particular regarding employment of meters, its accuracy and frequency of calibration and controls / cross checks. Additionally, according to GS requirements monitoring of employment quality, employment numbers, mitigation/compensation measures w.r.t. the soil condition and biodiversity as well as water quality and quantity and air quality needs to be monitored, too. Section B.7.2 does not include any operational and management structure and the share of responsibilities of staff. Training measures for the staff shall be included in the corresponding sections. Section B.7.2. of the PDD contains the description of the Draft B5 B6 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-24

25 CHECKLIST QUESTION Ref. MoV* COMMENTS A.4. Contribution to Sustainable Development The project s contribution to sustainable development is assessed. A.4.1. Has the host country confirmed that the project assists it in achieving sustainable development? monitoring plan as well as information for satisfying the Gold Standard requirements w.r.t. the project s contribution to sustainable development in terms of training of staff. During the site visit the validation team was informed that training measures for the LODOS Elektrik Uretim A.S. staff are element of the maintenance contract with Enercon. However, the PDD does not give such information in the relevant section(s). Please refer to A4, B5 and B6. Draft /SD/ Not applicable. Final A.4.2. Will the project create other environmental or social benefits than GHG emission reductions? (A.2.) The view of the project participants on the contribution of the project activity towards sustainable development is briefly described in section A.2. The project activity contributes to the dissemination of clean technology. Furthermore it improves the air conditions as fossil fuel energy is replaced and the economic growth of the region is positively influenced. This is mainly due to the creation of employment opportunities during construction and operation of the A2, A4; B5; E1 * MoV = Means of Verification, = Document Review, I= Interview Page A-25

26 CHECKLIST QUESTION Ref. MoV* COMMENTS Large scale project activity Is it assessed whether the project qualifies as large-scale CDM project activity? A.4.3. Does the project qualify as a large scale GS VER project activity as defined in the introduction of the GS VER manual for project developers.? A.4.4. Is it ensured that the project proponent is not claiming for carbon credits or Renewable Energy Certfificates (RECs) from another GHG ER / REC scheme? (B.1. / B.2.) /ACM0002/ /GS/ plant. The project activity also helps to reduce the dependency of ending fossil fuel resources. Nevertheless A2 and A4 are raised as it is failed to fill the sustainability matrix according to the GS requirements. In section B.2. of the PDD it is explained why the project activity refers to ACM0002. It fulfils all criteria as a renewable energy source which is connected to an electricity grid that is fed inter alia by fossil fuel fired power plants. The geographic and system boundaries for the relevant electricity grid can be clearly identified and information on the characteristics of the grid is available. However, it is not clearly indicated whether the project activity qualifies as a large Scale Project as per the Gold Standard requirements. Please refer to A6 in the section Findings. /CPM/, I So far no information has been provided whether the project proponent is claiming for carbon credits or Renewable Energy Certificates (RECs) from another GHG ER / REC scheme. The project proponent has to provide a written confirmation that no claim will be made. Please refer to B3 in the section Findings. Draft A6 A3 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-26

27 CHECKLIST QUESTION Ref. MoV* COMMENTS A.5. General Topics Draft Final A.5.1. Has the PDD been duly filled? No, the GS-VER-PDD template is not applied. Therefore A2 has been raised. A2 A.5.2. Has all necessary information been made available to the validator? B. Project Baseline The validation of the project baseline establishes whether the selected baseline methodology is appropriate and whether the selected baseline represents a likely baseline scenario., I Several documents which are necessary to provide a final assessment of the proposed project activity are pending. Kindly refer to B7 and B8. B7; B8 B.1. Baseline Methodology It is assessed whether the project applies an appropriate baseline methodology. B.1.1. Does the project apply an approved methodology and the correct version thereof? B.1.2. Are the applicability criteria in the baseline methodology all fulfilled? (B.1) /ACM0002/ (B.1./ B.2.), /ACM0002./ The project applies the large scale methodology ACM0002 Version 7 (EB 36). The same expired during validation and accordingly the PDD and the corresponding ER calculation has been revised. The project activity uses wind power as a renewable energy source and is connected to the Turkish national electricity grid. No retrofit or modifying measures are included in the project activity as it is a Greenfield project. * MoV = Means of Verification, = Document Review, I= Interview Page A-27

28 CHECKLIST QUESTION Ref. MoV* COMMENTS B.2. Baseline Scenario Determination The choice of the baseline scenario will be validated with focus on whether the baseline is a likely scenario, and whether the methodology to define the baseline scenario has been followed in a complete and transparent manner. B.2.1. What is the baseline scenario? B.2.2. What other alternative scenarios have been considered and why is the selected scenario the most likely one? (B.2.) /ACM0002/ (B.4.; B6) /ACM0002/, I As the total capacity is 24 MW and the total estimated ERs do exceed 15,000 tco 2eq annually it can be categorised as a large scale project as per the UNFCCC and the GS requirements as well. The baseline scenario is the continuation of the preproject scenario, i.e. the electricity generation by all power plants in the electricity system. However, several mistakes have been identified in the ER calculation. Please refer to. B1; B2; B3; CR B2; CR B3; CR B4; CR A1. According to ACM0002 only the pre-project scenario can be the baseline, thus an alternative must not be determined. B.2.3. Has the baseline scenario been Yes, the baseline scenario is in line with the latest version Draft B1; B2; B3; CR A1; CR B2; CR B3; CR B4 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-28

29 CHECKLIST QUESTION Ref. MoV* COMMENTS determined according to the methodology? B.2.4. Has the baseline scenario been determined using conservative assumptions where possible? B.2.5. Does the baseline scenario sufficiently take into account relevant national and/or sectoral policies, macro-economic trends and political aspirations? B.2.6. Is the baseline scenario determination compatible with the available data and are all literature and sources clearly referenced? (B.4.; B6), /ACM0002/ (B.4.; B6), /ACM0002/ (B.3.), /ACM0002/ (B.4); (B.6) /ACM0002/ /TECP/ /TEF/ /ACM0002/ /EYE/ /eia/ of the methodology, even though the first sentence within the quotation marks in section B.4 does not reflect the correct wording according to the methodology. The baseline scenario is determined according to publicly available energy data, i.e. Turkish statistical yearbook 2007, actual installed capacity and energy projections from TEIAS, the Turkish grid operator and EPDK respectively, which is the Turkish Energy Market Regulatory Authority. The energy projections from the above mentioned institutions can be deemed as conservative. However, several s and CRs respectively were raised. Please refer to table 3 for additional information. Yes, there are no political or economical trends or aspirations to prohibit electricity generation from wind sources or fossil fuels. The baseline scenario data, determined as per the data provided by TEIAS and EPDK can be assessed as compatible. As it is deemed likely that fossil fuel-fired power plants, particularly Natural Gas fired power plants, will continue to dominate the power sector for the next years it is expected that no significant changes in the mix of the Turkish National Grid during the first crediting period will occur. However, the approach of calculating the ERs needs revision. In this respect please refer to CR B3. Draft A5; B1; B2; B3; CR B2; CR B3; CR B4 B1; B2; B3; CR B2; CR B3; CR B4 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-29

30 Draft CHECKLIST QUESTION Ref. MoV* COMMENTS B.2.7. Have major risks to the baseline No major risks were identified and are not to be expected. been identified? (B.4.; B6) B.3. Additionality Determination The assessment of additionality will be validated with focus on whether the project itself is not a likely baseline scenario. B.3.1. Is the project additionality assessed according to the methodology? B.3.2. Are all assumptions stated in a transparent and conservative manner? (B.5.), /ACM0002/ (B.5.) Yes, in section B.5 of the PDD the additionality is justified with the barrier approach according to the additionality tool Version 5.2. Several barriers are described in section B.5 in the PDD and were found partially appropriate. However, the barriers as stated in the relevant section of the PDD need further justification; please refer to checklist question B.3.2. Several barriers are stated without sufficient justification and transparency. The following barriers need further justification: Identification of barriers: During on-site visit it could be identified that a major barrier of the project activity s implementation might have occurred in obtaining a bank loan. In respect of this please refer to the relevant s raised in table 3 in this report. In order to justify the above mentioned barrier the project proponent is requested to submit additional documentation. Common practice analysis: the common practice analysis does not follow the proposed approach according to the additionality tool. Furthermore the explanation for the exclusion of similar projects is in parts contradictory to the B4; B7; B8; B10; CR B1 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-30

31 CHECKLIST QUESTION Ref. MoV* COMMENTS B.3.3. Is sufficient evidence provided to support the relevance of the arguments made? B.3.4. If the starting date of the project activity is before the date of validation, has sufficient evidence been provided that the incentive from the CDM was seriously considered in the decision to proceed with the project activity? B.4. Calculation of GHG Emission Reductions Project emissions It is assessed whether the project emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified. B.4.1. Are the calculations documented according to the approved methodology and in a complete and transparent manner? (B.5.) (B.3.) (B.6.) /ACM0002/, I, I information in table 2 on page 15 in the PDD and needs to be revised. Several documents should be provided to assess the argumentation. Please see above. The validation is conducted after the start of the project activity. Reliable and approved documents were not yet presented to the validator. Documentation should be provided. Kindly refer to table 3. According to ACM0002 project emissions must not be considered for renewable energy projects. Draft B7; B8; CR B1 B7; B8; CR B1 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-31

32 Draft CHECKLIST QUESTION Ref. MoV* COMMENTS B.4.2. Have conservative assumptions Refer B.4.1 been used when calculating the (B.6.) project emissions B.4.3. Are uncertainties in the project emission estimates properly addressed? B.5. Calculation of GHG Emission Reductions Baseline emissions It is assessed whether the baseline emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified. B.5.1. Are the calculations documented according to the approved methodology and in a complete and transparent manner? B.5.2. Have conservative assumptions been used when calculating the baseline emissions B.5.3. Are uncertainties in the baseline emission estimates properly addressed? (B.6.) (B.6.) /ACM0002/ (B.6.) (B.6.) Refer B.4.1 The calculations and formulas provided in section B.6 are in accordance to ACM0002. As per ACM0002 baseline emissions must not be considered for new grid-connected renewable power plants. Please refer section B.5.1 Please refer section B.5.1 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-32

33 CHECKLIST QUESTION Ref. MoV* COMMENTS B.6. Calculation of GHG Emission Reductions Leakage It is assessed whether leakage emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified. B.6.1. Are the leakage calculations documented according to the approved methodology and in a complete and transparent manner? (B.6), I According to ACM0002 leakage emissions must not be considered for renewable energy projects. Draft Final B.6.2. Have conservative assumptions been used when calculating the leakage emissions? B.6.3. Are uncertainties in the leakage emission estimates properly addressed? (B.6.) (B.6.) Not applicable since leakage is not considered. N/A Not applicable since leakage is not considered. N/A * MoV = Means of Verification, = Document Review, I= Interview Page A-33

34 CHECKLIST QUESTION Ref. MoV* COMMENTS B.7. Emission Reductions The emission reductions shall be real, measurable and give long-term benefits related to the mitigation of climate change. B.7.1. Are the emission reductions real, measurable and give long-term benefits related to the mitigation of climate change. B.8. Monitoring Methodology It is assessed whether the project applies an appropriate baseline methodology. B.8.1. Is the monitoring plan documented according to the approved methodology and in a complete and transparent manner? (B.6.) (B.7.) The s/crs given in section B have to be closed satisfactorily before forming an opinion. The methodology applied is ACM0002. According to ACM0002 the generated electricity by the project activity, the electricity exported to the grid shall be monitored. This has to be included in the relevant sections of the PDD. Furthermore, the whole monitoring section needs revision esp. according to the following issues: The net electricity stated in section B.7.1. is contradictory to page 2 of the PDD, where the same amount is considered as produced electricity. To be most accurate, the electricity generation, the auxiliary consumption and the transmission losses shall be included to calculate the net generation which is to be monitored. The quality procedure of the monitoring should be described more precisely. Calibration periods Draft Not yet A2; A4; B5 Final * MoV = Means of Verification, = Document Review, I= Interview Page A-34

35 CHECKLIST QUESTION Ref. MoV* COMMENTS B.8.2. Will all monitored data required for verification and issuance be kept for two years after the end of the crediting period or the last issuance of CERs, for this project activity, whichever occurs later? B.9. Monitoring of Project Emissions It is established whether the monitoring plan provides for reliable and complete project emission data over time. B.9.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for estimation or measuring the (B.7.2.) (B.6.) should be included. The metering system / measurement equipment should be described very precisely w.r.t. technical specifications and frequency of controls. Procedures for the data handling and measurements should be included. Responsibilities should be explained to ensure the data handling and accuracy. The provision of the management and operational structure might be helpful. Furthermore please refer to A4 for additional information according to the GS requirements. Yes, the data will be archived two years after the end of the crediting period. This is indicated in B.7.2. Draft As project emissions are zero, this is not applicable. N/A Final * MoV = Means of Verification, = Document Review, I= Interview Page A-35

36 CHECKLIST QUESTION Ref. MoV* COMMENTS greenhouse gas emissions within the project boundary during the crediting period? B.9.2. Are the choices of project GHG indicators reasonable and conservative? (B.6.) Draft As project emissions are zero, this is not applicable. N/A Final B.9.3. Is the measurement method clearly stated for each GHG value to be monitored and deemed appropriate? B.9.4. Is the measurement equipment described and deemed appropriate? B.9.5. Is the measurement accuracy addressed and deemed appropriate? Are procedures in place on how to deal with erroneous measurements? B.9.6. Is the measurement interval identified and deemed appropriate? B.9.7. Is the registration, monitoring, measurement and reporting (B.6.) (B.6.) (B.6.) (B.6.) (B.6.) As project emissions are zero, this is not applicable. N/A As project emissions are zero, this is not applicable. N/A As project emissions are zero, this is not applicable. N/A As project emissions are zero, this is not applicable. N/A As project emissions are zero, this is not applicable. N/A * MoV = Means of Verification, = Document Review, I= Interview Page A-36

37 CHECKLIST QUESTION Ref. MoV* COMMENTS procedure defined? Draft Final B.9.8. Are procedures identified for maintenance of monitoring equipment and installations? Are the calibration intervals being observed? (B.6.) As project emissions are zero, this is not applicable. N/A B.9.9. Are procedures identified for dayto-day records handling (including what records to keep, storage area of records and how to process performance documentation) (B.6.) As project emissions are zero, this is not applicable. N/A B.10. Monitoring of Baseline Emissions It is established whether the monitoring plan provides for reliable and complete baseline emission data over time. B Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining baseline emissions during the crediting period? (D.7.) The only parameter that will be required for calculating the baseline emissions is net electricity supplied to the grid. In section B.7.2 the monitoring of the same is addressed, the data collection and archiving for a period of 2 years beyond the crediting period is mentioned. Please note that the metering devices, frequency, calibration procedures etc. are not stated in a precise manner. Kindly refer to table 3. A5; B2; B3; B5; CR * MoV = Means of Verification, = Document Review, I= Interview Page A-37