CDM AND VER VALIDATION PROTOCOL

Transcription

1 APPENDIX A CDM AND VER VALIDATION PROTOCOL SAYALAR 30.4 MW WIND FARM PROJECT TURKEY FINAL REPORT NO REVISION NO. 01

2 Table 1 Mandatory Requirements for High Standard Voluntary Emission Reduction ( VER ) and Clean Development ( CDM ) Project Activities About Parties Requirement Reference Comments Conclusion 1. The project shall assist Parties included in Annex I in achieving compliance with part of their emission reduction commitment under Art The project shall assist non-annex I Parties in contributing to the ultimate objective of the UNFCCC. 3. The project shall have the written approval of voluntary participation from the designated national authority of each Party involved. Kyoto Protocol Art.12.2 Kyoto Protocol Art Kyoto Protocol Art. 12.5a, CDM Modalities and Procedures 40a No participating Annex I Party is yet identified. A deduction of the commitment of the Annex I Party throughout VERs is not feasible, only CERs or ERUs are so far eligible for this purpose. It has to be clarified which Annex I Party has been meanwhile identified as potential VER buyer. Conclusion: It is not mandatory, to have a VER buyer from an Annex I country. The project activity applies a zero emissions technology with sustainable development benefits. There is no designated national authority announced in Turkey, because Turkey has not yet ratified the Kyoto protocol. Anyhow, a letter of endorsement of the national focal point of Turkey, which confirms that the project is voluntary and contributes to the sustainable development in Turkey will be CL1 FCAR 1 2

3 Requirement Reference Comments Conclusion issued. Refer A.4.1 and table 1, question ¾ A reply letter from the Ministry of Environment and Forestry of Turkey, General Directorate of Environmental Management was received on 18 th of September 2007 which contains a positive comment towards the two previous investments of Demirer Holding, the Mare Manastir project and the Anemon Intepe project. The statement within the above letter points out, that a request for an official Letter of Endorsement can only be issued after the adequate infrastructure of a DNA is established. The same applies for the Sayalar project. It is deemed reasonable to close therefore FCAR1 and go ahead also with the voluntary offset project Sayalar as GS-VER project. 4. The project shall assist non-annex I Parties in achieving sustainable development and shall have obtained confirmation by the host country thereof. Kyoto Protocol Art. 12.2, CDM Modalities and Procedures 40a A letter of endorsement of the national focal point of Turkey, which confirms that the project is voluntary and contributes to the sustainable development in Turkey is in preparation. FCAR 1 3

4 Requirement Reference Comments Conclusion Refer A.4.1 and table 1, question 3/4 5. In case public funding from Parties included in Annex I is used for the project activity, these Parties shall provide an affirmation that such funding does not result in a diversion of official development assistance and is separate from and is not counted towards the financial obligations of these Parties. Decision 17/CP.7, CDM Modalities and Procedures Appendix B, 2 The validation did not reveal any information that indicates that the project can be seen as a diversion of ODA funding towards Turkey. 6. Parties participating in the CDM shall designate a national authority for the CDM. CDM Modalities and Procedures 29 Not applicable for VER-projects. Turkey as host country has not yet ratified the Kyoto Protocol. The national focal point of Turkey is the Ministry of Environment and Forestry. 7. The host Party and the participating Annex I Party shall be a Party to the Kyoto Protocol. CDM Modalities 30/31a Turkey as host country has not yet ratified the Kyoto Protocol. The national focal point of Turkey is the Ministry of Environment and Forestry. There is no designated national authority announced in Turkey yet. No participating Annex I Party is yet identified. The project activity does not fulfil the criteria of a CDM project or JI project under the Kyoto Protocol, but is eligible as voluntary CO2 CL1 4

5 Requirement Reference Comments Conclusion offset project with generation of voluntary emission reductions ( VERs ). It has to be clarified which Annex I Party has been meanwhile identified as potential VER buyer. Conclusion: It is not mandatory, to have a VER buyer from an Annex I country. 8. The participating Annex I Party s assigned amount shall have been calculated and recorded. 9. The participating Annex I Party shall have in place a national system for estimating GHG emissions and a national registry in accordance with Kyoto Protocol Article 5 and 7. About additionality 10. Reduction in GHG emissions shall be additional to any that would occur in the absence of the project activity, i.e. a CDM project activity is additional if anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the registered CDM project activity. About forecast emission reductions and environmental impacts CDM Modalities and Procedures 31b CDM Modalities and Procedures 31b Kyoto Protocol Art. 12.5c, CDM Modalities and Procedures 43 No participating Annex I Party is yet identified. Not applicable for VER-projects No participating Annex I Party is yet identified. Not applicable for VER-projects The Additionality Tool of UNFCCC has been applied, see B.3. 5

6 Requirement Reference Comments Conclusion 11. The emission reductions shall be real, measurable and give long-term benefits related to the mitigation of climate change. Kyoto Protocol Art. 12.5b The emission reductions by renewable energy generation and replacement of the fossil-fuel based energy mix from the grid fulfils these requirements. For large-scale projects only 12. Documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts, shall be submitted, and, if those impacts are considered significant by the project participants or the Host Party, an environmental impact assessment in accordance with procedures as required by the Host Party shall be carried out. CDM Modalities and Procedures 37c Refer D.1.1. D.1.6. About stakeholder involvement 13. Comments by local stakeholders shall be invited, a summary of these provided and how due account was taken of any comments received. 14. Parties, stakeholders and UNFCCC accredited NGOs shall have been invited to comment on the validation requirements for minimum 30 days, and the project design document and comments have been made publicly available. CDM Modalities and Procedures 37b Refer E.1.1. E.1.5. CDM Modalities and Procedures 40 Refer E.1.1. E.1.5. Other 15. The baseline and monitoring methodology shall be previously approved by the CDM CDM Modalities and Procedures 37e The approved CDM baseline and monitoring methodology ACM0002, 6

7 Requirement Reference Comments Conclusion Executive Board. version 06 was applied. 16. A baseline shall be established on a projectspecific basis, in a transparent manner and taking into account relevant national and/or sectoral policies and circumstances. 17. The baseline methodology shall exclude to earn CERs for decreases in activity levels outside the project activity or due to force majeure. 18. The project design document shall be in conformance with the UNFCCC CDM-PDD format. 19. Provisions for monitoring, verification and reporting shall be in accordance with the modalities described in the Marrakech Accords and relevant decisions of the COP/MOP. CDM Modalities and Procedures 45c,d The baseline establishment has been done project specific and retraceable CDM Modalities and Procedures 47 N/A for this wind energy project. CDM Modalities and Procedures Appendix B, EB Decision CDM Modalities and Procedures 37f The GS-VER PDD template was applied. The verification will be based on the recordings according to the approved monitoring methodology ACM0002, version 06 and the monitoring plan, which contains also selected sustainable development indicators as requested by the Gold Standard SD matrix. Table 2 Requirements Checklist CHECKLIST QUESTION A. General Description of Project Activity 7

8 The project design is assessed. 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? /1/ - The project has installed 38 WEG machines of 800 kw rating in Manisa Province, Sayalar District in Turkey. The WEGs are set-up in Manisa Province, Sayalar District, Rahmanlar-Akkocalı-Gökçealan Region in Turkey near to Deremahallesi Village, approximately 2km away from the project area. The project sites need to be clearly demarked. The unique identification of each turbine needs to provided in the PDD. Please provide these installed turbine details for verification. FCAR 2 A.1.2. Are the project s system boundaries (components and facilities used to mitigate GHGs) clearly defined? /1/ DR Yes, the project s system boundaries are defined clearly. It includes the wind energy generators and the electricity grid to which the generated power is dispatched. 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, 8

9 Letter of Approval, Authorization and Project Participant. A.2.1. Which Parties and project participants are participating in the project? The project participant is the private entity Doğal Enerji Üretim A.Ş. of Turkey. Turkey is the host country. No Annex-I country has been identified as yet. It shall be clarified whether Enercon GmbH, Germany, or Polat Enerji A.Ş., Turkey respectively is a project participant? CL3 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? /1/ DR The Turkish Country Office of REC - Regional Environmental Center for Central and Eastern Europe has taken over certain functions of a National Focal Point for UNFCCC according to Article 6. REC Turkey has endorsed in this function the project. The Letter of Endorsement or Approval is to be submitted to TÜV Rheinland. Refer A.4.1 and table 1, question 3/4 FCAR 1 A.2.3. Do all participating Parties fulfil the participation requirements as follows: - Ratification of the Kyoto Protocol - Voluntary participation /1/ DR It is expected that Turkey will ratify the Kyoto protocol. The current DFP, the Ministry of Environment and Forests is expected to become the official DNA of Turkey. 9

10 - Designated a National Authority N/A for VER projects A.2.4. Potential public funding for the project from Parties in Annex I shall not be a diversion of official development assistance. No public funding from any Annex-I country has been received 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? The WEGs installed under the project has been designed and commissioned by Demirer Holding / Enercon GmbH. Enercon GmbH, Germany is a reputed firm in the field of wind energy. The salient features of the E- 48 models implemented under the project activity include gearless construction, variable speed and pitch functions and independent braking technology. The project design thus reflects good practice. 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? The E-48 models with its sophisticated rotor blade design used in the project are likely to result in significantly better performance than the commonly used WEGs in Turkey. 10

11 A.3.3. Does the project make provisions for meeting training and maintenance needs? The project will require some initial training and maintenance efforts for proper operation. The operation and maintenance of the WEGs have been taken care by Enercon GmbH. The ENERCON PartnerKonzept (EPK) gives customers the assurance of consistently high wind turbine availability for the first twelve years of operation with calculable operating costs. From servicing to safety inspections, maintenance and repairs, all eventualities are covered. This ensures proper maintenance and operation of the WEGs during the crediting period. 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? The Letter of Endorsement or Approval from the DFP of Turkey is to be submitted to TÜV Rheinland. Refer A.2.2 and table 1, question 3/4 FCAR 1 A.4.2. Will the project create other environmental or social benefits than GHG emission reductions? The project will help to decrease the dependence on fossil fuels for power generation. 11

12 The project activity will create employment opportunities during construction and also operation phases. The organigram and the HR planning could be verified by the validation team. 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. 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? /1/ DR The latest version of ACM0002 was applied for the project activity. B.1.2. Are the applicability criteria in the baseline methodology all fulfilled? /1/ DR All selected criteria could be sufficiently justified, see B.2. 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? /1/ DR The baseline scenario is the continuation of current scenario, i.e. the electricity displaced by the project would have been generated by 12

13 B.2.2. What other alternative scenarios have been considered and why is the selected scenario the most likely one? the operation of grid-connected power plants or by the addition of new generation sources. Other than the baseline scenario, the option of setting up a fossil fuel based power plant or hydro power plant and project without VER benefits have been discussed. However, coal based power plant option has not been considered as the baseline since this option would have required considerable amount of investment as compared to the baseline which do not require any investment at all. Also this option would have led to higher amount of emissions in the baseline. Also, the option of project without VER has not been considered due to the presence of several barriers discussed later. Thus the selected baseline scenario is the most likely scenario in the absence of the project. B.2.3. Has the baseline scenario been determined according to the methodology? /1/ DR The baseline has been determined as per the methodology. B.2.4. Has the baseline scenario been determined using conservative assumptions where possible? /1/ DR The discussion of the baseline selection has been done in a transparent manner based on public available data from TEIAŞ website or Turkey s Statistical Yearbook Electricity generation by the existing grid CL2 13

14 connected power plants have been selected as the baseline. The baseline emission factor has been calculated as a combination of OM and BM emission factors. In order to ensure, the most conservative approach for the calculation of the emission factor, it has to be clarified with TEIAŞ, which are the latest public available data for the calculation of the OM and BM emission factors. Any updates have to be taken into account. B.2.5. Does the baseline scenario sufficiently take into account relevant national and/or sectoral policies, macro-economic trends and political aspirations? /1/ DR Yes, relevant national and sectoral policies have been taken into account. B.2.6. Is the baseline scenario determination compatible with the available data and are all literature and sources clearly referenced? /1/ DR Yes, the baseline scenario selection is compatible with available data. B.2.7. Have the major risks to the baseline been identified? /1/ DR There are no risks to the baseline. B.3. Additionality Determination The assessment of additionality will be validated with focus on whether the project itself is not a likely baseline scenario. 14

15 B.3.1. Is the project additionality assessed according to the methodology? Yes, the project s additionality is demonstrated using Tool for the demonstration and assessment of additionality, version 02, which is not the latest version ( version 03 ). Step 0: Since the project activity does not seek for retro active credits, this step is not applicable to the project activity. Step 1: Three alternatives to the project activity have been considered as the baseline scenario. These are i) project not undertaken as a VER project activity ii) Setting up of equivalent capacity of fossil fuel or hydro power based plants and supply electricity to the Turkish national electricity grid and ii) continuation of current scenario without the project activity. All the alternatives are in compliance with the laws and regulations of Turkey. For considering the baseline emissions the continuation of power generation from existing and future grid connected power plants have been selected as the baseline since this option results in lower baseline emissions than the coal based power plant option. Step 2: Investment analysis: To demonstrate the additionality of the project, the contracted CO2 consultant CAR1 15

16 Ecofys has chosen Option III benchmark analysis. It has been demonstrated that the IRR of the project activity without VER revenues is negative which is lower than the recommended benchmark IRR of 15% for independent wind power producers and the rate of Turkish Government Bonds of 16 19%. The IRR improves by 5.5 % with VER revenues, but is still negative ( 10 years ). A sensitivity analysis has to be performed in order to show that the project activity is not the most financially attractive option. The financial spread sheet calculations need to be provided for verification including sensititivity analysis ( including ±5% change in PLF ). Step 3: Not chosen, but requested by additionality tool, version 03. Step 4: Common practice analysis: It has to be demonstrated which capacity in the license pipeline is already approved by Turkish Government. 16

17 Step 5: Impact of CDM registration: The CDM benefits increases the equity IRR of the project by 5.5 % ( 10 years ) thus providing the project with necessary financial back-up. It has to be explained, how the remaining financial risk can be overcome. B.3.2. Are all assumptions stated in a transparent and conservative manner? The PLF of the wind project has been assumed to be 2.4 % less than the results of the energy yield simulation while calculating the IRR. This is deemed conservative as against the actual PLF realized by wind plants in the region. B.3.3. Is sufficient evidence provided to support the relevance of the arguments made? /1/ DR Financial spread sheet need to be provided for verification. CAR1 B.3.4. 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? The starting date of the crediting period is after the date of registration of the project as a GS-VER project activity. Hence the project does not seek retro-active credits. 17

18 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? /1/ DR The project being a wind energy generation project, there are no emissions from the project activity. B.4.2. Have conservative assumptions been used when calculating the project emissions? B.4.3. Are uncertainties in the project emission estimates properly addressed? /1/ DR Refer B.4.1 /1/ DR Refer B.4.1 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? /1/ DR The calculation of the baseline emissions has been done in a transparent manner. Electricity generation by the existing grid connected power plants have been selected as the baseline. The baseline emission factor has been calculated as a combination of OM and CL2 18

19 BM emission factors and it is fixed ex-ante. However, the project proponent is requested to consider the latest public available OM and BM data provided by TEIAŞ to calculate the most conservative CM. 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? /1/ DR Refer B.5.1. CL2 /1/ DR Yes. 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? /1/ DR The project being a wind energy generation project, there are no leakages due to the project activity. 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? /1/ DR Refer B.6.1. /1/ DR Refer B

20 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. /1/ DR Yes, the emission reductions are real and measurable. The project will reduce 595,245 tco2e emissions per year over the 7 years crediting period. 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.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? The monitoring methodology selected complies with requirements of ACM0002, version 6. The net amount of electricity despatched by the WEGs to the TEIAŞ grid will be monitored continuously. The net electricity exported to the grid will be reported on monthly basis and cross-checked with the invoices raised to TEIAŞ. /1/ The project proponent is requested to clarify the data archiving method and period in the PDD. B.9. Monitoring of Project Emissions 20

21 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 greenhouse gas emissions within the project boundary during the crediting period? /1/ DR There are no emissions from the project activity since this is a renewable energy generation project. B.9.2. Are the choices of project GHG indicators reasonable and conservative? 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 procedure defined? B.9.8. Are procedures identified for maintenance of monitoring equipment and installations? Are the calibration intervals being /1/ DR Refer B.9.1. /1/ DR Refer B.9.1. /1/ DR Refer B.9.1. /1/ DR Refer B.9.1. /1/ DR Refer B.9.1. /1/ DR Refer B.9.1. /1/ DR Refer B

22 observed? B.9.9. Are procedures identified for day-to-day records handling (including what records to keep, storage area of records and how to process performance documentation) /1/ DR Refer B.9.1. 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? /1/ DR Yes, the monitoring plan provides for the monitoring and collection of the net electricity supplied to the grid. This is the only parameter that will be required for calculating the baseline emissions. B Are the choices of baseline GHG indicators reasonable and conservative? /1/ DR CO2 is the only relevant baseline indicator and it has been accounted for. B Is the measurement method clearly stated for each baseline indicator to be monitored and also deemed appropriate? /1/ DR the WEGs to the Turkish national electricity grid will be monitored continuously. The net electricity exported to the grid will be reported on monthly basis and cross-checked with the invoices raised to TEIAŞ. B Is the measurement equipment described and deemed appropriate? /1/ DR The electricity meters installed under the project activity are approved by TEIAŞ and deemed appropriate. 22

23 B Is the measurement accuracy addressed and deemed appropriate? Are procedures in place on how to deal with erroneous measurements? B Is the measurement interval for baseline data identified and deemed appropriate? B Is the registration, monitoring, measurement and reporting procedure defined? B Are procedures identified for maintenance of monitoring equipment and installations? Are the calibration intervals being observed? /1/ DR Yes. /1/ DR Yes. /1/ DR Yes. /1/ DR Yes. B Are procedures identified for day-to-day records handling (including what records to keep, storage area of records and how to process performance documentation) /1/ DR The electricity generation reports on joint meter reading are generated by TEIAŞ and Demirer Holding on monthly basis. The project proponent is requested to clarify the archiving details for the monthly electricity sales receipts from TEIAŞ. B.11. Monitoring of Leakage It is assessed whether the monitoring plan provides for reliable and complete leakage data over time. B Does the monitoring plan provide for the collection and /1/ DR Leakage monitoring is not required for this 23

24 archiving of all relevant data necessary for determining leakage? project activity. B Are the choices of project leakage indicators reasonable and conservative? B Is the measurement method clearly stated for each leakage value to be monitored and deemed appropriate? /1/ DR Refer B /1/ DR Refer B B.12. Monitoring of Sustainable Development Indicators/ Environmental Impacts It is assessed whether choices of indicators are reasonable and complete to monitor sustainable performance over time. B Is the monitoring of sustainable development indicators/ environmental impacts warranted by legislation in the host country? /1/ DR The DFP of Turkey does not mandate the monitoring of sustainable development indicators, but according to GS-VER standard a voluntary monitoring of selected sustainable development indicators will be performed. B Does the monitoring plan provide for the collection and archiving of relevant data concerning environmental, social and economic impacts? B Are the sustainable development indicators in line with stated national priorities in the Host Country? /1/ DR Yes. /1/ DR Yes. 24

25 B.13. Project Management Planning It is checked that project implementation is properly prepared for and that critical arrangements are addressed. B Is the authority and responsibility of overall project management clearly described? /1/ DR The responsibility of overall project management lies with Demirer Holding, supported by Enercon GmbH. B Are procedures identified for training of monitoring personnel? /1/ DR The monitoring of the WEG performance has been taken care by Demirer Holding, supportrd by Enercon GmbH. B Are procedures identified for emergency preparedness for cases where emergencies can cause unintended emissions? No emergencies due to the project activity will lead to unintended GHG emissions B Are procedures identified for review of reported results/data? Yes. Demirer Holding will be responsible for the review of reported results B Are procedures identified for corrective actions in order to provide for more accurate future monitoring and reporting? Yes. C. Duration of the Project/ Crediting Period It is assessed whether the temporary boundaries of the project are clearly defined. C.1.1. Are the project s starting date and operational lifetime clearly defined and evidenced? /1/ DR Yes, the starting date of the project is 1 Jaunary 2008, the date of placement of purchase order. The lifetime of the project 25

26 has been identified as 20 years. This is deemed reasonable and can be achieved under normal construction conditions. C.1.2. Is the start of the crediting period clearly defined and reasonable? /1/ DR The project has selected a two times renewable crediting period of 7 years starting from January Since the crediting period for the project cannot start prior to the registration of the project, the project proponent is requested to delay the starting date of the crediting period. D. Environmental Impacts Documentation on the analysis of the environmental impacts will be assessed, and if deemed significant, an EIA should be provided to the validator. D.1.1. Has an analysis of the environmental impacts of the project activity been sufficiently described? /1/ DR The project does not require an environmental impact analysis as per the EIA notification of the MoEF. However, an voluntary assessment was conducted by Demirer Holding. The statutory approvals and clearances need to be provided for verification. Any relevant EMP parameters need to be monitored in addition. D.1.2. Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, is an EIA /1/ DR The project does not require an environmental impact analysis as per the EIA 26

27 approved? notification of the MoEF D.1.3. Will the project create any adverse environmental effects? D.1.4. Are transboundary environmental impacts considered in the analysis? The project is not likely to create any adverse environmental effects. /1/ DR There are no trans-boundary impacts of the project activity D.1.5. Have identified environmental impacts been addressed in the project design? /1/ DR There no negative environmental impacts due to the project D.1.6. Does the project comply with environmental legislation in the host country? E. Stakeholder Comments The validator should ensure that stakeholder comments have been invited with appropriate media and that due account has been taken of any comments received. E.1.1. Have relevant stakeholders been consulted? /1/ DR The project complies with environmental regulations in Turkey. The statutory clearances need to be provided to TÜV Rheinland for verification. The stakeholders, the local population and the village representative have been consulted. E.1.2. Have appropriate media been used to invite comments by local stakeholders? The stakeholders were invited for comments through local newspaper advertisement. E.1.3. If a stakeholder consultation process is required by A stakeholder consultation is not required by 27

28 regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws? E.1.4. Is a summary of the stakeholder comments received provided? the DFP of Turkey,, but according to GS- VER standard a voluntary stakeholder consultation have been performed in two main phases: 1. Initial stakeholder consultation 2. Main stakeholder consultation including a voluntary publication for GSP CAR2 The output of the main consultation with a overall duration of 60 days, which is a report including all written and oral comments given as well as the argumentation on whether or not the comments are taken into account, has to be submitted to the validation team. Yes, a summary of the comments received have been provided. E.1.5. Has due account been taken of any stakeholder comments received? The project did not receive any negative comment. 28

29 Table 3 Resolution of Corrective Action and Clarification Requests report clarifications and corrective action requests by validation team Ref. to checklist question in table 2 Summary of project owner response FCAR1 A copy of the letter of endorsement of the national focal point of Turkey, which confirms that the project is voluntary and contributes to the sustainable development has to be submitted to the validation team. Table 1 Table 2 A request for issuance of the Letter of Endorsement (LoE) was sent to Mr. Sedat Kadıoğlu on 06/07/2007. ( Given the experiences from the Anemon and Mare project we are aware that no such letter can be issued, therefore this request was made to inform the National Focal Point on the project activity. The Ministry of Environment and Forestry was involved in the stakeholder consultation process by invitation of Mr. Mustafa Şahin (responsible for climate change issues under The Ministry). During the Main Stakeholder Consultation the Initial Stakeholder Consultation report and a non-technical draft PDD was sent twice to Mr. Mustafa Şahin ( and ). He was requested to comment on the project, however, no response has been received. The Validation team conclusion Gold Standard voluntary offset projects are required to send a letter to the DNA or to a relevant authority, if DNA does not exist, in order to communicate the development of the project as a Gold Standard voluntary offset project. A reply letter from the Ministry of Environment and Forestry of Turkey, General Directorate of Environmental Management was received on 18 th of September 2007 which contains a positive comment towards the two previous investments of Demirer Holding, the Mare Manastir project and the Anemon Intepe project. The statement within the above letter points out, that a request for an official Letter of Endorsement can only be issued after the adequate infrastructure of a DNA is established. The same applies for the Sayalar project. Conclusion: The explanation given is deemed 29

30 report clarifications and corrective action requests by validation team FCAR2 The project sites need to be clearly demarked. The unique identification of each turbine needs to provided in the PDD. Please provide these installed turbine details for verification. CAR1 A sensitivity analysis has to be performed in order to show that the project activity is not the most financially attractive option. The financial spread sheet calculations need to be provided for verification including sensititivity analysis ( including ±5% change in PLF ). Ref. to checklist question in table 2 Table 2 A.1.1. Table 2 B.3.1. B.3.3. Summary of project owner response original scan of the request for issuance of the LoE can be found under Annex A of this document. The coordinates of the wind turbines are enclosed in Annex 8 of the revised PDD, version 2. According to the Tool for the Demonstration and Assessment of the Additionality (version 2), a sensitive analyse has only to be performed in sub-step 2d of the investment analysis. In the Salayar wind farm PDD no investment analysis is performed, but a barrier analysis is applied. Therefore a sensitivity analysis is not required. In order to make the impact of the new legislation (feed in tariff 5eurocent/kwh) visible, the project IRR has been calculated taken into account this new feed in tariff and the suggested fluctuations in project load factor. This analyses can be found in the revised PDD (version 2) under B.3 step 5, Table Validation team conclusion reasonable to close therefore FCAR1 and go ahead also with the voluntary offset project Sayalar as GS-VER project. FCAR2 could be resolved and closed. According to the Tool for the Demonstration and Assessment of Additionality (version 03) is a sensitivity analysis applicable to options II (investment comparison analysis) and and III (benchmark analysis). Conclusion: The additionality tool was used to access and determine the additionality by means of step 3 (barrier analysis) only. Hence no sensitivity analysis, which is part of the optional step 2 (investment analysis), was applied. This approach is feasible and could be justified. Nevertheless a reduced sensitivity analysis was performed as part of step 5 according to 30

31 report clarifications and corrective action requests by validation team CAR2 The output of the main consultation with a overall duration of 60 days, which is a report including all written and oral comments given as well as the argumentation on whether or not the comments are taken into account, has to be submitted to the validation team. Ref. to checklist question in table 2 Table 2 E.1.3. Summary of project owner response Validation team conclusion 14. additionality tool, version 2 ( impact of VER registration ), which has to be used according to the Gold Standard Flyer GS_At_A_Glance_Additionality, which is not consistent with GS_VVM_VER of June 2007, which was announced, after the validation work has been already started and the GS_VVM_VER of February 2007 was still valid, which has referred to additionality tool, version 2. Under these circumstances CAR1 can finally be closed. The report of the main consultation has been finalised on 1 October 2007, and has been submitted to the validator. The report of the main consultation was reviewed by TÜV Rheinland and deemed adequate and transparent without concluding further corrective action or clarification requests. 31

32 report clarifications and corrective action requests by validation team CL 1 It has to be clarified, if meanwhile any participating Annex I Party have been identified. CL 2 The project proponent is requested to consider the latest public available OM and BM data provided by TEIAŞ to calculate the most conservative CM. CL 3 It shall be clarified whether Enercon GmbH, Germany, or Polat Enerji A.Ş., Turkey respectively is a project participant? Ref. to checklist question in table 2 Table 1 Table 2 B.2.4, B.5.1, B.5.2. Table 2 A.2.1. Summary of project owner response No Annex I Party has been identified so far. This has been clarified in section A. 3 of the revised PDD, version 2. During the development of the PDD the 2006 statistical yearbook was published. The emission factor calculations are based on the figures from the 2006 statistical yearbook. This was confirmed by a telephone call on 17 September 2007 to the person responsible for publication of statistics within TEIAS. (Ms. Gülsüm tel ). The project participants are Demirer Enerji Uretim A.S and Polat Enerji A.S. This has been clarified under section A.3 and Annex I of the revised PDD, version 2. Validation team conclusion The project proponent was requested to consider the latest public available OM and BM data provided by TEIAŞ to calculate the most conservative CM. Conclusion: The justification of the chosen public available data for the calculation of the emission factor is deemed as sufficient and acceptable. 32