Determination Report

Transcription

1 Determination Report Determination of the Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) JI Program of Activities in Germany (Track 1) Report No TÜV SÜD Industrie Service GmbH, Carbon Management Service Westendstr Munich GERMANY TÜV SÜD Industrie Service GmbH

2 Report No. Date of first issue Revision No. Date of this revision Certificate No Subject: Executing Operational Unit: Client: Contract approved by: Report Title: Number of pages Determination of a JPoA TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstr Munich Germany prisma trade GmbH i.g. Energieagentur.NRW Eupener Weg Mühlheim an der Ruhr Javier Castro Determination of the JI-PoA: Pilot programmatic Joint Implementation project in North Rhine-Westphalia (JIM.NRW) 19 (excluding cover page and annexes) Summary: The Certification Body Climate and Energy of TÜV SÜD Industrie Service GmbH has been ordered by prisma trade GmbH i.g. Energieagentur.NRW to determine the above mentioned JI Program of Activities (JPoA) in Germany. The determination of this PoA has been performed by document reviews, interviews by and on-site inspections, audits at potential locations of the JPoA and interviews at the offices of the PoA owner. As result of this procedure, it can not yet finally be confirmed that the submitted JPoA documentation is in line with all requirements set by the Marrakech Accords and the Kyoto Protocol. This opinion is caused by the solely remaining outstanding issue regarding the Letter of Approvals of the involved Annex-I-Party, which are Germany and an investing country yet to be defined. Apart of this requirement, TÜV SÜD can recommend this JPoA for acceptance as JI Track 1 PoA according to the German rules. If necessary further criteria set by track 1 rules of the investing country will have to be assessed in a second step. The German D DEHSt communicated already a positive signal of acceptance as JI Track 1 PoA under certain conditions. Additionally the assessment team reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of tons CO 2e (to be issued as ERUs) in the intended first crediting period from (the first Commitment Period of the Kyoto Protocol lasts from ), resulting in annual emission reductions of tons CO 2e, represents a reasonable estimation using the assumptions given by the PoA documents. However, the amount of emission reductions is strongly dependent on the number of project activities JPAs. Work carried out by: Klaus Nürnberger (project manager, lead auditor) Robert Mitterwallner (GHG auditor) Internal Quality Control by: Werner Betzenbichler TÜV SÜD Industrie Service GmbH

3 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 2 of 19 Abbreviations CAR CDM CPA CR DOE D DP EIA / EA ER ERU GHG IRR JI JPoA JPA KP LoA MP MS NGO NPV PDD PoA SC Corrective action request Clean Development Mechanism CDM Project Activity Clarification request Designated Operational Entity Designated National Authority Determination Protocol Environmental Impact Assessment / Environmental Assessment Emission reduction Emission Reduction Unit Greenhouse gas(es) Internal Rate of Return Joint Implementation JI Program of Activity JI Project Activity Kyoto Protocol Letter of Approval Monitoring Plan Management System Non Governmental Organisation Net Present Value Project Design Document Program of Activity Supervisory Commitee TÜV SÜD Industrie Service GmbH

4 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 3 of 19 Table of Contents Page 1 INTRODUCTION Objective Scope GHG PoA Description 5 2 METHODOLOGY Review of Documents Follow-up Interviews Resolution of Clarification and Corrective Action Requests 10 3 DETERMITION FINDINGS PoA Design General Findings Issued CARs/CRs Conclusion Baseline Findings Issued CARs/CRs Conclusion Duration of the JPoA Findings Issued CARs/CRs Conclusions Monitoring Plan Findings Issued CARs/CRs Conclusion Calculation of GHG Emissions Findings Issued CARs/CRs Conclusion Environmental Impacts Findings Issued CARs/CRs Conclusion Local stakeholder process Findings Issued CARs/CRs Conclusion 17 4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS DETERMITION OPINION TÜV SÜD Industrie Service GmbH

5 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 4 of 19 1 INTRODUCTION 1.1 Objective The private company, prisma trade GmbH i.g. Energieagentur.NRW has commissioned TÜV SÜD Industrie Service GmbH to conduct a determination of the Pilot programmatic Joint Implementation project in North Rhine-Westphalia (JIM.NRW) JPoA in Germany with regard to the relevant requirements for JI project activities and JPoAs. The determination serves as a conformity test of the PoA design and is a requirement for all JI projects or JPoAs. In particular, the PoA's baseline, the monitoring plan (MP), and the PoA s compliance with relevant UNFCCC and host country criteria are validated in order to confirm that the PoA design as documented is sound and reasonable and meets the stated requirements and identified criteria. Determination is considered necessary to provide assurance to stakeholders of the quality of the PoA and its intended generation of emission reductions (in particular ERUs - in the first commitment period under the Kyoto Protocol). UNFCCC criteria refer to the Kyoto Protocol Article 6 criteria and the Guidelines for the implementation of Article 6 of the Kyoto Protocol as agreed in the Marrakech Accords. 1.2 Scope The determination scope is defined as an independent and objective review of the JPoA s design documents (JPoA-DD, JPA-DDs), the PoAs baseline study and monitoring plan and other relevant documents. The information in these documents is reviewed against Kyoto Protocol requirements, UNFCCC rules and associated interpretations. TÜV SÜD has, based on the recommendations in the Validation and Verification Manual (see for further information employed a risk-based approach in the determination, focusing on the identification of significant risks for JPoA implementation and the generation of emission reductions. This report is based on the JPoA-DD version of September 14, 2007 (version No. 2) and the JPA-DDs (versions of September 18, 2007). These documents were published in the context of the Global Stakeholder Process (GSP) on the website of (link see chapter 4). Potential stakeholders have been invited for commenting. According to CARs and CRs indicated in the audit process the client decided to revise the JPoA-DD and JPA-DDs. Furthermore, participation information for the two real cases was submitted to the AIE. The final versions submitted on November 14th, 2007 (version 03 for JPoA-DD) and November 6 th, 2007; (version 02 for JPA-DD and real case PDDs) serves as the basis for the final conclusions presented herewith. Studying the existing PoA documentation, it was obvious that the competence and capability of the validation team has to cover at least the following aspects: Knowledge of Kyoto Protocol and the Marrakech Accords Environmental and Social Impact Assessment Skills in environmental auditing (ISO 14001) Quality Assurance Technologies, processes and operation of heat only boilers and energy efficiency TÜV SÜD Industrie Service GmbH

6 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 5 of 19 Fuel switch Baseline concepts Monitoring concepts Political, economical and technical random conditions in host country According to these requirements TÜV SÜD has assembled a project team in accordance with the appointment rules of the TÜV certification body Climate and Energy : Klaus Nürnberger is head of the division energy certification at TÜV SÜD Industrie Service GmbH. In his position he is responsible for the implementation of verification and certifications processes for electricity production based on renewable sources. The division has assessed more than 600 plants and sites all over Europe in particular hydro power plants. He has received extensive training in the CDM and JI validation and verification processes and participated already in several CDM and JI project assessments. Robert Mitterwallner is a GHG-A with a background as auditor for environmental management systems (according to ISO 14001) and expert in environmental permit procedures. He is located at the headquarter of TUV SÜD Industrie Service in Munich. He has received training in the JI determination as well as CDM validation process and applied successfully as GHG Auditor for several scopes. The audit team covers following requirements: Knowledge of Kyoto Protocol and the Marrakech Accords (All) Environmental and Social Impact Assessment (All) Skills in environmental auditing (ISO 14001) (All) Quality Assurance (All) Technologies, processes and operation of heat only boilers and energy efficiency (All) Baseline concepts (All) Monitoring concepts (All) Political, economical and technical random conditions in host country (All) In order to have an internal quality control of the PoA, a team of the following persons has been composed by the certification body climate and energy : Werner Betzenbichler Head of the Certification Body Climate and Energy 1.3 GHG PoA Description The core part of the JPoA is the improvement of energy efficiency of existing steam or hot water boilers by state of the art technologies as well as by fuel switch. TÜV SÜD Industrie Service GmbH

7 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 6 of 19 The criteria for participation to the JPoA, listed on page 3 of the JPoA-DD, were verified by the AIE. Each JPA participant has to sign the participation declaration of prisma trade GmbH i.g. Energieagentur.NRW confirming the criteria for participation of PoA. Generally all JPA participants located in North Rhine-Westphalia are eligible (JPoA boundary). Based on the implementation of measures to improve energy efficiency, the JPoA leads to a significant reduction of CO 2 emissions in the PoA scenario in comparison to the baseline scenario. The starting date of the JPoA was 1 June The starting date of the crediting period will be January 1st, The crediting period will end on December 31st, 2012 with the end of the first commitment period of the Kyoto protocol. The JPoA has one project participant: prisma trade GmbH i.g. Energieagentur.NRW. Potential investors that can act as well as JPoA participant are not defined yet. TÜV SÜD Industrie Service GmbH

8 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 7 of 19 2 METHODOLOGY In order to ensure transparency, a determination protocol was customised for the PoA, according to the Validation and Verification Manual (VVM). The protocol shows, in a transparent manner, criteria (requirements), means of verification and the results from validating the identified criteria. The determination protocol serves the following purposes: It organises, details and clarifies the requirements a JPoA is expected to meet; It ensures a transparent determination process where TÜV SÜD has documented how a particular requirement has been validated and the result of the determination. The determination protocol consists for this PoA of three tables. The completed determination protocol is enclosed in Annex 1 to this report. TÜV SÜD Industrie Service GmbH

9 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 8 of 19 Determination Protocol Table 1: Mandatory Requirements Requirement Reference Conclusion Cross reference The requirements the PoA must meet. Gives reference to the legislation or agreement where the requirement is found. Determination Protocol Table 2: Requirement checklist This is either acceptable based on evidence provided (OK), or a Corrective Action Request (CAR) of risk or non-compliance with stated requirements. The corrective action requests are numbered and presented to the client in the determination report. O is used in case of an outstanding, currently not solvable issue, AI means Additional Information is required. Used to refer to the relevant checklist questions in Table 2 to show how the specific requirement is validated. This is to ensure a transparent determination process. Checklist Question Reference Means of verification (MoV) The various requirements in Table 1 are linked to checklist questions the PoA should meet. The checklist is organised in six different sections. Each section is then further subdivided. 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 (DR) or interview (I). N/A means not applicable. Comment The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. Draft and/or Final Conclusion This is either acceptable based on evidence provided (OK), or a Corrective Action Request (CAR) due to non-compliance with the checklist question (See below). Clarification or Additional Information is used when the independent entity has identified a need for further clarification or more information. Determination Protocol Table 3: Resolution of Corrective Action and Clarification Requests Draft report clarifications and corrective action and additional Information requests Ref. to checklist question in table 2 Summary of PoA owner response Determination conclusion If the conclusions from the draft determination are either a Corrective Action Request or a Clarification or Additional Information Request, these should be listed in this section. Reference to the checklist question number in Table 2 where the Corrective Action Request or Clarification or Additional Information Request is explained. The responses given by the Client or other PoA participants during the communications with the independent entity should be summarised in this section. This section should summarise the independent entity s responses and final conclusions. The conclusions should also be included in Table 2, under Final Conclusion. TÜV SÜD Industrie Service GmbH

10 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 9 of Review of Documents The project developer submitted a JPoA-DD, a JPA-DD and real case PDDs for steam and hot water as well as additional background documents related to the JPoA design and baseline. A review for all these documents has been performed in order to identify all issues for discussion during the follow-up interviews on-site and by phone or Follow-up Interviews On July 19 th and 20 th 2007, the audit team of TÜV SÜD performed on-site audits and subsequently additional interviews with the site owner and the JPoA developer to resolve issues identified in the document review. The main topics of the interviews are summarised in Table 1. The complete and detailed list of all persons interviewed is enclosed in Appendix 2 to this report. Table 4: Interview topics Interviewed organisation FutureCamp GmbH, Duisburg Interview topics PoA design, baseline, monitoring plan, environmental impacts, stakeholder comments, monitoring procedures, calibration of the measurement equipment, archiving of data, electricity use, approval of the JPoA, JI-Guidelines, national and regional policy, social issues (stakeholder) prisma trade GmbH i.g. Energieagentur.NRW PoA design, baseline, monitoring plan, environmental impacts, stakeholder comments, monitoring procedures, calibration of the measurement equipment, archiving of data, electricity use, approval of the JPoA, JI-Guidelines, national and regional policy, social issues (stakeholder) SWB Stadtwerke Bremen Features of JPA, criteria of participation, permits, contracts, emission measuring reports, monitoring plan Rheinische Bioester GmbH Features of JPA, criteria of participation, permits, contracts, emission measuring reports, monitoring plan TÜV SÜD Industrie Service GmbH

11 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 10 of Resolution of Clarification and Corrective Action Requests The objective of this phase of the determination is to resolve the requests for corrective actions and clarification and any other outstanding issues, which need to be clarified in order to achieve a positive conclusion during the assessment process. Clarification Requests raised by TÜV SÜD have been resolved in most parts in the answers to the draft determination protocol (submitted from TÜV SÜD to the client after onsite visit in July), prepared by the JPoA developer FutureCamp GmbH and prisma trade GmbH i.g. Energieagentur.NRW at mid of September A revised final JPoA-DD, dated November 14 th, 2007 and a number of additional documents have been submitted to the EIA in order to provide the required evidences. To guarantee the transparency of the determination process, the concerns raised and the response given are summarised in chapter 3 below. The whole process is documented in more detail in the final determination protocol in Annex 1. The determination is not meant to provide any consulting towards the client. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the JPoA design. TÜV SÜD Industrie Service GmbH

12 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 11 of 19 3 DETERMITION FINDINGS In the following sections the findings of the final determination are stated. The determination findings for each determination subject are presented as follows: 1) The findings from the desk review of the PoA design document and the findings from interviews during the follow up visit are summarised. A more detailed record of these findings can be found in the Determination Protocol in Annex 1. 2) Where TÜV SÜD has identified issues that needed clarification or that represented a risk to the fulfilment of the PoA objectives, a Clarification or Corrective Action Request, respectively, has been issued. The Clarification and Corrective Action Requests are stated, where applicable, in the following sections and are further documented in the Determination Protocol in Annex 1. In total 24 Corrective Action Requests and 7 clarification requests have been raised. 3) Where Clarification and Corrective Action Requests have been issued, the response by the JPoA developer to resolve these requests are summarized in the final determination protocol. 4) The final conclusions of the determination are presented consecutively. 3.1 PoA Design General Findings The JPoA-DD as well as the JPA-DD correctly adopts the current valid format for PoAs and CPAs according to the CDM. The JPoA design fulfils all current requirements for PoAs. The foreseen technology does reflect current good practice for steam and hot water boilers. The JPoA itself has to be considered as innovative as currently no similar activities have started in North Rhine-Westphalia. The JPoA will use technology that can be considered as advanced technology in the host country. Moreover it is unlikely that the foreseen PoA technology will be substituted during the crediting period by a more efficient technology. Germany is a Party to the Kyoto Protocol and already has installed national procedures for the approval of JPoAs. One of the requirements for the approval of a JPoA is a positive determination opinion in this determination report. The German DEHSt has issued a Letter of Endorsement (LoE) on 15 th of October As this a track 1 determination there is no need to issue a Letter of Approval (LoA) for this JPoA. However, for the transfer of ERUs the participating countries, if applicable, have to provide a LoA. It is noted that no other Party as investing country yet has been indicated in the JPoA-DD. If necessary, further criteria set by track 1 rules of the investing country will have to be assessed in a second step. The JPoA description is clear, transparent, re-traceable and fulfils all the requirements for a well-developed JPoA. The JPoA starting date is clearly defined in the JPoA-DD. Also the starting date of the crediting period is clearly defined (January 1 st, 2008) Issued CARs/CRs See Annex 1, table 1 and 2 TÜV SÜD Industrie Service GmbH

13 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 12 of Conclusion All given responses to the indicated CARs and CRs are resolving the relevant issues. 3.2 Baseline Findings Approved CDM methodologies are not available for this JPoA. Therefore, the baseline methodology for this JPoA is developed by using a PoA specific approach. Possible baseline alternatives have been plausibly and re-traceably elaborated and transparently discussed. The final baseline scenario is the status quo alternative. Replacement or modernization of the installations to steam or hot water generation as well as fuel switch activity are not to be applied, as there are not any legal and other obligations. The necessary data to calculate the baseline are available. All assumptions for the baseline calculation are proven, defined and sourced correctly. The additionality of the PoA is proven by using the Additionality Tool. The additionality of the PoA is mainly proven by barrier and common practice analysis Issued CARs/CRs See Annex 1, table 1 and Conclusion The JPoA fulfils the criteria on baselines as set for the approval of JI-PoAs. TÜV SÜD Industrie Service GmbH

14 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 13 of Duration of the JPoA The JPoA starting date in June 2007 is defined as date of starting gathering potential JPA participants. The crediting period is demonstrated as the five years from 1 January 2008 to 31 Dec Findings None Issued CARs/CRs See Annex 1, table 1 and Conclusions The JPoA fulfils the criteria on baselines as set for the approval of JI-PoAs. TÜV SÜD Industrie Service GmbH

15 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 14 of Monitoring Plan Findings The JPoA uses a project-specific approach for the monitoring. As far as possible guidance from approved CDM methodologies is used for the monitoring concept. The monitoring methodology reflects current good practice and is supported by the monitored and recorded data. The monitoring provisions are in line with the JPoA boundaries. Indicators for JPoA emissions and baseline emissions have been defined and will be monitored. Leakage emissions are not monitored according to the monitoring plan as there are no emissions to be expected. The registration, monitoring, measurement and reporting will be under the responsibility of prisma trade GmbH i.g. Energieagentur.NRW. It is considered necessary that, once the JPoA is implemented, standard operating procedures need to be defined in line with the specific technical outline of the PoA. Regarding the monitoring plan a Corrective Action Request has been issued, requesting the fulfilment of the requirement set by the German DFP, that 10 % of the installations have to be visited during verification. This requirement finally has been considered in JPoA-DD Issued CARs/CRs See Annex 1, table 1 and Conclusion With the revised JPoA-DD the monitoring plan fulfils all requirements for such type of JPoA. The discussed issues can be considered to be resolved. TÜV SÜD Industrie Service GmbH

16 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 15 of Calculation of GHG Emissions Findings The PoAs spatial boundaries are correctly described. All necessary parameters to monitor PoA emissions have been defined. The most relevant and likely operational characteristics and indicators to calculate PoA emissions and baseline emissions have been chosen. Thus, the PoA will result in fewer GHG emissions than the baseline scenario Issued CARs/CRs None Conclusion The GHG calculations are documented in a complete and transparent manner. Conservative assumptions have been used when calculating baseline emissions. The given responses to the indicated CRs are resolving all open issues. The PoA thus does fulfil all the relevant requirements for JPoAs. TÜV SÜD Industrie Service GmbH

17 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 16 of Environmental Impacts Findings The analysis of the environmental impacts is sufficient. Relevant environmental impacts are listed sufficiently in the PDD. It is considered reasonable that the PoA will improve the current environmental situation. Transboundary impacts are not expected. No EIA is requested Issued CARs/CRs See Annex 1, table 1 and Conclusion The PoA fulfils all prescribed requirements completely. The open issue has been clarified sufficiently. TÜV SÜD Industrie Service GmbH

18 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 17 of Local stakeholder process Findings There are no PoA-specific requirements how to conduct a Local Stakeholder Process for this PoA. The PoA developer has demonstrated to have consulted mainly with interested companies. It is indicated by the PoA developer that mostly positive comments have been received. Homepage of the PoA developer has been used for publishing and / or systematic stakeholder identifications Issued CARs/CRs See Annex 1, table 1 and Conclusion The contacting meets the basic requirements of stakeholder consultation under the Kyoto Protocol and the Marrakech Accords. TÜV SÜD Industrie Service GmbH

19 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 18 of 19 4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS TÜV SÜD published the PoA design documents on its website for 30 days from September 21th, 2007 to October 20th, 2007 Documents have been public available for commenting under the following link &mode=1 Received Comments: No comments have been received. TÜV SÜD Industrie Service GmbH

20 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Page 19 of 19 5 DETERMITION OPINION TÜV SÜD has performed a determination of the Pilot programmatic Joint Implementation project in North Rhine-Westphalia (JIM.NRW) JPoA in Germany on the basis of all currently valid and relevant JI criteria of the host country. The review of the JPoA design documentation and the subsequent follow-up interviews have provided TÜV SÜD with sufficient evidence to determine the fulfilment of stated criteria. It has been verified that the requirements of the Letter of Endorsement of DEHSt have been considered in the JPoA documentation. Additionally the assessment team reviewed the estimation of the projected emission reductions. We can confirm that the indicated amount of emission reductions of tons CO 2e (to be issued as ERUs) in the intended first crediting period from (the first Commitment Period of the Kyoto Protocol lasts from ), resulting in annual emission reductions of tons CO 2e, represents a reasonable estimation using the assumptions given by the PoA documents. The determination is based on the information made available to us and the engagement conditions detailed in this report. The determination has been performed using a risk-based approach as described above. The only purpose of the report is its use during the registration process as JPoA. Hence, TÜV SÜD can not be held liable by any party for decisions made or not made based on the determination opinion, which will go beyond that purpose. Munich, Munich, Werner Betzenbichler Head of Certification Body Climate and Energy Klaus Nürnberger Assessment Team Leader TÜV SÜD Industrie Service GmbH

21 Determination Report: JPoA Pilot programmatic Joint Implementation project in North Rhine- Westphalia (JIM.NRW) Annex 1 of 2 Determination Protocol TÜV SÜD Industrie Service GmbH

22 Page / Number of Pages: 1 / 41 CHECKLIST TOPIC / QUESTION Ref. COMMENTS A. General description of the programme of activities (PoA) A.1. A.1.1. Title of the PoA: Does the used project title clearly enable to identify the unique JI program? PDD in GSP Final PDD A.1.2. A.1.3. A.2. Are there an indication of a revision number and the date of the revision? Is this in consistency with the time line of the project s history? Description of the (PoA):, the JPoA-DD has version 02 issued September 14 th A.2.1. Is the description of the policy or stated goal delivering a transparent overview of the program of activities?, the program is sufficiently describing the two measures of activity: - efficiency increase in steam production or - efficiency increase in heat production whereas fuel switch can be part of these two measures. A.2.2. Is it confirmed that the proposed PoA is a voluntary action by the coordination/managing entity?, this JI project is a voluntary action by the prisma trade GmbH i.g. Energie Agentur NRW and the participation is voluntary as well. A.2.3. Are the criteria for participation of the different JI program activities (JPA) clearly defined? In general yes CORRECTIVE ACTION REQUEST: CAR 1 For JPA with a need for authorization according to the German 4.BImSchV, in general the need for verification of particular permit requirements shall be added in chapter A.2.3 if applicable. Table 1 is applicable to JI PoA form Page A-1

23 Page / Number of Pages: 2 / 41 CHECKLIST TOPIC / QUESTION Ref. COMMENTS PDD in GSP Final PDD A.2.4. Is a design document according to No. 5b) of Annex 39 (see B.1.1) or a comparable documentation for the JPA with generic information relevant to all JPAs available and is this documentation linked with the PDD of the PoA? A.2.5. Is a design document according to No. 5c) of Annex 39 (see B.1.1) or a comparable documentation for the which is to be based on the application of the PoA to one real case available and is this documentation linked with the PDD of the PoA and the document mentioned in A.2.4? 1 No, CORRECTIVE ACTION REQUEST: Separate documentation defining the different JPAs has to be carried out. 1, 4 Each single JI program activity (JPA) under this PoA should be managed in an internet based data bank. Exemplary activities are already implemented in this databank. This data bank can be the base for each JPA as far as it covers all required information and if it is possible to export the data in a form which can be submitted to the determinator. CAR 2 A.2.6. A.3. A.3.1. Is all information provided in consistency with details provided by further chapters of the PDD? Project participants: Is the form required for the indication of project participants correctly applied? CORRECTIVE ACTION REQUEST: At the time submitting the PoA for approval a separate documentation (design description) defining the application of the PoA to at least one real case has to be elaborated (JPA- DD). CAR 3 1, the form is correctly applied. Table 1 is applicable to JI PoA form Page A-2

24 Page / Number of Pages: 3 / 41 A.3.2. CHECKLIST TOPIC / QUESTION Ref. COMMENTS Is the participation of all listed entities or Parties confirmed by each of them? 1 Participation of prisma trade GmbH i.g. Energie Agentur NRW is confirmed by the minutes of the meeting August 17 th with DEHSt. PDD in GSP Final PDD A.3.3. Is all information provided in consistency with details provided by further chapters of the PDD (in particular annex 1)? 1 Table 1 is applicable to JI PoA form Page A-3

25 Page / Number of Pages: 4 / 41 A.4. Technical description of the PoA: A.4.1. Location of the project activity: A Does the information provided on the location of the project activity allow for a clear identification of the site(s)?, the area of North Rhine-Westphalia (NRW) is clearly indicated in the PDD. A How is it ensured, that the project proponents can implement the project at this site (ownership, licenses, contracts etc.)? 5 Participation criteria and a technical questionnaire for the old and new installation is used systematically for data request of participants (see CAR 2). 6 The participant agreement (declaration) which has to be signed by each participant should cover all important information of old and new installations and this information has to be in compliance with Nr. 4 of Annex 39. CORRECTIVE ACTION REQUEST: CAR 4 In the declaration the participant and location of JPA as well as the expected life-time of the old boiler have to be clearly indicated. Furthermore the content of the declaration has to be updated with the requirements under Nr. 4 of Annex 39. Additionally have to be indicated in the declaration: monitoring parameters as well as the commitment that the use of heat or steam in the project has to be as in the historical situation. A.4.2. Technology(ies) to be employed, or measures, operations or actions to be implemented by the project activity: Table 1 is applicable to JI PoA form Page A-4

26 Page / Number of Pages: 5 / 41 A To which category(ies) is the progamme of activity belonging to? Is it correctly identified and indicated? 1, all measures of activity are desribed in detail (see CR 1). In my view the category of PoA is not mentioned explicitly. It is scope 3 (energy demand) and the categories are energy efficiency increase in steam and heat production and also fuel switch. CORRECTIVE ACTION REQUEST: Scope and category have to be described in the PDD. CAR 5 A Does the design engineering of the PoA reflect current good practices? Not applicable A A A A A.4.3. Does the description of the technologies to be applied provide sufficient and transparent input to evaluate its impact on the greenhouse gas balance? Is the technology implemented by the project activity environmentally safe? Does the PoA 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? Is the programme likely to be substituted by other or more efficient technologies within the project period? See F.1 Not applicable for PoA Not applicable for PoA Brief explanation of how the anthropogenic emissions of greenhouse gases by sources are to be reduced by the proposed PoA, including why the emission reductions would not occur in the absence of the proposed PoA, taking into account national and/or sectoral policies and circumstances: Table 1 is applicable to JI PoA form Page A-5

27 Page / Number of Pages: 6 / 41 A Is it clearly demonstrated that in the absence of the JI project the proposed voluntary measures would not be impelemented? A Is the form required for the indication of projected emission reductions correctly applied? A Are the figures provided consistent with other data presented by the PDD? A Is all information provided consistent with the details given in remaining chapters of the PDD (in particular annex 2)? 1, 2, 3, if the program were not be realized the old steam and hot water installations would be used as long as end of life time is not met. A.5. Project approval by the Parties involved: A.5.1 Is the project approved by the parties involved? 7 The letter of endorsement or support by the German DEHSt was requested in February 2007 and an official response is expected. CORRECTIVE ACTION REQUEST: A letter of endorsement or support of the DEHSt for the PoA is not yet available. CAR 6 B. Baseline B.1. Description and justification of the baseline chosen B.1.1. Are reference number, version number, and title of the baseline and monitoring methodology clearly indicated? 1 A separate JI methodology for PoAs is not available. In case of CDM there are two documents (Annex 38 and 39 of EB 32) which give roughly guidance. Besides of PoA procedural method there is no approved methodology used for the activities itself. A project specific approach is Table 1 is applicable to JI PoA form Page A-6

28 Page / Number of Pages: 7 / 41 B.1.2. B.1.3. B.1.4. Is the applied version the most recent one or still applicable? Is the methodology for JPAs sufficiently described? Is the applied methodology considered being the most appropriate one? developed. Not applicable Mainly yes, detailed check will follow. See comment in B.1.3 B.1.5. Are typical JPAs described, covering the technology or measure to be used, justification of the choice of an approved baseline and monitoring methodology and application of an approved baseline and monitoring methodology? 1, 2, 3 Not yet! The referenced participation declaration can be seen as a kind of JPA-Description-Template. It has to be checked, if all content requirements are fulfilled sufficiently (see A.4.1.2). B.2. Description of how the anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the PoA B.2.1. Is a description of the baseline scenario, (b) a description of the PoA scenario, and (c) an analysis showing why the emissions in the baseline scenario would likely exceed the emissions in the PoA scenario. 1 the Additionality tool of the CDM EB has been applied. CORRECTIVE ACTION REQUEST: The indicated additionality test is not existing, substitute the word Test by Tool. CAR 7 B.2.2. Have all technically feasible baseline scenario alternatives (at least all scenarios listed under step 1a in the additionality tool) to the PoA been identified and discussed by the PDD? 1, 9, legal framework requirements are listed in a complete manner. Clarification Request: The indicated due date for existing installations of 2012 is neither mentioned in the German instruction TA Luft nor in the CR 1 Table 1 is applicable to JI PoA form Page A-7

29 Page / Number of Pages: 8 / 41 3.BImSchV which is applicable for the limitation of the Sulphur content in liquid fuel. Combustion engines are not part of the measures and therefore should not be treated in the PDD. Clarification Request: Why is the REN-program not mentioned as alternative? CR 2 B.2.3. B.2.4. B.2.5. B.2.6. Does the PoA identify correctly and excludes those options not in line with regulatory or legal requirements? Have applicable regulatory or legal requirements been identified? In case of applying step 2 of the additionality tool: Is the analysis method appropriately identified (step 2a)? In case of applying step 3 (barrier analysis): Is a complete list of barriers developed that prevent alternatives to occur? 1, for the definition/completeness of status quo from the perspective of project participants (JPA level) see CAR 1. 1, 5, 6, see B.2.2 Step 3 is applied.. B.2.7. In case of applying step 3 (barrier analysis): Is transparent and documented evidence provided on the existence and significance of these barriers? 11 On level of JPAs the evidences can only given for each project activity in connection with the JPA-DD. CORRECTIVE ACTION REQUEST: Prove for missing financing of new programs has to be provided (s. foot note 4 in PDD with tense budgetary situation of North Rhine-Westphalia ). CAR 8 B.2.8. In case of applying step 3 (barrier analysis):, this is applicable for the public subsidy program REN of Table 1 is applicable to JI PoA form Page A-8

30 Page / Number of Pages: 9 / 41 Is it transparently shown that at least one of the alternatives is not prevented by the identified barriers? B.2.9. Have other activities in the host country / region similar to the project activity been identified and are these activities appropriately analyzed by the PDD (step 4a)? B If similar activities are occurring: Is it demonstrated that in spite these similarities the project activity would not be implemented without the JI (step 4b)? NRW. CORRECTIVE ACTION REQUEST: CAR 9 The source for the REN program should be added., common practice analysis has been applied., see B.2.9 B.3. Description of how the definition of the project boundary is applied to the PoA: B.3.1. Do the spatial and technological boundaries as verified on-site comply with the discussion provided by the PDD? 1, project boundaries on level of PoA are clearly defined and visualized. Description of the sources and gases included in the project boundary (Fill in the required amount of sub checklists for sources and gases as given by the methodology applied and comment at least every line answered with No ) B.3.2. Source: emissions from. Not Applicable for PoA B.4. Further baseline information, including the date of baseline setting and the name(s) of the person(s)/entity(ies) setting the baseline Emissions reductions B.4.1. Is there any indication of a date when determining the baseline? Table 1 is applicable to JI PoA form Page A-9

31 Page / Number of Pages: 10 / 41 B.4.2. Is this in consistency with the time line of the PDD history? B.4.3. Is information of the person(s) / entity(ies) responsible for the application of the baseline methodology provided in consistency with the actual situation? B.4.4. Is information provided whether this person / entity is also a project participant? CORRECTIVE ACTION REQUEST: The form of the date when determining the baseline is not in line with the Guideline for users of the JI PDD Form. CAR , the entity responsible for the application of the baseline methodology is not a project participant according to Annex 1. CORRECTIVE ACTION REQUEST: It should be mentioned in chapter B.4 of the PoA-PDD that the responsible entitiy for the application of the baseline methodology is not a project participant. CAR 11 Table 1 is applicable to JI PoA form Page A-10

32 Page / Number of Pages: 11 / 41 C. Duration of the PoA / crediting period C.1. Are the project s starting date and operational lifetime clearly defined and reasonable? CORRECTIVE ACTION REQUEST: According to the Guidelines for users of the JI PDD form the operational life time has to be stated in years and month. CAR 12 The Participant Declaration should indicate for old and new installation the expected operational lifetime. The remaining lifetime for old installation should be backed by statistical or individual reasons. C.2. Is the assumed crediting time clearly defined and reasonable (crediting period between 2008 and 2012)? CORRECTIVE ACTION REQUEST: According to the Guidelines for users of the JI PDD form the length of the crediting period has to be stated in years and month. CAR 13 D. Monitoring plan D.1. Description of monitoring plan chosen: Is the applied methodology considered being the most appropriate one? D , 2, 3 Monitoring of the emissions in the project scenario and the baseline scenario:, all measures of JPA are covered by the monitoring plan. In the following data checklists are shown for all data which are fixed at determination time, and monitoring checklists for all data which have to be monitored during the life-time of the project. D Data to be collected in order to monitor emissions from the project and how these data will be archived Is the list of parameters presented by chapter D In general considered to be complete with regard to the Table 1 is applicable to JI PoA form Page A-11

33 Page / Number of Pages: 12 / 41 requirements of the applied methodology? Clarification Request: The applied abbreviation r is not explained in the first line of the table. CR 3 ID 1: Name of the participant 5 Data Checklist / No / Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 2: Measure / Technology 5 Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 3: Emission factor EF CO2 Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? No Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? CAR 14 Table 1 is applicable to JI PoA form Page A-12

34 Page / Number of Pages: 13 / 41 QA/QC procedures appropriate? CORRECTIVE ACTION REQUEST: Source of emission factors indicated in Annex 2 is missing. ID 4: Fuel consumption Data Checklist / No / Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 5: heat production Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 6: standard annual utilisation Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Table 1 is applicable to JI PoA form Page A-13

35 Page / Number of Pages: 14 / 41 Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? D Description of formula used to estimate emissions from the PoA Are formulae required for the estimation of project Mainly yes emissions correctly presented, enabling a complete identification of parameter to be used and / or Clarification Request: monitored? The formula for Total Project Emissions is assuming a double counting of Project Emissions, please clarify, e.g. by the substitution of the single formula by one formula for each variant instead. D Data to be collected in order to determine the baseline emissions within the project boundary how these data will archived Fill in the required amount of sub checklists for fixed data parameter and comment any line answered with No ID 1: year of boiler construction Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 2: installed heating output (old system) Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? CR 4 Table 1 is applicable to JI PoA form Page A-14

36 Page / Number of Pages: 15 / 41 QA/QC procedures appropriate? ID 3: type of old system Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 4: type of fuel (old system) Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 5: type of new system Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 6: legal criterias, e.g. permit according to Data Checklist / No 4.BImSchV available and installed thermal power < / 20 MW Data unit correctly expressed? Table 1 is applicable to JI PoA form Page A-15

37 Page / Number of Pages: 16 / 41 Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? No ID 7: compliance with emission limit values in permit according to 4.BImSchV or of 1.BImSchV CORRECTIVE ACTION REQUEST: The eligibility of each participant requiring a BImSchG permit should be ensured by assessment of the corresponding permit. E.g. if in the case of Reference 3 company methane gas generated on-site is fed to a steam boiler this might not be obliged by the permit requirements. Data Checklist / No / Data unit correctly expressed? Appropriate description? No Source clearly referenced? No Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? CAR 15 ID 8: other incentive criteria than the PoA, e.g. by regional programs CORRECTIVE ACTION REQUEST: The parameter of legal compliance is still missing. Data Checklist / No / Data unit correctly expressed? Appropriate description? No CAR 16 Table 1 is applicable to JI PoA form Page A-16

38 Page / Number of Pages: 17 / 41 Source clearly referenced? No Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? CORRECTIVE ACTION REQUEST: The parameter of other incentive criteria is still missing. ID 9: standard annual utilisation of old system Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 10: standard annual utilisation of new system Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 11: Emission factor EF CO2 Data Checklist / No Data unit correctly expressed? Appropriate description? CAR 17 Table 1 is applicable to JI PoA form Page A-17

39 Page / Number of Pages: 18 / 41 Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? No See CAR 5 ID 12: Fuel consumption Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 13: heat production Data Checklist / No Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? ID 14: auxiliary fossil fuel 3 Data Checklist / No Data unit correctly expressed? No Appropriate description? No Source clearly referenced? No Table 1 is applicable to JI PoA form Page A-18

40 Page / Number of Pages: 19 / 41 Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? QA/QC procedures described? QA/QC procedures appropriate? No No No No No No Is the list of parameters presented by chapter D considered to be complete with regard to the requirements of the applied methodology? 3 CORRECTIVE ACTION REQUEST: The parameter of auxiliary fossil fuel which may occur e.g. for ignition process of burners and which has to be deducted in project is still missing. Clarification Request: Evidence should be given to the procedure how to deduct CO2 emissions from fossil fuel consumption used alternatively in the project, e.g. in plant Ref. 3 with multiburner for biogene and fossil fuel. CAR 18 CR 5 CORRECTIVE ACTION REQUEST: Apply, if applicable (see A.4.1.2), additional parameters. CAR 19 D Description of formula used to estimate baseline emissions Are formulae required for the estimation of baseline, it is assured that if the capacity of the new installed boiler is emissions correctly presented, enabling a complete higher than the capacity of the old boiler, only part of the fuel consumption can be related to the baseline emissions. identification of parameter to be used and / or monitored? D.1.3 Treatment of leakage in the monitoring plan: Is it explained how the procedures provided by the methodology are applied by the proposed project activity?, leakages are not relevant because of defined project boundaries. Table 1 is applicable to JI PoA form Page A-19

41 Page / Number of Pages: 20 / 41 D.2. Quality control (QC) and quality assurance (QA) procedures undertaken for data monitored: This aspect is covered for the relevant data in section D and D D.3. Please describe the operational and management structure that the project operator will apply in implementing the monitoring plan: D.3.1. Is the operational and management structure clearly described and in compliance with the envisioned situation? D.3.2. Are responsibilities and institutional arrangements for data collection and archiving clearly provided? D.3.3. Does the monitoring plan provide current good monitoring practice? D.3.4. Does annex 3 provide useful information enabling a better understanding of the envisioned monitoring provisions? D.4. Name of person(s)/entity(ies) establishing the monitoring plan: Annex 3 is only applicable for default values in the absence of fuel data of the participants. D.4.1. Is information of the person(s) / entity(ies) responsible for the monitoring methodology provided in consistency with the actual situation? D.4.2. Is information provided whether this person / entity is also a project participant? Table 1 is applicable to JI PoA form Page A-20

42 Page / Number of Pages: 21 / 41 E. Estimation of greenhouse gas emission reductions E.1. Estimated PoA emissions and formulae used in the estimation E.1.1. Are formulae required for the estimation of leakage emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? E.2. Estimated leakage and formulae used in the estimation, if applicable:, however, the estimated emissions are rather uncertain in this stage of PoA validation. E.2.1. Are formulae required for the estimation of leakage emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? E.2.2. Why are the leakage emissions not constant over the years? E.3. The sum of E.1. and E.2.: E.3.1. Is the data provided under this section in consistency with data as presented by other chapters of the PDD? E.4. Estimated baseline emissions and formulae used in the estimation: Ex-ante calculation of emission reductions E.4.1. Is the projection based on the same procedures as used for later monitoring? E.4.2. Is the data provided under this section in consistency with data as presented by other chapters of the PDD? Table 1 is applicable to JI PoA form Page A-21

43 Page / Number of Pages: 22 / 41 E.4.3. Are formulae required for the estimation of baseline emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? E.5. Difference between E.4. and E.3 representing the emission reductions of the project: E.5.1. Are formulae required for the determination of emission reductions correctly presented? yes E.6. Table providing values obtained when applying formulae above: E.6.1. Will the project result in fewer GHG emissions than the baseline scenario? E.6.2. Is the form/table required for the indication of projected emission reductions correctly applied? E.6.3. Is the projection in line with the envisioned time schedule for the project s implementation and the indicated crediting period? E.6.4. Is the data provided under this section in consistency with data as presented by other chapters of the PDD? F. Environmental impacts, see comment in E.1.1 F.1. Documentation on the analysis of the environmental impacts of the project, including transboundary impacts, in accordance with procedures as determined by the host Party: F.1.1. Has an analysis of the environmental impacts of the project activity been sufficiently described? Mainly yes, CORRECTIVE ACTION REQUEST: Negative impacts are not discussed (e.g. possibly higher emis- CAR 20 Table 1 is applicable to JI PoA form Page A-22

44 Page / Number of Pages: 23 / 41 sions regarding production and transport of biomass, noise etc. ). F.1.2. Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, is an EIA approved? No, it is not likely that EIAs are necessary regarding the project measures. F.1.3. Will the PoA create any adverse environmental effects? F.1.4. Are transboundary environmental impacts considered in the analysis? No No F.2. If environmental impacts are considered significant by the project participants or the host Party, provision of conclusions and all references to supporting documentation of an environmental impact assessment undertaken in accordance with the procedures as required by the host Party: F.2.1. Have identified environmental impacts been addressed in the project design? F.2.2. Does the PoA comply with environmental legislation in the host country? G. Stakeholders comments No CORRECTIVE ACTION REQUEST: It is not discussed whether the environmental impacts are significant? CAR 21 G.1. Information on stakeholders comments on the project, as appropriate: G.1.1. Have relevant stakeholders been consulted? 8 CORRECTIVE ACTION REQUEST: The act of publishing of PoA information on the homepage of Energie Agentur NRW should be added in the PDD. CAR 22 Table 1 is applicable to JI PoA form Page A-23

45 Page / Number of Pages: 24 / 41 G.1.2. Have appropriate media been used to invite comments by local stakeholders? G.1.3. If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws? G.1.4. Is the undertaken stakeholder process described in a complete and transparent manner? G.1.5. Is a summary of the stakeholder comments received provided? (participant list, minutes of meeting) G.1.6. Has due account been taken of any stakeholder comments received? H. Annexes 1 3 Annex 1: Contact Information 1. Is the information provided in consistency with the one given under section A.3? 2. Is information on all private participants and directly involved Parties presented?.. Annex 2: Baseline study 1. If additional background information on baseline data is provided: Is this information in consistency 1, 10 See CAR 5 Table 1 is applicable to JI PoA form Page A-24

46 Page / Number of Pages: 25 / 41 with data presented by other sections of the PDD? Values in table 1 for the years before 1978 are directly quoted from the literature source. However, the eligibility according to the Requirements of the German EnEV is not assessed here. 2. Is the data provided verifiable? Has sufficient evidence been provided to the validation team? Clarification Request: Source for data in tables 1 and 2 has to be clarified. CR 6 Clarification Request: CR 7 Evidence for the chosen values for calculation of emission reductions of biomass and biogas boilers shall be given, e.g. specification on low temperature data in table 1. CORRECTIVE ACTION REQUEST: Sources for net calorific values of possible fuel types are missing. CAR Does the additional information substantiate statements given in other sections of the PDD? Annex 3: Monitoring information 4. If additional background information on monitoring is provided: Is this information in consistency with data presented by other sections of the PDD? 1, 2, 3 5. Is the information provided verifiable? Has sufficient evidence been provided to the validation team? 1, 2, 3 Table 1 is applicable to JI PoA form Page A-25

47 Page / Number of Pages: 26 / Do the additional information / procedures substantiate statements given in other sections of the PDD? Table 1 is applicable to JI PoA form Page A-26

48 Page / Number of Pages: 27 / 41 Table 2 Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests by validation team Ref. to table 1 Summary of project owner response Validation team conclusion Corrective Action Requests For JPA with a need for authorization according to the German 4.BImSchV, in general the need for verification of particular permit requirements shall be added in chapter A.2.3 if applicable. CAR 1 of A.2.3 Completed as requested as follows: further particular requirements which result from the notice of approval of the installation related to the implemented JI program activities The additional criteria are appropriate to cover possible permit requirements and it was added to the list of criteria in PDD. Separate documentation defining the different JPAs has to be carried out. CAR 2 of A.2.4 The JPAs are developed and submitted. One JPA regarding energy efficiency increase through replacement and modernization of low efficient heating boiler by highly new ones with and without fuel switch The respective JPA-DDs were submitted according to Annex 39 of CDM EB (EB 32 report). One JPA regarding energy efficiency increase through replacement and modernization of low efficient steam boilers by highly new ones measures in steam production with and without fuel switch. Page A-27

49 Page / Number of Pages: 28 / 41 Before submitting the PoA for approval a separate documentation (design description) defining the application of the PoA to at least one real case has to be elaborated (JPA-DD). CAR 3 of A.2.5 A real case documentation per JPA is compiled and submitted Real case PDDs for steam and hot water have been submitted. Project specific information is indicated in Annex 2 of the PDDs. 1. Information regarding the participant and the location of the activity is quoted under a identification-no due to reasons of privacy at this project stage. Information was submitted in a separate document. 1. With the submitted participation information for real cases sufficiently information about the participant is provided. 2. The figure 0,955 is based on the combination the following calculation values (listed in Annex 2 of the JPoA): Measure Calculation value Large water tank boiler 0,89 Economiser 0,05 Continuous burner setting 0,01 O2-setting 0, It has been verified that Annex 2 of the JPoA as well as Annex 2 of the JPA-DD real case steam give evidence about the calculation of the figure 0,955 for the standard annual utilisation ration project boiler. Result 0,955 The value 0,955 is explained in the Annex 2 of the JPA-DD real case steam. Page A-28

50 Page / Number of Pages: 29 / 41 In the declaration the participant and location of JPA as well as the expected life-time of the old boiler have to be clearly indicated. Furthermore the content of the declaration has to be updated with the requirements under Nr. 4 of Annex 39. Additionally have to be indicated in the declaration: monitoring parameters as well as the commitment that the use of heat or steam in the project has to be as in the historical situation. CAR 4 of A Completed as requested. Information are given in the submitted JPAs For further information regarding the expected lifetime of the boiler see comments in CAR 12. Separate JPAs for replacement and modernization of heating boilers on one hand and steam boilers on the other hand are developed and submitted. Therefore a differentiation is made. If the capacity of the new installed boiler is higher than the capacity of the old boiler, only part of the fuel consumption can be related to the baseline emissions. In that case the calculation must be corrected as described in D See CR 8 and CR 9 Scope and category have to be decribed in the JpoA-DD. CAR 5 of A Completed as requested in chapter A.4.2. The scope of energy efficiency is mentioned in chapter A.4.2. of JPoA-DD. Page A-29

51 Page / Number of Pages: 30 / 41 A letter of endorsement or support of the DEHSt for the PoA is not yet available. CAR 6 of A.5.1 Letter of endorsement issued 15/10/2007 by the German DNF is submitted to TÜV SÜD. Based on requirements of the letter of endorsement of the German DFP, further information regarding leakage is given in chapter D1.3. of the JPoA as follows: In CDM methodology ACM 0009 Consolidated baseline methodology for fuel switching from coal or petroleum fuel to natural gas (Version 3; 26. July 2006) it is quoted, that to the extent that upstream emissions occur in Annex I countries that have ratified the Kyoto Protocol, from 1 January 2008 onwards, these emissions should be excluded, if technically possible, in the leakage calculations. According to the LoE of DEHSt a final approval of the JPoA is not possible. However, an approval will be possible under certain conditions, e.g. prove of Additionality, monitoring requirements. It has been verified that these conditions are covered by the JPoA documentation (see TÜV SÜD comments to CAR 12). Based on requirements of the letter of endorsement of the German DFP, further information regarding monitoring are given in chapter D1.3. of the JPoA and in the participant agreements (JPA_DD real case) as follows: Within the on-site meetings at the JPoA participants, EnergieAgentur NRW will also check, if the old installation is dismantled and a new boiler is installed. Moreover the JPoA participants have to ensure, that they won t use the replaced boiler in another activity and that the replaced boiler is dismantled and if applicable, duly disposed. This is quoted in the participant agreement. Adjusted as requested in chapter D.3. of the JPoA-DD as follows: In order to guarantee the data and quality reliability, it is further determined, that within the scope of the verification process, a random check of the emission reductions of 10% of the project participants will be ac- Closed Finally the JPoA-DD states the number of participants which have to be monitored Page A-30 during verification in compliance with the LoE.

52 Page / Number of Pages: 31 / 41 The indicated Additionality test is not existing, substitute the word Test by Tool. CAR 7 of B.2.1 Adjusted as requested in chapter B.2. Prove for missing financing of new programs has to be provided (s. foot note 4 in PDD with tense budgetary situation of North-Rhine- Westphalia ). CAR 8 of B.2.7 Foot note is cancelled The source for the REN program should be added. CAR 9 of B.2.8 Adjusted as requested as follows: Additional information about the support program of the Minstry for Economic Affairs and Energy of the State of NRW: progres.nrw has been provided in separate documentation. Form of the date when determining the baseline is not in line with the Guideline for users of the JI PDD Form. CAR 10 of B.4.1 Adjusted as requested as follows: The date of completion: 14/09/2007 It should be mentioned in chapter B.4 of the PoA-PDD that the responsible for the application of the baseline methodology is not a project participant. CAR 11 of B.4.4 Adjusted as requested as follows: The entity developing the baseline methodology is FutureCamp GmbH. FutureCamp GmbH is not a project participant. Page A-31

53 Page / Number of Pages: 32 / 41 CAR 12 of C.1 Adjusted as requested in chapter C.2. To ensure the possibility of further operation of the existing installation under technical aspects it is stated, that 1. participants with hot water boiler or steam boiler with an installed capacity up to 400 kw are allowed to take part in this program until the end of the expected life-time of the boiler. To indicate the expected life-time of the boiler the maximum expected life-time of a boiler with an installed capacity up to 400 kw is determined by 30 years. The basis for that value is given in the EnEV (Energieeinsparverordnung, German Energy Saving Regulation), which stipulates that boilers installed before October,1st 1978 must be put out of operation by December, 31st The aim is to increase energy efficiency by use of more efficient new boilers, taking into account that many existing boilers are installed before Thus it can be assumed, that boilers can be operated at least 30 years. Therefore the end of the expected life-time of the boiler is stated at the date 30 years after commissioning date. In D the parameter ID 2 is added. Closed: 1. Since the expected lifetime of an existing boiler can be assumed to be maximum 30 years, boilers built before October 1th 1978 are not eligible for JPoA. This criterion for participation is indicated in the PoA documentation. According to the Guidelines for users of the JI PDD form the operational life time has to be stated in years and month. The Participant Declaration should indicate for old and new installation the expected operational lifetime. The remaining lifetime for old installation should be backed by statistical or individual reasons. 2. Regarding the expected life-time of the old hot water boiler or steam boiler with an installed capacity over 400 kw it is stated, that the remaining lifetime for the old installation will be proven by legal requirements. Therefore different parameters are stated which provides data that give clear evidence, if the further operation of the existing installation under legal aspects is ensured. In D the parameter ID 7, ID 8 and ID 9 and in D provide relevant information. Moreover the responsible staff of EnergieAgen- 2. All applicable criteria for participation are sufficiently covered by JPoA documentation (see also comments of JPoA proponent to LoE in CAR 6). Page A-32

54 Page / Number of Pages: 33 / 41 According to the Guidelines for users of the JI PDD form the length of the crediting period has to be stated in years and month. Source of emission factors indicated in Annex 2 is missing. CAR 13 of C.2 CAR 14 of D Adjusted as requested in chapter C.3. Completed as requested as follows : DEHSt 2004 (Emissionsfaktoren und Kohlenstoffgehalte; Emission factors and carbon contents) The eligibility of each participant requiring a BImSchG permit should be ensured by assessment of the corresponding permit. E.g. if in the case of Reference 3 company methane gas generated on-site is fed to a steam boiler this might not be obliged by the permit requirements. CAR 15 of D Completed as requested as follows in chapter D.1.1.3: A new parameter is included: ID 9: Requirements regarding the notice of approval of the installation which require a replacement or modernization of the installation Furthermore this parameter is also included in the participant agreement. Information regarding the procedure is given in chapter D.2. and D.3. Page A-33

55 Page / Number of Pages: 34 / 41 CAR 16 of D Completed as requested as follows in chapter D.1.1.1: A new parameter is included: ID 10: Requirements which result from the notice of approval of the installation which are in conflict with the implemented JI program activities closed The parameter of legal compliance is still missing. Aim of this parameter is to secure legal compliance during the crediting period of the implemented project activity. Furthermore this parameter is also included in the participant agreement. CAR 17 of D Information regarding the procedure is given in chapter D.2. and D.3. Completed as requested; as seen in chapter D a new parameter is included. closed The parameter of other incentive criteria is still missing. ID 11: Use of any subsidies for the implementation of the measure or receipt of remuneration in terms of EEG or KWKG Furthermore this parameter is also included in the participant agreement. Page A-34

56 Page / Number of Pages: 35 / 41 The parameter of auxiliary fossil fuel which may occur e.g. for ignition process of burners and which has to be deducted in project is still missing. CAR 18 of D In chapter D the parameter ID 14 annual fuel consumption of each fuel source of the installation is already included. Therefore it is already stated, that every fuel source (fossil or biogenic) which is applicable in the context of the programme has to be measured. Furthermore this parameter is also included in the participant agreement. Closed, auxiliary fuel is covered by main fuel consumption, if applicable. Information regarding the procedure is given in chapter D.2. and D.3. Page A-35

57 Page / Number of Pages: 36 / 41 CAR 19 of D Completed as requested as follows in chapter D.1.1.3: A new parameter is included: ID 4: Installed capacity of the new system Furthermore this parameter is also included in the participant agreement Closed: Data regarding the used fuel in the new installation is not required for baseline calculation. Data regarding the type of the new installation is already included in chapter D Apply, if applicable (see A.4.1.2), additional parameters. Based on requirements of the letter of endorsement of the German DFP, a limitation regarding the participation within this JI program of activities is quoted. In order to ensure a delimitation to existing support program (progres.nrw) concerning the measures included in this JI program of activities, emission reductions due to the implementation of an economizer can only be imputed within this JI program of activities, if the JPoA participants are not within threshold according to definition of European Commission regarding small and medium sized companies. If the JPoA participants are within threshold, then the emission reductions due to the implementation of an economizer can only be accounted for, when a negative notice from the competent department is received. To check if a participant qualifies for this JI program of activities, two new parameters are included in chapter D ID 17: Within threshold according to definition of European Commission regarding small and medium sized companies It has been verified Page A-36 that parameters ID 17 and ID 18 were added in chapter D

58 Page / Number of Pages: 37 / 41 E.4: Based on own initiative the calculation in chapter E.4. Estimated baseline emissions are corrected, because incorrect annual utilization ratios were used in this calculation [for Oil-boiler (Low-temperature), Liquid gas / Natural gas boiler (low temperature), Liquid gas/natural gas steam boiler, built before 1978, Large water tank boiler with economizer] Negative impacts are not discussed (e.g. possibly higher emissions regarding production and transport of biomass, noise etc. ) CAR 20 of F.1.1 Completed as requested as follows: Negative impacts due to the implemented measures are not expected. Possibly noise may increase, e.g. by transportation of biomass, but these impacts are unkindly and negligible. It is not discussed whether the environmental impacts are significant? The act of publishing of PoA information on the homepage of Energie Agentur NRW should be added in the PDD. CAR 21 of F.2 CAR 22 of G.1.1 Clarification that negative environmental impacts are not considered significant Completed as requested in chapter G.1. Sources for net calorific values of possible fuel types are missing. CAR 23 of Annex 2 Completed as requested in in Annex 2 Clarification Requests Page A-37

59 Page / Number of Pages: 38 / 41 The indicated due date for existing installations of 2012 is neither mentioned in the German instruction TA Luft nor in the 3.BImSchV which is applicable for the limitation of the Sulphur content in liquid fuel. Combustion engines are not part of the measures and therefore should not be treated in the PDD. CR 1 of B.2.2 Source of the indicated date is TA Luft, page 88. Thresholds of the sulphur content in liquid fuel in existing installations have to be met 10 years since TA Luft is coming into force at the latest. TA Luft came into force October 1st, Combustion engines are cancelled in the PDD (page 10) Why is REN-program not mentioned as alternative? CR 2 of B.2.2 The REN-program, 2007 renamed to "progres.nrw, is not an alternative because of the following reasons: Conditions of "progres.nrw" are to be adjusted annually by the Ministry of Economic Affairs and Energy of the State of North Rhine-Westphalia, in case the market situation changes. The latest adjustment was performed in The program usually starts with the beginning of each year and last until the end of the year. This year it will finish at the end of November, as the funds are annually limited and financial resources this year are not available for any technology. The fund is allocated based on the principle "first come first served". Large interest of progres.nrw caused, that it was running short already in the middle of the year. The applied abbreviation r is not explained in the first line of the table. CR 3 of D The abbreviation r is cancelled Page A-38

60 Page / Number of Pages: 39 / 41 Formula for Total Project Emissions is assuming a double counting of Project Emissions, please clarify, e.g. by the substitution of the single formula by one formula for each variant instead. CR 4 of D This formula is chosen to be able to consider the entirety of all single activities under one formula in the PoA. Due to the indexing of every single activity double counting is excluded. Evidence should be given to the procedure how to deduct CO2 emissions from fossil fuel consumption used alternatively in the project, e.g. in plant Ref. 3 with multiburner for biogenic and fossil fuel. CR 5 of D In chapter D the parameter ID 14 annual fuel consumption of each fuel source of the installation is already included. Therefore it is already stated, that every fuel source (fossil and biogenic) which is applicable in the context of the program has to be measured. See also CAR 18. Source for data in tables 1 and 2 has to be clarified. CR 6 of Annex 2 Information regarding the procedure is given in chapter D.2. and D.3. Source: RECKGEL 2001, page The data Value for calculation of emission reductions are calculated average values based on the different annual utilization ratios for the respective boilers built from 1979 on. Evidence for the chosen values for calculation of emission reductions of biomass and biogas boilers shall be given, e.g. specification on low temperature data in table 1. CR 7 of Annex 2 Chosen values refer to data for low temperature oil boiler and low temperature gas boiler in table 1. This is applicable because liquid biomass is predominantly used in marginal converted oil boiler and biogas is predominantly used in marginal converted natural gas boiler. Source: Fachagentur Nachwachsende Rohstoffe (2007), Handbuch Bioenergie Kleinanlagen Page A-39

61 Page / Number of Pages: 40 / 41 Table 3 Unresolved Corrective Action and Clarification Requests (in case of denials) Clarifications and / or corrective action requests by validation team Id. of CAR/CR Explanation of Conclusion for Denial Page A-40

62 Page / Number of Pages: 41 / 41 Page A-41