SEL Validation Report 10MW

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VALIDATION REPORT

SEL MANUFACTURING
COMPANY LIMITED

VALIDATION OF THE
10 MW BIOMASS BASED POWER
PLANT IN PUNJAB, INDIA
REPORT NO. INDIA-VAL/295.49/2012
REVISION NO. 01

BUREAU VERITAS CERTIFICATION


Great Guildford House, 30 Great Guildford Street
SE1 0ES - London – United Kingdom

Report Template Revision 14 01/11/2011


BUREAU VERITAS CERTIFICATION

Report No: INDIA-val/295.49/2012 rev. 01


VALIDATION REPORT

Date of first issue: Organizational unit:


10/05/2012 Bureau Veritas Certification
Holding SAS
Client: Client ref.:
SEL Manufacturing Company Mr. Vinod Kumar Goyal
Limited
Summary:
Bureau Veritas Certification has made the validation of the “10 MW Biomass based Power plant in Punjab,
India” project of SEL Manufacturing Company Limited located at village Shekhon Mazara of Nawanshahar
district in the state of India on the basis of UNFCCC criteria for the CDM, as well as criteria given to provide for
consistent project operations, monitoring and reporting. UNFCCC criteria refer to Article 12 of the Kyoto
Protocol, the CDM rules and modalities and the subsequent decisions by the CDM Executive Board, as well as
the host country criteria.

The validation scope is defined as an independent and objective review of the project design document, the
project’s baseline study, monitoring plan and other relevant documents, and consisted of the following three
phases: i) desk review of the project design and the baseline and monitoring plan; ii) follow-up interviews with
project stakeholders; iii) resolution of outstanding issues and the issuance of the final validation report and
opinion. The overall validation, from Contract Review to Validation Report & Opinion, was conducted using
Bureau Veritas Certification internal procedures.

The first output of the validation process is a list of Clarification and Corrective Actions Requests (CL and
CAR), presented in Appendix A. Taking into account this output, the project proponent revised its project
design document.

In summary, it is Bureau Veritas Certification’s opinion that the project correctly applies the baseline and
monitoring methodology AMS I C, Version 19 and meets the relevant UNFCCC requirements for the CDM and
the relevant host country criteria.

Report No.: Subject Group:


INDIA-val/295.49/2012 CDM Indexing terms
Project title: Work approved by:
10 MW Biomass based Power plant in Mr. Flavio Gomes
Punjab, India

Work carried out by:


Bhavesh Prajapati – Team Leader No distribution without permission from the
Anupam Badola – Team Member Client or responsible organizational unit
Sushil Budhia and Associates – Financial
Expert
Internal Technical Review carried our by:
H. B. Muralidhar Limited distribution

Date of this revision: Rev. No.: Number of pages:


28/06/2012 01 251 Unrestricted distribution

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Table of Contents Page

1 INTRODUCTION .................................................................... 5
1.1 Objective 5
1.2 Scope 5
1.3 Validation team 5

2 METHODOLOGY .................................................................... 6
2.1 Review of Documents 6
2.2 Follow-up Interviews 7
2.3 Resolution of Clarif ication and Corrective Action Requests 7
2.4 Internal Technical Review 8

3 VALIDATION CONCLUSIONS ................................................. 9


3.1 Approval (49-50) 9
3.2 Participation (54) 10
3.3 Project design document (57) 10
3.4 Changes in the Project Activity 11
3.5 Project description (64) 12
3.6 Baseline and monitoring methodology 14
3.6.1 General requirement (76-77) 14
3.6.2 Project boundary (80) 23
3.6.3 Baseline identification (87-88) 24
3.6.4 Algorithms and/or formulae used to determine emission
reductions (92-93) 38
3.7 Additionality of a project activity (97) 48
3.7.1 Prior consideration of the clean development mechanism
(104) 48
3.7.1.1 Historical information on project timeline 52
3.7.2 Identification of alternatives (107) 52
3.7.3 Investment analysis (114) 53
3.7.4 Barrier analysis (118) 76
3.7.5 Common practice analysis (121) 77
3.8 Monitoring plan (124) 77
3.9 Sustainable development (127) 81
3.10 Local stakeholder consultation (130) 81
3.11 Environmental impacts (133) 82

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS........ 82

5 VALIDATION OPINION ......................................................... 82

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6 REFERENCES ..................................................................... 84

7 CURRICULA VITAE OF THE DOE’S VALIDATION TEAM


MEMBERS ........................................................................... 88

APPENDIX A: SEL MANUFACTURING COMPANY LIMITED CDM


PROJECT VALIDATION PROTOCOL ..................................... 89

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Abbreviations
CAR Corrective Action Request
CDM Clean Development Mechanism
CER Certified Emission Reductions
CL Clarification Request
CO 2 Carbon Dioxide
DOE Designated Operational Entity
GHG Green House Gas(es)
I Interview
IETA International Emissions Trading Association
NGO Non Government Organization
PDD Project Design Document
UNFCCC United Nations Framework Convention for Climate Change
DNA Designated National Authority
M & P Modalities and Procedure
VVM Validation and Verification Manual
MP Monitoring Plan
LCA Levelised Cost Analysis
NCV Net Calorific Value
PO Purchase Order
TFH Thermic Fluid Heater
MW h Mega W att Hour
SLM Straight Line Method
O & M Operation and Maintenance
SELML SEL Manufacturing Company Limited

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1 INTRODUCTION
SEL Manufacturing Company Limited has commissioned Bureau Veritas
Certification to validate its CDM project “10 MW Biomass based Power
plant in Punjab, India” (hereafter called “the project”) at village Shekhon
Mazara of Nawanshahar district in the state of Punjab, India.

This report summarizes the findings of the validation of the project,


performed on the basis of UNFCCC criteria, as well as criteria given to
provide for consistent project operations, monitoring and reporting.

1.1 Objective
The validation serves as project design verification and is a requirement
of all projects. The validation is an independent third party assessment of
the project design. In particular, the project's baseline, the monitoring
plan (MP), and the project’s compliance with relevant UNFCCC and host
country criteria are validated in order to confirm that the project design,
as documented, is sound and reasonable, and meet the stated
requirements and identified criteria. Validation is a requirement for all
CDM projects and is seen as necessary to provide assurance to
stakeholders of the quality of the project and its intended generation of
certified emission reductions (CERs).

UNFCCC criteria refer to Article 12 of the Kyoto Protocol, the CDM rules
and modalities and the subsequent decisions by the CDM Executive
Board, as well as the host country criteria.

1.2 Scope
The validation scope is defined as an independent and objective review of
the project design document, the project’s 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.

The validation 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 project design.

1.3 Validation team


The validation team consists of the following personnel:

FUNCTION NAME CODE TASK


HOLDER* PERFORMED
Lead Verifier Bhavesh Prajapati Yes No DR SV RI
Verifier Anupam Badola Yes No DR SV RI
Technical Not Applicable
Yes No DR SV RI
Specialist

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Financial Sushil Budhia and


Yes No DR SV RI
Specialist Associates
Internal Mr. H. B. Muralidhar
Technical Yes No DR SV RI
Review er (ITR)
Specialist Not Applicable
Yes No DR SV RI
supporting ITR
Report Flavio Gomes
Yes No DR SV RI
approval
*DR = Document Review; SV = Site Visit; RI = Report issuance

2 METHODOLOGY
The overall validation, from Contract Review to Validation Report &
Opinion, was conducted using Bureau Veritas Certification internal
procedures.

In order to ensure transparency, a validation protocol was customized for


the project, according to the version 01.2 of the Clean Development
Mechanism Validation and Verification Manual, issued by the Executive
Board at its 55 t h meeting on 30/07/2010. The protocol shows, in a
transparent manner, criteria (requirements), means of validation and the
results from validating the identified criteria. The validation protocol
serves the following purposes:
• It organizes, details and clarifies the requirements a CDM project is
expected to meet;
• It ensures a transparent validation process where the validator will
document how a particular requirement has been validated and the
result of the validation.

The completed validation protocol is enclosed in Appendix A to this


report.

2.1 Review of Documents


The Project Design Document (PDD) submitted by SEL Manufacturing
Company Limited and additional background documents related to the
project design and baseline, i.e. country Law, Guidelines for Completing
the Project Design Document (CDM-PDD), Approved methodology, Kyoto
Protocol, Clarifications on Validation Requirements to be Checked by a
Designated Operational Entity were reviewed.

To address Bureau Veritas Certification corrective action and clarification


requests, SEL Manufacturing Company Limited revised the PDD and
resubmitted it on 06/2012.

The validation findings presented in this report relate to the project as


described in the PDD version 05 dated 15/06/2012 (Ref /2/).

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2.2 Follow-up Interviews


On 26/08/2010 and 27/08/2010, the validation team of Bureau Veritas
Certification performed interviews with project stakeholders to confirm
selected information and to resolve issues identified in the document
review. Representatives of SEL Manufacturing Company Limited (project
participant), Ernst & Young Pvt. Ltd. (CDM Consultant) and local
stakeholders were interviewed (see References). The main topics of the
interviews are summarized in Table 1.

Table 1 Interview topics


Interview ed Interview topics
organization
SEL Manufacturing  Project design and implementation
Company Limited  Technical equipment and operation
(Project Participant)  Compliance with national laws and regulations
 Prior consideration of CDM
 Investment Analysis
 Additionality
 Baseline determination
 Monitoring Plan
 Data archiving and recording
LOCAL Stakeholders  Views and concerns about the project activity
 Confirmation of the local stakeholders’ meeting
conducted by the project participant
Ernst & Young, India  Baseline determination
(CDM Consultant)  Additionality discussions
 Monitoring Plan
 GHG emission reduction calculations
 Environmental impacts

2.3 Resolution of Clarification and Corrective Action


Requests
The objective of this phase of the validation is to raise the requests for
corrective actions and clarification and any other outstanding issues that
needed to be clarified for Bureau Veritas Certification positive conclusion
on the project design.

Corrective Action Requests (CAR) is issued, where:

(a) The project participants have made mistakes that will influence the
ability of the project activity to achieve real, measurable additional
emission reductions;
(b) The CDM requirements have not been met;
(c) There is a risk that emission reductions cannot be monitored or
calculated.

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The validation team may also use the term Clarification Request (CL), if
information is insufficient or not clear enough to determine whether the
applicable CDM requirements have been met.

To guarantee the transparency of the validation process, the concerns


raised are documented in more detail in the validation protocol in
Appendix A.

2.4 Internal Technical Review


The validation report underwent an Internal Technical Review (ITR) before
requesting registration of the project activity.

The ITR is an independent process performed to examine thoroughly that


the process of validation has been carried out in conformance with the
requirements of the validation scheme as well as internal Bureau Veritas
Certification procedures.

The Lead Verifier provides a copy of the validation report to the reviewer,
including any necessary validation documentation. The reviewer reviews
the submitted documentation for conformance with the validation scheme.
This will be a comprehensive review of all documentation generated
during the validation process.

W hen performing an Internal Technical Review, the reviewer ensures that:

The validation activity has been performed by the team by


exercising utmost diligence and complete adherence to the CDM
rules and requirements.

The review encompasses all aspects related to the project which


includes project design, baseline, additionality, monitoring plans and
emission reduction calculations, internal quality assurance systems
of the project participant as well as the project activity, review of the
stakeholder comments and responses, closure of CARs, CLs and
FARs during the validation exercise, review of sample documents.

The reviewer compiles clarification questions for the Lead Verifier and
Validation Team and discusses these matters with Lead Verifier.

After the agreement of the responses on the ‘Clarification Request’ from


the Lead Verifier as well as the PP(s) the finalized validation report is
accepted for further processing such as uploading on the UNFCCC
webpage.

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3 VALIDATION CONCLUSIONS
In the following sections, the conclusions of the validation are stated.

The findings from the desk review of the original project design
documents and the findings from interviews during the follow up visit are
described in the Validation Protocol in Appendix A.

The Clarification and Corrective Action Requests are stated, where


applicable, in the following sections and are further documented in the
Validation Protocol in Appendix A. The validation of the Project resulted in
39 Corrective Action Requests (CARs) and 18 Clarification Requests
(CLs).

The CARs and CLs were closed based on adequate responses from the
Project Participant which meet the applicable requirements. They have
been reassessed before their formal acceptance and closure.

The number between brackets at the end of each section corresponds to


the VVM paragraph.

3.1 Approval (49-50)


India is the only party involved in the project activity at this stage and is
the host party. Project participant M/s. SEL Manufacturing Company
Limited has obtained approval from DNA of India i.e. Ministry of
Environment and Forest. The project participant provided a copy of the
letter of approval (vide letter No: 4/19/2009-CCC dated 19/06/2010) (Ref
/3/) to the validation team. The validation team confirmed the authenticity
of the approval by reviewing the original letter of approval during site visit
on 26/08/2010. The letter of approval (Ref /3/) clearly states that India
has ratified the Kyoto Protocol and the approval is for voluntary
participation in CDM project activity. The project title and the project
participant referred in the letter of approval are consistent with the web-
hosted PDD and the validation team confirms that letter of approval refers
to the same project activity being submitted for the registration. The letter
of approval further confirms that proposed CDM project activity
contributes to the sustainable development in the host country (India).

The validation team further confirms that letter of approval from the host
party (India) is unconditional with respect to party to the Kyoto Protocol,
voluntary participation and project’s contribution to the sustainable
development. The title of the project activity and the project participant
referred in the letter of approval is same as mentioned in the web-hosted
PDD and revised PDD, version 5 (Ref /2/) being submitted for registration.
Hence, the validation team confirms that letter of approval from the host
party is in accordance with paragraphs 49–50 of VVM version 1.2 (Ref
B/1/).

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3.2 Participation (54)


The host party for this project activity is India. India has ratified the Kyoto
Protocol in August 2002 1. This was checked from the UNFCCC website
and the host country approval letter. As reported above in section 3.1, the
participation of the project participant has also been approved by the
National CDM Authority of India (NCDMA), therefore, by a Party to the
Kyoto Protocol.

The validation team concluded this by referring to the original letter of


approval (Ref /3/) issued by the DNA of India (NCDMA). The DNA
approved the project on 19/06/2010. The letter of approval clearly states
that India has ratified the Kyoto Protocol and the approval is for voluntary
participation in CDM project activity. The letter of approval also mentions
that the project contributes to sustainable development in India.

3.3 Project design document (57)


In line with requirement of Para 56 of VVM, Version 1.2 (Ref B/1/), the
validation team reviewed the web hosted PDD (Ref /1/) against the CDM-
EB guidance documents for completion of simplified PDD (Ref B/2/). The
validation team validated that the Project Design Document is based on
the currently valid CDM-SSC-PDD template, Version 03 (Ref B/3/). W hile
reviewing the web hosted PDD, the validation team observed erroneous
details in various sections of the web hosted PDD (Ref /1/). The validation
team raised following corrective action requests corresponding to the
relevant section of the PDD and guidance for completing SSC CDM PDD
(Ref B/2/).

CAR-1 The project participant’s view on project activity’s


contribution to sustainable development were not mentioned
in accordance with the host country criteria
CAR-2 Section A.4.1.4 was not restricted to one page and reference
to Lat/Long of the project activity was not provided.
CAR-3 The type and category of the project were not correct in the
web-hosted PDD.
CAR-4 Section A.4.3 and section B.4 of the web-hosted PDD were
and not in accordance with the guidance for completing SSC CDM
CAR-11 PDD
CAR-5 The confirmation on de-bundling of the project activity was
not complete in accordance to Guidelines on the assessment
of de-bundling for SSC project activities.
CAR-6 The title and reference of the applied small scale
methodology were not provided correctly in accordance with
the guidance for completing SSC CDM PDD.
CAR-7 The sources of the data provided in section B.4 of the web-

1
http://maindb.unfccc.int/public/country.pl?country=IN

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hosted PDD were not provided.


CAR-8 The web-hosted PDD was silent upon national policies and
circumstances.
CAR-9 The data and parameters available at the time of validation
were not clearly addressed in accordance with the guidance
for completing SSC CDM PDD
CAR-10 The ex ante calculations of emission reductions were not
presented clearly in section B.6.3 of the PDD.
CAR-12 Regarding the completeness of the monitoring plan
and presented in section B.7.1 and B.7.2 of the PDD in
CAR-13 accordance with the applied methodology and the guidance
for completing SSC CDM PDD.
CAR-15 The pre-project scenario was not clearly stated in the web-
hosted PDD.
CL-1 The local stakeholder consultation process was not clearly
and stated in the section E.1 of the web-hosted PDD and the
CAR 14 local stakeholders who have made comments were not
identified in section E.2 of the web-hosted.

In response to above CARs and CLs, the project participant revised the
PDD to correct the erroneous details. Having reviewed the revised PDD,
the validation team confirms that revised PDD, version 5 dated
09/01/2012 (Ref /2/) complies with the latest forms of the guidance
documents for completion of PDD and the information therein in
accordance with the applicable guidance document (Ref B/2/), and thus
complying with Para 57 of VVM, version 1.2.

3.4 Changes in the Project Activity


The validation team has observed during site visit that the project activity
has been implemented in conformance of the description provided in the
web hosted PDD. Thus, during the site visit, there were no changes
observed in project as compared to details mentioned in web hosted PDD
(Ref /1/). However, the pre-project scenario was not clearly stated in
section A.2 of the PDD and the validation team raised corrective action
request CAR-15 with respect to the same. In response to the CAR-15, the
project participant provided the revised PDD which clearly specif y the pre-
project scenario and the pre-project scenario description is in accordance
with the observations of the validation team during site visit (please refer
to Appendix A of the report for the details on the CAR-15 and it’s closure
by the validation team).

Based on the CAR/CLs raised by the validation team during the course of
validation, the web hosted PDD (Ref /1/) did undergo changes and the
final PDD version 5 dated 15/06/2012 (Ref /2/) has the following changes
as compared to the web hosted PDD:
1. Information in section A.2 has been updated.

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2. The applicable baseline and monitoring methodology has been


changed to its latest version available in section B.1. The
applicability conditions are revised and detailed by the project
participant in accordance with the latest approved methodology
AMS-I.C. version 19.
3. Project boundary has been revised in accordance with applied
baseline and monitoring methodology.
4. The detailed computation on the baseline and project emissions
have been provided in section B.6.3 and methodological choices
have been explained clearly by the project participant in section
B.6.3 of the PDD. The ex ante determination of the emission
reductions has been changed due to change in the auxiliary
electricity consumption as compared to the web-hosted PDD.
5. The national policies and circumstance relevant to the baseline have
been explained in the section B.5 of the revised PDD
6. Some input assumptions taken in the investment analysis have been
revised in section B.5 (please refer to section 3.7 of the report for
details on the input assumptions taken by the project participant).
7. Demonstration of prior consideration of CDM has been revised in
accordance with latest approved prior consideration guidance
(Annex 13; EB 62).
8. Monitoring parameters and monitoring plan has been revised in
section B.7.1 and B.7.2 of the PDD.

3.5 Project description (64)


The project activity involves 10 MW biomass based co-generation power
plant at an already exiting manufacturing facility of the SEL Manufacturing
Company Limited. The proposed CDM project activity involves use of
renewable biomass for generation of thermal and electrical energy in a
co-generation plant. The project activity is a Greenfield co-generation
plant and prior to the project activity, there was no simultaneous
generation of steam and electricity at the manufacturing facility of the
project participant. The validation team has carried out the site visit on
26 t h and 27 t h Aug 2010 to confirm the project description with respect to
the web-hosted PDD. The validation team has also reviewed the technical
specifications (Ref /4 and 6/, Ref /5 and 7/) of the equipments (boiler and
turbine) to confirm the rated project capacity. In addition the validation
team has also conducted the site visit to validate the physical aspects of
the project implementation and confirm that technical specifications
presented in the PDD being submitted for registration represent the actual
implemented project activity.

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Sr. Equipment Details Means of


no. verification
1 Boiler Type – AFBC Balance Draft, single Manufacturer’s
drum, under and over-bed fuel specification
feeding system with multi-fuel (Ref /4 and 6/)
combination and natural water and physical
circulation boiler site verification
Rated Capacity – 50 TPH conducted by a
Rated Steam Temperature – 517 0 C two member
Rated Steam Pressure – 88 ATA validation team.
Make – Cethar Vessels Limited
2 Turbine Turbine Type- Extraction cum Manufacturer’s
and condensing turbine specification
Generator Rated steam temperature at the (Ref /5 and 7/)
set turbine inlet – 510 0 C and physical
Rated steam pressure at the turbine site verification
inlet – 85 ATA conducted by a
Rated steam flow at the turbine inlet two member
– 48.40 TPH validation team.
Rated steam extraction temperature
from the turbine – 259.5 0 C
Rated steam extraction pressure from
the turbine – 9.4 ATA
Rated steam extraction flow from the
turbine – 19.70 TPH
Turbine Make – Siemens
Rated power at generator terminals –
10000KW
Generator Make – Siemens

The validation team noted that project participant has provided the
extraction steam temperature from the turbine as 190ºC in the web-hosted
PDD. Besides, the technical details of the project activity were not clear
from section A.4.2 of the web-hosted PDD. Hence, the validation team
raised a corrective action request CAR-3 on the same.

In response to CAR-3, the project participant provided the details of the


technical specifications of boiler and turbine in section A.4.2 of the PDD
and also clarified that extracted steam from the turbine at 259.5ºC is
reduced at desuperheater to 190 ºC in line with the process steam
requirements. The project participant has also used the steam
temperature after desuperheating for emission reduction calculations,
which is conservative and hence, the validation team closed CAR-3.

Based on the site visit carried out on 26 t h and 27 t h Aug. 2010, the
validation team confirms that project description presented in the revised
PDD version 5 represents the actual physical implementation of the

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project activity. The fixed crediting period of ten years has been chosen
by the project participant. The validation team further confirms that the
project activity equipments are new and the technical lifetime of the
project activity, as described by the manufacturer (Ref /9/ and Ref /10/) is
twenty years. Hence, the validation team also confirms that the project
lifetime is more than the applicable crediting period selected by the
project participant.

3.6 Baseline and monitoring methodology


3.6.1 General requirement (76-77)
The proposed CDM project activity “10 MW Biomass based Power plant in
Punjab, India” uses the approved baseline and monitoring methodology
AMS I C, Version 19 (Ref B/5/). The project participant had used
approved methodology AMD I C, Version 17 (Ref B/14/) at the time of web
hosting. However during the course of the validation, the methodology
AMS-I.C. has been revised by the CDM Executive Board and hence, the
project participant has revised the PDD with latest applicable version 19
of the baseline and monitoring methodology AMS-I. C.

The steps taken to assess the relevant information contained in the PDD
against each applicability condition, as stated in AMS I C, version 19, are
described below.

Applicability Condition-1 (Sr. No. 1 of methodology): This methodology


comprises renewable energy technologies that supply users with thermal
energy that displaces fossil fuel use. These units include technologies
such as solar thermal water heaters and dryers, solar cookers, energy
derived from renewable biomass and other technologies that provide
thermal energy that displaces fossil fuel.

The proposed project activity is a 10 MW biomass based co-


generation project. The project activity will utilise the renewable
biomass for the generation of the thermal and electrical energy. The
project activity has been commissioned during the course of CDM
validation activity and the validation team confirms based on the site
visit observations and review of the annual report of the company
(Ref /8/) that project activity consumes renewable biomass for the
thermal and electrical energy generation. As reported in section
3.6.3 of this report later, in absence of the proposed CDM project
activity, equivalent energy would have been generated by the coal
based co-generation plant. Thus, the proposed CDM project activity
displaces fossil fuel. Hence, this condition of the methodology has
been fulfilled.

Applicability Condition-2 (Sr. No. 2 of methodology): Biomass-based


cogeneration systems are included in this category. For the purpose of

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this methodology, cogeneration shall mean the simultaneous generation of


thermal energy and electrical energy in one process. Project activities
that produce heat and power in separate element processes (for example
heat from a boiler and electricity from a biogas engine) do not fit under
the definition of cogeneration project.

The project activity is a Co-generation power plant where


simultaneous generation of the thermal and electrical energy takes
place in a single process. The validation team has confirmed the
same by conducting an on site visit and also reviewed the technical
specification of the project equipments (boiler and turbines) based
on the purchase orders issued by the project participant (Ref /4 and
5/). Hence this condition of the methodology has been fulfilled by
the project activity.

Applicability Condition-3 (Sr. No. 3 of methodology): Emission reductions


from a biomass cogeneration system can accrue from one of the following
activities: (a) Electricity supply to a grid; (b) Electricity and/or thermal
energy (steam or heat) production for on-site consumption or for
consumption by other facilities; (c) Combination of (a) and (b).

The biomass based cogeneration project activity will supply the


electricity and thermal energy to the adjoining manufacturing facility
(spinning and terry towel) of the project participant and the project
participant has selected option (b) “Electricity and/or thermal energy
(steam or heat) production for on-site consumption or for
consumption by other facilities” in the web-hosted PDD. However,
during site visit it was observed by the validation team that project
participant has taken approval from the Punjab Energy Development
Agency (PEDA) towards sale of excess electricity from the project
activity to the grid and raised corrective action request CAR-16
towards selection of the option (b) of the applicability condition
selected in the web-hosted PDD. The project participant provided a
response to CAR-16 stating that though the project participant has
got an approval towards sale of the electricity to the grid, there is no
such power sale agreement signed with the state electricity utility
and provided an undertaking (Ref /11/) stating that electricity from
the project activity will not be sold to any external party. The
undertaking further states that electricity generated from the project
activity will be exclusively used to meet the internal power
requirements of the company. The project activity has already been
commissioned and hence, in order to cross-check the statement of
the company, the validation team reviewed the Annual report of the
company for year 2010-11 (Ref /8/), which does not specif y any
power sale to the grid or any other party. Hence, the validation team
accepted the response provided by the project participant and
confirms that option (b) of the applicability condition “Electricity

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and/or thermal energy (steam or heat) production for on-site


consumption or for consumption by other facilities” is applicable to
the project activity. Thus, this applicability condition of the
methodology has been fulfilled by the proposed CDM project
activity.

Applicability Condition-4 (Sr. No. 4 of methodology): The total


installed/rated thermal energy generation capacity of the project
equipment is equal to or less than 45 MW thermal.

The cogeneration plant consists of a boiler having rated capacity of


50 Tonnes per hour of steam, 88 ata steam pressure, 517 ºC steam
temperature and 135 ºC feed water temperature. Based on the
above rated technical specifications, which have also been cross-
verified during on-site assessment, the rated capacity of at the
boiler output is 39.74 MW t h e r m a l . Hence, the validation team confirms
that the rated capacity of the co-generation project activity is well
below the 45 MW thermal. The validation team observed that the
project participant did not demonstrate the total installed/rated
capacity of the co-generation project explicitly in the web-hosted
PDD against applicability condition no. 4 of the applied baseline and
monitoring methodology and hence raised clarification requests CL-
2 and CL-3. This was also due to lack of clarity whether any feed
water return or any condensate recovery has been considered by
the project participant in the calculation of the net thermal output of
the boiler. In response to the CL-2 and CL-3, the project participant
elaborated the justification of the applicability condition no. 4 of the
methodology in the revised PDD. The project participant explained
that 135 ºC feed water temperature has been considered for the
calculation of the net boiler output. The validation team reviewed
the technical specifications of the boiler and confirmed that the feed
water temperature and other steam parameters considered in the
calculation of the net thermal output of the boiler are based on the
rated technical specifications of the technology supplier. Hence, the
validation team accepted the response provided by the project
participant and closed CL-2 and CL-3. The project activity fulfils this
applicability condition.

Applicability Condition-5 (Sr. No. 5 of methodology): For co-fired systems,


the total installed thermal energy generation capacity of the project
equipment, when using both fossil and renewable fuel shall not exceed 45
MW thermal (see paragraph 6 for the applicable limits for cogeneration
project activities).

The project activity is a biomass based co-generation project. The


cogeneration plant consists of a boiler having capacity of 50 Tonnes
per hour of steam, 88 ata steam pressure, 517 ºC steam

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temperature and 135 ºC feed water temperature. Based on the


above technical specifications, which have also been validated
during on-site visit, the rated capacity of at the boiler output is
39.74 MW t h e r m a l . Hence, the validation team confirms that the rated
capacity of the co-generation project activity is well below the 45
MW t h e r m a l . The rated capacity of the boiler will not change even with
co-firing. In the web-hosted PDD, under this applicability condition,
the project participant specified that project activity is not a co-fired
project. However, during site visit, the validation team observed that
the boiler is a multi-fuel fired system where a coal feeding system
has also been installed for the exigency situations and therefore,
the validation team raised corrective action CAR-17. In the
response, the project participant revised the justification for the
applicability condition no. 5 of the methodology in the PDD. The
project participant further responded that use of fossil fuel will only
take place during exigencies and in accordance with the applied
methodology AMS-I.C. version 19, provided ex ante determination of
the renewable biomass and the fossil fuel usage in the revised PDD.
In addition, the project participant has also provided the procedure
for the calculation of project emissions from fossil fuel consumption
in accordance with the tool to calculate project or leakage emissions
from fossil fuel consumption (Ref B/10/) and also provided the
monitoring procedure for the fossil fuel consumption in the revised
PDD. The validation team has also assessed biomass assessment
report (Ref /12/) provided by the project participant. The same is
also approved by the Punjab Energy Development Agency (a
Government of Punjab Entity). Based on the local sectoral
experience of the validation team and review of the biomass
assessment report, the validation team confirms that there is
surplus biomass available in the region in accordance with
competing use of biomass (Ref B/6/). Hence, the project participant
accepted the response provided by the project participant and
closed CAR-17. The project activity fulfils this applicabilit y
condition.

Applicability Condition-6 (Sr. No. 6 of methodology): The following


capacity limits apply for biomass cogeneration units: (a) if the project
activity includes emission reductions from both the thermal and electrical
energy components, the total installed energy generation capacity
(thermal and electrical) of the project equipment shall not exceed 45 MW
thermal. For the purpose of calculating this capacity limit the conversion
factor of 1:3 shall be used for converting electrical energy to thermal
energy (i.e. for renewable energy project activities, the maximal limit of
15 MW(e) is equivalent to 45 MW thermal output of the equipment or the
plant); (b) If the emission reductions of the cogeneration project activity
are solely on account of thermal energy production (i.e. no emission
reductions accrue from electricity component), the total installed thermal

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energy production capacity of the project equipment of the cogeneration


unit shall not exceed 45 MW thermal; (c) If the emission reductions of the
cogeneration project activity are solely on account of electrical energy
production (i.e. no emission reductions accrue from thermal energy
component), the total installed electrical energy generation capacity of the
project equipment of the cogeneration unit shall not exceed 15 MW.

The project activity is a co-generation project. The emission


reduction from the project activity is on the account of thermal as
well as electrical energy. The rated thermal output of the boiler is
39.74 MW t h e r m a l which is well below the small scale project activity
limit of 45 MW t h e r m a l for the co-generation project activities.
However, in the web-hosted PDD, the project participant has
referred that total thermal capacity of the project activity is 42.25
MW t h e r m a l (based on 12.25 MW t h e r m a l energy requirements and 10
MW e l e c t r i c a l energy of the project converted to thermal using 1:3
conversion ratio). However, it was not explicit how 12.25 MW t h e r m a l
energy has been determined. Hence, the validation team raised a
clarification request CL-4. In response to the CL-4, the project
participant revised the justification of the applicability condition in
the revised PDD and also provided details of the computation
approach in the spreadsheet. The validation team observed that in
the revised PDD, thermal energy generation capacity of the project
is specified as 13.12 MW t h e r m a l (except 10 MW e l e c t r i c a l ) which is
based on the turbine steam extraction specifications (Ref /5/).
Hence, the same has been accepted by the validation team and
closed CL-4. Thus, the validation team confirms that even based on
the electrical output (10 MW electrical at the generator terminals)
and thermal output (13.12 MW thermal as per the turbine extraction
steam parameters) the total rated installed capacity of the project
arrives as 43.12 MW t h e r m a l which is still below the 45 MW t h e r m a l
threshold of the small-scale project. Hence, the project activity
fulfills this applicability condition.

Applicability Condition-7 (Sr. No. 7 of methodology): The capacity limits


specified in the above paragraphs apply to both new facilities and retrofit
projects. In the case of project activities that involve the addition of
renewable energy units at an existing renewable energy facility, the total
capacity of the units added by the project should comply with capacity
limits in paragraphs 4 to 6 and should be physically distinct from the
existing units.

The project activity is a green field co-generation project and not a


modification or retrofit project. The validation team has confirmed
that project equipments are new and the same has been verified
through the physical verification during site visit and review of the
purchase orders (Ref /4 and 5/). Hence, as explained above, the

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total thermal output of the boiler is less than 45 MW t h e r m a l . This


applicability condition has been fulfilled.

Applicability Condition-8 (Sr. No. 8 of methodology): Project activities that


seek to retrofit or modify an existing facility for renewable energy
generation are included in this category.

Since the project activity does not seek to retrofit or modification of


an existing facility, this condition is not applicable. The project
activity is a Greenfield renewable biomass based cogeneration
project.

Applicability Condition-9 (Sr. No. 9 of methodology): New Facilities


(Greenfield projects) and project activities involving capacity additions
compared to the baseline scenario are only eligible if they comply with the
related and relevant requirements in the General Guidelines to SSC CDM
methodologies.

As explained above in applicability condition 4 and 5, the proposed


CDM project activity involves generation of the thermal and
electrical energy from the renewable biomass fuel in a cogeneration
mode. The thermal output of the project activity based on the boiler
specifications on the techno-commercial offer provided by the
manufacturer (Ref /6/) and the purchase order released by the
project participant (Ref /4/) is 39.74 MW t h e r m a l . The project capacity
based on the turbine and generator set technical specifications (Ref
/5/) provided by the manufacturer arrives as 43.12 MW t h e r m a l
(thermal energy capacity based on turbine steam extraction
parameters arrives as 13.12 MW t h e r m a l and 10 MW electrical output
at generator terminals). The same is also well within the specified
small-scale capacity threshold for the Type I project activities. The
validation team also confirms that the thermal output of the project
as specified above is based on the rated parameters of the
equipment supplier irrespective of the load factors. The project
participant has applied previously approved small-scale CDM
baseline and monitoring methodology AMS-I.C. version 19 and
demonstrated the additionality of the project in accordance with
Attachment A to Appendix B. The validation team also confirms that
the project activity is not a de-bundled component of a large project
activity. The project activity will utilise the renewable biomass and
the validation team confirms that emission reductions estimated ex
ante in the validated PDD are accounted for the renewable biomass
only. In accordance with the methodology AMS-I.C. version 19, the
project participant has determined ex ante that only will be utilized
in the project activity.

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The project participant has considered the leakage in accordance


with the applicable methodology and also referred to the EB 47,
Annex 28 “General guidance on leakage in biomass project
activities” for the leakage calculations. The biomass assessment
report submitted by the project participant (Ref /12/) which has also
been approved by the state government entity Punjab Energy
Development Agency (PEDA), confirms that there is more than 89%
(as compared to the total consumption in the area) renewable
biomass available within 50km distance from the project boundary.
The same is significantly sufficient as compared to 25% surplus
guidance provided in General guidance on leakage in biomass
project activities. Hence, the validation team confirms that leakage
from competing use of biomass is not applicable to the project
activity.

The validation team further noted that in Executive Board Meeting


report 63, Methodological tool “Project and leakage emissions from
road transportation of freight” (Ref B/11/) was approved by the CDM
Executive Board. Moreover, footnote 18 of the applied methodology
AMS-I.C. Version 19 states that “If biomass residues are transported
over a distance of more than 200 kilometers due to the
implementation of the project activity then this leakage source
attributed to transportation shall be considered, otherwise it can be
neglected”. The biomass assessment report, approved by the
government agency Punjab Energy Development Agency (PEDA),
estimates significantly sufficient surplus biomass (about 83% as
compared to the total consumption in the area) is available within
the 50km distance from the project activity. Thus, transportation of
biomass from more than 200km distance seems a very distant
scenario. Thus, the validation team confirms that methodological
tool “Project and leakage emissions from road transportation of
freight” is not applicable to the proposed CDM project activity
considering the methodology precedence over the tool and
confirmation from the biomass assessment study report (Ref /12/)
that sufficient biomass is available for the project activity within
50km distance from the project site.

The validation team further confirms that the project participant has
taken latest default IPCC values based on 2006 IPCC Guidelines for
National Greenhouse Gas Inventories. The baseline and the
monitoring methodology have been applied in accordance with the
applicable methodology AMS-I.C. version 19. The project activity is
a Greenfield project and technical lifetime of the project has been
considered by the project participant in accordance with the
technology supplier’s specifications (Ref /9 and 10/). Hence, the
validation team confirms that the project activity complies with the
general guidance with the small-scale methodologies version 17.

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Applicability Condition-10 (Sr. No. 10 of methodology): If solid biomass


fuel (e.g. briquette) is used, it shall be demonstrated that it has been
produced using solely renewable biomass and all project or leakage
emissions associated with its production shall be taken into account in the
emission reduction calculation.

The proposed CDM project activity uses rice husk (loose renewable
biomass) as a fuel in the boiler of the cogeneration project activity.
Thus, the applicability condition is not relevant to the proposed CDM
project activity.

Applicability Condition-11 (Sr. No. 11 of methodology): Where the project


participant is not the producer of the processed solid biomass fuel, the
project participant and the producer are bound by a contract that shall
enable the project participant to monitor the source of the renewable
biomass to account for any emissions associated with solid biomass fuel
production. Such a contract shall also ensure that there is no double-
counting of emission reductions.

As explained above in applicability condition 10, the proposed CDM


project activity does not use solid biomass fuel and hence this
condition is not relevant to the proposed CDM project activity.

Applicability Condition-12 (Sr. No. 12 of methodology): If electricity and/or


steam/heat produced by the project activity is delivered to a third party
i.e. another facility or facilities within the project boundary, a contract
between the supplier and consumer(s) of the energy will have to be
entered into that ensures there is no double-counting of emission
reductions.

The project activity is a captive co-generation power plant. The


electricity and thermal energy generated from the project activity
will be utilized within the manufacturing facility (spinning and Terry
Towel Units) of the project participant in the same premises.
However, as explained in the applicability condition no. 3 above, the
validation team observed during site visit that project participant has
taken approval from the PEDA to enter into Power Purchase
Agreement (PPA) with the state electricity utility and raised
clarification request CL-5 for further clarification on the same with
respect to this applicability condition. The project participant
provided the response that though approval was obtained from the
PEDA, due to captive electricity requirements of the manufacturing
facility, the PP has not entered into any power purchase agreement
and provided an undertaking that no power sale has been taking
place to any external party. In order to cross-check the statement of
the project participant, the validation team reviewed the annual
report of the project participant for the year 2010-11 (Ref /8/), which

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does not specify any revenue realization from the sale of the power
to the grid or any other entity. Therefore, the validation team
confirms that both thermal and electrical energy are being
consumed by the manufacturing facility of the project participant in
the same premises and there is no risk of double counting of the
emission reductions. Hence, this condition is not applicable.

Applicability Condition-13 (Sr. No. 13 of methodology): If the project


activity recovers and utilizes biogas for power/heat production and applies
this methodology on a stand alone basis i.e. without using a Type III
component of a SSC methodology, any incremental emissions occurring
due to the implementation of the project activity (e.g. physical leakage of
the anaerobic digester, emissions due to inefficiency of the flaring), shall
be taken into account either as project or leakage emissions.

As described in above applicability conditions, the proposed CDM


project activity is co-generation project which uses renewable
biomass (rice husk) as a fuel in the boiler for the thermal and
electrical energy generation. There is neither recovery nor
utilization of biogas for heat production. This applicability condition
is not relevant to the proposed CDM project activity.

Applicability Condition-14 (Sr. No. 14 of methodology): Charcoal based


biomass energy generation project activities are eligible to apply the
methodology only if the charcoal is produced from renewable biomass
sources provided: (a) Charcoal is produced in kilns equipped with
methane recovery and destruction facility; or (b) If charcoal is produced in
kilns not equipped with a methane recovery and destruction facility,
methane emissions from the production of charcoal shall be considered.
These emissions shall be calculated as per the procedures defined in the
approved methodology AMS-III.K. Alternatively, conservative emission
factor values from peer reviewed literature or from a registered CDM
project activity can be used, provided that it can be demonstrated that the
parameters from these are comparable e.g. source of biomass,
characteristics of biomass such as moisture, carbon content, type of kiln,
operating conditions such as ambient temperature.

The proposed CDM project activity is co-generation project which


uses renewable biomass (rice husk) as a fuel in the boiler for the
thermal and electrical energy generation. Thus, there is no charcoal
used for energy generation. Hence, this applicability condition is not
relevant to the proposed CDM project activity.

The validation team, based on the above assessment of each of the


applicability condition of the applied baseline and monitoring methodology
AMS-I.C. version 19, hereby confirm that the selected baseline and
monitoring methodology AMS I C, version 19 (Ref B/5/), Tool to calculate

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project or leakage CO 2 emissions from fossil fuel combustion, version 2


(Ref B/10/) and Tool to calculate baseline, project and/or leakage
emissions from electricity consumption, version 1 (Ref B/9/) is previously
approved by the CDM Executive Board, and is applicable to the project
activity, which, complies with all the relevant applicability conditions
therein.

The DOE hereby confirms that, as a result of the implementation of the


proposed CDM project activity, there are no greenhouse gas emissions
occurring within the proposed CDM project activity boundary, which are
expected to contribute more than 1% of the overall expected average
annual emissions reductions, which are not addressed by the applied
methodology.

3.6.2 Project boundary (80)


The spatial extent of the project boundary has been assessed through the
description provided in the web hosted PDD (Ref /1/), the project
equipments generating thermal and electrical energy located at project
site i.e. Co-generation plant boiler, TG set and the manufacturing facility
of project participant consuming thermal and electrical energy generated
by the project activity. The project boundary also includes the processes
and equipments that are affected by the project activity. The spatial
extent of the project activity boundary therefore also includes the
renewable biomass (rice husk) storage yard or fossil fuel storage yard and
the spinning and terry towel manufacturing facilities of the SEL
manufacturing Company Limited (the project participant). The green
house gas considered in both baseline and project scenario is Carbon
Dioxide i.e. CO 2 . The validation team hereby confirms that the GHG
considered is appropriate to the baseline and project scenario as both the
scenario include use of fossil fuel and there is no other GHG involved.

The validation team observed during site visit that fossil fuels may be
used in the project activity boiler and hence raised corrective action
request CAR-20 as the web-hosted PDD was only specifying the project
boundary with respect to the renewable biomass fuel. Further the web-
hosted PDD also specify the baseline boundary which has been selected
as a coal based co-generation plant. However, since project participant
had not discussed pre-project scenario clearly in the web-hosted PDD, the
establishment of the baseline boundary in the web-hosted PDD was not
clear. Further, the project participant had not discussed the pre-project
scenario as one of the plausible alternative scenario in the web-hosted
PDD (please refer to section 3.7.2 report “Identification of alternatives” for
details). Therefore, the validation team raised corrective action request
CAR-21 with respect to identified baseline boundary in section B.3 of the
web-hosted PDD.

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In response to the CAR-20 and CAR-21, the project participant revised


the PDD where the pre-project scenario has been discussed in the details
under section A.2 of the revised PDD. Further, the project participant has
also substantiated that the continuation of the pre-project scenario
(please refer to section 3.7.2 report “Identification of alternatives” for
details) was not the economical option for the project participant. The
baseline boundary selected by the project participant is based on the
baseline identification as carried out by the project participant by means
of the levelised cost analysis which demonstrates that the coal based co-
generation project is the most economical alternative to the project
participant. Hence, based on the project boundary description contained
in the revised PDD and the responses of the project participant, the
validation team confirms that project and baseline boundary identified in
section B.3 of the PDD is in accordance with the applied small scale
methodology AMS-I.C. version 19.

Based on the above assessment, the DOE hereby confirms that the
identified boundary including the co-generation plant generating thermal
energy and electricity and industrial facility consuming energy generated
by the co-generation plant are justified for the project activity. The project
participant has established the baseline as coal-based co-generation
plant and hence, the baseline boundary presented in section B.3 of the
revised PDD is also appropriate and well justified with respect to the
green house gases included in the baseline and project scenario.

3.6.3 Baseline identification (87-88)


The steps taken to assess the requirement given in paragraph 81 and 82
of the VVM are described below:

The validation team assessed the applicability of the baseline scenario in


accordance with the applied methodology AMS-I.C. Version 19. As
reported above in section 3.6.1, the project activity is a new project and in
accordance with the Para 19 of the applicable methodology AMS-I.C.
Version 19

“New Facilities (Greenfield projects) and project activities involving


capacity additions compared to the baseline scenario are only eligible if
they comply with the related and relevant requirements in the General
Guidelines to SSC CDM methodologies.”

The “General Guidelines to SSC CDM methodologies” provides stepwise


approach to identify the most plausible baseline scenario for new
facilities. The validation team has assessed the approach followed by the
project participant to determine the baseline scenario for the project
activity. The same has been discussed below:

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Step 1 – Identify various alternatives available to the project


proponent that deliver comparable level of service including the
proposed project activity undertaken without being registered as a
CDM project activity.

Since the project activity involves simultaneous production of both heat


and electricity i.e. co-generation, the methodology AMS I.C, version 19
prescribes the following baseline scenarios in its para 19 (a) to 19 (i):

Plausible baseline scenario Yes / No Justification for


selection/rejection of the
plausible baseline scenario
(a) Electricity is imported from Yes The project participant took
a grid and thermal energy the investment decision to
(steam/heat) is produced implement the project activity
using fossil fuel in Feb. 2008 (Ref /13/). Prior
to the investment decision
date, the project participant
was purchasing the electricity
from Punjab State Electricity
Board (PSEB). There was no
thermal energy requirement at
the project site prior to the
investment decision date (as
only spinning units were
commissioned before
investment decision date).
However, this alternative has
been considered as a
plausible alternative as the
project participant may
purchase additional electricity
from the state electricity board
and may also install a low
pressure fossil fuel based
boiler to meet the thermal
energy requirements arising
from the capacity expansion of
the manufacturing facility
(Terry Towel Units)
(b) Electricity is produced in No The project participant took
an on-site captive power plant the investment decision to
using fossil (with a possibility implement the project activity
of export to the grid) and in Feb. 2008 (Ref /13/). Prior
thermal energy (steam/heat) to the investment decision
is produced using fossil fuel date, the project participant
was purchasing the electricity

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from Punjab State Electricity


Board (PSEB) and there was
no existing captive power
plant or captive co-generation
plant at the project site.

Hence, for a new facility, this


scenario is not considered as
a plausible baseline
alternative as separate
generation of steam and
electricity is an inefficient
option compared to the
cogeneration systems. The
efficiency of the co-generation
plant can reach up to 90% or
even more 2 through the
utilization of the heat which is
very high as compared to the
segregated systems for
electricity and thermal energy
(steam).

Based on the above


justification, the scenario is
not considered as a plausible
baseline alternative as it does
not reflect the scenario that
would have happened in the
absence of the project
activity.
(c) A combination of (a) and No Since option (b) above has
(b) been ruled out hence the
combination has also not been
considered as a plausible
baseline alternative. Based on
the above justification, the
scenario is not considered as
a plausible baseline
alternative as it does not
reflect the scenario that would
have happened in the absence
of the project activity.

http://www.energymanagertraining.com/announcements/issue25/winners_papers_Issue25/11_Suresh
Kolamala.pdf

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(d) Electricity and thermal Yes This scenario can be


energy (steam/heat) are considered as a plausible
produced in a cogeneration baseline alternative as the
unit using fossil fuel (with a project activity itself is a
possibility of export of renewable biomass based co-
electricity to a grid/other generation project. Thus, it is
facilities and/or thermal also plausible to install a
energy to other facilities) similar capacity fossil fuel
(coal) based co-generation
system.

The project participant has


considered the same option
and coal based co-generation
generation unit has been
considered for the further
analysis. However, since the
new biomass based co-
generation project (the project
activity) of the project
participant has been
envisaged for captive use
only, the plausible alternative
to be considered is “Electricity
and thermal energy
(steam/heat) are produced in
a cogeneration unit using
fossil fuel (coal 3) without
possibility to export the
electricity and thermal energy
to any external facility”
(e) Electricity is imported from Yes The project participant took
a grid and/or produced in an the investment decision to
on-site captive power plant implement the project activity
using fossil fuels (with a in Feb. 2008 (Ref /13/). Prior
possibility of export to the to the investment decision
grid); steam/heat is produced date, the project participant
from biomass was purchasing the electricity
from Punjab State Electricity

3
Th e l a t e s t p u b l i s h e d d a t a b a s e o f t h e C E A ( C e n t r a l E l e c t r i c i t y A u t h o r i t y , G o v e r n m e n t o f I n d i a )
s t a t e s t h a t t h e p o we r g e n e r a t i o n c a p a c i t y u s i n g c o a l i n t h e h o s t c o u n t r y i s 5 6 . 8 % a s o n
3 1 / 0 3 / 2 0 1 1 ( http://www.cea.nic.in/reports/planning/cdm_co2/user_guide_ver7.pdf) m a k i n g i t m o s t p r e f e r r e d
f o s s i l f u e l i n I n d i a . Th e g a s b a s e d p o we r g e n e r a t i o n c a p a c i t y r e m a i n s s e c o n d l a r g e s t a f t e r
c o a l a s 9 . 7 % o f t h e t o t a l g e n e r a t i o n c a p a c i t y a s o n 3 1 / 0 3 / 2 0 1 1 . H o we v e r , g a s p i p e l i n e i s
n o t a v a i l a b i l i t y i n t h e r e g i o n o f t h e p r o j e c t a c t i v i t y . Th u s , v a l i d a t i o n t e a m c o n f i r m s t h a t i n
s e l e c t i o n o f t h e f o s s i l fu e l s , m o s t p l a u s i b l e f ue l s o u r c e i s c o a l a n d t h e s a m e h a s b e e n
c o n s i d e r e d f o r t h e f o s s i l f u e l b a s e d c o - g e n e r a t i o n a s we l l a s t h e r m a l e n e r g y g e n e r a t i o n
alternatives.

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Board (PSEB) and there was


no existing captive power
plant or captive co-generation
plant at the project site.
Hence, this alternative seems
applicable in following form:
“Electricity is imported from a
grid and steam/heat is
produced from biomass” as
the project participant may
continue purchasing the
electricity from the grid (as it
was the case in the pre-
project scenario) and may
have installed a renewable
biomass based low pressure
boiler for thermal energy
requirements. Thus, this
alternative has been
considered for further
analysis.
(f) Electricity is produced in No The project participant took
an on-site captive power plant the investment decision to
using biomass (with a implement the project activity
possibility of export to a grid) in Feb. 2008 (Ref /13/). Prior
and/or imported from a grid; to the investment decision
steam/heat is produced using date, the project participant
fossil fuel was purchasing the electricity
from Punjab State Electricity
Board (PSEB) and there was
no existing captive power
plant or captive co-generation
plant at the project site.

Further, the alternative (f) as


“Electricity is imported from a
grid and steam/heat is
produced using f ossil fuel”
has been assessed by the
validation team. As the project
participant may continue
purchasing the electricity from
the grid (as it was the case in
the pre-project scenario) and
may have installed a fossil
fuel (coal) based low pressure
boiler for thermal energy

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requirements, this alternative


can appropriately be
considered for the
identification of the baseline
scenario. However, with the
above consideration, scenario
(f) becomes exactly identical
to alternative (a) as described
above in the same table.
Since alternative (a) has
already been considered as a
plausible alternative, scenario
(f) has not been considered
for the further analysis.
(g) Electricity and thermal No This scenario is not applicable
energy (steam/heat) are to the project activity as the
produced in a biomass fired project participant has
cogeneration unit (without a installed the new renewable
possibility of export of biomass based co-generation
electricity either to a grid or to unit to meet the requirements
other facilities and without a of the adjoining manufacturing
possibility of export of thermal facility (Spinning and Terry
energy to other facilities). towel units). The project
This scenario applies to a participant has also provided
project activity that installs a an undertaking for the same
new grid connected biomass stating that electricity will not
cogeneration system that be sold to any external party
produces surplus electricity from the project activity (Ref
and this surplus electricity is /11/).
exported to a grid. The
baseline scenario is that the The project activity has been
electricity would otherwise commissioned during the
have been generated by the course of validation. The
operation of grid-connected validation team has also
power plants and by the reviewed the annual report of
addition of new generation the company for the financial
sources to the grid year 2010-11 and confirms
that project participant has not
sold electricity to any external
party (Ref /8/).

Hence, the validation team


confirms that this alternative
scenario is not applicable and
has not been considered
further.
(h) Electricity and/or thermal No The project participant has

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energy produced in a co-fired already considered the


system following two plausible
alternatives for co-generation
system:
 Electricity and thermal
energy (steam/heat) are
produced in a
cogeneration unit using
fossil fuel (coal) without
possibility to export the
electricity and thermal
energy to any external
facility

 Electricity is produced in
renewable biomass (rice
husk) fired cogeneration
unit without possibility to
export the electricity and
thermal energy to any
external facility

The validation team confirms


that unit cost of energy
generation from co-firing (any
ratio of coal to rice husk)
system (in case of the
cogeneration unit) will always
fall between the above two
alternatives and at least one
of the above two options
reported will be more
economical. Hence, it can
never be the baseline
scenario.

For stand alone co-firing units


(thermal energy generated
separately and electrical
energy generated separately),
the same is not a plausible
scenario as installation of the
cogeneration plant is more
efficient than stand alone
power plant and steam
generation plant.

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Hence, in both the scenarios,


this alternative is not a
plausible baseline alternative.
(i) Electricity is imported from Yes In the pre-project scenario,
a grid and/or produced in a the project participant was
biomass fired cogeneration purchasing the electricity from
unit (without a possibility of Punjab State Electricity Board
export of electricity either to (PSEB) and there was no
the grid or to other facilities); existing captive power plant or
steam/heat is produced in a captive co-generation plant at
biomass fired cogeneration the project site. The new
unit and/or a biomass fired biomass based co-generation
boiler (without a possibility of project being installed by the
export of thermal energy to project participant is declared
other facilities). This scenario for captive use only (Ref /11/)
applies to a project activity and will supply the electricity
that installs a new biomass and thermal energy (steam) to
cogeneration system that the adjoining manufacturing
displaces electricity which facility of the project
otherwise would have been participant. The same has
imported from a grid. also been verified from the
annual report of the company
(Ref /8/). Thus, the validation
team confirms that the
scenario “Electricity is
produced in a biomass fired
cogeneration unit without
possibility to export the
electricity and thermal energy
to any external facility” is the
project activity scenario and
considered as a plausible
alternative for further
analysis.

Step 2 – List the alternatives identified per step 1 in compliance with


the local regulations (if any of the identified baseline is not in
compliance with the local regulations, then exclude the same from
further consideration).

 Electricity is imported from a grid and thermal energy (steam/heat)


is produced using fossil fuel (coal) – Alternative (a) as per Para 19
of the methodology

 Electricity and thermal energy (steam/heat) are produced in a


cogeneration unit using fossil fuel (coal) without possibility to export

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the electricity and thermal energy to any external facility –


Alternative (d) as per Para 19 of the methodology

 Electricity is imported from a grid and steam/heat is produced from


biomass – Alternative (e) as per Para 19 of the methodology

 Electricity and thermal energy is produced in a biomass fired


cogeneration unit without possibility to export the electricity and
thermal energy to any external facility – Alternative (i) as per Para
19 of the methodology

The validation team confirms that above-mentioned alternative scenarios


are in compliance with the local national and state regulations and
considered them for the further analysis.

Step 3 – Eliminate and rank the alternatives identified in Step 2 taking


into account barrier tests specified in Attachment A to Appendix B of
simplified modalities and procedures of SSC CDM project activities.

The project participant has used an investment analysis method to rank


the plausible baseline alternatives in step 1 and 2. The validation of the
investment analysis including appropriateness and correctness of the
Investment comparison analysis has been described in section 3.7.3 of
this report later. The investment comparison analysis has been used in
accordance with Attachment A to Appendix B of Simplified modalities and
procedures for small scale CDM project activities (Ref B/8/).

The project participant has carried out the levelised cost analysis to
determine the baseline scenario from the remaining alternatives under
consideration. The details of the validation of the appropriateness of the
alternative scenarios considered by the project participant have been
provided in section 3.7.2 of the validation report below. The alternatives
for which levelised cost analysis has been carried out and the cost of the
levelised cost of energy generation for the alternative scenarios are as
follows:

Alternative The alternative Levelised Ranking of


as per scenarios for the Cost of the
methodology project activity energy alternatives
production based on the
(INR results of the
Million/TJ) Levelised
cost
a Electricity is imported 3.7205 The Third
from a grid and thermal preferred
energy (steam/heat) is option as the

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produced using fossil levelised cost


fuel (coal) of energy is
least
d Electricity and thermal 2.5996 The Most
energy (steam/heat) are preferred
produced in a option as the
cogeneration unit using levelised cost
fossil fuel (coal) without of energy is
possibility to export the least
electricity and thermal
energy to any external
facility
e Electricity is imported 3.8251 The least
from a grid and preferred
steam/heat is produced option as the
from biomass levelised cost
of energy is
least
i Electricity and thermal 2.9285 The Second
energy is produced in a preferred
biomass fired option as the
cogeneration unit levelised cost
without possibility to of energy is
export the electricity least
and thermal energy to
any external facility

Step 4 – If only one alternative remains that is:

• Not the proposed project activity undertaken without being


registered as a CDM project activity; and
• It corresponds to one of the baseline scenarios provided in the
methodology; then the project activity is eligible under the
methodology.

It can be seen from above that the most plausible baseline option
identified after step 3 is Option (b) above viz; Electricity and thermal
energy (steam/heat) are produced in a cogeneration unit using fossil fuel.

This alternative is not the proposed project activity undertaken without


being registered as a CDM project activity; and also corresponds to one of
the baseline scenarios provided in Para 19 of the applied the methodology
viz; option (d). Hence, the project activity is eligible under the baseline
and monitoring methodology AMS I C, version 19.

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Based on the above mentioned results of Levelised Cost Analysis, the


validation team hereby confirms that the coal based co-generation
alternative is the most economical and attractive scenario for the project
participant reasonably representing what would have occurred in the
absence of the proposed CDM project activity and hence, it is the
baseline scenario. The validation team has also confirmed this fact from
the web site of Central Electricity Authority (CEA). CEA is a government
entity operating under the Ministry of Power, Government of India. CEA is
responsible for publishing such data in the host country. The latest
published database of the CEA 4 clearly states that the power generation
using coal in the host country is 56.8% as on 31/03/2011. Thus, it is well
established fact that coal is primary and most prevalent fuel in the host
country (India) for the public and private sector power generating
companies. In addition, the details of the appropriateness of the baseline
validation have been discussed below.

The validation team conducted a site visit of the project activity on 26 t h


and 27 t h Aug. 2010. The validation team observed that the project activity
has been implemented adjoining to the manufacturing facility in the same
premises of the project participant at Rahon, district Nawansahar, Punjab,
India. The project participant is manufacturer of the knitted fabrics, yarns,
terry towels and readymade garments. The project activity is renewable
biomass based co-generation power plant for the captive consumption of
power and steam. The manufacturing facility at Rahon is an expansion
project of the project participant where continuous expansion of the
manufacturing facility took place (Ref /14/) through addition of the new
spinning units and terry towel units (Ref /14/). The spinning units
commissioned in the pre-project scenario have electrical energy
requirements and the project participant was purchasing the electricit y
from the state electricity utility with standby captive DG set arrangements
(as confirmed during site visit) and there was no captive power plant
(except DG sets) or co-generation plant at the project site in the pre-
project scenario. In year 2008, the project participant commissioned it’s
first terry towel unit (Unit I) at Rahon and another terry towel unit (Unit II)
was commissioned in year 2010 (Ref /15/). The Terry towel units have
both thermal as well as electrical energy requirements. Above-mentioned
manufacturing capacity expansion programme has been verified by the
validation team by means of the on-site visit, review of the commissioning
certificates provided by the project participant (Ref /15/) and review of the
website of the company i.e. SEL Manufacturing Co. Ltd. (Ref /14/).

Based on the above-description, it is clear that there has been a phase-


wise expansion programme of the manufacturing facility. From year 2008
onwards, the manufacturing facilities also required thermal energy due to
commissioning of the terry towel units. In order to meet the thermal

4
http://www.cea.nic.in/reports/planning/cdm_co2/user_guide_ver7.pdf

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energy requirements arising from the terry towel unit I (year 2008 onwards
until the co-generation plant was commissioned), the project participant
was meeting the thermal energy requirements of the project from fossil
fuel fired thermic fluid heater of (1.5 million kcal/hour) and a low
pressure boiler having capacity of 5TPH . However, the electrical
requirements until the commissioning of the project activity were met by
the grid electricity import and the captive DG sets (used as standby in
emergency situations).

The proposed CDM project activity (the co-generation plant) was


commissioned on 10/01/2010 (Ref /12/), which is before the
commissioning of the second terry towel unit (Unit II) commissioned on
26/06/2010. However, the board decision to implement the co-generation
power plant took place on 01/02/2008 (Ref /13/), and the same is even
before the commissioning of the first terry towel unit (Unit I) (Ref /17/).
The validation team has also reviewed the original board register of the
SEL Manufacturing Company at their registered office located at
Ludhiana, Punjab, India to confirm the investment decision date of the co-
generation project activity took place on 01/02/2008. Hence, it can be
confirmed that the decision to set up the co-generation project (project
activity) was taken considering the capacity expansion of the
manufacturing facility of the project participant and before the
commissioning of the terry towel units. Hence, at the time of investment
decision, there were only electrical requirements of the manufacturing
facility and thermal energy requirements were expected to arise due to
future expansion programmes of the project participant. Hence, the
energy requirements of the pre-project scenario and the project scenario
are significantly different.

The desk review of the web-hosted PDD does not provide information on
the pre-project scenario and the capacity expansion programme of the
project participant which has resulted into additional requirement of the
thermal as well as electrical energy. Hence, the validation team raised
corrective action request CAR-22. In response to CAR-22, the project
participant described the phase-wise commissioning of the manufacturing
facility (spinning and terry towel units) in the revised PDD. The project
participant also included continuation of the current practice as one of the
alternative in section B.4 of the PDD (i.e. electricity requirements met
from the grid and additional low pressure boiler installation for the
increased thermal energy requirements due to commissioning of the terry
towel units). The project participant also provided the commissioning
certificates for the justification of the phase-wise commissioning of the
manufacturing facility (Ref /15, 16, 17/). The phase-wise commissioning of
the manufacturing facility was established by the project participant in the
section A.2 of the revised PDD. In addition, the validation team confirms
that due to the fact that energy requirements of the manufacturing facility
(which was under continuous expansion during the entire project

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implementation) significantly vary prior to the investment decision and


after the investment decision date of the project activity (as discussed
above) and, the co-generation plant (project activity) being a new project,
the baseline scenario identified by the project activity is in accordance
with the applicable guidance provided in the General Guidance for small
scale methodologies and the applied methodology AMS-I.C (as discussed
above in this section), CAR 22 was closed by the validation team.

The validation team also noticed that in section B.4 of the web-hosted
PDD, the project participant provided the levelised cost of the various
alternatives in INR million/year and not in terms of the cost of energy
production/unit of the output. Besides, the levelised cost was not
computed for the entire technical lifetime of the project activity. Hence,
the validation team raised corrective action request CAR-23. In response
to the CAR-23, the project participant revised the description in section
B.4 of the PDD and also submitted the revised Levelised Cost Analysis
(hereafter referred as LCA) spreadsheets where the levelised cost energy
has been reported in Million INR/Terra Joule of the energy production for
the alternatives considered. Further, the revised LCA spreadsheet
submitted by the project participant considers the entire technical lifetime
of the project which is 20 years (as per the manufacturer’s specification of
the boiler and turbine). Hence, the validation team closed CAR-23.

It was further observed by the validation team that LCA spreadsheets


submitted by the project participant were though specif ying the source of
the input values, the references provided were not complete and the
supporting documents were not submitted. In this regard, the validation
team raised corrective action request CAR-28. The CAR-28 was closed
after the validation team received complete information on the input
sources in the LCA spreadsheet (the details of the validation of the input
values in the LCA spreadsheet has been described in section 3.7 later in
this validation report).

The project participant also considered petcoke as a fuel under the fossil
fuel based alternatives in web-hosted PDD and eliminated this option (use
of petcoke as a fuel) in the we-hosted PDD itself due to higher energy
cost of petcoke as compared to other fossil fuel based alternative (i.e.
sub-bituminous coal). However, the validation team observed that that
input assumptions considered for the cost and NCV of petcoke and coal
were not specified under section B.4 of the web-hosted PDD. Hence, the
validation team raised corrective action request CAR-4 with respect to the
same. In response to CAR-4, the project participant provided the sources
of input assumptions for the cost and NCV of the coal and petcoke in the
revised PDD being submitted for the registration. The validation team
confirms that the calorific value of the petcoke was considered is based
on the IPCC default value. The calorific value of the coal has been
considered from third party lab test report (Ref /30/) available at the time

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of investment decision. Similarly, the cost of petcoke was considered


based quotations submitted by the fuel suppliers (Ref /40/) and the same
was crosschecked with the actual invoices of the petcoke bought by the
project participant (Ref /8/). The validation of cost of coal has already
been provided under section 3.7.2 of the validation report. Hence, CAR-4
was closed by the validation team.

The project activity was web-hosted on UNFCCC web site for global
stakeholders’ comments with version no. 17 of the applied methodology
AMS-I.C. The version 17 of the applied methodology AMS-I.C. (Ref B/5/)
in Para 13 specify that “for calculating the emission factor, reliable local
or national data shall be used. IPCC default values shall be used only
when country or project specific data are not available or demonstrably
difficult to obtain”. The validation team observed that project participant
has considered IPCC 2006 default emission factor of the coal for the
emission reduction calculations. Hence, based on the description
contained in Para 13 of the AMS-I.C. version 17, the validation team
raised clarification request CL-6.

The methodology AMS-I.C. was revised two times during the course of the
validation and version 17 of the methodology expired. The project
participant applied the latest available approved version 19 of the
methodology AMS-I.C. and responded to CL-6 that the methodology
revision has taken place and in the revised methodology, IPCC default
emission factors have been specified as an alternative approach. The
validation team also reviewed the revised the methodology and confirms
that Para 16 of AMS I C, version 19 (which was Para 13 in version 17)
has been revised and the statement “for calculating the emission factor,
reliable local or national data shall be used. IPCC default values shall be
used only when country or project specific data are not available or
demonstrably difficult to obtain” has been deleted. Further, the equations
for the baseline emission calculations specif y using IPCC default emission
factors as an alternative option. Therefore, the validation team accepted
the response of the project participant and closed CL-6.

Each of the input values’ and assumptions considered by the project


participant in the levelised cost of energy generation has been validated
and cross-checked by the validation team with respect to the investment
decision timing. Further, the actual project cost and actual cost of the
energy generation has also been verified by the validation team. The
details of the validation of the input values’ and assumptions of the
levelised cost analysis have been provided in the section 3.7 of the
validation report below. The validation of the appropriateness of the
selected alternatives has been explained above. .

The validation team further confirms that the project participant has also
included the description on national policies and circumstances relevant

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to the baseline in accordance with the PDD completeness guidance


guidelines (Ref B/4/) and the sub-sequent amendments. The validation
team confirms that description presented on national policies and
circumstances relevant to the baseline in the revised PDD version 5
represent the correct scenario at the time of investment decision of the
project activity.

Based on the above assessment, the DOE hereby confirms that:


(a) All the assumptions and data used by the project participants and
listed in the PDD, including their references and sources, are correct;

(b) All documentation used is relevant for establishing the baseline


scenario and correctly quoted and interpreted in the revised PDD
version 5;

(c) Assumptions and data used in the identification of the baseline


scenario are justified appropriately, supported by evidence and can
be deemed reasonable;

(d) The project participant has taken into account prevailing national
and/or sectoral policies relevant to the baseline.

(e) The approved baseline methodology has been correctly applied to


identif y the most reasonable baseline scenario and the identified
baseline scenario reasonably represents what would occur in the
absence of the proposed CDM project activity.

3.6.4 Algorithms and/or formulae used to determine emission


reductions (92-93)
The steps taken to assess the requirements outlined in paragraph 89 the
VVM, version 1.2 (Ref B/1/) are described below:

The project participant has used the algorithms and formulae in


accordance with the applied baseline and monitoring methodology (Ref
B/5/), the “Tool to calculate baseline, project and/or leakage emissions
from electricity consumption” (Ref B/9/) and the “Too to calculate project
or leakage emissions from fossil fuel consumption” (Ref B/10/). The
detailed algorithms and formulae used in calculations of baseline
emissions are explained in section B.6.1 and applied in B.6.3 of the
revised PDD, version 5 for emission reduction estimation. The validation
team confirms that the formulae have been applied correctly in line with
the applied baseline and monitoring methodology AMS I C, Version 19.

Baseline emissions:
In accordance with the requirement of applied methodology AMS I C,
Version 19, project participant has calculated the baseline emissions by

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following Paragraph 27 of applied methodology i.e. For electricity and


thermal energy (steam/heat) produced in a baseline cogeneration unit,
which is in accordance with the identified baseline for the project activity
as per Para 19 (d) of the methodology. However, the web-hosted PDD
was not clear with respect to the approach considered for the baseline
identification and did not provided information on the pre-project scenario.

The validation team observed during site visit (conducted on 26 t h and 27 t h


August 2010) that fossil fuel based thermic fluid heater of 1.5 million
kcal/hour and a 5 TPH low pressure boiler were existing within the project
premises. The validation team interviewed the team of project participant
at project plant and understood that the above-equipments were supplyin g
the thermal energy to the manufacturing facilities prior to the
implementation of the project activity and electrical energy was purchased
from the state grid (Punjab State Electricity Board). Hence, the validation
team was of an opinion that baseline scenario as identified by the project
participant in the web-hosted PDD (10 MW coal based co-generation unit)
may instead be the pre-project scenario which is Electricity is imported
from a grid and thermal energy (steam/heat) is produced using fossil fuel.
Hence, the validation team also raised corrective action request CAR-29,
CAR-30 and clarification request CL-8 which were particularly raised with
respect to the baseline emission calculation approach as per the scenario
“Electricity is imported from a grid and thermal energy (steam/heat) is
produced using fossil fuel”. However, based on the review of the
responses provided by the project participant (explained in detail above
under section B.6.3 “Baseline Identification”), the validation team confirms
that pre-project scenario can not be considered as a baseline scenario as,
at the time of investment decision, there were only electrical requirements
of the manufacturing facility and thermal energy requirements were
expected to arise due to future expansion programmes of the project
participant (phase-wise commissioning of the terry towel and spinning
units). Hence, the pre-project scenario can not be considered as a
baseline scenario as the energy requirements of the pre-project scenario
and the project scenario are significantly different. Hence, the validation
team accepted the calculation approach followed by the project participant
as per Paragraph 27 of applied methodology i.e. for electricity and thermal
energy (steam/heat) produced in a baseline cogeneration unit.

Following parameters have been considered by the project participant for


the baseline emission calculations

Parameter Value Source of Validation team’s justification


Information
used by the
validation to
verify
Electricity Feasibility The validation team has referred

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generation 10MW report provided to the techno-commercial


capacity of by the project quotation (Ref /7/) provided by
the co- participant (Ref the technology supplier and also
generation /18/) validated the same from the
plant - name plate specifications of the
Generator during validation site
visit and the purchase order
(Ref /5/). Hence, the value is
correct and appropriate.
Plant 330 Feasibility The validation team has
Operation days/y report provided reviewed the feasibility report
ear by the project prepared and submitted by M/s.
participant (Ref ACE Engineers and Consultants
/18/) (Ref /18/). This is a
conservative assumption for the
calculation of the baseline
emissions. Further, the project
participant has conducted the
levelised cost analysis keeping
330 plant operational days
consistent in all the alternatives
considered for LCA. The
numbers of operating days
considered are normative for
such plants considering
scheduled maintenance of the
plant. Hence, the same has
been accepted by the validation
team.
Plant 24 Feasibility The validation team has
Operation hours/ report provided reviewed the feasibility report
day by the project prepared and submitted by M/s.
participant (Ref ACE Engineers and Consultants
/18/) (Ref /18/). The value is cross
checked with DPR and found to
be consistent. Hence, this value
is appropriate and accepted by
the validation team.
Auxiliary 10% Tariff order The auxiliary electricity
electricity summary consumption of 10% has been
consumptio published by considered by the project
n Indian participant based on the tariff
Renewable order summary report published
Energy by IREDA (Ref /19/) for the
Development various states tariff orders
Agency Limited available and applicable at the

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(hereafter time of investment decision. The


referred as validation team referred to the
IREDA) (Ref detailed tariff order for the
/19/) renewable energy published by
the Central Electricity
Regulatory Commission (CERC)
in Dec. 2009 (Ref /20/) which
provides the specific approved
assumptions by the commission
for the co-generation power
plants in Punjab state. The
CERC tariff orders also refer
10% auxiliary consumption for
co-generation power plants.
Hence, the same has been
accepted by the validation team.
Net 71280 This is The calculated value is based
electrical (GW h/ calculated on the rated specifications
energy year) value from provided by the technology
output from gross supplier. The efficiency of the
the con- generation co-generation plant has been
generation (rated output of conservatively considered by
plant the generator – the project participant as 100%,
auxiliary which is in accordance with
consumption) applied baseline and monitoring
methodology AMS I C, version
19. Hence, the same has been
accepted by the validation team.
Quantity of 19.7 Feasibility The quantity of the steam
steam Tonne report provided supplied to the process has
supplied to s /hour by the project been sourced from a feasibility
the process participant (Ref report prepared by ACE
by the co- /18/) Engineers and Consultants in
generation January 2008. The validation
plant team has also cross-checked
the value with the technical
specifications of the turbine
(Ref /5/). The rated steam
extraction parameters of the
turbine also corroborates with
the value mentioned in the
feasibility report. Hence, the
validation team accepted 19.7
TPH value of average quantity
of the steam supplied to the
process.

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Pressure of 9.4 Feasibility The pressure of the steam


the steam ATA report provided supplied to the process has
supplied to by the project been sourced from a feasibility
the process participant (Ref report prepared by ACE
/18/) Engineers and Consultants in
January 2008. The validation
team has also cross-checked
the value with the technical
specifications of the turbine
(Ref /5/). The rated steam
extraction parameters of the
turbine also corroborates with
the value of pressure mentioned
in the feasibility report. Hence,
the validation team accepted the
9.4 ATA value for the pressure
of steam supplied to the
process.
Temperatur 190ºC Feasibility The temperature of the steam
e of the report provided supplied to the process has
steam by the project been sourced from a feasibility
supplied to participant (Ref report prepared by ACE
the process /18/) Engineers and Consultants in
January 2008. The validation
team cross-checked the value
with the technical specifications
of the turbine and observed that
as per the rated steam
extraction parameters of the
turbine the value of the
extraction steam temperature is
259.5 ºC. The validation team
raised CAR-4 which also covers
the same. The project
participant responded that
though the extraction
temperature from the turbine is
259.5 ºC, due to the process
requirements, the steam
temperature will be reduced to
190 ºC through de-superheating
station. The project participant
has computed the thermal
energy output for baseline
emissions computation based on
the 190 ºC steam temperature.
The same is conservative and

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hence accepted by the


validation team. The validation
team further confirms that the
extraction steam temperature
has been consistently applied in
the levelised analysis cost also.
The validation team further
confirms that even at the rated
steam temperature of 259.5 ºC,
the results of the levelised cost
analysis remain in the same
order and still coal based co-
generation plant is the most
economical alternative for the
project participant. Hence, the
response of the project
participant and the value of
steam temperature have been
accepted by the validation team.
Temperatur 135ºC Feasibility The temperature of the feed
e of the report provided water supplied to the boiler has
feed water by the project been sourced from a feasibility
participant (Ref report prepared by ACE
/18/) Engineers and Consultants in
January 2008. The validation
team has also cross-checked
the value with the technical
specifications of the boiler (Ref
/4/). The rated feed water
temperature of the boiler also
corroborates with the same.
Hence, the validation team
accepted the 135ºC value for
the temperature of boiler feed
water.
Enthalpy of 2805.8 Calculated This value is based on the
the steam at KJ/kg based on the online steam tables provided by
9.4 ATA and steam table the Spirax Sarco. The validation
190ºC team has also referred to the
website and reproduced the
same value based on the steam
parameters specified above and
found the value of enthalpy
correct. Hence, the same has
been accepted by the validation
team.

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Enthalpy of 567.48 Calculated This value is based on the


the feed KJ/kg based on the online steam tables provided by
water steam table the Spirax Sarco. The validation
team has also referred to the
website and reproduced the
same value based on the feed
water temperature specified
above and found the value of
enthalpy correct. Hence, the
same has been accepted by the
validation team.
The net 349.23 Calculated This is a calculated value based
quantity of TJ/yea value on the above-specified feed
thermal r water and steam specifications.
energy The same value has been
supplied by reproduced by the validation
the project team considering the above-
activity specified parameters and hence
during the accepted by the validation team.
year y
Efficiency of 100% Default This is the most conservative
the co- efficiency value default value of efficiency of the
generation as provided in baseline co-generation plant.
plant the provisions The same has been accepted by
contained in the the validation team as it is
applied suggested by the applied
methodology baseline and monitoring
AMS-I.C. methodology.
Emission 96.1 This is IPCC This is IPCC published default
factor of tCO2/ 2006 default value for the emission factor of
coal TJ emission factor the sub-bituminous coal with net
for sub- calorific value of 18.9TJ/Gg
bituminous (~4514 kcal/kg). The NCV of the
coal. coal considered by the project
participant (based on the lab
lest reports submitted to the
validation team) is 4131kcal/kg
which is within the uncertainty
range of the IPCC reported
default calorific values of the
sub-bituminous coal (11.5 to
26.0 TJ/Gg). Hence, the
emission factor of 96.1 tCO2/TJ
has been accepted by the
validation team.

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Based on the above-mentioned values and the validation approach


followed by the validation team for the each of the input assumptions
considered by the project participant for the baseline emission
computation, the validation team confirms that the baseline emissions
computed ex ante in the PDD by the project participant are appropriate,
conservative and follows the guidance provided by the approved
methodology AMS-I.C. version 19.

Project emissions:
The project activity is a renewable biomass (rice husk) based co-
generation project activity. The project participant has provided ex ante
determination in the latest version of the PDD 5 that 100% renewable
biomass will be used in the project activity.

However, it has also been specified in the PDD that in case, during
exigency, the project activity may use the coal. It was also observed by
the validation team during site visit that the project activity boiler is a
multi-fuel fired boiler. Hence, for the purpose of the estimation of project
emissions and emission reduction, the consumption of fossil fuel (coal) is
considered to be zero.

The project participant has provided the provisions to calculate the project
emissions from fossil fuel consumption in accordance with the tool to
calculate project or leakage CO2 emissions from fossil fuel combustion
(Ref B/10/). Similarly, provisions for the computation of project emissions
from the electricity consumption have been considered in accordance with
the tool to calculate baseline, project and/or leakage emissions from
electricity consumption (Ref B/9/). The optional choices provided in the
tools have been detailed by the project participant in section B.6.1 of the
PDD version 5.

Leakage emissions
In accordance with the applied baseline and monitoring methodology
AMS-I.C., version 19, the leakage needs to be considered in accordance
with Paragraph 47 and 48. The validation team has reviewed and
analyzed the applicability of leakage to the project activity as follows:
Conditions in the Validation team’s observation and
methodology for leakage justification
consideration (AMS-I.C. Ver.
19)

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If the energy generating The project activity is a Greenfield co-


equipment currently being generation project. The project
utilized is transferred from equipments currently being utilized
outside the boundary to the under the project activity (mainly boiler,
project activity, leakage is to be turbine, generators and other BOP 5)
considered (Para 47 of the have been purchased by the project
methodology) participant and have not been
transferred from outside the boundary
to the project activity. The validation
team has confirmed the same by
reviewing the purchase orders (Ref /4/
and /5/) released by the project
participant to M/s Cethar Vessels
Limited for the boiler and M/s Siemens
Limited for the turbine and generator
set. Hence, this condition is not
applicable.
In cases where the The project activity will utilise the rice
collection/processing/transporta husk and collection/processing of the
tion of the biomass residues is biomass outside the project boundary is
outside the project boundary not applicable to the project activity.
CO 2 emissions from the However, the transportation of the
collection/processing biomass residues outside the project
/transportation of biomass boundary will be applicable to the
residues to the project site project activity for the consideration
shall be taken into account as and calculation of the leakage emission
leakage (Para 48 of the in accordance with Para 48.
methodology)
If biomass residues are The project participant has submitted
transported over a distance of the biomass assessment report (Ref
more than 200 kilometers due /12/) prepared by ACE Engineers and
to the implementation of the Consultants and approved by the
project activity then this Punjab Energy Development Agency
leakage source attributed to (PEDA, a Govt. entity). The biomass
transportation shall be assessment report specifies that there
considered, otherwise it can be are surplus biomass residues available
neglected (footnote 18 of Para for the project activity within 50km
48 of the methodology). distance from the project boundary.
Since the biomass assessment study
report has been approved by the PEDA
(local state government authority), the
same has been accepted by the
validation team.

5
BOP; Balance of Plant

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The biomass assessment report (Ref


/12/), confirms that the total availability
of biomass is 13694237 MT/annum
within 50km radius and total
consumption of biomass including the
consumption of proposed CDM project
activity is 7181423MT/annum within
50km radius. Thus, surplus quantity of
biomass available is even more than
25% of the total biomass consumption
within the 50 km. radius. Thus, it can be
said that highly unlikely scenario that
project participant will transport the
biomass for more than 200 kilometer
distance from the project site.

Based on the above assessment of the requirement of applicability and


consideration of leakage emission in accordance with the applied
methodology, the validation team hereby confirms that the leakage is not
applicable to the proposed CDM project activity.

Hence, the estimated annual average of approximately 58,221 tCO 2 e of


emission reduction over the crediting period represents a reasonable
estimation using the assumptions given by the project participant. The
validation team confirms that the estimates of emission reductions can be
replicated using the information provided. It also can be verified from the
spreadsheet (Ref /21/) of emission reduction calculations provided by the
project participant. The validation team confirms that the algorithms are
correctly applied in accordance with the applied methodology AMS-I.C.,
version 19 for calculation of baseline emissions, project emissions,
leakage emissions and hence emission reductions.

Based on the above assessment, the DOE hereby confirms that:

(a) All assumptions and data used by the project participants are listed in
the PDD, including their references and sources are correct;
(b) All documentation used by project participants as the basis for
assumptions and source of data is correctly quoted and interpreted in
the PDD;
(c) All values used in the PDD are considered reasonable in the context
of the proposed CDM project activity;
(d) The baseline methodology has been applied correctly to calculate
project emissions, baseline emissions, leakage emissions and
emission reductions;

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(e) All estimates of the baseline emissions can be replicated using the
data and parameter values provided in the PDD.

3.7 Additionality of a project activity (97)


The proposed CDM project is a small scale project activity as per the
classification of type I small scale projects provided in General
Guidelines to SSC CDM methodologies (Ref B/7/) provided by CDM-EB in
Annex 21 of EB-61. Therefore, in accordance with § 28 of the simplified
modalities and procedures for small-scale CDM project activities, the
additionality of the project activity has been demonstrated using
Attachment A to Appendix B (Ref B/8/) (additionality tool for small scale
project activities) and guidance given vide Annex 5 of EB-62 (Ref B/12/).
As, all requirements specified vide § 28 of the simplified modalities and
procedures are complied with by the project activity, this approach has
been assessed to be appropriate for the additionality assessment for the
proposed CDM project activity.

The steps taken and sources of information used to cross-check the


information contained in the PDD on this matter are described in the
subsequent sections from 3.7.1 to 3.7.5 of this report below.

3.7.1 Prior consideration of the clean development mechanism (104)


The proposed CDM project activity is a biomass based co-generation
project. The board of directors of the project participant took the decision
to invest in the project activity on 1 s t Feb. 2008. The same has been
verified by the validation team by reviewing the original register of
minutes of meeting of the board of directors of the SEL Manufacturing
Company Limited at their registered Office located at Ludhiana, Punjab.
The board has taken the investment decision based on the project
feasibility report prepared by the ACE Engineers and Consultants dated
04/01/2008. Hence, the validation team confirms that the project
feasibility report (Ref /18/) was available to the board at the time of
investment decision. In accordance with the CDM Glossary of terms, the
earliest start date of the project activity is 01/03/2008, which is date of
the first purchase order of the project released for the boiler of the co-
generation plant (Ref /4/). Since, this is the earliest financial commitment
by the project participant towards the implementation of the proposed
CDM project activity, the date of purchase order released for the boiler
was deemed appropriate as project start date by the validation team.
Hence, in accordance with the version 5.0 of the Guidelines on the
demonstration of and assessment of prior consideration of the CDM (Ref
B/15/) published in CDM Executive Board Meeting report 62 (Annex 13),
the project activity is an existing project with start date before 2 n d Aug.
2008 as stated in Para 6 of Annex 13, EB 62.

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As reported above, the starting date of the project activity is 01/03/2008,


which is before 02/08/2008. Hence, in accordance with Para 6 (a) and 6
(b) of the Guidelines of the Demonstration and Assessment of prior
consideration of the CDM i.e. Annex 13 of EB-62, the validation team
reviewed the chronology of the project activity to assess that CDM was a
decisive factor to proceed with the project activity and real and continuing
actions were taken to secure CDM status of the proposed project activity
in parallel with its implementation. The details of assessment of the
validation team have been presented in the Table below:

Chronology of events:
Date Events Evidence verified EB 62, Annex 13
requirements
04/01/2008 Feasibility The validation team Para 6 (a)
report of has reviewed the The project feasibility
the project feasibility study report also refers to
activity report of the project the eligibility of the
prepared activity dated project activity under
by the ACE 04/01/2008 (Ref CDM mechanism. This
Engineers /18/) report was available to
and the Board at the time
Consultants of investment decision
thus making an
awareness of CDM to
the project participant
and consideration of
CDM as a decisive
factor for the
implementation of
proposed CDM project
activity.
01/02/2008 Decision to The project Para 6 (a)
approve the participant has Extracts of the board
10 MW provided the resolution clearly
Biomass Certified true copy specif y that decision to
based co- of the extracts of undertake the project
generation the minutes of the activity has been
project board meeting (Ref carried out considering
activity by /13/). The extracts the CDM benefits to
the Board of the board the project activity.
of Directors meeting provided by The validation team
of the the project has cross-checked the
company. participant were evidence from the
cross-verified by the original Board Meeting
validation team register of the project
during the site visit participant at their
with the Original registered office in

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Board Meeting Ludhiana, Punjab,


register of the India.
project participant
at their registered
office in Ludhiana
and found them
consistent.
Hence, the validation team confirms that the project activity meets the
requirements of Para 6 (a) of the Annex 13 of EB 62 as the project
feasibility report (which was available to the PP at the time of board
decision) and the Board resolution of the company clearly specify that
project activity is eligible to claim the CDM benefits and decision to
undertake the project activity was taken considering CDM benefits
available to the proposed CDM project activity.
Date Events Evidence verified EB 62, Annex 13
requirements
01/03/2008 Placement of The purchase order Para 6 (b)
the purchase released by the This is earliest
order for the project participant financial
AFBC boiler towards Cethar commitment by the
of the project Vessels Limited dated project participant
activity 01/03/2008 (Ref /4/) towards the
implementation of
the project activity
and hence,
considered as the
start date, which is
correct and
appropriate.
07/03/2008 Purchase The purchase order Para 6 (b)
Order for 10 released by the This is second
MW biomass project participant financial
based Turbo- towards Siemens commitment by the
Generator Limited dated project participant
07/03/2008 (Ref /5/) towards
implementation of
the project activity.
15/01/2009 Contract The contractual Para 6 (b)
signed with agreement signed In accordance with
the CDM between the project Para 6 (b) this can
consultant participant and Ernst be considered as
and Young India Pvt. first real action
Ltd. for CDM advisory towards securing
services (Ref /22/) the CDM benefits
parallel to its
implementation by

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the project
participant.
29/10/2009 Meeting with Email correspondence Para 6 (b)
national from National CDM In accordance with
CDM Authority of India Para 6 (b) this can
Authority of regarding the be considered
India intimation of the another real action
regarding meeting and towards securing
host country considering the the CDM benefits
approval of project activity for parallel to its
the project host country approval implementation by
activity (Ref /23/). the project
participant.
16/02/2010 Appointment The contractual Para 6 (b)
of DOE for agreement signed In accordance with
validation of between the project Para 6 (b) this can
the CDM participant and be considered
project Bureau Veritas for another real action
activity CDM validation towards securing
services (Ref /24/) the CDM benefits
parallel to its
implementation by
the project
participant.
10/01/2010 Commissioni Minutes of meeting Para 6 (b)
ng of the took place between The evidence
project representatives of the towards
activity project participant and implementation of
Siemens (Ref /16/), the project activity.
which includes the
commissioning details
and confirmation of
the successful
commissioning of the
project.
19/06/2010 Host Country Letter of approval Para 6 (b)
Approval for issued by the In accordance with
the project Government of India; Para 6 (b) this can
activity Ministry of be considered
Environment and another real action
Forest (Ref /3/) towards
securing the CDM
benefits parallel to
its implementation
by the project
participant.

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Based on the above time lines and its validation, the validation team
confirms that the project activity meets the requirements of Para 6 (a)
and 6 (b) of the Annex 13 of EB 62. Moreover, assessment of the real
and continuing action validated by the validation team (as reported
above) confirms that in accordance with Para 8 (a) of the Annex 13, EB
62, there is a less than two years gap between the documented
evidences since the start date of the proposed CDM project activity till
the start of the validation. Hence, the validation team concludes that
the project activity meets the requirements of prior consideration of the
CDM. The above-specified assessment of the validation team confirms
that CDM benefits were seriously considered by the project participant
at the time of investment decision and during the implementation phase
of the project activity.

3.7.1.1 Historical information on project timeline


The project activity is located within the same premises of the
manufacturing facility of the project participant at Rahon, Punjab. It is part
of a capacity expansion project of the project participant where first
spinning unit was set up in year 2007. The second spinning unit was set
up in year 2008. The spinning units have electrical energy requirements
and the project participant was purchasing the electricity from the state
electricity utility with standby captive DG set arrangements (as confirmed
during site visit). In year 2008, the project participant commissioned its
first terry towel unit (Unit I) at Rahon and another terry towel unit (Unit II)
was also commissioned in year 2010. The Terry towel units have both
thermal as well as electrical energy requirements. Above-mentioned
manufacturing capacity expansion programme has been verified by the
validation team by means of the on-site visit, review of the website of the
project participant (Ref /14/) and commissioning certificates provided by
the project participant (Ref /15, 16 and 17/).

The co-generation project activity implemented by the project participant


is a new project and the same has been commissioned in the year 2010 to
meet the captive thermal and electrical energy requirements of the
manufacturing facility within the same premises. The validation team
further confirms that the implementation of the project activity was not
seized or recommenced and the investment decision timing of the project
activity considered by the project participant (which is date of the board
resolution) is applicable and appropriate.

3.7.2 Identification of alternatives (107)


The project activity is a 10 MW co-generation power plant which supplies
electricity and thermal energy (steam) to the adjoining manufacturing
facility of the project participant. The applied methodology AMS-I.C.
version 19 provides various baseline alternatives for a co-generation
power project. All the baseline alternatives stated in the methodology

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AMS-I.C. version 19 have been discussed in detail following the general


Guidance for small scale CDM project activities version 17 (Ref B/7/)
under section 3.6.3 (baseline identification) of the report. As described
above in section 3.6.3 of this report, the project participant has correctly
applied baseline and monitoring methodology AMS I C, version 19 for the
identification of the alternatives and the Paragraphs 15 (d) of the applied
methodology provides the most plausible baseline scenario for the project
activity.

3.7.3 Investment analysis (114)


The project participant has demonstrated the additionality of the project
activity using the investment analysis, in accordance with Attachment A to
Appendix B (Ref B/8/) of simplified modalities and procedures for SSC
CDM project activities.

The proposed CDM project activity is a captive co-generation project. The


project activity has been envisaged due to expansion of the manufacturing
capacity (terry towel and spinning units) of the project participant, which
will lead to the additional requirements of the thermal and electrical
energy. The project participant carried out the levelised cost analysis to
demonstrate that coal based co-generation unit is the most economical
scenario to the project participant and the proposed CDM project activity
is not the baseline scenario. The validation team reviewed the web-hosted
PDD and observed that the web-hosted PDD does not provide justification
as why levelised cost analysis is appropriate to the project activity.
Hence, the validation team raised clarification request CL-11 and
corrective action requests CAR-32 and CAR-34.

The project participant provided the response that the project activity has
been envisaged due to the capacity expansion of the manufacturing
facility which leaves the project participant no other choice than to make
an investment to supply the same (or substitute) products or services. In
order to verify the capacity expansion of the manufacturing capacity of the
project participant, the validation team interviewed the plant personnel
during the site visit and also reviewed the commissioning certificates
provided by the project participant for the added capacity of the terry
towel units and the spinning units (Ref /14, 15, and 17/). Moreover, the
project participant provided description on the capacity addition of the
manufacturing facility in the PDD version 3 including the justification for
selection of the levelised cost analysis. Based on the review of the
commissioning certificates of the terry towel and spinning units and the
site visit conducted, the validation team confirms that the electrical and
thermal energy requirements of the manufacturing facility of the project
participant were increased significantly due to the capacity expansion
which compels the project participant to invest in the project activity (as

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considered for the levelised cost analysis) to meet the total electrical and
thermal energy requirements of the manufacturing facility.
Hence, the validation team concluded that the levelised cost analysis
selected by the project participant is the most appropriate and well
justified method of demonstrating the additionality of the proposed CDM
project activity and is also in conformity with Para 19 of the latest
available guidance on investment analysis approved in of CDM Executive
Board Meeting report 62 (Ref B/12/) and Para 109 of VVM, Version 1.2
(Ref B/1/).

The validation team also observed that the levelised cost analysis results
reported in the web-hosted PDD were not computed in the terms of unit
cost of energy generation and hence raised corrective action request
CAR-33 on the same. CAR-33 was closed after the project participant
submitted the revised PDD and revised levelised cost analysis sheet in
terms of unit cost of generation of the energy (Million INR/TJ). In addition,
the validation team also observed that the project participant has
considered the period of assessment for the levelised cost analysis as 10
years which does not cover the complete technical lifetime of the project
activity. Hence, corrective action request CAR-37 was raised with respect
to the same. The project participant resubmitted the levelised cost
analysis spreadsheet considering the entire technical lifetime of the
project activity of twenty years as certified by the technology supplier (Ref
/9 and 10/). Hence, CAR-37 was closed by the validation team.

Investment Analysis: Input Parameters


The validation team noted that the sources for some of the input
parameters provided in the web hosted PDD (Ref /1/) and the levelised
cost analysis spreadsheet submitted to the validation team were not
provided clearly. Hence, the validation team raised clarification request
CL-14 with respect to the input values’ assumptions considered by the
project participant. CL-14 was closed after the project participant
resubmitted the levelised cost analysis spreadsheet and the PDD version
5 in which, the reference to the input values’ assumptions considered by
the project participant were appropriately specified. The validation team’s
analysis of the input assumptions considered by the project participant for
each of the alternative considered has been presented in the table below.

Input assumptions related to alternatives:


Option (d) project participant installs a fossil-fuel based co-generation
power plant without possibility of export of thermal energy and electrical
energy to any external party (please refer to section 3.6.3 of the report
for details)

Option (i) project participant installs a fossil-fuel based co-generation


power plant without possibility of export of thermal energy and electrical
energy to any external party (please refer to section 3.6.3 of the report

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for details)

Parameter Value used Source of Validation justification


data
Date of 1 s t Feb. Extract ofThe validation team has
investment 2008 the reviewed the extract of board
decision minutes ofmeeting to confirm the date
meeting ofof investment decision. The
the board validation team has also
of crosschecked the extract of
directors the minutes of the board
held on 1 s t
meeting during validation site
Feb. 2008 visit from the company’s
(Ref /13/)board register at the
registered office of the PP
located at Ludhiana, Punjab
and confirms that date of the
investment decision is as per
the board register of the
company.
Capital cost for Rs. 405 Feasibility The project participant has
cogeneration million report considered the capital cost
project activity dated from the feasibility report
at the time of 04/01/2008 submitted by ACE
investment (Ref /18/) Engineering and Consultants.
decision The validation team has also
referred to other appropriate
publicly available sources to
cross-check the project cost
as specified below:

The detailed tariff order for


the state of the Punjab was
not available at the time of
investment decision however,
in other states of India, such
tariff orders were available
and the same were referred
by the validation team for the
crosschecking of the input
assumption for the co-
generation project cost.

It was observed by the


validation team that the
Chhattisgarh Electricity

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Regulatory Commission
renewable energy tariff order
published on 15/01/2008 (Ref
/19/), The Gujarat Electricity
Regulatory Commission
renewable energy tariff order
published on 17/08/2007 (Ref
/19/) and Madhya Pradesh
Electricity Regulatory
Commission tariff order dated
07/08/2007 (Ref /19/) refer
the capital cost of the
biomass power project as Rs
40 million/MW , Rs. 35
million/MW and Rs. 42.5
million/MW respectively and
the average of the same work
out as 39.1 Million/MW . The
project participant has
considered the project cost
for the co-generation plant as
Rs. 405 million for 10 MW
(i.e. Rs. 40.5 million/MW )
and subjected the value to
+/- 10% sensitivity.

The validation team has also


referred to the quotations
from the equipment (boiler
and turbine) suppliers (Ref
/6 and 7/) and noted that the
cost of boiler and TG set
together forms about 73% of
the total project cost
considered by the project
participant in the levelized
cost analysis. Hence,
judgement of the
appropriateness of the
capital cost is reasonable.

In 2009, Central Electricity


Regulatory Commission
(CERC) published detailed
tariff order for the co-
generation plants. The
capital cost of the biomass

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based co-generation project


in accordance with the tariff
order of CERC published in
year 2009 in Annexure 4 E
(published on 03-12-2009),
the capital cost for biomass
based co-generation power
project in Punjab State is
specified as Rs. 44.5 million
/MW which results into Rs.
445.0 million for 10 MW
capacity (Ref /20/).

The project activity is


commissioned in year 2010
and the validation team has
also cross-checked the actual
implemented project cost
which is Rs. 433.36 million
(Ref /25/). The actual cost of
the project was verified from
certificate issued by the
chartered accountant Mr.
Dinesh Methani dated
05/10/2011, who are also
auditors of the project
participant.

In the view of above, the


validation team confirms that
the capital cost considered
by the project participant as
Rs. 405 million at the time of
investment decision is
appropriate and conservative.

The project participant has


considered the same project
cost for the rice husk and
coal based co-generation
project. This is a
conservative and consistent
assumption and hence
accepted by the validation
team.
Numbers of 24 hours Feasibility This is a normative
Hours of report assumption consistently

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operation in a dated applied for all the


day 04/01/2008 alternatives under the
(Ref /18/) levelised cost analysis
spreadsheet. It has been
sourced from the feasibility
report, which prepared by
ACE Engineering and
Consultant, who were
appointed by the project
participant. The feasibility
report was submitted to the
project participant
on04/01/2008 and hence
used for decision making.
The validation team also
verified this in a board
resolution, which mentions
that the feasibility report has
been one of the bases of
decision to implement the
project activity. Hence, the
same has been accepted by
the validation team.
Days of plant 330 days Feasibility This is a normative
operation in a report assumption consistently
year dated applied for all the
04/01/2008 alternatives under the
(Ref /18/) levelised cost analysis
spreadsheet. It has been
sourced from the feasibility
report, which prepared by
ACE Engineering and
Consultant, who were
appointed by the project
participant. The feasibility
report was submitted to the
project participant on
04/01/2008 and hence used
for decision making. The
validation team also verified
this in a board resolution,
which mentions that the
feasibility report has been
one of the bases of decision
to implement the project
activity. Hence, the same has
been accepted by the

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validation team.
Price of rice Rs. 2800 Quotations The price of the rice husk
husk /MT provided has been considered by the
by the rice project participant based on
husk the quotation from Rice husk
suppliers Supplier dated 15/12/2007
(Ref /26/) (Ref /26/). The feasibility
study report (Ref /18/) of the
project activity also
corroborates with the price of
rice husk specified in the
quotation dated 15/12/2007.

In addition, the validation


team has also referred to the
Biomass Assessment report
which has been duly
approved by the Government
entity Punjab Energy
Development Agency and
prepared by ACE Engineering
and Consultants (Ref /12/). It
was observed that the landed
cost of the biomass as
specified in the report is from
Rs. 2600/MT (transportation
distance up to 15km), Rs.
2800/MT (from transportation
distance of 15 to 25 km) and
Rs. 2950/MT (for
transportation distance 25 to
50 km). The landed cost
considered by the project
participant based on the
quotation received on 15 t h
Dec. 2007 is Rs. 2800/MT,
which is approximately an
average value of the price
range provided in the
biomass assessment report,
approved by the Punjab
Energy Development Agency
(PEDA), a Government of
Punjab entity.

The project activity is


commissioned in year 2010.

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The annual report of the


company for year 2010-11
(Ref /8/) also specify the
price of the rice husk
purchased by the project
participant for year 2009 (Rs.
3095/MT) and year 2010 (Rs.
2440/MT). As per the annual
audited report, the average
price of the biomass for both
the years (2009 and 2010) is
Rs. 2767/MT, which is close
to Rs. 2800/MT, the cost
considered by the project
participant in the levelised
cost analysis spreadsheet.
Besides ±10% sensitivity
analysis has also been
carried out by the project
participant on the base price
of Rs. 2800/MT which already
covers a range between Rs.
2520/MT to Rs. 3080/MT.
Hence, the validation team
accepted the price of the rice
husk as Rs. 2800/MT, which
is based on the source
available at the time of
decision making and well
justified with respect to the
investment decision timing
context.
Price of coal Rs. 3575 Quotation The project participant has
from Coal considered the highest of the
Supplier price Rs. 3575 out of the two
dated quotations submitted by the
17/12/2007 coal suppliers (Ref /27 and
(Ref /27 28/). The validation team
and 28/) also reviewed the feasibility
report of the project activity
prepared by the Ace
Engineers and Consultants
(Ref /18/ and noted that in
feasibility report the price of
the coal has been considered
as Rs. 3200/MT. Hence, the
validation team confirms that

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cost of the coal considered


by the project participant in
the levelised cost analysis
sheet as Rs. 3575/MT is
conservative and hence
accepted by the validation
team.
Net calorific 2767 Lab Test The value applied is sourced
value of rice Kcal/Kg Reports from third party lab test
husk dated report dated 24/12/2007. The
24/12/2007 lab test report was available
(Ref /29/) at the time of decision
making i.e. prior to the
investment decision date i.e.
01/02/2008. The validation
team has also referred to the
other publicly available
information to cross check
the parameter and observed
that Indiasolar.com website 6
provides details of the
calorific value of the various
fuels including the rice husk
and reports the rice husk
calorific value as
3000kcal/kg. The validation
team confirms that the range
of the sensitivity on the net
calorific value of the rice
husk taken as +/-10% already
covers range of NCV of rice
husk up to 3043.7 kcal/kg.
The validation team further
confirms that even at 14%
variation in the net calorific
value (i.e. 3154.38kcal/kg) of
the rice husk, the rice husk
based co-generation plant
(the project activity) does not
become the most economical
scenario.
Net calorific 4131 Lab Test The value applied is sourced
value of coal Kcal/Kg Reports from third party lab test
dated report dated 24/12/2007. The
24/12/2007 lab test report was available

6
http://www.indiasolar.com/cal-value.htm

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(Ref /30/) at the time of decision


making i.e. prior to the
investment decision date i.e.
01/02/2008. The validation
team concluded that the
value is accurate and
suitable.

The calorific value


considered by the project
participant as 4131 kcal/kg
and the +/-10% sensitivity of
on the coal calorific value
which covers the range of
NCV of 3718kcal/kg to 4544
kcal/kg for coal falls under
typical D grade (GCV from
4200kcal/kg to 4940kcal/kg) 7
Indian coal which is widely
used in India. Hence, the
same has been accepted by
the validation team.
Annual 5% Tariff The detailed tariff order for
escalation on order of the state of the Punjab was
the rice husk RERC (Ref not available at the time of
price /37/) investment decision however,
in other states of India, such
tariff orders were available
and the same were referred
by the validation team for the
crosschecking of the input
assumption. The
Chhattisgarh Electricity
Regulatory Commission
renewable energy tariff order
published on 15/01/2008 (Ref
/19/) and The Gujarat
Electricity Regulatory
Commission renewable
energy tariff order published
on 17/08/2007 (Ref /19/) also
refer annual escalation in
renewable biomass price as

http://www.productivity.in/knowledgebase/Energy%20Management/c.%20Thermal%20Energy%20systems/4.1%20Fuels%2
0and%20Combustion/4.1.3%20Properties%20of%20Coals.pdf

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5%.
In 2009, Central Electricity
Regulatory Commission
(CERC) published detailed
tariff order (Ref /20/) for the
co-generation plants. The
capital cost of the biomass
based co-generation project
in accordance with the tariff
order of CERC published in
year 2009 in Annexure 4 E
(published on 03-12-2009),
the year on year escalation
on the biomass has been
considered as 5%. Hence,
year on year escalation of 5%
was accepted by the
validation team.
Annual 5.35% W hole sale The PP has conservatively
escalation on price index applied the escalation of
coal for coal 5.35% on the coal cost based
published on the one year data (Jan
by Office 2007 to Dec 2007).
of the
Economic The same can be attributed
Advisor to the fact that the escalation
(Govt. of for the year 2006 stood as
India) (Ref 0.17%, whereas the same for
/31/) year 2005 stood as 0% as
evident from the W holesale
price index for Coal. Hence,
validation team accepted the
annual escalation on coal as
5.35% as a conservative
estimate.
Rate of 7.84% As per As per companies Act
depreciation companies applicable to the project
for building Act activity
applicable (http://taxclubindia.com/simpl
to the e/depreciation%20rates%202
project 009-10.pdf).
activity.
Rate of 7.84% As per As per companies Act
depreciation companies applicable to the project
for plant and Act activity
machinery applicable (http://taxclubindia.com/simpl

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to the e/depreciation%20rates%202
project 009-10.pdf).
activity.
Rate of 7.69% As per As per companies Act
depreciation companies applicable to the project
for spare parts Act activity
applicable (http://taxclubindia.com/simpl
to the e/depreciation%20rates%202
project 009-10.pdf).
activity.
Discount rate 13.00% Reserve The discount rate used for
Bank of
the calculation of levelised
India (RBI)
cost of energy over lifetime
prime of the energy generating
lending equipments has been
rate (Ref
sourced from Reserve Bank
/35/) of India (RBI) prime lending
rate published by RBI on 1 s t
Feb. 2008. The validation
team has accepted the
discount rate and confirms
that it is correct and
appropriate to the type of
project activity as it is
provided by RBI, which as a
Monetary Authority, which
formulates, implements and
monitors the monetary policy
of the host country India. The
RBI specifies the prime
lending rates of the five
major banks of India from
28 t h Dec. 2007 to 18 t h Jan
2008 between the range of
12.75% to 13.25%. Thus, the
average value of 13% applied
by the project participant has
been accepted by the
validation team.
Operation and Rs. 7.78 Feasibility The operation and
maintenance million study maintenance expenses
expenses /year report (Ref considered by the project
(including the /18/) participant as per the
manpower feasibility study report are
cost) Rs. 7.78 Million/ year.
including the manpower cost

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which is 1.92% of the capital


cost considered by the
project participant

The detailed tariff order for


the state of the Punjab was
not available at the time of
investment decision however,
in other states of India, such
tariff orders were available
and the same were referred
by the validation team for the
crosschecking of the input
assumption. The
Chhattisgarh Electricity
Regulatory Commission
renewable energy tariff order
published on 15/01/2008 (Ref
/19/), The Gujarat Electricity
Regulatory Commission
renewable energy tariff order
published on 17/08/2007 (Ref
/19/) refer O&M expenses as
7% of the project cost.
Further the Tariff order
published by Madhya
Pradesh Electricity
Regulatory Commission on
07/08/2007 refers O&M
expenses as 4% of the
project cost.

In 2009, Central Electricity


Regulatory Commission
(CERC) published detailed
tariff order (Ref /20/) for the
co-generation plants. The
capital cost of the biomass
based co-generation project
in accordance with the tariff
order of CERC published in
year 2009 in Annexure 4 E
(published on 03-12-2009),
refers the O&M expenses as
3% of the project cost.
Hence, the validation team
confirms that O&M expenses

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considered as 1.92% of the


project cost are conservative
and the same was accepted
by the validation team
Escalation in O 5.70% Consumer The project participant has
& M cost price Index considered the increment on
for the O&M cost based on the
Industrial consumer price index for the
workers Industrial workers which is
from the published data by the
annual Reserve Bank of India (RBI),
report of in it’s annual report for year
Reserve 2006-07 (Ref /36/). The same
Bank of was available to the project
India participant at the time of
published investment decision.
on
30/08/2007 The validation team cross-
(Ref /36/) checked the escalation
considered by the project
participant in the O&M cost
through other publicly
available information. It was
observed that a tariff order
published by Chhattisgarh
state government dated
15/01/2008 for biomass
based projects (Ref /19/)
specifies annual escalation in
operation and maintenance
expenses as 5%. Another
tariff order for biomass
projects published by Gujarat
Govt. on 17/08/2007 (Ref
/19/) also specify the annual
escalation in the O&M
expenses as 5%. In addition
the tariff order for the
biomass co-generation power
plants published by the
CERC in year 2009 refers
escalation on in O&M as
5.72% (Ref /20/).

The validation team confirms


that even after considering
the annual escalation in

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operation and maintenance


expenses as 5% does not
bring any significant impact
on the results of the levelized
cost analysis. Hence, the
annual escalation in O&M
expenses as 5.70% was
accepted by the validation
team.
Steam 50000 Feasibility The validation team has
generation per kg/hour study cross-checked the value as
hour from the report (Ref per the technical
co-generation /18/) specifications of the boiler
project (Ref /4/). The rated steam
flow from the boiler is 50
Tonnes/hour. Hence, the
same has been accepted by
the validation team.
Specific 819.16 Feasibility The value is based on the
enthalpy of the kcal/kg study rated steam properties at the
steam for co- report (Ref boiler outlet are 88 ATA
generation /18/) pressure and 517 ºC
project activity temperature. The steam
enthalpy is taken from
standard steam tables for the
rated steam properties of the
boiler. Hence, the same has
been accepted by the
validation team.
Specific 135.56 Feasibility The rated feed water
enthalpy of the kcal/kg study temperature as per the boiler
feed water for report (Ref technical specifications is
the co- /18/) 135ºC. The feed water
generation enthalpy is taken from
project standard water enthalpy
tables. Hence, the same has
been accepted by the
validation team.
Net heat output 34180000 Feasibility This is a calculated value
from the boiler kcal/ study and the same has been
for the co- hour report (Ref cross-checked based on the
generation /18/) rated technical specifications
project of the boiler (Ref /4/) as
specified above. Hence, the
same has been accepted by
the validation team.

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Efficiency of 100% Feasibility The efficiency of the co-


the co- study generation plant considered
generation report (Ref by the project participant is
plant /18/) the most conservative
assumption. The same has
also been allowed by the
applied baseline and
monitoring methodology
AMS-I.C. version 19. The
project participant has
consistently applied the
efficiency of the co-
generation plant as 100% in
the levelised cost
spreadsheet as well as the
emission reduction
calculations. Hence, the
same has been accepted by
the validation team.
Specific 135.56 Feasibility The validation team has
enthalpy of the kcal/kg study cross-checked the value as
feed water for report (Ref per the technical
the low /18/) specifications of the boiler
pressure boiler (Ref /4/). The rated feed
+ grid water temperature as per the
alternative boiler technical specifications
is 135 degree Celsius. The
feed water enthalpy is taken
from standard water enthalpy
tables. Hence, the same has
been accepted by the
validation team.

Specific Input assumptions related to alternatives:

Option (e) Electricity is imported f rom a grid and thermal energy


(steam/heat) is produced using fossil fuel (please refer to section 3.6.3
of the report for details)

Option (i) Electricity is imported from a grid and steam/heat is produced


from biomass (please refer to section 3.6.3 of the report for details)

Parameter Value used Source of Validation justification


data
Cost of Rs. Electricity The project participant has

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purchasing 4.66/kW h Bills for sourced this input


electricity from the Month assumption based on the
the grid for of Dec. electricity bills for the month
industries in 2007 (Ref of Dec. 2007 issued on
Punjab /32/) 12/01/2008. The value is
based on the actual HT
electricity consumption bill
issued by the Punjab
Electricity Board (a Govt.
entity) and was available at
the time of investment
decision i.e. 01/02/2008.
Hence, the validation team
accepted the same.
Annual 3.04% Punjab The annual escalation on grid
escalation on State tariff for Punjab state has
HT tariff in Electricity been computed by the project
Punjab Board participant based on the
(PSEB) actual electricity bills from
electricity Dec. 2005 to Dec. 2007. The
bills from same has been verified by
Dec 2005 the validation team from the
to Dec electricity bills produced by
2007 (Ref the project participant. This
/32, 33, is applicable to the
34/) investment decision timing as
the date of investment
decision is 01/02/2008.
Capital cost of Rs. 162 Feasibility This is one of the options
low pressure million report (Ref considered under the
boiler /18/) feasibility report and is a
plausible alternative scenario
where the project participant
may purchase the electricity
from the state grid and
generate the thermal energy
from the low pressure boiler
at the plant premises.

The capital cost of the low


pressure boiler has also been
cross-checked with the
quotations submitted for the
20 TPH boiler (Ref /38/) and
balance of the plant of 20
TPH boiler (Ref /39/)
supplied to the project

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participant from M/s Cethar


Vessels Limited. The cost of
the 20 TPH boiler as per the
quotations is 126.5 million
INR which is excluding the
service tax and excise duty.
The total landed cost arrives
as 147 million INR.

The validation team confirms


that the cost of the low
pressure boiler considered by
the project participant in the
levelised cost analysis (as
Rs. 162 million) is based on
the boiler cost and the cost
of Civil work).

Hence, the cost of the low


pressure boiler alternative as
boiler cost + cost of civil
work in the DPR has been
accepted by the validation
team.
Specific 135.56 Feasibility The rated feed water
enthalpy of the kcal/kg study temperature as per the boiler
feed water for report (Ref technical specifications is
the co- /18/) 135ºC. The feed water
generation enthalpy is taken from
project standard water enthalpy
tables. Hence, the same has
been accepted by the
validation team.
Efficiency of 100% Feasibility The efficiency of the co-
the boiler study generation plant considered
report (Ref by the project participant is
/18/) the most conservative
assumption. The same has
also been allowed by the
applied baseline and
monitoring methodology
AMS-I.C. version 19. The
project participant has
consistently applied the
100% efficiency in all the
alternatives of the levelised
cost spreadsheet as well as

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the emission reduction


calculations. Hence, the
same has been accepted by
the validation team.
Steam 19700 Feasibility As per the feasibility study
generation per kg/hour study report, the process steam
hour for the report (Ref requirements of the
low pressure /18/) manufacturing facility are
boiler 19700 kg/hour. The feasibility
report proposes a 20 TPH
boiler to meet the thermal
energy requirements of the
plant. The validation team
has also verified the rated
extraction steam flow from
the implemented project
activity (alternative d) turbine
and confirms that the same is
also 19700kg/hour (Ref /5/).
Hence, rated steam flow for
the Low Pressure Boiler was
accepted by the validation
team.
Outlet steam 9.4 ATA Feasibility This has been further cross-
pressure for study checked with the extraction
the low report (Ref steam turbine parameters of
pressure boiler /18/) the implemented co-
generation project (the
project activity) to ascertain
the thermal energy
requirements of the plant.
The extraction steam
parameters of the turbine in
the project activity also
specif y the extraction steam
pressure as 9.4 ATA (Ref
/5/). Hence, the same has
been accepted by the
validation team.
Outlet steam 190ºC Feasibility This has been further cross-
temperature for study checked with the extraction
the low report (Ref steam turbine parameters of
pressure boiler /18/) the implemented co-
generation project (the
project activity) to ascertain
the thermal energy

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requirements of the plant.


The extraction steam
parameters of the turbine in
the project activity specif y
the extraction steam
temperature as 259ºC (Ref
/5/) which is higher than the
low pressure boiler
alternative scenario selected
by the project participant.

However, the project


participant has commissioned
a desuperheater to reduce
the outlet steam temperature
in the project activity
scenario from 259ºC to meet
the 190ºC process steam
requirement. Hence, the
validation team accepted the
value of 190ºC as outlet
steam temperature for the
low pressure boiler. The
emission reductions have
also been claimed for the
thermal energy as per the
process steam requirements
only i.e. at 190ºC and 9.4
ATA.
Specific 670.28 Calculated This is calculated value of
enthalpy of the kcal/kg value the steam enthalpy for the
steam for the alternative of low pressure
low pressure boiler. As per the steam
boiler + grid requirements of the plant
alternative specified in the feasibility
study report and cross-
checked as specified above.
Specific 135.56 Feasibility The validation team has
enthalpy of the kcal/kg study cross-checked the value as
feed water for report (Ref per the technical
the low /18/) specifications of the boiler
pressure boiler (Ref /4/). The rated feed
+ grid water temperature as per the
alternative boiler technical specifications
is 135ºC. The feed water
enthalpy is taken from
standard water enthalpy

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tables. Hence, the same has


been accepted by the
validation team.

Investment comparison anal ysis: Calculation and conclusion (111)


The validation team has verified the assumptions of the levelised cost
analysis as a part of investment comparison analysis as explained above
and observed that they are correct and based on conservative values that
are applicable at the time of decision making.

The financial expert in the validation team has verified the calculations of
levelised cost of energy presented by the project participant and observed
them to be in order. The calculation includes the values of depreciation as
per company’s act of host country India. The validation team confirms that
the project participant has applied all the statutory levies as per then valid
applicable rules of the host country.

The financial expert has also verified the arithmetic accuracy of the
calculations of levelised cost of energy and found the same to be correct.
The calculations of levelised cost have been provided in an MS-Excel
transparent spreadsheet. The formulae used in the spreadsheet are
readable. All the cells of the spreadsheet can be accessed and the data in
the cells can be viewed, as the cells are unprotected. The levelised cost
in baseline and project scenario has been computed over an entire
technical lifetime of the project activity, which is in accordance with
applied methodology (Ref B/5/) and General Guidelines for SSC CDM
methodologies (Ref B/7/). The calculations of levelised cost of energy are
thus based on the most appropriate and well justified input values in
accordance with Guidelines on the assessment of investment analysis
(Annex 5, EB-62) (Ref B/12/).

The validation team hereby confirms that the approach adopted in making
assumptions, projections and the computations for levelised cost of
energy in the investment comparison analysis, conforms to the accepted
and standard accounting principles of the host country and is also in line
with the Guidelines on the assessment of Investment analysis (Annex 5 of
EB-62). The financial expert has verified the calculations of levelised cost
of energy in alternatives to the project scenario and project scenario itself
and observed them to be in order and are hence certified by the financial
expert.

The validation team thus concludes that the underlying assumptions in the
investment analysis are appropriate. Accounting principles adopted in the
calculations and the calculations per se are also correct.

The levelised costs of energy are worked out are as per the following
details:

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Alternative The alternative Levelised Ranking of


as per scenarios for the Cost of the
methodology project activity energy alternatives
production based on the
(INR results of the
Million/TJ) Levelised
cost
a Electricity is imported 3.7205 The Third
from a grid and thermal preferred
energy (steam/heat) is option as the
produced using fossil levelised cost
fuel (coal) of energy is
least
d Electricity and thermal 2.5996 The Most
energy (steam/heat) are preferred
produced in a option as the
cogeneration unit using levelised cost
fossil fuel (coal) without of energy is
possibility to export the least
electricity and thermal
energy to any external
facility
e Electricity is imported 3.8251 The least
from a grid and preferred
steam/heat is produced option as the
from biomass levelised cost
of energy is
least
i Electricity and thermal 2.9285 The Second
energy is produced in a preferred
biomass fired option as the
cogeneration unit levelised cost
without possibility to of energy is
export the electricity least
and thermal energy to
any external facility

The validation team hereby confirms that the levelised cost of coal based
co-generation captive plant is the least cost alternative for the project
participant and allowed to implement as per the local regulations of the
host country. On the other hand, the rice husk based captive co-
generation project, which in turn, implemented by the project participant,
is the second most plausible scenario for the project participant. Other
two scenarios are not discussed further as they are more costly to
implement and operate as compared to the rice husk based and coal
based co-generation captive plant.

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Hence, the validation team concludes that it is essential for the project
activity to get the CDM revenue in order to make the project economically
comparable to the least cost alternative available to the project
participant i.e. coal based co-generation project.

Sensitivity Anal ysis (111(e))


In order to demonstrate the robustness of the conclusion arrived above,
viz; the project is additional; and as per the guidelines on the assessment
of investment analysis (paragraph 20 and 21 of Annex 5 of EB-62), the
sensitivity of the investment analysis to all parameters constituting more
than 20% of either total project costs or total project revenues has been
determined by the project participant. The following two parameters were
subjected to a variation of ± 10% to check the effect it would have on the
overall levelised cost analysis, since these parameters constitute more
than 20% of total operating cost. The range of variation could be
considered to be reasonable in the context of the project activity and also
meets the requirement of the guidelines by CDM-EB.

1. Price of fuels i.e. coal and rice husk


2. Calorific value of fuels i.e. coal and rice husk
3. Project cost Co-generation plant (both rice husk and fossil fuel
based)
4. Project cost for low pressure boiler and grid alternatives (both rice
husk and fossil fuel based low pressure boiler)

The project participant carried out the sensitivity analysis for ±10% range
of the sensitivity. The same is in accordance with the guidance provided
for the sensitivity analysis in Annex 5 of EB-62. The results of the
sensitivity analysis carried tabulated below:

-10% -5% 0% 5% 10%


Alternative Scenario Parameter - Cost of Coal
Coal based captive cogeneration 2.3694 2.4845 2.5996 2.7148 2.8299
Electricity from grid and steam from
3.6486 3.6845 3.7205 3.7564 3.7923
coal based low pressure boiler
Electricity from grid and steam from
3.8251 3.8251 3.8251 3.8251 3.8251
rice husk low pressure boiler
Rice husk based captive cogeneration 2.9285 2.9285 2.9285 2.9285 2.9285
Alternative Scenario Parameter - Cost of Rice husk
Coal based captive cogeneration 2.5996 2.5996 2.5996 2.5996 2.5996
Electricity from grid and steam from
3.7205 3.7205 3.7205 3.7205 3.7205
coal based low pressure boiler
Electricity from grid and steam from
3.7430 3.7840 3.8251 3.8661 3.9071
rice husk low pressure boiler

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Rice husk based captive cogeneration 2.6657 2.7971 2.9285 3.0600 3.1914
Alternative Scenario Parameter -Calorific Value of Coal
Coal based captive cogeneration 2.8554 2.7208 2.5996 2.4900 2.3903
Electricity from grid and steam from
3.8003 3.7583 3.7205 3.6863 3.6552
coal based low pressure boiler
Electricity from grid and steam from
3.8251 3.8251 3.8251 3.8251 3.8251
rice husk low pressure boiler
Rice husk based captive cogeneration 2.9285 2.9285 2.9285 2.9285 2.9285
Alternative Scenario Parameter - Calorific Value of Rice Husk
Coal based captive cogeneration 2.5996 2.5996 2.5996 2.5996 2.5996
Electricity from grid and steam from
3.7205 3.7205 3.7205 3.7205 3.7205
coal based low pressure boiler
Electricity from grid and steam from
3.9162 3.8682 3.8251 3.7860 3.7505
rice husk low pressure boiler
Rice husk based captive cogeneration 3.2206 3.0669 2.9285 2.8034 2.6896
Alternative Scenario Parameter - Project Cost (Cogeneration)
Coal based captive cogeneration 2.5801 2.5899 2.5996 2.6094 2.6191
Electricity from grid and steam from
3.7205 3.7205 3.7205 3.7205 3.7205
coal based low pressure boiler
Electricity from grid and steam from
3.8251 3.8251 3.8251 3.8251 3.8251
rice husk low pressure boiler
Rice husk based captive cogeneration 2.9090 2.9188 2.9285 2.9383 2.9480
Alternative Scenario Parameter - Project Cost (Grid + L P boiler)
Coal based captive cogeneration 2.5996 2.5996 2.5996 2.5996 2.5996
Electricity from grid and steam from
3.7126 3.7165 3.7205 3.7244 3.7284
coal based low pressure boiler
Electricity from grid and steam from
3.8172 3.8211 3.8251 3.8290 3.8330
rice husk low pressure boiler
Rice husk based captive cogeneration 2.9285 2.9285 2.9285 2.9285 2.9285

The results of the sensitivity analysis (tabulated above) demonstrate that


coal based co-generation project is always the least cost option available
to the project participant throughout the range of the sensitivity analysis
and rice husk based co-generation project has higher levelised cost than
coal based co-generation plant throughout the range of sensitivity. Thus
the validation team concurs with the project participant that project
activity is additional and economically not comparable without the benefits
from CDM. DOE is, therefore, convinced that the project is additional.

3.7.4 Barrier analysis (118)


As described above in section 3.7.3 of this report, project participant has
demonstrated additionality on investment barrier in accordance with
Attachment A to Appendix B of Simplified modalities and procedures for

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small-scale CDM project activities. Barrier analysis was not applied for
the demonstration of additionality of proposed CDM project activity.

3.7.5 Common practice analysis (121)


Common practice analysis has not been used to demonstrate
additionality. As per Attachment A to Appendix B of Simplified modalities
and procedures for small scale CDM project activities, additionality can be
demonstrated by any one of the four barriers listed. The project
participant has demonstrated additionality using investment barrier. The
project participant has also not claimed any first-of-its-kind barrier. Being
a small scale project activity, the common practice is not applicable.

3.8 Monitoring plan (124)


The DOE hereby confirms that the monitoring plan complies with the
requirements of the methodology.

The steps taken to assess whether the monitoring arrangements


described in the monitoring plan are feasible within the project design are
also described below.

The project activity uses the approved baseline and monitoring


methodology AMS I C, Version 19. Validation team considers the
monitoring plan to be complying with the requirements of the methodology
based on the following assessment.

According to the Paragraph 50 (Table 1: Parameters for monitoring during


the crediting period) of applied baseline and monitoring methodology AMS
I C, version 19, monitoring shall consist of (with respect to proposed CDM
project activity)

Requirement as per the Included in the monitoring plan


monitoring methodology appropriate to type of project
activity
Quantity of steam supplied to the This parameter has been included
process by the project participant in section
B.7.1 as Q s t e a m . The monitoring plan
relies on 100% monitoring of the
parameter based on the steam flow
meter. In addition, the provisions
for the annual calibration archiving
procedure and data recording
frequency have been specified in
the monitoring plan. Thus, the
validation team confirms that
monitoring procedure for the
parameter meets the requirements

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of the monitoring methodology


AMS-I.C. Version 19.
Pressure of the temperature The monitoring plan relies on the
supplied to the process measured value of the outgoing
steam pressure to the process after
the de-superheating. Monitoring
plan relies on pressure transmitters
connected to the DCS of the plant
with yearly calibration frequency.
Thus, the same has been accepted
by the validation team.
Temperature of the steam supplied The monitoring plan includes the
to the process measured value of the outgoing
steam temperature to the process
after the de-superheating.
Monitoring plan relies on
temperature transmitters connected
to the DCS of the plant with yearly
calibration frequency. Thus, the
same has been accepted by the
validation team.
Temperature of the feed water The monitoring plan includes the
supplied to the process measured value of the feed water to
the project activity boiler.
Monitoring plan relies on
temperature transmitters connected
to the DCS of the plant with yearly
calibration frequency. Thus, the
same has been accepted by the
validation team.
Net heat supplied to the process This is a calculated value based on
the above-specified essential
monitoring parameters of steam and
the feed water.
Gross electricity generation from For the gross electricity generation
the project from the project plant, monitoring
plan relies on 100% monitoring
based on 0.2 class accuracy energy
meter. Thus, the same has been
accepted by the validation team. PP
has also specified yearly calibration
frequency of the energy meter.
Plant auxiliary electricity For the net electricity generation
consumption from the project plant, monitoring
plan relies on 100% monitoring
based on 0.2 class accuracy energy

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meter. Thus, the same has been


accepted by the validation team. PP
has also specified yearly calibration
frequency of the energy meter.
Net electricity supplied to the This is a calculated value based on
process the monitored values of the gross
electricity generation and auxiliary
consumption.
Quantity of rice husk consumed in The monitoring plan relies on the
the project activity load cell based measurements for
the biomass consumption in the
project activity boiler. The PP has
also specified the calibration
frequency of the load cell on yearly
basis.
NCV of rice husk The monitoring plan relies on the
external laboratory test reports for
the net calorific value determination
for the rice husk based on
national/international standards.
Moisture content in the rice husk The moisture content of the rice
husk is based on the internal testing
process. It is an acceptable practice
as the payment is made to the
supplier considering the moisture
content of the rice husk. Thus, the
internal testing of the rice husk
moisture content has been accepted
by the validation team.
Quantity of coal used in the project The monitoring plan relies on the
activity (in case of exigencies) load cell based measurements for
the fossil fuel consumption in the
project activity boiler. The PP has
also specified the calibration
frequency of the load cell on yearly
basis.
NCV of fossil fuel used The monitoring plan relies on the
external laboratory test reports for
the net calorific value determination
for the fossil fuel based on
national/international standards.
Grid electricity imported in the The project participant has also
project activity included the monitoring of the grid
electricity import in the project
activity (in case of exigencies) for
the project emissions calculations

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as per the tool to calculate baseline


project or/and leakage emissions
from electricity consumption.

Project participant has provided for archiving in electronic and paper form
of all the monitored data. This is stated transparently in section B.7 of the
revised PDD (Ref /2/). Project participant has provided for keeping the
data for 2 years after the end of the last crediting period.

The monitoring plan includes requirements and procedures for meter


testing and calibration. The relevant monitoring equipments/instruments
will be calibrated once in a year. The monitoring plan also includes
organizational structure, roles & responsibilities and procedures for data
collection and record keeping, archiving of data and data uncertainty in
section B.7.2 of the revised PDD (Ref /2/).

W hile reviewing the web hosted PDD validation team observed that
“source of data” and “description of measurement methods” were not
explained explicitly in the monitoring plan. The validation team raised
corrective action request CAR-12 and CAR-13. The project participant
revised the monitoring plan in response to CAR-12 and 13 and included
additional description on source of data and description of measurement
methods. The validation team reviewed the revised monitoring plan
submitted by the project participant and found the corrections appropriate
and thus, closed CAR-12 and CAR-13.

The validation team also observed that the monitoring plan of the web
hosted PDD was not detailed with respect to the QA/QC procedures,
calibration frequency, data uncertainty and cross checking mechanisms
for the applicable monitoring parameters. The validation team raised
clarification request CL-18 with respect to the same. The project
participant detailed the data uncertainty procedures, data cross checking
mechanism, and calibration frequency of energy meters, transmitters etc.
in the revised PDD. The validation team noted that QA/QC procedures
mentioned above have been sufficiently addressed in accordance with the
applicable monitoring methodology AMS-I.C. version 19. Thus, CL-18 was
closed by the validation team.

The validation team further noted from the review of the web-hosted PDD
that monitoring plan was clear with respect to the monitoring of the
moisture content of the biomass and temperature of the feed water. In
addition, the monitoring plan presented in the web-hosted PDD was silent
on the monitoring of the fossil fuel consumption (during exigencies) in the
project activity. Thus, the validation team raised clarification request CL-
15 with respect to the same. The project participant revised the
monitoring plan and included the procedures for the monitoring of feed
water temperature, moisture content of the biomass, fossil fuel

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consumption in the project activity. The validation team closed CL-15


after the review of the revised PDD provided by the project participant.

Hence, the DOE hereby confirms that the project participant is able to
implement the monitoring plan in accordance with the applied monitoring
methodology and the monitoring plan is feasible within the project design
as it relies on metered data from widely accepted monitoring instruments.

The validation team also confirms that the operating staff of project
participant are experienced in the operation the thermal energy
generating equipments. The validation team therefore is of the opinion
that the project participant is capable of implementing the monitoring plan
in the specific context of the project activity.

3.9 Sustainable development (127)


The project participant has described contribution to sustainable
development in line with the four indicators of sustainable development
stipulated by Ministry of Environment & Forests, DNA of India. The
validation team noted that the LoA (Letter of Approval) from the Host
country DNA (Ref /3/) contains the confirmation that the proposed CDM
project activity contributes to the sustainable development of the host
party.

3.10 Local stakeholder consultation (130)


The steps taken to assess the adequacy of the local stakeholder
consultation are described below.

The project participant has conducted a local stakeholder consultation


meeting to get the comments and suggestions of the local stakeholders on
the project activity i.e. 10 MW rice husk based co-generation project in
Punjab. The stakeholder consultation meeting was conducted on
13/07/2009 within the premises of the SEL Manufacturing company. The
local stakeholders were invited before the meeting date on 08/07/2009.
The validation team cross-checked the information provided in the PDD b y
means of the interviewing the local stakeholders during the site visit.

It was observed by the validation team that under section E.2 of the web-
hosted PDD, the local stakeholders who have made comments were not
identified. Thus, the validation team raised corrective action request CAR-
14. The validation team closed CAR-14 after the project participant
provided the revised PDD with the identified local stakeholders who have
made the comments. The validation team cross-checked the information
provided in the PDD by means of the interviewing the local stakeholders
during the site visit and there were no negative comments regarding the
project activity from any of the local stakeholders. The stakeholders also
confirmed the process of invitation as described in the PDD. The

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validation team therefore confirms that the process of local stakeholder


consultation is adequate.

3.11 Environmental impacts (133)


According to the Schedule 1 of the EIA notification dated 14 t h September
2006 (http://envfor.nic.in/legis/eia/eia-2006.htm), given by the Ministry of
Environment and Forests (Government of India) under the Environment
(Protection) Act 1986, Environmental Impact Assessment (EIA) is not a
regulatory requirement in India for the project activity. Hence the
validation team confirms that the project complies with the environmental
regulations in India.

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS


The PDD using methodology AMS I C, version 16 was web hosted on the
UNFCCC for global stakeholder’s comments as per CDM requirements
from 10/07/2010 to 08/08/2010. The validation team confirms that no
comments were received during the project web-hosting period for the
project activity.

5 VALIDATION OPINION
Bureau Veritas Certification has performed a validation of the “10 MW
Biomass based Power plant in Punjab, India”. The validation was
performed on the basis of UNFCCC criteria and host country criteria and
also on the criteria given to provide for consistent project operations,
monitoring and reporting.

The validation consisted of the following three phases: i) a desk review of


the project design and the baseline and monitoring plan; ii) follow-up
interviews with project stakeholders; iii) the resolution of outstanding
issues and the issuance of the final validation report and opinion.

Project participant/s used the latest guidance and tools published by the
CDM Executive Board for demonstration of the additionality. In line with
this tool, the PDD provides analysis of investment barrier to determine
that the project activity itself is not the baseline scenario. Project
participant used Attachment A to Appendix B of simplified modalities and
procedures for small scale CDM project activities for demonstration of the
additionality. The PDD provides investment barrier to demonstrate
additionality. The levelised cost of energy from rice husk (even with
sensitivity on cost of fuel and calorific value of fuel) is higher than the
levelised cost of output energy in the baseline scenario i.e. using fossil
fuel (coal) and hence it is demonstrated that the project is additional.

By synthetic description of the project, the project is likely to result in


reductions of GHG emissions partially. An analysis of the investment
barrier demonstrates that the proposed project activity is not a likely

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baseline scenario. Emission reductions attributable to the project are


hence additional to any that would occur in the absence of the project
activity. Given that the project is implemented and maintained as
designed, the project is likely to achieve the estimated amount of
emission reductions.

The review of the project design documentation being submitted for


registration and the subsequent follow-up interviews have provided
Bureau Veritas Certification with sufficient evidence to determine the
fulfillment of stated criteria. In our opinion, the project correctly applies
and meets the relevant UNFCCC requirements for the CDM and the
relevant host country criteria. Bureau Veritas Certification thus requests
registration of “10 MW Biomass based Power plant in Punjab, India” as
CDM project activity.

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6 REFERENCES
Categor y 1 Documents:
Documents provided by Type the name of the company that relate directly
to the GHG components of the project.
/1/ W eb-hosted PDD titled 10 MW biomass based power plant in
Punjab, India, version 01, dated 11/06/2010
/2/ Revised PDD version 5, dated 15/06/2012
/3/ Host Country Approval letter, reference no. 4/19/2009-CCC, issued
by Government of India, Ministry of Environment and Forest, dated
19/06/2010
/4/ Purchase order for the boiler issued by M/s SEL Manufacturing
Company Limited to M/s Cethar Vessels Limited; reference no.
SELML 001AFBC; dated 01/03/2008
/5/ Purchase order for the STG set and auxiliaries issued by M/s SEL
Manufacturing Company Limited to M/s Siemens Limited; reference
no. SELML 002STG; dated 07/03/2008
/6/ Techno-Commercial offer for the supply of the boiler to M/s SEL
Manufacturing Company Limited from M/s Cethar Vessels Limited
dated 08/11/2007
/7/ Techno-Commercial offer for the supply of the Turbo-generator set
to M/s SEL Manufacturing Company Limited from M/s Siemens
Limited dated 11/09/2007
/8/ Annual report of the company SEL Manufacturing Company Limited
for financial year 2010-11 dated 19/05/2011
/9/ Certificate of the technical lifetime of the project activity boiler
from the manufacturer M/s Cethar Vessels Limited; reference no.
CVL/RD/2533/10 dated 29/10/2010
/10/ Certificate of the technical lifetime of the project activity Turbo-
Generator Set from the manufacturer M/s Siemens Limited; dated
02/11/2010
/11/ Undertaking from M/s SEL Manufacturing Company dated
07/09/2011 stating that company will not sell power from it’s 10
MW project activity to any external party and the same would be
exclusively used for the internal power requirements of SEL
manufacturing Company
/12/ Biomass Assessment Report of SEL Manufacturing Company
Limited, A Feasibility Report for SEL Manufacturing Company
Limited prepared by Ace Engineers and Consultants and approved
by the Punjab Energy Development Agency (PEDA) on 26/03/2010.
/13/ The certified true extracts of the resolution passed by the Board of
Directors of SEL Manufacturing Company Limited in the Meetin g
Held on 1 s t Feb. 2008 at their registered office Ludhiana, Punjab,
India
/14/ Growth journey milestones of the M/s SEL Manufacturing Company
Limited available on the official website http://www.selindia.in/growth.html
of the company.

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/15/ Commissioning certificate for the second terry towel unit


commissioned in year 2010, dated 26/06/2010 issued by Itema
W eaving (India) Private Limited.
/16/ Minutes of the meeting held between the technology supplier M/s
Siemes Limited and the project participant on 12/01/2010.
/17/ Commissioning of the first terry towel unit commissioned in year
2008, dated 14/11/2008 verified from the minutes of the meeting
between PP and the technology supplier Tsudacoma, Japan
/18/ Feasibility Study Report dated 04/01/2008; prepared by Ace
Engineers and Consultants for Power cum Steam Generation Plant
at SEL Manufacturing Company Limited, January 2008.
/19/ The Tariff order summary report prepared and published by Indian
Renewable Energy Development Agency Limited available on their
website http://www.ireda.gov.in/Trifforder/Proceedings/Summary/Biomass.pdf
/20/ 2.1 Form Template for Non-Fossil Fueled Based Cogeneration
Power Projects under the Determination of generic levelised
generation tariff under Regulation 8 of the Central Electricity
Regulatory Commission (Terms and Conditions for Tariff
determination from Renewable Energy Sources) Regulations, 2009;
dated 03/12/2009
/21/ Emission Reduction Calculation spreadsheet submitted by the
project participant along with the revised PDD being submitted for
the registration
/22/ Engagement letter for the CDM Advisory services between M/s
Ernst and Young Pvt. Limited and M/s SEL Manufacturing
Company Limited dated 15/01/2009
/23/ Email Notification of the Meeting of the National CDM Authorit y
(NCDMA) of India for the consideration of the project activity for
host country approval; reference no. 4/19/2009-CCC; dated
15/10/2009
/24/ Contract for CDM validation services with Bureau Veritas
Certification dated 16/02/2010
/25/ Certificate of capital investment made by M/s SEL Manufacturing
Company Limited for 10 MW Biomass based co-generation project
activity issued by the Charted Accountant Mr. Dinesh Methani;
dated 05/10/2011
/26/ Rice husk supply quotation provided to M/s SEL Manufacturing
Company Limited by M/s V.D. Traders; dated 15/12/2007
/27/ Coal supply quotation provided to M/s SEL Manufacturing
Company Limited by M/s Mohit Minerals Pvt. Ltd.; dated
17/12/2007
/28/ Coal supply quotation provided to M/s SEL Manufacturing
Company Limited by M/s Black Diamond Minerals Pvt. Ltd.; dated
21/12/2007
/29/ Third party lab test report by M/s Lab Equipments Calibration
Centre dated 24/12/2007 for the determination of the calorific
value of the rice husk contracted by M/s SEL Manufacturing

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Company Limited
/30/ Third party lab test report by M/s Lab Equipments Calibration
Centre dated 24/12/2007 for the determination of the calorific
value of the coal contracted by M/s SEL Manufacturing Company
Limited
/31/ W holesale Price Index for the “coal” commodity published by the
Office of the Economic Advisor (Government of India) for Jan.
2007 to Dec. 2007 available at the website http://eaindustry.nic.in/
/32/ Punjab State Electricity Board (state government utility company)
electricity bill dated 12/01/2008 for the month of Dec. 2007
/33/ Punjab State Electricity Board (state government utility company)
electricity bill dated 12/01/2006 for the month of Dec. 2005
/34/ Punjab State Electricity Board (state government utility company)
electricity bill dated 12/01/2007 for the month of Dec. 2006
/35/ W eekly Statistical Supplement published by Reserve Bank of India
dated 01/02/2008 specif ying the prime lending rates of the five
major banks of India from 28 t h Dec. 2007 to 18 t h Jan 2008 between
the range of 12.75% to 13.25%
/36/ Annual Report of the Reserve Bank of India for the financial year
2006-07 published on 30/08/2007
/37/ Rajasthan Electricity Regulatory Commission Tariff order for wind
and biomass projects published on 15/03/2007
/38/ Techno-commercial proposal of 20TPH low pressure boiler from
M/s Cethar Vessels Limited to the project participant dated
10/11/2007 bearing reference no. CVL/RD/RSS/07
/39/ Techno-commercial proposal for the balance of the plant for
20TPH low pressure boiler from M/s Cethar Vessels Limited to the
project participant dated 10/11/2007 bearing reference no.
CVL/RD/2533/07
/40/ Petcoke supply quotation provided to M/s SEL Manufacturing
Company Limited by M/s Ek Onkar Trading Company, dated
13/12/2007; reference no. EOTC-QUT/10/0113

Categor y 2 Documents:
Background documents related to the design and/or methodologies
employed in the design or other reference documents.

B/1/ Validation and Verification Manual, version 1.2, EB 55


B/2/ Guidelines For Completing The Simplified Project Design
Document (CDM-SSC-PDD) and the form for Proposed New
Small Scale Methodologies (CDM-SSC-NM) – Version 05
B/3/ Project design document form (CDM-SSC-PDD) - Version 03
B/4/ Guidelines on Assessment of Debundling for SSC project
activities(EB 54/Annex 13)
B/5/ AMS I.C., Version 19 - Thermal energy production with or without
electricity
B/6/ General guidance on leakage in biomass project activities (EB

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47/ Annex 28)


B/7/ General guidelines to SSC CDM methodologies version 17( EB
61/Annex 21)
B/8/ Attachment A to Appendix B of Simplified modalities and
procedures for small scale CDM project activities( EB 63/Annex
24)
B/9/ Tool to calculate baseline, project and/or leakage emissions from
electricity consumption version 01 (EB 39/Annex 7)
B/10/ Tool to calculate project or leakage CO2 emissions from fossil
fuel combustion version 02 (EB 41/Annex 11)
B/11/ Tool to calculate Project and leakage emissions from road
transportation of freight (EB 63/Annex 10)
B/12/ Guidance on the Assessment of Investment Analysis, Version 05,
EB 62/Annex 5
B/13/ Tool to calculate the emission factor for an electricity system,
version 02.2.1
B/14/ AMS I.C., Version 17 - Thermal energy production with or without
electricity
B/15/ Guidelines on the demonstration of and assessment of prior
consideration of the CDM, approved in Executive Board Meeting
Report 62, Annexure 13

Persons interviewed:
List persons interviewed during the validation or persons that contributed
with other information that are not included in the documents listed above.
/1/ Mr. K.S. Bedi (General Manager, Power Plant) – SEL
Manufacturing Company Limited
/2/ Mr. Joginder Singh, Farmer, Shekhon Mazara
/3/ Mr. Pratik Sharma, Consultant, E&Y India
/4/ Mr. Atin Prakash, Sr. Consultant E&Y India

1. o0o -

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7 CURRICULA VITAE OF THE DOE’S VALIDATION TEAM


MEMBERS

Mr. Bhavesh Prajapati, Team Leader


Bureau Veritas Certification, Lead Verifier – Climate Change
Graduate in the field of Chemical Engineering and post graduate in
finance (MBA-Finance). He has more than 8 years of Industrial work
experience in the field of environment audits, consultancy of HVAC
(pharmaceutical industry as well as commercial air conditioning) and
utility services and project management of various Greenfield as well as
gray field projects. He has undergone lead verifier's t raining on Clean
Development Mechanism. He is involved in the validation/verification
projects of CDM and VCS.

Mr. Anupam Badola, Team Member


Bureau Veritas Certification, Lead Verifier – Climate Change
Post Graduate in Environmental Science with five years of work
experience in climate change services. He has previously worked with a
manufacturing organisation and a carbon advisory firm in India on CDM
project development, CDM project due diligence, stack, ambient air
pollution monitoring, water pollution monitoring, etc. He has undergone
intensive training on Clean Development Mechanism and involved in the
Validation and verification of CDM/VCS projects.

H.B. Muralidhar, Internal Technical Review er


Bureau Veritas Certification, General Manager - Climate Change Services
Lead auditor in Bureau Veritas Certification for Environment Management
System, Quality Management System and Occupational Health and Safety
Management System. Graduate in Electrical Engineering with 25 years of
experience power generation and distribution relate
d fields as well as in management system auditing. He is the Lead auditor
for Environmental Management System, Quality Management system and
Occupational Health and Safety Management System. He has undergone
intensive training on Clean Development Mechanism. He is the technical
expert & conducted Validation / Verification for more than 50 CDM
Projects.

2. o0o -

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APPENDIX A: SEL MANUFACTURING COMPANY LIMITED CDM PROJECT VALIDATION PROTOCOL
Table 1 Validation requirements based on the Clean Development Mechanism Validation and Verification Manual
(Version 01.2) and methodology AMS-I.C (Version 19) – “Thermal energy production with or without electricity”

Draft Final
CHECKLIST QUESTION Ref. § COMMENTS
Concl Concl
1. Approval COUNTRY A COUNTRY B
(India) (Not applicable)
a. Have all Parties involved approved the project VVM 44 Yes, the project activity Not applicable OK OK
activity? has been approved by
the national CDM
authority of India
(designated national
authority of India)
b. Has the DNA of each Party indicated as being VVM 45 Yes, the NCDMA has Not applicable OK OK
involved in the proposed CDM project activity in provided written letter of
section A.3 of the PDD provided a writTen letter approval (through letter
of approval? (If yes, provide the reference of the reference no 4/19/2009-
letter of approval, any supporting documentation, CCC; dated 19th June
and specify if the letter was received from the 2010). The letter has
project participatn or directly from the DNA) been provided to DOE.
c. Does the letter of approval from DNA of each VVM 45 -
Party involved:
i. confirm that the Party is a Party of the Kyoto VVM 45.a Yes, the NCDMA has Not applicable OK OK
Protocol? provided written letter of
approval (through letter
reference no 4/19/2009-
CCC; dated 19th June
2010). The National
CDM Authority of India

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confirms that India is
party of the Kyoto
Protocol.
ii. confirm that participation is voluntary? VVM 45.b Yes, the NCDMA has Not applicable OK OK
provided written letter of
approval (through letter
reference no 4/19/2009-
CCC; dated 19th June
2010). The National
CDM Authority of India
confirms that
participation is
voluntary.
iii. confirm that, in the case of the host Party, the VVM 45.c Yes, the NCDMA has Not applicable OK OK
proposed CDM project activity contributes to provided written letter of
the sustainable development of the country? approval (through letter
reference no 4/19/2009-
CCC; dated 19th June
2010), the National
CDM Authority of India
confirms that proposed
CDM project activity
contributes to the
sustainable
development of the
country.
iv. Refers to the precise proposed CDM project VVM 45.d The title of the project Not applicable OK OK
activity title in the PDD being submitted for activity, as specified in
registration? the web-hosted PDD is

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“10 MW Biomass based
power plant in Punjab,
India”. The title of the
project activity matches
with the project title
provided in the host
country approval letter.
d. Is(are) the letter(s) of approval unconditional with VVM 46 Yes, the letter is Not applicable OK OK
respect to (i) to (iv) above? unconditional with
respect to 1.(i) and 1.(iv)
above.
e. Has(ve) the letter(s) of approval been issued by VVM 47 Yes, the letter has been Not applicable OK OK
the respective Party’s designated national issued by National CDM
authority (DNA)? Authority (DNA of India).
f. If there is doubt with respect to (e) above, was VVM 47 The letter has been Not applicable OK OK
verified with the DNA that the letter of approval is cross-checked with the
valid for the proposed CDM project activity under information available on
validation? the website of National
CDM Authority and
found correct.
g. Is there doubt with respect to the authenticity of VVM 48 The letter has been Not applicable OK OK
the letter of approval? cross-checked with the
information available on
the website of National
CDM Authority and
found correct.
h. If yes, was verified with the DNA that the letter of VVM 48 The letter has been Not applicable OK OK
approval is authentic? cross-checked with the
information available on

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the website of National
CDM Authority and
found correct.
2. Participation PP1 (SEL PP2 (Not applicable, as
Manufacturing Company there is only one project
Limited) participant)
a. Have all project participants been listed in a VVM 51 There is only one Not applicable OK OK
consistent manner in the project documentation? project participant in this
project activity. The
project participant has
been consistently listed
in section A.3; B.8 and
Annex 1 of the PDD.
b. Has the participation of the project participants in VVM 51 Yes, the participation of Not applicable OK OK
the project activity been approved by a Party to the PP has been
the Kyoto Protocol? approved by National
CDM Authority of India,
which is a party to Kyoto
Protocol.
c. Are the project participants listed in tabular form VVM 52 The project participant OK OK
in section A.3 of the PDD? (SEL Manufacturing
Company Limited) has
been listed in tabular
form in section A.3 of
the PDD.
d. Is the information in section A.3 consistent with VVM 52 Yes, the project Not applicable OK OK
the contact details provided in annex 1 of the participant has been
PDD? listed in a consistent
manner in the PDD.

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e. Has the participation of each of the project VVM 52 Yes, the participation of Not applicable OK OK
participants been approved by at least one Party the project participant
involved, either in a letter of approval or in a has been approved by
separate letter specifically to approve National CDM Authority
participation? (Provide reference of the approval of India, which is a party
document for each of the project participants) to Kyoto Protocol.
f. Are any entities other than those approved as VVM 52 Entity, other than those approved, as project OK OK
project participants included in these sections of participant has not been listed in section A.3 and
the PDD? Annex. 1 of the PDD.
g. Has the approval of participation issued from the VVM 53 Yes, the participation of Not applicable OK OK
relevant DNA? the PP has been
approved by National
CDM Authority of India,
which is a party to Kyoto
Protocol.
h. Is there doubt with respect to (g) above? VVM 53 The letter has been Not applicable OK OK
cross-checked with the
information available on
the website of National
CDM Authority and
found correct.
i. If yes, was verified with the DNA that the VVM 53 The letter has been Not applicable OK OK
approval of participation is valid for the proposed cross-checked with the
project participant? information available on
the website of National
CDM Authority and
found correct.
3. Project desing document
a. Is the PDD used as a basis for validation VVM 55 Yes, the project participant has used latest available OK OK

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prepared in accordance with the latest template PDD template (version 3 for small scale PDD, in effect
and guidance from the CDM Executive Board from 22nd Dec. 2006). The PDD completeness
available on the UNFCCC CDM website? guidance used by project participant is also the latest
one (EB 34, Annex 09).
b. Is the PDD in accordance with the applicable VVM 56 No, some sections of the PDD are not in accordance OK OK
CDM requirements for completing the PDD? with the applicable CDM requirements for completing
the PDD. Section 3 of this protocol, in Table 1,
provides detailed analysis of the PDD as per the PDD
completeness requirements as per version 5 of small-
scale PDD guidelines.
c. In CDM-SSC-PDD section A.1 are following EB Ann
provided? 34 09
i. Title of project EB Ann Yes. Project title has been provided as “10 MW OK OK
34 09 Biomass based power plant in Punjab, India”
ii. Current version number and date of document EB Ann Yes, the current version and date has been provided OK OK
34 09 as “01” and “11/06/2010” respectively.
d. In CDM-SSC-PDD section A.2 are following EB Ann
provided (max. one page)? 34 09
i. A brief description of the project activity EB Ann Project participant has provided description in brief on OK OK
covering purpose which includes the scenario 34 09 purpose, pre-project scenario and project scenario.
existing prior to the start of project, present
scenario and baseline.
ii. Explanation how the GHG emission reductions EB Ann Yes, explanation has been provided on how GHG OK OK
are effected 34 09 emission reductions are affected.
iii. The PP’s view on the contribution of project EB Ann Please explain the last sentence of section Economic CAR-1 OK
activity to sustainable development 34 09 well being “Hence project contributes to the economic
sustainability around the plant site, which helps in
decentralization of economic power”. In section A.2,
under environmental well being, please explain what

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precautions have been taken during plant designing
so that it does not affect the ecology. Provide the
supporting documents.
The description on technological well being is not in
line with the guidelines provided by the NCDMA.
e. In CDM-SSC-PDD section A.3 are following EB Ann
provided in the tabular format? 34 09
i. List of project participants and Party(ies) EB Ann Yes, “SEL Manufacturing Company Limited” has been OK OK
34 09 listed as project participant in section A.3 of the PDD.
ii. Identification of host party EB Ann Yes, Government of India has been identified as host OK OK
34 09 party.
iii. Indication whether the Party wishes to be EB Ann Yes, it has been indicated that party does not wish to OK OK
considered as project participant 34 09 be considered as project participant.
f. In CDM-SSC-PDD section A.4.1 are following EB Ann
provided? 34 09
i. Technical description, location, host party(ies) EB Ann Yes, technical description location and host party OK OK
and address as required? 34 09 provided.
ii. Detailed physical location with unique EB Ann Yes, the project participant has provided lat-long of CAR-2 OK
identification of the project activity (eg. 34 09 the project location. However section A.4.1.4 has not
Longitude/latitude) – not to exceed one page been restricted to one page (requirement of CDM
PDD completeness guidelines, version 5, 14th Sept.
2007). Further, the lat-long of the project activity is not
referenced to the source.
g. In CDM-SSC-PDD section A.4.2 are following EB Ann
provided 34 09
i. the list of categoreis of project activities as per EB Ann Project participant has not provided the “type” and CAR-3 OK
the latest categorization of Appendix B to to the 34 09 “category” as per the CDM PDD small-scale PDD
simplified modalities and procedures for small- guidelines (version 5) in section A.4.2 of the PDD.
scale CDM project activities, hereafter referred Also, it is not in accordance with Appendix B of

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to as Appendix B. (refer simplified modalities and procedure of small-scale
http://cdm.unfccc.int/methodologies/SSCmetho project activity. The complete and explicit technical
dologies details of boiler and turbine, which are main project
activity equipments, have not been provided in section
A.4.2 of the PDD.
ii. A description of how environmentally safe and EB Ann As per PDD there is no technology transfer in the OK OK
sound technology and know how is being 34 09 project activity.
applied by the project activity interalia
technology transfer to the Host Party(ies) for
application in the project activity
h. In CDM-SSC-PDD section A.4.3 is the estimation EB Ann The estimation of emission reductions provided has CAR-4 OK
of emission reductions provided, as requested, in 34 09 been presented by PP in tabular format. The rows and
a tabular format? column headings are consistent with small-scale PDD
guidelines (EB 34, Annex 09).
However, the crediting period for which the emission
reduction is estimated has not been indicated, which
is not in accordance with small-scale PDD guidelines
(EB 34, Annex 09) in Section A.4.3 of the web hosted
PDD.
i. In CDM-SSC-PDD section A.4.4 is information EB Ann Yes, as per PDD no public funding involved in this OK OK
regarding Public funding provided? 34 09 project activity.
j. In CDM-SSC-PDD section A.4.5 are following EB Ann
provided? 34 09
i. Confirmation that the small-scale project activity EB Ann The project participant has provided description on the CAR-5 OK
is not a debundled component of a large scale 34 09 confirmation on debundling. However, from the
project activity. description, it is not clear whether project participant
has any application to register a CDM project activity
or in advanced stage of CDM validation. The
description is incomplete to conclude that project

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activity is not a de-bundled component of a large
project activity.
ii. Indication if there is a registered small-scale EB Ann The project participant has provided description on the CAR-5 OK
project activity under the CDM or an application 34 09 confirmation on de-bundling. However, from the
to register another small-scale project activity description, it is not clear whether project participant
under the CDM has any application to register a CDM project activity
or in advanced stage of CDM validation. The
description is incomplete to conclude that project
activity is not a de-bundled component of a large
project activity.
a. With the same project participants EB Ann The project participant has provided description on the CAR-5 OK
34 09 confirmation on de-bundling. However, from the
description, it is not clear whether project participant
has any application to register a CDM project activity
or in advanced stage of CDM validation. The
description is incomplete to conclude that project
activity is not a de-bundled component of a large
project activity.
b. Registered within the period of 2 years EB Ann The project participant has provided description on the CAR-5 OK
34 09 confirmation on de-bundling. However, from the
description, it is not clear whether project participant
has any application to register a CDM project activity
or in advanced stage of CDM validation. The
description is incomplete to conclude that project
activity is not a de-bundled component of a large
project activity.
c. Whose project boundary is within 1 km of EB Ann The project participant has provided description on the CAR-5 OK
the project boundary of the proposed 34 09 confirmation on de-bundling. However, from the
small-scale activity under the CDM at the description, it is not clear whether project participant

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closest point. has any application to register a CDM project activity
or in advanced stage of CDM validation. The
description is incomplete to conclude that project
activity is not a de-bundled component of a large
project activity.
k. In CDM-SSC-PDD section B.1 is the approved EB Ann The title and reference of the approved baseline and CAR-6 OK
baseline and monitoring methodology and 34 09 monitoring methodology have not been provided
version no provided? correctly in Section B.1 of the web hosted PDD.
l. In CDM-SSC-PDD section B.2 are the following EB Ann - -
provided? 34 09
i. Justification of the choice of project activity and EB Ann Yes, justification of the choice of the project category OK OK
category? 34 09 has been provided.
ii. Demonstration that the project activity qualifies EB Ann The demonstration of project activity qualifying as OK OK
as a small-scale project activity and that it will 34 09 small scale CDM project has been provided (Type I
remain under the limits of small-scale project project).
activity types during every year of the crediting
period as per the following:For Type I : the
capacity of the proposed project activity will not
exceed 15 MW (or an appropriate equivalent);
For Type II: the annual energy savings on
account of efficiency improvements will not
exceed 60 GWh (or an appropriate equivalent)
in any year of the crediting period; For Type III:
the estimated emission reductions of the project
activity will not exceed 60 ktCO2e in any year
of the crediting period.
m. In CDM-SSC-PDD section B.3 is the project EB Ann Yes, the project boundary of the project activity, based OK OK
boundary of the project activity, based on the 34 09 on the guidance of the applicable project category,
guidance of the applciable project category, has been provided.

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provided?
n. In CDM-SSC-PDD section B.4 are following EB Ann
provided? 34 09
i. The baseline for the proposed project activity EB Ann Yes, the project participant has provided the OK OK
with reference to the chosen project category 34 09 description on the baseline as per the chosen project
category.
ii. Justification of key assumptions and rationales EB Ann The justification for key assumption and rationales has OK OK
34 09 been provided.
iii. Transparent illustration of all data used to EB Ann In section B.4, the project participant has provided CAR-7 OK
determine the baseline emissions (variables, 34 09 NCV and cost of pet coke and coal. However, the data
parameters, data sources etc) sources have not been specified.
o. In CDM-SSC-PDD section B.5 are following EB Ann
provided? 34 09
i. Explanation that the proposed project activity is EB Ann Yes, project participant has demonstrated additionality OK OK
additional as per options provided under 34 09 as per options provided under Attachment A to
Attachment A to Appendix B of the simplified Appendix B of the simplified modalities and
modalities and procedures for small-scale CDM procedures for small-scale CDM project activities.
project activities
ii. National policies and circumstances relevant to EB Ann In section B.5, PDD is silent upon national policies CAR-8 OK
the baseline of the proposed project activity 34 09 and circumstances relevant to the baseline of the
proposed project activity. Project participant to clarify
how national policies and circumstances have been
taken into account on establishment of the baseline
scenario as per EB 22, Annex 3.
iii. Evidence that the incentive from the CDM was EB Ann Yes, the project participant has provided the OK OK
seriously considered in the decision to proceed 34 09 chronology of events to secure CDM revenues in
with the project activity, if the starting date of parallel to the project implementation.
the project activity is before the date of
validation. (this is part of the large scale project

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guidelines. It is better to be retained)
p. In CDM-SSC-PDD section B.6.2 are following EB Ann -
provided? 34 09
i. A compilation of information on the data and EB Ann In section B.6.2 of the web hosted PDD, the project CAR-9 OK
parameters that are not monitored but 34 09 participant has not clearly addressed the data and
determined upfront so as to be available for parameters that are not monitored but determined
validation. upfront so as to be available for validation.
ii. The actual value applied. EB Ann In section B.6.2 of the web hosted PDD, the project CAR-9 OK
34 09 participant has not clearly addressed the data and
parameters that are not monitored but determined
upfront so as to be available for validation.
iii. Explaination and justification for the choice of EB Ann In section B.6.2 of the web hosted PDD, the project CAR-9 OK
the source of data. 34 09 participant has not clearly addressed the data and
parameters that are not monitored but determined
upfront so as to be available for validation.
iv. Clear and transparent references or additional EB Ann In section B.6.2 of the PDD, the project participant has not- clearly -addressed th
documentation in Annex 3 34 09 monitored but determined upfront so as to be available for validation.
v. Where values have been measured, a EB Ann In section B.6.2 of the PDD, the project participant has CAR-9 OK
description of the measurement methods and 34 09 not clearly addressed the data and parameters that
procedures (e.g. which standards have been are not monitored but determined upfront so as to be
used), indicated the responsible person/entity available for validation.
having undertaken the measurement, the date
of measurement(s) and the measurement
results
q. In CDM-SSC-PDD section B.6.3 are following EB Ann - -
provided? 34 09
i. A transparent ex ante calculation of project EB Ann In section B.6.3, the ex ante calculation of emission CAR-10 OK
emissions, baseline emissions (or, where 34 09 reductions, baseline emissions, leakage emissions,
applicable, direct calculation of emission etc. have not been presented in a manner that

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reductions) and leakage emissions expected enables the reader to reproduce the calculations.
during the crediting period, applying all relevant Project participant has applied equation 3 of the
equations provided in the approved methodology AMS I C, Version 17. However, it is not
methodology explicitly provided how parameters EGpjthermal and
EGpjelectrical have been computed for the purpose of
computing baseline emissions.
ii. Documentation how each equation is applied, EB Ann In section B.6.3, the ex ante calculation of emission CAR-10 OK
in a manner that enables the reader to 34 09 reductions, baseline emissions, leakage emissions,
reproduce the calculation etc. have not been presented in a manner that
enables the reader to reproduce the calculations.
Project participant has applied equation 3 of the
methodology AMS I C, Version 17. However, it is not
explicitly provided how parameters EGpjthermal and
EGpjelectrical have been computed for the purpose of
computing baseline emissions.
iii. Additional background information and or data EB Ann In section B.6.3, the ex ante calculation of emission CAR-10 OK
in Annex 3, including relevant electronic files 34 09 reductions, baseline emissions, leakage emissions,
(i.e. spreadsheets) etc. have not been presented in a manner that
enables the reader to reproduce the calculations.
Project participant has applied equation 3 of the
methodology AMS I C, Version 17. However, it is not
explicitly provided how parameters EGpjthermal and
EGpjelectrical have been computed for the purpose of
computing baseline emissions.
iv. Emission reduction calculations for each EB Ann In section B.6.3, the ex ante calculation of emission CAR-10 OK
component are provided separately if more 34 09 reductions, baseline emissions, leakage emissions,
than one component activity is applied etc. have not been presented in a manner that
enables the reader to reproduce the calculations.
Project participant has applied equation 3 of the

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methodology AMS I C, Version 17. However, it is not
explicitly provided how parameters EGpjthermal and
EGpjelectrical have been computed for the purpose of
computing baseline emissions.
r. In CDM-SSC-PDD section B.6.4 are the results of EB Ann The ex ante determination of the emission reductions CAR-11 OK
the ex ante estimation of emission reductions for 34 09 in section B.6.4 have not been provided as per the
all years of the crediting period, in a tabular prescribed format of the small-scale PDD
format, provided? completeness guidelines (version 5, 14th Sept. 2007).
s. In CDM-SSC-PDD section B.7.1 are following EB Ann
provided? 34 09
i. Specific information on how the data and EB Ann Yes, the information has been provided on how data OK OK
parameters that need to be monitored would 34 09 and parameters that need to be monitored would
actually be collected during monitoring for the actually be collected during monitoring for the project
project activity activity
ii. For each below parameter the following EB Ann - -
information, using the table provided: 34 09
a. The source(s) of data that will be actually EB Ann The specific data source for parameters presented in CAR-12 OK
used for the proposed project activity (e.g. 34 09 section B.7.1 has not been identified and the accuracy
which exact national statistics). Where of the measurement method has not been specified
several sources may be used, explain and for the measured parameters in section B.7.1 of the
justify which data sources should be PDD. The monitoring plan in section B.7.2 refers to
preferred the Annex 4 of the PDD. However, there is no
information in Annex 4 of the PDD.
b. Where data or parameters are supposed to EB Ann The specific data source for parameters presented in CAR-12 OK
be measured, specify the measurement 34 09 section B.7.1 has not been identified and the accuracy
methods and procedures, including a of the measurement method has not been specified
specification which accepted industry for the measured parameters in section B.7.1 of the
standards or national or international PDD. The monitoring plan in section B.7.2 refers to
standards will be applied, which the Annex 4 of the PDD. However, there is no

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measurement equipment is used, how the information in Annex 4 of the PDD.
measurement is undertaken, which
calibration procedures are applied, what is
the accuracy of the measurement method,
who is the responsible person/entity that
should undertake the measurements and
what is the measurement interval; (i) A
description of the QA/QC procedures (if
any) that should be applied; (ii) Where
relevant: any further comment. Provide any
relevant further background documentation
in Annex 4.
iii. A detailed description of the monitoring plan. EB Ann
34 09
a. The operational and management EB Ann Yes, the operational and management structure has OK OK
structure that the project operator will 34 09 been presented in Annex 4 of the PDD.
implement in order to monitor emission
reductions and any leakage effects
generated by the project activity.
b. Thes responsibilities for and institutional EB Ann Yes, the institutional arrangements and OK OK
arrangements for data collection and 34 09 responsibilities for data collection and archiving have
archiving. been presented in section B.7.2 of the PDD.
c. Does the monitoring plan reflect good EB Ann The monitoring plan described does not include CAR-13 OK
monitoring practice appropriate to the type 34 09 various requirements to be met for monitoring of such
of project activity. project activity. These inadequacies are also detailed
in Section 7 of Table 1 of this protocol below.
d. Relevant further background information EB Ann The monitoring plan in section B.7.2 refers to the CAR-12 OK
in Annex 4. 34 09 Annex 4 of the PDD. However, there is no information
in Annex 4 of the PDD.

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t. In CDM-SSC-PDD section B.8 are following EB Ann - -
provided 34 09
i. Date of completion of the application of the EB Ann Yes, provided in DD/MM/YYYY format. OK OK
methodology to the project activity study in 34 09
DD/MM/YYYY
ii. Contact information of the person(s)/entity(ies) EB Ann Yes, it has been indicated that entity responsible for OK OK
responsible for the application of the baseline 34 09 application of baseline and monitoring methodology is
and monitoring methodology to the project also a project participant listed in Annex 1 of the PDD
activity and the contact information has been provided in
Annex 1 of the PDD.
iii. Indicated if the person/entity is also a project EB Ann Yes, it has been indicated that entity responsible for OK OK
participant listed in Annex 1 34 09 application of baseline and monitoring methodology is
also a project participant listed in Annex 1 of the PDD.
u. In CDM-SSC-PDD section C.1.1 are following EB Ann - -
provided? 34 09
i. The starting date of a CDM project activity is EB Ann The start date provided in section C.1.1 meets the OK OK
the earliest of the date(s) on which the 34 09 criteria of start date of project activity as per CDM
implementation or construction or real action of glossary of terms.
a project activity begins/has begun (EB33, Para
76/CDM Glossary of terms/EB41, Para 67)
ii. A description of how this start date has been EB Ann Yes, the start date has been taken on the basis of the OK OK
determined, and a description of the evidence 34 09 date of the boiler purchase order.
available to support this start date
iii. If this starting date is earlier than the date of EB Ann The start date of the project activity is prior to the OK OK
publication of the CDM-SSC-PDD for global 34 09 publication of the CDM-SSC-PDD for global
stakeholder consultation by a DOE, does stakeholder consultation by a DOE. The PP has
Section B.5 above contain a description of how provided the description of how the benefits of the
the benefits of the CDM were seriously CDM were seriously considered prior to the starting
considered prior to the starting date (EB41, date in section B.5 of the PDD.

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Para 68).?
v. In CDM-SSC-PDD section C.1.2 is the expected EB Ann Yes, expected lifetime of project activity is indicated OK OK
operational lifetime of the project activity in years 34 09 as 25 years and 0 months.
and months provided?
w. In CDM-SSC-PDD section C.2 is it statet whether EB Ann Yes, as per PDD, fixed crediting period of 10 years OK OK
the project activity will use a renewable or a fixed 34 09 has been selected by the project participant (PP).
crediting period and completed C.2.1 or C.2.2
accordingly?
x. In CDM-SSC-PDD section C.2.1 is it indicated EB Ann Not applicable as fixed crediting period has been OK OK
thath each crediting period shall be at most 7 34 09 chosen by PP.
years and may be renewed at most two times,
provided that, for each renewal, a designated
operational entity determines and informs the
Executive Board that the original project baseline
is still valid or has been updated taking account
of new data where applicable?
y. In CDM-SSC-PDD section C.2.1.1 are the dates EB Ann Not applicable as fixed crediting period has been OK OK
in the following format: (DD/MM/YYYY) provided? 34 09 chosen by PP.
z. In CDM-SSC-PDD section C.2.1.2 is the length of EB Ann Not applicable as fixed crediting period has been OK OK
the first crediting period in years and months? 34 09 chosen by PP.
aa. In CDM-SSC-PDD section C.2.2 is it indicated EB Ann As per PDD, fixed crediting period of 10 years has OK OK
fixed crediting period at most ten (10) years 34 09 been selected by the project participant (PP).
bb. In CDM-SSC-PDD section C.2.2.1 are the dates EB Ann Yes, mentioned in DD/MM/YYYY format. OK OK
in the format (DD/MM/YYYY) provided? 34 09
cc. In CDM-SSC-PDD section C.2.2.2 is the length of EB Ann Yes, length of crediting period is mentioned as 10 OK OK
the crediting period in years and months 34 09 years and 0 months.
provided?
dd. In CDM-SSC-PDD section D.1 is the EB Ann The project participant has submitted a letter from OK OK
documentation on the analysis of the 34 09 state expert appraisal committee, Punjab (letter ref.

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environmental impacts, if required by Host Party, No SEAC/128/6396; dated 20/02/2009). As per the
provided? above-referenced letter, the project activity has been
categorized as B-1 and requires environmental impact
assessment to be carried out prior to the construction.
Project participant it has been reviewed during site
visit that PP has received a letter from MOEF vide
reference no. SEILL/2010/6717 dated 11/02/2010,
which states that the said project activity is exempted
from EIA.
ee. In CDM-SSC-PDD section E.1 are following EB Ann - -
provided? 34 09
i. The process by which comments by local EB Ann The process of stakeholder consultation has been CL-1 OK
stakeholders have been invited and compiled. 34 09 explained. As per PDD, the invitations were sent on
An invitation for comments by local 08/07/2009 and stakeholder meeting took place on
stakeholders shall be made in an open and 13/07/2009. Project participant to clarify following:
transparent manner, in a way that facilities a) How PP has considered that time provided for
comments to be received from local stakeholder consultation is reasonable?
stakeholders and allows for a reasonable time b) The description in section E.1 of the PDD does
for comments to be submitted. not provide description on how stakeholders
were identified
c) How project activity has been described in a
manner, which allows the local stakeholders to
understand the project activity, taking into
account confidentiality provisions of the CDM
modalities and procedures?
ii. The project activity is described in a manner, EB Ann The process of stakeholder consultation has been CL-1 OK
which allows the local stakeholders to 34 09 explained. As per PDD, the invitations were sent on
understand the project activity, taking into 08/07/2009 and stakeholder meeting took place on
account confidentiality provisions of the CDM 13/07/2009. Project participant to clarify following:

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modalities and procedures a) How PP has considered that time provided for
stakeholder consultation is reasonable?
b) The description in section E.1 of the PDD does
not provide description on how stakeholders
were identified
c) How project activity has been described in a
manner, which allows the local stakeholders to
understand the project activity, taking into
account confidentiality provisions of the CDM
modalities and procedures?
iii. The local stakeholder process has been EB Ann Yes, the stakeholder meeting has been completed OK OK
completed before submitting the proposed 34 09 before submitting the proposed project activity to the
project activity to the DOE for validation DOE for validation.
ff. In CDM-SSC-PDD section E.2 are following EB Ann - -
provided? 34 09
i. Local stakeholders that have made comments EB Ann Project participant has not identified the local CAR-14 OK
identified 34 09 stakeholders who made the comments in section E.2
of the PDD. Besides, the summary of the comments
has not been presented clearly.
ii. A summary of these comments EB Ann Project participant has not identified the local CAR-14 OK
34 09 stakeholders who made the comments in section E.2
of the PDD. Besides, the summary of the comments
has not been presented clearly.
gg. In CDM-SSC-PDD section E.3 is and explanation EB Ann As per PDD, there were no negative comments by OK OK
of how due account have been taken of 34 09 local stakeholders. This was further crosschecked by
comments received from local stakeholders DOE during validation site visit after meeting the local
provided? stakeholders.
hh. In CDM-SSC-PDD Annex 1 are following EB Ann - -
provided? 34 09

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i. Contact information of project participants EB Ann Yes, the contact information has been provided. OK OK
34 09
ii. For each organisation listed in section A.3 the EB Ann Contact details have been provided as per the OK OK
following mandatory fields: Organization, Name 34 09 requirements of Annex 1 of the PDD.
of contact person, Street, City, Postfix/ZIP,
Country, Telephone and Fax or e-mail
ii. In CDM-SSC-PDD Annex 2 is information from EB Ann As per PDD, no public funding is involved in the OK OK
Parties included in Annex I on sources of public 34 09 project activity. The same has been stated in Annex 2
funding for the project activity which shall provide of the PDD.
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 those Parties
provided?
jj. In CDM-SSC-PDD Annex 3 is the background EB Ann As per Annex 3 of the PDD, the baseline information OK OK
information used in the application of the baseline 34 09 has been provided in section B.4 and B.6.1 of the
methodology provided? PDD.
kk. In CDM-SSC-PDD Annex 4 is the background EB Ann As per PDD, the monitoring plan has been discussed OK OK
information used in the application of the 34 09 in section B.7.2 of the PDD.
monitoring methodology provided?
4. Project description
a. Does the PDD contain a clear description of the VVM 58 The validation team observed during site visit that the CAR-15 OK
project activity that provides the reader with a manufacturing units viz; Spinning unit was in
clear understanding of the precise nature of the operation since March 2008 and Terri Towel unit was
project activity and the technical aspects of its operationalised in November 2008 and March 2009 in
implementation? two phases. prior to the commissioning of the 10MW
biomass based power plant. The electricity
requirements of the plant are being met through grid
power. It has been further observed that project

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participant has synchronized the power plant with grid
and in future, excess electricity (after meeting the
captive consumption) may be sold to the grid. The PP
has also availed relevant statutory approval from
PEDA (Punjab Energy Development Authority) on
13/05/2010 for entering in to PPA with state electricity
utility. It was also observed by the validation team that
there were two sources including 5 TPH fossil fuel
based boiler and 15 Lac Kcal/Hr Thermopack to meet
thermal energy requirement of manufacturing units
prior to implementation of project activity.
The project description is not transparently provided
with respect to the above-mentioned observations of
the project implementation.
b. Is the description of the proposed CDM project VVM 59 - -
activity as contained in the PDD:
i. sufficiently covering all relevant elements? VVM 59 The Pre-project scenario of the project activity is not CAR-15 OK
correctly described in accordance with site
observations as mentioned above in CAR-15.
ii. acurate? VVM 59 The Pre-project scenario of the project activity is not CAR-15 OK
correctly described in accordance with site
observations as mentioned above in CAR-15.
iii. providing the reader with a clear understanding VVM 59 The Pre-project scenario of the project activity is not CAR-15 OK
of the nature of the proposed CDM project correctly described in accordance with site
activity? observations as mentioned above in CAR-15.
c. Is the proposed CDM project activity in existing VVM 60 No, the proposed project activity is a Greenfield OK OK
facilities or or utilizing existing equipments? biomass based cogeneration unit.
d. Is the CDM project activity one of the following VVM 60 - -
types:

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i. Large scale? VVM 60 No, the project activity is a small-scale project. OK OK
ii. Non-bundled small scale projects with emission VVM 60 The project activity is a non-bundled project with OK OK
reductions exceeding 15,000 tonnes per year? estimated emission reductions more than
15ktonnes/year.
iii. Bundled small scale projects, each with VVM 60 The project activity is a non-bundled project with OK OK
emission reductions not exceeding 15,000 estimated emission reductions more than
tonnes? 15ktonnes/year.
e. If yes to (c) and (d) above, was a physical site VVM 60 Yes, the site visit has been carried out by two-member OK OK
inspection conducted to confirm that the validation team from 26th August 2010 to 28th August
description in the PDD reflects the proposed 2010.
CDM project activity, unless other means are
specified in the methodology?
f. If yes to (d.iii) above, was the number of physical VVM 60 No, since the project is not a bundled project activity, OK OK
site visits base on sampling? sampling was not applicable.
g. If yes is the sampling size appropriately justified VVM 60 No, since the project is not a bundled project activity, OK OK
through statistical analysis? sampling was not applicable.
h. For other individual proposed small scale CDM VVM 61 Yes, the site visit has been carried out by two-member OK OK
project activities with emission reductions not validation team from 26th August 2010 to 28th August
exceeding 15,000 tonnes per year, was a 2010.
physical site inspection conducted?
i. For all other proposed CDM project activities not VVM 62 Yes, the site visit has been carried out by two-member OK OK
referred to in paragraphs 59 – 61, and for other validation team from 26th August 2010 to 28th August
individual proposed small scale CDM project 2010.
activities with emission reductions not exceeding
15,000 tonnes per year, was a physical site
inspection conducted?
j. If no, was it appropriately justified? VVM 62 Not applicable as the site visit was conducted by OK OK
validation team.
k. Does the proposed CDM project activity involve VVM 63 No, the proposed project activity is a greenfield OK OK

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the alteration of an existing installation or biomass based cogeneration unit. Hence, this
process? condition is not applicable.
l. If yes, does the project description clearly state VVM 63 Not applicable as the project activity does not involve OK OK
the differences resulting from the project activity any alteration of an existing equipment.
compared to the pre-project situation?
5. Baseline and monitoring methodology
a. General requirement
a. Do the the baseline and monitoring VVM 65 Yes, the baseline and monitoring methodology OK OK
methodologies selected by the project selected by the project participants is AMS I C,
participants comply with the methodologies Version 17, which is previously approved by the CDM
previously approved by the CDM Executive Executive Board.
Board?
b. Is the selected methodology applicable to the VVM 66 Refer to (5.b.a) below - -
project activity?
c. Had the PP correctly applied the sellected VVM 66 Refer to (5.b.c) below - -
methodology?
d. Had the selected methodology been correctly VVM 67 Refer to (5.c) below - -
applied with respect to project boundary?
e. Had the selected methodology been correctly VVM 67 Refer to (5.d) below - -
applied with respect to baseline identification?
f. Had the selected methodology been correctly VVM 67 Refer to (5.e) below - -
applied with respect to Algorithms and/or
formulae used to determine emission reductions?
g. Had the selected methodology been correctly VVM 67 The methdology AMS I C refers to the Attachment A OK OK
applied with respect to additionality? to appendix B for demonstration of additionality. The
project participant has referred to the same.
h. Had the selected methodology been correctly VVM 67 The project participant has provided monitoring plan OK OK
applied with respect to monitoring methodology? and data parameters to be monitored in accordance
with the methodological requirements. However,

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certain inadequacies of the monitoring sections have
been identified in Section 7 of this protocol.
b. Applicability of the selected methodology to
the project activity
a. Is the selected baseline and monitoring VVM 68 The AMS 1C ver. 17, baseline and monitoring OK OK
methodology, previously approved by the CDM methodology selected by PP, has been previously
Executive Board, applicable to the project approved by the CDM Executive Board and applicable
activity? to the project activity.
b. Is the methodology correctly quoted? VVM 69 The title and reference of the approved baseline and CAR-6 OK
monitoring methodology have not been provided
correctly in Section B.1 of the web hosted PDD.
c. Are the following applicability conditions of the VVM 70 - -
methodology met?
i. Does the project category comprises of AMS 1 Yes, the project activity consists of renewable thermal OK OK
renewable energy technologies that supply IC energy generation for an industrial process, which
users with thermal energy that displaces fossil displaces fossil fuel use.
fuel use? Do they include technologies such as
solar thermal water heaters and dryers, solar
cookers, energy derived from renewable
biomass and other technologies that provide
thermal energy that displaces fossil fuel?
ii. Is the project activiity involve biomass-based AMS 2 The project activity is a biomass-based cogeneration OK OK
co-generating systems that produce heat and IC plant generating thermal energy and power in a single
electricity? Does the project activity generates process.
both thermal energy and electrical and/or
mechanical energy in one process?
iii. If it is a cogeneration system, can emission AMS 3 PDD describes the applicability of option (b) as per CAR-16 OK
reductions be accrued from one of the following IC the applied methodology i.e. Electricity and/or thermal
activities: energy (steam or heat) production for on-site

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a. Electricity supply to a grid; consumption or for consumption by other facilities.
b. Electricity and/or thermal energy (steam However, it was observed during site visit that project
or heat) production for on-site participant aims to export the power generated to
consumption or for consumption by other PSEB grid other than captive consumption. Hence,
facilities; the applicability of option (b) is not correct.
c. Combination of (a) and (b).
iv. Is the total installed/rated thermal energy AMS 4 As demonstrated in the PDD in the justification of CL-2 OK
generation capacity of the project equipment is IC selected methodology, total thermal output of the
equal to or less than 45 MW thermal? (As per project activity is 39.74 MW. Project participant to
condition 6 for the applicable limits for clarify the rationale of pressure considered for
cogeneration project activities). enthalpy of feed water.
a. Is the thermal energy generation AMS 4 Yes, the thermal energy generation capacity, CL-3 OK
capacity determined by taking the IC presented by the project participant is the rated
difference between enthalpy of total capacity of the boiler. The project participant for the
outuput leaving the project equipment purpose of calculation of boiler capacity has also
and the total enthalpy of input entering incorporated the condensate return. Please clarify
the project equipment? (For boilers, how the condensate recovered from the user plants is
condensate return (if any) must be considered. Project participant to clarify what is a
incorporated into enthalpy of the feed. pressure considered for feed water and rationale of
the same for determination of enthalpy.
v. Is it a co-fired systems? If yes, the total AMS 5 It is stated that the project activity is not a co-fired CAR-17 OK
installed thermal energy generation capacity of IC system. The validation team observed during site visit
the project equipment, when using both fossil that the implemented project activity is a multiple fuel-
and renewable fuel shall not exceed 45 MW fired system. Additionally, the project participant has
thermal (Refer to condition 6 for the applicable installed coal feeding system including conveyors,
limits for cogeneration project activities below). coal crushers, coal storage, etc. for coal firing in
project activity in case of exigency. Thus, it is evident
that the project activity is a co-fired system.
vi. Are the following capacity limits applied for AMS 6 As provided in the applicability condition 6, the project CL-4 OK

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biomass co-generation unit? IC activity involves both thermal and electrical energy
a. If the project activity includes emission components and total installed, both thermal and
reductions from both the thermal and electrical energy, generation is 42.25 MW thermal.
electrical energy components, the total However, it is not clearly demonstrated and
installed energy generation capacity substantiated that how 12.25 MW thermal is calculated.
(thermal and electrical) of the project
equipment shall not exceed 45 MW thermal.
For the purpose of calculating this capacity
limit the conversion factor of 1:3 shall be
used for converting electrical energy to
thermal energy (i.e., for renewable project
activities, the maximal limit of 15MW(e) is
equivalent to 45 MW thermal output of the
equipment or the plant);
b. If the emission reductions of the
cogeneration project activity are solely on
account of thermal energy production (i.e.,
no emission reductions accrue from
electricity component), the total installed
thermal energy production capacity of the
project equipment of the cogeneration unit
shall not exceed 45 MW thermal;
c. If the emission reductions of the
cogeneration project activity are solely on
account of electrical energy production (i.e.,
no emission reductions accrue from thermal
energy component), the total installed
electrical energy generation capacity of the
project equipment of the cogeneration unit

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shall not exceed 15 MW.
vii. Is electricity and/or steam/heat produced by the AMS 7 The electricity and steam will be used for captive CL-5 OK
project activity delivered to another facility or IC consumption within manufacturing facility of the
facilities within the project boundary? If yes, has project participant. Project participant is required to
there been a contract between the supplier and clarify how this condition is complied in case of
consumer(s) of the energy specifying that only exporting the electricity to PSEB grid as described
the facility generating the energy can claim above in CAR-15 above in section (4.a) of this
emission reductions from the energy displaced? protocol.
viii. Does project activities seek to retrofit or modify AMS 8 The proposed project activity is a greenfield biomass OK OK
an existing facility for renewable energy IC based cogeneration project and does not include any
generation? retrofitting or modification in existing facility for
renewable energy generation.
ix. Does the project activity involve addition of AMS 9 As mentioned in above comment, the project activity CAR-18 OK
renewable energy units at an existing IC is a new green field project and does not add any
renewable energy facility? If yes, the total renewable energy unit to existing renewable energy
capacity of the units added by the project facility and hence, the rest of the conditions including
should comply with capacity limits in conditions total capacity and physically distinct units are not
4 to 6 above? Are the units added by project applicable. However, justification provided in the
activity physically distinct from the existing section B.2 of the web hosted PDD is not in line with
units? the applicability condition of the methodology.
x. Is the proposed project activity a charcoal AMS 10 No, the project activity is not a charcoal based OK OK
based biomass energy generation? If yes, is IC biomass energy generation and hence applicability
the charcoal produced from renewable biomass conditions of charcoal production with and without
sources provided below in a) and b) ? methane recovery and destruction facility are not
a. Charcoal is produced in kilns equipped with applicable.
methane recovery and destruction facility;
or
b. If charcoal is produced in kilns not equipped
with a methane recovery and destruction

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facility, methane emissions from the
production of charcoal shall be considered.
These emissions shall be calculated as per
the procedures defined in the approved
methodology AMS-III.K. Alternatively,
conservative emission factor values from
peer reviewed literature or from a registered
CDM project activity can be used, provided
that it can be demonstrated that the
parameters from these are comparable e.g.,
source of biomass, characteristics of
biomass such as moisture, carbon content,
type of kiln, operating conditions such as
ambient temperature.
xi. Is solid biomass fuel (e.g., briquette) is used b y AMS 11 The project activity does not use solid biomass fuel OK OK
project activity? If yes, is it demonstrated IC and hence this applicability condition is not applicable
demonstrated that solid biomass fuel has been to proposed project activity.
produced using solely renewable biomass and
all project or leakage emissions associated with
its production are taken into account in
emissions reduction calculation?
d. Is the proeject activity expected to result in VVM 70 Emissions other than those allowed by the OK OK
emissions other than those allowed by the methodology are not expected in the project activity.
methodology?
e. Is the choice of the methodology justified? VVM 70 Yes, the choice of methodology is justified in Section - -
B.2 of the web hosted PDD. However, inadequacies
observed in the justification of choice of methodology
are described above in section (5.b.c (i) to (xi)).
f. Have the project participants shown that the VVM 70 Some of the justifications of the applicability - -

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project activity meets each of the applicability conditions as provided by the applied baseline and
conditions or the approved methodology? monitoring methodology AMS IC, Version 17 have
been identified above in section (5.b.c (i) to (xi)).
g. Have the project participants shown that the VVM 70 Some of the justifications of the applicability - -
project activity meets each of the applicability conditions as provided by the applied baseline and
conditions of any tool or other methodology monitoring methodology AMS IC, Version 17 have
component referred to the methodology? been identified above in section (5.b.c (i) to (xi)).
i. Does the project activity substitute electricity AMS I.C The project activity does not only substitute electricity OK OK
from the grid i.e project activity supplies from the grid. The project activity is aimed at
electricity to the grid or project activity results in generation of both thermal and electrical energy from
savings in electricity that would have been biomass and thereby displacing use of grid electricity
provided by the grid? as well as fossil fuel based thermal energy. Moreover,
the project activity will supply the additional power to
PSEB grid and thereby result in electricity saving that
would have been provided by grid.
ii. If yes, is the latest version of the “Tool to AMS I.C The web hosted PDD is silent on the fact that the CAR-19 OK
calculate the emission factor for an electricity project activity will displace grid electricity also and
system” used to calculate the Operating hence does not include description on the tools that
margin, Build margin and the Combined are to be used for the emission factor calculations for
Margin? electricity system as well as fossil fuel.
h. Is the DOE, based on local and sectoral VVM 70 There is no such comparison of source required. OK OK
knowledge, aware that comparable information is
available from sources other than that used in the
PDD?
i. If yes, was the PDD cross checked agains the VVM 70 Not applicable OK OK
other sources to confirm that the project activity
meets the applicability conditions of the
methodology? (provide the reference to these
choices)

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j. Can a determination regarding the applicability of VVM 71 Yes, it can be determined based on the applicability of - -
the selected methodology to the proposed CDM selected methodology. However, some of the CARs
project activity be made? and CLs as mentioned above in Section (5.b.c (i) to
(xi)) need to be closed for confirmation on the
applicability.
k. If no, clarification of the methodoloy was VVM 71 Not applicable. OK OK
requested, in accordance with the guidance
provided by the CDM Executive Board?
l. If answer to (5.b.c) above is “no”, revision or VVM 72 Not applicable. OK OK
deviation from the methodology was requested,
in accordance with the guidance provided by the
CDM Executive Board?
m. If yes to (5.b.k) and (5.b.l) above, a request for VVM 73 Not applicable. OK OK
registration was submited before the CDM
Executive Board has approved the proposed
deviation or revision?
c. Project boundary
a. Does the PDD correctly describe the project VVM 77 The project boundary is not described correctly in the CAR-20 OK
boundary, including the physical delineation of web hosted PDD, as it does not include processes /
the proposed CDM project activity included within equipments consuming thermal and electrical energy.
the project boundary for the purpose of It is shown that the emissions from project activity will
calculating project and baseline emissions for the be sequestered. Please clarify. It also does not
proposed CDM project activity? include fossil fuel storage, consumption and
monitoring in case of co-firing requirement.
i. Does the project boundary delineate the AMS I.C Yes, the project boundary delineates the physical, OK OK
physical, geographical site of the project geographical site of the project equipment producing
equipment producing the renewable energy? the renewable energy.
ii. Does the boundary also extend to the industrial, AMS I.C The project boundary does not include processes / CAR-20 OK
commercial or residential facility, or facilities, equipments consuming thermal and electrical energy

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consuming energy generated by the system and that are affected by the project activity.
and the processes or equipment that is affected
by the project activity?
b. Is the delineation in the PDD of the project VVM 78 No, the project boundary delineation is not in CAR-20 OK
boundary correct? accordance with Para 12 of selected methodology
AMS I C, Version 17.
c. Does the delineation in the PDD of the project VVM 78 The baseline boundary is not in accordance with CAR-21 OK
boundary meet the requirements of the selected actual implemented baseline i.e. it is does not include
baseline? baseline project equipments for thermal energy and
grid for electricity and mentions co-generation, which
is not the case.
d. Have all sources and GHGs required by the VVM 78 No, the project boundary delineation is not in CAR-20 OK
methodology been included within the project accordance with Para 12 of selected methodology
boundary? AMS I C, Version 17.
e. Does the methodology allow project participant to VVM 78 This is not applicable as the proposed project activity OK OK
choose whether a source or gas is to be included is a small-scale project.
within the project boundary?
f. If yes, have the project participants justified that VVM 78 Not applicable OK OK
choice?
g. If yes, is the justification provided reasonable? VVM 78 Not applicable OK OK
(provide reference to the supporting documented
evidence provided by the project participants)
d. Baseline identification
a. Does the PDD identify the baseline for the VVM 80 Yes, PDD identifies the baseline scenario that OK OK
proposed CDM project activity, defined as the reasonably represents the anthropogenic emissions
scenario that reasonably represents the by sources of GHGs that would occur in the absence
anthropogenic emissions by sources of GHGs of the proposed CDM project activity. However, the
that would occur in the absence of the proposed validation team has observed some inadequacies in
CDM project activity? baseline identification with respect to the use

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electricity and source of thermal energy in scenario
existing prior to project activity implementation.
b. Has any procedure contained in the methodology VVM 81 -
to identify the most reasonable baseline scenario,
been correctly applied?
i. For renewable energy technologies that AMS 13 There is not only displacement of fossil fuel based OK OK
displace technologies using fossil fuel, is the IC technology but the project activity also involves
simplified baseline calculated as ”the fuel replacement of grid electricity by biomass-based
consumption of the technologies that would power.
have been used in the absence of the project
activity times an emission factor for the fossil
fuel displaced” ?
ii. For calculating the emission factor, were AMS 13 Project participant has used IPCC data for the OK OK
reliable local or national data used? IC purpose of calculation of emission factor.
iii. If country of project specific data are not AMS 13 The project participant is requested to clarify the CL-6 OK
available or demonstrably difficult to obtain, IC rationale of using IPCC data as that can only be used
were IPCC default values used? when country or project specific data are not available
or demonstrably difficult to obtain.
iv. For fuel switching from fossil fuel to renewable The validation team observed during site visit that the CAR-22 OK
biomass in existing facilities, historical manufacturing units viz; Spinning unit was in
information (detailed records) on the use of operation since March 2008 and Terri Towel unit was
energy sources (e.g., electricity, fossil fuel) and operationalised in November 2008 and March 2009 in
the plant output (e.g., steam/electricity) in the two phases prior to the commissioning of the 10MW
baseline plant from at least 3 years prior to biomass based power plant. The electricity
project implementation shall be used in the requirements of the plant are being met through grid
baseline calculations, For facilities that are less power. It was also observed by the validation team
than 3 years old, all historical data shall be that there were two sources including 5 TPH fossil fuel
available (a minimum of one year data would based boiler and 15 Lac Kcal/Hr Thermopack to meet
be required). In case of project activity thermal energy requirement of manufacturing units

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exporting to other facilities included in the prior to implementation of project activity. These
project boundary, the above historical scenarios are not transparently described and further
information from the recipient plants are considered in the Section B.4 and B.5 of web hosted
required. PDD.
v. If the project activity produces both heat and AMS 15 The proposed project activity is a greenfield CAR-23 OK
electricity including cogenerationt, are one of IC cogeneration project. The project participant has also
the following baseline scenarios used? (Cases taken various alternatives into account and listed in
where no historical information is available, the section B.4 of the PDD. As per section B.4 of the
most plausible energy supply sources shall be PDD, the project participant has selected coal based
established in accordance with the guidance on cogeneration unit as a baseline by considering it most
Greenfield projects in the general guidance to plausible investment option. However, the justification
SSC methodologies.) presented is based on initial investment cost of the
project. The levelised cost of energy production for the
entire technical lifetime of the project activity for the
alternatives has not been considered. Besides, the
project participant has not computed the levelised cost
of energy production/unit of output. Instead the total
project cost has been computed which is not in line
with the procedures of investment comparison
analysis.
a. Electricity is imported from the grid and AMS 15 The validation team observed during site visit that the CAR-22 OK
thernal energy (steam/heat) is produced IC manufacturing units viz; Spinning unit was in
using fossil fuels. operation since March 2008 and Terri Towel unit was
operationalised in November 2008 and March 2009 in
two phases prior to the commissioning of the 10MW
biomass based power plant. The electricity
requirements of the plant are being met through grid
power. It was also observed by the validation team
that there were two sources including 5 TPH fossil fuel

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based boiler and 15 Lac Kcal/Hr Thermopack to meet
thermal energy requirement of manufacturing units
prior to implementation of project activity. These
scenarios are not transparently described and further
considered in the Section B.4 and B.5 of web hosted
PDD.
b. Electricity is produced on an on-site captive AMS 15 This is not applicable as the project participant was OK OK
power plant using fossil (with a possibility of IC sourcing the electricity from PSEB grid prior to the
export to grid) and thermal energy project activity implementation. It was also observed
(steam/heat) is produced using fossil fuel. that even after project implementation, project
participant will continue to source electricity from grid
as and when required.
c. A combination of (a) and (b) AMS 15 Not applicable OK OK
IC
d. Electricity and thermal energy (steam/heat) AMS 15 There was not any co generation unit existing prior to OK OK
are produced in a cogeneration unit using IC the proposed project implementation and hence not
fossil fuel (with possibility of export of applicable.
electricuty to the grid/other facilities and/or
thermal energy to other facilities).
e. Electricity is imported from the grid and/or AMS 15 This is not applicable as the project participant was OK OK
produced in an onsite captive power plant IC sourcing the electricity from PSEB grid prior to the
using fossil fuels (with a possibility of export project activity implementation but the thermal energy
to the grid); steam/heat is produced from was not produced from biomass.
biomass.
f. Electricity is produced in an on-site captive AMS 15 This is not applicable as the project participant was OK OK
power plant using biomass (with a possibility IC sourcing the electricity from PSEB grid prior to the
of export to the grid) and/or imported from the project activity implementation and not from biomass
grid; steam/heat is produced using fossil fuel; based captive power plant.
g. Electricity and thermal energy (steam/heat) AMS 15 This is not applicable as the project participant was OK OK

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are produced in a biomass fired cogeneration IC sourcing the thermal from fossil fuel based boiler and
unit (without a possibility of export of thermopack prior to the project activity implementation
electricity either to the grid or to other facilities and not biomass fired co-generation.
and without a possibility of export of thermal
energy to other facilities)
vi. For cases iv (a), (b) & (c) above, are the AMS 19 As mentioned above, the section B.4 of the web CAR-24 OK
baseline emissions calculated as the sum of IC hosted PDD does not transparently describe the
emissions from the production of electricity and scenario existing prior to the project activity
steam/heat considering most recent historical implementation and hence the baseline emissions are
records? not in accordance with Paragraph 19 of the applied
methodology AMS I C, Version 17.
vii. Is the annual electricity produced in the AMS 19 The baseline emissions are not in accordance with CAR-25 OK
project activity less than or equal to the IC Paragraph 19 of the applied methodology AMS I C,
sum of on-site captive generation and net Version 17.
grid import (average of most recent 3 years
data) in the baseline scenario? (Note: Net
grid import is the difference of total
electricity imported from the grid and total
electricity exported to the grid.)
viii. If yes, is the emission factor calculated as AMS 19 The baseline emissions are not in accordance with CAR-25 OK
the weighted average of on-site captive IC Paragraph 19 of the applied methodology AMS I C,
electricity generation and the net grid Version 17.
electricity import (average of most recent
three years data) in the baseline scenario?
[Note: Net grid electricity import - For
example in the baseline if 80% of annual
electricity requirement was met by grid
import and rest by captive generation, the

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weighted average emission factor (EF)
would be 0.8 EFgrid+ 0.2 EFcaptive.]
ix. If no, is the lower of the two values i.e., AMS 19 The baseline emissions are not in accordance with CAR-25 OK
emission factor of the grid or the emission IC Paragraph 19 of the applied methodology AMS I C,
factor of the captive plant, used for the Version 17.
incremental generation (i.e., the difference
between the electricity generation in the
project activity and the sum of captive
generation and net grid import)?
x. For case iv (d) – Electricity and steam AMS 20 Not applicable as there was not any co-generation OK OK
produced in a cogeneration point using IC plant using fossil fuel in baseline scenario.
fossil fuel – Is the baseline calculated using
the formula, BEcogen,CO2,y =
[((EGpj,thermal,y + EGpj,electrical,y *
3.6)/ηcogen] * EFff,CO2,?
xi. Is the efficiency of the baseline units AMS 21 - -
determined by adopting one of the following IC
criteria (in a preferential order):
a. Highest measured operation efficiency over AMS 21 This option is not adopted OK OK
the full range of operating conditions of a unit IC
with similar specifications, using baseline fuel.
The efficiency tests shall be conducted
following the guidance provided in relevant
national / international standards;
b. Highest of the efficiency values provided by AMS 21 This option is not adopted OK OK
two or more manufacturers for units with IC
similar specifications, using the baseline fuel;
c. Default efficiency of 100%. AMS 21 The efficiency of the baseline units is taken as 100%. OK OK

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IC
xii. For household or commercial applications AMS 22 This is not applicable as it cannot be demonstrated OK OK
/systems, whose maximum output capacity IC that that the metering of thermal energy output is not
is less than 45 kW thermal and where it can plausible.
be demonstrated that the metering of
thermal energy output is not plausible, as in
the case of cooking stoves, gasifiers, driers,
water heaters etc., was efficiency of the
baseline units determined by adopting one
of the following criteria:
a. Highest measured operational efficiency over AMS 22 Not applicable OK OK
the full range of operating conditions of a IC
representative sample of units with similar
specifications, using baseline fuel. The
efficiency tests shall be conducted following
the guidance provided in relevant national /
international standards;
b. Highest of the efficiency values provided by AMS 22 Not applicable OK OK
two or more manufacturers for units with IC
similar specifications using the baseline fuel;
c. Highest efficiency from referenced literature AMS 22 Not applicable OK OK
values or default efficiency of 100%. IC

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xiii. If the electricity is produced in captive AMS 16 Not applicable as there was no captive power OK OK
plants, is the baseline emission calculated IC generation in the baseline scenario.
as the amount of electricity produced with
the renewable energy technology (GWh)
multiplied by the CO2 emission factor per
unit of energy of the fuel that would have
been used in the baseline plant in
(tCO2/TJ) divided by the efficiency of the
captive plant?
xiv. For steam/heat produced using fossil fuels, AMS 18 Though the steam was produced using fossil fuels in CL-7 OK
is the baseline emissions calculated as, IC pre project scenario, the baseline emissions are not
BEthermal,CO2,y = (EG calculated in accordance with Paragraph 18 of the
thermal,/ηBL,thermal) * EFff, CO2? applied methodology AMS IC, Version 17.
xv. For case iv (e), is the baseline emission AMS 23 Not applicable OK OK
calculated as defined in (v) above? IC
xvi. For case iv (f), is the baseline emission AMS 24 Though the steam was produced using fossil fuels in CL-7 OK
calculated as defined in (xiv) above? IC pre project scenario, the baseline emissions are not
calculated in accordance with Paragraph 18 of the
applied methodology AMS IC, Version 17.
xvii. For case iv (g), is the baseline emissions AMS 25 Not applicable OK OK
from the production of electricity that IC
displaces grid electricity import/or supply
electricity to the grid calculated as per the
procedures detailed in AMS-I.D?
xviii. Does the project activity involve the AMS 27 No, the project activity does not involve addition of OK OK
addition of new energy production units IC new energy production units (e.g., turbines) at an
(e.g., turbines) at an existing facility ? existing facility.

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xix. If yes, is the net increase in thermal energy AMS 27 Not applicable OK OK
generation calculated as follows: IC
EGthermal,add,y = EGthremal,pj,y –
EGthermal,old,y?
xx. Are the existing units shut down, are AMS 27 Not applicable OK OK
derated, or otherwise become limited in IC
production ?
xxi. If yes, is the project activity claiming credits AMS 27 Not applicable OK OK
for generating thermal energy from the IC
same renewable resources that would have
otherwise been used by the existing units
(or their replacements)?
xxii. Do the project activity seek to retrofit or AMS 27 No, the project activity is a new green field project and OK OK
modify an existing facility for renewable IC does not seek to retrofit or modify an existing facility.
energy generation ?
xxiii. If yes, is the baseline scenario calculated AMS 27 Not applicable OK OK
as follows; EGbl,thermal,retrofit,y = IC
MAX(EGhistorical,thermal,y,EGestimated,t
hermal,y) until DATEBaselineRetrofit ?
xxiv. If yes to above question, does the baseline AMS 27 Not applicable OK OK
emissions (BEretrofit,CO2,y) correspond to IC
the difference of the thermal energy
supplied by the project activity and the
baseline thermal energy supplied in the
case of modified or retrofit facilities
multiplied by the emission factor or the fuel
that would have been used to generate the

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incremental energy?
xxv. Were the requirements concerning AMS 29 The project participant has not demonstrated the CAR-26 OK
demonstration of the remaining lifetime of IC remaining lifetime of the replaced fossil fuel fired
the replaced equipment met as described in baseline thermal energy generating units viz; 5 TPH
the General Guidance for SSC boiler and Thermopack.
methodologies?
xxvi. Does the remaining lifetime of the affected The project participant has not demonstrated the CAR-26 OK
systems increase due to the project remaining lifetime of the replaced fossil fuel fired
activity? baseline thermal energy generating units viz; 5 TPH
boiler and 15 Lac Kcal/Hr Thermopack.
xxvii. If yes, is the crediting period limited to the AMS 29 The project participant has not demonstrated the CAR-26 OK
estimated remaining lifetime, i.e. the time IC remaining lifetime of the replaced fossil fuel fired
when the affected systems would have baseline thermal energy generating units viz; 5 TPH
been replaced in the absence of the project boiler and 15 Lac Kcal/Hr Thermopack.
actitivy? (If not, a CAR shall be raised)
xxviii. In order to estimate the AMS 29 Not applicable as there is not retrofitting involved in OK OK
(DATEBaselineRetrofit), has the project IC project activity.
participant followed the procedures
described in the general guidance?
c. Does the selected methodology require use of VVM 81 The selected methodology requires use of “Tool to OK OK
tools (such as the “Tool for the demonstration calculate baseline, project leakage emissions from
and assessment of additionality” and the electricity consumption” and “Tool to calculate project
“Combined tool to identify the baseline scenario or leakage CO2 emissions from fossil fuel
and demonstrate additionality”) to establish the combustion”.
baseline scenario?
d. If yes, was the methodology consulted on the VVM 81 No, the methodology was not consulted on the OK OK
application of these tools? (In such cases, the application of these tools.
guidance in the methodology shall supersede the

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tool.)
i. Does the project activity displace grid AMS I.C Yes, the project activity displaces the grid electricity OK OK
electricity import and/or supply electricity to imported in baseline scenario and also supplies
grid? electricity to grid after captive consumption.
ii. If yes, was the emission factor of the grid AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
calculated as per the procedures detailed in per the procedures detailed in AMS-I.D in accordance
AMS-I.D? with Tool to Calculate the Emission factor for an
Electricity System
iii. Is the latest version of the ‘Tool to Calculate AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
the Emission factor for an Electricity per the procedures detailed in AMS-I.D in accordance
System’ used in the project activity? with Tool to Calculate the Emission factor for an
Electricity System.
iv. Is the baseline determined by using the 7 AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
steps outlined in the tool? per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
v. Are the calculations of the Operating AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
Margin, Build Margin and the Combined per the procedures detailed in AMS-I.D in accordance
margin transparently described in the PDD? with Tool to Calculate the Emission factor for an
Electricity System.
vi. Is the latest version of the CEA data used AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
in the calculations? per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
vii. Are the emission factor calculations using AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
any other data apart from the CEA data? per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
e. Does the methodology require several alternative VVM 82 Yes, for greenfield projects, the methodology refers to OK OK

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scenarios to be considered in the identification of the general guidance to SSC CDM methodologies,
the most reasonable baseline scenario? which provides the stepwise approach for the
demonstration of most reasonable baseline. Also,
there has been fossil fuel fired source of thermal
energy and grid as source of electrical energy, which
is not considered as an one of the options in
accordance with the methodology.
f. If yes, are all scenarios that are considered by VVM 82 The validation team observed during site visit that the CAR-22 OK
the project participants and are supplementary to manufacturing units viz; Spinning unit was in
those required by the methodology reasonable in operation since March 2008 and Terri Towel unit was
the context of the proposed CDM project activity? operationalised in November 2008 and March 2009 in
two phases prior to the commissioning of the 10MW
biomass based power plant. The electricity
requirements of the plant are being met through grid
power. It was also observed by the validation team
that there were two sources including 5 TPH fossil fuel
based boiler and 15 Lac Kcal/Hr Thermopack to meet
thermal energy requirement of manufacturing units
prior to implementation of project activity. These
scenarios are not transparently described and further
considered in the Section B.4 and B.5 of web hosted
PDD..
g. Has any reasonable alternative scenario been VVM 82 The validation team observed during site visit that the CAR-22 OK
excluded? manufacturing units viz; Spinning unit was in
operation since March 2008 and Terri Towel unit was
operationalised in November 2008 and March 2009 in
two phases prior to the commissioning of the 10MW
biomass based power plant. The electricity
requirements of the plant are being met through grid

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power. It was also observed by the validation team
that there were two sources including 5 TPH fossil fuel
based boiler and 15 Lac Kcal/Hr Thermopack to meet
thermal energy requirement of manufacturing units
prior to implementation of project activity. These
scenarios are not transparently described and further
considered in the Section B.4 and B.5 of web hosted
PDD.
h. Is the baseline scenario identified reasonably VVM 83 The validation team observed during site visit that the CAR-22 OK
supported by: manufacturing units viz; Spinning unit was in
operation since March 2008 and Terri Towel unit was
operationalised in November 2008 and March 2009 in
two phases prior to the commissioning of the 10MW
biomass based power plant. The electricity
requirements of the plant are being met through grid
power. It was also observed by the validation team
that there were two sources including 5 TPH fossil fuel
based boiler and 15 Lac Kcal/Hr Thermopack to meet
thermal energy requirement of manufacturing units
prior to implementation of project activity. These
scenarios are not transparently described and further
considered in the Section B.4 and B.5 of web hosted
PDD.
i. Assumptions? VVM 83 Refer to the comment above in (5.d.h) - -
ii. Calculations? VVM 83 Refer to the comment above in (5.d.h) - -
iii. Rationales? VVM 83 Refer to the comment above in (5.d.h) - -
i. Are the documents and sources referred to in the VVM 83 Yes, the sources are provided in the spreadsheets CAR-28 OK
PDD correctly quoted and interpreted? used for the identification of baseline scenario.
However, copies of the evidences are not submitted to

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the validation team.
j. Was the information provided in the PDD cross VVM 83 The sources are provided in the spreadsheet working CAR-28 OK
checked with other verifiable and credible used for the identification of baseline scenario.
sources, such as local expert opinion, if However, copies of the evidences are not submitted to
available? (idendify the sources) the validation team.
k. Have all applicable CDM requirements been VVM 84 Yes OK OK
taken into account in the identification of the
baseline scenario for the proposed CDM project
activity?
l. Have all relevant policies and circumstances VVM 84 Yes OK OK
been identified and correctly considered in the
PDD, in accordance with the guidance by the
CDM Executive Board?
m. Does the PDD provide a verifiable description of VVM 85 Refer to the comment above in (5.d.h) - -
the identified baseline scenario, including a
description of the technology that would be
employed and/or the activities that would take
place in the absence of the proposed CDM
project activity?

e. Algorithms and/or formulae used to determine


emission reductions
a. Do the steps taken and equations applied to VVM 88 The calculations of baseline emissions are not CAR-29 OK
calculate project emissions, baseline emissions, completely in accordance with the selected baseline
leakage and emission reductions comply with the and monitoring methodology because the baseline
requirements of the selected baseline and identification does not include the scenario existing
monitoring methodology? prior to the proposed CDM project activity for thermal
and electrical energy generation and its use in the
manufacturing facility of the project participant.

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b. Have the equations and parameters in the PDD VVM 89 The calculations of baseline emissions are not CAR-29 OK
been correctly applied with respect those in the completely in accordance with the selected baseline
select approved methodology? and monitoring methodology because the baseline
identification does not include the scenario existing
prior to the proposed CDM project activity for thermal
and electrical energy generation and its use in the
manufacturing facility of the project participant.
i. If the steam/heat is produced using fossil fuels, AMS I.C No, though the steam/heat, in the scenario existing CAR-30 OK
is the baseline emission calculated as, prior to the proposed CDM project activity, produced
BEthermal,CO2,y = (EGthermal,y/ηBL,thermal) using fossil fuel the baseline emissions are not
* EFff,CO2? calculated as BEthermal,CO2,y = (EGthermal,y/ηBL,thermal) *
EFFF,CO2?
ii. If electricity and steam is produced in a AMS I.C This is not applicable as there was not a co- CL-8 OK
cogeneration unit, using fossil fuel, are the generation unit in baseline scenario. However, the
baseline emisions calculated using the web hosted PDD in section B.6.1 mentioned the
following formula, BEcogen,CO2,y = equation as per Para 20 of the selected methodology
[(EGpj,thermal,y + EGpj,electricl,y * though there was not a co-generation unit in baseline
3.6)/ηbl,cogen] * EFff,CO2? scenario.
iii. For project activities that involve the addition of AMS I.C This is not applicable, as the project activity does not OK OK
new energy production units (e.g., turbines) at involve the addition of new energy production units
an existing facility, was the increase in energy (e.g., turbines) at an existing facility.
production associated with the project (EGy in
MWh/ year) calculated as follows: EGy = TEy –
WTEy?
iv. Is WTEy calculated as MAX(WTEactual,y , AMS I.C This is not applicable, as the project activity does not OK OK
WTEestimated,y)? involve the addition of new energy production units
(e.g., turbines) at an existing facility.
v. For project activities that seek to retrofit or AMS I.C This is not applicable, as the project activity does not OK OK
modify an existing facility for renewable energy seek to retrofit or modify an existing facility for

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generation, is the baseline scenario calculated renewable energy generation.
as the following: EGbl,thermal,retrofit,y =
MAX(EGhistorical,thermal,y,EGestimated,therm
al,y) until DATEBaselineRetrofit?
vi. Is the emission factor for grid electricity AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
calculated as per the procedures detailed in per the procedures detailed in AMS-I.D in accordance
AMS I.D? with Tool to Calculate the Emission factor for an
Electricity System.
vii. If yes, is the calculation of the Operating Margin AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
(OM) emission factor EFgridOMy based on one per the procedures detailed in AMS-I.D in accordance
of the 4 methods described? with Tool to Calculate the Emission factor for an
Electricity System.
viii. If the simple OM method is used, is it shown AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
that the low-cost/must-run resources constitute per the procedures detailed in AMS-I.D in accordance
less than 50% of total grid generation in: with Tool to Calculate the Emission factor for an
Electricity System.
a. average of the five most recent years; or AMS I.C No, the emission factor of the grid is not calculated as OK
per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
b. based on long-term averages for AMS I.C No, the emission factor of the grid is not calculated as
hydroelectricity production. per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
ix. For the simple OM, are the emissions factor AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
calculated using either of the two following data per the procedures detailed in AMS-I.D in accordance
vintages: with Tool to Calculate the Emission factor for an
Electricity System.
a. Ex-ante option AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK

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per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
b. Ex-post option AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
x. Is the data vintage chosen as indicated above, AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
documented in the CDM PDD? per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
xi. If the dispatch data analysis OM is chosen, is AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
the year in which the project activity displaces per the procedures detailed in AMS-I.D in accordance
grid electricity used? with Tool to Calculate the Emission factor for an
Electricity System.
xii. For dispatch data analysis OM, is it indicated AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
that the emission factor would be updated per the procedures detailed in AMS-I.D in accordance
annually during the monitoring? with Tool to Calculate the Emission factor for an
Electricity System.
xiii. Is the Operating Margin Emission factor, AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
according to the selected method, calculated as per the procedures detailed in AMS-I.D in accordance
per Step 3 of the latest version of the ”Tool to with Tool to Calculate the Emission factor for an
calculate the emission factor for an electricity Electricity System.
system”?
xiv. Is the Build Margin (BM) emission factor AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
calculated as EFgrid,BM,y = (Σ EGm,y X per the procedures detailed in AMS-I.D in accordance
EFEL,m,y)/(Σ EGm,y)? with Tool to Calculate the Emission factor for an
Electricity System.
xv. Is the combined margin emission factor AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK

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calculated as, EFgrid,CM,y = EFgrid,OM,y X W per the procedures detailed in AMS-I.D in accordance
OM + EFgrid,BM,y X W BM? with Tool to Calculate the Emission factor for an
Electricity System.
xvi. Are the percent weightages of OM and BM AMS I.C No, the emission factor of the grid is not calculated as CAR-27 OK
emission factors used as per the tool? per the procedures detailed in AMS-I.D in accordance
with Tool to Calculate the Emission factor for an
Electricity System.
c. Does the methodology provide for selection VVM 89 Yes, the methodology provides selection between - -
between different options for equations or various options for equations or parameters. However,
parameters? various CARs/CLs are raised by the validation team in
earlier section of this protocol in Section (5.d) above.
d. If yes, has adequate justification been provided VVM 89 Various CARs/CLs are raised by the validation team - -
(based on the choice of the baseline scenario, in earlier section of this protocol in Section (5.d)
context of the proposed CDM project activity and above.
other evidence provided)?
e. If yes, have correct equations and parameters VVM 89 Various CARs/CLs are raised by the validation team - -
been used, in accordance with the methodology in earlier section of this protocol in Section (5.d)
selected? above.
f. Will data and parameters be monitored VVM 90 There are data which are available at the time of OK OK
throughout the crediting period of the proposed validation and are fixed ex-ante and provided in
CDM project activity? Section B.6.2 of the web hosted PDD.
g. If no, and these data and parameters will remain VVM 90 As the project activity has arrangements for co-firing CAR-31 OK
fixed throughout the crediting period, are all data also, the web hosted PDD does not include the
sources and assumptions: parameters on fossil fuel and other, as may required
as per scenario existing prior to the project activity are
not provided.
i. Appropriate and correct? VVM 90 Refer to above comment in (5.e.g) - -
ii. Applicable to the proposed CDM project VVM 90 Refer to above comment in (5.e.g) - -
activity?

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iii. Resulting in a conservative estimate of the VVM 90 Refer to above comment in (5.e.g) - -
emission reductions?
h. Will data and parameters be monitored on VVM 90 The data and parameters, which will be monitored are OK OK
implementation and hence become available only provided in Section B.7.1 of the web hosted PDD.
after validation of the project activity ?

i. If yes, are the estimates provided in the PDD for VVM 90 Refer to the section (7) of this protocol for details on OK OK
these data and parameters reasonable? the data and parameters to be monitored after project
implementation.
6. Additionality of a project activity
a. Does the PDD describe how a proposed CDM VVM 93 Yes, as per Attachment A to Appendix B, the project OK OK
projet activity is additional? participant has demonstrated the additionality of the
project.
b. Does the CDM-PDD state the latest version of VVM 94 Any additionality tool has not been referred in the web OK OK
the additionality tool being used? hosted PDD. The project activity is a small scale
project and methodology AMS I C, Version 17 also
does not refer to any additionality tool except
attachment A of appendix B.
c. Were the following steps of the tool to assess EB Ann
additionality used: 39 10
i. Identification of alternatives to the project EB Ann The alternatives are identified only in baseline OK OK
activity? 39 10 development and not applicable for additionality, as it
does not use the tool to assess additionality.
ii. Investment analysis to determine that the EB Ann Yes, the project participant has demonstrated OK OK
proposed project activity is either: 1) not the 39 10 investment barrier based on Attachment A to
most economically or financially attractive, or 2) Appendix B of simplified modalities and procedures.
not economically or financially feasible?
iii. Barriers analysis? EB Ann Not applicable for additionality, as project activity does OK OK
39 10 not use the tool to assess additionality.

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iv. Common practice analysis? EB Ann Not applicable for additionality, as project activity does OK OK
39 10 not use the tool to assess additionality.
d. In step 1 (i) have all the sub-steps as below been EB Ann Not applicable for additionality, as project activity does OK OK
followed? 39 10 not use the tool to assess additionality.
i. Sub-step 1a: Define alternatives to the project EB Ann Not applicable for additionality, as project activity does OK OK
activity 39 10 not use the tool to assess additionality.
ii. Sub-step 1b: Consistency with mandatory laws EB Ann The options are consistent with mandatory laws and OK OK
and regulations 39 10 regulations.
e. Have the following alternatives been included EB Ann
while defining alternatives as per sub-step 1a? 39 10
i. he proposed project activity undertaken without EB Ann Yes, proposed project activity undertaken without OK OK
being registered as a CDM project activity; 39 10 being registered as a CDM project activity has been
considered as one of the alternatives.
ii. Other realistic and credible alternative EB Ann Other realistic and credible alternative scenario(s) to OK OK
scenario(s) to the proposed CDM project 39 10 the proposed CDM project activity scenario that
activity scenario that deliver outputs services or deliver outputs services or services with comparable
services with comparable quality, properties quality, properties and application areas have been
and application areas, taking into account, considered.
where relevant, examples of scenarios
identified in the underlying methodology;
iii. If applicable, continuation of the current EB Ann The validation team observed during site visit that the CAR-22 OK
situation (no project activity or other alternatives 39 10 manufacturing units viz; Spinning unit was in
undertaken). operation since March 2008 and Terri Towel unit was
operationalised in November 2008 and March 2009 in
two phases prior to the commissioning of the 10MW
biomass based power plant. The electricity
requirements of the plant are being met through grid
power. It was also observed by the validation team
that there were two sources including 5 TPH fossil fuel

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based boiler and 15 Lac Kcal/Hr Thermopack to meet
thermal energy requirement of manufacturing units
prior to implementation of project activity. These
scenarios are not transparently described and further
considered in the Section B.4 and B.5 of web hosted
PDD.
f. Has the project participant included the EB Ann The project participant has included the technologies OK OK
technologies or practices that provide outputs or 39 10 or practices that provide outputs or services with
services with comparable quality, properties and comparable quality, properties and application areas
application areas as the proposed CDM project as the proposed CDM project activity and that have
activity and that have been implemented been implemented previously.
previously or are currently being introduced in the
relevant country/region?
g. Has the outcome of Step 1a: Identified realistic EB Ann Not applicable for additionality, as project activity does OK OK
and credible alternative scenario(s) to the project 39 10 not use the tool to assess additionality.
activity done correctly? Please briefly mention the
outcome.
h. Is the alternative(s) in compliance with all EB Ann Yes, all the alternatives are in compliance with all OK OK
mandatory applicable legal and regulatory 39 10 mandatory applicable legal and regulatory
requirements, even if these laws and regulations requirements.
have objectives other than GHG reductions, e.g.
to mitigate local air pollution.?
i. If an alternative does not comply with all EB Ann Not applicable, as all the alternatives comply with all OK OK
mandatory applicable legislation and regulations, 39 10 mandatory applicable legislation and regulations.
has it been shown that, based on an examination
of current practice in the country or region in
which the law or regulation applies, those
applicable legal or regulatory requirements are
systematically not enforced and that

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noncompliance with those requirements is
widespread in the country?
j. Has the outcome of Step 1b: Identified realistic EB Ann Not applicable for additionality, as project activity does OK OK
and credible alternative scenario(s) to the project 39 10 not use the tool to assess additionality.
activity that are in compliance with mandatory
legislation and regulations taking into account the
enforcement in the region or country and EB
decisions on national and/or sectoral policies and
regulations done correctly? Please state the
outcome.
k. Has PP selected Step 2 (Investment analysis) or EB Ann The PP has selected investment analysis under OK OK
Step 3 (Barrier analysis) or both Steps 2 and 3? 39 10 Attachment A to Appendix B of simplified modalities
and procedure for demonstration of additionality.
l. In step 2, have all the sub-steps as below been EB Ann
followed? 39 10
i. Sub-step 2a: Determine appropriate analysis EB Ann The project participant has not included the CAR-32 OK
method; 39 10 explanation on the determination of appropriate
analysis method, which may cover all three options
viz; Simple cost analysis, investment comparison
analysis and benchmark analysis in section B.5 of the
web hosted PDD.
ii. Sub-step 2b: Option I. Apply simple cost EB Ann PP has not applied simple cost analysis for OK OK
analysis; 39 10 demonstration of investment barrier.
iii. Sub-step 2b: Option II. Apply investment EB Ann The PP has applied investment comparison analysis - -
comparison analysis; 39 10 method. In validation team’s opinion this is not an
appropriate selection of investment analysis method
with respect to the project activity. Refer to relevant
CAR-34 below in section (6.o).
iv. Sub-step 2b: Option III. Apply benchmark EB Ann PP has not applied benchmark analysis for - -

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analysis; 39 10 demonstration of investment barrier. In validation
team’s opinion this is an appropriate option of
investment analysis method with respect to the project
activity. Refer to relevant CAR-34 below in section
(6.o).
v. Sub-step 2c: Calculation and comparison of EB Ann The project participant has carried out levelised cost CAR-33 OK
financial indicators (only applicable to Options II 39 10 analysis. The PP has compared the cost of operation
and III); of various alternatives as identified, which is not
correct and in accordance with Para (3) of Sub-step 2
(b) of the “Tool for the demonstration and assessment
of additionality”. It is required to calculate cost of
output energy i.e. cost/KWh or cost/GJ.
vi. Sub-step 2d: Sensitivity analysis (only EB Ann Yes, the sensitivity analysis has been included in OK OK
applicable to Options II and III). 39 10 section B.5 of the web hosted PDD.
m. In sub-step 2a has the determination of EB Ann
appropraite method of analysis done as per the 39 10
guidance as below?
i. Simple cost analysis if the CDM project activity EB Ann PP has not applied simple cost analysis for OK OK
and the alternatives identified in Step 1 39 10 demonstration of investment barrier.
generate no financial or economic benefits
other than CDM related income (Option I).
ii. Otherwise, use the investment comparison EB Ann The PP has applied investment comparison analysis - -
analysis (Option II) or the benchmark analysis 39 10 method. In validation team’s opinion this is not an
(Option III). Specify option used with appropriate selection of investment analysis method
justification. with respect to the project activity. Refer to relevant
CAR-34 below in section (6.o).
n. Has the below guideline followed for sub-step 2b EB Ann PP has not applied simple cost analysis for OK OK
Option I. Apply simple cost analysis? Document 39 10 demonstration of investment barrier.
the costs associated with the CDM project activity

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and the alternatives identified in Step 1 and
demonstrate that there is at least one alternative
which is less costly than the project activity.
o. Has the below guideline followed for sub-step 2b EB Ann The project participant has not applied benchmark CAR-34 OK
Option II. Apply investment comparison analysis? 39 10 analysis (Option III). As per validation team’s opinion,
Identify the financial indicator, such as IRR, NPV, investment comparison analysis is not appropriate as
cost benefit ratio, or unit cost of service most per the Para 16 of “Guidelines on the assessment of
suitable for the project type and decision-making the investment analysis” (Annex 58, EB-51). In
context. Please specify scenario existing prior to the project activity, the PP
has been supplied electricity from PSEB grid. Further,
as per discussion with the project participant, there
will be export of power also to grid to the tune of
approximately 2.0 MW. For the thermal energy, in
baseline there were boiler and a thermopack. Thus,
the project participant does not have compulsory
investment. Thus, investment comparison analysis is
not appropriate.
p. Has the below guideline followed for Sub-step 2b: EB Ann The project participant has not applied benchmark CAR-34 OK
Option III. Apply benchmark analysis? 39 10 analysis (Option III). As per validation team’s opinion,
investment comparison analysis is not appropriate as
per the Para 16 of “Guidelines on the assessment of
the investment analysis” (Annex 58, EB-51). In
scenario existing prior to the project activity, the PP
has been supplied electricity from PSEB grid. Further,
as per discussion with the project participant, there
will be export of power also to grid to the tune of
approximately 2.0 MW. For the thermal energy, in
baseline there were boiler and a thermopack. Thus,
the project participant does not have compulsory

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investment. Thus, investment comparison analysis is
not appropriate.
i. Identify the financial/economic indicator, such EB Ann No, the project participant has not opted for - -
as IRR, most suitable for the project type and 39 10 benchmark analysis.
decision context.
ii. When applying Option II or Option III, the EB Ann No, the project participant has not opted for - -
financial/economic analysis shall be based on 39 10 benchmark analysis.
parameters that are standard in the market,
considering the specific characteristics of the
project type, but not linked to the subjective
profitability expectation or risk profile of a
particular project developer. Only in the
particular case where the project activity can be
implemented by the project participant, the
specific financial/economic situation of the
company undertaking the project activity can be
considered.
iii. Discount rates and benchmarks shall be EB Ann No, the project participant has not opted for - -
derived from: (a) Government bond rates, 39 10 benchmark analysis.
increased by a suitable risk premium to reflect
private investment and/or the project type, as
substantiated by an independent (financial)
expert or documented by official publicly
available financial data; (b) Estimates of the
cost of financing and required return on capital
(e.g. commercial lending rates and guarantees
required for the country and the type of project
activity concerned), based on bankers views
and private equity investors/funds’ required

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return on comparable projects; (c) A company
internal benchmark (weighted average capital
cost of the company), only in the particular case
referred to above in 2. The project developers
shall demonstrate that this benchmark has
been consistently used in the past, i.e. that
project activities under similar conditions
developed by the same company used the
same benchmark; (d) Government/official
approved benchmark where such benchmarks
are used for investment decisions; (e) Any
other indicators, if the project participants can
demonstrate that the above Options are not
applicable and their indicator is appropriately
justified. Please specify benchmark and justify.
q. Has the below guideline followed for Sub-step 2c: EB Ann - -
Calculation and comparison of financial indicators 39 10
(only applicable to Options II and III)?
i. Calculate the suitable financial indicator for the EB Ann The project participant has calculated levelised cost in CAR-33 OK
proposed CDM project activity and, in the case 39 10 line with Tool for the demonstration and assessment
of Option II above, for the other alternatives. of additionality. However, the levelised cost is
Include all relevant costs (including, for calculated based on the cost of operation, which is not
example, the investment cost, the operations correct and in accordance with Para (3) of Sub-step
and maintenance costs), and revenues 2b. It is required to calculate cost of output energy i.e.
(excluding CER revenues, but possibly cost/KWh or cost/GJ.
including inter alia subsidies/fiscal incentives,
ODA, etc, where applicable), and, as
appropriate, non-market cost and benefits in
the case of public investors if this is standard

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practice for the selection of public investments
in the host country.
ii. Present the investment analysis in a EB Ann Yes, all the assumptions made in the investment OK OK
transparent manner and provide all the relevant 39 10 analysis for all the options have been presented in
assumptions, preferably in the CDM-PDD, or in Section B.5 of the web hosted PDD.
separate annexes to the CDM-PDD.
iii. Justify and/or cite assumptions. EB Ann Copies of the source documents of the assumptions CAR-35 OK
39 10 have not been provided to the validation team
including feasibility study report, cost of rice husk and
coal, calorific value of rice husk and coal, cost of
power from grid, project costs, etc. Also, complete
details of the sources of input values in assumptions
are not mentioned e.g. reference no., date of
document, etc.
iv. In calculating the financial/economic indicator, EB Ann This is not included, as project participant has opted - -
the project’s risks can be included through the 39 10 for investment comparison analysis. However, refer to
cash flow pattern, subject to project-specific the CAR raised above in (6.o) and (6.p).
expectations and assumptions.
v. Assumptions and input data for the investment EB Ann The assumptions and input values are found OK OK
analysis shall not differ across the project 39 10 consistent across the investment analysis.
activity and its alternatives, unless differences
can be well substantiated.
vi. Present in the CDM-PDD a clear comparison of EB Ann The comparison of the operation cost of the OK OK
the financial indicator for the proposed CDM 39 10 alternatives along with project activity has been
activity.Please specify details for above. presented in the investment analysis in section B.5 of
web hosted PDD.
r. Has the below guideline followed for Sub-step 2d: EB Ann The sensitivity analysis has been carried out for the CL-9 OK
Sensitivity analysis (only applicable to Options II 39 10 variables like cost of fuel and calorific values of fuels.
and III)? Include a sensitivity analysis that shows Project participant to clarify why project cost is not

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whether the conclusion regarding the subjected to sensitivity analysis.
financial/economic attractiveness is robust to
reasonable variations in the critical assumptions.
s. Has the outcome of Step 2 clearly mentioned EB Ann The out comes of the investment analysis have been OK OK
with justification? 39 10 mentioned in section B.5 of the web hosted PDD.
t. In step 3: Barrier analysis have all the sub-steps EB Ann - -
as below been followed? 39 10
i. Sub-step 3a: Identify barriers that would EB Ann Not applicable as the project participant has opted OK OK
prevent the implementation of the proposed 39 10 investment analysis as per Attachment A to Appendix
CDM project activity; B of simplified modalities and procedure being a
small-scale project activity.
ii. Sub-step 3 b: Show that the identified barriers EB Ann Not applicable as the project participant has opted OK OK
would not prevent the implementation of at 39 10 investment analysis as per Attachment A to Appendix
least one of the alternatives (except the B of simplified modalities and procedure being a
proposed project activity). small-scale project activity.
u. Has the below guideline followed for Sub-step 3a: EB Ann - -
Identify barriers that would prevent the 39 10
implementation of the proposed CDM project?
i. Investment barriers: For alternatives EB Ann Project participant has provided demonstration of OK OK
undertaken and operated by private entities: 39 10 investment barrier following investment analysis.
Similar activities have only been implemented Refer to the section (6.c) of this protocol for details on
with grants or other non-commercial finance the investment analysis
terms. No private capital is available from
domestic or international capital markets due to
real or perceived risks associated with
investment in the country where the proposed
CDM project activity is to be implemented, as
demonstrated by the credit rating of the country
or other country investments reports of reputed

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origin.
ii. Technological barriers: Skilled and/or properly EB Ann Not applicable as the project participant has opted OK OK
trained labour to operate and maintain the 39 10 investment analysis as per Attachment A to Appendix
technology is not available in the relevant B of simplified modalities and procedure being a
country/region, which leads to an unacceptably small-scale project activity.
high risk of equipment disrepair and
malfunctioning or other underperformance;
Lack of infrastructure for implementation and
logistics for maintenance of the technology,
Risk of technological failure: the
process/technology failure risk in the local
circumstances is significantly greater than for
other technologies that provide services or
outputs comparable to those of the proposed
CDM project activity, as demonstrated by
relevant scientific literature or technology
manufacturer information, The particular
technology used in the proposed project activity
is not available in the relevant region.
iii. Barriers due to prevailing practice: The project EB Ann Not applicable as the project participant has opted OK OK
activity is the “first of its kind”. 39 10 investment analysis as per Attachment A to Appendix
B of simplified modalities and procedure being a
small-scale project activity.
iv. Other barriers, preferably specified in the EB Ann Not applicable as the project participant has opted OK OK
underlying methodology as examples. 39 10 investment analysis as per Attachment A to Appendix
B of simplified modalities and procedure being a
small-scale project activity.
v. Has the outcome from Step 3a clearly mentioned EB Ann Not applicable as the project participant has opted OK OK
in PDD? 39 10 investment analysis as per Attachment A to Appendix

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B of simplified modalities and procedure being a
small-scale project activity.
w. Has the below guideline followed for Sub-step 3 EB Ann
b: Show that the identified barriers would not 39 10
prevent the implementation of at least one of the
alternatives (except the proposed project
activity)?
i. If the identified barriers also affect other EB Ann Not applicable as the project participant has opted OK OK
alternatives, explain how they are affected less 39 10 investment analysis as per Attachment A to Appendix
strongly than they affect the proposed CDM B of simplified modalities and procedure being a
project activity. In other words, demonstrate small-scale project activity.
that the identified barriers do not prevent the
implementation of at least one of the
alternatives. Any alternative that would be
prevented by the barriers identified in Sub-step
3a is not a viable alternative, and shall be
eliminated from consideration.
ii. Provide transparent and documented evidence, EB Ann Not applicable as the project participant has opted OK OK
and offer conservative interpretations of this 39 10 investment analysis as per Attachment A to Appendix
documented evidence, as to how it B of simplified modalities and procedure being a
demonstrates the existence and significance of small-scale project activity.
the identified barriers and whether alternatives
are prevented by these barriers.
iii. The type of evidence to be provided should EB Ann Not applicable as the project participant has opted OK OK
include at least one of the following: (a) 39 10 investment analysis as per Attachment A to Appendix
Relevant legislation, regulatory information or B of simplified modalities and procedure being a
industry norms; (b) Relevant (sectoral) studies small-scale project activity.
or surveys (e.g. market surveys, technology
studies, etc) undertaken by universities,

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research institutions, industry associations,
companies, bilateral/multilateral institutions, etc;
(c) Relevant statistical data from national or
international statistics; (d) Documentation of
relevant market data (e.g. market prices, tariffs,
rules); (e) Written documentation of
independent expert judgments from industry,
educational institutions (e.g. universities,
technical schools, training centres), industry
associations and others. Please specify.
x. Has the outcome from Step 3 clearly mentioned EB Ann Not applicable as the project participant has opted OK OK
in PDD? 39 10 investment analysis as per Attachment A to Appendix
B of simplified modalities and procedure being a
small-scale project activity.
y. In step 4: Common practise analysis have all the EB Ann
sub-steps as below followed? 39 10
i. Sub-step 4a: Analyze other activities similar to EB Ann Not applicable as the project participant has opted OK OK
the proposed project activity; 39 10 investment analysis as per Attachment A to Appendix
B of simplified modalities and procedure being a
small-scale project activity.
ii. Sub-step 4b: Discuss any similar Options that EB Ann Not applicable as the project participant has opted OK OK
are occurring. 39 10 investment analysis as per Attachment A to Appendix
B of simplified modalities and procedure being a
small-scale project activity.
z. Has the below guideline followed for Sub-step 4a: EB Ann Not applicable as the project participant has opted OK OK
Analyze other activities similar to the proposed 39 10 investment analysis as per Attachment A to Appendix
project activity? Provide an analysis of any other B of simplified modalities and procedure being a
activities that are operational and that are similar small-scale project activity.
to the proposed project activity. Other CDM

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project activities are not to be included in this
analysis. Provide documented evidence and,
where relevant, quantitative information. On the
basis of that analysis, describe whether and to
which extent similar activities have already
diffused in the relevant region.
aa. Has the below guideline followed for Sub-step 4b: EB Ann Not applicable as the project participant has opted OK OK
Discuss any similar Options that are occurring? If 39 10 investment analysis as per Attachment A to Appendix
similar activities are identified, then it is B of simplified modalities and procedure being a
necessary to demonstrate why the existence of small-scale project activity.
these activities does not contradict the claim that
the proposed project activity is
financially/economically unattractive or subject to
barriers. This can be done by comparing the
proposed project activity to the other similar
activities, and pointing out and explaining
essential distinctions between them that explain
why the similar activities enjoyed certain benefits
that rendered it financially/economically attractive
(e.g., subsidies or other financial flows) and
which the proposed project activity cannot use or
did not face the barriers to which the proposed
project activity is subject. In case similar projects
are not accessible, the PDD should include
justification about non-accessibility of
data/information.
bb. Has the outcome from Step 4 clearly mentioned EB Ann Not applicable as the project participant has opted OK OK
in PDD? 39 10 investment analysis as per Attachment A to Appendix
B of simplified modalities and procedure being a

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small-scale project activity.
cc. Has it been proved that the porject is additional? EB Ann Not applicable as the project participant has opted OK OK
39 10 investment analysis as per Attachment A to Appendix
B of simplified modalities and procedure being a
small-scale project activity.
dd. Has the PP demonstrated additionality by EB Ann Project participant has provided demonstration of OK OK
explaining Investment barrier, Access-to-finance 35 34 investment barrier following investment analysis.
barrier, Technological barrier, Barrier due to Refer to the section (6.c) of this protocol for details on
prevailing practice or other barriers? the investment analysis
ee. If Investment barrier has been explained, is it EB Ann The selection of the option of investment analysis is - -
demonstraed that financilly more viable 35 34 not appropriate. Refer to relevant CAR raised above
alternative to the project activity would have led in (6.o) and (6.p).
to higher emissions? Please explain.
ff. If Access-to-finance has been explained, is it EB Ann Project participant has provided demonstration of OK OK
demonstraed that the project activity could not 35 34 investment barrier following investment analysis.
access appropriate capital without consideration
of the CDM revenues? Please explain.
gg. If Technological barrier has been explained, is it EB Ann Project participant has provided demonstration of OK OK
demonstraed that a less technologically 35 34 investment barrier following investment analysis.
advanced alternative to the project activity
involves lower risks due to the performance
uncertinity or low market share of the new
technology adopted for the project activity and so
would have led to higher emissions? Please
explain.
hh. If prevailing practise barrier has been explained, EB Ann Project participant has provided demonstration of OK OK
is it demonstrated that the prevailing practice or 35 34 investment barrier following investment analysis.
existing regulatory or policy requirements would
have led to implementation of a technology with

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higher emissions? Please explain.
ii. If other barrier has been explained, is it EB Ann Project participant has provided demonstration of OK OK
demonstrated that Other barriers such as 35 34 investment barrier following investment analysis.
institutional barriers or limited information,
managerial resources, organizational capacity, or
capacity to absorb new technologies would
prevent the project activity any way?
jj. Have the project participants identifed the most EB Ann Yes, project participant has identified investment OK OK
relevant barrier? 35 34 barrier as the most relevant to proposed CDM project
activity.
kk. Have the project participants provided EB Ann Project participant has not provided the transparent CAR-35 OK
transparent and documented third party evidence 35 34 documents to the validation team including feasibility
such as national/international statistics, study report, cost of rice husk and coal, calorific value
national/provincial policy and legislation, of rice husk and coal, cost of power from grid, project
studies/surveys by independent agencies etc. to costs, etc. Also, complete details of the sources of
demonstrate the most relevant barrier? Please input values in assumptions are not mentioned e.g.
explain. reference no., date of document, etc.
a. Prior consideration of the clean
development mechanism
a. Is the project ativity start date prior to the date of VVM 96 As per PDD, the project activity start date is OK OK
publication of the PDD for stakeholder 01/03/2008 and the PDD was published for global
comments? stakeholder comments from 10th July 2010 to 8th
August 2010. Hence, the project activity start date is
prior to its publication date for global stakeholder
comments.
b. If yes, were the CDM benefits considered VVM 96 Yes, the CDM benefits were considered necessary in OK OK
necessary in the decision to undertake the decision to undertake the project. This has been
project as a proposed CDM project activity? confirmed by reviewing the original board meeting
register dated 01/02/2008.

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c. Is the start date of the project activity, reported in VVM 97 The start date of project activity, as reported in web OK OK
the PDD, in accordance with the “Glossary of hosted PDD, is 01/03/2008, which is date of Purchase
CDM terms”, which states that “The starting date Order of boiler. This is in accordance with the EB-41
of a CDM project activity is the earliest date at as well as glossary of CDM terms.
which either the implementation or construction
or real action of a project activity begins.”?
d. Does the project activity require construction, VVM 97 Yes, the project activity is a green field project from OK OK
retrofit or other modifications? concept to commissioning of 10 MW co-generation
plant and hence requires construction.
e. If yes, is it ensured that the date of VVM 97 The project was commissioned on 10/01/2010, which OK OK
commissioning cannot be considered as the is not considered as a start date of project activity.
project activity start date?
f. Is it a new project activity (project activities with VVM 98 It is not a new project activity having start date as OK OK
staring date on or after 02 August 2008) or an 01/03/2008, which is before 02/08/2008.
existing project activity (project activities with a
start date before 02 August 2008)?
g. For a new project, for which PDD has not been VVM 99 Not applicable as the project activity is an existing OK OK
published for global stakeholder consultation or a project having start date before 02/08/2008.
new methodology proposed to the Executive
Board before the project activity start date, had
the PP informed the Host Party DNA and/or the
UNFCCC secretariat in writing of the
commencement of the project activity and of their
intention to seek CDM status? (Provide reference
to such confirmation from Hos Party DNA and/or
UNFCCC secretariat).
h. For an existing project activity, for which the start VVM 100 -
date is prior to the date of publication of the PDD
for global stakeholder consultation, are the

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following evidences provided:
i. evidence that must indicate that awareness of VVM 100 -
the CDM prior to the project activity start date,
and that the benefits of the CDM were a
decisive factor in the decision to proceed with
the project, including, inter alia:
1. minutes and/or notes related to the The validation team, during site visit, has reviewed the OK OK
consideration of the decision by the Board original board meeting register. The minutes of board
of Directors, or equivalent, of the project meeting dated 01/02/2008 indicates that the benefits
participant, to undertake the project as a of the CDM were a decisive factor in the decision to
proposed CDM project activity? proceed with the project.
ii. reliable evidence from project participants that VVM 100 The detailed chronology of events has been CL-10 OK
must indicate that continuing and real actions presented in section B.5 of the web hosted PDD,
were taken to secure CDM status for the project however project participant has not submitted the
in parallel with its implementation, including, evidences of each event, which are required to be
inter alia: submitted. Also, project participant is requested
provide a comparative table showing actions towards
project implementation and securing CDM status of
the project activity.
1. contract with consultants for VVM 100 Contract with CDM consultant to is not provided. - -
CDM/PDD/methodology services? Refer to above comment.
2. Emission Reduction Purchase VVM 100 The project participant has not entered in to Emission OK OK
Agreements or other documentation Reduction Purchase Agreements pr other
related to the sale of the potential CERs documentation related to sale of potential CERs.
(including correspondence with
multilateral financial institutions or carbon
funds)?
3. evidence of agreements or negotiations VVM 100 Provide evidences of the communications related to OK OK
with a DOE for validation services? DOE appointment.

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4. submission of a new methodology to the VVM 100 Not applicable as the project activity uses OK OK
CDM Executive Board? methodology, which is previously approved by CDM-
EB.
5. publication in newspaper? VVM 100 The web hosted PDD is silent on whether a general OK OK
invitation notice was provided in newspaper for the
local stakeholders’ meeting. Please clarify and
provided evidence of the same if any.
6. interviews with DNA? VVM 100 Provide supporting documents for various - -
correspondence with DNA for obtaining host country
approval.
7. earlier correspondence on the project with VVM 100 There is no other communication with DNA or OK OK
the DNA or the UNFCCC secretariat? UNFCCC on the project activity.
b. Identification of alternatives
a. Does the approved methodology that is selected VVM 103 The approved methodology AMS I C, Version 17 CAR-36 OK
by the proposed CDM project activity prescribe prescribes various options in its Para 15 (a) to 15 (h)
the baseline scenario and hence no further for baseline identification. Further, the project activity
analysis is required? involves capacity addition in both thermal energy and
electrical energy as compared to pre project scenario
and hence having historical data available. The
project activity cannot be considered completely
greenfield project activity. Thus, the baseline
identification is not in accordance with the applied
methodology.
b. If no, does the PDD identify credible alternatives VVM 103 The approved methodology AMS I C, Version 17 CAR-36 OK
to the project activity in order to determine the prescribes various options in its Para 15 (a) to 15 (h)
most realistic baseline scenario? for baseline identification. Further, the project activity
involves capacity addition in both thermal energy and
electrical energy as compared to pre project scenario
and hence having historical data available. The

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project activity cannot be considered completely
greenfield project activity. Thus, the baseline
identification is not in accordance with the applied
methodology.
c. Does the list of alternatives given in the PDD VVM 104 - -
esure that:
i. the list of alternatives includes as one of the VVM 104 Yes, the project participant has taken one of the OK OK
options that the project activity is alternatives as the project activity is undertaken
undertaken without being registered as a without being registered as a proposed CDM project
proposed CDM project activity? activity.
ii. the list contains all plausible alternatives VVM 104 The approved methodology AMS I C, Version 17 CAR–37 OK
that the DOE, on the basis of its local and prescribes various options in its Para 15 (a) to 15 (h)
sectoral knowledge, considers to be viable for baseline identification. Further, the project activity
means of supplying the outputs or services involves capacity addition in both thermal energy and
that are to be supplied by the proposed electrical energy as compared to pre project scenario
CDM project activity? and hence having historical data available. The
project activity cannot be considered completely
greenfield project activity. Thus, the baseline
identification is not in accordance with the applied
methodology.
iii. the alternatives comply with all applicable VVM 104 Yes, all the alternatives listed in the PDD, do comply OK OK
and enforced legislation? with all applicable and enforced legislation.
c. Investment analysis
a. Has investment analysis been used to VVM 106 Yes, the project participant has carried out the OK OK
demonstrate the additionality of the proposed investment analysis to demonstrate the additionality of
CDM project activity? the proposed CDM project activity.
b. If yes, does the PDD provide evidence that the VVM 106 - -
proposed CDM project activity would not be:
i. the most economically or financially VVM 106 The project participant has provided a demonstration CAR -34 OK

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attractive alternative? on levelise cost based on cost of operations, which is
not correct. Also, the project participant has not
computed the levelised cost of energy production/unit
of output. Instead the total project cost has been
computed which is not in line with the procedures of
investment comparison analysis. The project
participant has not applied benchmark analysis
(Option III). As per validation team’s opinion
benchmark analysis is more appropriate as per the
Para 16 of “Guidelines on the assessment of the
investment analysis” (Annex 58, EB-51). In scenario
existing prior to the project activity, the PP has been
supplied electricity from PSEB grid. Further, as per
discussion with the project participant, there will be
export of power also to grid to the tune of
approximately 2.0 MW. For the thermal energy, in
baseline there were boiler and a thermopack. Thus,
the project participant does not have compulsory
investment. Thus, investment comparison analysis is
not appropriate.
ii. economically or financially feasible, without VVM 106 The project participant has provided a demonstration CAR-34 OK
the revenue from the sale of certified on levelise cost based on cost of operations, which is
emission reductions (CERs)? not correct. Also, the project participant has not
computed the levelised cost of energy production/unit
of output. Instead the total project cost has been
computed which is not in line with the procedures of
investment comparison analysis. The project
participant has not applied benchmark analysis
(Option III). As per validation team’s opinion

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investment comparison analysis is not appropriate as
per the Para 16 of “Guidelines on the assessment of
the investment analysis” (Annex 58, EB-51). In
scenario existing prior to the project activity, the PP
has been supplied electricity from PSEB grid. Further,
as per discussion with the project participant, there
will be export of power also to grid to the tune of
approximately 2.0 MW. For the thermal energy, in
baseline there were boiler and a thermopack. Thus,
the project participant does not have compulsory
investment. Thus, investment comparison analysis is
not appropriate.
c. Was this shown by one of the following VVM 107 - -
approaches?
i. The proposed CDM project activity would VVM 107 The project participant has not applied benchmark CL-11 OK
produce no financial or economic benefits analysis (Option III). As per validation team’s opinion
other than CDM-related income. Document benchmark analysis is more appropriate as per the
the costs associated with the proposed Para 16 of “Guidelines on the assessment of the
CDM project activity and the alternatives investment analysis” (Annex 58, EB-51). Further, as
identified and demonstrate that there is at per discussion with the project participant, there will
least one alternative which is less costly be export of power also to PSEB grid to the tune of
than the proposed CDM project activity. approximately 2.0 MW. Since, the PP will have
captive power generation, it is required to clarify what
will be the difference in cost of power between grid
power and captive power as it is very obvious and
discussed with PP that the cost of grid is higher than
the cost of self-generation. These scenarios will bring
cash in flow other than CDM revenue.
ii. The proposed CDM project activity is less VVM 107 The project participant has provided a demonstration CAR-34 OK

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economically or financially attractive than at on levelise cost based on cost of operations, which is
least one other credible and realistic not correct. Also, the project participant has not
alternative. computed the levelised cost of energy production/unit
of output. Instead the total project cost has been
computed which is not in line with the procedures of
investment comparison analysis. The project
participant has not applied benchmark analysis
(Option III). As per validation team’s opinion
investment comparison analysis is not appropriate as
per the Para 16 of “Guidelines on the assessment of
the investment analysis” (Annex 58, EB-51). In
scenario existing prior to the project activity, the PP
has been supplied electricity from PSEB grid. Further,
as per discussion with the project participant, there
will be export of power also to grid to the tune of
approximately 2.0 MW. For the thermal energy, in
baseline there were boiler and a thermopack. Thus,
the project participant does not have compulsory
investment. Thus, investment comparison analysis is
not appropriate.
iii. The financial returns of the proposed CDM VVM 107 The project participant has selected levelized cost of - -
project activity would be insufficient to energy production to demonstrate investment barrier.
justify the required investment. The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
d. Is the period of assessment limited to the EB Ann The period of assessment taken for levelized cost CAR-37 OK
proposed crediting period of the CDM project 51 58 analysis is only 10 years. Project participant to take
activity? the entire technical lifetime of the project activity as a

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period of assessment or provide justification why 10
year assessment period will not lead to
under/overestimation of the computation results.
e. Does the project IRR and equity IRR calculations EB Ann The project participant has selected levelized cost of OK OK
reflect the period of expected operation of the 51 58 energy production to demonstrate investment barrier.
underlying project activity (technical lifetime), or - The financial returns of the proposed project activity
if a shorter period is chosen - include the fair have not been computed. Hence, this is not
value of the project activity assets at the end of applicable.
the assessment period?
f. Does the IRR calculation include the cost of EB Ann The project participant has selected levelized cost of OK OK
major maintenance and/or rehabilitation if these 51 58 energy production to demonstrate investment barrier.
are expected to be incurred during the period of The financial returns of the proposed project activity
assessment? have not been computed. Hence, this is not
applicable.
g. Do the project participants justify the EB Ann The period of assessment taken for levelized cost CAR-37 OK
appropriateness of the period of assessment in 51 58 analysis is only 10 years. Project participant to take
the context of the underlying project activity, the entire technical lifetime of the project activity as a
without reference to the proposed CDM crediting period of assessment or provide justification why 10
period? year assessment period will not lead to
under/overestimation of the computation results.
h. Does the cash flow in the final year include a fair EB Ann The project participant has selected levelized cost of OK OK
value of the project activity assets at the end of 51 58 energy production to demonstrate investment barrier.
the assessment period? The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
i. Has the fair value been calculated in accordance EB Ann The project participant has selected levelized cost of OK OK
with local accounting regulations where available, 51 58 energy production to demonstrate investment barrier.
or international best practice? The financial returns of the proposed project activity

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have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
j. Does the fair value calculations include both the EB Ann The project participant has selected levelized cost of OK OK
book value of the asset and the reasonable 51 58 energy production to demonstrate investment barrier.
expectation of the potential profit or loss on the The financial returns of the proposed project activity
realization of the assets? have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
k. Was depreciation, and other non-cash items EB Ann The project participant has selected levelized cost of OK OK
related to the project activity, which have been 51 58 energy production to demonstrate investment barrier.
deducted in estimating gross profits on which tax The financial returns of the proposed project activity
is calculated, added back to net profits for the have not been computed. Hence, this is not
purpose of calculating the financial indicator (e.g. applicable. However, refer to CAR raised above in
IRR, NPV)? (6.o) and (6.p) above.
l. Has taxation been included as an expense in the EB Ann The project participant has selected levelized cost of OK OK
IRR/NPV calculation in cases where the 51 58 energy production to demonstrate investment barrier.
benchmark or other comparator is intended for The financial returns of the proposed project activity
post-tax comparisons? have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
m. Are the input values used in all investment EB Ann Copies of the source documents of the assumptions CAR-35 OK
analysis valid and applicable at the time of the 51 58 have not been provided to the validation team
investment decision taken by the project including feasibility study report, cost of rice husk and
participant? coal, calorific value of rice husk and coal, cost of
power from grid, project costs, etc. Also, complete
details of the sources of input values in assumptions
are not mentioned e.g. reference no., date of
document, etc.

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n. Is the timing of the investment decision EB Ann Copies of the source documents of the assumptions CAR-35 OK
consistent and appropriate with the input values? 51 58 have not been provided to the validation team
including feasibility study report, cost of rice husk and
coal, calorific value of rice husk and coal, cost of
power from grid, project costs, etc. Also, complete
details of the sources of input values in assumptions
are not mentioned e.g. reference no., date of
document, etc.
o. Are all the listed input values been consistently EB Ann Yes, all the input values are consistently applied in all OK OK
applied in all calculations? 51 58 the calculations.
p. Does the investment analysis reflect the EB Ann This condition is not applicable as the implementation OK OK
economic decision making context at point of the 51 58 did not cease for this project activity.
decision to recomence the project in the case of
project activities for which implementation ceases
after the commencement and where
implementation is recommenced due to
consideration of the CDM?
q. Have project participants supplied the EB Ann Yes, the spreadsheet version of the investment OK OK
spreadsheet versions of all investment analysis? 51 58 analysis has been provided by the project participant.
r. Are all formulas used in this analysis readable EB Ann The work sheet of the “Sensitivity Analysis” contains CL-12 OK
and all relevant cells be viewable and 51 58 the values, which are provided as absolute figures,
unprotected? which is not correct. It is required to provide all the
relevant formula and spreadsheet links for transparent
illustration of the sensitivity analysis.
s. In cases where the project participant does not EB Ann All the formulas in the analysis are readable and all OK OK
wish to make such a spreadsheet available to the 51 58 the relevant cells are viewable.
public has the PP provided an exact read-only or
PDF copy for general publication?
t. In case the PP wishes to black-out certain EB Ann All the formulas in the analysis are readable and all OK OK

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elements of the publicly available version, is it 51 58 the relevant cells are viewable.
justifiable?
u. Was the cost of financing expenditures (i.e. loan EB Ann The project participant has selected levelized cost of OK OK
repayments and interest) included in the 51 58 energy production to demonstrate investment barrier.
calculation of project IRR? The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
v. In the calculation of equity IRR, has only the EB Ann The project participant has selected levelized cost of OK OK
portion of investment costs which is financed by 51 58 energy production to demonstrate investment barrier.
equity been considered as the net cash outflow? The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
w. Has the portion of the investment costs which is EB Ann The project participant has selected levelized cost of OK OK
financed by debt been considered a cash outflow 51 58 energy production to demonstrate investment barrier.
in the calcualtion of equity IRR? (this is not The financial returns of the proposed project activity
allowed) have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
x. Was a pre-tax benchmark be applied? EB Ann The project participant has selected levelized cost of OK OK
51 58 energy production to demonstrate investment barrier.
The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
y. In cases where a post-tax benchmark is applied, EB Ann The project participant has selected levelized cost of OK OK
is actual interest payable taken into account in 51 58 energy production to demonstrate investment barrier.
the calculation of income tax? The financial returns of the proposed project activity

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have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
z. In such situations, was interest calculated EB Ann The project participant has selected levelized cost of OK OK
according to the prevailing commercial interest 51 58 energy production to demonstrate investment barrier.
rates in the region, preferably by assessing the The financial returns of the proposed project activity
cost of other debt recently acquired by the project have not been computed. Hence, this is not
developer and by applying a debt-equity ratio applicable. However, refer to CAR raised above in
used by the project developer for investments (6.o) and (6.p) above.
taken in the previous three years?
aa. In cases where a benchmark approach is used is EB Ann The project participant has selected levelized cost of - -
the applied benchmark appropriate to the type of 51 58 energy production to demonstrate investment barrier.
IRR calculated? The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
bb. Has local commercial lending rates or weighted EB Ann The project participant has selected levelized cost of - -
average costs of capital (WACC) selected as 51 58 energy production to demonstrate investment barrier.
appropriate benchmarks for a project IRR? The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
cc. Has required/expected returns on equity selected EB Ann The project participant has selected levelized cost of OK OK
as appropriate benchmark for an equity IRR? 51 58 energy production to demonstrate investment barrier.
The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
dd. In case benchmarks supplied by relevant national EB Ann The project participant has selected levelized cost of OK OK

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authorities selected is it applicable to the project 51 58 energy production to demonstrate investment barrier.
activity and the type of IRR calculation The financial returns of the proposed project activity
presented? have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
ee. In the cases of projects which could be EB Ann The project participant has selected levelized cost of OK OK
developed by an entity other than the project 51 58 energy production to demonstrate investment barrier.
participant is the benchmark applied based on The financial returns of the proposed project activity
publicly available data sources which can be have not been computed. Hence, this is not
clearly validated? applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
ff. Have internal company benchmarks/expected EB Ann The project participant has selected levelized cost of OK OK
returns (including those used as the expected 51 58 energy production to demonstrate investment barrier.
return on equity in the calculation of a weighted The financial returns of the proposed project activity
average cost of capital - WACC) been applied in have not been computed. Hence, this is not
cases where there is only one possible project applicable. However, refer to CAR raised above in
developer? (6.o) and (6.p) above.
gg. In such cases, have these values been used for EB Ann The project participant has selected levelized cost of OK OK
similar projects with similar risks, developed by 51 58 energy production to demonstrate investment barrier.
the same company or, if the company is brand The financial returns of the proposed project activity
new, would have been used for similar projects in have not been computed. Hence, this is not
the same sector in the country/region? applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.
hh. Has a minimum clear evidence of the resolution EB Ann The project participant has selected levelized cost of OK OK
by the company’s Board and/or shareholders 51 58 energy production to demonstrate investment barrier.
been provided to the effect as above? The financial returns of the proposed project activity
have not been computed. Hence, this is not
applicable. However, refer to CAR raised above in
(6.o) and (6.p) above.

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ii. Has a thorough assessment of the financial EB Ann The project participant has selected levelized cost of OK OK
statements of the project developer - including 51 58 energy production to demonstrate investment barrier.
the proposed WACC - to assess the past The financial returns of the proposed project activity
financial behavior of the entity during at least the have not been computed. Hence, this is not
last 3 years in relation to similar projects been applicable. However, refer to CAR raised above in
conduted? (6.o) and (6.p) above.
jj. Does the risk premiums applied in the EB Ann The project participant has selected levelized cost of OK OK
determination of required returns on equity 51 58 energy production to demonstrate investment barrier.
reflect the risk profile of the project activity being The financial returns of the proposed project activity
assessed, established according to have not been computed. Hence, this is not
national/international accounting principles? (It is applicable. However, refer to CAR raised above in
not considered reasonable to apply the rate (6.o) and (6.p) above.
general stock market returns as a risk premium
for project activities that face a different risk
profile than an investment in such indices.)
kk. Has an investment comparison analysis and not EB Ann Yes, the project participant has selected levelized cost OK OK
a benchmark analysis used when the proposed 51 58 of energy production to demonstrate investment
baseline scenario leaves the project participant barrier.
no other choice than to make an investment to
supply the same (or substitute) products or
services?
ll. Have variables, including the initial investment EB Ann Yes, as per PDD variables including the initial CAR-38 OK
cost, that constitute more than 20% of either total 51 58 investment cost, that constitute more than 20% of
project costs or total project revenues been either total project costs or total project revenues been
subjected to reasonable variation (positive and subjected to reasonable variation.
negative) and the results of this variation been The sensitivity analysis has been carried out by the
presented in the PDD and be reproducible in the project participant on parameters price of baseline
associated spreadsheets? and project activity fuel, calorific value of basline fuel
and project activity fuel. However, project participant

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has not demonstrated clearly as how variables
selected constitue more than 20% of the total project
cost and under which circumstances the variation
would occur.
mm. Have a corrective action been raised for a EB Ann The following corrective action request is raised by the CAR-38 OK
variable to be included in the sensitivity analysis 51 58 validation team.
which constitute less than 20% and have a The sensitivity analysis has been carried out by the
material impact on the analysis ? project participant on parameters price of baseline
and project activity fuel, calorific value of basline fuel
and project activity fuel. However, project participant
has not demonstrated clearly as how variables
selected constitue more than 20% of the total project
cost and under which circumstances the variation
would occur.
nn. Is the range of variations selected is reasonable EB Ann The range of variation taken for senstivity analysis by OK OK
in the project context? 51 58 project participant is ±10%, which is an appropriate
range.
oo. Does the variations in the sensitivity analysis at EB Ann The range of variation taken for senstivity analysis by OK OK
least cover a range of +10% and -10%, unless 51 58 project participant is ±10%, which is an appropriate
this is not deemed appropriate in the context of range.
the specific project circumstances?
pp. In cases where a scenario will result in the EB Ann The project participant has not applied benchmark CAR-34 OK
project activity passing the benchmark or 51 58 analysis (Option III). As per validation team’s opinion,
becoming the most financially attractive investment comparison analysis is not appropriate as
alternative, is an assessment done of the per the Para 16 of “Guidelines on the assessment of
probability of the occurrence of this scenario in the investment analysis” (Annex 58, EB-51). In
comparison to the likelihood of the assumptions scenario existing prior to the project activity, the PP
in the presented investment analysis, taking into has been supplied electricity from PSEB grid. Further,
consideration correlations between the variables as per discussion with the project participant, there

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as well as the specific socio-economic and policy will be export of power also to grid to the tune of
context of the project activity? approximately 2.0 MW. For the thermal energy, in
baseline there were boiler and a thermopack. Thus,
the project participant does not have compulsory
investment. Thus, investment comparison analysis is
not appropriate.
qq. Was the plant load factor defined ex-ante in the EB Ann - -
CDM-PDD according to one of the following 51 58
options:
i. The plant load factor provided to banks EB Ann As the project participant has used the levelised cost - -
and/or equity financiers while applying the 51 58 analysis to demonstrate investment barrier, plant load
project activity for project financing, or to factor has not been used in levelised cost analysis.
the government while applying the project However, refer to CAR raised above in section 6.p
activity for implementation approval? and 6.o above.
ii. The plant load factor determined by a third EB Ann As the project participant has used the levelised cost - -
party contracted by the project participants 51 58 analysis to demonstrate investment barrier, plant load
(e.g. an engineering company)? factor has not been used in levelised cost analysis.
However, refer to CAR raised above in section 6.p
and 6.o above.
rr. Was a thorough assessment of all parameters VVM 109 Copies of the source documents of the assumptions CAR-35 OK
and assumptions used in calculating the relevant have not been provided to the validation team
financial indicator, and determine the accuracy including feasibility study report, cost of rice husk and
and suitability of these parameters using the coal, calorific value of rice husk and coal, cost of
available evidence and expertise in relevant power from grid, project costs, etc. Also, complete
accounting practices conducted? details of the sources of input values in assumptions
are not mentioned e.g. reference no., date of
document, etc.
ss. Were the parameters cross-checked agains third- VVM 109 Copies of the source documents of the assumptions CAR-35 OK
party or publicly available sources, such as have not been provided to the validation team

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invoices or price indices? including feasibility study report, cost of rice husk and
coal, calorific value of rice husk and coal, cost of
power from grid, project costs, etc. Also, complete
details of the sources of input values in assumptions
are not mentioned e.g. reference no., date of
document, etc.
tt. Were feasibility reports, public announcements VVM 109 The project participant has not submitted the CAR-35 OK
and annual financial reports related to the feasibility study report to the validation team.
proposed CDM project activity and the project
participants reviewed?
uu. Was the correctness of computations carried out VVM 109 Yes, the correctness of the computations is carried OK OK
and documented by the project participants out and same is found correct.
assessed?
vv. Was the sensitivity analysis by the project VVM 109 No, the sensivity analysis is done for the range from CL-13 OK
participants to determine under what conditions +10% to –10%. It does not include the details of the
variations in the result would occur, and the under what conditions variations in the result would
likelihood of these conditions assessed? occur, and the likelihood of these conditions
assessed.
ww. Is the type of benchmark applied is suitable for VVM 110 Project participant has not used any bechmark. OK OK
the type of financial indicator presented? Levelized cost of energy has been used to
demonstrate the additionality.
xx. Do any risk premiums applied determining the VVM 110 Project participant has not used any bechmark. OK OK
benchmark reflect the risks associated with the Levelized cost of energy has been used to
project type or activity? demonstrate the additionality.
yy. To determine this, was it assessed whether it is Project participant has not used any bechmark. OK OK
reasonable to assume that no investment would Levelized cost of energy has been used to
be made at a rate of return lower than the demonstrate the additionality.
benchmark by:
iii. assessing previous investment decisions by VVM 110 Project participant has not used any bechmark. OK OK

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the project participants involved? Levelized cost of energy has been used to
demonstrate the additionality.
iv. determining whether the same benchmark VVM 110 Project participant has not used any bechmark. OK OK
has been applied? Levelized cost of energy has been used to
demonstrate the additionality.
v. determining if there are verifiable VVM 110 Project participant has not used any bechmark. OK OK
circumstances that have led to a change in Levelized cost of energy has been used to
the benchmark? demonstrate the additionality.
zz. Did the project participants rely on values from VVM 111 As per the investment analysis spreadsheet submitted CL-14 OK
Feasibility Study Reports (FSR) that are during validation, the project participant rely on many
approved by national authorities for proposed assumptions and values from the feasibility report.
CDM project activities? However, the extract of the board resolution submitted
by the project participant does not refer to any
feasibility report. Project participant to clarify the
timing of the feasibility report with respect to the
investment decision context and provide the
supporting evidences for the values considered in the
feasibility report. The copy of the feasibility report is to
be submitted.
xx. If yes: VVM 111
i. has the FSR been the basis of the decision VVM 111 As per the investment analysis spreadsheet submitted CL-14 OK
to proceed with the investment in the during validation, the project participant rely on many
project, i.e. that the period of time between assumptions and values from the feasibility report.
the finalization of the FSR and the However, the extract of the board resolution submitted
investment decision is sufficiently short for by the project participant does not refer to any
the DOE to confirm that it is unlikely in the feasibility report. Project participant to clarify the
context of the underlying project activity that timing of the feasibility report with respect to the
the input values would have materially investment decision context and provide the
changed? supporting evidences for the values considered in the

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feasibility report. The copy of the feasibility report is to
be submitted.
ii. Are the values used in the PDD and VVM 111 As per the investment analysis spreadsheet submitted CL-14 OK
associated annexes fully consistent with the during validation, the project participant rely on many
FSR? assumptions and values from the feasibility report.
However, the extract of the board resolution submitted
by the project participant does not refer to any
feasibility report. Project participant to clarify the
timing of the feasibility report with respect to the
investment decision context and provide the
supporting evidences for the values considered in the
feasibility report. The copy of the feasibility report is to
be submitted.
iii. If not, was the appropriateness of the VVM 111 As per the investment analysis spreadsheet submitted CL-14 OK
values validated? during validation, the project participant rely on many
assumptions and values from the feasibility report.
However, the extract of the board resolution submitted
by the project participant does not refer to any
feasibility report. Project participant to clarify the
timing of the feasibility report with respect to the
investment decision context and provide the
supporting evidences for the values considered in the
feasibility report. The copy of the feasibility report is to
be submitted.
iv. On the basis of its specific local and VVM 111 As per the investment analysis spreadsheet submitted CL-14 OK
sectoral expertise, is confirmation provided, during validation, the project participant rely on many
by cross-checking or other appropriate assumptions and values from the feasibility report.
manner, that the input values from the FSR However, the extract of the board resolution submitted
are valid and applicable at the time of the by the project participant does not refer to any

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investment decision? feasibility report. Project participant to clarify the
timing of the feasibility report with respect to the
investment decision context and provide the
supporting evidences for the values considered in the
feasibility report. The copy of the feasibility report is to
be submitted.
d. Barrier analysis
a. Has barrier analysis been used to demonstrated VVM 113 The proposed project activity is a small-scale project. OK OK
the additionality of the proposed CDM project The project participant has not applied barrier analysis
activity? of Tool to demonstrate additionality. The project
participant has referred to the Attachment A to
Appendix B.
b. If yes, does the PDD demonstrate that the VVM 113
proposed CDM project activity faces barriers that:
i. prevent the implementation of this type of VVM 113 The proposed project activity is a small-scale project. OK OK
proposed CMD project activity? The project participant has not applied barrier analysis
of Tool to demonstrate additionality. The project
participant has referred to the Attachment A to
Appendix B.
ii. do not prevent the implementation of at VVM 113 The proposed project activity is a small-scale project. OK OK
least one of the alternatives? The project participant has not applied barrier analysis
of Tool to demonstrate additionality. The project
participant has referred to the Attachment A to
Appendix B.
c. Are there any issues that have a clear direct VVM 114 The proposed project activity is a small-scale project. OK OK
impact on the financial returns of the project The project participant has not applied barrier analysis
activity, other than: risk related barriers, for of Tool to demonstrate additionality. The project
example risk of technical failure, that could have participant has referred to the Attachment A to
negative effects on the financial performance; or Appendix B.

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barriers related to the unavailability of sources of
finance for the project activity? {If yes, these
issues cannot be considered barriers and shall
be assessed by investment analysis. [Refer to
(6.c) above]}
d. Were the barriers determined as real by: VVM 115
i. assssing the available evidence and/or VVM 115 The proposed project activity is a small-scale project. OK OK
undertaking interviews with relevant The project participant has not applied barrier analysis
individuals (including members of industry of Tool to demonstrate additionality. The project
associations, government officials or local participant has referred to the Attachment A to
experts if necessary) to determine whether Appendix B.
the barriers listed in the PDD exist?
ii. ensuring that existence of barriers is VVM 115 The proposed project activity is a small-scale project. OK OK
substantiated by independent sources of The project participant has not applied barrier analysis
data such as relevant national legislation, of Tool to demonstrate additionality. The project
surveys of local conditions and national or participant has referred to the Attachment A to
international statistics? Appendix B.
iii. Is existence of a barrier substantiated only VVM 115 The proposed project activity is a small-scale project. OK OK
by the opinions of the project participants? The project participant has not applied barrier analysis
(If yes, this barrier cannot be considered as of Tool to demonstrate additionality. The project
adequately substantiated) participant has referred to the Attachment A to
Appendix B.
e. Were the barriers determined as preventing the VVM 115 The proposed project activity is a small-scale project. OK OK
implementation of the project activity but not the The project participant has not applied barrier analysis
implementation of at least one of the possible of Tool to demonstrate additionality. The project
alternatives by applying local and sectoral participant has referred to the Attachment A to
expertise to judge whether a barrier or set of Appendix B.
barriers would prevent the implementation of the
proposed CDM project activity and would not

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equally prevent implementation of at least one of
the possible alternatives, in particular the
identified baseline scenario?
e. Common practice analysis
a. Is this a proposed large-scale, or first-of-its kind VVM 117 The proposed CDM project activity is a small-scale OK OK
small-scale project activity? project where first-of-its kind barrier has not been
demonstrated.
b. If yes, was common practice analysis carried out VVM 117 The proposed CDM project activity is a small-scale OK OK
as a credibility check of the other available project. Common practice analysis is not required.
evidence used by the project participants to
demonstrate additionality?
c. Was it assessed whether the geograpphical VVM 118 The proposed CDM project activity is a small-scale OK OK
scope (e.g. defined region) of the common project. Common practice analysis is not required.
practice analysis is appropriate for the
assessment of common practice related to the
project activity’s technology or industry type? (For
certain technologis the relevatn region for
assessment will be local and for others it may be
transnational/global.
d. Was a region other than the entire host country VVM 118 The proposed CDM project activity is a small-scale OK OK
chosen? project. Common practice analysis is not required.
e. If yes, was the explanation why this region is VVM 118 The proposed CDM project activity is a small-scale OK OK
more appropriate assessed? project. Common practice analysis is not required.
f. Using official sources and local and industry VVM 118 The proposed CDM project activity is a small-scale OK OK
expertise, was it determined to what extent project. Common practice analysis is not required.
similar and operational projects (e.g., using
similar technology or practice), other than CDM
project activities, have been undertaken in the
defined region?

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g. Are similar and operational projects, other than VVM 118 The proposed CDM project activity is a small-scale OK OK
CDM project activities, already ”widely observed project. Common practice analysis is not required.
and commonly carried out” in the defined region?
h. If yes, was it assessed whether there are VVM 118 The proposed CDM project activity is a small-scale OK OK
essential distinctions between the proposed CDM project. Common practice analysis is not required.
project activity and the other similar activities?
7. Monotoring plan
a. Does the PDD include a monitoring plan? VVM 120 Yes, monitoring plan has been included in section OK OK
B.7.2 of the web hosted PDD along with data /
parameters to be monitored in section B.7.1 of the
web hosted PDD.
b. Is this monitoring plan based on the approved VVM 120 Yes, the project participant has referred to AMS I C; OK OK
monitoring methodology applied to the proposed Version 17 approved monitoring methodology for the
CDM project activity? proposed project activity.
c. Were the list of parameters required by the the VVM 121 As per the methodology AMS I C, version 17, the OK OK
selected methodology identified? identified monitoring parameters for this project
activity are:
a. Quantity of electricity generated
b. Quantity of auxillary consumption of electricity
c. Net quantity of electricity supplied
d. Quantity of steam generated
e. Net quantity of thermal energy supplied by the
project activity during the year y;
f. Quantity of fossil fuel type j combusted in year y
g. Net quantity of biomass consumed in year y
h. Steam outlet temperature and pressure
i. Net calorific value of fossil fuel type I
j. Net calorific value of biomass
d. Does the monitoring plan contains all necessary VVM 121 The monitoring plan does not cover following CL-15 OK

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parameters? parameters required for the purpose of conservative
estimates of the emission reductions:
a) Moisture content of the biomass residues
b) Quantity, temperature and pressure of the feed
water
Also, PDD is silent upon how the monitoring of
pressure, temperature and quantity of the steam, that
is going to the process after extraction from the
turbine will be carried out. Further a clarification is
required as what

The web hosted PDD does not include the parameters


to be monitored for project emissions in accordance
with “Tool to calculate baseline, project and/or
leakage emissions from electricity consumption” (EB-
39, Annex 7) on account of electricity consumption
from grid.
e. Are the parameters clearly described? VVM 121 Yes, the parameters to be monitored (which are OK OK
provided in section B.7.1 of the web hosted PDD) are
described correctly.
f. Does the means of monitoring described in the VVM 121 No, the means of monitoring described in the plan CL-15 OK
plan comply with the requirements of the does not comply with the requirements of the
methodology? methodology. The monitoring plan does not cover
following parameters required for the purpose of
conservative estimates of the emission reductions:
a) Moisture content of the biomass residues
b) Quantity, temperature and pressure of the feed
water
Also, PDD is silent upon how the monitoring of

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pressure, temperature and quantity of the steam, that
is going to the process after extraction from the
turbine will be carried out. It is observed during site
visit that the monitoring is done at the generation of
the thermal and electrical energy. As per methodology
it is required to monitor net energy supplied. Thus, the
energy (both thermal and electrical) being monitored
is not net of the transformation, transmission and
distribution losses. Hence, it is required to monitor the
net energy (both thermal and electrical) at user end.

The web hosted PDD does not include the parameters


to be monitored for project emissions in accordance
with “Tool to calculate baseline, project and/or
leakage emissions from electricity consumption” (EB-
39, Annex 7) on account of electricity consumption
from grid.
g. Does the monitoring consist of metering the AMS I.C The monitoring consists of metering of the 100% OK OK
energy produced by a sample of systems where energy produced and not the sampling. Hence this
the simplified baseline is based on the energy condition is not applicable.
produced multiplied by an emission coefficient?
h. Metering the thermal and electrical energy AMS I.C
produced?
i. In the case of heat energy (e.g. hot air, hot AMS I.C The project activity involves steam energy and hence OK OK
water), direct measurement of flow and this condition is not applicable
temperature is required.
ii. In the case of steam energy, direct AMS I.C Yes, the monitoring includes direct measurement of OK OK
measurement of flow, temperature, flow, temperature and pressure for the determination
pressure is required to determine enthalpy of enthalpy of the steam.

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of the steam.
i. If the emissions reduction per system is less than AMS I.C
5 tonnes of CO2e a year:
i. Recording annually the number of systems AMS I.C Not applicable as the emission reduction of the project OK OK
operating (evidence of continuing operation, activity is to the tune of 57399 tCO2 per annum.
such as on-going rental/lease payments could
be a substitute), if necessary using survey
methods;
ii. Estimating the annual hours of operation of an AMS I.C Not applicable as the emission reduction of the project OK OK
average system, if necessary using survey activity is to the tune of 57399 tCO2 per annum.
methods. Annual hours of operation can be
estimated from total output (e.g. tonnes of grain
dried) and output per hour if an accurate value
of output per hour is available.
j. Are these household or commercial applications AMS I.C The metering of thermal energy output is possible and OK OK
where it can be domonstrated the metering of hence the not applicable.
thermal energy output is not plausible, as in the
case of biomass stoves, gasifiers, driers, water
heaters etc?
k. If yes, was the project output energy estimated AMS I.C Not applicable OK OK
based on consumption of the biomass (in terms
of energy quantity) times the efficiency of the
project equipment? BEy = [HGpj,y/ηbl] *
EFff,CO2 = {[Bbiomass,pj,y * NCVbiomass *
ηpj]/ηbl} * EFff,CO2
l. If the Project Activity is using only biomass or AMS I.C Yes, as per section B.7.1, the amount (quantity) of OK OK
biomass and fossil fuel, are the amount of both biomass and fossil fuel consumption is being
biomass and fossil fuel used being monitored ? monitored.
m. What are the various types of fuels used in the AMS I.C Project technology is designed for multiple fuels firing. OK OK

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Project Activity ? The project participant has included monitoring of rice
husk (biomass) and fossil fuel both.
n. Is the consumption of each type of fuel used in AMS I.C Project technology is designed for multiple fuels firing. OK OK
the Project Activity monitored ? The project participant has included monitoring of rice
husk (biomass) and fossil fuel both.
o. In the case of project activity consuming biomass AMS I.C The specific energy consumption of each type of fuel CL-16 OK
and fossil fuel to produce thermal and or being consumed to is not fixed ex-ante in accordance
electrical energy, was the specific energy with the Para 32 of the applied methodology AMS I C,
consumption of each type of fuel (biomass or Version 17.
fossil) to be used specified ex ante?.
p. Is the consumption of each type of fuel AMS I.C Project technology is designed for multiple fuels firing. OK OK
monitored? The project participant has included monitoring of rice
husk (biomass) and fossil fuel both.
q. If more than one type of biomass is consumed in AMS I.C As per the web hosted PDD, only rice husk is being CL-17 OK
the Project Activity, are each type of biomass monitored. Project participant is to clarify, what if any
monitored separately ? other type of biomass than the rice husk is used by
project activity. The monitoring plan is silent on this
scenario.
r. For the specific case of co-fired plants, was the AMS I.C The monitoring plan descriptions in case of co-firing CAR-39 OK
baseline emissions for the amount of thermal by the project activity has not been included the web
energy or electricity produced corresponding to hosted PDD in accordance with Para 33 of the applied
biomass fuels use calculated as follows? methodology AMS I C, Version 17.
BEcofire,y = [∑(FCbiomass,k,y X
NCVbiomass,k,y)]/(SECpj,j,y,measured X ηbl) X
EFbl
s. Are the monitoring arrangements described in the VVM 121 The validation team, during site visit, observed some CL-18 OK
monitoring plan feasible within the project of the meters are not available within the
design? manufacturing facility to monitor the consumption of
net thermal energy at user end.

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Monitoring plan does not include explicit QA/QC


procedures, calibration procedures, cross checking
mechanism, data uncertainty, data archiving etc.

The line diagram including monitoring points of entire


project activity in line with project boundary is not
provided.
t. Are the following means of implementation of the VVM 121 - -
monitoring plan sufficient to ensure that the
emission reductions achieved by/resulting from
the proposed CDM project activity can be
reported ex post and verified:
i. data management procedures? VVM 121 Monitoring plan does not include data uncertainty and
data archiving etc.
ii. quality assurance procedures? VVM 121 QA/QC procedures are not explicitly described. CL-18 OK
iii. quality control procedures? VVM 121 QA/QC procedures are not explicitly described. CL-18 OK
8. Sustainable development
a. Does the CDM project activity assists Parties not VVM 123 Yes, as per the host country approval letter, the OK OK
included in Annex I to the Convention in proposed CDM project activity assists parties not
achieving sustainable development? included in Annex I to the Convention in achieving
sustainable development.
b. Does the letter of approval by the DNA of the VVM 124 Yes, as per the host country approval letter, the OK OK
host Party confirm the contribution of the proposed CDM project activity contributes to the
proposed CDM project activity to the sustainable sustainable development of the host party.
development of the host Party?
9. Local stakeholder consultation
a. Were local stakeholders (public, including VVM 126 Yes, the local stakeholders were invited through OK OK
individuals, groups or communities affected, of personal invitation letters as well as verbal and

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likely to be affected, by the proposed CDM personal invitations on 08/07/2009, which was prior to
project activity or actions leading to the the publication of the PDD on the UNFCCC website.
implementation of such an activity) invited by the
PPs to comment on the proposed CDM project
activity prior to the publication of the PDD on the
UNFCCC website?
b. Have comments by local stakeholders that can VVM 127 Yes, the project participant invited local stakeholders OK OK
reasonably be considered relevant for the comments on proposed CDM project activity.
proposed CDM project activity been invited?
c. Is the summary of the comments received as VVM 127 Project participant has not identified the local CAR-14 OK
provided in the PDD complete? stakeholders who made the comments in section E.2
of the PDD. Besides, the summary of the comments
has not been presented clearly.
d. Have the project participants taken due account VVM 127 As per web hosted PDD and discussion with the local OK OK
of any comments received and described this stakeholders, there was no adverse comment
process in the PDD? received in the local stakeholders’ meeting.
10. Environmental impacts
a. Have the project participants submitted VVM 129 As per the letter from MOEF vide reference OK OK
documentation on the analysis of the SEIAA/2010/6717 dated 11/02/2010 proposed project
environmental impacts of the project activity? activity is exempted from EIA.
b. Have the project participants undertaken an VVM 130 As per the letter from MOEF vide reference OK OK
analysis of environmental impacts? SEIAA/2010/6717 dated 11/02/2010 proposed project
activity is exempted from EIA.
c. Does the host Party require an environmental VVM 130 As per the letter from MOEF vide reference OK OK
impact assessment? SEIAA/2010/6717 dated 11/02/2010 proposed project
activity is exempted from EIA.
d. If yes, have the project participants undertaken VVM 130 Not applicable OK OK
an environmental impact assessment?

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Table 2 Specific validation activities


I. Draft Final
CHECKLIST QUESTION Ref. § COMMENTS
Concl Concl
1. Project design of small-scale clean
development mechanism project activities
a. Does the proposed small-scale CDM project VVM 133 Yes, the project activity meets the requirements of OK OK
activity meet the requirements of the simplified simplified modalities and procedures for small-
modalities and procedures for small-scale CDM scale CDM project activities, as it is a type 1
project activities? project activity with category C Thermal energy
generation for user. The capacity of the project
activity is well below 45 MW thermal limits for
small-scale projects. The project is not a
component of a large project activity and not a de-
bundled small-scale project activity.
b. Does the project activity qualify within the VVM 134 The proposed project activity is type 1 project, OK OK
thresholds of the three prossble types of small category C ‘thermal energy generation for user’.
scale project activities? [Type (i) project activities: The project activity is well below the threshold limit
renewable energy project activities with a of 45 MW thermal.
maximum output capacity equivalent to up to 15
megawatts; Type (ii) project activities: energy
efficiency improvement project activities which
reduce energy consumption, on the supply and/or
demand side, by up to the equivalent of 15
gigawatt hours per year; Type (iii) project
activities: other project activities that both reduce
anthropogenic emissions by sources and directly
emit less than 15 kilotonnesof carbon dixide
equivalent annually.]
c. Does the project activity conform to one of the VVM 134 Refer 1.b. in Table 2. - -
approved small-scale categories?

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d. Does the project activity apply the relevant tool VVM 134 Refer to (5.b.g) above in Table 1 - -
and methodology?
e. Are the small-scale methodologies applied in VVM 134
conjunction with the general guidance to the
methodologies, which provides guidance on
equipment capactiy, equipment performance,
sampling and other monitoring-related issues?
f. Is the project activity a debundled component of a VVM 134 No, project activity is not a de-bundled component OK OK
large-scale project, i.e., is there a registered of a large-scale project.
small-scael CDM project activity or an application
to register another CDM project actifity: (a) with
the same project participants; (b) in the same
project category and technology/measure; and (c)
registered within the previous 2 years; and (d)
whose project boundary is within 1 km of the
proposed boudary of the proposed small-scale
activity at the closest point?
g. Is and assessment of the environmental impacts VVM 134 Refer 10.a. in table 1. - -
of the proposed CDM project activity required by
the host Party?
h. Is the project additional? VVM 135 Refer 6.c above in Table 1 - -

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Table 3 Resolution of Corrective Action and Clarification Requests


Ref. To
Draft report clarifications and corrective action checklist Summary of project owner
Validation team conclusion
requests by validation team question in response
Table 1
CAR-1 Table 1 The description on the technological The project participant has revised
Please explain the last sentence of section well being is also revised on the the description in section A.2 of the
Economic well being “Hence project contributes to (3.d.iii)
guidelines provided by NCDMA. revised PDD. The description
the economic sustainability around the plant site, contained in the revised PDD on
which helps in decentralization of economic project participant’s view on project
power”. In section A.2, under environmental well The statement (“Hence project activity’s contribution to sustainable
being, please explain what precautions have been contributes to the economic development is based on the four
taken during plant designing so that it does not sustainability around the plant site, sustainable indicators identified by
affect the ecology. Provide the supporting which helps in decentralization of the host party (India) as
documents. economic power”) under Economic environmental well being,
The description on technological well being is not in well being was a repeat of the technological well being, social well
line with the guidelines provided by the NCDMA. contribution of the project activity to being and economic well being.
the Social well being. Thus, the Hence CAR-1 is closed.
extra statement was deleted from
the revised PDD and the section
had been modified as required in
the PDD.
CAR-2 Table 1 The section A.4.1.4 has now been The project participant has revised
The project participant has provided lat-long of the restricted to one page as per the the section A.4.1.4 of the PDD and
project location. However section A.4.1.4 has not (3.f.ii)
requirement of the CDM the information has been restricted
been restricted to one page (requirement of CDM completeness guidelines, version 5. to one page. Secondly, the
PDD completeness guidelines, version 5, 14th Sept. The same has been updated in the reference to the Lat-Long has been
2007). Further, the lat-long of the project activity is revised PDD. Also, the latitude and provided in the section A.4.1.4 of
not referenced to the source. longitude has now been updated in the revised PDD. Having cross
the revised PDD. The source for the checked with

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latitude and longitude has been http://www.wikimapia.org/#lat=31.05
provided as – &lon=76.1166667&z=13&l=0&m=b&
http://www.tageo.com/index-e-in-v- search=31%C2%B0%2003'%2000
23-d-m2927166.htm %22%20N%2C%2076%C2%B0%2
007'%2000%22%20E, The lat-long
It should be noted that PP had provided are found to be correct
erroneously put in the latitude and and hence, CAR-2 has been closed.
longitude of the head office rather
than the project site in the earlier
version of the PDD.
CAR-3 Table 1 The “type” and the “category” has The project participant has revised
Project participant has not provided the “type” and been provided in the revised PDD section A.4.2 of the PDD wherein
“category” as per the CDM PDD small-scale PDD (3.g.i)
as per the small scale PDD the type of the project activity has
guidelines (version 5) in section A.4.2 of the PDD. guidelines, version 5 and appendix been correctly mentioned as I
Also, it is not in accordance with Appendix B of B of the simplified modalities and “Renewable energy projects” which
simplified modalities and procedure of small-scale procedure of the small-scale project is in accordance with Appendix B of
project activity. The complete and explicit technical activity. the simplified modalities and
details of boiler and turbine, which are main project procedure of small-scale project
activity equipments, have not been provided in activity.
section A.4.2 of the PDD. The explicit technical details of
boiler and turbine are also provided
in section A.4.2 of the revised PDD. Category of the project activity has
been appropriately mentioned under
section A.4.2 of the revised PDD as
It should be noted that the – C “Thermal energy production
temperature of the steam required with or without electricity”
for the process is 190° C and the
same has been conservatively

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taken for the determination of the The technical specifications of
Emission Reductions. It should be turbine and boilers have been
further noted that the extraction cross-checked from the purchase
temperature of the steam from the order for the turbine and boiler. The
turbine as mentioned in the de-superheating of the steam will
technical specification is 259.5° C take place to reduce the
and the temperature of the steam is temperature and get the saturated
reduced to 190° C by de- steam as per the process
superheating for its usage in the requirements. The project
process. participant has included the
description in the revised PDD also.
Hence, CAR-3 has been closed.
CAR-4 Table 1 The crediting period is now Crediting period has now been
The crediting period for which the emission indicated in section A.4.3 of the indicated under section A.4.3 of the
reduction is estimated has not been indicated, (3.h)
revised PDD as per the small scale PDD and it has been mentioned
which is not in accordance with small-scale PDD PDD guidelines. that PP has chosen the fixed
guidelines (EB 34, Annex 09) in Section A.4.3 of crediting period. Hence CAR-4 is
the web hosted PDD. closed.
CAR-5 Table 1 The complete description is now The project participant has revised
The project participant has provided description on provided in Section A.4.5 of the the description under section A.4.5
the confirmation on debundling in Section A.4.5. (3.j.i)
revised PDD confirming that the of the PDD. It is now explicitly
However, from the description, it is not clear project activity is not a debundled stated that the PP does not have
whether project participant has any application to component of a large scale project another project registered and also
register a CDM project activity or in advanced activity. does not have an application to
stage of CDM validation. The description is register in the same project
incomplete to conclude that project activity is not a category within the previous two

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de-bundled component of a large project activity. years or within 1 km of the project
boundary of the proposed project
activity. The same has also been
verified from the latest CDM
Pipeline database published by the
UNEP Risoe centre. Hence, CAR-5
has been closed.
CAR-6 Table 1 The title and reference of the The project participant has provided
The title and reference of the approved baseline approved baseline and monitoring the title and references of the
and monitoring methodology have not been (3.k), (5.b.b) methodology is now provided in approved CDM methodology
provided correctly in Section B.1 of the web hosted section B.1 of the revised PDD. applied by the PP. The latest
PDD. version of the tools referred by the
methodology are also identified by
the project participant in section B.1
of the revised PDD.
Hence CAR-6 is closed.

CAR-7 Table 1 In section B.4 of the revised PDD, The project participant has specified
In section B.4, the project participant has provided the NCV and cost/price of Coal and the data sources of NCV and cost of
NCV and cost of pet coke and coal. However, the (3.n.iii)
Pet Coke has been taken from the the pet coke and coal. Thus, CAR-7
data sources have not been specified. following sources: has been closed.
• Price of Coal – 3.575 INR/kg
(Quotation from Coal
Supplier dated 21 December
2007)

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• NCV of Coal – 4131 Kcal/kg
(Lab Test Report dated 24
December 2007)
• Price of Pet Coke – 6.8
INR/kg (Quotation from Pet
Coke Supplier dated 13
December 2007)
• NCV of Pet Coke – 32.5
TJ/Gg (Default Net Calorific
Value of Pet Coke as given
by 2006 IPCC Guidelines for
National Greenhouse Gas
Inventories)
CAR-8 Table 1 The PDD is revised taking in The project participant has provided
In section B.5, PDD is silent upon national policies account the national policies and the description on national policies
and circumstances relevant to the baseline of the (3.o.ii)
circumstances prevalent at the time and circumstances in accordance
proposed project activity. Project participant to of investment decision for the with the Annexure 3 of the EB
clarify how national policies and circumstances project activity. meeting report 22 in the section B.5
have been taken into account on establishment of of the revised PDD. Hence, CAR-8
the baseline scenario as per EB 22, Annex 3. has been closed.
CAR-9 Table 1 The data and parameters are now The latest approved methodology
In section B.6.2 of the web hosted PDD, the project been clearly mentioned in the AMS-I.C. (version 19) in para 44
participant has not clearly addressed the data and (3.p.i, ii and
section B.6.2 of the revised PDD as specifies “The quantities and types
parameters that are not monitored but determined iii)
applicable in version 19 of AMS I C of biomass and the biomass to
upfront so as to be available for validation. (applied methodology). fossil fuel ratio (in the case of co-

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fired systems) to be used during the
crediting period should be explained
The following parameters required and documented transparently in
as per paragraph 44 of the applied the CDM-PDD. For the selection of
methodology has been added in the baseline scenario, an ex ante
section B.6.2 of the revised PDD: estimation of these quantities
should be provided”.
• Quantity and type of
biomass (Ex ante The project participant has provided
determination) the ex ante determination of
• Quantity of fossil fuel usage quantity of the biomass and fossil
(Ex ante determination) fuel usage in the revised PDD. It
has been specified that project
• Biomass to fossil fuel ratio activity will use rice husk as a main
(Ex ante determination) fuel and coal will only be used in
case of exigencies. Further, the
project participant has also provided
the procedure for the computation
of the project emissions from the
fossil fuel consumption in
accordance with the latest version
of the Tool to calculate
project/leakage emissions from the
fossil fuel consumption. Hence,
CAR 9 has been closed.
CAR-10 Table 1 The ex ante calculation of emission The project participant has provided

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In section B.6.3, the ex ante calculation of emission (3.q.i, ii, iii reductions, baseline emissions & the revised PDD wherein the project
reductions, baseline emissions, leakage emissions, and iv) leakage emissions is now presented participant has provided the detailed
etc. have not been presented in a manner that in a desired manner in the revised calculation approach for the
enables the reader to reproduce the calculations. PDD. As equation 3 of the parameters EGpjthermal and EGpjelectrical
Project participant has applied equation 3 of the methodology AMS I C, Version 19 in section B.6.3 of the revised PDD.
methodology AMS I C, Version 17. However, it is (paragraph 27) has been applied, it Hence, CAR-10 has been closed.
not explicitly provided how parameters EGpjthermal is now clearly presented how
and EGpjelectrical have been computed for the EGpjthermal and EGpjelectrical have been
purpose of computing baseline emissions. computed. The same can also be
crosschecked from the excel
spreadsheet named SEL Emission
Reduction.
CAR-11 Table 1 The ex ante determination of the Format included under section B.6.4
The ex ante determination of the emission emission reductions in section B.6.4 of the revised PDD is as per the
reductions in section B.6.4 have not been provided (3.r) has been updated as per the prescribed format of the small-scale
as per the prescribed format of the small-scale prescribed format in the revised PDD. PDD completeness guidelines
PDD completeness guidelines (version 5, 14th Sept. (version 5, 14th Sept. 2007). Hence,
2007). CAR-11 has been closed.
CAR-12 Table 1 The specific data source for The accuracy of the measurement
The specific data source for parameters presented parameters presented in section methods and specific data sources
in section B.7.1 has not been identified and the (3.s.ii.a and
B.7.1 of the PDD has been has been addressed under section
accuracy of the measurement method has not b), (3.s.iii.d)
identified and the accuracy of theB.7.1 of the revised PDD. The
been specified for the measured parameters in measurement method has been reference to Annex 4 has been
section B.7.1 of the PDD. The monitoring plan in mentioned in section B.7.1 of the removed from the project participant
section B.7.2 refers to the Annex 4 of the PDD. revised PDD. from section B.7.2 of the revised
However, there is no information in Annex 4 of the
PDD. The mention of Annex 4 in the PDD PDD. Hence, CAR-12 has been

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was due to a typographical error closed.
and the same has now been
removed from the revised PDD.
CAR-13 Table 1 The monitoring plan under the The project participant has revised
The monitoring plan described does not include revised PDD has now addressed all the PDD. The monitoring plan of the
various requirements to be met for monitoring of (3.s.iii.c)
the inadequacies identified in revised PDD presented in section
such project activity. These inadequacies are also section 7 of Table 1 of this protocol. B.7.1 and B.7.2 now identified the
detailed in Section 7 of Table 1 of this protocol. required monitoring parameters of
latest version of the AMS-I.C.
The monitoring of NCV of biomass Besides, the accuracy of the
and fossil fuel has been provided as measurement method, the
per the applied methodology. frequency of the calibration, role
and responsibilities, etc. have been
presented. The project participant
The grid electricity consumed by the has also incorporated the
project activity has also been monitoring of NCV of the biomass.
included as the monitoring The grid electricity consumed by the
parameter. project activity has not been
considered a monitoring parameter.
Hence, CAR- 13 has been closed..
CAR-14 Table 1 The documents related to the local Stakeholders making comments
Project participant has not identified the local stakeholders meeting are being have been identified by the project
stakeholders who made the comments in section (3.ff.i) and
provided to the validation team. participant along with summary of
E.2 of the PDD. Besides, the summary of the (3.ff.ii)
Moreover, the summary of the comments under section E.2 of the
comments has not been presented clearly. comments has been clearly PDD. Hence CAR-14 is closed.
presented in the revised version of

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the PDD.
CAR-15 Table 1 Correct phase wise commissioning The project participant has revised
The validation team observed during site visit that status of the project activity has now the project description under section
the manufacturing units viz; Spinning unit was in (4.a), (4.b.i),
been substantiated along with the A.2 of the PDD and the pre-project
operation since March 2008 and Terri Towel unit (4.b.ii),
commissioning certificates of the scenario/project scenario has been
was operationalised in November 2008 and March (4.b.iii)
manufacturing units for the Terri clearly specified with respect to the
2009 in two phases prior to the commissioning of Towel Units as well as the Spinning energy generating equipments
the 10MW biomass based power plant. The units and the delivery certificate available in the pre-project scenario.
electricity requirements of the plant are being met from technology suppliers. It can be
through grid power. It has been further observed seen from that spinning unit 1 was
that project participant has synchronized the power commissioned in April - May 2008 Further, the project participant has
plant with grid and in future, excess electricity (after whereas the spinning unit 2 was also specified the details of the
meeting the captive consumption) may be sold to commissioned in December 2009. commissioning of the various
the grid. The PP has also availed relevant statutory The Terri Towel Division 1 was manufacturing units which resulted
approval from PEDA (Punjab Energy Development commissioned in November – into higher energy requirement for
Authority) on 13/05/2010 for entering in to PPA with December 2008, whereas, the Terri manufacturing complex compared
state electricity utility. It was also observed by the Towel Division 2 was commissioned to the pre-project scenario. The
validation team that there were two sources in June 2010. The same has been project participant has also provided
including 5 TPH fossil fuel based boiler and 15 Lac detailed in section A.2 of the PDD. the commissioning certificates for
Kcal/Hr Thermopack to meet thermal energy added spinning and terri towel units.
requirement of manufacturing units prior to Hence, it is evident that due to
implementation of project activity. Also, the PP has availed the expansion programme of the
The project description is not transparently relevant statutory approval from manufacturing facility (new capacity
provided with respect to the above-mentioned PEDA for entering in to a PPA with of spinning units and terri towel
observations of the project implementation. the state electricity utility. However, units) of the project participant, the
based on the increased power thermal and electrical energy
demands, the PP has decided not requirements were increased

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to supply power to any external substantially and the same can not
agency. The undertaking for the be met by the pre-project scenario
same has been provided to DOE. equipments. The same has also
been explained by the project
participant in the revised PDD.
Moreover, description regarding the
5 TPH fossil fuel based boiler and
15 Lac Kcal/Hr Thermopack has It was further noted that the project
now being incorporated in section participant, has not signed the
A.2 of the revised PDD. power purchase agreement with the
state electricity utility and provided
an undertaking with respect to the
same. The project activity has been
commissioned in the financial year
2009-10 and the validation team
has also reviewed the annual report
of the company. The Annual report
does not talk about any revenue
from power sale to the grid and
hence, the undertaking provided by
the project participant has been
accepted by the validation team.
Based on the above-points, CAR 15
has been closed by the validation
team.
CAR-16 Table 1 The PP has availed the relevant It was noted that the project
PDD describes the applicability of option (b) as per statutory approval from PEDA for participant, has not signed the

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the applied methodology i.e. Electricity and/or (5.b.c.iii) entering in to a PPA with the state power purchase agreement with the
thermal energy (steam or heat) production for on- electricity utility. However, based on state electricity utility and provided
site consumption or for consumption by other the increased power demands, the an undertaking with respect to the
facilities. However, it was observed during site visit PP has decided not to supply power same. The project activity has been
that project participant aims to export the power to any external agency. The commissioned in the financial year
generated to PSEB grid after meeting the captive undertaking for the same has been 2009-10 and the validation team
requirement. Hence, the applicability of option (b) is provided to DOE. has also reviewed the annual report
not correct. of the company for year 2009-10
and 2010-11. The Annual reports do
Thus, it can be concluded that the not specify any revenue from power
applicability of option (b) as per the sale to the grid and hence, the
applied methodology, i.e. Electricity undertaking provided by the project
and/or thermal energy (steam or participant has been accepted by
heat) production for on-site the validation team. Hence, CAR-
consumption or for consumption by 16 has been closed.
other facilities is applicable for the
project activity.
CAR-17 Table 1 In the revised PDD, it is mentioned The project participant has provided
It is stated that the project activity is not a co-fired that the project activity is a multi fuel the revised PDD where the project
system. The validation team observed during site (5.b.c.v)
co-fired system. It is envisaged that activity has been specified as multi-
visit that the implemented project activity is a the project activity would utilize fuel fired system. The project
multiple fuel-fired system. Additionally, the project 100% biomass residue (rice husk) participant has also provided the ex
participant has installed coal feeding system for energy generation, whereas, at ante determination of the quantity of
including conveyors, coal crushers, coal storage, any time, if any fossil fuel is used, the biomass and fossil fuel as per
etc. for coal firing in project activity in case of the same would be accurately the relevant guidance provided in
exigency. Thus, it is evident that the project activity measured and the amount of project the latest approved methodology
is a co-fired system. emissions accruing as a result of AMS I.C. version 19. Further, the

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the fossil fuel usage would be project participant has determined
deducted from the baseline that project activity will use 100%
emissions while claiming the biomass. However, in case of
emission reductions for the project exigencies, the fossil fuels may be
activity. The fossil fuel consumed in used. The provision for the
such cases would be monitored and monitoring and calculation of project
the monitoring procedures for the emissions from the fossil fuel
same have been incorporated in consumption has also been
section B.7.1 of the revised PDD. incorporated by the PP in section
B.6.1 of the PDD. Hence, CAR-17
has been closed.
Additionally, as per the requirement
of the applied methodology, the
quantity of biomass, biomass types
used and the fossil fuel envisaged
for the project activity has been
provided ex ante in the PDD.

Also, provisions have been provided


in the PDD for the calculation of
project emissions arising out of the
fossil fuel usage (in case of any
exigencies) in the project activity
which will be determined ex post.
CAR-18 Table 1 Justification provided in section B.2 Section B.2 of the PDD has been
The project activity is a new green field project and of the revised PDD is in line with the revised now and it has been
does not add any renewable energy unit to existing (5.b.c.ix)

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renewable energy facility and hence, the rest of the applicability condition of the explicitly stated that the project
conditions including total capacity and physically methodology. activity does not involve addition of
distinct units are not applicable. However, any renewable energy units at an
justification provided in the section B.2 of the web existing renewable energy facility.
hosted PDD is not in line with the applicability Hence CAR-18 has been closed.
condition of the methodology.
CAR-19 Table 1 Although, the PP had availed the It was noted that the project
The web hosted PDD is silent on the fact that the relevant statutory approval from participant, has not signed the
project activity will displace grid electricity also and (5.b.g.ii)
PEDA for entering in to a PPA with power purchase agreement with the
hence does not include description on the tools that the state electricity utility. However, state electricity utility and provided
are to be used for the emission factor calculations based on the increased power an undertaking with respect to the
for electricity system as well as fossil fuel. demands, the PP has decided not same. The project activity has been
to supply power to any external commissioned in the financial year
agency. The undertaking for the 2009-10 and the validation team
same has been provided to DOE. has also reviewed the annual report
Methodological choice and of the company for year 2009-10
reference to the methodology has and 2010-11. The Annual reports do
now been provided under section not specify any revenue from power
B.6.1 of the revised PDD. Besides, sale to the grid and hence, the
the methodological choice for the undertaking provided by the project
calculation of CO2 emission participant has been accepted by
coefficient of fossil fuel for the the validation team.
purpose of calculating project
emissions has now also been
The project participant has also
provided in section B.6.1 of the
included the provisions for the
revised PDD.
computation of the project

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emissions from the fossil fuel
consumption and electricity
Also, tool to calculate the emission consumption in section B.6.1 of the
factor for an electricity system revised PDD. The fossil fuel
(Version – 2.2.0) has been used for consumption and electricity
the calculation of Grid emission consumption in the project activity
factor for the project activity and the (grid electricity import for the project
same has now been detailed in the activity) have also been considered
revised PDD. as monitoring parameters in the
revised PDD by the project
participant in section B.7.1 .Hence,
CAR-19 has been closed.
CAR-20 Table 1 The project boundary has now been The project participant has revised
The project boundary is not described correctly in corrected in the revised PDD. The the project boundary in section B.3
the web hosted PDD, as it does not include (5.c.a)
emissions generated and emissions of the revised PDD. The project
processes / equipments consuming thermal and (5.c.a.ii), sequestered blocks from the project boundary in the revised PDD is now
electrical energy. It is shown that the emissions boundary of the project activity have in accordance with the latest
from project activity will be sequestered. Please (5.c.b)
been removed in order to avoid the approved methodology AMS-I.C,
clarify. It also does not include fossil fuel storage, complexity. The processes version 19. Hence, CAR-20 is
consumption and monitoring in case of co-firing consuming thermal and electrical closed.
requirement. energy has been depicted in the
project boundary.

It should be noted that as per the


applied methodology AMS I C
(Version – 19), paragraph 15, the

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project boundary has been revised
in the PDD. Also, the fossil fuel
storage, consumption and
monitoring in case of co-firing has
been depicted in the project
boundary in the revised PDD.
CAR-21 Table 1 In the pre project scenario, only a The project participant has provided
The baseline boundary is not in accordance with part of the Spinning and Territowel the revised PDD where the project
actual implemented baseline i.e. it is does not (5.c.c)
units had been commissioned boundary for the baseline has been
include baseline project equipments for thermal before the implementation of the identified as a coal based
energy and grid for electricity and mentions co- project activity. A 5 TPH fossil fuel cogeneration project activity. The
generation, which is not the case. based boiler and 15 lac kCal/hour baseline has been identified by the
thermopack were present at the site project participant considering the
to meet the thermal energy plausible alternatives as explained
requirement of the partially in section B.4 of the PDD.
commissioned manufacturing units
prior to implementation of the
project activity. Further, the However, in pre-project scenario,
electrical requirement for the same the project participant was using
was being met through the grid electricity from the grid and
electricity. Now, to meet the generating thermal energy from
increased energy requirements of thermic fluid heater and a boiler.
fully commissioned spinning and Since, additional spinning and terri
territowel units, the project towel units were added to the
proponent in the baseline scenario manufacturing facility of project
would have gone for a coal based participant, the thermal and
cogeneration plant. Thus, it can be electrical energy requirements of

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concluded that the baseline the project scenario have been
boundary is in accordance with the increased and the output of the pre-
baseline which would ‘provide project scenario equipments (boiler
output or services comparable with and thermic fluid heater) are not
the proposed CDM project activity’, comparable with the greenfield co-
which is the operation of a coal generation plant (the project
based cogeneration system. scenario). The details of the phase-
Details (with supporting evidences) wise commissioning of the spinning
of phase wise commissioning of units and terri towel units has also
spinning and territowel units have been provided by the project
now been provided to the DOE. participant in section A.2 of the
Moreover, the supporting evidence revised PDD and also provided the
of commissioning dates of the 5 commissioning certificates from the
TPH fossil fuel based boiler and 15 technology supplier. The project
Lac kcal/hr thermopac operating in participant has also justified the
the pre-project scenario is also baseline through the levelized cost
provided to the DOE. analysis presented in section B.5 of
the PDD. Hence, the verification
team confirms that baseline project
These equipments were used in the boundary depicted in section B.3 of
temporary basis and were the PDD is applicable to the project
transferred to the project site as activity and closed CAR-21.
physically verified by the DOE
during the validation site visit.
CAR-22 Table 1 Although, the PP had availed the The project participant has provided
The validation team observed during site visit that relevant statutory approval from the revised PDD where in section
the manufacturing units viz; Spinning unit was in (5.d.b.iv)
PEDA for entering in to a PPA with A.2, phase-wise commissioning of

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operation since March 2008 and Terri Towel unit (5.d.f) the state electricity utility. However, the terri towel and the spinning units
was operationalised in November 2008 and March based on the increased power of the manufacturing plant prior to
2009 in two phases prior to the commissioning of (5.d.g) demands, the PP has decided not the commissioning of the project
the 10MW biomass based power plant. The (5.d.h) to supply power to any external activity (10 MW biomass based co-
electricity requirements of the plant are being met agency. The undertaking for the generation plant). The project
through grid power. It was also observed by the same has been provided to DOE. participant has also provided the
validation team that there were two sources supporting evidences for the
including 5 TPH fossil fuel based boiler and 15 Lac commissioning dates of the
Kcal/Hr Thermopack to meet thermal energy Correct phase wise commissioning spinning units (certificate from the
requirement of manufacturing units prior to status of the project activity has now manufacturers) and terri towel units
implementation of project activity. These scenarios been substantiated along with the (records of MoM with the
are not transparently described and further commissioning certificates of the representatives of the technology
considered in the Section B.4 and B.5 of web manufacturing units for the Terri supplier). Further, the project
hosted PDD. Towel Units as well as the Spinning participant has also included the
units and the delivery certificate pre-project scenario under section
from technology suppliers. It can be B.4 of the revised PDD as one of
seen from that spinning unit 1 was the plausible scenario. The
commissioned in April - May 2008 justification for the levelized cost
whereas the spinning unit 2 was analysis in section B.5 of the PDD
commissioned in December 2009. has also been provided by the
The Terri Towel Division 1 was project participant. It was earlier
commissioned in November – understood from the approval letter
December 2008, whereas, the Terri from the Punjab Energy
Towel Division 2 was commissioned Development Agency (PEDA) that
in June 2010. The same has been project participant may sell the
detailed in section A.2 of the PDD. excess electricity to the grid.
However, as per the undertaking
provided by the project participant,

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The pre project scenario with an the PP has not entered into any
addition of a fossil fuel fired boiler power purchase agreement with the
has now been described as one of state electricity utility. The validation
the alternatives to the project team has further reviewed the
activity in section B.4 of the revised annual reports of the company after
PDD. The same alternative has also the commissioning of the power
been eliminated from further plant (2009-10 and 2010-11) and
consideration as the single confirmed that project participant
cogeneration system providing both has not soled electricity to the grid.
thermal and electrical output is Hence, based on the revisions
inherently more efficient than an made in the PDD which
individual generation systems transparently describe the project
(http://www.retscreen.net/fichier.php activity, the validation team closed
/1000/chapter-cogeneration.pdf). CAR 22.
CAR-23 Table 1 The levelized cost spreadsheet has Section B.4 of the PDD has been
The proposed project activity is a greenfield been revised for the entire technical revised now. Levelised cost of
cogeneration project. The project participant has (5.d.b.v)
lifetime of the project activity (20 energy production has now been
also taken various alternatives into account and years – as per the certificate used instead of project cost as the
listed in section B.4 of the PDD. As per section B.4 provided by the technology basis for selecting the most
of the PDD, the project participant has selected supplier). In addition, the project plausible investment option.
coal based cogeneration unit as a baseline by participant has computed the Similarly in the revised levelized
considering it most plausible investment option. levelized cost of energy cost spreadsheet submitted by the
However, the justification presented is based on production/unit of output (INR project participant, the technical
initial investment cost of the project. The levelised Million/TJ) for the project activity in lifetime of the project has been
cost of energy production for the entire technical the revised spreadsheet submitted considered for the analysis and the
lifetime of the project activity for the alternatives to the DOE. levelized cost of the energy
has not been considered. Besides, the project production has been reported has

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participant has not computed the levelised cost of Million INR/TJ. Hence, CAR-23 is
energy production/unit of output. Instead the total closed.
project cost has been computed which is not in line The same has also been revised in
with the procedures of investment comparison section B.5 of the PDD.
analysis.
CAR-24 Table 1 As the version 17 of applied The project participant has also
The section B.4 of the web hosted PDD does not methodology (AMS I C) has already included the pre-project scenario
transparently describe the scenario existing prior to (5.d.b.vi)
expired, the PP has applied version condition as one of the alternatives
the project activity implementation and hence the 19 of the same methodology and under identification of the baseline
baseline emissions are not in accordance with has transparently described the in section B.4 of the PDD. However,
Paragraph 19 of the applied methodology AMS I C, scenario existing prior to the project since the energy out in the pre-
Version 17. activity. project scenario is different
compared to the project scenario
(higher energy requirement in the
Also, correct phase wise project scenario due to capacity
commissioning status of the project expansion), it may not be necessary
activity has now been substantiated to establish the baseline on
along with the commissioning historical data.
certificates of the manufacturing
The project participant has specified
units for the Terri Towel Units as
that a fossil fuel based boiler and a
well as the Spinning units and the
thermic fluid heater was in operation
delivery certificate from technology
prior to the project activity to meet
suppliers. It can be seen from that
the thermal energy requirements of
spinning unit 1 was commissioned
the plant. The investment decision
in April - May 2008 whereas the
was taken on 01/02/2008 (as per
spinning unit 2 was commissioned
the board resolution cross-checked
in December 2009. The Terri Towel

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Division 1 was commissioned in during site visit).
November – December 2008, However, the annual report for the
whereas, the Terri Towel Division 2 year 2008-09, in page 7, also
was commissioned in June 2010. specify the use of rice husk and pet
The same has been detailed in fossil fuel in the boiler for the year
section A.2 of the PDD. 2007-08 and 2008-09. It was
understood from the discussion with
the project participant that rice husk
The pre project scenario with an
was specified in the consolidated
addition of a fossil fuel fired boiler
annual report of the company was
has now been described as one of
consumed at LP Boiler of the Kudu
the alternatives to the project
Industries (having partnership deal
activity in section B.4 of the revised
with SEL Manufacturing company).
PDD. The same alternative has also
been eliminated from further The project participant has also
consideration as the single provided the partnership agreement
cogeneration system providing both and rice husk consumption invoices
thermal and electrical output is of Kudu Industries. Thus, CAR-24
inherently more efficient than an has been closed. Hence, CAR-24
individual generation systems has been closed.
(http://www.retscreen.net/fichier.php
/1000/chapter-cogeneration.pdf).
The PP is also providing the sample
invoices of the rice husk purchased
at Kudu Industries before the
investment decision date.

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CAR-25 Table 1 As version 17 of the applied The project participant has provided
The baseline emissions are not in accordance with methodology (AMS – I C) has the details of the energy outputs of
Paragraph 19 of the applied methodology AMS I C, (5.d.b.vii, viii
expired, PP has applied the current the boiler and the thermopack used
Version 17. and ix)
applicable version 19 of the in the pre-project scenario. It is
methodology. Thereby, paragraph therefore, evident that the energy
19 of AMS I C (Version 17) is now required in the pre-project scenario,
paragraph 23 of AMS I C (Version is not comparable to the energy
19). Thus, PP would like to clarify required in the project scenario due
that paragraph 23 of methodology to capacity expansion of the
AMS I.C (Version 19) is not manufacturing facility of the project
applicable as the equipment being participant. Secondly, there was no
used before the implementation of co-generation power plant at the
the project activity could not manufacturing facility of the project
‘provide output or services participant. The project participant
comparable with the proposed CDM has carried out the levelized cost
project activity’. It can be seen that analysis and demonstrated that coal
the combined thermal output of the based cogeneration is the most
boiler (5 TPH) and thermopac (15 plausible baseline. Hence, the
lack K Cal/hr) was only 138.37 validation team has accepted the
TJ/annum whereas, the thermal calculation of the baseline
output required post expansion was emissions carried out by the project
349.23 TJ/annum. participant based on the Para 27 of
the methodology AMS-I.C. version
19 and closed CAR 25.
Thus, historical data is not
applicable to the project activity as
the energy requirement in the pre

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project scenario and the project
scenario is not comparable.

Thus, the PP would like to submit


that the project activity is a
Greenfield cogeneration project
activity and the baseline emissions
are not calculated in accordance
with paragraph 23 of the applied
methodology AMS I C, Version 19,
whereas, owing to the project being
a Greenfield cogeneration plant, the
baseline emissions are calculated
as per paragraph 27 of AMS I C
(Version 19).
CAR-26 Table 1 PP would like to clarify that the The project participant has provided
The project participant has not demonstrated the equipment being used before the the details of the phase wise
remaining lifetime of the replaced fossil fuel fired (5.d.b.xxv)
implementation of the project commissioning of the manufacturing
baseline thermal energy generating units viz; 5 activity could not ‘provide output or facility of the project participant
TPH boiler and 15 Lac Kcal/Hr Thermopack. services comparable with the which has resulted into significant
proposed CDM project activity’. It increase in electrical and thermal
can be seen that the combined energy requirements of the
thermal output of the boiler (5 TPH) manufacturing facility (terri towel
and thermopac (15 lack K Cal/hr) and the spinning units) of the
was only 138.37 TJ/annum project participant. Considering the
whereas, the thermal output fact that project activity is part of an

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required post expansion was 349.23 expansion programme of the project
TJ/annum. participant, the pre-project scenario
is not applicable as it will not be
able to provide the comparable
Thus, the PP would like to submit output of the project activity
that the project activity is a scenario. Besides, there was no
Greenfield cogeneration project simultaneous generation of heat
activity and since the continued use and power in the pre-project
of these above mentioned scenario. Hence, the proposed
equipments is not a viable project activity is a greenfield
alternative to the project activity as project and agreed to the response
explained in section B.4 of the provided by the project participant
revised PDD, the remaining lifetime that fossil fuel based thermopac and
of these equipment is not relevant the boiler are not a viable option
to the baseline determination. (continuation of the current practice)
due to increased thermal and
electrical energy requirements and,
the remaining lifetime of those
equipments is also not applicable.
Hence, CAR-26 has been closed.
CAR-27 Table 1 The emission factor of the grid is The project participant has provided
The emission factor of the grid is not calculated as now calculated in section B.6.1 of the combined margin emission
per the procedures detailed in AMS-I.D in (5.d.d.ii to
the revised PDD in accordance with factor of the grid as per the Tool to
accordance with Tool to Calculate the Emission iv)
the Tool to calculate the emission calculate emission factor for an
factor for an Electricity System. factor for an electricity system electricity system and also provided
(Version 2.2.0). the methodological choice for the
same in section B.6.1 of the revised

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PDD. Hence, CAR 27 has been
closed.
CAR-28 Table 1 In section B.5 of the web hosted The project participant has provided
The sources are provided in the spreadsheets used PDD, the levelized cost of the supporting evidences for the
for the identification of baseline scenario. However, (5.d.i) and
alternatives was sourced from the input assumptions considered in the
copies of the evidences are not submitted to the (5.d.j)
levelized cost analysis spreadsheet. levelized cost analysis spreadsheet.
validation team.
In addition the reference to the input
values has also been provided in
The copy of evidences has been
the levelized cost spreadsheet.
provided for the input values
Thus, CAR-28 has been closed.
considered in the levelized cost
analysis spreadsheet. Also, the
sources of the input values have
been explicitly explained in the
levelized cost spreadsheet
submitted to the DOE.
CAR-29 Table 1 PP would like to clarify that the The project participant has
The calculations of baseline emissions are not equipment being used before the submitted the technical
completely in accordance with the selected (5.e.a) and
implementation of the project specifications of the thermopac and
baseline and monitoring methodology because the (5.e.b)
activity could not ‘provide output or the boiler operating in the pre-
baseline identification does not include the services comparable with the project scenario which confirms that
scenario existing prior to the proposed CDM project proposed CDM project activity’. It the thermal output in the pre-project
activity for thermal and electrical energy generation can be seen that the combined scenario is not comparable to the
and its use in the manufacturing facility of the thermal output of the boiler (5 TPH) project activity (10 MW
project participant. and thermopac (15 lac K Cal/hr) cogeneration plant). The phase-
was only 138.37 TJ/annum wise commissioning details of the
whereas; the thermal output manufacturing facility has also been

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required post expansion was 349.23 provided by the project participant in
TJ/annum. the revised PDD. Hence, it is
evident that the project activity is a
part of a capacity expansion project
Thus, the pre project scenario with (also validated from the annual
an addition of a fossil fuel fired report of the company) and the
boiler has now been described as energy requirements of the pre-
one of the alternatives to the project project and the project scenario are
activity in section B.4 of the revised altogether different. Hence,
PDD. The same alternative has also continuation of the pre-project
been eliminated from further scenario can not be considered as a
consideration as the single baseline scenario. The para 27 of
cogeneration system providing both the methodology AMS-I.C. version
thermal and electrical output is 19 for the calculation of the baseline
inherently more efficient than an emissions has been accepted by
individual generation systems the validation team and closed CAR
(http://www.retscreen.net/fichier.php 29.
/1000/chapter-cogeneration.pdf).
.

Thus, the PP would like to submit


that the project activity is a
Greenfield cogeneration project
activity, since the continued use of
these above mentioned equipments
is not a viable alternative to the
project activity as explained in
section B.4 of the revised PDD,

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Emission reductions have thus been
calculated in accordance with
paragraph 27 of AMS I C (Version
19).
CAR-30 Table 1 PP would like to clarify that the The phase wise commissioning
Though the steam/heat, in the scenario existing equipment being used before the details of the manufacturing facility
prior to the proposed CDM project activity, (5.e.b.i)
implementation of the project have also been submitted by the
produced using fossil fuel the baseline emissions activity could not ‘provide output or project participant. Hence, it is
are not calculated as BEthermal,CO2,y = services comparable with the evident that the project activity is a
(EGthermal,y/ηBL,thermal) * EFFF,CO2? proposed CDM project activity’. It part of a capacity expansion project
can be seen that the combined (also validated from the annual
thermal output of the boiler (5 TPH) report of the company) and the
and thermopac (15 lac K Cal/hr) energy requirements of the pre-
was only 138.37 TJ/annum project and the project scenario are
whereas; the thermal output altogether different. Hence,
required post expansion was 349.23 continuation of the pre-project
TJ/annum. scenario can not be considered as a
baseline scenario. The project
participant has demonstrated the
Thus, the pre project scenario with baseline scenario as coal based
an addition of a fossil fuel fired cogeneration project and carried out
boiler has now been described as levelized cost analysis. The
one of the alternatives to the project validation team accepted the
activity in section B.4 of the revised response of the project participant
PDD. The same alternative has also and confirms that para 27 of AMS-
been eliminated from further I.C. is applicable to the project
consideration as the single activity for the calculation of

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cogeneration system providing both baseline emissions. Hence, CAR
thermal and electrical output is 30 has been closed.
inherently more efficient than an
individual generation systems
(http://www.retscreen.net/fichier.php
/1000/chapter-cogeneration.pdf).

Thus, the PP would like to submit


that the project activity is a
Greenfield cogeneration project
activity, since the continued use of
these above mentioned equipments
is not a viable alternative to the
project activity as explained in
section B.4 of the revised PDD,
Emission reductions have thus been
calculated in accordance with
paragraph 27 of AMS I C (Version
19).
CAR-31 Table 1 The data and parameters are now The project participant has provide
As the project activity has arrangements for co- been clearly mentioned in the the revised PDD where in section
firing also, the web hosted PDD does not include (5.e.g)
section B.6.2 of the revised PDD as 6.1, the project participant has
the parameters on fossil fuel and other, as may applicable in version 19 of AMS I C included the computation approach
required as per scenario existing prior to the project (applied methodology). for the project emissions from the
activity are not provided. fossil fuel consumption and also
included the fossil fuel consumption

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The following parameters required as a monitoring parameter in
as per paragraph 44 of the applied section B.7.1 of the PDD which is in
methodology has been added in accordance with the methodology
section B.6.2 of the revised PDD: AMS-I.C. version 19.

• Quantity and type of In accordance with the para 44 of


biomass (Ex ante the applied methodology AMS-I.C.
determination) version 19, the project participant
has also specified ex-ante that
• Quantity of fossil fuel usage 100% biomass will be consumed in
(Ex ante determination) the project activity. Hence, CAR 31
• Biomass to fossil fuel ratio has been closed by the validation
(Ex ante determination) team.

In the revised PDD, it is mentioned


that the project activity is a multi fuel
co-fired system. It is envisaged that
the project activity would utilize
100% biomass residue for energy
generation, whereas, at any time, if
any fossil fuel is used, the same
would be accurately measured and
the amount of project emissions
(the procedures for the calculation
of the project emissions from the

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fossil fuel usage has been provided
in section B.6.2 of the PDD)
accruing as a result of the fossil fuel
usage would be deducted from the
baseline emissions while claiming
the emission reductions for the
project activity. The monitoring
procedures for the firing of fossil
fuels have been incorporated in
section B.7.1.
CAR-32 Table 1 The project participant has now The project participant has provided
The project participant has not included the included the explanation on the the revised PDD and in section B.5,
explanation on the determination of appropriate (6.l.i)
determination of appropriate the justification for the use of
analysis method, which may cover all three options analysis method covering all three investment analysis method and
viz; Simple cost analysis, investment comparison options viz; Simple cost analysis, selection of the levelized cost
analysis and benchmark analysis in section B.5 of investment comparison analysis analysis has been provided by the
the web hosted PDD. and benchmark analysis in section project participant in section B.5 of
B.5 of the revised PDD. The reason the PDD. The project participant
for the selection of Investment has also referred to the latest
Comparison Analysis for the project available version of the Guidance
activity has been explicitly explained on the investment analysis. Hence,
in section B.5 of the revised PDD. CAR 32 has been closed.

CAR-33 Table 1 The project proponent has now Section B.4 and B.5 of the PDD has
The project participant has carried out levelised carried out the Levelized Cost been revised by the project
cost analysis. The PP has compared the cost of (6.l.v),
Analysis of the energy production, participant. Levelised cost of energy

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operation of various alternatives as identified, (6.q.i), which is in accordance Para (3) of production (in INR Million/TJ) has
which is not correct and in accordance with Para Sub-step 2 (b) of the “Tool for the now been submitted by the project
(6.b.c.ii)
(3) of Sub-step 2 (b) of the “Tool for the demonstration and assessment of participant instead of project cost as
demonstration and assessment of additionality”. It additionality”. Cost of output energy the basis for selecting the most
is required to calculate cost of output energy i.e. is now calculated as INR/TJ. plausible investment option. Also,
cost/KWh or cost/GJ. under section B.5 of the PDD,
comparison of credible baseline
scenario alternatives is done on the
basis of Levelised cost of energy
production (in INR Million/TJ).
Hence, CAR-33 has been closed.
CAR-34 Table 1 The project participant has now The project participant has revised
The project participant has not applied benchmark included the explanation on the the PDD and in section B.5, the
analysis (Option III). As per validation team’s (6.o), (6.p),
determination of appropriate project participant has justified the
opinion, investment comparison analysis is not (6.c.b.i),
analysis method covering all three reason for the selection of the
appropriate as per the Para 16 of “Guidelines on (6.c.b.ii),
options viz; Simple cost analysis, levelized cost analysis. It has also
the assessment of the investment analysis” (Annex (6.c.c.ii)
investment comparison analysis been verified by the validation team
58, EB-51). In scenario existing prior to the project and benchmark analysis in section that pre-project scenario
activity, the PP has been supplied electricity from B.5 of the revised PDD. equipments were not sufficient to
PSEB grid. Further, as per discussion with the provide the same level of the output
project participant, there will be export of power as considered in the project
also to grid to the tune of approximately 2.0 MW. The reason for the selection of scenario. It was further validated by
For the thermal energy, in baseline there were Investment Comparison Analysis the validation team that increased
boiler and a thermopack. Thus, the project over Benchmark analysis is based energy demand has been arrived by
participant does not have compulsory investment. on the fact that, the equipments the expansion of the manufacturing
Thus, investment comparison analysis is not available in the pre project scenario facility of the project participant
appropriate. (5 TPH fossil fuel based boiler and where new spinning and terri towel

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15 Kcal/ hour thermopack) could units have been added before the
only have provided 138.37 TJ/year commissioning of the project
of thermal energy to the plant, activity.
whereas, the thermal energy
supplied by the project activity is to
the tune 349.23 TJ/year to meet the It was further observed by the
expanded manufacturing capacity of validation team that though the
the project participant. Thus, the project participant has got an
project participant had no choice but approval for the sale of the power to
to make an investment to supply the the grid, the same has not been
increased level of energy. Hence, in carried out. The project participant
accordance with Paragraph 19 of has provided an undertaking on the
the “Guidelines on the Assessment same. The project activity has been
of Investment Analysis” Version 05 commissioned and the validation
which states that “If the proposed team has reviewed the annual
baseline scenario leaves the project report of the company for year
participant no other choice than to 2010-11 and confirms that project
make an investment to supply the participant has not sold the
same (or substitute) products or electricity to the state grid. Hence,
services, a benchmark analysis is there is no additional source of
not appropriate and an investment revenue to the project participant
comparison analysis shall be used”. from the sale of electricity to the
Thereby, investment comparison grid.
analysis was used by the project
activity over Benchmark analysis.
The co-generation plant was
commissioned in year 2010.
Also, the PP has availed the Further, the validation team has

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relevant statutory approval from also checked that in the annual
PEDA for entering in to a PPA with report, the unit cost of generation of
the state electricity utility. However, electricity has been specified from
based on the increased power the captive power plant. The unit
demands, the PP has decided not cost of electricity purchase has also
to supply power to any external been specified in the annual report
party. The undertaking for the same of 2010-11 and it was observed that
has been provided to DOE. unit cost of electricity generation
from the captive co-generation plant
is higher than the cost of electricity
purchased. Hence, the validation
team accepted the response
provided by the project participant
and closed CAR 34.
CAR-35 Table 1 All the copies of the source The project participant has
Copies of the source documents of the documents of the assumptions are submitted the lab test report for the
assumptions have not been provided to the (6.q.iii)
thus being provided to the validation CV of the rice husk and the coal
validation team including feasibility study report, team. available to the PP at the time of the
cost of rice husk and coal, calorific value of rice investment decision. The Lab test
husk and coal, cost of power from grid, project reports of the CV of the rice husk
costs, etc. Also, complete details of the sources of The following input values have and the coal have been taken by
input values in assumptions are not mentioned e.g. been taken for the levelized cost the PP in the revised investment
reference no., date of document, etc. analysis for the project activity and analysis (LCA spreadsheet). Since
there evidences are mentioned in NCV of the coal and rice husk
the parenthesis: considered by the project participant
are based on third party lab analysis
report, the same has been accepted

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• Price of Rice Husk – 2800 by the validation team.
INR/tonne (Quotation from
Rice Husk Supplier dated 15
The price of the rice husk has been
December 2007)
considered by the project participant
• Price of Coal – 3575 based on the quotations submitted
INR/tonne (Quotation from by the rice husk suppliers dated 15th
Coal Supplier dated 21 Dec. 2007. Further, the validation
December 2007) team has also referred to the
Biomass Assessment report which
• Annual escalation on Rice
has been duly approved by the
Husk – 5% (Reference of
PEDA (Punjab Energy Development
the registered CDM projects
Agency) and prepared by ACE
like PID: 3232 & 4488 and
Engineering and consultants. It was
various tariff orders
observed that the landed cost of the
suggesting 5% price
biomass as specified in the report is
escalation
from Rs. 2600 (transportation
• Annual escalation on Coal – distance upto 15km), Rs. 2800
5% (Whole sale price index (from transportation distance of 15
for coal from Jan 2007 to to 25 km) and Rs. 2950 per ton (for
Dec 2007) transportation distance 25 to 50
km). The landed cost considered by
• NCV of Rice Husk – 2767
the project participant based on the
Kcal/kg (Lab Test Report
quotation received on 15th Dec.
dated 21 December 2007)
2007 also corroborates with the
• NCV of Coal – 4131 Kcal/kg same. Further, the project
(Lab Test Report dated 24 participant has also carried out
sensitivity analysis on the rice husk

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December 2007) price for +/-10% which also covers
the range of rice husk price from
• Cost of Power from Grid –
Rs. 2600/ton to Rs. 2950/ton
INR 4.66 per kWh
specified in the biomass
(Electricity Bills for
assessment report. Hence, based
December 2007 issued on
on the above, the validation team
12 January 2008)
accepted the price of the rice husk
• Project Cost for considered
(a) by the project
Cogeneration participant.
project
activity, & (b) L P Boiler &
Grid (Taken from Feasibility
Study Report prepared by Price of the coal has been
Ace Engg & Consultants in considered by the project participant
January 2008) as Rs, 3575/ton which is based on
the highest price value of the two
• Depreciation rates – (As per quotations from the coal suppliers
Direct tax reckoner) (dated 21/12/2007).
• Discount rate – 13% [RBI
PLR –
(http://rbidocs.rbi.org.in/rdoc The project participant has also
s/Wss/PDFs/82830.pdf)] provided the supporting evidence
for the HT tariff considered in the
• Man Power Cost & levelized cost analysis. The same is
Operation and Maintenance based on the electricity bill of the
Cost - (Taken from from the Punjab State Electricity
Feasibility Study Report Board energy bill for the month of
prepared by Ace Engg & Dec. 2007. Since the Board
Consultants in January decision took place in Feb. 2008,

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2008) the same is applicable with respect
to the investment decision timing.
• Increment in man power &
Hence, the validation team
OM Cost - (Taken from
accepted the HT Tariff considered
Feasibility Study Report
in the LCA spreadsheet.
prepared by Ace Engg &
Consultants in January The sources of depreciation and
2008) discount rate have been provided.
The project participant has taken
• Increment in Man power & prime lending rate as discount rate
OM Cost – 5.70% [As per and depreciation rate has been
the Consumer price Index considered as per the Indian
for Industrial workers (CPI - accounting rules. Hence, the same
IW) determined by RBI in its has been accepted by the validation
annual report for 2006 - team.
2007 (Page - 78)]
Increment in the man power and
O&M cost has been considered by
PP would like to explain that it has the project participant as 5.70%
conservatively applied the which is based on the Consumer
escalation of 5.35% on the coal cost Price Index for the Industrial
based on the one year data (Jan workers. The report is a publicly
2007 to Dec 2007). The same can available published RBI annual
be attributed to the fact that the report of year 2006-07 (published
escalation for the year 2006 stood on Aug. 30, 2007) and specifically
at 0.17%, whereas the same for provide CPI rate for industrial
year 2005 stood at 0% as evident workers. Hence, the same has been
from the Wholesale price index for accepted by the validation team.
Coal. The scanned copy of the

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wholesale price index for coal from The validation team confirms that
year 2005 to year 2007 is being year on year escalation on coal
provided to the DOE. considered by the project participant
is conservative and based on the
publicly available data published by
Government of India which is
based on the WPI inflation of coal.
Hence, the same has been
accepted.
The project participant has
considered the project cost from the
feasibility report. The project cost
considered in the LCA Spreadsheet
is 405 million INR. In order to cross-
check the project cost, the
validation team has also referred to
the quotations from the equipment
suppliers (boiler and TG set which
forms about 73% of the project cost
considered by the project participant
in the levelized cost analysis).
Further, the validation team has
also referred to other publicly
available sources to confirm the
appropriateness of the project cost
considered by the project
participant. In year 2008, no

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detailed tariff order is available
which provides capital cost of the
biomass based co-generation
project. However, the validation
team has referred to the CERC
(central electricity regulatory
commission; a govt. entity) tariff
order of year 2009 in Annexure 4 E
(published on 03-12-2009) specify
the project cost for biomass based
co-generation power project in
Punjab State as 44.5 million
INR/MW which results into 445.0
million INR for 10 MW project
capacity. In the view of above, the
validation team confirms that the
project cost considered by the
project participant as 405 million
INR is appropriate and
conservative.

The cost of the low pressure boiler


(which has been considered in the
alternative scenario of grid + low
pressure boiler) has been sourced
by the project participant from the
feasibility report as 162 million INR.

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The validation team has also
reviewed the boiler quotations made
available by the project participant
and found that the 162 million INR
cost considered is the conservative
as the cost specified in the LP boiler
quotation comes out to be 186.7
million INR. Based on the above,
facts, the validation team accepted
the co-generation project cost and
LP boiler cost taken by the project
participant in the levelized cost
analysis spreadsheet. CAR 35 has
been closed.
CAR-36 Table 1 As version 17 of the applied Since the requirement of the
The approved methodology AMS I C, Version 17 methodology (AMS – I C) has thermal and electrical energy is
prescribes various options in its Para 15 (a) to 15 (6.b.a),
expired, PP has applied the current varying in the pre-project and
(h) for baseline identification. Further, the project (6.b.b) applicable version 19 of the project scenario due to capacity
activity involves capacity addition in both thermal methodology. Thereby, paragraph expansion, validation team agree
energy and electrical energy as compared to pre 15 of AMS I C (Version 17) is now with the response provided by the
project scenario and hence having historical data paragraph 19 of AMS I C (Version project participant that historical
available. The project activity cannot be considered 19). Thus, PP would like to clarify data will not be applicable for the
completely greenfield project activity. Thus, the that it has selected the baseline determination of the baseline.
baseline identification is not in accordance with the scenario as per paragraph 19 (d), Further, the project participant has
applied methodology. i.e, “Electricity and thermal energy demonstrated through the levelized
(steam/heat) are produced in a cost analysis that coal based co-
cogeneration unit using fossil fuel generation is the most economical

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(with a possibility of export of alternative and considered the
electricity to a the grid/other same as a baseline. Based on the
facilities and/or thermal energy to fact that pre-project scenario energy
other facilities)” as the equipment requirements of the project
being used before the participant’s manufacturing facility
implementation of the project are lower than the project scenario
activity could not ‘provide output or and coal based co-generation is the
services comparable with the most economic alternative to the
proposed CDM project activity’. It project participant, the validation
can be seen that the combined team accepted the response of the
thermal output of the boiler (5 TPH) project participant and confirms that
and thermopac (15 lack K Cal/hr) baseline emissions have been
was only 138.37 TJ/annum calculated in accordance with para
whereas, the thermal output 27 of the methodology AMS IC
required post expansion was 349.23 version 19. Hence, CAR 36 has
TJ/annum. been closed by the validation team.

It is also clarified that there was no


cogeneration unit in the pre project
scenario; therefore, the project
activity is a Greenfield cogeneration
unit.

Also, the historical data is not


applicable to the project activity as
the energy requirement in the pre

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project scenario and the project
scenario is not comparable.

Thus, the PP would like to submit


baseline emissions are calculated in
accordance with paragraph 27
(which in turn is referred by
paragraph 19 – d of the applied
methodology AMS I C, Version 19).

CAR-37 Table 1 The period of assessment taken for The period of assessment has been
The period of assessment taken for levelized cost (6.c.d), levelized cost analysis is now taken by the project participant as
analysis is only 10 years. Project participant to take (6.c.g) revised to 20 years (technical 20 years which is in accordance
the entire technical lifetime of the project activity as lifetime of the project activity). The with the general guidance for
a period of assessment or provide justification why revised levelized cost analysis investment analysis. Hence CAR-37
10 year assessment period will not lead to spreadsheet is being provided as has been closed by the validation
under/overestimation of the computation results. Annexure 7. team.
CAR-38 Table 1 The sensitivity analysis has been The project participant has revised
The sensitivity analysis has been carried out by the carried out for the following the description on the sensitivity
project participant on parameters price of baseline (6.c.ll)
parameters of the project activity: analysis in section B.5 of the PDD.
and project activity fuel, calorific value of basline The project participant has carried
fuel and project activity fuel. However, project out the sensitivity analysis for the
participant has not demonstrated clearly as how • Cost of Coal. parameters which contribute more
variables selected constitue more than 20% of the than 20% to the project cost and

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total project cost and under which circumstances • Cost of Rice Husk. applied the range of +/-10% for the
the variation would occur. sensitivity analysis. The project
• Calorific Value of Coal. participant has also provided
• Calorific Value of Rice Husk. description on which variation of the
individual parameter, the project
• Project Cost (Cogeneration activity becomes most economically
Plant) viable option. Hence, CAR 38 has
• Project Cost (Grid & LP been closed.
Boiler)

These parameters have been


selected in accordance with the
guidance on the assessment of
Investment Analysis (Version 5),
which states that “Only variables,
including the initial investment cost,
that constitute more than 20% of
either total project costs or total
project revenues should be
subjected to reasonable variation”.

The result of Sensitivity Analysis


shows that the Coal based
cogeneration project is always the
most economical option even when

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the above mentioned parameters
are subjected to the sensitivity of ±
10%.

The percentage variation of the


other alternatives from the most
economic alternative (Coal based
cogeneration) has also been
calculated and mentioned in section
B.5 of the revised PDD.

CAR-39 Table 1 The version 17 of the applied In accordance with the applied
The monitoring plan descriptions in case of co- methodology (AMS – I C) has methodology AMS-I.C. version 19,
firing by the project activity has not been included (7.r)
expired and the PDD has been the project participant has specified
the web hosted PDD in accordance with Para 33 of updated with the current version 19 ex ante in the revised PDD that
the applied methodology AMS I C, Version 17. of the methodology (AMS – I C). PP project activity will utilise 100% rice
would like to submit that the husk. Since the project activity is
paragraph 33 & 34 of version 17 of based in an area where rice husk is
AMS – I C has now been deleted in sufficiently available (also evident
version 19 of the methodology from the govt. approved biomass
(AMS – I C). assessment report). However, in
case of exigency, the project
participant has included the
The PP would also like to clarify that provisions for the monitoring of the
the following parameters required fossil fuel consumption and
as per paragraph 44 of the applied calculation of project emissions

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methodology has been added in from the fossil fuel consumption in
section B.6.2 of the revised PDD: accordance with the methodology
(AMS IC ver. 19) in the revised
PDD. Hence, CAR 39 has been
• Quantity and type of closed.
biomass (Ex ante
determination)
• Quantity of fossil fuel usage
(Ex ante determination)
• Biomass to fossil fuel ratio
(Ex ante determination)

In the revised PDD, it is mentioned


that the project activity is a multi fuel
co-fired system. It is envisaged that
the project activity would utilize
100% biomass residue for energy
generation, whereas, at any time, if
any fossil fuel is used, the same
would be accurately measured and
the amount of project emissions
(the procedures for the calculation
of the project emissions from the
fossil fuel usage has been provided
in section B.6.2 of the PDD)
accruing as a result of the fossil fuel

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usage would be deducted from the
baseline emissions while claiming
the emission reductions for the
project activity. The monitoring
procedures for the firing of fossil
fuels have been incorporated in
section B.7.1.
CL-1 Table 1 The PP had sent the personal (a) Justification provided by the PP
The process of stakeholder consultation has been invitation letters for the stakeholders is deemed to be reasonable in the
explained. As per PDD, the invitations were sent on (3.ee.i),
meeting on 8th July, 2009 and the project context as the project
08/07/2009 and stakeholder meeting took place on (3.ee.ii)
meeting took place on 13th July, activity has been implemented in
13/07/2009. Project participant to clarify following: 2009. As the stakeholders were the the manufacturing premises of the
a) How PP has considered that time provided local populace and as the project company. Further, the validation
for stakeholder consultation is reasonable? activity did not involved any land team has also conducted a
b) The description in section E.1 of the PDD acquisition, etc. Thus, the PP stakeholder’s meeting at the time of
does not provide description on how considered that the time provided validation site visit and did not
stakeholders were identified for the stakeholder consultation was receive any negative comment from
c) How project activity has been described in a reasonable. the local stakeholders.
manner, which allows the local stakeholders
to understand the project activity, taking into
account confidentiality provisions of the CDM The description in section E.1 of the (b) Section E.1 of the PDD has
modalities and procedures? PDD has been revised to been revised by the project
incorporate the identification of the participant and information on
stakeholders for the concerned identified stakeholder’s viz. local
meeting. villagers, employees of SELML and
biomass suppliers) has been
included in the PDD.

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The local stakeholders’ meeting
was carried out in the local
(c) At the time of re-conducting
language (Punjabi). Moreover,
stakeholder’s meeting, the DOE had
translators were also available for
observed that the commonly used
any clarification. Thus, it can be
language of the identified
considered that the confidentiality
stakeholder’s was Punjabi. Hence, it
provisions of the CDM modalities
was ensured that the project activity
and procedures were taken into
has been described in a manner,
account while conducting the local
which allows the local stakeholder’s
stakeholders meeting. The
to understand the project activity.
documents related to the local
stakeholders meeting have been Hence CL-1 is closed.
provided to the DOE.
CL-2 Table 1 The enthalpy of feed water has The project participant has taken
As demonstrated in the PDD in the justification of been taken from the feasibility enthalpy value of 567.48 kJ/kg of
selected methodology, total thermal output of the (5.b.iv)
report which mentions the feed feed water at 135 degree
project activity is 39.74 MW. Please clarify how water temperature as 135 degree centigrade. The same is a standard
enthalpy of the feed water has been considered. centigrade. value of enthalpy of feed water at
135 degree centigrade. Hence, CL-
2 has been closed by the validation
The same can also be team.
crosschecked from the technical
specification of the boiler which
mentions the feed water
temperature of 135 degree
centigrade.

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The total thermal output is thus


calculated using the formula:
(enthalpy of superheated steam-
enthalpy of feed water)*boiler
capacity. Details have been
provided in the emission reduction
sheet provided in the DOE.
CL-3 Table 1 PP would like to clarify that the feed The project participant has
The thermal energy generation capacity, presented water temperature considered for considered the enthalpy of the feed
by the project participant is the rated capacity of (5.b.iv.a)
emission reduction calculation is water at 135 degree centigrade for
the boiler. The project participant for the purpose of 135 o C measured after deaeration the purpose of emission reduction
calculation of boiler capacity has also incorporated before the economizer. The calculation. CL 3 has been closed.
the condensate return. Please clarify how the condensate return happens before
condensate recovered from the user plants is the economizer and hence, has
considered. already been considered in the net
enthalpy calculation. Thus, the
enthalpy of the feed water is also
calculated on 135 degree
centigrade.
CL-4 Table 1 It is clarified that in the web hosted The project participant has provided
As provided in the applicability condition 6, the PDD, the thermal energy capacity the details of the calculation of the
project activity involves both thermal and electrical (5.b.vi)
was calculated at the process capacity of the boiler in the section
energy components and total installed, both steam requirement of 190 degree B.2 of the revised PDD. The rated
thermal and electrical energy, generation is 12.25 Celsius (which was reduced from thermal capacity of the boiler is less
MW thermal. However, it is not clearly demonstrated the rated temperature of 259.5 than 45 MW thermal which is within

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and substantiated that how 12.25 MW thermal is degree Celsius by desuperheating the limits of the small scale project
calculated. of the steam) and at the pressure of activity. The validation team has
9.4 ata, which when computed gave also verified the technical
the thermal energy output of 12.25 specifications of the project
MW thermal at the requirement of equipments and confirms that the
19.7 TPH. capacity considered by the project
participant as 43.12 MW thermal is
based on rated parameters. Hence
Whereas, the process requirement CL-4 is closed.
is same as 19.7 TPH at 190 degree
Celsius and at the pressure of 9.4
ata, the extraction temperature
specified in the technical
specification of the turbine
(purchase order of the turbine dated
7th March 2008) is 259.5 degree
centigrade.

Thus, for the calculation of the


thermal capacity for the project
activity, the temperature of the
process steam is considered as
259.5 which is the rated extraction
temperature provided by the
technology supplier which gave the
thermal capacity of 13.12 MW
thermal.

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Also, the calculation of thermal


energy capacity viz. 13.12
MWthermal of the thermal energy
component has now been clearly
demonstrated in the section B.2 of
the revised PDD and the revised ER
Sheet.
CL-5 Table 1 Although, the PP had availed the It was observed by the validation
The electricity and steam will be used for captive relevant statutory approval from team during the site visit that project
consumption within manufacturing facility of the (5.b.vii)
PEDA for entering in to a PPA with participant has got approval for the
project participant. Project participant is required to the state electricity utility. However, sale of excess power from the co-
clarify how this condition is complied in case of based on the increased power generation plant to the state grid
exporting the electricity to PSEB grid as described demands, the PP has decided not from the PEDA (Punjab Energy
above in CAR-15 above in section (4.a) of this to supply power to any external Development Agency). However,
protocol. agency. The undertaking for the the project participant has
same has been provided to DOE. responded that though approval has
As per the updated methodology granted, the PP has not signed any
(AMS – I C, Version 19), the power purchase agreement with the
applicability condition 19 (d) is state grid and also provided an
applied to the project activity i.e., undertaking dated 7th Sept. 2011
electricity and thermal energy that they will not sell power from the
(steam/heat) are produced in the co-generation plant to any external
cogeneration unit using fossil fuel party. The project activity has been
(with a possibility of export of commissioned in year 2010 and
electricity to the grid/other facilities validation team has also reviewed

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and/or thermal energy to other the annual report of the company
facilities). Thereby, the calculations for year 2010-11 where sale of
of the baseline emissions are in electricity from the grid has not
accordance with paragraph 27 of been mentioned. Hence, based on
the applied methodology AMS I C, the undertaking provided by the
Version 19. project participant and review of the
annual report of the year 2010-11,
the validation team accepted the
response from the project
participant and closed CL 5.
CL-6 Table 1 The paragraph 16 of the updated The project participant has referred
The project participant is requested to clarify the methodology (AMS – I C, version to the latest version of the AMS-I.C.
rationale of using IPCC data as that can only be (5.d.b.iii)
19) states that for renewable energy version 19 approved in Executive
used when country or project specific data are not technologies that displace Board Meeting 61. The para 16 of
available or demonstrably difficult to obtain. technologies using fossil fuels, the the methodology has been revised.
simplified baseline is the fuel As per the revised para 16 of the
consumption of the technologies methodology AMS-I.C. there is no
that would have been used in the condition of using IPCC data when
absence of the project activity, country or project specific data are
times an emission factor for the not available or demonstrably
fossil fuel displaced. difficult to obtain. In the revised
methodology AMS-I.C., the IPCC
emission factor has been specified
Similarly, the IPCC default value of as an alternative approach and
Coal (96.1 t CO2/TJ) has been hence, the CL 6 has been closed by
considered for the calculation of the validation team.
baseline emissions. This is also in

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accordance with paragraph 18 of
the applied methodology (AMS – I
C, Version 19).

CL-7 Table 1 PP would like to clarify that the The project participant has provided
Though the steam was produced using fossil fuels equipment being used before the the details of the phase wise
and electricity was imported from PSEB grid in pre (5.d.b.xiv),
implementation of the project commissioning of the manufacturing
project scenario, the baseline emissions are not (5.d.b.xvi)
activity could not ‘provide output or facility of the project participant.
calculated in accordance with Paragraph 18 of the services comparable with the Hence, the electrical and thermal
applied methodology AMS IC, Version 17. proposed CDM project activity’. It requirements in the pre-project and
can be seen that the combined project scenario are not comparable
thermal output of the boiler (5 TPH) as the thermal and electrical
and thermopac (15 lac K Cal/hr) requirements in the project scenario
was only 138.37 TJ/annum have been significantly increased.
whereas; the thermal output Besides, there was no simultaneous
required post expansion was 349.23 heat and power generation in the
TJ/annum. pre-project scenario as compared to
the project activity. Hence, the
validation team accepted the
Thus, the pre project scenario with response of the project participant.
an addition of a fossil fuel fired As the revised baseline emissions
boiler has now been described as are in accordance with the baseline
one of the alternatives to the project identified by the project participant
activity in section B.4 of the revised based on the most economical
PDD. The same alternative has also scenario of levelized cost analysis,
been eliminated from further CL-7 has been closed.
consideration as the single

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cogeneration system providing both
thermal and electrical output is
inherently more efficient than an
individual generation systems
(http://www.retscreen.net/fichier.php
/1000/chapter-cogeneration.pdf).

Thus, the PP would like to submit


that the project activity is a
Greenfield cogeneration project
activity, since the continued use of
these above mentioned equipments
is not a viable alternative to the
project activity as explained in
section B.4 of the revised PDD,
Emission reductions have thus been
calculated in accordance with
paragraph 27 of AMS I C (Version
19).
CL-8 Table 1 PP would like to clarify that it has The project participant has provided
The web hosted PDD in section B.6.1 mentioned selected the baseline scenario as the details of the phase wise
the equation as per Para 20 of the selected (5.e.b.ii)
per paragraph 19 (d) of the applied commissioning of the manufacturing
methodology though there was not a co-generation methodology (AMS – I C, facility of the project participant.
unit in baseline scenario. Version19), i.e. “Electricity and Hence, the electrical and thermal
thermal energy (steam/heat) are requirements in the pre-project and
produced in a cogeneration unit project scenario are not

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using fossil fuel (with a possibility of comparable. Besides, there was no
export of electricity to a the simultaneous heat and power
grid/other facilities and/or thermal generation in the pre-project
energy to other facilities)” as the scenario as compared to the project
equipment being used before the activity. Hence, the validation team
implementation of the project accepted the response of the
activity could not ‘provide output or project participant as project
services comparable with the participant has installed greenfield
proposed CDM project activity’. It biomass based cogeneration facility
can be seen that the combined and there is always an alternative
thermal output of the boiler (5 TPH) available to the project participant to
and thermopac (15 lack K Cal/hr) install a fossil fuel based co-
was only 138.37 TJ/annum generation facility. Since revised
whereas, the thermal output baseline emissions are in
required post expansion was 349.23 accordance with the revised
TJ/annum. baseline and monitoring
methodology, CL-8 has been
closed.
It is also clarified that there was no
cogeneration unit in the pre project
scenario; therefore, the project
activity is a Greenfield cogeneration
unit.

Also, as demonstrated in the


investment comparison analysis,
the coal based cogeneration system

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has been the most economical
option available to the PP and
which is in accordance with the
applicable rules and regulation of
the host country, India.

Thus, the PP would like to submit


baseline emissions are calculated in
accordance with paragraph 27
(which in turn is referred by
paragraph 19 – d of the applied
methodology AMS I C, Version 19).
CL-9 Table 1 Project Cost has also been The project participant has also
The sensitivity analysis has been carried out for the subjected to the sensitivity analysis. subjected the sensitivity to variation
variables like cost of fuel and calorific values of (6.r)
The same can be cross checked in project cost in the levelised cost
fuels. Project participant to clarify why project cost from the levelised cost analysis analysis sheet and the results have
is not subjected to sensitivity analysis. spreadsheet submitted to DOE. also been included under section
B.5 of the revised PDD. Hence, CL-
9 is closed.
CL-10 Table 1 Comparative table showing actions The project participant has revised
The detailed chronology of events has been towards project implementation and the PDD and provided the
presented in section B.5 of the web hosted PDD, (6.a.h.ii)
securing CDM status of the project chronology for the project
however project participant has not submitted the activity is now presented in the implementation and actions to
evidences of each event, which are required to be revised PDD. Evidences of the secure the CDM for the proposed
submitted. Also, project participant is requested events are also being provided to CDM project activity. The project
provide a comparative table showing actions the DOE. participant has provided the certified

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towards project implementation and securing CDM true copy of the minutes of the
status of the project activity. board meeting took place on 1st
Feb. 2008 which confirms that
project participant was aware of the
CDM process and CDM benefits
were decisive factor for the project
activity. The validation team, during
the site visit, also checked the
Board Meeting register of the
company and confirms that project
participant was aware of the CDM
and CDM benefits were decisive
factor in project approval from the
Board which satisfies requirements
of Para 6 (a) of EB 62, Annex 13.

The project participant has also


provided a copy of the work order
signed with CDM consultant dated
15/01/2009 which has taken place
within one year of the board
decision to implement the project.
Further, the letter from the Ministry
of Environment and Forest for the
intimation of the meeting for the
host country approval sent to the
PP was dated 15th Oct. 2009.

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Further, the meeting of PP with the
members of the National CDM
Authority of India took place on 29th
Oct. 2009. Since, the CDM
consultant was appointed within one
year of the board decision and also,
the supporting evidences support
that host country approval process
reached advanced stage within two
years of the board decision, in
accordance with Para 6 (b, Para 7
and Para 8 (a) of the EB 62, Annex
13, The validation team confirms
that project participant has taken
the real and parallel actions to
secure the CDM benefits for the
project activity. Hence, CL 10 has
been closed by the validation team.
CL-11 Table 1 The project participant has now The validation team has observed
The project participant has not applied benchmark included the explanation on the the annual audited reports (for year
analysis (Option III). As per validation team’s (6.c.c.i)
determination of appropriate 2009-10 and year 2010-11). The
opinion benchmark analysis is more appropriate as analysis method covering all three project has been commissioned in
per the Para 16 of “Guidelines on the assessment options viz; Simple cost analysis, year 2010. It has been observed
of the investment analysis” (Annex 58, EB-51). investment comparison analysis that the cost of power generation
Further, as per discussion with the project and benchmark analysis in section from the co-generation plant is
participant, there will be export of power also to B.5 of the revised PDD. higher than the cost of power
PSEB grid to the tune of approximately 2.0 MW. purchased. It was further noted by

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Since, the PP will have captive power generation, it the validation team after reviewing
is required to clarify what will be the difference in the annual reports of the company
cost of power between grid power and captive The reason for the selection of (post commissioning of the project
power as it is very obvious and discussed with PP Investment Comparison Analysis activity) that electricity generated
that the cost of grid is higher than the cost of self- over Benchmark analysis is based from the project has not been sold
generation. These scenarios will bring cash in flow on the fact that, the equipments to state electricity board.
other than CDM revenue. available in the pre project scenario
(5 TPH fossil fuel based boiler and
15 Kcal/ hour thermopack) could Hence, based on the review of the
only have provided 138.37 TJ/year annual audited report, undertaking
of thermal energy to the plant, submitted by the PP (that project
whereas, the thermal energy will not sell power to any third
supplied by the project activity is to party), the validation team confirms
the tune 349.23 TJ/year to meet the that there is no additional revenue
expanded manufacturing capacity of generation for the PP either from
the project participant. Thus, the the sale of the excess electricity to
project participant had no choice but any third party or savings from the
to make an investment to supply the captive generation compared to the
increased level of energy. Hence, in purchased electricity cost. Hence,
accordance with Paragraph 19 of the verification team accepted the
the “Guidelines on the Assessment response provided by the project
of Investment Analysis” Version 05 participant and also accepted the
which states that “If the proposed levelized cost analysis as the
baseline scenario leaves the project significant capacity expansion of the
participant no other choice than to manufacturing facility (spinning and
make an investment to supply the terri towel units) leaves the PP with
same (or substitute) products or no other choice than investing into
services, a benchmark analysis is the project activity. Hence, CL-11

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not appropriate and an investment has been closed.
comparison analysis shall be used”.
Thereby, investment comparison
analysis was used by the project
activity over Benchmark analysis.

Also, the PP has availed the


relevant statutory approval from
PEDA for entering in to a PPA with
the state electricity utility. However,
based on the increased power
demands, the PP has decided not
to supply power to any external
party. The undertaking for the same
has been provided to DOE.

Further, PP would like to clarify that


the captive power plant is already
commissioned (commissioning date
of 10 January 2010) and in
operation. Thus, it should be noted
that as per the annual report of
SELML for the year 2010 – 2011,
the average cost per unit of
electricity purchased for the year
2009 – 2010 & 2010 – 2011 is Rs

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5.20 & Rs 4.41 respectively,
whereas, the cost of generation per
unit of electricity through captive
power plant for the year 2009 –
2010 & 2010 – 2011 is Rs 5.25 &
Rs 5.97 respectively. Thus, it can
be said that the cost of generation
of power through captive power
plant is higher than the cost of
purchase of power and no
additional revenue flow is there for
the PP from the cost savings.

Hence, as explained above, the


investment comparison analysis is
the most appropriate analysis for
the project activity.
CL-12 Table 1 Relevant formula with links to the The project participant has
The work sheet of the “Sensitivity Analysis” values has been provided in the submitted the revised sensitivity
contains the values, which are provided as (6.c.c.r)
work sheet of the “Sensitivity analysis spreadsheet with relevant
absolute figures, which is not correct. It is required Analysis” for the transparent formula with links to the values for
to provide all the relevant formula and spreadsheet illustration of the sensitivity analysis. transparent illustration of the
links for transparent illustration of the sensitivity sensitivity analysis. CL 12 has been
analysis. closed by the validation team.
CL-13 Table 1 The sensivity analysis is done for The project participant has included
The sensivity analysis is done for the range from the range from +10% to –10%. The the likelihood of the scenario when

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+10% to –10%. It does not include the details of the (6.c.c.vv) results of the sensitivity analysis variation in the individual parameter
under what conditions variations in the result would shows that the Coal based for the project activity will become
occur, and the likelihood of these conditions cogeneration is always the most equivalent to the baseline
assessed. economical option for the PP alternative. The project activity does
amongst all plausible alternatives. not cross the sensitivity analysis
and baseline chosen by the project
participant remains the most
Further, rice husk cogeneration can economical scenario at +/-10%
become the most economically range. Hence, CL 13 has been
feasible option (based on levelized closed.
cost analysis) in the following
individual conditions:

• Cost of coal increased by


16%.
• Cost of rice husk decreased
by 14%.
• Net Calorific value (NCV) of
coal decreased by 14%.
• Net Calorific value (NCV) of
rice husk increased by 16%.

The same has been demonstrated


in section B.5 of the revised PDD.

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Moreover, likelihood of the above
mentioned variations are not
possible as net calorific value (NCV)
of coal and rice husk are fixed
parameters and do not vary by a
great margin of 14 - 16%. Also, the
prices of rice husk and coal would
be subjected to annual escalation
which has been justified from the
evidence provided to support the
annual escalations for the same.
Thus, it can be concluded that there
is very limited probability of the
above mentioned variations in
regards to the cost and Net calorific
value (NCV) of coal and rice husk.
CL-14 Table 1 The PP does rely on many It has been observed by the
As per the investment analysis spreadsheet assumptions and values from the validation team from the
submitted during validation, the project participant (6.c.c.zz)
feasibility report. The copy of the documentary evidence submitted by
rely on many assumptions and values from the report has been provided to the PP that a feasibility report was
feasibility report. However, the extract of the board DOE also. prepared for a 10 MW Cogeneration
resolution submitted by the project participant does plant by Ace Engineers and
not refer to any feasibility report. Project participant The extract of the board resolution
does refers to the gist of the consultant and was submitted to
to clarify the timing of the feasibility report with SELML on 04-01-2008. Also, the
respect to the investment decision context and feasibility report as the feasibility
report was prepared and submitted extract of Board resolution dated
provide the supporting evidences for the values 01-02-2008 has been submitted by
considered in the feasibility report. The copy of the to the PP on 4th January, 2008 and
the Board Resolution for the project the PP as a proof of timing of

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feasibility report is to be submitted. activity was passed on 1st February, investment decision as well as CDM
2008. The feasibility report was consideration. Although, the board
prepared by a third party named resolution dated 01-02-2008 does
Ace Engineers and Consultants and not refer to the feasibility report but
the same was based on the the recommendations/outcome of
experience of their team. the feasibility report were available
to the PP at the time of investment
decision. Hence, CL-14 has been
closed.
CL-15 Table 1 The monitoring plan in the revised The project participant has provided
The monitoring plan does not cover following PDD is now covering the following revised PDD where data/parameter
parameters required for the purpose of (7.d)
parameters: symbols are consistent with the
conservative estimates of the emission reductions: applied methodology AMS-I.C.
a) Moisture content of the
a) Moisture content of the biomass residues biomass residues Secondly; it has been clarified by
b) temperature of the feed water b) Quantity, temperature and the project participant that instead
Also, PDD is silent upon how the monitoring of pressure of the feed water of steam temperature at turbine
pressure, temperature and quantity of the steam, extraction point, PP has selected
that is going to the process after extraction from the the monitoring point after the de-
turbine will be carried out. It is observed during site Energy extracted from the project superheating of the steam which is
visit that the monitoring is done at the generation of activity is being supplied to different 190 degree centigrade.
the thermal and electrical energy. As per sections and sub units of Spinning
methodology it is required to monitor net energy and Terri Towel units, which makes
supplied. Thus, the energy (both thermal and it difficult to monitor the energy at However, it is not explicit from the
electrical) being monitored is not net of the each individual consumption point. monitoring plan whether the
transformation, transmission and distribution Thus, as per the methodology, monitoring of the steam parameters
losses. Hence, it is required to monitor the net (temperature and pressure) will take
energy (both thermal and electrical) at user end. place after the de-superheating of

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Heat generation is determined as the steam.
The web hosted PDD does not include the the difference of the enthalpy of the
parameters to be monitored for project emissions in steam or hot fluid and/or gases
accordance with “Tool to calculate baseline, project generated by the heat generation The project participant has referred
and/or leakage emissions from electricity equipment and the sum of the to the latest version of the
consumption” (EB-39, Annex 7) on account of enthalpies of the feed-fluid and/or methodology AMS-I.C. version 19
electricity consumption from grid. gases blow-down and any approved in EB meeting 61. The
condensate returns. latest approved methodology
specifies that “in case project
activity is exporting heat to other
Similarly quantity of electricity facilities, the metering shall be
generated is also monitored at the carried out at the recipient’s end
generation stage and not the and measurement results shall be
consumption stage. cross checked with records for
sold/purchased thermal energy (e.g.
invoices/receipts)”. In this case, the
Thus, the applied methodology thermal and electrical energy
doesn’t specify that monitoring the produced by the project activity will
consumption is required. As per the be consumed by the adjoining
methodology, we can monitor the manufacturing facility of the project
energy generation, which is our participant and the project
project case. participant is not supplying the
energy to any other facility. Hence,
the validation team has accepted
The web hosted PDD now includes
the response provided by the
the parameters to be monitored for
project participant.
project emissions in accordance
with “Tool to calculate baseline,

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project and/or leakage emissions CL -15 has been closed.
from electricity consumption” on
account of electricity consumption
from grid.

PP would like to submit that


monitoring of the steam parameters
(temperature and pressure) will take
place after the desuperheating of
the steam. The same has now been
incorporated in section B.7.1 of the
revised PDD.
CL-16 Table 1 As the version 17 of applied The latest approved methodology
The specific energy consumption of each type of methodology (AMS I C) has already AMS-I.C. (version 19) in para 44
fuel being consumed to is not fixed ex-ante in (7.o)
expired, the PP has applied version specifies “The quantities and types
accordance with the Para 32 of the applied 19 of the same methodology. The of biomass and the biomass to
methodology AMS I C, Version 17. latest approved methodology AMS- fossil fuel ratio (in the case of co-
I.C. (version 19) in paragraph 44 fired systems) to be used during the
specifies “The quantities and types crediting period should be explained
of biomass and the biomass to and documented transparently in
fossil fuel ratio (in the case of the CDM-PDD. For the selection of
cofired systems) to be used during the baseline scenario, an ex ante
the crediting period should be estimation of these quantities
explained and documented should be provided”.
transparently in the CDM-PDD. For
the selection of the baseline

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scenario, an ex ante estimation of The project participant has provided
these quantities should be the ex ante determination of
provided”. quantity of the biomass and fossil
fuel usage in the revised PDD. It
has been specified that project
Thus, the following parameters activity will use rice husk as a main
required as per paragraph 44 of the fuel and coal will only be used in
applied methodology has been case of exigencies. Further, the
added in section B.6.2 of the project participant has also provided
revised PDD: the procedure for the computation
of the project emissions from the
fossil fuel consumption in
• Quantity and type of accordance with the latest version
biomass (Ex ante of the Tool to calculate
determination) project/leakage emissions from the
• Quantity of fossil fuel usage fossil fuel consumption. The ex ante
(Ex ante determination) determination of the fuel usage has
been provided by the project
• Biomass to fossil fuel ratio participant in section B.6.2 of the
(Ex ante determination). PDD in accordance with the latest
version (19) of the methodology
AMS-I.C. Hence, CL 16 has been
closed.
CL-17 Table 1 It is envisaged to utilize 100% The project participant has
As per the web hosted PDD, only rice husk is being biomass for the project activity, the submitted the biomass assessment
monitored. Project participant is to clarify, what if (7.q)
same can be justified by the report which has been duly
any other type of biomass than the rice husk is biomass assessment report, which approved by the PEDA (Punjab

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used by project activity. The monitoring plan is clearly demonstrate the availability Energy Development Agency)
silent on this scenario. of ample amount of rice husk which which is a Govt. entity. As per the
is required for the project activity. biomass assessment report, there is
Thus, in agreement with the SSC surplus availability of the rice husk.
WG Clarification 366, it can be Since total available rice husk
confirmed that the biomass specified in the feasibility
specified in the biomass assessment report is much higher
assessment report is much higher than the quantity required by the
than the quantity required by the project activity, the validation team
project activity and the PP only accepted the response of the PP
envisaged to use rice husk as the and closed CL 17 based on SSC
biomass for the project activity. WG clarification no. 366.
CL-18 Table 1 Energy extracted from the project The project participant has referred
The validation team, during site visit, observed activity is being supplied to different to the latest version of the
some of the meters are not available within the (7.s)
sections and sub units of Spinning methodology AMS-I.C. version 19
manufacturing facility to monitor the consumption and Terri Towel units, which makes approved in EB meeting 61. The
of net thermal energy at user end. it difficult to monitor the energy at latest approved methodology
each individual consumption point. specifies that “in case project
Monitoring plan does not include explicit QA/QC Thus, as per the methodology, activity is exporting heat to other
procedures, calibration procedures, cross checking facilities, the metering shall be
mechanism, data uncertainty, data archiving etc. carried out at the recipient’s end
Heat generation is determined as and measurement results shall be
The line diagram including monitoring points of the difference of the enthalpy of the cross checked with records for
entire project activity in line with project boundary is steam or hot fluid and/or gases sold/purchased thermal energy (e.g.
not provided. generated by the heat generation invoices/receipts)”. In this case, the
equipment and the sum of the thermal and electrical energy
enthalpies of the feed-fluid and/or produced by the project activity will

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gases blow-down and any be consumed by the adjoining
condensate returns. manufacturing facility of the project
participant and the project
participant is not supplying the
Similarly quantity of electricity energy to any other facility. Hence,
generated is also monitored at the the validation team has accepted
generation stage and not the the response provided by the
consumption stage. project participant. However, the
monitoring plan in section B.7.1 has
been further clarified with respect to
Thus, the applied methodology
the following :
doesn’t specify that monitoring the
consumption is required. As per the
methodology, we can monitor the (i) The monitoring of the pressure
energy generation, which is our and temperature of steam is taking
project case. place after the de-superheating of
the steam. The validation team
considers the same as appropriate.
Also, the power plant is located
within the manufacturing facility of
the PP, thus, losses will be minimal. (ii) The project participant has also
The PP would also like to clarify that provided the cross-checking
the steam temperature and procedures to be applied for the
pressure would be monitored after quantity of the rice husk consumed
the desuperheating point which which is in accordance with the
would further reduce the losses for applied monitoring methodology
steam temperature and pressure. AMS-I.C. version 19

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Now, the monitoring plan in the (iii) The project participant has also
revised PDD does include explicit provided details of the recording
QA/QC procedures, calibration frequency, measurement accuracy,
procedures, cross checking etc. for net electricity supplied to the
mechanism, data uncertainty, data manufacturing plant
archiving etc.

Based on the above-revisions in the


The line diagram for the project revised PDD submitted by the
activity is also being provided to the project participant, CL 18 has been
DOE. closed.

PP would further like to submit that:

(i) Monitoring of the pressure and


temperature of steam is taking
place after the desuperheating of
steam. Same has now been
incorporated in section B.7.1 of the
revised PDD.

(ii) Cross-checking procedures for


the quantity of the rice husk

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consumed in the project activity
have now been described in section
B.7.1 of the revised PDD.
(iii) PP would like to submit that the
net electricity supplied by the
project activity is a calculated value
which is calculated by subtracting
the auxiliary consumption from the
total electricity generated. The
recording frequency, Archiving
Procedure, Data Type, etc has now
been described in section B.7.1 of
the revised PDD.

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