ex c v m r e g p mgec.jp/gec/jp/activities/cdm/oe/vr03_azusa.pdf · azsa & co validation report...

VALIDATION REPORT

EX CORPORATION

VALIDATION OF THE METHANE RECOVERY AND RENEWABLE ELECTRICITY GENERATION PROJECT AT

PALM OIL MILL IN MALAYSIA (DRAFT)

AZSA & CO

VALIDATION REPORT

Date of first issue: Project No.: Approved by: Organisational unit:

AZSA & Co

Client: Client ref.:EX Corporation

Summary: AZSA & Co. has performed a validation of the Methane Recovery and Renewable Electricity Generation project in Malaysia. The validation was performed on the basis of UNFCCC criteria and host country criteria, as well as criteria given to provide for consistent project operations, monitoring and reporting. The sectoral scope of the project is Waste Handling and Disposal, Methane recovery, and the category of the project is Methane recovery and power generation. Project activities are planned to be executed in a palm oil mill in Malaysia. Methane gas is incessantly emitted out of anaerobic digestion treatment of effluent from the palm oil mill. In this project, the methane gas is recovered and is utilized for electric power generation. Thus 137,809 tons of CO2 equivalent is reduced during the project period with this project. Anaerobic fermentation technology by sealed digester is employed in this project. Two tanks are to be installed which have 10 meter water depth and a diameter of approximately 17 meters and the volume for each tank are 2,800 cubic meters. The validation has revealed that the procedures for monitoring and reporting are not yet sufficiently developed. The lack of such procedures may represent a risk for emission reductions not being verified and certified. Satisfactory procedures should hence be developed prior to project implementation. The validation of the Project resulted in four Corrective Action Requests and three Clarification Requests. The purpose of the validation is not to assess the emission reduction to generate CER, but to assess the project from the viewpoint of conditions on the application for new methodology approval or for new project validation. PDD is still draft version. Then validation itself is draft version. Therefore ,validation opinion is the qualified opinion. AZSA & Co. does not guarantee that this project should be entitled as a CDM project without any negative opinion raised or that no other CARs should be raised by any validation entities than AZSA & Co. did, if the project participant corrects the CARs and places the application for CDM approval to CDM-EB. Report No.: Subject Group: Indexing terms Report title:

Work carried out by: Yukinobu Matsuo, Maho Yao, Toshio Hayashi, Yayoi Nakamura

No distribution without permission from the Client or responsible organisational unit

Work verified by: Ryuta Uozumi Limited distribution

Date of this revision: Rev. No.: Number of pages: 17 Unrestricted distribution

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Abbreviations Abbreviations that have been used in the report. BOD Biochemical Oxygen Demand COD Chemical Oxygen Demand CPO Crude Palm Oil EFB Empty Fruit Bunch FFB Fresh Fruit Bunch POME Palm Oil Mill Effluent UNFCCC United Nations Framework Convention on Climate Change MCF Methane Conversion Factor RM Malaysia Ringitt (local currency) CDM Clean Development Mechanism CER Certified Emission Reduction ER Emission Reduction IETA International Emissions Trading Association CDM-EB Clean Development Mechanism Executive Board CO2 Carbon Dioxide GHG Greenhouse Gas GWP Global Warming Potential CAR Corrective Action Request DNA Designated National Authority ODA Official Development Assistance

Conversion Factors and Definitions Conversion factors used in the report. .

conversion factors terminologies 0.189 (t-CPO/t-FFB) extraction ratio of CPO to unit FFB 2.5 (m3-POME/t-CPO) amount of POME generated per unit CPO 24 (m3-biogas/ m3-POME) amount of biogas generated per unit CPO production 2.5(kg_CH4/kg_COD) maximum CH4 producing capacity 85% COD removal efficiency in lagoon 90% COD removal efficiency in sealed digestion tank 58 (%) methane content in the biogas in the baseline scenario 65 (%) methane content in the biogas in the project scenario 98 (%) COD removal efficiency 0.9 MCF for sealed digestion tank 0.85 MCF for lagoon 55.5 (MJ/kg) heat value of methane 30 (%) efficiency in the gas turbine power generation 3.8 (RM/US$) currency exchange rate 21 GWP CH4 310 GWP N2O 6.24x10-1 kg/kWh Emission factor Grid CO2 2.81x10-6 kg/kWh Emission factor Grid CH4 3.74x10-6 kg/kWh Emission factor Grid N2O

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Table of Contents Page

1 INTRODUCTION ....................................................................................................... 3 1.1 Objective 3 1.2 Scope 3 1.3 GHG Project Description 4

2 METHODOLOGY......................................................................................................... 4 2.1 Review of Documents 7 2.2 Follow-up Interviews 7 2.3 Resolution of Clarification and Corrective Action Requests 7

3. VALIDATION FINDINGS ......................................................................................... 8 3.1 New Methodology 8 3.2 Project Design 10 3.3 Baseline 11 3.4 Monitoring Plan 12 3.5 Calculation of GHG Emissions 12 3.6 Environmental Impacts and Comments by Local Stakeholders 13 3.6.1 Environmental Impacts 13 3.6.2 Comments by Local Stakeholders 13

4. COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS .............................. 13

5. VALIDATION OPINION ......................................................................................... 13 5.1 Validation opinion for New Methodology 13 5.2 Validation opinion for Project Design Document 13

6. REFERENCES........................................................................................................... 15

Appendix A: Validation Protocol

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1 INTRODUCTION

1.1 Objective The EX Corporation has commissioned AZSA & Co. to validate the “Methane Recovery and Renewable Electricity Generation Project at Palm oil mill in Malaysia” project. This validation is executed under 2003 CDM accreditation trial scheme of Japan Ministry of Environment. The validation serves as a design verification. The purpose of a validation is to have an independent third party assess the project design. In particular, the project's baseline, the monitoring plan, 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 meets 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 (CER). This project design document employs a new methodology for GHG emission reduction which essentially needs to be approved by CDM-EB in advance to execution of the validation. The validation has been processed with the detailed description of the project shown in the project design document, while the new methodology has not been approved, referring to the guidance proposed by CDM-EB on the description methods and the items to describe. UNFCCC criteria refer to the Kyoto Protocol criteria and the CDM rules and modalities as agreed in the Bonn Agreement and the Marrakech Accords.

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. AZSA & Co. has, based on the recommendations in the Validation and Verification Manual version 3.0 compiled by IETA, employed a risk-based approach in the validation, focusing on the identification of significant risks for project implementation and the generation of ERs. In this particular case, the validation is not performed based on the methodology approved by CDM-EB and the completion of the validation does not directly allow certified emission reductions to be generated. AZSA & Co. is to make sure during the validation period that all the items required for the application for the approval of CDM-EB as a new methodology and a new CDM project should be given in the project design document. The validation is not meant to provide any consulting towards the EX Corporation. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the project design.

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1.3 GHG Project Description Project activities are planned to be executed in a palm oil mill located at Dengkil Town, Langat Selangor State, Malaysia.

Methane gas is incessantly emitted out of anaerobic digestion treatment of effluent from the palm oil mill. In this project, the methane gas is recovered which reduces GHG emission by 139,161 tons of CO2 equivalent per year. The recovered methane gas is utilized for electric power generator. The power generated substitutes the grid electricity which reduces GHG emission by 156.037 tons of CO2 equivalent in the project. On the other hand, 18,228 tons of CO2 is emitted annually by methane combustion in the project. Therefore 137,800 tons of CO2 equivalent is reduced during the project period with this project.

Anaerobic fermentation technology by sealed digester is employed in this project. Two tanks are to be installed which have 10 meter water depth and a diameter of approximately 17 meters and the volume for each tank are 2,800 cubic meters.

The sectoral scope of the project is Waste Handling and Disposal, Methane recovery, and the category of the project is Methane recovery and power generation.

The operational lifetime of the project activity is expected to be 21 years min., starting on January 1st, 2006. The crediting period is 7 years (renewable), starting on the day of the commencement of the project activity.

The figures shown in the table below reflect the figures described in the draft3 PDD as summary. These figures will be revised in final PDD as promised in the draft2 meeting.

Anthropogenic GHG emission and expected reduction:

1st year 2nd year 3rd year 4th year 5th year 6th year 7th year total

baseline emission

(ton-CO2/yr) 22,291 22,291 22,291 22,291 22,291 22,291 22,291 156,037

project emission

(ton-CO2/yr) 2,604 2,604 2,604 2,604 2,604 2,604 2,604 18,228

emission reduction

(ton-CO2/yr) 19,687 19,687 19,687 19,687 19,687 19,687 19,687 137,809

2 METHODOLOGY In order to ensure transparency, a validation protocol was customised for the project, according to the Validation and Verification Manual and other criteria which the validator believes are

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necessary. The protocol shows, in a transparent manner, criteria (requirements), means of verification and the results from validating the identified criteria. The validation protocol serves the following purposes: ・ It organises, 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. Validation Team Member:

Lead Verifier: Ryuta Uozumi

Validator : Maho Yao (Environmental Aspect)

Validator : Yukinobu Matsuo ( Quality System)

Validator : Toshio Hayashi ( Technology)

Validator : Yayoi Nakamura( Economical Aspect)

The validation consists of the following four phases this time: I a desk review of the project design documentation II follow-up interviews with project developer(including E-mail correspondings) III onsite visit in Malaysia IV the resolution of outstanding issues and the issuance of the final validation report and opinion. Findings established during the validation can either be seen as a non-fulfilment of validation protocol criteria or where a risk to the fulfilment of project objectives is identified. Corrective Action Requests (CAR) are issued, where: i) mistakes have been made with a direct influence on project results; ii) validation protocol requirements have not been met; or iii) there is a risk that the project would not be accepted as a CDM project or that emission

reductions will not be certified. The validation team may also use the term Clarification, which would be where: iv) additional information is needed to fully clarify an issue. The protocol developed by IETA is used with some additional check items originated by us to make the validation work execute smoothly. The validation protocol consists of three tables. The different columns in these tables are described in Figure 1. The completed validation protocol is enclosed in Appendix A to this report.

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Validation Protocol Table 1: Mandatory Requirements

Requirement Reference Conclusion Cross reference The requirements the project must meet.

Gives reference to the legislation or agreement where the requirement is found.

This is either acceptable based on evidence provided (OK), or a Corrective Action Request (CAR) of risk or non-compliance with stated requirements. The corrective action requests are numbered and presented to the client in the Validation report.

Used to refer to the relevant checklist questions in Table 2 to show how the specific requirement is validated. This is to ensure a transparent Validation process.

Validation Protocol Table 2: Requirement checklist

Checklist Question Reference Means of verification (MoV)

Comment Draft and/or Final Conclusion

The various requirements in Table 1 are linked to checklist questions the project should meet. The checklist is organised in seven different sections. Each section is then further sub-divided. The lowest level constitutes a checklist question.

Gives reference to documents where the answer to the checklist question or item is found.

Explains how conformance with the checklist question is investigated. Examples of means of verification are document review (DR) or interview (I). N/A means not applicable.

The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached.

This is either acceptable based on evidence provided (OK), or a Corrective Action Request (CAR) due to non-compliance with the checklist question (See below). Clarification is used when the validation team has identified a need for further clarification.

Validation Protocol Table 3: Resolution of Corrective Action and Clarification Requests

Draft report clarifications and corrective action requests

Ref. to checklist question in table 2

Summary of project owner response

Validation conclusion

If the conclusions from the draft Validation are either a Corrective Action Request or a Clarification Request, these should be listed in this section.

Reference to the checklist question number in Table 2 where the Corrective Action Request or Clarification Request is explained.

The responses given by the Client or other project participants during the communications with the validation team should be summarised in this section.

This section should summarise the validation team’s responses and final conclusions. The conclusions should also be included in Table 2, under “Final Conclusion”.

Figure 1 Validation protocol tables

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2.12.1 Review of Documents

The Project Design Document submitted by EX Corporation as draft2 and additional background documents related to the project design , baseline and monitoring were reviewed.

2.22.2 Follow-up Interviews In the period of (03-11-13 through 04-03-22), AZSA & Co. performed interviews with representatives of EX Corporation to confirm selected information and to resolve issues identified in the document review. The main topics of the interviews are summarised in Table 1.

Table 1 Interview topics Interviewed organisation Interview topics EX Corporation Representatives: Mr.Suzuki, Ms.Kawamura AZSA &Co Ms Yao, Mr Hayashi, Ms Nakamura Date: 03-11-13 Place: PACIFIC CONSULTANS CO.LTD

General explanation of the project Validation schedule

EX Corporation Representatives: Mr. Suzuki, Ms. Kawamura, Mr. Lim, Mr. Shahrakbah AZSA & Co Mr. Matsuo, Mr Hayashi Date: 04-02-11to 04-02-13 Place: Dengkil in Malaysia

Onsite visit to Malaysia Discussion with expected project participants and co-project developer

of Malaysia side.

EX Corporation Representatives: Mr. Suzuki, Ms. Kawamura AZSA & Co Ms. Yao, Mr. Hayashi Date: 04-03-22 Place: EX Corporation

Draft2 meeting for Validation with project developer to validate PDD (ver2)presented by project developer. Draft3 PDD was prepared by EX corporation at the meeting. EX corporation will revise Draft3 according to the draft2 conclusion and results of the draft2 meeting.

2.3 Resolution of Clarification and Corrective Action Requests

The objective of this phase of the validation was to resolve the requests for corrective actions and clarifications and any other outstanding issues which needed to be clarified for AZSA &

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Co.'s positive conclusion on the project design. The Corrective Action Requests and Clarification Requests raised by AZSA & Co. were resolved during communications between EX Corporation and AZSA & Co. To guarantee the transparency of the validation process, the concerns raised and responses given are summarised in chapter 3 below and documented in more detail in the validation protocol in Appendix A.

Since modifications to the Project design were necessary to resolve AZSA & Co.'s concerns, EX Corporation decided to revise the documentation and resubmitted the project design document (ver3) on (04-03-22). After reviewing the revised and resubmitted project documentation, AZSA & Co. issued this draft3 validation report and opinion. And after the receipt of final PDD, final validation will be done.

3. VALIDATION FINDINGS In the following sections the findings of the validation are stated. The validation findings for each validation subject are presented as follows: 1) The findings from the desk review of the original project design documents and the findings from interviews during the follow up visit are summarised. A more detailed record of these findings can be found in the Validation Protocol in Appendix A. 2) Where AZSA & Co. had identified issues that needed clarification or that represented a risk to the fulfilment of the project objectives, a Clarification or Corrective Action Request, respectively, have been issued. 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 X(number) Corrective Action Requests and X(number) Clarification Requests. 3) Where Clarification or Corrective Action Requests have been issued, the exchanges between EX Corporation and AZSA & Co. to resolve these Clarification or Corrective Action Requests are summarised. AZSA & Co. validated first received PDD(ver2)(04-02-10) by EX Corporation as draft2 conclusion and after the second meeting(04-03-22) with revised PDD(ver3) validated as draft3 conclusion. 4) The conclusions for validation subject are presented The draft3 validation findings relate to the project design as documented and described in the revised and resubmitted project design documentation.

3.1 New Methodology For the validation of this project, Methodologies of Baseline and Monitoring are not approved by CDM-EB of UNFCCC. Therefore at first the validation of new methodologies were done and after that the Validation of PDD was done based on the new methodologies ,supposing that those are approved.

Validation of new methodology shall be done from the point of view of transparency and conservativeness. Based on these concepts , the approach , algolism , additionality and other items to be confirmed. will be evaluated.

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3.1.1 New Baseline Methodology

(1) GHG emission from methane gas power generation The amount of methane to be calculated in this case is the amount of methane emitted

in project, not the baseline as actual emission.

(2) project boundary The project boundary in the baseline scenario needs to include the aerobic lagoon system after the anaerobic lagoon system. The water discharge after the aerobic lagoon system is required to be examined under the legal regulation.

(3) the methane conversion factor The source or back ground of ”water depth factor” is not given. It is not rationally understood that the corelation between the water depth and anaerobic coefficient, shows discontinuity.

The clear explanation is required for the relationship between water depth factor and MCF.

(4)emission from start up of methane power generation facility The duration is not considered in the formula to obtain GHG emission from start up of methane power generation facility.

(5)potential leakage COD consentration in POME after the digestion tank may be as much as a certain level. If any of the aerobic lagoons after the digestion tanks are deeper than 3 meters, it is possible that methane is emitted from the aerobic lagoons. The emission can be counted as the leakage and it is not described in the project design. (6)decision tree Decision tree is not complete in its logics. (7) uncertainty Following points need to be clarified: uncertainty #1(weight of FFB in rain) When FFBs are shipped in to the palm oil mill, they are weighed on a truck scale. In rainy days the FFBs may be soaked enough to weigh noticeably heavier than what they are in dry days. The possible fluctuation of the weight measured of incoming shipment of FFBs is not discussed in the project design.

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uncertainty #2( transportation of FFB) Naturally the amount of incoming shipment of FFBs fluctuate annually. The fluctuation stays the same in the baseline scenario and in the project scenario. But if more FFBs should be shipped in than the maximum capacity of the digestion tanks in the project, the shipment of the excessive FFBs is thought to generate GHG emission during transportation. The possibility of the excessive receiving of FFBs is not discussed in the project design. As stated in the project design document, if no increase of transportation of FFB is expected, this item is cleared. uncertainty #3( treatment of rain water etc.) At present, rain water and cleaning water for autotruck are treated in open lagoons. It is not clearly stated whether open lagoons are used as before or not and whether any GHGs be emitted or not after the project starts due to the possible excessive amount of POME(should be checked). (8) methane concentration Clearer explanation or evidence is required on the values of the methane concentration after the treatment of POME. (9) BOD regulation It is desired to clarify the type of BOD stated in regulation in Malaysia. 3.1.2 New Monitoring Methodology (1) It is required to monitor following factors:

- COD concentration and flow amount effluent discharge from the palm oil mill.

- fossil fuel (gasoline) consumed by the trucks for the shipment of FFBs

- working hours(or days) of sealed digestion tanks and gas engine if they are not continuosly operated all through the year. (2) It is required to specify the monitoring factor(s) for sustainability. (3)Description of the monitoring scheme in the quality control systems is not sufficiently clear.

3.2 Project Design (1) the technology used

State of art design technology is used in this project while basic concept is not new. Although this technology has been researched in the host country long before, it has not been realised yet.

(2) the project’s contribution to sustainable development This project is understood to reduce the GHGs emission through reducing fossil fuel enegry consumption. (3) endorsement by host country DNA,

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This project has not been endorsed by Malaysian DNA yet.

But discussions are continued.

(4) ODA additionality

No fund is deemed from ODA for this project.

(5) project duration and crediting time

Project duration is estimated to be 21 years or longer and crediting time is set to be 7 years. These period settings are thought to be adequate.

(6) possibility of substitution by other technologies

Substitution by other technologies is not normally assumed unless new technology,for instance, like effective organic compounds recovery in POME is realised during credit duration. (7) Methane treatment It needs clarified what happens to the methane gas emitted in case the gas engine unintentionally should stop or the sealed digention tank should be shut,if there is some possibility. Flare combustion may possibly be considered effective. (8) power generation

The maximum electricity and the minimum electricity generated by the methane gas engine are estimated, but the logics – formulae and the values of related parameters – are not clearly explained and are required to be clarified. (9) additives Additives may be put into Sealed Digestion System to maintain stable and safwty operation. The possibility of GHG emission from the additive handling, for example, transportation of additives, is not discussed. (10) estimation of annual FFB generation The annual FFB generation is estimated from the actual data in the past few years, but it is not clearly stated which specific years are the ”past few years”. Clearer explanation is desired. (11) estimation of annual CPO extraction The annual CPO extraction is estimated from the actual data in the past 10 years, but it is not clearly stated which specific years are the ”past 10 years”. Clearer explanation is desired.

(12) temperature The methane gas valume is a funcion of the temparature. In the project design document, 27 degree celsius as the average temparature in the Southeast Asia plains, is taken. It is not normally understood that it is difficult to measure temperature in terms of technical, physical, economical or any other point of views. The temparature is required to be monitored or it is necessary to justify the eligibility to use average temperature.

3.3 Baseline

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(1) baseline is followed by the new methodology.

(2) approval of the baseline methodology,

the baseline methodology is not yet approved, will be submitted as new methodology

(3) from the scenario, to continue to use open lagoons is quite reasonable to justify that it is the

correct application and justification of selected baseline methodology.

(4) the project’s environmental additionality is to remove the methane released to atmosphere

and the reduction of fossil fuels by the generation of electricity by captured methane.

3.4 Monitoring Plan

(1) monitoring plan is followed by new methodology except for some points.

(2) approval of the monitoring methodology,

the monitoring methodology is not yet approved, will be submitted as new methodology

(3) the monitoring methodology is justified and applicable

(4) some of adequate indicators for sustainability development (social, environmental,

economic) are not included in as monitoring items

(5) monitoring plan includes

a. to estimate or measure emissions occurring within the project boundary,

b. to determine the baseline emissions, and determined by conservative way

c. to estimate changes in emissions outside the project boundary is considered, but no change is expected.

(6) QC/QA system like ISO9000 is not introduced.

3.5 Calculation of GHG Emissions The project boundaries are properly defined. The project design document shows that the gas engines in the methane power generation facility work 300 days in a year. It is safely understood that they stop working in the remainder of 65 (or 66) days probably because of regular maintenance. It is required to discuss the possibility of leakage of methane recovered and stored in the digestion tanks while the gas engines is not working. The formulae are transparent but the sources/grounds are not satisfactorily given of following factor:

- 85% in baseline scenario as COD removal factor

- emission factors of average grid mix

- for electricity to grid average distribution losses are not considered.

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- zero as the estimated amount of GHG upon start up of the power generation facility

The assumption made for estimating GHG emission reductions are made conservative and rational.

Uncertainties are recognized but two shown in 3.1.1 in this validation report need to be discussed.

It is required to reconsider the designed capacity of the sealed digestion tank (20,410 tons per month) in the project. The actual FFB receiving in the year of 2003 was 246,555 tons in total and the simple average by month falls on 20,546 tons which implies overflow out of the digestion tank.

3.6 Environmental Impacts and Comments by Local Stakeholders 3.6.1 Environmental Impacts At this moment, it is not required by Malaysia Regulation.

3.6.2 Comments by Local Stakeholders At this moment, it is not planned to get comments from Local Stakeholders.

4. COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS Not included in the project design document.

5. VALIDATION OPINION

5.1 Validation opinion for New Methodology Qualified validation opinion

The evaluation results of new methodologies derived from the analysis of

findings show that those are conservative and transparent. Some points to be explained

clearly are remained, but in final PDD will reflect those items as promised. Then we

conclude they are validate as unqualified validation opinion.

5.2 Validation opinion for Project Design Document

Qualified validation opinion

AZSA & Co. has performed a validation of the Methane Recovery and Renewable Electricity Generation project in Malaysia. The validation was performed on the basis of UNFCCC criteria and host country criteria, as well as criteria given to provide for consistent project operations, monitoring and reporting.

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AZSA & Co. have provided the review of the project design documentation and the subsequent follow-up interviews. The validation has revealed that the procedures for monitoring and reporting are not yet sufficiently developed. Further the consistency between new methodology and PDD are not sufficient and not established. The lack of such procedures may represent a risk for emission reductions not being verified and certified. Satisfactory procedures should hence be developed prior to project implementation.

The validation is based on the information made available to us and the engagement conditions detailed in this report. AZSA & Co. cannot guarantee the accuracy or correctness of this information. Hence, AZSA & Co. cannot be held liable by any party for decisions made or not made based on the validation opinion.

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6. REFERENCES

Category 1 Documents:

Documents provided by the project participant that relate directly to the GHG components of the project, which were used as direct sources of evidence for the validation conclusions, and were further checked through interviews with key personnel. /1/ Project Design Document January 2004

Category 2 Documents:

Background documents related to the design and/or methodologies employed in the design or other reference documents, which were used to check project assumptions and confirm the validity of information given in the Category 1 documents and in validation interviews. /2/ “The Relationship Between Oil Palm Bunch Quality (Composition) and Bunch

Weight”, B.M.Ojuederie, Nigerian Institute for Oil Palm Research, Benin city, Nigeria/3/ “Thermophilic Anaerobic Contact Digestion of Palm Oil Mill Effluent”, A.Ibrahim et

al. /4/ “Anaerobic Treatment of Palm Oil Mill Effluent by Tank Digesters”, C.C.Ho and

Y.K.Tan, Department of Chemistry, University of Malaya, Kuala Lumpur, Malaysia

/5/ “Disposal of Palm Oil Mill Effluent in Malaysia – A Survey”, Ma Aah Ngan and Chow Chee Sing, Palm Oil Research Institute of Malaysia, Kuala Lumpur, Malaysia

/6/ “An Introduction of the Decanter-Drier System in the Clarification Station for Crude Oil and Sludge Treatment”, H.K.Jorgensen and Gurmit Singh, United Plantations Bhd., Teluk Anson, Malaysia

/7/ “The Oil Palm Industry – from Pollution to Zero Waste” Yusof Basiron and Ariffin Darus, Palm Oil Research Institute of Malaysia

Persons interviewed:

Persons interviewed during the validation, or persons contributed with other information that are not included in the documents listed above.

/8/ SUZUKI, Shinichi, EX Corporation

/9/ KAWAMURA, Ai, EX Corporation

/10/ LIM, Sang Ting, Seri Ulu Langat Palm Oil Mill Sdn. Bhd.

/11/ SHAHRAKBAH, Yacob, Department of Biotechnology, Universiti Putra Malaysia

- o0o -

CDM VALIDATION PROTOCOL

(METHANE RECOVERY AND RENEWABLE ELECTRICITY GENERATION PROJECT AT PALM OIL MILL IN MALAYSIA)

VALIDATION PROTOCOL CONSIST OF THREE PARTS.

Table 1 Mandatory Requirements for Clean Development Mechanism (CDM) Project Activities

Table 2 Requirements Checklist

Table 3 Resolution of Corrective Action and Clarification Requests

CDM VVM (VER 3.0) IS USED BASICALLY.

Page A-1

Table 1 Mandatory Requirements for Clean Development Mechanism (CDM) Project Activities REQUIREMENT Reference CONCLUSION Cross Reference / Comment

1. Assist Parties included in Annex I in achieving compliance with part of their emission reduction commitment under Art. 3

Kyoto Protocol Art.12.2

Yes

2. Assist non-Annex I Parties in achieving sustainable development and the project has obtained confirmation by the host country that the project assists in achieving sustainable development

Kyoto Protocol Art. 12.2, Marrakesh Accords, CDM Modalities §40a

Yes Mitigation of climate change through the recovery of the methane gas from POME effluent and fossil fuel energy conservation are admitted.

3. Assist non-Annex I Parties in contributing to the ultimate objective of the UNFCCC

Kyoto Protocol Art.12.2.

Yes

GHGｓemission reduction

4. The project has the written approval of voluntary participation from the designated national authorities of each party involved

Kyoto Protocol Art. 12.5a, Marrakesh Accords, CDM Modalities §40a

Not yet

5. The emission reductions shall be real, measurable and give long-term benefits related to the mitigation of climate change

Kyoto Protocol Art. 12.5b

Yes. Methane gas is released from anaerobic lagoon at present.

6. Reduction in GHG emissions shall be additional to any that Kyoto Protocol Art. Yes. Additionality

Page A-2

REQUIREMENT Reference CONCLUSION Cross Reference / Comment would occur in absence of the project activity, i.e. a CDM project activity is additional if anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the registered CDM project activity

12.5c, Marrakesh Accords, CDM Modalities §43

is admitted as long as no restriction is imposed on the methane release to atmosphere from lagoons.

7. Potential public funding for the project from Parties in Annex I is not a diversion of official development assistance

Marrakech Accords No

8. Parties participating in the CDM shall designate a national authority for the CDM

Marrakech Accords, CDM Modalities §29

OK

9. The host country is a Party to the Kyoto Protocol Marrakech Accords, CDM Modalities §30

OK

10. Comments by local stakeholders are invited, a summary of these provided and how due account was taken of any comments received

Marrakech Accords, CDM Modalities §37b

Not yet

11. Documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts, has been submitted, and, if those impacts are considered significant by the project participants or the Host Party, an environmental impact assessment in accordance with procedures as required by the Host Party has been carried out.

Marrakech Accords, CDM Modalities §37c

Not yet

12. Baseline and monitoring methodology is previously approved by the CDM Methodology Panel

Marrakech Accords, CDM Modalities §37e

No. This project utilises a new methodology.

13. Provisions for monitoring, verification and reporting are in accordance with the modalities described in the Marrakech Accords and relevant decisions of the COP/MOP

Marrakech Accords, CDM Modalities §37f

OK

14. Parties, stakeholders and UNFCCC accredited NGOs have been invited to comment on the validation requirements for

Marrakech Accords, CDM Modalities, §40

Not yet.

Page A-3

REQUIREMENT Reference CONCLUSION Cross Reference / Comment minimum 30 days, and the project design document and comments have been made publicly available

15. A baseline shall be established on a project-specific basis, in a transparent manner and taking into account relevant national and/or sectoral policies and circumstances

Marrakech Accords, CDM Modalities, §45c,d

OK

16. The baseline methodology shall exclude to earn CERs for decreases in activity levels outside the project activity or due to force majeure

Marrakech Accords, CDM Modalities, §47

OK

17. The project design document is in conformance with the UNFCCC CDM-PDD format

Marrakech Accords, CDM Modalities, Appendix B, EB Decisions

OK

Page A-4

Table 2 Requirements Checklist

CHECKLIST QUESTION Item Page COMMENTS Draft2 Concl.

Draft3 Concl.

A. General Description of Project Activity The project design is assessed.

A.1. Project Boundaries Project Boundaries are the limits and borders defining the GHG

emission reduction project.

A.1.1. Are the project’s spatial (geographical) boundaries clearly defined?

Yes, the project’s spatial (geographical) boundaries are clearly defined.

OK

A.1.2. Are the project’s system (components and facilities used to mitigate GHGs) boundaries clearly defined?

Yes, the project’s system boundaries are clearly defined.

OK

A.2. Technology to be employed Validation of project technology focuses on the project

engineering, choice of technology and competence/ maintenance needs. The validator should ensure that environmentally safe and sound technology and know-how is used.

A.2.1. Does the project design engineering reflect current good practices?

The up-to-date technology is utilized though the basic concept is not new.

OK

A.2.2. Does the project use state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in the host country?

The technology utilized in this project can be understood to be better than commonly used technologies in Malaysia.

OK

A.2.3. Are safety, operability of the facilities assessed? It needs clarified what happens to the methane gas emitted in case the gas engine

CL OK

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Draft3 Concl.

unintentionally should stop or the sealed digention tank should be shut..

A.2.4. Is the project technology likely to be substituted by other or more efficient technologies within the project period?

Substitution by other technologies is not normally assumed unless new technology like effective organic compounds recovery in POME is realised during credit duration.。

OK

A.2.5. Does the project require extensive initial training and maintenance efforts in order to work as presumed during the project period?

Not much specialty is required, but training for plant is necessary. (eg.oxygen control system)

OK

A.2.6. Does the project make provisions for meeting training and maintenance needs?

No. The provisions need to be made. CL CL

A.3. Contribution to Sustainable Development The project’s contribution to sustainable development is assessed.

A.3.1. Is the project in line with relevant legislation and plans in the host country?

A.3.2. Is the project in line with host-country specific CDM requirements?

Yes. The reduction of usage of fossil fuels. Promotion of renewable energy to realize the reduction of GHGs.

OK

A.3.3. Is the project in line with sustainable development policies of the host country?

Yes. OK

A.3.4. Will the project create other environmental or social benefits than GHG emission reductions?

Yes. OK

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Draft3 Concl.

B. Project Baseline The validation of the project baseline establishes whether the selected baseline methodology is appropriate and whether the selected baseline represents a likely baseline scenario.

Yes. OK

B.1. Baseline Methodology It is assessed whether the project applies an appropriate baseline methodology.

B.1.1. Is the baseline methodology previously approved by the CDM Methodology Panel?

B.1.2. Is the baseline methodology the one deemed most applicable for this project and is the appropriateness justified?

7 No. This project utilizes a new methodology in the category of “Waste Handling and Disposal”

OK

The below questions only apply when the validator is reviewing the baseline methodology prior to submission to the CDM EB (Two Steps Approach):

Explanation (max 1page) B.1.3. Is the discussion and selection of the baseline

methodology transparent? 13 Estimation of annual FFB generation/CPO

extraction need clearer explanation.

The maximum input (receiving) of FFB and the minimum input (receiving) of FFB are estimated, but it is not explained how they are calculated. The amount of methane to be calculated in this case is the amount of methane emitted in project, not the baseline.

CL

CL

OK

OK

OK

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Draft3 Concl.

B.1.4. Unnecessary information 44 Incineration factor is unnecessary and needs deleted.

CL OK

B.1.5. Is the proposed baseline methodology in line with one of the approaches outlined in Paragraph 48 of the Marrakech Accords?

43 ４８（ａ）is selected. OK

B.1.6. explanation for selection of 48(a)

3.1 Open lagoons are used continuously. OK

B.1.7. Does the baseline methodology specify data sources and assumptions?

5

Used data 32 56 52

Origin of emission factors in Chart E.11 and its reasonableness Origin of Methane concentration

CAR

CAR

OK

OK Project boundary 4.5 45

46 To include aerobic lagoon after anaerobi lagoon and sealed digesting tankin flow sheet.(Regulation of discharged water at the outlet of aerobic lagoon )

CL OK

Does the baseline methodology sufficiently describe the underlying rationale for algorithm/formulae (e.g. marginal vs. average, etc.)

4.6 6

53

56

Origin or background for relationship between water depth and water depth factor.At５．９Ｍ:factor =０．６? To estimate MCF, experimental results are used and extrporate to shallow side. Yearly average water depth of open lagoon. Operating time of gas engine with number of

CAR

CAR

CAR

OK

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Draft3 Concl.

24

& 56

56

start up to calculate the amount of emission While the formula for calculating the amount of GHG emission due to the electric power consumption is shown in the new methodology, it is calculated in the project design, although electricity generated is monitored.(possibility of occurring the discrepancy) Electricty to grid : average distribution losses are not considered.

CAR

CAR

CAR

OK

B.1.8. Does the baseline methodology specify types of variables used (e.g. fuels used, fuel consumption rates, etc)?

4.6 4.7 4.9

Yes. OK

B.1.9. Does the baseline methodology specify the spatial level of data (local, regional, national)?

Policy of Malaysia Important products of palm oils Important industries in Local area.

OK

B.1.10. Does the baseline methodology specify an approach to define the additionality of the project?

4.3 Flow chart OK

B.1.11. leakage 4.8 57 Difference of anaerobic open lagoon and Sealed Digestion Tank is COD concentration of treated water to aerobic lagoon. Water depth of aerobic lagoon more than 3m. Methane is produced to some extent according to the CODconcentration.

CL OK

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Draft3 Concl.

Minus leakage is expected. B.1.12. technical explanation Experiment report to support the methane

concentration CL OK

B.1.13. adequacy of scenario 39 42

Decision tree more accurately (to refer additional paper)

CAR OK

B.1.14. Uncertainty 5 47

47

Weight measurement of FFB in rain Correction is required. Transportation of FFB Over production of CPO due to the demands of Palm oil. Naturally the amount of incoming shipment of FFBs fluctuate annually. The fluctuation stays the same in the baseline scenario and in the project scenario. But if more FFBs should be shipped in than the maximum capacity of the digestion tanks in the project, the shipment of the excessive FFBs is thought to generate GHG emission during transportation. The possibility of the excessive receiving of FFBs is not discussed in the project design. As stated in the project design document, if no increase of transportation of FFB is expected, this item is cleared.

CAR

CL

OK

OK

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Draft3 Concl.

48

47

Rain water and cleaning water of autotruck After the starting up of project, operation of present lagoon Additives into Sealed Digestion (transportation of additives etc.)

OK

CL

OK

B.1.15. Transparancy of baseline development 7 49 ＦＦＢ:clear explanation is necessary. ＣＰＯ: variables?

Clear explanation is necessary. Temperature: variables (or need the deviation of ±)

CL

CL

CL

OK

OK

OK

B.2. Baseline Determination The choice of baseline will be validated with focus on whether the baseline is a likely scenario, whether the project itself is not a likely baseline scenario, and whether the baseline is complete and transparent.

B.2.1. Is the application of the methodology and the discussion and determination of the chosen baseline transparent?

Based on the past analysis date and experiment data

OK

B.2.2. Has the baseline been determined using Based on the ＦＦＢ(lowest amount in the past) OK

Page A-11


Draft3 Concl.

conservative assumptions where possible? Water regulation to confirm COD orBOD（BOD5？） Formula for Electricity Expense purchase does not reflect the monthly fixed cost which is commonly seen in Japanese electricity cost. The ground is required to show the digestion tank with the capacity of 500m3 is US$120,000.- Gas engine efficiency to confirm The ground is required to show the efficiency of methane gas power generation is 25% ～ 35%. The ground is required to show the O&M cost is 3% of total construction cost. While the income by selling the electric power generated with methane gas power generator is deemed, the income, unit price, sold amount are not shown in the project design document.

ＣＬ

ＣＬ

ＣＬ

ＣＬ

ＣＬ

ＣＬ

OK

OK

OK

OK

OK

OK

Page A-12


Draft3 Concl.

Further explanation is desired on the ground that the “average” is appropriate for the representative of the palm oil extraction ratio in the last 10 years. Further explanation is desired on the ground that 85% is appropriate or conservative for COD conversion ratio.

CL

CAR

OK

OK

B.2.3. Has the baseline been established on a project-specific basis?

ＹＥＳＯＫ

B.2.4. Does the baseline scenario sufficiently take into account relevant national and/or sectoral policies, macro-economic trends and political aspirations?

ＹＥＳＯＫ

B.2.5. Is the baseline determination compatible with the available data?

ＹＥＳＯＫ

B.2.6. Does the selected baseline represent the most likely scenario among other possible and/or discussed scenarios?

ＹＥＳＯＫ

B.2.7. Is it demonstrated/justified that the project activity itself is not a likely baseline scenario (e.g. through demonstrating investment barriers, technology barriers, barriers to prevailing practices, and/or other barriers or through quantitative evidence that the project would otherwise not be implemented)?

Decision tree and barriers ＣＬ OK

Page A-13


Draft3 Concl.

B.2.8. Have the major risks to the baseline been identified?

58 Yes. (see B.1.14) ＣＬ

OK

B.2.9. Is all literature and sources clearly referenced? CL OK

C. Duration of the Project/ Crediting Period It is assessed whether the temporary boundaries of the project are clearly defined.

C.1.1. Are the project’s starting date and operational lifetime clearly defined and reasonable?

Yes. OK

C.1.2. Is the assumed crediting time clearly defined and reasonable (renewable crediting period of max. two x 7 years or fixed crediting period of max. 10 years)?

Yes. OK

D. Monitoring Plan The monitoring plan review aims to establish whether all relevant project aspects deemed necessary to monitor and report reliable emission reductions are properly addressed ((Blue text contains requirements to be assessed for optional review of monitoring methodology prior to submission and approval by CDM EB).

D.1. Monitoring Methodology It is assessed whether the project applies an appropriate baseline methodology.

D.1.1. Is the monitoring methodology previously approved by the CDM Methodology Panel?

New methodology ＯＫ

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Draft3 Concl.

D.1.2. Is the monitoring methodology applicable for this project and is the appropriateness justified?

ＹＥＳＯＫ

D.1.3. Does the monitoring methodology reflect good monitoring and reporting practices?

ＹＥＳＯＫ

D.1.4. Is the discussion and selection of the monitoring methodology transparent?

ＹＥＳＯＫ

The below questions only apply when the validator is reviewing the monitoring methodology prior to submission to the CDM EB (Two Steps Approach):

D.1.5. Does the monitoring methodology provide for the collection and archiving of all relevant data necessary for estimation or measuring the greenhouse gas emissions within the project boundary during the crediting period?

23

22

To add flow rate of factory effluent and its COD(or BOD) to confirm within regulation. While the amount of FFB received is to be monitored in the new methodology, it is not monitored in the project design, which generates a discrepancy between the methodology and the project design.(tables)

CL

CAR

OK

CAR

(adequacy of monitoring point to counter base line and project)

To add monitoring point in monitoring flow sheet

CL OK

D.1.6. measurement of leakage No leakage OK D.1.7. Is the selected monitoring methodology

supported by the monitored and recorded data? 62

63

YES OK

( To check basic flow sheet) 61 D.1.8. Are the monitoring provisions in the monitoring

methodology consistent with the project boundaries in the baseline study?

To add operating hours/days for all processes, If required.

CL OK

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Draft3 Concl.

D.1.9. Have any needs for monitoring outside the project boundaries been evaluated and if so, included as applicable?

ＹＥＳ

OK

D.1.10. Does the monitoring methodology allow for conservative, transparent, accurate and complete calculation of the ex post GHG emissions?

Baseline:EX-ANTE Project::EX-POST conservative

OK

D.1.11. Are formulas used for calculations stated and calculations incorporated or referenced?

YES ＯＫ

D.1.12. Do the methodologies for calculating emission reductions comply with existing good practice?

YES ＯＫ

D.1.13. Is the monitoring methodology clear and user friendly?

YES ＯＫ

D.1.14. Does the methodology mitigate possible monitoring errors or uncertainties addressed?

The methodology mitigate possible monitoring errors or uncertainties addressed. The explanation of QA/QC system is not clear.

CL OK

D.1.15. monitoring of sustainabilities No indicators to monitor CL OK

D.2. Monitoring of Project Emissions It is established whether the monitoring plan provides for reliable and complete project emission data over time.

D.2.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for estimation or measuring the greenhouse gas emissions within the project boundary during the crediting period?

ＹＥＳＯＫ

D.2.2. Are the choices of project GHG indicators reasonable?

ＹＥＳＯＫ

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Draft3 Concl.

D.2.3. Will it be possible to monitor / measure the specified project GHG indicators?

ＹＥＳＯＫ

D.2.4. Will the indicators give opportunity for real measurements of achieved emission reductions?

31 step3

55

The amount of methane to estimate by using nominal engine efficiency. While it can safely be understood that the electricity generated can be monitored, it is obtained through the calculation with the factors of annual methane recovery and other factors. It sounds somewhat unrealistic.

ＣＬ

CAR

CL

CAR

D.2.5. Will the indicators enable comparison of project data and performance over time?

ＹＥＳ（to compare the amount of methane from ＰＯＭＥ based on the calculation with the amount of methane estimated by using nominal engine efficiency.

ＯＫ

D.3. Monitoring of Leakage It is assessed whether the monitoring plan provides for reliable and complete leakage data over time.

D.3.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining leakage?

ＮＯＬＥＡＫＡＧＥＯＫ

D.3.2. Have relevant indicators for GHG leakage been included?

―

D.3.3. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining leakage?

―

D.3.4. Will it be possible to monitor the specified GHG leakage indicators?

―

Page A-17


Draft3 Concl.

D.4. Monitoring of Baseline Emissions It is established whether the monitoring plan provides for reliable and complete project emission data over time.

D.4.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining baseline emissions during the crediting period?

ＹＥＳＯＫ

D.4.2. Is the choice of baseline indicators, in particular for baseline emissions, reasonable?

ＹＥＳＯＫ

D.4.3. Will it be possible to monitor the specified baseline indicators?

ＯＫ

D.5. Monitoring of Sustainable Development Indicators/ Environmental Impacts

It is checked that choices of indicators are reasonable and complete to monitor sustainable performance over time.

D.5.1. Does the monitoring plan provide the collection and archiving of relevant data concerning environmental, social and economic impacts?

No special measurement factors are not described.

ＣＬ OK

D.5.2. Is the choice of indicators for sustainability development (social, environmental, economic) reasonable?

Eg. Change of renewable energy statistic of the country.(to monitor)

ＣＬ OK

D.5.3. Will it be possible to monitor the specified sustainable development indicators?

Same as above ＣＬ OK

D.5.4. Are the sustainable development indicators in line with stated national priorities in the Host Country?

ＹＥＳＯＫ

Page A-18


Draft3 Concl.

D.6. Project Management Planning It is checked that project implementation is properly prepared for and that critical arrangements are addressed.

(D6 counted as 1CL)

D.6.1. Is the authority and responsibility of project management clearly described?

ＮＯＣＬ CL

D.6.2. Is the authority and responsibility for registration, monitoring, measurement and reporting clearly described?

ＮＯＣＬ CL

D.6.3. Are procedures identified for training of monitoring personnel?

ＮＯＣＬ CL

D.6.4. Are procedures identified for emergency preparedness for cases where emergencies can cause unintended emissions?

ＮＯＣＬ CL

D.6.5. Are procedures identified for calibration of monitoring equipment?

ＮＯＣＬ CL

D.6.6. Are procedures identified for maintenance of monitoring equipment and installations?

ＮＯＣＬ CL

D.6.7. Are procedures identified for monitoring, measurements and reporting?

Possible to use Present system ＯＫ

D.6.8. Are procedures identified for day-to-day records handling (including what records to keep, storage area of records and how to process performance documentation)

Possible to use Present system ＯＫ

D.6.9. Are procedures identified for dealing with possible monitoring data adjustments and uncertainties?

Quality Control is not clear. ＣＬ CL

D.6.10. Are procedures identified for review of reported results/data?


Page A-19


Draft3 Concl.

D.6.11. Are procedures identified for internal audits of GHG project compliance with operational requirements where applicable?


D.6.12. Are procedures identified for project performance reviews before data is submitted for verification, internally or externally?


D.6.13. Are procedures identified for corrective actions in order to provide for more accurate future monitoring and reporting?


E. Calculation of GHG Emissions by Source It is assessed whether all material GHG emission sources are addressed and how sensitivities and data uncertainties have been addressed to arrive at conservative estimates of projected emission reductions.

E.1. Predicted Project GHG Emissions The validation of predicted project GHG emissions focuses on transparency and completeness of calculations.

E.1.1. Are all aspects related to direct and indirect GHG emissions captured in the project design?

ＹＥＳＯＫ

E.1.2. Are the GHG calculations documented in a complete and transparent manner?

25

Receiving amount of FFB on is 246,555tons. And as monthly base, 20,546tons、This figure is over the design figure of Sealed Digestion tank,20,410tons.（however, excluding safety factor）

ＣＬ

OK

E.1.3. Have conservative assumptions been used to calculate project GHG emissions?

Step 2.3

28

Confirmation of water dephth. （15feet on onsite assessment）

ＣＬ

OK

Page A-20


Draft3 Concl.

Step2

31 In Charte.9, annual operating days are 300days . remained 60,or66 is not clear. Days. Operation days of production of CPO Any possibility of Sealed Digestion tank shut down and its countermeasures. (not count as CL as pointed out before)

ＣＡＲ

ＣＬ

ＣＬ

OK

OK OK

E.1.4. Are uncertainties in the GHG emissions estimates properly addressed in the documentation?

ＹＥＳＯＫ

E.1.5. Have all relevant greenhouse gases and source categories listed in Kyoto Protocol Annex A been evaluated?

ＣＯ２，ＣＨ４、Ｎ２Ｏ

No other GHGs are not present.

ＯＫ

E.2. Leakage It is assessed whether there leakage effects, i.e. change of emissions which occurs outside the project boundary and which are measurable and attributable to the project, have been properly assessed.

E.2.1. Are potential leakage effects beyond the chosen project boundaries properly identified?

ＮＯＬＥＡＫＡＧＥＯＫ

E.2.2. Have these leakage effects been properly accounted for in calculations?

―

E.2.3. Does the methodology for calculating leakage comply with existing good practice?

―

E.2.4. Are the calculations documented in a complete ―

Page A-21


Draft3 Concl.

and transparent manner? E.2.5. Have conservative assumptions been used

when calculating leakage? ―

E.2.6. Are uncertainties in the leakage estimates properly addressed?

―

E.3. Baseline Emissions The validation of predicted baseline GHG emissions focuses on transparency and completeness of calculations.

E.3.1. Have the most relevant and likely operational characteristics and baseline indicators been chosen as reference for baseline emissions?

ＹＥＳＯＫ

E.3.2. Are the baseline boundaries clearly defined and do they sufficiently cover sources and sinks for baseline emissions?

ＹＥＳＯＫ

E.3.3. Are the GHG calculations documented in a complete and transparent manner?

ＹＥＳＯＫ

E.3.4. Have conservative assumptions been used when calculating baseline emissions?

ＹＥＳＯＫ

E.3.5. Are uncertainties in the GHG emission estimates properly addressed in the documentation?

ＹＥＳＯＫ

E.3.6. Have the project baseline(s) and the project emissions been determined using the same appropriate methodology and conservative assumptions?

ＹＥＳＯＫ

Page A-22


Draft3 Concl.

E.4. Emission Reductions Validation of baseline GHG emissions will focus on methodology transparency and completeness in emission estimations.

E.4.1. Will the project result in fewer GHG emissions than the baseline scenario?

ＹＥＳＯＫ

F. Environmental Impacts Documentation on the analysis of the environmental impacts will be assessed, and if deemed significant, an EIA should be provided to the validator.

Environmenta Impacts assessment is not required.

F.1.1. Has an analysis of the environmental impacts of the project activity been sufficiently described?

―

F.1.2. Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, is an EIA approved?

―

F.1.3. Will the project create any adverse environmental effects?

―

F.1.4. Are transboundary environmental impacts considered in the analysis?

―

F.1.5. Have identified environmental impacts been addressed in the project design?

―

F.1.6. Does the project comply with environmental legislation in the host country?

―

Page A-23


Draft3 Concl.

G. Stakeholder Comments The validator should ensure that a stakeholder comments have been invited and that due account has been taken of any comments received.

At present no action is taken into account.

G.1.1. Have relevant stakeholders been consulted? ―

G.1.2. Have appropriate media been used to invite comments by local stakeholders?

―

G.1.3. If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws?

―

G.1.4. Is a summary of the stakeholder comments received provided?

―

G.1.5. Has due account been taken of any stakeholder comments received?

―

G.1.6. G.1.7.

Page A-24

Table 3 Resolution of Corrective Action and Clarification Requests Draft report clarifications and corrective

action requests by validation team Ref. To checklist

question in table 2Summary of project owner response Validation team conclusion

CAR 1. Origin of emission factors in Chart E.11 and its reasonableness Origin of Methane concentration

B1.7 Project Owner Response Showed the evidence and will be mentioned in final PDD.

Validation Team Response Agreed. Validation Team Conclusion.

CAR 2 Operating time of gas engine with number of start up to calculate the amount of emission

B1.7 Project Owner Response To add the operating time in monitoring.


CAR 3 Electricty to grid : average distribution losses are not considered.

B1.7 Project Owner Response To modify the equation to take the distribution into account according to the site situation.


CAR4 Decision tree more accurately (to refer additional paper)

B1.13 Project Owner Response To revise it as reasonable.


CAR5 B1.14 Project Owner Response Reasonable explaination will be described in final

Validation Team Response Agreed.

Page A-25

Draft report clarifications and corrective action requests by validation team

Ref. To checklist question in table 2

Summary of project owner response Validation team conclusion

Weight measurement of FFB in rain Correction is required

PDD as FFB weight with/without rain waters will be equalized.

Validation Team Conclusion.

CAR6 Further explanation is desired on the ground that 85% is appropriate or conservative for COD conversion ratio.

B 2.2 Project Owner Response To explain with literatures and experiment data

researched by MPOB.

Validation Team Response .agreed Validation Team Conclusion.

CAR7 In Charte.9, annual operating days are 300days . remained 60,or66 is not clear.

E 1.3 Project Owner Response 1dday a week , plant shuts down and 5or 6days

are required for maintenance of gas engine. To explain precisely in PDD.

Validation Team Response agreed Validation Team Conclusion.

CL 1 It needs clarified what happens to the methane gas emitted in case the gas engine unintentionally should stop or the sealed digention tank should be shut..

A2.3 Project Owner Response Flare system will be considered to avoid the methane release when processes shut down or other reasons.


CL 2 Estimation of annual FFB generation/CPO extraction need clearer explanation. The maximum input (receiving) of FFB and the minimum input (receiving) of FFB are estimated, but it is not explained how they are calculated.

B1.3 Project Owner Response Explanation will be described in final PDD.


Page A-26




CL3 Difference of anaerobic open lagoon and Sealed Digestion Tank is COD concentration of treated water to aerobic lagoon. Water depth of aerobic lagoon more than 3m. Methane is produced to some extent according to the COD concentration.

B1.11 Project Owner Response To check again it wether this should be added or not.


CL4 Experiment report to support the methane concentration

B.1.12 Project Owner Response To include the information.


CL5 Transportation of FFB Over production of CPO due to the demands of Palm oil. Naturally the amount of incoming shipment of FFBs fluctuate annually. The fluctuation stays the same in the baseline scenario and in the project scenario. But if more FFBs should be shipped in than the maximum capacity of the digestion tanks in the project, the shipment of the excessive FFBs is thought to

B1.14 Project Owner Response To explain that there is no difference between the FFB in baseline and in project .


Page A-27




generate GHG emission during transportation. The possibility of the excessive receiving of FFBs is not discussed in the project design. As stated in the project design document, if no increase of transportation of FFB is expected, this item is cleared. CL6 Additives into Sealed Digestion (transportation of additives etc.)

B1.14 Project Owner Response Sodium Hydroxide is used as additive, then to check the amount and GHGs related to it.


CL7 ＦＦＢ:clear explanation is necessary. ＣＰＯ: variables?

Clear explanation is necessary.Temperature: variables (or need the deviation of ±)

B1.15 Project Owner Response To explain clearly how to calculate.


CL8 Water regulation to confirm COD orBOD（BOD5？） Formula for Electricity Expense purchase does not reflect the monthly

B 2.2 Project Owner Response To explain all CL points relating to the design figure


Page A-28




fixed cost which is commonly seen in Japanese electricity cost. The ground is required to show the digestion tank with the capacity of 500m3 is US$120,000.- Gas engine efficiency to confirm The ground is required to show the efficiency of methane gas power generation is 25% ～ 35%. The ground is required to show the O&M cost is 3% of total construction cost. CL9 While the income by selling the electric power generated with methane gas power generator is deemed, the income, unit price, sold amount are not shown in the project design document.

B 2.2 Project Owner Response Data was missed to write and will revise.


CL10 B 2.2 Project Owner Response


Page A-29




Further explanation is desired on the ground that the “average” is appropriate for the representative of the palm oil extraction ratio in the last 10 years.

Validation Team Conclusion.

CL11 To add flow rate of factory effluent and its COD(or BOD) to confirm within regulation.

D.1.5 Project Owner Response To add the monitoring data


CL12 To add operating hours/days for all processes, If required

D 1.8 Project Owner Response To check the necessity to record it separately as by checking the operation records notes intended to use.


CL13 The methodology mitigate possible monitoring errors or uncertainties addressed. The explanation of QA/QC system is not clear

D 1.14 Project Owner Response To explain clearer.


CL14 No indicators to monitor

D 1.15 Project Owner Response To check employee numbers as social sustainability monitoring point.

Validation Team Response Agreed. Validation Team Conclusion

Page A-30




CL15 Receiving amount of FFB on is 246,555tons. And as monthly base, 20,546tons、This figure is over the design figure of Sealed Digestion tank,20,410tons.（however, excluding safety factor）

E 1.2 Project Owner Response To reconsider the design figure to meet the FFB treatment requirement.


CL16 Confirmation of water dephth. （15feet on onsite assessment）

E 1.3 Project Owner Response To confirm with drawing of Lagoons. And comfirmed.


CL17

Project Owner Response


CL18

Project Owner Response
