lbk_finalvalidationreport

RINA

VALIDATION REPORT

CDM SSC Validation Report 2009 IQ ME 10, rev. 02 FORM: CDM_SCC_VAL_REP-02-09

“Wind Power Project in

Maharashtra by M/s L. B. Kunjir Engineers & Contractors”

in India

REPORT NO. 2009 IQ ME 10 REVISION NO. 02

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CDM SSC Validation Report 2009 IQ ME 10, rev. 02 2 FORM: CDM_SCC_VAL_REP-02-09

Project Name: Country: Estimated CERs (tCO2e):“Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors”

India 21,290 tCO2e over ten years

Client: Client contact:

M/s L. B. Kunjir Mr. Amit Kunjir Report title: Report No.: Rev. No. Date of this report: “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors” in India

2009 IQ ME 10

02 26 March 2010

Approved by: (Final Report – DCI Director approval) Organizational Unit: Date:

Roberto Cavanna DCI 26 March 2010

Methodology Reference: Version: Title: Sectoral Scope:

AMS-I.D Version 13 of 14 December 2007

“Grid connected renewable electricity generation”

01

RINA performed a validation of the CDM project activity “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors” 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 modalities and procedures, the simplified modalities and procedures for small-scale CDM project activities, the subsequent decisions by the CDM Executive Board and the Host country criteria. The validation consisted of the following three phases: i) a desk review of the project design documents, ii) follow-up interviews with project stakeholders and iii) the resolution of outstanding issues and the issuance of the final validation report and opinion.. Five Corrective Action Requests (CAR’s) and eight requests for Clarification (CL’s) have been identified. Upon the satisfactory resolution of these CAR’s and CL’s presented in this report. In summary, it is RINA’s opinion that the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors” in India, as described in the PDD version 02 dated 06/02/2010meets all relevant UNFCCC requirements for the CDM and all relevant host country criteria and correctly applies the baseline and monitoring AMS I.D, Version 13. RINA thus requests the registration of the project as a CDM project activity.

Work carried out by: Michela Gallo, Shivraj Sharma, Rekha Menon, Dhanya Nambiar.

No distribution without permission from the Client or responsible organizational unit

Strictly confidential

Unrestricted distribution

Work verified by: (CRT Responsible approval) Keywords:

Paolo Teramo Climate Change, Kyoto Protocol, Validation, Clean Development

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VALIDATION REPORT

CDM SSC Validation Report No. 2009 IQ ME 10, rev. 02 3 FORM: CDM_SCC_VAL_REP-02-09

Abbreviations Explain any abbreviations that have been used in the report here. CAR Corrective Action Request CDM Clean Development Mechanism CL Clarification Request CER(s) Certified Emission Reduction(s) CH4 Methane CO2 Carbon dioxide CO2e Carbon dioxide equivalent DNA Designated National Authority EB Executive Board FAR Forward Action Request GHG Greenhouse gas(es) GoI Government of India GWh Giga Watt Hour IPCC Intergovernmental Panel on Climate Change IRR Internal Rate Return JMR Joint Meter Reading kWh Kilo Watt Hour LBK M/s L. B Kunjir MEDA Maharashtra Energy Development Agency MERC Maharashtra Electricity Regulatory Commission MoEF Ministry of Environment & Forest MP Monitoring Plan MSEB Maharashtra State Electricity Board MSEDCL Maharashtra State Electricity Distribution Co. Ltd. MW Mega Watt ODA Official Development Assistance O&M Operation and Maintenance PDD Project Design Document PLF Plant Load Factor RBI Reserve Bank of India RINA RINA Services Spa NEWNE Northern Eastern Western North-Eastern Regional Grid UNFCCC United Nations Framework Convention on Climate Change WEG Wind Energy Generators WEPA Wind Energy Purchase Agreement

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Table of Contents Page

1. INTRODUCTION ....................................................................................................... 5 1.1. Objective 5 1.2. Scope 5 1.3. GHG Project Description 6

2 METHODOLOGY....................................................................................................... 6 2.1 Review of Documents 9 2.2 Follow-up Interviews 9 2.3 Resolution of Clarification and Corrective Action Requests 9

3 VALIDATION FINDINGS ....................................................................................... 10 3.1 Project Design 10 3.2 Baseline 10 3.3 Monitoring Plan 12 3.4 Calculation of GHG Emissions 23 3.5 Environmental Impacts 24 3.6 Comments by Local Stakeholders 24

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS .............................. 24

5 VALIDATION OPINION ......................................................................................... 25

6 REFERENCES........................................................................................................... 26

Appendix A: Validation Protocol

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CDM SSC Validation Report No. 2009 IQ ME 10, rev. 02Error! Reference source not found. 5 FORM: CDM_SCC_VAL_REP-02-09

1. INTRODUCTION The Client - M/s L. B. Kunjir has commissioned RINA to perform a validation of the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors” in Error! Reference source not found. (hereafter called “the project”). This report summarizes the findings of the validation of the project, performed 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 modalities and procedures, the simplified modalities and procedures for small-scale CDM project activities and the subsequent decisions by the CDM Executive Board.

The following team/technical review personnel performed this validation: Role/Qualification Last Name First Name CountryTeam leader, CDM validator Gallo Michela Italy CDM Validator Sharma Shivraj India CDM Validator Menon Rekha India Technical Expert CDM Nambiar Dhanya India Technical Reviewer Teramo Paolo Italy Technical Reviewer Valoroso Rita Italy

The validation report, including the initial validation findings, underwent a technical review before being submitted for registration. The technical review was performed by the technical reviewer qualified in accordance with RINA’s qualification scheme for CDM validation and verification.

1.1. Objective The purpose of a validation is to have an independent third party assessment of the project design. In particular, the project's baseline, monitoring plan, and the project’s compliance with relevant UNFCCC and host Party criteria are validated in order to confirm that the project design, as documented, is sound and reasonable and meets the 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).

1.2. Scope The validation scope is defined as an independent and objective review of the project design document (PDD). The PDD is reviewed against the criteria stated in Article 12 of the Kyoto Protocol, the CDM modalities and procedures as agreed in the Marrakech Accords, the simplified modalities and procedures for small-scale CDM project activities and the relevant decisions by the CDM Executive Board, including the approved baseline and monitoring methodology AMS-I.D version 13 /05/. The validation team based on the recommendations in the CDM Validation and Verification Manual (hereinafter referred as the VVM) /03/ employed a risk-based approach, focusing on the identification of significant risks for project implementation and the generation of CERs.

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The validation is not meant to provide any consulting towards the project participants. However, stated requests for clarifications and/or corrective actions may have provided input for improvement of the project design.

1.3. GHG Project Description The proposed CDM small-scale project activity is a renewable energy (wind energy) power generation project that is located at Adwadi site of Sinnar taluka, Nashik district, Maharashtra, India. The project consists of a wind energy generator (WEG) with the capacity of 1.5 MW to generate electricity and supply the same to the Northern Eastern Western North-Eastern Regional Grid (NEWNE). Emission reductions are claimed from displacing the grid electricity supplied to the NEWNE grid. The project is expected to reduce CO2 emissions to the extent of 21,290 tCO2e (2,129 tCO2e / year average) over the fixed 10 years crediting period, with an expected operational lifetime of 20 years /1/.

2 METHODOLOGY The validation may consist of the following three phases:

i) a desk review of the project design documentation ii) follow-up interviews with project stakeholders

iii) resolution of outstanding issues and the issuance of the final validation report and opinion.

In order to ensure transparency, a validation protocol was customized for the project, according to the Validation and Verification Manual /3/. 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 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 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. Findings established during the validation can either be seen as a non-fulfillment of validation protocol criteria or where a risk to the fulfillment of project objectives is identified. Corrective Action Requests (CAR) are issued, where: • mistakes have been made with a direct influence on project results; • validation protocol requirements have not been met; or • 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 also used the term Clarification Request (CL), where: • additional information is needed to fully clarify an issue.

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A forward action request (FAR) is raised during validation to highlight issues related to project implementation that require review during the firs verification of the project activity. FAR shall not relate to the CDM requirements for registration.

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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 and 3 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 organized 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 Request is used when the validation team has identified a need for further clarification. A Forward Action Request (FAR) shall be raised during validation to highlight issues related to project implementation that require review during the first verification of the project activity.

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 summarized in this section.

This section should summaries 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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2.1 Review of Documents The Project Design Document (PDD) /1/, Version 00 of 10 March 200 submitted by the project participant M/s L. B. Kunjir and additional background documents (/2/ to /40/) related to the project design and baseline were assessed by RINA. To address RINA Certification corrective action and clarification requests, M/s. L.B. Kunjir revised the PDD and resubmitted it on February 2010. The validation findings presented in this report relate to the project as described in the PDD Version 02 Dated 06 February 2010. This latest version of the PDD is as per the template and complies with the latest guidelines for completing the simplified project design document.

2.2 Follow-up Interviews On 09 June 2009, RINA performed site visit and interviews with project stakeholders (/41/ to /43/) to confirm selected information and to resolve issues identified in the document review. Representatives of M/s L. B. Kunjir, MITCON Consultancy Services Ltd and Suzlon Energy Limited were interviewed. The main topics of the interviews are summarized in table below:

Table 1 Interview topics Interviewed organization Interview topics

Representatives from M/s L. B. Kunjir MITCON Consultancy Services Ltd, Suzlon Energy Limited

- Clarifications on establishment of baseline, monitoring plan and emission reduction calculations

- Sources utilized to calculate the financial calculations - Monitoring Plan / Records (backups) - Maintenance program (calibration) - Project boundaries - Baseline emissions - Emissions reductions calculations

2.3 Resolution of Clarification and Corrective Action Requests The objective of this phase of the validation is to resolve any outstanding issues, which need to be clarified for RINA's positive conclusion on the project design.

The initial validation of the Project resulted in five (05) Corrective Action Requests and eight (08) Clarification Requests. Project participant was invited to respond to RINA’s Clarification and Corrective Action Requests and include their response in Table 3 of the validation protocol, in Appendix A.

To guarantee the transparency of the validation process, the concerns raised are summarized in chapter 3 below and documented in more detail in the validation protocol in Appendix A.

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3 VALIDATION FINDINGS The findings of the validation are stated in the following sections.

The findings from the desk review of the original project design documents and the findings from interviews during the follow up visit are summarized. A more detailed record of these findings can be found in the Validation Protocol in Appendix A.

Where RINA identified issues that need clarification or that could represent risk to the fulfillment of project objectives, Clarification or Corrective Action Requests, respectively, have been issued. The Clarification and Corrective Action Requests are documented in Validation Protocol in Appendix-A.

The initial validation findings in the protocol in Appendix A relate to the project design as documented and described in the CDM-SSC-PDD for the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors”, Version 00 dated 10 March 2009 /1/.

The validation findings presented in this report relate to the project as described in the PDD Version 02 Dated 06 February 2010. The conclusions of the validation finding as required by the CDM Validation and Verification Manual, version 1.1are presented as below.

3.1 Project Design The project activity aims to reduce the GHG emission by installing a 1.5 MW WEG in Nashik District of Maharashtra thereby generating electricity from a renewable source. The project will generate 2.628 GWh power and will export it to the NEWNE regional grid of India. The estimated GHG reduction is of 2,129 tCO2e per annum for fixed crediting period of ten years./1/

The project activity has installed one WEG of 1.5 MW, Suzlon make and is located at Survey no. 134, Adwadi site, Sinnar Taluka, Nashik district of Maharashtra state /7/. Its geographical co-ordinates are 21021’57.31”N & 74014’32.09”E.

Approvals Paragraph 44-50 and paragraph 124-126, VVM, Version 1.1

The project participant is M/s L. B. Kunjir from India. The DNA of India has issued the Letter of Approval (LoA) on 29 June 2009 authorizing M/s L. B. Kunjir as a project participant confirming voluntary participation and that the project will contribute to sustainable development for the host country. The LoA issued by the DNA of India has been verified by RINA receiving the copy approval letter from the project participants directly and refer to the précised project activity in the PDD /2/. RINA has been further verified the authenticity of the approval from the website of DNA of India (http://cdmindia.nic.in/cdm_india.htm). The website confirms approval of this project by DNA under project ID no: 1471-08. The LoA does not refer to a specific version of the PDD or validation report and the DNA has not imposed any specific condition for the project participant. By checking the above documents RINA considers the letter of approval in accordance with paragraphs 45 – 48 of VVM version 1.1 and confirms that corresponding references included to LoA, PDD and validation report are consistent.

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The project is owned by M/s L. B. Kunjir and does not involve any public funding, and the validation did not reveal any indication that the project can be seen as a diversion of official development assistance (ODA).

Participation: Paragraph 51-54, VVM, Version 1.1

The project participant is M/s L. B. Kunjir; the project is unilateral project and hence India is the only Party involved in the project activity at this stage and is the host party and the relevant DNA. The host Party India fulfills the participation requirements, having ratified the Kyoto protocol on the 26 August 2002 and established the National Clean Development Mechanism Authority, Ministry of Environment and Forest (MoEF) as its DNA. RINA verified the information provided about the party and PP involved by referring to PDD and LoA and confirms that the information is consistent in section A.3, Annex 1of PDD and in LoA.

Project Design Document: Paragraph 55-57, VVM, Version 1.1

The PDD for the project Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors version 00 of 06 February 2010 and previous versions submitted by the project participant have been the basis for the validation process. By checking both the versions of the PDD submitted, RINA confirms that they are in accordance with the applicable CDM requirements for completing the Simplified Project Design document (CDM-SCC-PDD), version 05. .

Project Description: Paragraph 58-64, VVM, Version 1.1

The technical design given in the PDD is consistent with the actual planning and implementation of the project activity. The validation team confirmed the installation, make and capacity through personal inspection of the WEG during site visit and cross verifying with the purchase order /6/, commissioning certificate /8/ /10/, land deed document /7/, wind energy purchase agreement with the state utility /26/. The latitude and longitude for the WEGs locations said in the PDD were also cross checked by the validation team through google map and found them to be correct and appropriate. The technology used in the project activity is Suzlon’s four poles - asynchronous wind generator controlled by microprocessor which is environmentally safe and sound, since no GHG emissions are associated with the electricity generation using windmills /1/.Hence there is no technology involved in this project activity. This technology is utilized in India extensively and have been implemented which reflects good practices followed in India. The project is not a de-bundled component of a large project activity as there is no registered small-scale CDM project activity or an application to register another small-scale CDM project activity with the same project participants in the same project category and technology/measure within the previous two years and whose project boundary is within 1 km of the project boundary of the proposed small-scale project activity at the closest point. During site visit, the validation team found that the WEG was commissioned on 30 March 2009 /8/.

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The validation team confirm that the project description said in the latest version of the PDD is accurate, complete and as at site.

Project start date: The start date of the project activity is 18 December 2008 /6/, which is the date of placing the purchase order towards Suzlon make WEG. It has been verified by RINA representing the earliest date at which either the implementation or construction or real action of the project activity begin. RINA confirms that the starting date of the proposed project activity is in line with the CDM Glossary Terms. The operational life of the project is expected to be 20 years as the same was evidenced in the purchase order and technical specification of Wind Turbine Generator provided by Suzlon Energy Limited /16/.

RINA was able to cross check all the documented evidences listed above during the validation process and can confirm that the data and consideration are complete and accurate.

3.2 Baseline The project correctly applies the approved consolidate baseline and monitoring methodology AMS I.D version 13 /5/ “Grid connected renewable electricity generation”.

Applicability of the methodology selected: Paragraph 68-76, VVM, Version 1.1

The project activity meets the applicability criteria expected in the baseline methodology as it ensure:

1. The project is renewable energy generation project with wind power, supplying electricity to NEWNE Grid, where major part of the electricity comes from non renewable electricity generation.

2. There is no combination of renewable and non renewable component in this project activity

3. The project activity does not involve combined heat and power (co-generation) systems

4. The project activity does not involve the addition of renewable energy generation units at an existing renewable power generation facility,

5. The project activity does not seek to retrofit or modify an existing facility for renewable energy generation.

The project capacity is 1.5 MW, well below the limit of 15 MW and falls under the small scale category I.D as per the Appendix B. RINA confirms the capacity by verifying the commissioning certificate /8/ , Energy Purchase agreement /26/ and onsite visit.

As this is a windmill project, there are no likely emission sources, which are not addressed by the applied methodology, and are expected to contribute more than 1% of the overall expected average annual emission reductions.

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Project boundary Paragraph 77-79, VVM, Version 1.1

The project is located in the state of Maharashtra, which is a part of NEWNE grid. Hence the baseline determination is appropriately done considering the NEWNE grid. The project boundary encompasses the physical, geographical site of renewable generation source and includes wind turbines installation, pooling and Maharashtra Electricity Distribution Corporation Limited (MSEDCL) sub-stations. It was verified that the wind turbine is new and connected to the NEWNE grid and there is no transfer of equipment to or from other project activity. Hence, no leakage has been considered for this project activity. Site visit observations, commissioning certificates and land deed agreements are verified to confirm the project boundary. The validation team confirms that the identified boundary, the selected sources, and gases as documented in the PDD are justified and appropriate for the project activity.

GHGs

involved Description

Baseline emissions CO2 Emissions from net electricity displaced from the grid based on fossil fuel power plant

Project emissions / No project emissions are envisaged in the project activity since it is Wind Energy based power generation project.

Leakage / There no leakages that needs to be considered in applying this methodology.

Baseline Identification Paragraph 80-87, VVM, Version 1.1

According to the applied methodology AMS-I.D, version 13, the baseline is defined as the kWh produced by the renewable generating unit multiplied by an emission coefficient (measured in kg CO2e/kWh) calculated in a transparent and conservative manner. The PP has considered the baseline in line with what is prescribed by the methodology. As per the methodology point no. 9, baseline is the kWh produced by the renewable generating units multiplied by an emission co-efficient calculated in a transparent and conservative manner. Since the approved methodology applied prescribes the baseline scenario, according to paragraph 104 of the VVM version 01.1 no further analysis is required /3/. The baseline emissions have been calculated according to the approved methodology where the net energy supplied to the grid by renewable generating unit is multiplied with the carbon emission factor for the displaced grid electricity.

The baseline is the kWh produced by the renewable generating unit multiplied by an emission coefficient (measured in kg CO2e/kWh) calculated as the weighted average emissions (in tCO2 eq/ MWh) of the current generation mix. The data of the year in which project generation occurs must be used. In line with the methodology, the weighted average emissions emission factor for NEWNE of India has been calculated to be 0.810 tCO2/MWh, the emission factor has been

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sourced from Central Electricity Authority Database “CO2 baseline data base for the Indian Power sector User guide – Version 4.0 Data base” /15/. This was accepted by the validation team as the CEA data base, version 04 was the latest available to the project participant at the time of PDD submission for validation.

Additionality: As per the Attachment A to Appendix B of simplified modalities of small-scale projects, the project additionality has been demonstrated applying the investment barriers.

Prior consideration of CDM Paragraph 97-103 VVM, Version 1.1 The starting date of the project activity is 18 December 2008, which is the date of purchase order for supply and commissioning of non conventional energy generation project from M/s L. B. Kunjir to Suzlon Energy Ltd. /6/. It has been verified by RINA representing the earliest date at which either the implementation or construction or real action of the project activity begin. RINA confirms that the starting date of the proposed project activity is in line with the CDM Glossary Terms. Since the project starting date is 18 December 2008, which is after 02 August 2008 and before the global stakeholder’s comments started on 27 March 2009, as per the Guidance on the demonstration and assessment of prior consideration of the CDM (EB 41, Annex-46) project participant has informed UNFCCC about the project activity and their intention to seek CDM status. The validation team has verified the same from UNFCCC website (http://cdm.unfccc.int/Projects/PriorCDM/notifications/index_html), and communications dated 06 January 2009 /22/. It is evident that the project participant has informed UNFCCC secretariat about the project activity as required by the guidance. The extract of note by the partners of M/s L. B. Kunjir, dated 17 December 2008 has been verified /21/. From partner’s note and the IRR sheet submitted by the PP to the validation team, it is observed that the benefits of CDM were a decisive factor in the decision to proceed with the project activity. For assessing the decisiveness, the validation team also looked for the communication related with the project. PP had approached an independent Chartered Accountant /19/ to assess the project feasibility wherein it was evident that CDM benefit was considered to assess the feasibility/20/. This has given confidence to the validation team to conclude that the project participant was aware of CDM much before the start of the project activity and CDM was seriously considered in the decision to implement the project activity.

The proponent has provided chronology of events in the PDD from conceptualization of the project activity till appointing RINA for validation. The validation team verified the evidences for all the events listed in the chronology. It is evident that the PP has initiated real action in parallel to the implementation of the project activity. Appointment of CDM consultant on 23 December 2008 /35/, intimation to UNFCCC on 06 January 2009 /22/, stakeholders consultation on 21 February 2009 /12/ /13/ and webhosting of the PDD on UNFCCC interface (http://cdm.unfccc.int/Projects/Validation/DB/LBEZJ4643SYTD4BSAEWDD005YI7B7C/view.html)on 27 March 2009 were completed even before the commissioning of the WEG on 30 March 2009 /8/. As such it is imperative that real actions were taken by the PP to secure CDM status for the project in parallel to its implementation.

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Thus the validation team confirms that the PP was aware of CDM prior to the start of the project activity, that CDM was a decisive factor to go-ahead with the project activity and that the PP has taken real actions to secure CDM status in parallel to the implementation of the project activity.

Identification of alternatives Paragraph 104-106, VVM, Version 1.1

As per paragraph 9 of the selected methodology AMS-I.D, version 13, the baseline is defined as the kWh produced by the renewable generating unit multiplied by an emission calculated in a transparent and conservative manner. The project participant also considered the baseline in line with what is prescribed by the methodology. Since the approved methodology applied prescribes the baseline scenario, according to paragraph 104 of the VVM version 01.1 no further analysis is required..

Investment analysis: Paragraph 107-113, VVM, Version 1.1

The PP has selected investment analysis to demonstrate that the financial returns of the project are insufficient to justify the investment. The project cannot apply simple cost analysis and investment comparison analaysis since the project brings in additional revenues from the sale of electricity and no alternatives are considered in the baseline. Hence the PP applied the benchmark analysis.

The PP uses the project IRR after tax (calculated for a period of 20 years i.e. equivalent to lifetime of the project) /14/ /17/ /20/as a basis to assess the financial attractiveness of the project activity. The PP has chosen RBI Prime Lending Rate as the benchmark available on December 2008 and so valid at the time of the investment decision was made, and it was in range of 12.75 to 14.00 % . The PP has chosen to refer to the average of the two rates, the 13.30 % was considered as the benchmark /33/. The validation team assessed the appropriateness of this benchmark chosen by the PP by referring to the link provided and noted that the same is representative to the month of July 2008. The validation team cross verified the weekly reports available at the RBI site to note that the PLR as at the month of November in the published report dated 12/12/2008 refers to a range of 13.00% to 13.50% (http://www.rbi.org.in/scripts/WSSView.aspx?Id=13042). The value chosen by the PP being conservative, the validation team accepted 12.75 % benchmark chosen by the PP.

As per paragraph 110, VVM, Version 1.1, Annex 3, EB 51 /3/, the validation team reviewed the financial worksheets and noted that all the cells in the excel sheet are transparent without any blocking of the cells and the formulae used for the computations are transparent. The calculations are reproducible and found to be correct. All documents pertaining to the source of input values presented in the analysis have been verified by RINA from the following documents:

Contracts for supply of the equipments /6/

Contracts for Erection and commissioning /6/

Contracts for Maintenance, Service and availability /28/

Loan Sanction letter from Bank of Baroda /23/

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Letter from Bank of Baroda on PLF selection /24/

Tariff as per MERC order /36/ and Wind Energy Purchase Order /26/

Written confirmation from the independent chartered accountant on profitability & cash flow statement along with assumptions supporting the calculation for the project activity in support to the financial calculation sheet

The validation team validated the assumptions in the investment analysis as follows :

Parameter, Value

Source of information Validation justification

Project cost:

INR 90.00 Million

Offer letter and purchase order with Suzlon Energy Ltd /6/.

Reflects realistic values and therefore eliminates ambiguity and need for sensitivity. Since the date of decision (17 December 2008), offer letter (16 December 2008) and the purchase order date (18 December 2008) are very close, it can be agreed that the value was reasonably known at the time of decision.

Hence this is identified as a parameter for sensitivity analysis.

Cost of wind mills:

INR 55.20 Million

Offer Letter and Purchase order with Suzlon Energy Ltd /6/.

Reflects realistic values and therefore eliminates ambiguity and need for sensitivity. Since the date of decision and the purchase order date are very close, it can be agreed that the value was reasonably known at the time of decision. The validation team noted that the cost incurred by the PP for the WEG is the same as that taken for financial analysis.

Debt-equity ratio:

71:29

Investment pattern in last three years, loan sanction letter dated 22 August 2007 /37/.

Debt-equity ratio has been considered according to their investment pattern in last three years, which is as per the guideline provided in point no. 11, “Guidelines On The Assessment Of Investment Analysis”, Version 03, Annex 58, EB 51.

The same was verified by the validation team through loans taken by the PP in the last three years span from which it was noticed that the PP had only one loan availed for the procurement of vehicles and is at 71:29 debt-equity ratio. Hence the Debt-equity ratio of 71:29 is accepted.

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Project Capacity:

1.5 MW

Offer Letter, Purchase order /6/ and commissioning certificate /8/

Self explanatory

Number of machines: 1

Offer Letter, Purchase order /6/ and commissioning certificate /8/

Self explanatory

PLF:

20.00 %

Project Feasibility Assessment /20/, MERC order /36/, Bank letter on PLF while applying for loan /24/ and Installation and electricity generation data for the year 2008-09 at Sinnar site published by Maharashtra Energy Development Agency (MEDA) /39/

Project feasibility assessment was carried out by an independent Chartered Accountant and based on that the PP had applied for the loan from Bank of Baroda. According to the assessment the PLF considered was 20 % based on the Maharashtra Electricity Regulatory Commission. The PLF has been sourced by the loan application and a letter from the Chief Manager, Bank of Baroda (No. Gultek/ADV/09/07) stating that the PP has applied for loan to them considering a PLF of 20%.

The same has been verified as per “Guidelines for the Reporting and Validation of Plant Load Factors”, Annex 11, EB 41. The validation team was provided with a letter from the bank stating that 20 % PLF was considered while applying for loan for the project activity.

PP has also submitted the publically available data for the Sinnar Taluka site /39/ wherein machines commissioned for the year 2008-09 has been compiled and provided for verification. According to the publically available data available from the Maharashtra Energy Development Agency, the total installed capacity in Sinnar region was 34.50 MW, the net generation was 40187.70 MW and the average PLF achieved was 13.30%. This generation has been achieved by same type S-82 WEGs of Suzlon make. The validation team checked the source and the data provided.

Since the PLF was provided to banks for project financing, and the Loan Bank was

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approved by Bank of Baroda on 06 March 2009 based on the above PLF, RINA confirms that the assumption of PLF is in line with the EB 48 Annex 11. Moreover, by checking the above evidence, RINA considers it as a credible source /23/.

Project participant has identified this as a parameter for sensitivity analysis.

O&M cost from 2nd year:

INR 1.55 Million

Offer letter from the Suzlon Energy Limited /6/

As per the EB guidance “Guidelines on the Assessment of Investment Analysis”“, Version 03, Point no. 6, Annex 58, EB 51, the PP had considered the value available to him to compute the investment returns.

Escalation in O&M cost:

5% annually after 2nd year.

Offer letter from the Suzlon Energy Limited /6/

This value has been taken as per the best offer provided by the supplier subsequent to negotiations by the PP and available at the time of decision making. Hence it is accepted.

PP has also identified operation and maintenance charges as a parameter for sensitivity analysis.

Tariff:

INR 3.50/kWh with escalation of INR 0.15/kWh till 13th year

Project Feasibility Assessment /20/, MERC tariff order /36/ cross compared in WEPA /26/

Wind Energy Purchase Agreement Tariff order from MERC confirms the tariff considering the lifetime of 13 years (Point no. 1.6.3 dated 24 November 2003) /36/ According to the WEPA the tariff has been set with escalation of INR 0.15 annually till thirteenth year. As per the point 1.4.2 of the 24 November 2003 MERC order, it has been clearly indicated that the tariff after the 13th year would be cheaper since the debt related expenditure should have been over by the 10th year.

As per the MERC order, projects were divided into three types:

Group I: Projects, which were commissioned before 27 December 1999.

Group II: Projects, which were commissioned after 27 December 1999 and before 01 April 2003.

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Group III: Projects, which were commissioned after 01 April 2003.

The validation team assessed the same and also observed that there are no projects from Group III who have reached the 13th year stage. It was also observed from the MERC order dated 20 November 2007 that PP should consider only O&M cost and Incidental cost for tariff after the tenure is over for group II.

Since the PP has taken the base price of INR 3.50 per kWh with escalation of INR 0.15 annually up to the 13th year and then on capped the price for the rest of the period, this is conservative and hence accepted by the validation team.

PP has identified tariff as a parameter for sensitivity analysis

Loan:

INR 63.9 million

Project Feasibility Assessment /20/, Project cost and Debt-Equity ratio based on loan sanction letter dated 22 August 2007 /37/.

Self explanatory

Interest on term loan:

12.25%

Project Feasibility Assessment /20/, Project cost and Debt-Equity ratio based on loan sanction letter dated 22 August 2007 /37/.

Self explanatory

However, the actual interest is 12.50 % as verified by the validation team from loan sanction letter /23/.

Loan tenure:

60 Months

Loan document of earlier investment for vehicle /37/

Consistent with basis for loan tenure as it is used to compute the financial viability of the project as per the guidance from EB and is cross verified with the loan letter dated 22 August 2007.

Loan moratorium:

1 month

Loan document of earlier investment for vehicle /37/

Consistent with basis for loan tenure as it is used to compute the financial viability of the project as per the guidance from EB and is cross verified with the loan letter dated 22 August 2007.

CER price:

Euro 21/CER

Assumed by PP, cross checked with the link provided

The link was posted on 04 September 2008 while indicating the expected CER price for

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the month of December 2008. This value is applicable as on the decision making date hence accepted.

Baseline EF:

0.810 tCO2/MWh per year

PDD /1/, CER calculation spreadsheet /34/

As explained above the Weighted Average Emission Factor has been taken as per the guidance of the approved methodology.

Benchmark, 12.75% PLR

PLR published by RBI /33/ as in http://rbi.org.in/scripts/PublicationsView.aspx?id=10292

and http://www.rbi.org.in/scripts/WSSView.aspx?Id=13042

Official data published by the central governing bank, i.e. Reserve Bank of India for the period relevant to the date of decision.

The validation team assessed the appropriateness of this benchmark chosen by the PP by referring to the link provided and noted that the same is representative to the month of July 2008. The validation team cross verified the weekly reports available at the RBI site to note that the PLR as at the month of November in the published report dated 12/12/2008 refers to a range of 13.00% to 13.50% (http://www.rbi.org.in/scripts/WSSView.aspx?Id=13042). The value chosen by the PP being conservative, the validation team accepted 12.75 % benchmark chosen by the PP.

The validation team validated the assumptions as above and observed that they are in order. The financial expert verified the IRR calculations and observed them to be in order.

The financial expert and the validation team hereby confirm that project participant has applied all the statutory levies and taxes as per valid rules. Project participant has also applied incentives like accelerated depreciation and provisions of section 80IA [deferred tax benefit] as per Indian Income Tax Act1 /38/. However, since the project activity does not generate sufficient profits, the accelerated benefits are not absorbed within the project activity and hence do not ultimately affect the IRR value.

The project IRR for the project activity without CDM is 10.40% which confirms that the proposed project activity in absence of CDM benefits and compared to the applicable benchmark IRR of 12.75% is not financially attractive while the project IRR with CDM benefit is 13.79 %

1 http://www.incometaxindia.gov.in/Acts/INCOME%20TAX%20ACT/80-ia.asp

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The project developer has checked the robustness of the financial model through a sensitivity analysis. A sensitivity analysis has been carried out for parameters contributing more than 20% to revenue costs to demonstrate the robustness of the financial analysis. Reasonable variations of the Plant Load Factor, operational costs, project costs and electricity tariff were checked by calculating the variation necessary to reach the benchmark and discussing the likelihood for that happen.

Plant Load Factor

Tariff

Project cost

Operation and Maintenance cost

These parameters were varied first with +/- 10% with the base value and again they were varied until the benchmark was reached and the likelihood for that to happen was assessed. No positive correlation of the parameters is expected.

Plant Load Factor: With increase and decrease of 10% the returns obtained are 12.06% and 8.61% respectively. With the decrease of 14.50% in PLF, the returns cross the benchmark. With the increase of 14.50% the resulting PLF would be at 22.90%. Based on the government published data for the Sinnar site, it has not reached the 20% PLF2 mark as explained in the table above. The same is further substantiated by the PLF achieved for Maharashtra state which was published by MEDA. It is observed that PLF has not reached to 20% level3. Hence this scenario is unrealistic.

Tariff: With increase and decrease of 10% the returns obtained are 11.74% and 9.00% respectively. With the increase of 18.00% in tariff, the returns cross the benchmark. This scenario is not possible since the PP has already entered in the contract with MSEDCL with INR 3.50 per kWh with escalation of INR 0.15 annually till thirteenth year /26/.

Project cost: With increase and decrease of 10% the returns obtained are 9.01% and 12.02% respectively. With the decrease of 14.10% in the project cost, the returns cross the benchmark. The value which has been considered was negotiated by the PP to the supplier continuously and the best offer from the supplier was provided /6/, hence no further possibility of the reduction in the project cost is envisaged. Hence this scenario is unrealistic.

Operation and Maintenance cost: With increase and decrease of 10% the returns obtained are 10.11% and 10.69% respectively. With the decrease of 88.00% in O&M cost, the returns cross the benchmark. This scenario is not possible since the PP has

2 http://www.mahaurja.com/Download/WindGenerationInfo0809.xls 3 http://www.mahaurja.com/Download/Sitewise_WindInstallationInfo.xls

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already entered in the contract with the O&M contractor with INR 1.55 Million at 5% escalation from the 2nd year /28/. Hence this scenario is unrealistic.

From the discussion above it can be concluded that the project activity cannot be considered as a business-as-usual scenario and the project is not likely to have been implemented without CDM benefits. Thus the project activity is additional.

Barriers due to prevailing practices: Paragraph 114-117, VVM, Version 1.1

The webhosted PDD initially did not have sufficient information to support the arguments made for the prevailing practices. The validation team raised a clarification [CL 4] in this regard. Project participant could not come up with supporting evidences to make the argument transparent and rational; hence this barrier has been removed from the final PDD by the PP.

3.3 Monitoring Plan Paragraph 121-123, VVM, Version 1.1

The project applies the approved monitoring methodology AMS-I.D version 13 - “Grid connected renewable energy generation”.

Parameters determined ex-ante: Baseline emission factor of NEWNE grid is based on the approved methodology AMS-I.D version 13 paragraph 9, using weighted average emission factor which is 0.810 tCO2e/ MWh. The emission coefficients are determined from official data published in Central Electricity Authority (CEA) CO2 Baseline Database version 04 /15/ and the same was available to the project participant at the time of submission of the PDD for validation dated 10 March 2009. CEA, which is an official source of Ministry of Power, Government of India, have worked out baseline emission factor for various grids in India and made them publicly available as CO2 Baseline database – Version 04 Database. The calculations and assumptions were verified by the validation team and found to be correct and appropriate. /34/

Parameters determined ex-post: The monitoring will involve parameters mentioned below:

The electricity generated by individual turbine

Grid emission factor – Weighted Average Grid Emission factor Management system and quality control As per point no. (c)-11.05 of the signed Wind Energy Purchase Agreement /26/, “Wherever more than one power producer are delivering energy produced by them using the common evacuation system and through the same common metering equipment, then they shall identify a common agency responsible for joint meter reading with MSEDCL. The Joint Meter Reading take at the common evacuation system shall be supported by meter readings of individual power producers using such common evacuation system. Based on this break up, limited to total energy delivered, the power generated from the individual power plant shall be certified by MSEDCL.” It is reported and made transparent in the PDD that incase when monitoring period and JMR dates are

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not matching, the PP will not claim the emission reductions for that period, which is conservative and hence accepted.

The PP has identified SISL who is responsible for O&M and responsible for the entire wind farm as their agency responsible for Joint Meter Reading with MSEDCL /29/. In turn, they get their credit note signed by MSEDCL and the invoicing is done based on the credit note for which they are paid to their nominated bank accounts. One such example for the month of October 2009 was cross checked and verified by the validation team and found following the procedure as mentioned in the Wind energy purchase agreement. Since the generation is finally certified by the government agency MSEDCL and based on which the payments are done to the PP, the validation team considered it to be authentic and acceptable /30//31//32/.

As per the requirement of Electricity rules mentioned in the WEPA, calibration of main and check meters will be done by MSEDCL officials. The accuracy test would be conducted by MSEDCL annually with 0.5 % accuracy class meters. The monitoring plan has provisions to archive the data for 2 years further to the end of crediting period.

The responsibilities and authorities of project management, data handling and recording, measurement methods and QA/QC procedure have been systematically established and formalized and the same was verified during the site visit and found to be in place and followed.

RINA confirms that the monitoring plan mentioned in the PDD is complete and in accordance with the requirements of the applied monitorin methodology and the local regulatory requirements. The monitoring plan will give opportunity for real measurement of achieved emissions reductions.

3.4 Calculation of GHG Emissions Paragraph 88 - 92, VVM, Version 1.1 The calculation and formulae as addressed in the approval baseline and monitoring methodology AMD-I.D version 13 have been applied.

The baseline emissions have been calculated as the product of the net electricity exported to the NEWNE grid by the project activity and weighted average emission factor of the NEWNE regional grid. As discussed in section 3.2, the weighted average emissions of the current generation mix for NEWNE grid of India has been taken as per the approved methodology. The weighted average emission factor of 0.810 tCO2e / MWh is considered for the calculations, which has been sourced from the Central Electricity Authority CO2 Baseline Database. However this will be monitored ex-post for the actual annual emission reductions. Central electricity Authority (CEA -which is an official source of Ministry of Power, Government of India) have worked out baseline emission factor for grid in India and made them publicly available as CO2 Baseline Database for the Indian Power Sector User Guide - Version 4.0 Database /15/. The project will partly displace fossil fuel-based electricity generation. While the project emissions are zero, baseline emissions are equal to the emission reductions due to the project activity and have been estimated to be 2,129 tCO2e per year, based on weighted average baseline emission factor of 0.810 tCO2e / MWh.

As per the methodology AMS-I.D version 13, the project activity involves grid connected energy generation from renewable power plant. Therefore, it doesn’t need to consider the project

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emissions. Also, it was verified that the wind turbine is new and there is no transfer of equipment to or from other project activity. Hence, no leakage has been considered for this project activity.

The validation team concluded that the project emissions, baseline emissions, leakage and emission reductions stated in the latest PDD are appropriate and as per the methodology.

Algorithm and formulae used to determine emission reductions Paragraph 88-92, VVM, Version 1.1

Based on the above consideration the emission reductions from the project activity have been determined to be 2,129 tCO2e/ year average over the 10 years crediting period /34/.

RINA verified that the formula, all assumptions and data used by the PP discussed in the PDD are as per the approved methodology and with appropriate source reference. The validation team cross checked the references and the sources provided by the PP in the PDD and found them to be appropriate and conservative. The baseline emissions are equal to the emission reductions due to the project activity and have been estimated, the same can be verified from the emission reduction calculation sheet provided by the PP RINA confirms that the estimates provided in the PDD and supporting files are correct, conservative and reasonable and can conclude that the project emissions, baseline emissions, leakage and emission reductions stated in the PDD are appropriate and as per the methodology. The project participant has correctly applied the methodology.

3.5 Environmental Impacts Paragraph 130-132, VVM, Version 1.1

The proposed project activity contributes to generation of green power and is expected to benefit the economic development of the region. Thus, the project activity is expected to have only beneficial impacts and no adverse impacts are foreseen. There is no mandatory legal requirement from Ministry of Environment & Forests for carrying out EIA for wind power projects, which was verified by means of EIA notification dated 14/09/2006.

However RINA has verified all the clearances like statutory clearances _6_references/10/, commissioning certificates /8/ and Energy Purchase Agreements /26/ for the WTG. The validation team concludes that all the clearances obtained are in accordance with the procedures required by the host party.

3.6 Comments by Local Stakeholders Paragraph 127-129, VVM, Version 1.1

As per the CDM requirements, it is necessary to invite the relevant stakeholders, before the validation process starts. Stakeholders consultation meeting to discuss stakeholders concerns on this CDM project- “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors”, Maharashtra , was held on 21 February 2009 at SISL Office, Nashik, Maharashtra. Invitation letters were sent on 06 February 2009 /11/. The local stakeholders identified are farmers, Village head and employees of Suzlon Infrastructure Services Limited. A brief description on the project was provided in the meeting and project proponent invited them to fill questionnaire on the project. The project has not received any adverse comments. The minutes of

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the meeting was provided to the validation team for verification and the same has been found acceptable /12/. The PP also maintains the photographic evidence for the conduct of the stakeholder consultation meeting and the same was also submitted to the validation team /40/.

The validation team also verified questionnaires /13/ to note that no negative comments were received. The validation team is of the opinion that the local stakeholder’s process was adequate giving fair opportunity for the participation by local stakeholders.

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS The PDD of 10 March 2009, version 00 was made publicly available on UNFCCC website. Parties, stakeholders and UNFCCC accredited non-governmental organizations were invited through the CDM-UNFCCC website (http://cdm.unfccc.int/Projects/Validation/DB/LBEZJ4643SYTD4BSAEWDD005YI7B7C/view.html) to provide comments during a 30 days period from 27 March 2009 to 25 April 2009. No comments were received in this period.

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5 VALIDATION OPINION RINA Services Spa (RINA) has performed a validation of the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors” in India on the basis of UNFCCC criteria for the Clean Development Mechanism and host Party criteria, as well as criteria given to provide for consistent project operations, monitoring and reporting. UNFCCC criteria refer to Article 12 of Kyoto Protocol, the CDM modalities and procedures and the subsequent decision by the CDM Executive Board.

The review of the project design documentation and the subsequent follow-up interviews have provided RINA with sufficient evidence to determine the fulfillment of stated criteria.

The project participant is M/s L. B. Kunjir. The host Party India which meets all participation. The DNA from India, issuing the Letter of Approval on 26 June 2009, approved the project, confirmed that the project assists in achieving sustainable development and authorized the project participant.

The project correctly applies the simplified baseline and monitoring methodology AMS-I.D, version 13 “Grid connected renewable electricity generation”. The installed capacity of the project is 1.5 MW, which is less than 15 MW, and the project is eligible as type I small-scale CDM project activity and it has also been demonstrated that the project is not a de-bundled component of a large scale project. By generating renewable energy from wind power plant, the project results in the reduction of GHG emissions those are real, measurable and give long term benefits and that are additional to what would have occurred in the absence of the project

.The total emission reductions from the project are estimated to be on the average 2,129 tCO2e annually over the selected fixed 10 year crediting period. The emission reduction forecast has been checked and it is deemed likely that the stated amount is achieved given that the underlying assumptions do not change.

In summary, it is RINA’s opinion that the project Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors, as described in the project design document version 02 of 06 February 2010, meets all relevant UNFCCC requirements for the CDM and all relevant host Party criteria and correctly applies the approved simplified baseline and monitoring methodology AMS-I.D version 13. Hence, RINA requests the registration of the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors” as a CDM project activity.

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6 REFERENCES

Category 1 Documents: List documents provided by the Client that relate directly to the GHG components of the project.,

/1/ M/s L. B. Kunjir CDM-SSC-PDD for the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors”, Version 00 of 10 March 2009 (web hosted). M/s L. B. Kunjir CDM-SSC-PDD for the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors”, Version 01 of 26 August 2009. M/s L. B. Kunjir CDM-SSC-PDD for the “Wind Power Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors”, Version 02 of 06 February 2010.

/2/ Copy of Letter of Approval from the DNA, India dated 29 June 2009

Category 2 Documents: List background documents related to the design and/or methodologies employed in the design or other reference documents.

/3/ CDM Validation and Verification Manual – Version 01.1, EB 51, dated 04 December 2009.

/4/ “Attachment A to Appendix B of the Simplified Modalities and Procedures for Small-Scale CDM project activities”.

/5/ Approved small scale methodology for “Grid connected renewable electricity generation” AMS-I.D, Version 13 dated 14December 2007

/6/ Copy of best Offer letter from Suzlon Energy Limited dated 16 December 2008 Copy of Purchase order/erection and commissioning with Suzlon Energy Limited dated 18 December 2008

/7/ Copy of land purchase records dated 07 January 2009 for Suzlon make WEG. (sale deeds execution date)

/8/ Copy of commissioning letter from Maharashtra State Electricity Distribution Co. Ltd. dated 02 April 2009

/9/ Copy of infrastructure clearance for setting up 1.50 MW capacity wind power project by Maharashtra Energy Development Agency dated 25 March 2009

/10/ Copy of clearance for commissioning for 1.50 MW capacity wind power project by Maharashtra Energy Development Agency dated 30 March 2009

/11/ Copy of invitation letter sent for local stakeholders’ consultation meetings 06 February 2009.

/12/ Copy of minutes of local stakeholders’ consultation meetings held on 21 February 2009.

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/13/ Copy of filled questionnaire from local stakeholders’ consultation held on 21 February 2009.

/14/ Soft copy of Financial calculation sheet

/15/ CO2 Baseline Database, Version 04 at: http://www.cea.nic.in/planning/c%20and%20e/Government%20of%20India%20website.htm

/16/ Copy of Suzlon Energy Limited technical specification document on Lifetime of S-82 type WEG

/17/ Copy of a certificate from an independent Chartered Accountant on cash flow & returns computation for the project activity

/18/ Copy of Controller Calibration Declaration from SISL dated 20 November 2009

/19 Copy of letter from PP to Independent Chartered Accountant to conduct feasibility assessment for the project activity dated 10 December 2008

/20/ Copy of Project feasibility assessment by Independent Chartered Accountant dated 15 December 2008

/21/ Copy of Partner’s Note to go ahead with CDM project activity – CDM consideration dated 17 December 2008

/22/ Copy of confirmation mail from UNFCCC on intimation about CDM project activity dated 06 January 2009

/23/ Copy of loan sanction letter from Bank of Baroda dated 06 March 2009

/24/ Copy of loan application letter to Bank of Baroda dated 09 January 2009 Copy of letter from the Chief Manager, Bank of Baroda confirming 20% PLF for the project (Ref: Gultek/ADV/09/07) activity dated 25 September 2009

/25/ Copy of Joint Meter Reading procedures from Maharashtra State Electricity Distribution Co. Ltd. To Suzlon Infrastructure Services Ltd. Dated 29 December 2009

/26/ Copy of Wind Energy Purchase Agreement with MSEDCL dated 23 June 2009

/27/ Micrositing drawing of project activity

/28/ Operation and Maintenance contract with SISL dated 10 June 2009

/29/ Copy of Letter from PP on appointing SISL/SEL as a common agency responsible for JMR with MSEDCL dated 24 December 2008

/30/ Copy of credit note from MSEDCL for the month of October 2009

/31/ Copy of invoice for the electricity exported to the grid for the month of October 2009

/32/ Copy of bank statement showing payment towards the invoice for the month of October 2009

/33/ Prime Lending Rate from Reserve Bank of India:

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http://rbi.org.in/scripts/PublicationsView.aspx?id=10292

/34/ Emission Reduction Calculation Sheet

/35/ Copy of appointment letter of MITCON Consultancy Services Ltd. Towards their services on CDM dated 17 December 2008.

/36/ Tariff Determination and Plant Load Factor Consideration as per Maharashtra Electricity Regulatory Commission dated 24 November 2003

/37/ Loan Sanction Letter from Bank of Baroda for procurement of vehicles dated 22 August 2007

/38/ Indian Income Tax Act – 80IA and clarification Effect on S. 80IA(5) of IT Act by Sharad Shah & Co., Chartered Accountants

/39/ Installed capacity and electricity generation at the Sinnar site for the year 2008-09 in Excel format – link: http://www.mahaurja.com/Download/WindGenerationInfo0809.xls

/40/ Photographs of local stakeholders’ consultation meetings held on 21 February 2009.

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

/41/ Mr. Vikash Kumar Singh – Senior Consultant – Mitcon Consultants Pvt. Limited

/42/ Mr. Smitanshu Karekar – Chartered Accountant representing M/s L. B. Kunjir Engineers & Contractors

/43/ Mr. Rajendra Tiwari – Deputy Manger, Electrical - Suzlon energy Limited

-- o0o --

RINA “WIND POWER PROJECT IN MAHARASHTRA BY M/S L. B. KUNJIR ENGINEERS & CONTRACTORS”

Page A-1 CDM SSC Validation Report No. 2009 IQ ME 10, rev. 02 FORM: CDM_SCC_VAL_REP-02-09

APPENDIX A

CDM VALIDATION PROTOCOL This document contains a generic Validation Protocol for small-scale CDM projects, which must be seen in conjunction with the CDM Validation and Verification Manual and the Validation Report Template. The entries in the protocol should be adjusted and amended as appropriate to prepare for the validation of a particular project.

This validation protocol serves the following purposes: • It organizes, details and clarifies the requirements a CDM project is expected to meet; and • It ensures a transparent validation process by inducing the Validator to document how a particular requirement has been validated and which conclusions have been reached; This protocol contains two tables with generic requirements for validation projects. Table 1 shows the requirements that the GHG emission reduction project will be validated against. Table 2 consists of a checklist with validation questions related to one or more of the requirements in Table 1. The checklist questions may not be applicable for all investors, and should not be viewed as mandatory for all projects. Where a finding is issued, a corrective action request or clarification request are stated. The resolution and final conclusions of these requests should be described in Table 3 of this protocol. Before this generic validation protocol can be applied to validate a specific project, the Validator must review and adjust/amend the protocol to make it applicable to individual project characteristics and circumstances as well as individual investor criteria. The application of the validator’s professional judgment and technical expertise should ensure that checklist amendments cover all necessary specific project requirements that have impact on project performance and acceptance of the project. Given the above, the checklist part of the protocol is neither exhaustive nor prescriptive.



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

Requirement Reference Conclusion Cross Reference / Comment 1. The project shall assist Parties included in Annex I in

achieving compliance with part of their emission reductions commitment under Art. 3.

Kyoto Protocol Art.12.2 OK This project has been proposed as unilateral project activity. Table 2, Section, B.6.3, B.6.4

2. The project shall assist non Annex I Parties in achieving sustainable development and shall have obtained confirmation by the host country thereof.

Kyoto Protocol Art. 12.2, Simplified Modalities and Procedures for Small Scale CDM Project Activities §23a

CAR 1 OK

The Host Country Approval needs to be provided. The PP is requested to provide evidences on compliance on all related regulatory and legislative requirements. Table 2 – A.1.1, A.2.3.1, A.2.3.2, A.2.3.3

3. The project shall assist non Annex I Parties in contributing to the ultimate objective of the UNFCCC.

Kyoto Protocol Art.12.2. OK Table 2, Section A.4.3, B.6.3, B.6.4

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

Kyoto Protocol Art.12.5a, Simplified Modalities and Procedures for Small Scale CDM Project Activities §23a

CAR 1 OK

The Host Country Approval needs to be provided. The PP is requested to provide evidences on compliance on all related regulatory and legislative requirements. Table 2 – A.1.1, A.2.3.1, A.2.3.2, A.2.3.3

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 OK Table 2, Section B.6.1.1 and B.6.3.1

6. Reductions in GHG emissions shall be additional to any that 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

Kyoto Protocol Art. 12.5c, Simplified Modalities and Procedures for Small Scale CDM Project Activities §23a

CAR 3, CL 4

OK

The discussion on the additionality needs to be more specific, clear and specifically referenced. The project activity does not fall under the purview of Environmental Impact Assessment (EIA) as per EIA Notification of Ministry of



Requirement Reference Conclusion Cross Reference / Comment occurred in the absence of the registered CDM project activity.

Environment & Forests (MoEF), Government of India (GoI) dated 27 January 1994 and the amendment dated 14 September 2006. The PP is requested to address criterion that clears the project activity from the purview of EIA Notification of MoEF, GoI and the subsequent amendment. The legal and regulatory approvals are to be provided for verification. The PP is requested to provide justification on selection and the appropriateness of the chosen benchmark as per the EB guidance on investment analysis along with supporting documents. The PP needs to also clarify on the source for the electricity generation value and transparently discuss the PLF considered. The PDD is not transparent on how the PLF is estimated and justified as to how it is in line with the EB 48 guidelines on reporting of PLF The PP needs to submit the commercial calculation provided by SEL for verification. As per the guidance provided on the assessment on Investment Analysis, point number 4 regarding the fair value of the project activity asset. The PP is requested to kindly justify the value chosen for residual value of the asset (5%) It is not transparent why the escalation in tariff is not considered in IRR calculations



Requirement Reference Conclusion Cross Reference / Comment Further most of the assumptions in the IRR sheet are based on post decision documents and hence cannot be accepted. As per the guidance provided in the tool for demonstration and assessment of additionality version 5.2, guidance point no. 6, the PP needs to use input values for all investment analysis should be valid and applicable at the time of the investment decision taken. The PP is also requested to provide clarification on the pre-tax/ post-tax returns comparison with the benchmark. The PP is requested to provide the use of this arrangement consistently in their investment decisions for last three years. The PP needs to justify that even considering the financial benefits from CDM the IRR reaches to 11.66% which is still lesser than the benchmark 13.30%, why should the project be taken at all, even with financial benefits, it falls short of the benchmark? The PP needs to justify the error in application of figures in the financial excel sheet and in the PDD. The PP is requested to incorporate point number 9, Annex 45, EB 41, while calculating the project IRR. The PP is also requested to provide written confirmation from the independent chartered accountant on verification of profitability, cash



Requirement Reference Conclusion Cross Reference / Comment flows and assumptions made for calculations made for implementation of this project activity. The PP needs to consider the O & M costing for sensitivity analysis, as the cumulative amount reaches more than 20 % of the project cost, hence the same needs to be considered. The PP is also requested to clarify on the sensitivity analysis carried out for generation with PLF consideration as to how the same has been carried out. PP is requested to carry out the sensitivity analysis by varying paragraph until the benchmark is reached and the likelihood for that to happen need to be supported by evidences. The PP needs to carry out the barrier due to prevailing practice as per the guidance given in ““Tool for the demonstration and assessment of additionality”, version 05.2.

7. Potential public funding for the project from Parties in Annex I shall not be a diversion of official development assistance (ODA).

Marrakech Accords OK The validation did not reveal any information that indicates that the project can be seen as a diversion of official development assistance (ODA) funding towards India. Table 2, Section A.4.4

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

Marrakech Accords, CDM Modalities §29

OK The Designated National Authority (DNA) of India is “National Clean Development Mechanism Authority”



Requirement Reference Conclusion Cross Reference / Comment 9. The host country and the participating Annex I Party

shall be a Party to the Kyoto Protocol. Marrakech Accords, CDM Modalities §30

OK The host country India has ratified the Kyoto protocol on August 26, 2002.

10. The participating Annex I Party’s assigned amount shall have been calculated and recorded.

CDM Modalities and Procedures §31b

NA

11. The participating Annex I Party shall have in place a national system for estimating GHG emissions and a national registry in accordance with Kyoto Protocol Article 5 and 7.

CDM Modalities and Procedures §31b

NA

12. Comments by local stakeholders shall be invited, a summary of these provided.

Simplified Modalities and Procedures for Small Scale CDM Project Activities §22b

OK Table 2, Section E

13. If required by the host country, an analysis of the environmental impacts of the project activity is carried out and documented.

Simplified Modalities and Procedures for Small Scale CDM Project Activities §22c

OK Table 2, Section D

14. The proposed project activity shall confirm to one of the project categories defined for small scale CDM project activities and uses the simplified baseline and monitoring methodology for that project category.

Simplified Modalities and Procedures for Small Scale CDM Project Activities §22e

OK Table 2, Section B.2

15. The proposed project activity shall meet the eligibility criteria for small scale CDM project activities set out in § 6 (c) of the Marrakesh Accords and shall not be a debundled component of a larger project activity.

Simplified Modalities and Procedures for Small Scale CDM Project Activities §12a,c

OK The project activity involves installation of one WEG with capacity less than 15 MW. Table 2, Section A.4.5

16. Parties, stakeholders and UNFCCC accredited NGOs shall have been invited to comment on the validation requirements for minimum 30 days, and the project design document and comments have been made

Marrakech Accords, CDM Modalities, §40

OK The PDD dated 10 March 2009 was made publicly available and Parties, stakeholders & NGOs were through the CDM website (http://cdm.unfccc.int/Projects/Validation/DB/L



Requirement Reference Conclusion Cross Reference / Comment publicly available. BEZJ4643SYTD4BSAEWDD005YI7B7C/vie

w.html) invited to provide comments during a 30 days period from 27 March 2009 to 25 April 2009. No Comment was received during the period.

17. The project design document shall be in conformance with the UNFCCC CDM-SCC-PDD format.

Marrakech Accords, CDM Modalities, Appendix B, EB Decisions

OK PDD is in accordance with CDM-SSC-PDD (version 03 of 22 December 2006).



Table 2 Requirements Checklist

Checklist Question Ref. MoV* Comments Draft Concl.

Final Concl.

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

A.1. Title of the small-scale project activity. A.1.1. Title of the project activity, version number and

date of document (PDD). /1/ /2/ DR, I Title of the project activity is “Wind Power

Project in Maharashtra by M/s L. B. Kunjir Engineers & Contractors”, Version is 00 and the date of the PDD is 10/03/2009. The project participant (PP) needs to change the version number from 00 to 01. However, the title of the project needs to be verified with the Host Country Approval letter issued by the DNA, India.

CL 1

CAR 1

OK

A.2. Description of the small-scale project activity. A.2.1. Is the purpose of the project activity

included? /1/ DR, I The purpose of the project activity is to

generate energy from 1.5 MW wind turbine which is from a renewable source.

OK

A.2.2. Is it explained how the project activity reduces greenhouse gas emissions, i.e. technology, measures?

/1/ DR, I The electricity is generated through the wind energy that would be done by the S82 type Suzlon wind turbine which has been developed in 2006 and has been implemented in the Indian subcontinent successfully.

OK

A.2.3. Contribution to Sustainable Development. Table 1 - 2

A.2.3.1. Is the project in line with relevant legislation and plans in the host country?

/1/ /2/ DR, I The PP is requested to provide evidences on compliance on all GHG emission reduction

CAR 1 OK




Final Concl.

related regulatory and legislative requirements. A.2.3.2. Is the project in line with host-country

specific CDM requirements? /1/ /2/ DR, I The Host Country Approval needs to be

provided. CAR 1 OK

A.2.3.3. Is the project in line with sustainable development policies of the host country?

/1/ /2/ DR, I See A.2.3.1. CAR 1 OK

A.2.3.4. Will the project create other environmental or social benefits than GHG emission reductions?

/1/ DR, I The project will create opportunities for infrastructure development, employment opportunities and the utilization of wind for energy generation reflects other social and environmental benefits.

OK

A.3. Project participants. A.3.1. Are Party (ies) and private and / or public

entities involved in the project activity listed? /1/ /2/ DR, I The private entity involved in the project

activity is “ M/s L. B. Kunjir” OK

A.3.2. Is the contact information provided in Annex 1 of the PDD, using the (proper table) tabular format?

/1/ DR, I The contact information is provided in annex 1 of the PDD.

OK

A.4. Technical description of the small-scale project activity.

A.4.1. Is the location of the project activity clearly defined, including details of the physical location and information allowing the unique identification of this small-scale project activity(ies)?

/1/ DR, I The project activity is located at Adwai, taluka Sinnar of Nashik district of Maharashtra in India. The geographical co-ordinates for the project site are 21021’57.31” N and 74014’32.09” E. However, the PP is requested to provide the evidence indicating the location of the project activity.

CL 1 OK

A.4.2. Is (are) the type(s) and category(ies) and technology/measure of the proposed small-

/1/ /5/ DR, I The type of the project activity is energy generation from the renewable sources. The

CAR 2 OK




Final Concl.

scale project activity specified? category of the applied methodology is “AMS I.D Grid connected renewable electricity generation, Version 13” The technology employed in the project activity is the conversion of kinetic energy of wind in to electricity through S-82 type, 1500 KW wind energy generator. This is a clean technology as the energy is generated through renewable wind energy. The PP needs to correct the category type as per Appendix B of “Simplified modalities and procedures for small-scale clean development mechanism project activities” In the PDD section A.2 the evacuation of energy is mentioned as 2.68 GWh which needs to be corrected as it will come at 2.628 GWh.

A.4.3. Estimated amount of emission reductions over the chosen crediting period.

A.4.3.1. Is the chosen crediting period, total and annual estimated reductions defined and presented in a (proper table) tabular format? (check these figures against item B.6.4 figures)

/1/ /3/ DR, I The project will generate 2129 tCO2e every year for the chosen crediting period of 10 years which is correctly represented in section B.6.4 of the PDD.

OK

A.4.4. Public funding of the project activity. A.4.4.1. Is it indicated whether public funding from

Parties included in Annex 1 is involved in the proposed project activity?

/1/ /6/ /7/ /37/

DR, I No public funding has been taken for this project activity. The same was verified with purchase order, erection and commissioning order of WEG.

OK




Final Concl.

A.4.4.2. If public funding is involved, is information on sources of public funding for the project activity is provided in Annex 2, including an affirmation that such funding does not result on a diversion of official development assistance and is separate from and is not counted towards the financial obligations of those Parties?

/1/ /6/ /7/ /37/

DR, I See A.4.4.1. OK

A.4.5. Confirmation that the SSC project is not a debundled component of a large scale project activity.

(Appendix C to the simplified modalities and procedures for the small-scale CDM project activities)

A.4.5.1 The small scale project activity is not a debundled component of a larger project activity?

/1/ DR, I The project activity is not a debundled component of a larger project activity and the project participants have not registered another project using the same technology within 1 KM radius of the project during the past two years.

OK




Final Concl.

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

B.1. Baseline and Monitoring Methodology. It is assessed whether the project applies an appropriate baseline & monitoring methodology (number, title and version).“Appendix B of the Simplified Modalities and Procedures for Small-Scale CDM project activities”.

B.1.1. Is the selected baseline and monitoring methodology previously approved by the CDM Methodology Panel and in line with the relevant project category? (correctly quoted and interpreted?)

/1/ /4/ /5/

DR, I Yes. The project correctly applies the approved baseline and monitoring methodology “Grid connected renewable electricity generation” type I. D, Version 13 as per Appendix-B of simplified modalities and procedures for small scale CDM projects.

OK

B.1.2. Is the baseline and monitoring methodology applicable to the project being considered?

/1/ /4/ /5/

DR, I Yes, the project activity meets the applicability criteria of AMS I.D, version 13 and is justified as under :

The project activity involves grid connected electricity from a renewable source - wind,

The project capacity is 1.5 MW which is less than 15 MW as required by the methodology.

The geographic and system boundaries for the relevant electricity grid has been

OK




Final Concl.

clearly identified to be the western electricity grid ;

The project activity will displace fossil fuel based electricity that would otherwise be provided by the operation and expansion of the NEWNE grid and sufficient information on the characteristics of the grid are available.

B.1.3. Are other methodologies or tools drawn up by the approved methodology mentioned? (correctly quoted and interpreted?)

/1/ /5/ DR, I No other tools are being utilized by the approved methodology.

OK

B.1.4. If comparable information is available from sources other than that used in the PDD, cross check the PDD against the other sources to confirm that the project activity meets the applicability conditions.

/1/ /2/ /3 /4/ /5/ /6/ /7/ /8/

/9/ /10/ /11/ /12/ /13/ /14/ /15/ /16/ /17/ /18/ /19/

/20/ to /40/

DR, I The PP needs to provide all sources from where the information has been obtained for verification. All original copies of sources/ evidences used in the PDD needs to be provided for verification The PP is requested to indicate the tool from where the guidance has been taken.

CL 2 OK




Final Concl.

B.2. Justification of the choice of the project category B.2.1. Does the project qualify as a small scale

CDM project activity as defined in Decision 1/CMP.2, paragraph 28 – “Further guidance relating to the CDM” (revision of paragraph 6 (c) of decision 17/CP.7 on the modalities and procedures for the CDM)?

/1/ /4/ /5/ /6/

/8/ /26/

DR, I Yes, the project qualifies as a small scale CDM project activity, since the installed capacity of the project activity is less than 15 MW and is in line with the simplified modalities and procedures for small-scale CDM project activities respectively.

OK

B.2.2. Does proposed project activity confirm to one of the project categories defined for small scale CDM project activities?

/1/ /5/ DR, I Refer to A.4.2 CAR 2 OK

B.3. Description of the project boundary (physical delineation of the proposed CDM project activity).

B.3.1. Are the project’s spatial (geographical) boundaries clearly defined?

/1/ /4/ /5/

DR, I Yes. As per the methodology AMS-I.D, the project boundary encompasses the physical, geographical site of the renewable generation source. Here, project boundary consists of WEG, grid and substation of the project.

OK

B.3.2. Are the project’s system (components and facilities used to mitigate GHGs) boundaries clearly defined and do they sufficiently cover sources for baseline emissions?

/1/ /5/ DR, I Project boundary is clearly defined and it covers sources for baseline emissions.

OK

B.3.3. If GHG emissions occurring within the proposed CDM project activity boundary (not addressed by the applied methodology), as a result of project’s implementation, are expected to contribute more than 1% of the overall expected average annual emissions reductions, are they informed in the PDD?

/1/ /5/ DR, I There is no GHG emission expected to occur in this project activity.

OK




Final Concl.

B.4. Description of how baseline scenario is identified. 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.4.1. Is the application of the methodology and the discussion and determination of the chosen baseline scenario transparent?

/1/ /5/ DR, I The project correctly applies the approved baseline methodology “Grid connected renewable electricity generation” type I. D, Version 13 as per Appendix-B of simplified modalities and procedures for small scale CDM projects. The baseline scenario considered is the NEWNE grid power generation. The baseline scenario has been chosen as per the methodology that the baseline is the MWh produced by the renewable generating unit multiplied by an emission coefficient calculated in the transparent and conservative manner.

OK

B.4.2. Has the baseline been determined using conservative assumptions where possible?

(confirm that any procedure contained in the methodology to identify the most reasonable baseline scenario, has been correctly applied)

/1/ /5/ DR, I Yes, the baseline has been determined using conservative assumptions.

OK

B.4.3. Has the baseline been established on a project-specific basis?

/1/ /5/ DR, I Yes OK

B.4.4. Does the baseline scenario sufficiently take /1/ /5/ DR, I Yes, the national policies favor the OK




Final Concl.

into account relevant national and / or sectoral policies, macro-economic trends and political aspirations?

development of renewable energy sources.

B.4.5. Is the baseline determination compatible with the available data?

/1/ /5/ DR, I See B.4.2. OK

B.4.6. Does the selected baseline represent the most likely scenario among other possible and/or discussed scenarios?

/1/ /5/ DR, I No other alternative scenarios have been discussed. The selection of baseline scenario is in accordance with the baseline methodology AMS ID, version 13.

OK

B.4.7. Have the major risks to the baseline been identified? (Are uncertainties in the GHG emission estimates properly addressed in the documentation?)

/1/ /5/ DR, I There are no major risks perceived to the proposed baseline.

OK

B.4.8. Is all literature and sources clearly referenced?

/1/ /5/ DR, I Yes the project is located in the state of Maharashtra which a part of the NEWNE grid hence the baseline scenario has been appropriately considered to be the grid mix in the NEWNE regional grid. The baseline determination is compatible with the available data. The grid emission factor has been used from the official CEA website. The Central Electricity Authority Database of the years 2005-06 to 2007-08 is referenced for baseline determination and is deemed appropriate. For Emission factor, weighted average approach was considered.

OK

B.4.9. Background information or documentation, including tables with time series data,

/1/ /5/ DR, I The PP needs to justify the chosen version of the CEA database with respect to the decision

CAR 2 OK




Final Concl.

documentation of measurement results and data sources are properly addressed? (check Annex 3)

making to go ahead for the project activity. The PP also needs to justify the method chosen for calculating emission factor in line with methodology requirement.

B.5. Description of how the anthropogenic emissions of GHG by sources are reduced below those that would have occurred in the absence of the registered CDM project activity (Assessment and demonstration of additionality - “Attachment A to Appendix B of the simplified modalities and procedures for small-scale CDM project activities”).

B.5.1. Does the PDD follow all the steps required in the methodology to determine the additionality? (Is an approved additionality tool required / used? - Note: the guidance in the methodology shall supersede the tool)

/1/ /5/ /6/ /7/ /8/ /9/ /10/ /14/ /16/ /17/ /19/ /20/ /21/ /22/ /23/ /24/ /26/ /24/ /26/ /28/ /29/

DR, I PP has established additionality of the project activity as per attachment A to Appendix B. Project activity is emphasized on investment barrier and barriers due to prevailing practice.

OK




Final Concl.

/30/ /31/ /32/ /33/ /35/ /36/ /37/ /38/ /39/

B.5.2. Is the discussion on the additionality clear and have all assumptions been conservative, supported by transparent and documented evidence for all steps?

/1/ /5/ /6/ /7/ /8/ /9/ /10/ /14/ /16/ /17/ /19/ /20/ /21/ /22/ /23/ /24/ /26/ /24/ /26/ /28/ /29/ /30/ /31/

DR, I The discussion on the additionality needs to be more specific, clear and specifically referenced. All references/ evidences/ documents needs to be provided for verification.

CL 2 OK




Final Concl.

/32/ /33/ /35/ /36/ /37/ /38/ /39/

B.5.3. Is it demonstrated / justified that the project activity itself is not a likely baseline scenario? (e.g. through (a) a flow-chart or series of questions that lead to a narrowing of potential baseline options, (b) a qualitative or quantitative assessment of different potential options and an indication of why the non-project option is more likely, (c) a qualitative or quantitative assessment of one or more barriers facing the proposed project activity or (d) an indication that the project type is not common practice in the proposed area of implementation, and not required by a Party’s legislation/regulations)

/1/ /5/ /6/ /7/ /8/ /9/ /10/ /14/ /16/ /17/ /19/ /20/ /21/ /22/ /23/ /24/ /26/ /24/ /26/ /28/ /29/ /30/ /31/ /32/ /33/

DR, I Please refer to B.4.1 OK




Final Concl.

/35/ /36/ /37/ /38/ /39/

B.5.4. If the starting date of the project activity is before 2 August 2008, for which the start date is prior to the date of publication of the PDD for global stakeholder consultation, evidence to demonstrate that the CDM was seriously considered in the decision to implement the project activity, was provided, adequate and sufficient to justify it? (If starting date is on or after 2 August 2008

/1/ /5/ /6/ /7/ /8/ /9/ /10/ /14/ /16/ /17/ /19/ /20/ /21/ /22/ /23/ /24/ /26/ /24/ /26/ /28/ /29/ /30/ /31/ /32/ /33/ /35/ /36/

DR, I The starting date of the project is 18/12/2008. As per EB 41, Annex-46, the project participant is requested to furnish the notification sent to DNA/UNFCCC of the commencement of the project activity and their intention to seek CDM status since the project start date is after 2nd August 2008.

CL 3 OK




Final Concl.

/37/ /38/ /39/

B.5.5. Is the above evidence based on official, legal and / or other corporate document that was available at, or prior to, the start of the project activity?

/1/ /5/ /6/ /7/ /8/ /9/ /10/ /14/ /16/ /17/ /19/ /20/ /21/ /22/ /23/ /24/ /26/ /24/ /26/ /28/ /29/ /30/ /31/ /32/ /33/ /35/ /36/ /37/ /38/

DR, I Refer to B.5.4 CL 3 OK




Final Concl.

/39/ B.5.6. If investment analysis has been used to

demonstrate the additionality of the proposed CDM project activity, evidences that the proposed CDM project activity would not be:

(a) The most economically or financially attractive alternative; or

(b) Economically or financially feasible, without the revenue from the sale of certified emission reductions (CERs);

were provided? (“Guidance on the Assessment of Investment Analysis”)

/1/ /5/ /6/ /7/ /8/ /9/ /10/ /14/ /16/ /17/ /19/ /20/ /21/ /22/ /23/ /24/ /26/ /24/ /26/ /28/ /29/ /30/ /31/ /32/ /33/ /35/ /36/ /37/ /38/ /39/

DR, I PP has attempted to establish additionality of the project activity as per attachment A to Appendix B. Project activity additionality is emphasized on investment barrier. In the investment analysis, the PP has chosen the benchmark as average of the PLR for the years of 2007-08. The PLR range varies from 12.75 % to 14 %. The average PLR comes to 13.30. The PP is requested to provide justification on selection and the appropriateness of the chosen benchmark as per the EB guidance on investment analysis along with supporting documents. The investment analysis shows that the PLF has been considered 20% based on SEB tariff order. Considering the PLF, the annual generation comes to 2.628 GWH. In this scenario, the expected return from the project activity is 9.98 %. The PP needs to also clarify on the source for the electricity generation value and transparently discuss the PLF considered. The PDD is not transparent on how the PLF is estimated and justified as to how it is in line with the EB 48 guidelines on reporting of PLF

CL 4

CL 4

OK




Final Concl.

Based on the purchase order placed to Suzlon Energy Limited, point number 14, it has been stated that the financial calculation submitted by SEL, the project doesn’t become commercially viable considering fluctuation in the power generation due to variations in wind patterns. The PP needs to submit the commercial calculation provided by SEL for verification. As per the guidance provided on the assessment on Investment Analysis, point number 4 regarding the fair value of the project activity asset. The PP is requested to kindly justify the value chosen for residual value of the asset (5%) It is not transparent why the escalation in tariff is not considered in IRR calculations Further most of the assumptions in the IRR sheet are based on post decision documents and hence cannot be accepted. As per the guidance provided in the tool for demonstration and assessment of additionality version 5.2, guidance point no. 6, the PP needs to use input values for all investment analysis should be valid and applicable at the time of the investment decision taken. The PP is also requested to provide clarification on the pre-tax/ post-tax returns comparison with the benchmark. The PP is requested to provide

CL 4

CL 4

CL 4

CL 4




Final Concl.

the use of this arrangement consistently in their investment decisions for last three years. With the financial benefits from CDM project activity, the IRR reaches up to 11.66% The PP needs to justify that even considering the financial benefits from CDM the IRR reaches to 11.66% which is still lesser than the benchmark 13.30%, why should the project be taken at all, even with financial benefits, it falls short of the benchmark? The PP needs to justify the error in application of figures in the financial excel sheet and in the PDD. As per the EB 41, Annex 45, point number 9, The cost of financing expenditures (i.e. loan repayments and interest) should not be included in the calculation of project IRR. The PP is requested to incorporate point number 9, Annex 45, EB 41, while calculating the project IRR. The PP is also requested to provide written confirmation from the independent chartered accountant on verification of profitability, cash flows and assumptions made for calculations made for implementation of this project activity. Sensitivity analysis: In order to check the robustness of the financial

CL 4

CL 4

CL 4

CL 4




Final Concl.

model, PP has chosen PLF, project cost and O & M cost to carry out the sensitivity analysis. Considering the generation increase and decrease in the generation with the variation in the PLF, the IRR increases up to 11.48% and decreases up to 8.36% respectively. Similarly, when the project cost is kept with 10 % increase and decrease, the IRR changes from 7.25% to 13.34 % respectively. Since the PP has already made the investment, this parameter actually can not impact the IRR. The PP needs to consider the O & M costing for sensitivity analysis, as the cumulative amount reaches more than 20 % of the project cost, hence the same needs to be considered. The PP is also requested to clarify on the sensitivity analysis carried out for generation with PLF consideration as to how the same has been carried out. PP is requested to carry out the sensitivity analysis by varying parameters until the benchmark is reached and the likelihood for that to happen need to be supported by evidences. Barriers due to prevailing practices: As per the argument of PP, India has predominantly replied on coal for energy solutions with the growth rate of 5.4% in

CL 4

CL 4

CL 4




Final Concl.

consumption. The PP needs to carry out the barrier due to prevailing practice as per the guidance given in ““Tool for the demonstration and assessment of additionality”, version 05.2. CDM consideration: The start date of the project activity is 18/12/2008 when the purchase order was placed. The PP has intimated about the decision to go ahead with this CDM project activity to the EB, UNFCCC and DNA of the host country, India.

The PP needs to provide the chronological order of events with supporting evidences.

Evidences need to be provided on:

1. PP’s awareness to CDM prior to start date

2. Whether CDM has been the decisive factor to go-ahead with the project considering the gap between purchase orders placed for two WEGs.

The PP also needs to provide evidences on intimations sent to the EB, UNFCCC regarding their intention to seek CDM status of their project activity as per EB 48, Annex 61.

CL 5




Final Concl.

B.6. Emission Reductions. Validation of baseline GHG emissions will focus on methodology transparency and completeness in emission estimations.

B.6.1. Explanation of methodological choices. B.6.1.1. Have the project, baseline and leakage

emissions and emission reductions been properly explained and determined using the same appropriate methodology and conservative assumptions?

/1/ /5/ /34/

DR, I Refer to B.4.9 CAR 2 OK

B.6.1.2. Does the proposed project clearly state which equations for the calculation of emission reductions are used, as given by the approved / applied methodology?

/1/ /5/ /34/


B.6.1.3. Are the demonstration / justification for the choice of the chosen scenario (for example, in ACM0006) or case, option / method (for example in ACM0002) adequate and sufficient?

/1/ /5/ /34/


B.6.1.4. Are the demonstration / justification for the chosen default values adequate and sufficient?

/1/ /5/ /34/


B.6.2. Data and parameter those are available at validation.

Data that is calculated with equations provided in the methodology or default values specified in the methodology should not be included in the compilation.




Final Concl.

B.6.2.1. Is the list of the ex-ante data and parameters used by the project -including data from other sources- complete, transparent, documented and available? (measurements after the implementation of the project activity should not need to be included here but in the tables in section B.7.1)

/1/ /5/ /34/


B.6.2.2. Is the chosen value or, where relevant, the qualitative information for each supporting data or parameter(s) provided in a (proper table) tabular form and the choice for the source of data explained / justified with clear and transparent references or additional documentation? (check Annex 3)

/1/ /5/ /34/


B.6.2.3. If values were measured, a description of measurement methods and procedures (standards), indicating the responsible(s) for carrying out the measurement(s), dates and results of measurement(s) was provided? (check Annex 3)

/1/ /5/ /34/


B.6.3. Ex-ante calculation of emission reductions. Table 1 - 1, 3

B.6.3.1. Is the ex-ante calculation of the expected project, baseline and leakage emissions transparent, conservative, accurate, and documented and as per the approved / applied methodology (equations) of the

/1/ /5/ /34/





Final Concl.

project activity? B.6.3.2. Sufficient background information and / or

data to assess the calculation(s) and enable its reproduction, including electronic files (i.e. spreadsheets), was provided? (check Annex 3)

/1/ /5/ /34/


B.6.4. Summary of ex-ante estimation of emission reductions. Table 1 - 1, 3

B.6.4.1. Is all ex-ante estimation of emission reductions summarized in a (proper table) tabular form for all years of the crediting period? (Check against A.4.3.1 figures)

/1/ /5/ /34/

DR, I Yes OK

B.7. Application of monitoring methodology and description of the monitoring plan. Compliance of the monitoring plan with the approved methodology and Implementation of the plan

B.7.1. Data and parameters monitored. (background documentation in Annex 4)

B.7.1.1. Specific information on how the data and parameters that need to be monitored would actually be collected during monitoring for the project activity is provided? (measurements after the implementation of the project activity should be included here)

/1/ /5/ DR, I The PP needs to discuss the application of a monitoring methodology in the section B.7. Specific information on data and parameters requiring monitoring needs to be addressed precisely. The PP needs to correct the same. The PP needs to clarify on availability and credibility of their energy meter as mentioned in Annex 4, why the same has not been included in section B.7.1 of the PDD. The PP needs to include the receipt of money

CAR 4 OK




Final Concl.

which will confirm the generation occurred for the chosen duration.

B.7.1.2. Are all the parameters and its sources of data reliable, specified and documented in a (proper table) tabular form?

/1/ /5/ DR, I Please refer to B.7.1. CAR 4 OK

B.7.1.3. Where data or parameters are supposed to be measured, are measurement methods and procedures, including a specification of which accepted industry standards or national or international standards will be applied, specified?

/1/ /5/ DR, I Please refer to B.7.1 CAR 4 OK

B.7.1.4. Are the measuring instruments / equipments, measurement methods, accuracy and interval, measurement responsible(s) and calibration procedures specified?


B.7.1.5. Are the QA / QC procedures applied described and complying with existing good practice? (The parameters related to the performance of the project will be monitored using meters and standard testing equipment, which will be regularly calibrated following standard industry practices)


B.7.2. Description of 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.




Final Concl.

B.7.2.1. Is the monitoring methodology previously approved by the CDM Methodology Panel?

/1/ /5/ DR, I Yes the monitoring methodology is approved by the CDM Methodology panel. However, PP is requested to provide documents/ records mentioning the ownership of main and check meters. However the monitoring plan is not complete, data uncertainties and data apportioning procedures not clearly defined.

CL 6

CL 8

OK

B.7.2.2. Is the monitoring methodology the one deemed most applicable for this project and is the appropriateness justified?

/1/ /5/ DR, I See B.2.1. OK

B.7.2.3. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for estimation or measuring the greenhouse gas emissions within the project boundary during the crediting period?

/1/ /5/ DR, I The list of monitoring parameters is not clear, the PP is requested to clarify the same with supporting evidences and methods describing the monitoring.

The description on method of proportioning needs to be clear and point-wise. It needs to be clarified how it is being done and the level of certainty needs to demonstrated with relevant evidences/records.

CAR 4 OK

B.7.2.4. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining leakage?

/1/ /5/ DR, I Leakage is not applicable in this project activity although the same needs to be added in the PDD. The PP is requested to justify on the conditions under which unintended emissions may arise and subsequent measures to ensure that it can be accounted.

CL 6 OK

B.7.2.5. Is the authority and responsibility of project /1/ /5/ DR, I Yes, the authority and responsibility of project OK




Final Concl.

management clearly described? management is clearly described. B.7.2.6. Is the authority and responsibility for

registration, monitoring, measurement and reporting clearly described?

/1/ /5/ DR, I Yes, the authority and responsibility for registration, monitoring, measurement and reporting is clearly described

OK

B.7.2.7. Are procedures identified for training of monitoring personnel?

/1/ /5/ DR, I Procedures are identified for training of monitoring personnel

OK

B.7.2.8. Are procedures identified for emergency preparedness for cases where emergencies can cause unintended emissions?

/1/ /5/ DR, I Procedures for emergency preparedness for cases where emergencies can cause unintended emissions need to be identified.

CL 6

B.7.2.9. Does the monitoring plan reflect good monitoring and reporting practices?

/1/ /5/ DR, I Yes, it does. OK

B.7.2.10. Is the discussion and selection of all required monitoring parameters and / or data variables (for example, project emissions, project electricity generation, baseline grid / captive power emission factor) of the monitoring plan according to the approved / applied methodology transparent?

/1/ /5/ DR, I Please refer to B.7.1. CAR 4 OK

B.8. Date of completion of the application of the baseline and monitoring methodology and the name of responsible person(s) / entity(ies).

B.8.1. Is the date of completion of the application of the methodology to the project activity provided and mentioned in the format DD / MM / YYYY?

/1/ /5/ DR, I The date of completion of the application of the methodology to the project activity is 10/03/2009 and the same has been mentioned in the format DD/ MM/ YYYY.

OK

B.8.2. Is the contact information of the person(s) / entity(ies) responsible for the baseline and

/1/ /5/ DR, I The contact information of the person(s)/ entity (ies) responsible for the baseline and

OK




Final Concl.

monitoring methodology to the project activity provided?

If applicable, are they indicated as project participants in Annex 1?

monitoring methodology to the project activity has been provided in this section. M/s L. B. Kunjir and MITCON have been mentioned as responsible for the completion of the application of the methodology, M/s. L. B. Kunjir has been mentioned in the annex 1.

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

C.1. Duration of project activity. C.1.1. Starting date of project activity. C.1.1.1. Is the project’s activity starting date (the

earliest date at which either the implementation or construction or real action of a project activity begins - project participant has committed to expenditures related to the implementation or related to the construction of the project activity) clearly defined and reasonable?

/1/ /6/ DR, I The start date of the project activity is December 18, 2008 when the purchase order for the project activity was placed. The purchase order for the same was verified during the site visit.

OK

C.1.1.2. If the project activity started on or after 2 August 2008, were the Host Party DNA and/or the UNFCCC secretariat informed in writing of the commencement of the project activity and of the intention to seek CDM status? (If starting date is before 2 August 2008, see B.5.4)

/1/ /22/

DR, I Project activity start date is after August 2008. Hence the PP needs to provide evidence on intention to seek CDM status for this project activity communicated to the Host Party DNA and/or the UNFCCC secretariat in writing of the commencement of the project activity. Also refer to B.5.6

CL 3, CL 5

OK

C.1.2. Expected operational life time of the project.




Final Concl.

C.1.2.1. Is the project’s operational lifetime (mentioned in years and months) clearly defined and reasonable? (check against crediting period and equipment lifetime)

/1/ /16/

DR, I The operational lifetime of the project has been estimated to be 20 years. This needs to be substantiated with documentary evidence.

CL 7 OK

C.2. Choice of crediting period. The crediting period may only start after the date of registration of the proposed activity as a CDM project activity.

C.2.1. Is the chosen crediting period clearly defined (mentioned in years and months) and its starting date mentioned in the format DD / MM / YYYY? (renewable crediting period of seven years with two possible renewals or fixed crediting period of 10 years with no renewal)

/1/ DR, I Yes, the chosen crediting period is clearly defined which is for 10 years 0 months. The starting date of the crediting period has been mentioned as 01/05/2009 which needs to be changed as per the guidance from the EB, UNFCCC, the crediting period start date can be kept four weeks after the small scale project has been uploaded on the UNFCC interface. The PP needs to change the start date of the crediting period.

CAR 5 OK

D. Environmental impacts. If required by the host party, documentation on the analysis of the environmental impacts will be assessed, and if deemed significant, an EIA should be provided to the Validator.

D.1. Documents on Environmental impacts, including transboundary impacts.

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

/1/ DR, I The project activity does not fall under the purview of Environmental Impact Assessment (EIA) as per EIA Notification of Ministry of

CAR 3 OK




Final Concl.

Environment & Forests (MoEF), Government of India (GoI) dated 27 January 1994 and the amendment dated 14 September 2006. The PP is requested to address criterion that clears the project activity from the purview of EIA Notification of MoEF, GoI and the subsequent amendment.

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

/1/ DR, I Refer to D.1.1 CAR 3 OK

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

/1/ DR, I The project is not expected to create any significant negative environmental impacts.

OK

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

/1/ DR, I Please refer to D.1.3 OK

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

/1/ DR, I Please refer to D.1.3 OK

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

/1/ DR, I The legal and regulatory approvals are to be provided for verification.

CAR 3 OK




Final Concl.

E. Stakeholders’ comments. The Validator should ensure that stakeholders’ comments have been invited and that due account has been taken of any comments received.

E.1. Description of how comments by local stakeholders have been invited and compiled. The local stakeholder process shall be completed before submitting the proposed project activity to a DOE for validation.

E.1.1. Have relevant stakeholders been adequately consulted / invited for comments?

/1/ /11/ /12/ /13/ /40/

DR, I Yes, local villagers who are being affected by the project activity were invited through the invitation letters.

OK

E.1.2. If a stakeholder consultation process is required by regulations / laws in the host country, has the stakeholders’ consultation process been carried out in accordance with such regulations / laws?

/1/ /11/ /12/ /13/ /40/

DR, I Stakeholders were informed orally by the PP regarding the meeting and the same was conducted on February 21, 2009 at SISL office, Nashik, Maharashtra at 11:30 AM. Invitation letters, Minutes of meeting and filled questionnaire were verified during the site visit.

OK

E.1.3. Was the stakeholders’ consultation process conducted, within a reasonable time for comments submission, in an open and transparent manner to facilitate comments and properly described?

/1/ /11/ /12/ /13/ /40/

DR, I Not specifically required for wind farm projects under Indian legislation.

OK

E.2. Summary of comments received. E.2.1. Are the stakeholders who made comments

identified (addresses provided / available)? /1/ /11/

DR, I Yes, PP had circulated questionnaire to stakeholders and the same has been verified

OK




Final Concl.

/12/ /13/ /40/

during the site visit.

E.2.2. The summary of the stakeholders’ comments received is provided / available?

/1/ /11/ /12/ /13/ /40/

DR, I No negative comments were received for the proposed project activity.

OK

E.3. Report on how due account was taken of any comments received.

E.3.1. Has due account been taken of any stakeholders’ comments received?

/1/ /11/ /12/ /13/ /40/

DR, I Please refer to E.2.2 OK

Annex 1. (contact information on project participants) • Are the Names of all organization given? (as listed in

section A.3) /1/ DR, I Yes name of the organization as mentioned in

the section A.3 has been given. OK

• Name of contact person, Street, City, Post fix / ZIP, Country, Telephone Fax or e-mail mandatory fields are filled?

/1/ DR, I Yes, all has been provided in the table. OK

Annex 2. (Information regarding public funding) • Is information from Parties included in Annex I on

sources of public funding for the project activity provided?

/1/ /6/ /23/ /24/ /37/

DR, I This is a unilateral project hence there is no other party involved and no ODA has been taken for this project activity.

OK

• Does the information provided above include an /1/ /6/ DR, I NA OK




Final Concl.

affirmation that such funding does not result in a diversion of ODA and is separate from and is not counted towards the financial obligation of those Parties?

/23/ /24/ /37/

Annex 3. (Baseline information). • Is any needed further background information used in the

application of the baseline methodology, i.e. tables with time series data, documentation of measurement results and data sources, provided?

/1/ DR, I Refer to B.4.9 CAR 2 OK

Annex 4. (Monitoring information) • Is any needed further background information used in the

application of the monitoring methodology, i.e. tables with time series data, documentation of measurement results and data sources, provided?

/1/ /5/ DR, I Yes, the table on QA/QC procedure, data monitoring, archiving has been provided.

However, the PP is requested to clarify on following issues on monitoring,

1. How to identify if meters are functioning ok or faulty in between calibrations and what will happen to those readings recorded with faulty meter?

2. What is the calibration frequency ?

3. What is the permissible deviation between the main meter and check meter, to identify the faulty meter?

4. What about data apportioning in case the monitoring period start and end date does not coincide with the JMR date ?

CL 8 OK



Table 3 Resolution of Corrective Action and Clarification Requests


Ref. to table 2

Summary of project participants’ response

Validation team conclusion

CAR 1 The Host Country Approval needs to be provided. The PP is requested to provide evidences on compliance on all GHG emission reduction related regulatory and legislative requirements.

Table1 - 2 and 4,

Table 2 – A.1.1,

A.2.3.1, A.2.3.2, A.2.3.3

Scanned copy of the Host Country Approval is submitted to the DOE.

The Host country approval letter dated 29th June 2009 for this project activity has been provided. The HCA confirms that the project activity is voluntary participation and contributes to Sustainable Development in India. CAR 1 is closed.

CAR 2 The PP needs to correct the category type as per Appendix B of “Simplified modalities and procedures for small-scale clean development mechanism project activities” The PP needs to justify the chosen version of the CEA database with respect to the decision making to go ahead for the project activity.

Table 2 - A.4.2, B.2.2, B.4.9,

B.6.1.1, B.6.1.2, B.6.1.3, B.6.1.4, B.6.2.1, B.6.2.2, B.6.2.3, B.6.3.1, B.6.3.2, Annex 3

The type and category of the project as per Appendix B of “Simplified modalities and procedures for small-scale clean development mechanism project activities” has now been rectified in the PDD. Please refer to section A.4.2 of the PDD. The decision on the project was taken in December 2008. During this period CEA database version 4 was published and same has been considered for the present case. This is in line with the requirement of tool to calculate the emission factor.

The same has been addressed in the revised PDD version 02 and found acceptable. Version 04, CEA database has been considered for the project activity as the same was applicable at the time of decision making. This query is closed.




Ref. to table 2



The PP also needs to justify the method chosen for calculating emission factor in line with methodology requirement. In the PDD section A.2 the evacuation of energy is mentioned as 2.68 GWh which needs to be corrected as it will come at 2.628 GWh.

As per the methodology AMSI D version 13, paragraph 9, “an emission coefficient (measured in kg CO2e/kWh) calculated in a transparent and conservative manner as: (a) A combined margin (CM), consisting of the combination of operating margin (OM) and build margin (BM) according to the procedures prescribed in the ‘Tool to calculate the emission factor for an electricity system’. OR (b) The weighted average emissions (in kg CO2e/kWh) of the current generation mix. The data of the year in which project generation occurs must be used. PP has chosen the most conservative value out the above two, which comes from option b i.e. weighted average emission factor, hence appropriate as per the methodology. This has been rectified in the revised version of PDD and the value has been changed from 2.68 to 2.628 GWh.

The chosen approach for calculation of emission factor is in line with the guidance provided by the methodology and found acceptable. This query is closed. The same has been corrected in the revised PDD version 02 . This query is closed. CAR 2 is closed.




Ref. to table 2



CAR 3 The discussion on the additionality needs to be more specific, clear and specifically referenced. The project activity does not fall under the purview of Environmental Impact Assessment (EIA) as per EIA Notification of Ministry of Environment & Forests (MoEF), Government of India (GoI) dated 27 January 1994 and the amendment dated 14 September 2006. The PP is requested to address criterion that clears the project activity from the purview of EIA Notification of MoEF, GoI and the subsequent amendment. The legal and regulatory approvals are to be provided for verification.

Table 2 –D.1.1, D.1.2, D.1.6

The discussion on the additionality is now more specific, clear and specifically referenced. Please refer to section B.5 of the PDD for further details. This has been addressed in the revised version of PDD and all criterion that clears the project activity from the purview of EIA Notification of MoEF, GoI and the subsequent amendment has now been explained in the section D.1 of the revised PDD. All legal and regulatory approval has now been provided to the DOE for verification. Same has been included in the section D.1 of the PDD.

PP has included detailed discussion on additionality and its applicability in the revised PDD version 02 . This query is closed. The same has been incorporated in the section D.1 of the revised PDD version 02 and found correct. This query is closed. The list of applicable approvals has been included in the section D.1 of the revised PDD version 02. CAR 3 is closed.

CAR 4 The PP needs to discuss the application of a monitoring methodology in the section B.7.

Table 2 – B.7.1.1, B.7.1.2, B.7.1.3, B.7.1.4, B.7.1.5,

Application of the used monitoring methodology i.e. AMSID version 13 has discussed in section B.7.1 of the methodology.

Application of monitoring methodology has been applied correctly in the section B.7 of the revised PDD version 02.




Ref. to table 2



Specific information on data and parameters requiring monitoring needs to be addressed precisely. The PP needs to correct the same. The PP is requested to clarify the same with supporting evidences and methods describing the monitoring.

The list of monitoring parameters is not clear, the PP is requested to clarify the same with supporting evidences and methods describing the monitoring.

The PP needs to clarify on availability and credibility of their energy meter as mentioned in Annex 4, why the same has not been included in section B.7.1 of the PDD.

B.7.2.3, B.7.2.10,

Same has been corrected in the revised version of PDD. Please refer to section B.7.1 for further clarification. The method of apportioning has been described in details under heading Apportioning of electricity supplied to the Feeder in section B.7.2 of the revised PDD. The list of monitoring parameter is now described clearly and only specific information as required by the monitoring methodology has been included in the section B.7.1 of the PDD. There is no energy meter of the PP, it is the WTG controller mentioned in the annex 4 of the PDD. Same has been corrected in the revised version of PPD and now has been discussed in section B.7.2 of the PDD. SCS

All parameters are incorporated as per the requirement of monitoring methodology and found correct. The same has been addressed with clarity in the section B.7.2. of the revised PDD version 02. All parameters are incorporated in the section B.7 of the revised PDD, version 02 as per the requirement of monitoring methodology and found correct. There is no energy meter that is under PP’s control, however, there is a SCS controller attached with the WTG to monitor its generation and control the WTG. The supporting evidence has been provided by




Ref. to table 2



The PP needs to include the receipt of money which will confirm the generation occurred for the chosen duration.

Controller is a micro-processor based intelligent controller which has been specially designed for control of wind turbines. It uses a Woodward Multi function Relay that has three current inputs from CT and three direct voltage inputs (690 Volts). The analog values of current/voltage are converted into digital signal internally using A/D Converters at very high sampling rate. A software program reads these values and displays instantaneous parameters such as voltage, current, power factor, kVAh, kVArh and kWh. These instantaneous values are then time integrated and displayed/stored. Woodward relay does not have a display and needs special protocol to view energy readings as this relay communicates digital signal through special communication protocol. In case of Malfunctioning of the controller, the WTG is programmed for automatic shut-down. Hence probability of error in controller meters is negligible Same has been discussed in section B.7.1 of the PDD.

the O & M contractor. The same has been included in the section B.7.1 of the revised PDD version 02 .




Ref. to table 2



The description on method of proportioning needs to be clear and point-wise. It needs to be clarified how it is being done and the level of certainty needs to demonstrated with relevant evidences/records.

The description on the method of proportioning is now described in more transparent manner in the section B.7.2 of the PDD.

Method of proportioning has been clearly described in the section B.7.2 of the PDD version 02 which are transparent as to how the same will be carried out and how the authenticity will be ensured. CAR 4 is closed.

CAR 5 The PP needs to change the start date of the crediting period.

Table 2 – C.2.1

Start date of the crediting period is now appropriately modified.

The start date of the crediting period has been appropriately changed. CAR 5 is closed.




Ref. to table 2



CL 1 The project participant (PP) needs to change the version number from 00 to 01. The PP is requested to justify major benefits described in the PDD with supporting evidences.

Table 2 – A.1.1, A.4.1,

The version of the PDD is now revised. The project will lead to Increase in employment opportunities, superior pricing of land and cost economy due to conservation of conventional fuel are some of the associated economic benefits of the project activity. Besides this, the generated electricity will be fed into the Integrated NEWNE grid. This will improve the grid frequency and availability of electricity to the local consumers. With better access to electricity, new opportunities for industries and economic activities will arise in the area thereby resulting in greater local employment.

The same has been observed in the revised PDD which is version 02 and found correct. This query is closed. The said benefits are related directly and/ or indirectly with the project activity. This project activity will contribute in sustainable development of the host country. This query is closed. CL 1 is closed.

CL 2 The PP needs to provide all sources from where the information has been used in the PDD. All original copies of sources/ evidences used in the PDD needs to be provided for

Table 2 – B.1.4, B.4.9, B.5.2,

All sources used in the PDD have been provided to the DOE. All original copies of sources/evidences

Sources used in the PDD version 02 have been provided in the revised version of the same and found ok. Original copies of relevant clearances,




Ref. to table 2



verification The PP is requested to indicate the tool from where the guidance has been taken. (wherever applicable)

used in the PDD have been shown to the DOE for verification. This has been addressed in the revised version of PDD.

approvals, CDM consideration, and purchase orders have been provided to the validation team and was found to be in order. The same has been incorporated in the revised PDD version 02 and found acceptable. CL 2 is closed.

CL 3 The project participant is requested to furnish the notification sent to DNA/UNFCCC of the commencement of the project activity and their intention to seek CDM status since the project start date is after 2nd August 2008. PP needs to provide evidence on intention to seek CDM status for this project activity communicated to the Host Party DNA and/or the UNFCCC secretariat in writing of the commencement of the project activity.

Table 2 – B.5.4, B.5.5, C.1.1.2

Evidence (acknowledgement email along with attached letter) for the same is submitted to the DOE.

The request sent to UNFCCC was provided to the validation team and it can be concluded from the same that, PP had intimated UNFCCC in the month of January 2009 which is within six months from the starting date of the proposed project activity. Hence accepted. CL 3 is closed.

CL 4 The PP is requested to provide justification on selection and the appropriateness of the chosen benchmark as per the EB guidance on investment analysis along with supporting

Table 1 - , Table 2 –

B.5.6,

Since the project is funded by both equity and debt, instead of equity IRR, project IRR has been considered as an appropriate financial indicator for the project activity. Accordingly, Prime Lending Rate (PLR)

As the project activity is funded through debt and equity, the major part of the funding comes from the debt component. Hence the PLR is appropriate benchmark for the project activity.




Ref. to table 2



documents.

has been selected as the benchmark. Annex 45 of EB 41 states that where the project IRR is used to demonstrate the additionality of the project, WACC or the commercial lending rates are suitable benchmarks. The PP has therefore chosen the commercial lending rate – Prime Lending Rate (PLR) – as the benchmark. Investment decision for the project was made in December 2008. The PLR of RBI was 12.75-14.004% during the period. Furthermore acting on this particular CAR raised by the DOE on the appropriateness of the benchmark considered, the same has been changed to 12.75% (discussed in section B.5 of the PDD) which is lowest of the range i.e. 12.75-14.00 and is a conservative approach. The Banks are expecting a return of 12.75% without any risk of the project activity. The PP has considered the same benchmark for evaluating the financial feasibility of the project activity which is reasonable with reference to risks

As the conservativeness can also be observed since the PLR for the year 2008-09 was in range from 12.75 to 14.00 as per Reserve Bank of India. The PP has chosen the lowest as their benchmark which demonstrates conservativeness in benchmark selection. Returns for this project activity were computed based on this benchmark. The validation team assessed the appropriateness of this benchmark chosen by the PP by referring to the link provided and noted that the same is representative to the month of July 2008. The validation team cross verified the weekly reports available

4 http://rbi.org.in/scripts/PublicationsView.aspx?id=10292 5 http://www.mercindia.org.in/pdf/Ord_20_11_2007_CNo_33_of_2007.pdf 6 http://www.mercindia.org.in/pdf/Detail_Wind_Energy_Order.pdf




Ref. to table 2



The PP needs to also clarify on the source for the electricity generation value and transparently discuss the PLF considered. The PDD is not transparent on how the PLF is estimated and justified as to how it is in line with the EB 48 guidelines on reporting of PLF

associated with the project, such as Wind Availability, Grid Availability, and Machine Availability etc. Hence the lowest range of Prime Lending Rate prevailing at the time of decision making is most appropriate and conservative benchmark for the present project activity and the project developer would definitely expect a retune of this tune from the project and it is deemed to be a realistic expectation. The Plant Load factor considered for the present case ( i.e. 20%) is appropriate as per EB -48, annex 11, GUIDELINES FOR THE REPORTING AND VALIDATION OF PLANT LOAD FACTORS, Bullet no.3, Which states that

The plant load factor shall be defined ex-ante in the CDM-PDD according to one of the following three options:

(a) The plant load factor provided to banks

and/or equity financiers while applying the project activity for project financing, or to the government while applying the

at the RBI site to note that the PLR as at the month of November in the published report dated 12/12/2008 refers to a range of 13.00% to 13.50% (http://www.rbi.org.in/scripts/WSSView.aspx?Id=13042). The value chosen by the PP being conservative, the validation team accepted 12.75 % benchmark chosen by the PP. The validation team agrees that this assumption of PLF is in line with the “Guidelines for the Reporting and Validation of Plant Load Factors”, paragraph 3a, Annex 11of EB 48 and based on credible source (the loan application & Letter from Bank of Baroda)




Ref. to table 2



The PP needs to submit the commercial calculation provided by SEL for verification. As per the guidance provided on the assessment on Investment Analysis, point number 4 regarding the fair value of the project activity asset. The PP is requested to kindly justify the value chosen for residual value of the asset (5%)

project activity for implementation approval;

(b) The plant load factor determined by a third party contracted by the project participants (e.g. an engineering company);

For the present case sub-bullet (a) is applicable as this PLF has been provided to the Bank for the sanction of term loan. Evidence for the same is enclosed. Commercial calculation from SEL is submitted to the DOE. It is to be noted that PP has done separate investment analysis from an independent Charted Accountant to take a decision on the project. SEL financials has not been considered in the decision making contest. Scanned copy of the Commercial calculation from SEL has been Submitted to the DOE. Point no. 4 of the referred guidance has been duly considered in the IRR calculation sheet. The residual value considered for the present case is 5% based on the MERC Order November 2003,

The commercial calculation provided by the technology provider has been provided to the validation team. The residual value of 5% has been taken as per the Maharashtra Electricity Regulatory Commission guidance which is accepted.




Ref. to table 2



It is not transparent why the escalation in tariff is not considered in IRR calculations

http://www.mercindia.org.in/pdf/Annexures.pdf , page no. 174 of 176, bullet no.22 Escalation in tariff has been considered in the IRR calculation. The Project Proponent has signed a power purchase agreement with MSEDCL to supply power generated from the wind mill at the rate of Rs. 3.50/KWh for first year and subsequent escalation of 0.15 INR per year. The PPA is valid for a period of 13 year, after which the purchase rate has not been specified by MERC. Hence in absence of any guideline the project promoter has considered the base price of Rs. 3.50 for 14th year to 20th year. This approach is substantiated by the fact that as per MERC order5 dated November 2007( Case No. 33 of 2007) the tariff rate of Group II projects was frozen at 90% of the lowest HT Tariff. Similar treatment was anticipated for this project activity as well. Adding further, the State Electricity Commission has hinted at reduction in this tariff rate after the 13th year. The following excerpt from MERC order6 dated 24th November 2003 corroborates the point further-

As per the explanation provided by the PP and clarification provided in the MERC order regarding the escalation in the tariff. The validation team assessed the same and also observed that there are no projects from Group III who have reached the 13th year stage. It was also observed from the MERC order dated 20 November 2007 that PP should consider only O&M cost and Incidental cost for tariff after the tenure is over for group II. Since the PP has taken the base price of INR 3.50 per kWh with escalation of INR 0.15 annually up to the 13th year and then on capped the price for the rest of the period, this is conservative and hence accepted by the validation team.




Ref. to table 2



Further most of the assumptions in the IRR sheet are based on post decision documents and hence cannot be accepted. As per the guidance provided in the tool for demonstration and assessment of additionality version 5.2, guidance point no. 6, the PP needs to use input values for all investment analysis should be valid and applicable at the time of the investment decision taken. The PP is also requested to provide clarification on the pre-tax/ post-tax returns comparison with the benchmark. The PP is requested to

As per section 1.4.2 Salient features of the Tariff Proposal of MERC Wind Tariff order 2003 Page 14 Para 1 and 2 “ The Commission notes that in Cost Plus Approach, which the Commission has adopted for tariff proposal, rate per unit charged by such projects during initial period of 10 years is bound to be higher as during this period the project has various debt related obligations. However, it is essential that the consumer is able to enjoy the benefit of cheaper power once all debt related obligations are paid off and project has virtually no variable costs.” This has been addressed in the revised version of IRR sheet & PDD, where all assumptions taken for the financial calculation is prior to the start date of the project activity i.e. at the time of decision making. The PP has compared post-tax returns with the benchmark. The PP considered the

All input values have been taken as per the guidance from the EB to take input values which were applicable at the time of decision making. Debt-equity ratio has been considered




Ref. to table 2



provide the use of this arrangement consistently in their investment decisions for last three years. The PP needs to justify that even considering the financial benefits from CDM the IRR reaches to 11.66% which is still lesser than the

post-tax returns as the same are actually physically available with the PP. The financial working has been revised as per the Guidance 11, EB 51, annex 58. A post tax benchmark is applied to test the viability of the project. As per this guideline the IRR calculations has been revised as per the terms and conditions of recently acquired debt by the PP, which was available with the PP at the time of conceptualization. As per this loan sanction letter which was acquired for purchase of construction machinery, the terms of sanction was as follows:

• Rate of interest- 12.25%, • Equity Margin - 29% and • Repayment period of 60 months

(including 1 month moratorium). The same has been considered in the financials working to comply with the stipulations made under Guidance 11, EB 51 annex 58. Please refer to the revised Investment analysis of the project; it is evident that

according to their investment pattern in last three years, which is as per the guideline provided in point no. 11, “Guidelines On The Assessment Of Investment Analysis”, Version 03, Annex 58, EB 51. The same was verified by the validation team through loans taken by the PP in the last three years span from which it was noticed that the PP had only one loan availed for the procurement of vehicles and is at 71:29 debt-equity ratio. Hence the Debt-equity ratio of 71:29 is accepted.




Ref. to table 2



benchmark 13.30%, why should the project be taken at all, even with financial benefits, it falls short of the benchmark? The PP needs to justify the error in application of figures in the financial excel sheet and in the PDD. The PP is requested to incorporate point number 9, Annex 45, EB 41, while calculating the project IRR. The PP is also requested to provide written confirmation from the independent chartered accountant on verification of profitability, cash

with the inclusion of CDM benefit Project IRR tends to 10.55 to 12.78%, which crosses the revised benchmark of 12.75%. Same rate of CER, which has been considered in the financials prepared at the time of decision making has been considered in the revised IRR excel sheet. Financials on which decision on the project was taken by the partner’s has been submitted to the DOE. According to point number 9, Annex 45, EB 41, “The cost of financing expenditures (i.e. loan repayments and interest) should not be included in the calculation of project IRR.” The repayment amount of loan is not a part of the Profit and Loss Account and so the same has not been included in the calculations of Project IRR. Further the interest on loan is debited to Profit and Loss Account, the same has been added back in the cash flow while calculating the Project IRR. Please refer the financials. The written confirmation from an independent charted accountant on

The same has been incorporated in the revised calculations which clearly reflect the point 9, Annex 45, EB 41.




Ref. to table 2



flows and assumptions made for calculations made for implementation of this project activity. The PP needs to consider the O & M costing for sensitivity analysis, as the cumulative amount reaches more than 20 % of the project cost, hence the same needs to be considered. The PP is also requested to clarify on the sensitivity analysis carried out for generation with PLF consideration as to how the same has been carried out. PP is requested to carry out the sensitivity analysis by varying parameters until the

profitability, cash flows and assumptions made for calculation is submitted to the DOE. This has been addressed in the revised version of PDD and sensitivity analysis has now been carried out on variation of the O & M cost. The robustness of the investment analysis has been further appreciated by the fact that even with 10% decrease in the O & M cost the IRR of the project does not crosses the bench mark considered. Electricity generation from the project is the most important and critical parameter & hence viability of the project will be affected by any fluctuation in this parameter. To estimate the electricity generation from the project 20% Plant Load factor has been considered, hence sensitivity analysis of PLF has been carried out as variation of this directly affects the electricity generation from the project. This has been addressed in the revised version of PDD. Please refer to section B.5

The written confirmation from an independent charted accountant on profitability, cash flows and assumptions made for calculation is submitted to the validation team and found acceptable. Operation and maintenance has been included in the sensitivity analysis as per the guidance provided by EB. Electricity generation parameter has been based on the plant load factor of the project and the same has been varied in order to conduct the sensitivity analysis.




Ref. to table 2



benchmark is reached and the likelihood for that to happen need to be supported by evidences. The PP needs to carry out the barrier due to prevailing practice as per the guidance given in ““Tool for the demonstration and assessment of additionality”, version 05.2.

of the PDD where break-even point of each parameter subjected to sensitivity analysis has been clearly defined. This analysis of the break-even point demonstrates the robustness of the investment analysis and it is also evident from the analysis that likelihood of crossing the benchmark based on the assumptions taken is not possible and the project is financially unattractive. In absence of supporting evidences, this has been removed from the revised PDD.

The PP has addressed the same in the revised PDD and for all three parameters PP has conducted the sensitivity analysis as per the guidance. The PP has removed this barrier from the PDD since the same could not be demonstrated by sufficient evidences. CL 4 is closed.

CL 5 The PP needs to provide the chronological order of events with supporting evidences.

Evidences need to be provided on:

1. PP’s awareness to CDM prior to start date

2. Whether CDM has been the decisive factor to go-ahead with the project considering the gap between purchase orders placed for

Table 2 – B.5.6, C.1.1.2

Chronology of events has been included in the section B.5 of the revised PDD. PP has intimated the CDM EB vide its e-mail dated 06th January 2009, immediately after the release of purchase order of the WTG (PO was released on 18/12/2009- start date of the project activity). Since the start date of the project activity is after 02 August 2008 and the project

Chronology of events has been incorporated in the revised PDD and supporting documents have been provided to the validation team. The validation team has assessed all evidences and found them in order. Awareness on CDM can be observed from




Ref. to table 2



two WEGs.

The PP also needs to provide evidences on intimations sent to the EB, UNFCCC regarding their intention to seek CDM status of their project activity as per EB 48, Annex 61.

participant had informed the UNFCCC secretariat in writing of the commencement of the project activity and of their intention to seek CDM status, thus the project fulfils the stipulations made under Annex 22 of EB 49. Evidence for the same has been submitted to the DOE.

the chronology of events that the PP was aware of CDM and its benefits. The PP has done the investment analysis based on the best offer provided by the technology provider and carries out the computation for returns of the project. It was observed that the project activity will not be viable without CDM benefits. CL 5 is closed.

CL 6 PP is requested to provide documents/ records mentioning the ownership of main and check meters. Leakage is not applicable in this project activity although the same needs to be added in the PDD. The PP is requested to justify on the conditions under which unintended emissions may arise and subsequent measures to ensure that it can

Table 2 - B.7.2.1, B.7.2.4, B.7.2.8,

The ownership of the main meter and check meters lies to the state utility and PP has no control over this. The sentence which states that “the main meter has been installed and owned by MSEDCL, whereas the project participant owns the check meters” has been removed from the revised PDD. Leakage is not applicable for this project activity and same has now been included in the revised version of PDD. Being a Wind Power Project there is no unintended emissions may arise from the project. Sentence stating this claim has

The sentence claiming the ownership has been removed from the revised PDD version 02. The non applicability of leakage has been addressed in the revised PDD version 02. The same has been incorporated in the revised PDD version 02 .




Ref. to table 2



be accounted. Procedures for emergency preparedness for cases where emergencies can cause unintended emissions need to be identified.

now been removed from the revised version of PDD. Being a Wind Power Project there is no unintended emissions may arise from the project. Hence there are no procedures for emergency preparedness for cases where emergencies can cause unintended emissions. Sentence stating the claim of unintended emissions has now been removed from the revised version of PDD.

Since there are no unintended emissions taking place in the project activity, no emergency preparedness procedures have been identified. CL 6 is closed.

CL 7 The operational lifetime of the project activity needs to be substantiated with documentary evidence.

Table 2 – C.1.1.1, C.1.2.1

Evidence pertaining to the operational life time of the project activity is submitted to the DOE.

Evidence on lifetime of the equipment from the equipment supplier has been provided to the validation and it is found acceptable. CL 7 is closed.

CL 8 The monitoring plan is not complete, data uncertainties and data apportioning procedures not clearly defined.

the PP is requested to clarify on following issues on monitoring,

1. How to identify if meters are functioning ok or faulty in between calibrations and what will happen to those readings recorded with faulty

Table 2 - B.7.2.1, Annex 4

Data uncertainties and data apportioning procedures have now been clearly defined in the section B.7.2 of the PDD. 1. The reading from both main meter and check will be matched every month and if the difference will be more, the meters will be subjected to the calibration.

Data apportioning procedures have been provided by the O & M contractor who is also responsible for maintaining the wind farm. These procedures are taking consideration into account on requirements from the state electricity distribution company.




Ref. to table 2



meter?

2. What is the calibration frequency ?

3. What is the permissible deviation between the main meter and check meter, to identify the faulty meter?

4. What about data apportioning in case the monitoring period start and end date does not coincide with the JMR date ?

2. Both main meter and check meter are scheduled to calibrate annually, however the calibration lies to the state utility and PP has no control over it. 3. As per PPA, Section 11.02(d) “if during any of the monthly meter reading, the variation between the main meter & the check meter is more than 0.5%, all the meters shall be re-tested and calibrated immediately by MSEDCL” Hence the permissible deviation between the main meter and check meter is 0.5% to identify the faulty meter. 4. In this peculiar condition, PP will not consider the said period for the calculation of CERs.

Procedures on identification of faulty meters are in place. In addition measures are included to deal with such events. As both meters are in purview of state utility, the PP has to approach the state utility for carrying out the calibration. The provision has been provided in the signed PPA that in case where deviation found between main and check meter, both meters would be subjected to calibration immediately and the allowable deviation is set at 0.5 %. It is reported and made transparent in the PDD that incase when monitoring period and JMR dates are not matching, the PP will not claim the emission reductions for that period, which is conservative and hence accepted. CL 8 is closed.

RINA è accreditato da UNFCCC, quale Entità Operativa Designata (DOE), per condurre la Validazione e la Verifica di Progetti CDM RINA is accredited by the UNFCCC, as Designated Operational Entity (DOE), to carry out Validation and Verification of CDM Projects

CDM_QUAL_CERT_EN-04-09 Page 1 of 1

CERTIFICATO DI QUALIFICA CDM CDM QUALIFICATION CERTIFICATE

Si attesta che il sig./sig.ra: We declare that Mr/Mrs/Ms:

Michela Gallo

è qualificato come: is qualified as:

CDM-VAL, CDM-VER, CDM-TL

per i seguenti settori (CDM) e principali aree tecniche: for the following Sectoral Scopes (CDM) and main technical areas:

SCOPO SETTORIALE SECTORAL SCOPE

CODICE RINA RINA CODE

AREA TECNICA TECHNICAL AREA


1 C.1 - 1-Biomass - 7,8,9- Non Renewable sources - 10-Waste incineration

- C11 - C17, C18, C19

- C110

3 C.3 - 3-Water supply - 4-Household/industrial electric

machinery and apparatus/equipment

- C33 - C34

4 C.4 - 2-Pulp and paper - 5-Rubber and Plastics - 6-Clay products - 7-Glass - 8-Ceramics - 9-Electrical /electro technical - 11-Iron and Steel production

- C42 - C45 - C46 - C47 - C48 - C49 - C411

13 C.13 - 1-Landfill - 2-Incineration - 3-Waste water - 4-Hazardous - 5-Methane collection/flaring

- C131 - C132 - C133 - C134 - C135

in accordo alle istruzioni della Divisione Certificazione e Servizi. in accordance with the instructions of the Certification and Services Division.

REVISION REVISION

DATA DATE

MOTIVAZIONI PER LA REVISIONE REASON FOR THE REVISION

0 31-01-2008 - 1 04-05-2009 ANNUAL REVISION

Il Responsabile di Schema Scheme Manager

Il Resp. Tecnico della Divisione Head of CRT

RINA è accreditato da UNFCCC, quale Entità Operativa Designata (DOE), per condurre la Validazione e la Verifica di Progetti CDM

RINA is accredited by the UNFCCC, as Designated Operational Entity (DOE), to carry out Validation and Verification of CDM Projects




SHIVRAJ SHARMA


CDM-VAL






1 C.1 1-Biomass 2-Hydropower 4-Wind Power

C11 C12 C14

5 C.5 - - in accordo alle istruzioni della Divisione Certificazione e Servizi. in accordance with the instructions of the Certification and Services Division. REVISION REVISION

DATA DATE


0 3-06-2009 -

Il Responsabile di Schema Scheme Manager

Il Resp. Tecnico della Divisione Head of CRT






Dhanya Nambiar


CDM-VAL






1 C.1 - 1-Biomass, - 4-Wind Power

- C11 - C14

13 C.13 - 2-Incineration - 3-Waste water - 5-Methane collection/flaring

- C132 - C133 - C135

14 C.14 - 1-Forest Land - 2-Wetland

- C141 - C142

15 C.15 - 3-Biomass management & treatment

- C153

in accordo alle istruzioni della Divisione Certificazione e Servizi. in accordance with the instructions of the Certification and Services Division. REVISION REVISION

DATA DATE


0 07/11/08 - 1 08/06/09 Annual revision

Il Responsabile di Schema

Scheme Manager Il Resp. Tecnico della Divisione

Head of CRT






Rekha Menon


CDM-VAL






1 C.1 - 1-Biomass - 4-Wind power; - 5-Solar energy - 6-Photovoltaic energy

- C11 - C14 - C15 - C16

3 C.3 - 4-Household/Industrial electric machinery & apparatus/equipments

- C34

13 C.13 - 1-Landfill - 3-Waste water - 5-Methane collection/flaring

- C131 - C133 - C135

in accordo alle istruzioni della Divisione Certificazione e Servizi. in accordance with the instructions of the Certification and Services Division.

REVISION REVISION

DATA DATE


0 06/03/2008 - 1 04/05/2009 Annual revision

Il Responsabile di Schema

Scheme Manager Il Resp. Tecnico della Divisione

Head of CRT