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VALIDATION REPORT
CLARION POWER
CORPORATION LIMITED
VALIDATION OF THE
12 MW GRID CONNECTED
BIOMASS POWER PLANT
Executive Summary:
M/s Clarion Power Corporation Limited (CPCL) has established a 12 MW grid connected biomass based
power project at village Tanguturu; district Prakasam, Andhra Pradesh, India. The project intends to use locally
produced low cost biomass waste and biomass generated through agro forestry projects. It is assumed that
the biomass energy generation is carbon neutral when biomass is harvested sustainably (reference: Revised
IPCC Guidelines 1996, Volume 1) and hence, considered net zero emitting for carbon-di-oxide (CO2)
emissions. Thus, CPCL proposes a cleaner electricity generation project compared to the existing fossil fuel
dominated local grid.
This report summarizes the results of the document review, background investigation, follow-up interviews with
local stakeholders and the staff at the project site during the visit to the CPCL power plant at Tangutur (Andhra
Pradesh). This has been during and after the process of the stakeholder consultation wherein the draft CDM
PDD of the proposed project was available on the UNFCCC CDM web site.
This process enabled the team to conduct a risk-based review of material issues with impact on future claims
of the emission reduction from the project. The concerns thereof, in the form of draft validation findings have
been registered in the Validation protocol.
The process of validation was performed on the basis of the UNFCCC established criteria, which refer to the
Kyoto Protocol criteria and the simplified modalities and procedures for small-scale CDM project activities.
The relevant host country criteria CDM interim approval criteria as available on the Ministry and Environment
and Forests (MoEF) web site are also considered.
Several concerns as elicited in the validation protocol have been raised in the form of 14 clarifications and 2
corrective action requests resulting in corrections required to the draft CDM PDD and its annexes as well as
evidences on meeting with the host country “sustainability development indicators’ of the CDM – interim
approval criteria (http://envfor.nic.in/divisions/ccd/cdm_iac.html). The report summarizes TUV Rheinland
Group’s opinion of the project activity as described in the project design document of (January 05) has met
with all the requirements of CDM and correctly applied the methodology suggested (I.D small-scale CDM
project activities). The relevant host country criteria have been evaluated by TUV Rheinland and are also
noted in the Authorization Letter (F.NO. 4/10/2003-CCC dated April 12, 2004) granted to the project by the
DNA for the project meeting with the sustainability criteria.
Therefore, TUV Rheinland Group requests the registration of the above-mentioned project as a CDM project.
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2 METHODOLOGY....................................................................................................... 5
2.1 Review of Documents 6
2.2 Follow-up Interviews 8
2.3 Resolution of Clarification and Corrective Action Requests 8
6 REFERENCES........................................................................................................... 24
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1 INTRODUCTION
Clarion Power Corporation Limited (CPCL), India has commissioned TUV Industrie
Service GmbH TUV Rheinland Group to validate their 12 MW (Gross) biomass based
power project in Prakasam district of Andhra Pradesh as a CDM project. The project is
expected to avoid 275,281 tCO2 due to replacement of some of the grid electricity by
clean biomass based electricity generation as per draft CDM PDD (June 2004).
CPCL is a small scale project as per the applicability criteria of small-scale modalities and
procedures and is, therefore, applying the simplified methodologies for baseline
determination and monitoring plans as specified in Appendix B of Annex II of Decision
21/CP.8 (Type I – D).
The objective of the validation report is to give validation opinion on this CDM project. The
scope of the work is to review the draft CDM PDD, its annexes, other relevant documents,
publish draft PDD and get opinion of global stakeholders arrive at a validation opinion and
submit the report to CDM executive board.
The service of the entire validation was performed by members of the TUV Rheinland
Group. The members of the validation team are as follows:
1.1 Objective
This report is representing the findings of the validation exercise along with the
methodology applied for validation, compliance of the project with the requirements of
- Kyoto protocol,
- Small-scale modalities and procedures (appendix B of Annex II to decision
21/CP.8)
- Guidelines issued by UNFCCC for validation of the project
- IETA/PCF Validation and Verification Manual v 4.0
It has checked
- Format of the documents as required by UNFCCC
- Additionality of the project
- Criteria for sustainable development by the host country (India),
- Baseline of the project
- GhG emission accounting practice
TUV Rheinland group when arriving at its opinion applied the above-mentioned criteria.
The project has followed the methodology as explained in quotation numbered
TUV/PNE/Qvs4002is/0602/ms dated February 5, 2004 and to the revisions thereof.
1.2 Scope
The scope of the audit is as follows
Review of the draft CDM PDD for preparation to publish the PDD (s) exclusive of
confidential data
Publication of draft CDM PDD without confidential data
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1
Data as referenced in the draft CDM PDD and information as available from www.cea.nic.in, www.mnes.nic.in,
www.ercap.org and www.npcil.org
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2 METHODOLOGY
The validation process consists of the following phases:
I Review of documents
A. Review of the CPCL’s documentation both on-site and off-site
B Desk review of identified supporting documents
II Site visit and follow-up interviews with project stakeholders (22-23 September 2004)
III Issue of the Draft Validation Report
IV Resolution of outstanding issues and the issuance of the final validation report and
opinion.
2
Reference: ASCI, Centre for Energy Environment and Technology, Hyderabad, February 2002, Biomass Resource Assessment
Studies for Andhra Pradesh, Vol. II and NEDCAP, 1997, District wise biomass assessment of Andhra Pradesh by prepared by
expert committee constituted by government of Andhra Pradesh through GO No. 5, dated 20th January 1997
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3 VALIDATION FINDINGS
In the following paragraphs observations of TUV Rheinland Group with respect to the review
of documents as well as observations and interviews during the site visit are noted. The
project was observed for compliance with requirements of Kyoto Protocol, Decision CP/21.8,
host country’s criteria for sustainable development and guidelines provided by UNFCCC. A
detailed account of the findings is documented in the “validation protocol” appended as
Appendix-A to the main report.
Where TUV Rheinland Group has identified issues that needed further inputs or those that
represent a risk to the fulfilment of the project objectives, a Clarification Request (CL) or
Corrective Action Request (CAR) respectively, have been raised upon identification of these
issues. The CL and CAR are stated, where applicable, in the following sections and are
further documented in the Validation Protocol.
The validation of the project resulted in two (2) Corrective Action Requests and fourteen (14)
Clarification Requests.
During the preparation of draft validation report two main issues that were identified as
CARs, it was found necessary for the project proponents to initiate immediate corrective
actions (CA) and therefore also their closure before proceeding to the validation stage.
The project proponent has hence submitted the CA to the satisfaction of TUV Rheinland
Group. The details of the CARs raised and the closure are as follows:
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Issues pending from CLs (OP): In case of CL2 exception has been made in terms of evidence
Justification for exceptions: CPCL has assured TUV Rheinland Group that it will present the
necessary evidences before verification
Implications of exceptions: As information will not hamper the validation opinion it is
considered for this stage as justifiable
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Issues pending from CLs (OP): In case of CL3 exception has been made in terms of evidence
Justification for exceptions: CPCL has assured TUV Rheinland Group that it will present the
necessary evidences before verification
Implications of exceptions: As information will not hamper the validation opinion it is
considered for this stage as justifiable
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3
The following words have been used throughout the text relating to the Synthesis Report to the Third Assessment
Report: virtually certain (greater than 99% chance that a result is true); very likely (90-99% chance); likely (66-
90% chance); medium likelihood (33-60% chance); unlikely (10-33% chance); very unlikely (1-10% chance) and
exceptionally unlikely (less than 1% chance), and were used in this validation report
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4
An explicit uncertainty range (±) is a likely range. Estimates of confidence relating to Working Group II (Synthesis
Report to the TAR) findings are used in the text as: very high (95% or greater); high (67-95%); medium (33-67%);
low (5-33%); and very low (5% or less), and were used in this report to describe these uncertainty range
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Possible impact of the project on the environment in which it is placed will be through
felling of trees in an unsustainable manner. For the implication of this environmental
5
Two part tariff consists of a ”fixed cost tariff” and a ”variable cost tariff”, respectively. The fixed cost tariff is the cost
calculated on a per kWh of generation (includes cost of depreciation, return on equity, interest on working capital, operation
and maintenance costs) whereas the basis for variable cost tariff is the cost of the fuel (which may vary with the plant
generation)
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Final Conclusion:
CL 12 CPCL has asked for an extension for submission of plan to use municipal solid
waste with APPCB. The extension request and plan will be submitted to TUV Rheinland
Group before verification.
CL 13 CPCL will submit plan for energy plantation to APPCB and a copy of the same
will be submitted to TUV Rheinland Group before verification.
CAR 02 The project proponent have stopped usage of Neem and Mango as fuel after
receipt of the consent to operate form APPCB. This CAR is closed by TUV Rheinland
Group.
Issues pending from CLs: For CL 12 and CL 13 exceptions have been made in terms of
evidences
Justification for exceptions: CPCL has assured TUV Rheinland Group that it will
present the necessary evidences before verification
Implications of exceptions: As information will not hamper the validation opinion it is
considered for this stage as justifiable exception.
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Stakeholder Comment
TUV Rheinland Group published the project documents on its own website along with a
link to UNFCCC website. from 15 August to 14 September 2004. during this period 1
comment was received from Mr. Ben Pearson of CDM Watch. Mr. Pearson’s comment
was –
The additionality of this project is highly questionable given that the plant has been in
operation since February 2004. The additionality demonstration in the PDD claims that
CDM funding “was initially considered” to cover the risk of rising biomass fuel prices.
However, the fact that the plant was actually constructed and entered commercial
operation before the developer knew whether CDM funding would be available stronger
suggests that it was not essential for the project to go ahead and that the risks are
manageable in the absence of CDM registration.
Furthermore, this assertion that the CDM was considered at an earlier stage of project
development must be documented, as per the Methodologies Panel’s recent Consolidated
Tools for Demonstration of Additionality which require that “evidence should be publicly
provided that the incentive provided by the CDM was seriously considered in the decision
to proceed with the project activity” [emphasis added] in the case of project activities that
start before registration. Assertions such as those contained in this PDD are insufficient.
Ben Pearson
CDM Watch
16 August 2004
The starting date of the project activity in the revised Draft CDM PDD (January 2005) is
mentioned as the Boiler inspection date of 24th November 2003. We were also submitted
by the project proponent the copy of the contract with the project consultants, in response
to this comment, whose contract with the project proponents is dated 19th February 2003.
Taking into account these time frames it can be acceptably concluded that the project
proponents thought of CDM benefits prior to time of the stated ‘starting date’ for the project
activity.
Furthermore, the recent decision of the State government of Andhra Pradesh to provide
free power to the farmers has put additional strain on the demand-supply gap.
This was not an anticipated barrier during the conceptualization of the project activity and
the project continues to operate within these constraints as of date.
All these conditions mentioned are now reflected in the revised Draft CDM PDD (January
2005).
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5 VALIDATION OPINION
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6 REFERENCES
Category 1 Documents:
Documents provided by the Project Proponent
On-site documents
• CPCL, 24/02/04, 1st invoice of Clarion for power generation to AP TRANSCO Letter no.
CPCL / APTRANSCO / INV / 115
• CPCL, 15/09/04, Copy of manpower status as on 15 / 09 / 04
• CPCL, 21/09/04, Daily Generation Report
• CPCL, 23/09/04, (September 2004, which is the date of submission of the report to TUV
Rheinland), Characteristics of coal available at the plant
• CPCL, 23/09/2004, (September 2004, which is the date of submission of the report to
TUV Rheinland), Lanco group profile
• CPCL. 23/09/04, (September 2004, which is the date of submission of the report to TUV
Rheinland), Copy of Performance guarantee parameters from turbo generator supplier
• CPCL, 20/10/04, Letter No. CPCL/E&Y/77/04, Roles and responsibilities of various
officials in CPCL
• Director of Boilers, Andhra Pradesh, Hyderabad, 31/05/04, letter no. F/6382/03
Certificate no. 8, dated 20/05/04 issued to boiler no. AP 3784
• ENERGOMACEXPORT dated nil, Turbine operation manual supplied by. Document no.
103 – M – 0898PE
• SARDS 22/09/04 (submission date), NGO Profile
• TUV Rheinland Group, January 04, (Submission date), Completed Questionnaire in
Application for Validation and Registration or Verification and Certification of CDM
Projects of TUV Rheinland Group, submitted by CPCL
• Walchand Nagar Industries, 18/10/02, Technical data sheet of document no. 44801 Rev-
A
Off-Site Documents Review
• Airport authority of India, 8/12/2000, NOC . Letter no. AAI / 20012 / 310 / 2000- ARI
• APITCO, August 1997, Biomass assessment study conducted by for CPCL
• APPCB, 22/02/01 Consent order for establishment issued by Order no.
132/PCB/C.Estt/ROH-II//EE-N/69-2000
• APPCB March 02, Amendment to Consent to Establish Letter no. 132/PCB/C.Estt./RO-
NLR/AEE-N/200202688
• APPCB, 22/09/04, Consent to operate, Consent order no. APPCB / VJA / NLR / 636 /
HO 2004 /A / 129
• CPCL, 7/1/98, MoU between NEDCAP and CPCL
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Persons interviewed:
List persons interviewed during the validation, or persons contributed with other information
that are not included in the documents listed above.
Sr. No Interviewee
1. Sarpanch of Gram Panchayat, Village Velagapudi
2. Member of Zilla Parishad, Dist. Prakasam
3. Secretary, Social Activity for Rural Development Society (Govt. recognised NGO
4. Managing Director NEDCAP
5. Dy. Director - Transmission APERC
- o0o -
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APPENDIX A
VALIDATION PROTOCOL
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INTRODUCTION
This document contains a generic Validation Protocol for small-scale CDM projects, which must be seen in conjunction with the Validation and
Verification Guidelines and the Validation Report Template.
This validation protocol serves the following purposes:
• It organises, details and clarifies the requirements a 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
Guideline
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
judgement 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. Report Protocol
Template (Requirements)
Table 1 Mandatory Requirements for Small Scale Clean Development Mechanism (CDM) Project Activities
Cross Reference/
REQUIREMENT REFERENCE CONCLUSION Comment
1. The project shall assist Parties included in Annex I in Kyoto Protocol Art. 12.2 The Annex 1 party is unknown
achieving compliance with part of their emission and the parties listed in Annex-
reduction commitment under Art. 3 1 to the revised draft CDM
PDD only addresses the main
equity fund-raiser who is the
Project Proponent and the
beneficiary of the Annex I
country is to be identified in the
future (at the earliest prior to
registration)
2. The project shall assist non-Annex I Parties in Kyoto Protocol Art. 12.2, Ok Host country approval
achieving sustainable development and shall have Simplified Modalities and granted vide Letter F.
obtained confirmation by the host country thereof Procedures for Small No. 4 / 10 / 2003 –
Scale CDM Project CCC dated 12 April
Activities §23a 2004 by Govt. of
India, Ministry of
Environment and
Forest, (DNA for
India)
3. The project shall assist non-Annex I Parties in Kyoto Protocol Art. 12.2. OK Host country approval
contributing to the ultimate objective of the UNFCCC granted vide Letter F.
No. 4 / 10 / 2003 –
CCC dated 12 April
2004 by Govt. of
India, Ministry of
Environment and
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Cross Reference/
REQUIREMENT REFERENCE CONCLUSION Comment
Forest, (DNA for
India)
4. The project shall have written approval of voluntary Kyoto Protocol Art. OK Letter F. No. 4 / 10 /
participation from the designated national authorities 12.5a, Simplified 2003 – CCC dated 12
of each party involved Modalities and April 2004 by Govt. of
Procedures for Small India, Ministry of
Scale CDM Project Environment and
Activities §23a Forest
5. The emission reductions should be real, measurable Kyoto Protocol Art. 12.5b Ok Section E of the
and give long-term benefits related to the mitigation of revised draft CDM
climate change PDD (Jan’05)
6. Reduction in GhG emissions must be additional to any Kyoto Protocol Art. OK Section B3 (revised
that would occur in absence of the project activity, i.e. 12.5.c, Simplified draft CDM PDD
a CDM project activity is additional if anthropogenic Modalities and Jan’05): Policy related
emissions of greenhouse gases by sources are Procedures for Small barrier is the most
reduced below those that would have occurred in the Scale CDM Project relevant to the present
absence of the registered CDM project activity Activities §26 project
7. Potential public funding for the project from Parties in Marrakech Accords OK CPCL has sent the
Annex I shall not be a diversion of official development (Decision 17/CP.7) debt and equity
assistance participant’s list.
No Annex-1 country is
involved in financing
this project and so,
any diversion of the
ODA is not expected
8. Parties participating in the CDM shall designate a Marrakesh Accords OK http://cdm.unfccc.int
national authority for the CDM (CDM modalities§ 29) DNA of India is
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Cross Reference/
REQUIREMENT REFERENCE CONCLUSION Comment
Ministry of
Environment and
Forest, Govt. of India
9. The host country shall be a Party to the Kyoto Protocol Marrakesh Accords OK http://cdm.unfccc.int
(CDM modalities§ 30) Accession on
26/08/02
10. The proposed project activity shall meet the eligibility Simplified Modalities and OK By referring to web
criteria for small scale CDM project activities set out in Procedures for Small site of Lanco group
§ 6 (c) of the Marrakesh Accords and shall not be a Scale CDM Project and SV it seen that
de-bundled component of a larger project activity Activities §12a,c the group is not
having another CDM
project within 1 km, in
the same area and
within same sectoral
scope as CPCL.
Thus, this is not a de-
bundled activity from
a large CDM project.
The project is also
fulfilling criteria of a
small-scale project.
11. The project design document shall conform with the Simplified Modalities and OK Revised draft CDM
Small Scale CDM Project Design Document format Procedures for Small PDD, January 2005
Scale CDM Project
Activities, Appendix A
12. The proposed project activity shall confirm to one of Simplified Modalities and OK Revised draft CDM
the project categories defined for small scale CDM Procedures for Small PDD, January 2005,
project activities and uses the simplified baseline and Scale CDM Project Performance
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Cross Reference/
REQUIREMENT REFERENCE CONCLUSION Comment
monitoring methodology for that project category Activities §22e guarantee of turbo
generator and boiler
suppliers The project
is falling in I – D of
small scale project
13. Comments by local stakeholders are invited, and a Simplified Modalities and OK The project proponent
summary of these provided Procedures for Small has invited comments
Scale CDM Project from local
Activities §22b stakeholders and a
summary of the same
has been provided in
revised draft CDM
PDD, January 2005,
sections G.1 and G.2
14. If required by the host country, an analysis of the Simplified Modalities and OK Ref. Revised draft
environmental impacts of the project activity is carried Procedures for Small CDM PDD, F1The
out and documented Scale CDM Project host country does not
Activities §22c require EIA for a
project having less
than Rs. 1000 million
investment
15. Parties, stakeholders and UNFCCC accredited NGOs Simplified Modalities and OK Section G of draft
have been invited to comment on the validation Procedures for Small CDM PDD (June
requirements and comments have been made publicly Scale CDM Project 2004). Yes, web site
available Activities §23b,c,d of validator has
published the PDD
from 15 August 2004
to September 14 2004
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Cross Reference/
REQUIREMENT REFERENCE CONCLUSION Comment
on the TUV website
www.tuvdotcom.com
with a linkage to the
site of UNFCCC site.
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* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-6
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Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
rs
and
web
site
of
Lanc
o
grou
p/
PDD
A.4.
5
A.1.3. Does proposed project activity confirm to PDD DR Yes. This project is falling under small scale OK
one of the project categories defined for A.4. methodology I – D i.e. Grid connected electricity
small-scale CDM project activities? 2 / generation by renewable energy sources
PDD
D.1
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Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
A.3. Contribution to Sustainable Development
The project’s contribution to sustainable
development is assessed
A.3.1. Will the project create other PDD DR/ The project will allow usage of wastelands for OK
environmental or social benefits than GhG A2 SV / energy plantation in the region.
emission reductions? I In addition, about 100 persons will be directly
employed by the project as per the employment
record supplied by CPCL. Indirect employment and
their dependents will be additional benefit of the
project
The project has also given stability to the local grid
and has ensured that the quality of power is
improved. These factors, however, cannot be
quantified in terms of tangible returns.
A.3.2. Will the project create any adverse SV / DR / There is a possibility of degradation of the local CL 2 OP
environmental or social effects? APP I environment if the project is not able to attract local
CB biomass producers or the waste biomass is not
cons available during a condition such as a prolonged
ent drought.
to It is further understood that the biomass from this OK
oper region may also be consumed by the paper
ate industry. This competition for the resource may
and escalate the price of biomass.
cons It is foreseeable that under the given extreme CL 2 OP
ent situation the fuel suppliers may resort to
to unsustainable cutting of trees indirectly affecting
esta the sustainability of the project.
blish
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Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
blish As per the draft CDM PDD (June 2004) the project
/ proponents have considered purchase of biomass
PDD from a radius of 80 Kilometres from the farmers.
A.2
The company has also identified cultivable OP
wastelands and the farmers are willing to grow
energy plantation. The identified wasteland records
and Memorandum of Understanding with the
farmers need to be documented.
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-10
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
• Economic well being (Income generation)
• Environmental well being (afforestation)
• Technical well being (Highest pressure
boiler)
All of them have been addressed by the project.
(Host country approval granted vide Letter F. No. 4
/ 10 / 2003 – CCC dated 12 April 2004 by Govt. of
India, Ministry of Environment and Forest, (DNA for
India))
A.3.4. Is the project in line with relevant APP DR AP Pollution control board has given consent to
legislation and plans in the host country? CB establish (Order no. 132 / PBC / C.Estt./ ROH – I /
Con EE-N / 69 – 2000 dt. 22 / 02 / 01), consent to
sent operate no. APPCB / VJA / NLR / 636 / HO / 2004 /
to A / 29 dated 22 / 09 / 2004)
oper According to this consent to operate, CPCL is not
ate permitted to use Mango and Neem wood as CAR 02 OK
and biomass fuels. During site visit the same was
cons noticed being consumed. A corrective action to this
ent effect is required by the project proponents
to
esta
blish
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-11
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Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
B. Project Baseline
The validation of the project baseline establishes
whether the selected baseline methodology is
appropriate and whether the selected baseline represents
a likely baseline scenario.
B.1. Baseline Methodology
It is assessed whether the project applies an
appropriate baseline methodology.
B.1.1. Is the selected baseline methodology in PDD DR CPCL proposes to use biomass (renewable OK
line with the baseline methodologies D.2 energy) based co-generating system to supply
provided for the relevant project category? electricity to the APTRANSCO grid.
Therefore, the application of the category I.D. to the
project is considered appropriate. The reasons are
as stated below (reference: Appendix B of the
simplified modalities and procedures for small-
scale CDM project activities Version 03)
Point 23: CPCL comprises renewable in the form of
biomass that supply electricity to an electricity OK
distribution system. It is also connected and
supplying to a non-renewable dominated grid.
Point 24: The gross capacity of the CPCL unit is
CAR 01 OK
stated to not exceed 12 MW gross of which 11.04
MW is for export to the grid. However, considering
an auxiliary consumption of 9 per cent as denoted
in the Order R. P. No. 84/2003 dated March 20,
2004 this would result in the export of 10.92MW).
Organization therefore has to reconsider the
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-12
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
Organization, therefore, has to reconsider the
auxiliary consumption of 8 per cent. CAR 01 OK
Co-firing in the form of coal usage is proposed to
the tune of 23 per cent at the end of the crediting
period (running for 7 years). However, as per the
Consent Order (APPCB /VJA/ NLR/ 636/ HO/ 2004/
A/ 129 dated 22/09/2004) Schedule-B coal
consumption is subject to a maximum of 30 per
cent per annum. This as per the TUV Rheinland
Group requires to be incorporated into the project
emissions, over the crediting period, to assimilate
the vintage of equipment
B.1.2. Is the baseline methodology applicable PDD DR CPCL is expected to replace and substitute fossil OK
to the project being considered? D2 fuels dominated grid electricity with biomass
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-14
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
B.2.3. Are relevant national and/or sectoral PDD DR The recent political election with the installation of a CL 5 OK
policies and circumstances taken into B.3 new State government in Andhra Pradesh has
account? made a policy decision to distribute electricity to
farmers free. Project proponent may well need to
reflect its stand on this late development in the
PDD
B.2.4. Is the baseline selection compatible with PDD DR The baseline is verified by publicly available OK
the available data? Ann authentic data source for the current year. The
ex 3 baseline is conservative by taking into account
/ these data.
CEA
web
site
B.2.5. Does the selected baseline represent PDD DR Yes. Small-scale methodology I – D has chosen for OK
the most likely scenario describing what E the baseline analysis the route of the weighted
would have occurred in absence of the average emissions of the current generation mix.
project activity? Therefore, even as the Andhra Pradesh grid in the
near future is likely to add more gas based projects
making the current generation mix rather cleaner
then it currently is. However, the baseline selected,
based upon the data represented in the PDD
baseline calculations is sufficiently conservative to
give the most likely scenario.
Further, according to APERC (R.P. No. 84) there
will be no additions to the Biomass projects until
review three years hence. Therefore, the stalled
capacity additions for renewable energy projects
from biomass could result in CO2 intensity within
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-15
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
the grid (provided that other renewable projects
also lag in their planned installation)
C. Duration of the Project / Crediting Period
It is assessed whether the temporary boundaries of the
project are clearly defined.
C.1 Are the project’s starting date and PDD DR Form 4, dated 20 May, 2004 issued by Andhra OK
operational lifetime clearly defined? C.1. Pradesh boiler inspection department for registry
1/ number AP – 3785 has been submitted as a proof
PDD that the hydraulic test was conducted on 24
C.1. November, 2003. The same date is now referred in
2 section C.1.1 of the revised draft CDM PDD of
January 05 as the starting date of the project
activity. The operational life of the project is stated
as 25 years
C.2 Is the crediting period clearly defined PDD DR A renewable crediting period is planned for the OK
(seven years with two possible renewals or 10 C.2. project as submitted vide the revised draft CDM
years with no renewal)? 1 PDD (January 2005) with a commencement of the
crediting period from February 2004 (in place of
February 2005 of earlier draft CDM PDD – June
2004)
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-16
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
D. Monitoring Plan
The monitoring plan review aims to establish whether
all relevant project aspects deemed necessary to monitor
and report reliable emission reductions are properly
addressed.
D.1. Monitoring Methodology
It is assessed whether the project applies an
appropriate monitoring methodology.
D.1.1. Is the selected monitoring methodology PDD DR/ Yes, however, clarification is sought on the
in line with the monitoring methodologies D.1 / I/ SV monitoring for
provided for the relevant project category? D.2 1. Energy content of biomass and coal, which CL 6 OK
at the moment is with a monthly monitoring
frequency but how is the same evaluated if
either of the fuel batches was to change
within the prescribed monitoring frequency
2. The calculation of GhG emission by sources
is indicating that the carbon percentage in OK
coal will be monitored. However, the same
is not calculated but obtained from the
supplier
OK
3. The CO2 emission from the transportation
is calculated at 1466 tonnes per annum
(TPA) and is found conservative
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-17
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
D.1.2. Is the monitoring methodology PDD DR Yes, With inclusion of above modifications OK
applicable to the project being D.3
considered?
D.1.3. Is the application of the monitoring PDD DR Yes, the methodology is transparent OK
methodology transparent? D.3
D.1.4. Will the monitoring methodology give PDD DR Yes, With inclusion of above modifications OK
opportunity for real measurements of D.3
achieved emission reductions?
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Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
D.4.3. Do the measuring technique and PDD DR Yes, Monitoring plan is following good practise OK
frequency comply with good monitoring D.3
practices?
D.4.4. Are the provisions made for archiving PDD DR Yes OK
baseline emission data sufficient to enable D.3
later verification?
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-22
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
E. Calculation of GhG emission
It is assessed whether all material GhG emission
sources are addressed and how sensitivities and data
uncertainties have been addressed to arrive at
conservative estimates of projected emission reductions.
E.1.Project GhG Emissions
The validation of predicted project GhG
emissions focuses on transparency and
completeness of calculations.
E.1.1. Are all aspects related to direct and PDD DR All direct emissions related to CO2 emissions have OK
indirect project emissions captured in the E.1. been considered in the project design, however,
project design? 2.5 / the design neglects emissions from other
E.2 greenhouse gases with justification for CH4 but no
elaboration of indirect emissions from SF6 and N2O
within the project design but TUV RHEINLAND
considers them to be negligible
E.1.2. Have all relevant greenhouse gases and PDD DR As mentioned in E1.1 OK
sources been evaluated? E
E.1.3. Do the methodologies for calculating PDD DR / Yes OK
project emissions comply with existing E/ I
good practice? Exp
ert
View
E.1.4. Are the calculations documented in a PDD DR Yes calculations of emission reductions while being OK
complete and transparent manner? E /I complete and transparent the calculation of arriving
125 at grid emission factor should be made transparent;
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
1.2.5 at grid emission factor should be made transparent;
Further, step 4 of the calculation ‘units exported to OK
APTRANSCO’ is incomplete in respect to
deductions of project related emissions due to use
of fossil fuels within the text of the PDD, however,
the same is seen elaborated in ‘enclosure-1:
baseline calculations’
E.1.5. Have conservative assumptions been PDD DR / Yes the emission factor is conservatively assumed. OK
used? E1 I However, see CAR 01 for more details on
conservativeness
E.1.6. Are uncertainties in the project PDD DR Yes, due to monitoring instrument related OK
emissions estimates properly addressed? E.1. uncertainties
2.5
E.2.Leakage
It is assessed whether there leakage effects, i.e.
change of emissions which occurs outside the
project boundary and which are measurable and
attributable to the project, have been properly
assessed.
E.2.1. Are leakage calculation required for the PDD DR Yes and leakage effects have been assessed. OK
selected project category and if yes, are E
the relevant leakage effects assessed? 1.2.2
E.2.2. Are potential leakage effects properly PDD DR The leakage due to biomass transportation is OK
accounted for in the calculations (if E accounted for and may be neglected as per
applicable)? 1.2.2 reasons identified in revised draft CDM PDD (also
see point D.3.2)
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-24
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
E.2.3. Do the methodologies for calculating PDD DR The leakage calculation is conservative and is OK
leakage comply with existing good practice E matching with good practices.
(if applicable)? 1.2.2
E.2.4. Are the calculations documented in a PDD DR Calculations are complete and transparent. OK
complete and transparent manner and (if E
applicable)? 1.2.2
E.2.5. Have conservative assumptions been PDD DR Yes as seen in the reply to the closure of CL 7 and CL 7 & OK
used (if applicable)? E CL 11 CL 11
1.2.2
E.2.6. Are uncertainties in the leakage PDD DR Uncertainties related to distance of biomass CL 11 OK
estimates properly addressed (if E procurement need to be identified
applicable)? 1.2.2
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-25
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
E.3.4. Do the methodologies for calculating PDD DR Yes, methodologies for calculating baseline OK
baseline emissions comply with existing E.1. emissions are complying with existing good
good practice? 2.4 practice
E.3.5. Are the calculations documented in a PDD DR Yes, calculations are complete and transparent OK
complete and transparent manner? E1.2
.4 /
E.2
E.3.6. Have conservative assumptions been PDD DR Assumptions on existing baseline are conservative OK
used? E.1.
2.4
E.3.7. Are uncertainties in the baseline PDD DR Key assumptions and uncertainties are based upon OK
emissions estimates properly addressed? E.1. the external data received from utilities of Andhra
2.4 Pradesh, future capacity additions and export of
power to APTRANSCO and these are seen to be
sufficiently addressed and recognised as being
conservative by TUV Rheinland Group
E.4.Emission Reductions
Validation of baseline GhG emissions will focus
on methodology transparency and completeness
in emission estimations.
E.4.1. Will the project result in fewer GhG PDD DR It is anticipated that due to power generation from OK
emissions than the baseline case? B.3 / the combustion of biomass (such as rice husk,
E.2 Juliflora, Chilli Stalk) would result in emission
reduction for the same amount of electricity/power
generated by means of combusting fossil fuels.
This is due to the reason that low cost biomass
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-26
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CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
generating stations have net zero emissions
(carbon neutral).
F. Environmental Impacts
It is assessed whether environmental impacts of the
project are sufficiently addressed.
F.1.1. Does host country legislation require an CA DR No, the project cost is less than Rs. 1000 million for OK
analysis of the environmental impacts of repo which no EIA is required.
the project activity? rt
F.1.2. Does the project comply with APP DR Yes, AP Pollution Control Board has issued
environmental legislation in the host CB consent to establish and consent to operate.
country? cons According to consent to operate Clarion Power
ent Corporation Ltd-
to CAR 02 OK
• Cannot use Mango and Neem as a biomass
esta fuel. However, during the site visit the same
blish was found to be used freely
/
• Is also required to give an action plan for usage CL 12 OP
Con
of Municipal solid waste, market yard waste as
sent
fuel within 3 months as per consent to operate.
to
A copy of the same should be submitted
oper
ate • Is required to submit an action plan for CL 13 OP
development of energy plantation within one
month. A copy of the same should be
submitted
Reference: APPCB consent to establish (Order no.
132 / PBC / C.Estt./ ROH – I / EE-N / 69 – 2000 dt.
22 / 02 / 01), consent to operate no. APPCB / VJA /
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Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
NLR / 636 / HO / 2004 / A / 29 dated 22 / 09 / 2004)
F.1.3. Will the project create any adverse PDD DR Adverse effects on environment can come into OK
environmental effects? A.2 / picture if no sustainable biomass plantation or
waste biomass collection systems are devised. The
project proponents are required to explain how they
are ensuring environmentally sustainable biomass
usage (see A.3.2).
F.1.4. Have environmental impacts been PDD DR Mango Wood and Neem Wood usage CAR 02 OK
identified and addressed in the PDD? F.1
G. Comments by Local Stakeholder
Validation of the local stakeholder consultation process.
G.1.1. Have relevant stakeholders been Site I AP Electricity Regulatory Authority, Zilla Panchayat OK
consulted? visit (District Local body) and Local NGO have been
consulted. However, draft CDM PDD has no
reference to their identification but now stand
identified in the revised draft CDM PDD
(January’05)
G.1.2. Have appropriate media been used to Visit I Personal communication is used for inviting OK
invite comments by local stakeholders? to comments from the stakeholders.
site
G.1.3. If a stakeholder consultation process is PDD DR / India doesn’t require stakeholder consultation for OK
required by regulations/laws in the host G.1 I/ the given size of the project. During TUV Rheinland
country, has the stakeholder consultation SV Group’s interview with head of Velagapudi village, it
process been carried out in accordance was pointed out that due to CPCL local grid is
with such regulations/laws? experiencing better quality of power in terms of
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-28
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Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
voltage.
G.1.4. Is a summary of the comments received PDD DR / Summary of the comments received from OK
provided? G.2 I stakeholders is received by TUV Rheinland Group.
G.1.5. Has due account been taken of any PDD DR / The project proponent shall describe the process of CL 14 OK
comments received? G.3 I identifying the local stakeholders and the manner in
which these comments were received from these
identified local stakeholders and accounted for
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-29
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Draft report clarifications and corrective Ref. To Summary of project owner response Validation team conclusion
action requests by validation team checklist
question in
table 2
Clarifications (CL)
CL 1 A.2.5 CPCL has appointed qualified CPCL has submitted copy of qualifying
Qualified personnel, as per the requirement personnel for operation and certificates of the boiler operators
of the statutory obligations, perform the boiler maintenance of boiler as per statutory
operation, the certificates and qualification requirements. The list of the qualified
process is to be made available. personnel along with supporting
documents can be given as proof on a
sample basis.
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question in
table 2
CL 5 B.2.3 As per Electricity act 2003, the This has been verified with the
The recent political election with the government shall deposit the money Electricity Act 2003 (Pg. 33, para 65).
installation of a new State government in equivalent to the value of supply of free The response is deemed sufficient and
Andhra Pradesh has made a policy decision power / subsidised power with the request for clarification is closed.
to distribute electricity to farmers free. Project APTRANSCO.
proponent may well need to reflect its stand
on this late development in the CDM PDD
CL 6 D.1.1 The company has in-house facility to The monitoring plan in section D3 of the
Energy content of biomass and coal, with a check the energy content of the fuel at revised draft CDM PDD has introduced
monthly monitoring as indicated in the any given point of time. For each batch measurement of calorific value of coal
monitoring plan, needs to elaborate on how of the fuel the energy content is and biomass for each batch.
the same is evaluated if either of the fuel measured and is available in the The response is deemed sufficient and
batches was to change within the prescribed records. the request for clarification is closed
monitoring frequency
CL 7 D.3.2, E.2.5 The distance from which biomass is Emission due to transportation of fuel is
The distance over which the biomass will be procured ranges from 5 to 150 km. As a not considered in the baseline
collected has to be fixed as per the conservative practice the distance is calculations. However, section E.1.2.2
recommendations of NEDCAP or other calculated at an average of 80 km. has considered biomass transportation
appropriate authorities so as to ensure for the plant. This calculation has
continuous compliance on the distance as considered average distance for the
well as the indicated leakage factors biomass transport.
incorporated in the CDM PDD. This needs to The response is deemed sufficient and
be verified and authenticated by the project the request for clarification is closed
proponent
CL 8 D.5.4 Emergencies are not expected to lead The emergencies are identified and the
While emergency preparedness have been to unintended emissions. However, a preparedness is demonstrated in the
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identified for various situations especial procedure for preparedness for submitted documents.
attention to the unintended emissions need to unintended emissions from the project The response is deemed sufficient and
be provided is submitted as a separate document. the request for clarification is closed.
CL 9 D.5.2, D.5.6 The procedures for maintenance of the The procedure for maintenance of
Maintenance procedures for monitoring monitoring equipments are identified monitoring equipments is understood
equipments and installations are identified and performed regularly. by TUV Rheinland Group to be
but their maintenance and management is maintained by CPCL as noted.
yet to be performed Implementation of these procedures will
be observed during the verification
stage.
CL 10 D.5.10 The GhG compliance internal audit will The internal audit procedures are
Procedures for internal audits of GhG be performed in the month of January submitted by the project proponent to
emissions project compliance are identified 2005 TUV Rheinland Group.
but the last scheduled audit for project GhG Implementation of the internal audit will
compliance was cancelled and remained be seen during verification stage
unscheduled
CL 11 E.2.5, E.2.6 CPCL states that it procures the CPCL has given assurance to TUV
Uncertainties related to distance of biomass biomass from distance of less than 50 Rheinland Group that the maximum
procurement need to be identified km. As a conservative practice the biomass coverage is less than 50 km
distance is considered to be 80 km, radius and maximum distance to some
which will be eliminating the extent is also procured from 150 km. As
uncertainties. a conservative practice, 80 km average
distance is considered. This
consideration is reducing the
uncertainty related biomass
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question in
table 2
transportation to a large extent.
The response is deemed sufficient and
the request for clarification is closed.
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question in
table 2
CL 12 Usage of municipal waste is TUV Rheinland Group is expecting a
CPCL is required to give an action plan for F.1.2 recommended by APPCB and it is not supporting document of the response
usage of Municipal solid waste, market yard compulsory for CPCL to implement from the project proponent. During the
waste as fuel within 3 months as per G.O Ms. these measures. However, CPCL has verification stage the document seeking
No. 3. dtd. 08/01/2004. A copy of the same asked for extension from APPCB for extension and action plan submitted to
should be submitted submission of the action plan. APPCB will be verified.
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Corrective Action Required (CAR)
CAR 1 The auxiliary consumption is All the issues raised in CAR 1 have
The gross capacity of the CPCL unit is stated B.1.1 reconsidered at 9% in the revised draft been resolved by the project
to not exceed 12 MW gross of which 11.04 CDM PDD. proponents while submitting the revised
MW is for export to the grid. However, PDD.
considering an auxiliary consumption of 9 per
cent as denoted in the Order R. P. No.
84/2003 dated March 20, 2004 this would
result in the export of 10.92MW).
Organization, therefore, has to reconsider the
auxiliary consumption of 8 per cent.
Co-firing in the form of coal usage is B.1.1 The revised PDD has considered 30%
proposed to the tune of 23 per cent at the usage of coal throughout the crediting
end of the crediting period (running for 7 period.
years). However, as per the Consent Order
(APPCB /VJA/ NLR/ 636/ HO/ 2004/ A/ 129
dated 22/09/2004) Schedule-B coal
consumption is subject to a maximum of 30
per cent on an annual basis. This as per the
TUV RHEINLAND requires to be
incorporated into the project emissions, over
the crediting period, to assimilate the vintage B.2.2
of equipment
Estimation of PLF is optimistic. Instead of 90 PLF is made to 80% in the revised draft
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per cent a PLF of 80% shall be considered as CDM PDD of January 2005.
described by the APERC order R.P. No. 84
dated 20th March 2004 based on and
keeping in line with the philosophy of two-part
tariff
CAR 2 Neem and mango ware acceptable Neem and Mango have constituted
Project proponent may clarify whether the A.3.2/A.3.4 biomass fuels as per NEDCAP about 20% of the total biomass used as
use of neem and mango trees are allowed as / F.1.2/F.1.4 guidelines as well as consent to per the data submitted to TUV
fuel in biomass based power projects. establish given by APPCB. Consent to Rheinland Group. This was not
operate received on October 3, 2004 permitted as per consent to operate of
has banned use of Neem and Mango. APPCB. CPCL used this non-permitted
Since than CPCL has stopped the biomass from February 21, 2004, (date
usage of these species. Biomass power of plant commissioning) to October 3,
producers will approach APPCB for 2004 (receipt of consent to operate
inclusion of Neem and Mango in the list from APPCB) for a period of 226 days.
of biomass fuel to be used. Till the time Hence, TUV Rheinland suggests a
Neem and Mango are permitted, CPCL deduction of 20% emission reduction
will not use Neem and Mango. from certified emission reduction for
first 226 days of crediting period to
CPCL.
The use of Neem and Mango has been
stopped as noted in revised draft CDM
PDD of January 2005.
o0o -
Page A-6-38
Report No. 4002is, rev. 05 This document is a part of the Validation and Verification Manual