global tan energy limited...report template revision 4, 28/09/2007 05 validation report global tan...

Report Template Revision 4, 28/09/2007

05

VALIDATION REPORT

GLOBAL TAN ENERGY LIMITED

VALIDATION OF THE AY-YILDIZ 15 MW WPP

BUREAU VERITAS CERTIFICATION

REPORT NO. TURKEY-VAL/ CER.163.09.C71.REV.1/2009

REVISION NO. 01


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Date of first issue: Organizational unit:

28/09/2009 Bureau Veritas Holding SAS

Client: Client ref.:

Global Tan Energy Mr. Brian P. de Thorpe Millard Mr. M. Kemal Demirkol

Summary:

Bureau Veritas Certification has made the validation of the AY-YILDIZ 15 MW WPP project of Global Tan Energy Limited located in Ayyildiz Hill, Bandirma, Balikesir-TURKEY on the basis of UNFCCC criteria for the CDM Methodology and Gold Standard Version2 criteria as well as the criteria given to provide for consistent project operations, monitoring and reporting.

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

The first output of the validation process is a list of Clarification and Corrective Actions Requests (CL and CAR), presented in Appendix A. Taking into account this output, the project proponent revised its project design document. In summary, it is Bureau Veritas Certification’s opinion that the project correctly applies the baseline and monitoring methodology ACM0002 version 9 and meets the relevant Gold Standard requirements for Voluntary Projects.

Report No.: Subject Group:

TURKEY-VAL/CER.163.09.C71.rev.1/ 2009

Gold Standard Indexing terms

Project title:

AY-YILDIZ 15 MW WIND POWER PLANT

Work carried out by:

Burcu MUTMAN, Team Leader Yildiz ARIKAN, Baseline Specialist Haluk CENGIZ, Investment Analysis Specialist

No distribution without permission from the

Client or responsible organizational unit

Work verified by:

Ashok Mammen

Limited distribution

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

28/06/2010 02 88 Unrestricted distribution


Report No: TURKEY-val/CER.163.09.C71.Rev.1/2009 rev. 00

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Abbreviations CAR Corrective Action Request CDM Clean Development Mechanism VER Verified Emission Reductions CL Clarification Request CO2 Carbon Dioxide tCO2e tons of carbon dioxide equivalent DOE Designated Operational Entity GHG Green House Gas(es) I Interview EPDK - EMRA

Elektrik Piyasasi Denetleme Kurulu – Electricity Market Regulatory Authority

MoV Means of Verification NGO Non Government Organization TEIAS Türkiye Elektrik Iletim A.S. – Turkish Electricity Transmission Company PDD Project Design Document TM Trafo Merkezi – Transformer Station UNFCCC United Nations Framework Convention for Climate Change



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Table of Contents Page

1 INTRODUCTION ............................................................................................5

1.1 Objective 5

1.2 Scope 5

1.3 GHG Project Description 5

1.4 Validation team 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 and Additionality 11

3.3 Monitoring Plan 13

3.4 Calculation of GHG Emissions 14

3.5 Sustainable Development Impacts 19

3.6 Comments by Local Stakeholders 19

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS........................20

5 VALIDATION OPINION ................................................................................21

6 REFERENCES .............................................................................................22

Appendix A: Validation Protocol

Appendix B: Verifiers CV’s



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1 INTRODUCTION Global Tan Energy Limited has commissioned Bureau Veritas Certif icat ion to validate its VER project AY-YILDIZ 15 MW Wind Power Plant (hereafter called “the project”) at Ayyi ldiz Hil l, Bandirma, Balikesir-Turkey This report summarizes the f indings of the validat ion of the project, performed on the basis of UNFCCC – CDM Methodology and Gold Standard Version 2 cri teria, as well as criteria given to provide for consistent project operations, monitoring and reporting.

1.1 Objective The validat ion serves as project design verif icat ion and is a requirement of all projects. The validat ion is an independent third party assessment of the project design. In particular, the project 's baseline, the monitoring plan (MP), and the project’s compliance with relevant UNFCCC – CDM Methodology, GS Version 2 requirements are val idated in order to confirm that the project design, as documented, is sound and reasonable, and meets the stated requirements and identif ied criteria. Validat ion is a requirement for al l Gold Standard projects and is seen as necessary to provide assurance to stakeholders of the quality of the project and its intended generat ion of voluntary emission reductions (VERs).

1.2 Scope The val idation scope is def ined as an independent and objective review of the project design document, the project’s baseline study and monitoring plan and other relevant documents. The information in these documents is reviewed against, UNFCCC – CDM Methodology and Gold Standard rules and associated interpretat ions. The validat ion is not meant to provide any consulting towards the Client. However, stated requests for clarif ications and/or corrective actions may provide input for improvement of the project design.

1.3 GHG Project Description Akenerji Elektrik Uretimi A.S. plans to install 5 x 3 MW Wind Turbines at Ayyildiz Hill near the town of Bandirma in the province of Balikesir with the purpose of contributing to national economy and providing a portion of growing electricity demand. Total installed power of the facility will be 15 MW. The project consists of 80 meter high wind turbines, each 3 MW and a 34.5 kV switchyard. The annual projected energy of 51,32 GWh will be transferred to the interconnected grid by a 5 km long power transmission line from the project switchyard to TEIAS Bandirma II TM substation.



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The project activity will generate greenhouse gas (GHG) emission reductions by avoiding CO2 emissions from electricity generation by fossil fuel power plants connected to Turkish National Power Grid. The average annual generated energy of 51,32 GWh, will be able to deliver a reduction in emissions of around 30,997 tCO2e (tons of carbon dioxide equivalent) per annum. This generation figure which is taken as reference in emission reduction calculations is net of internal consumption of plant but it does not include transmission loss of the grid. The project complies with the relevant regulations and laws in Turkey. Main goals of the Ayyildiz Wind Power Plant project include;

• Utilization of the wind potential of Turkey in order to meet increasing electricity demand and maintain energy security.

• Reduction of GHG emissions through increasing share of renewable resources.

• Contribution to economic development by creating direct and indirect job opportunities during construction and operation phases.

• Reduction of import dependency on fossil fuel weighed electricity sector and diversify generation mix through use of local resources.

In terms of local benefits, the project will mainly contribute to the reduction of local air pollutants. It is also expected that the project will contribute to local employment during both the construction and operation.

1.4 Validation team The val idation team consists of the following personnel: Burcu MUTMAN Bureau Veritas Certif ication Team Leader, Climate Change Verif ier Dr. Yi ldiz Arikan Sabanci University Baseline Expert Haluk Cengiz BV Turkey Investment Analysis Expert Ashok Mammen Bureau Veritas Certif ication, Internal reviewer

2 METHODOLOGY The overall val idation, from Contract Review to Validation Report & Opinion, was conducted using Bureau Veritas Cert i f ication internal procedures.



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In order to ensure transparency, a val idation protocol was customized for the project, according to the Validat ion and Verif ication Manual (IETA/PCF). The protocol shows, in a transparent manner, criteria (requirements), means of verif ication and the results from validating the identif ied criteria. The val idation protocol serves the following purposes:

• It organizes, detai ls and clarif ies the requirements a Gold Standard project is expected to meet;

• It ensures a transparent val idation process where the validator wil l document how a particular requirement has been val idated and the result of the validat ion.

The validat ion protocol consists of six tables. The dif ferent columns in these tables are described in Figure 1. The completed validation protocol is enclosed in Appendix A to this report

Validation Protocol Table 1: Requirements checklist

Checklist Question 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 several sections. Each section is then further sub-divided. The lowest level constitutes a checklist question.

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 (CL) is used when the validation team has identified a need for further clarification.

Validation Protocol Table 2: Baseline and Monitoring Methodologies


The various requirements of baseline and monitoring methodologies should be met. The checklist is organized in several sections. Each section is then further sub-divided. The lowest level constitutes a checklist question.





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Validation Protocol Table 3: Checklist based on methodological tool for assessment of additionality


The various requirements of the additionality tool that shall be met.



Validation Protocol Table 4: Legal requirements

hecklist Question Comment Draft and/or Final Conclusion

The national legal requirements the project must meet.



Validation Protocol Table 5: Gold Standard Passport Requirements checklist

Checklist Question GS Ref Comment Draft and/or Final Conclusion

The requirements that should be met under the Gold Standard Passport.

Gives reference to documents where to find the requirement related with the checklist question in Gold Standard.



Validation Protocol Table 6 Resolution of Corrective Action and Clarification Requests

Report clarifications and corrective action requests

Ref. to checklist question in tables 1/2/3/4/5

Summary of project owner response

Validation conclusion

If the conclusions from the 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 Tables 2, 3 and 4 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 summarize the validation team’s responses and final conclusions. The conclusions should also be included in Tables 2, 3 and 4, under “Final Conclusion”.

Figure 1 Validation protocol tables



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2.1 Review of Documents The Project Design Document (PDD) submitted by Global Tan Energy and additional background documents related to the project design and baseline, i.e. country Law, Guidelines for Complet ing the Project Design Document (GS-PDD), Approved methodology, Clarif icat ions on Validat ion Requirements to be Checked by a Designated Operat ional Entity were reviewed. To address Bureau Veritas Cert if icat ion correct ive action and clarif icat ion requests Global Tan Energy revised the PDD and resubmitted i t on 31/05/2010 The validat ion f indings presented in this report relate to the project as described in the PDD version 05.1 (dd.31.05.2010).

2.2 Follow-up Interviews On 04/05/2009 Bureau Veritas Certi f ication performed interviews with project stakeholders to confirm selected information and to resolve issues identif ied in the document review. Representat ives of Global Tan Energy and Akenerji Elektr ik Uret im A.S. were interviewed (see References). The main topics of the interviews are summarized in Table 1.

Table 1 Interview topics

Interviewed organization

Interview topics

Akenerji Elektrik Uretim A.S.

� Design of the project activity

� The planning and the construction phase of the project.

� Relations with stakeholders

Local Stakeholder � Stakeholder Meeting Comments

� Effects of the project activity

Global Tan Energy � Local Stakeholder Consultation Process

� Consideration of comments from the stakeholders

� Additionality of the project activity

� Investment Analysis

� Baseline Determination

� Emission Reduction calculations

2.3 Resolution of Clarification and Corrective Action Requests The objective of this phase of the val idation is to raise the requests for correct ive act ions and clarif icat ion and any other outstanding issues that needed to be clarif ied for Bureau Veritas Cert if icat ion posit ive conclusion on the project design.



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To guarantee the transparency of the val idat ion process, the concerns raised are documented in more detail in the val idation protocol in Appendix A.

3 VALIDATION FINDINGS In the following sections, the f indings of the val idation are stated. The validat ion f indings for each val idation subject are presented as follows: 1) The f indings from the desk review of the original project design

documents and the f indings from interviews during the follow up visit are summarized. A more detailed record of these f indings can be found in the Validation Protocol in Appendix A.

2) Where Bureau Veritas Cert if ication had identif ied issues that needed clarif icat ion or that represented a r isk to the fulf i l lment of the project objectives, a Clarif ication or Correct ive Action Request, respectively, have been issued. The Clarif ication and Correct ive Action Requests are stated, where applicable, in the following sect ions and are further documented in the Validat ion Protocol in Appendix A. The validat ion of the Project resulted in 27 Corrective Action Requests and 29 Clarif icat ion Requests.

3) The conclusions for validat ion subject are presented.

3.1 Project Design Bureau Veritas Certif icat ion recognizes that AY-YILDIZ 15 MW Wind Power Plant Project is helping country fulf i l l i ts goals of promoting sustainable development. It is validated that carbon revenues has been considered priorly for the project act ivity. The agreement between carbon consultant and project owner is June 2008 and local stakeholder consultation is dated August 2008. After local stakeholder consultation, project started in September 2008. These dates are clearly shows that ver revenues have been considered priorly. The Project Scenario is considered additional in comparison to the baseline scenario, and therefore eligible to receive GS Voluntary Emissions Reductions (VERs) under the Gold Standard, based on an analysis, presented by the PDD, of investment, technological and other barriers, and prevail ing practice. The project design is sound and the geographical (Balikesir province, Edincik Ward, Turkey) and temporal boundaries of the project are clearly def ined.



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CAR2 -The locations of project facilities are not identified in section A.4.1 of PDD.

A site layout has been included in Annex 7 of the PDD.

Site layout has been seen in Annex 7 of the PDD.

The corrective action request is closed.

CL2- The view of the project participants on the contribution of the project activity to sustainable development is not included in this section of the PDD.

The view of project participants on contribution of project is included in end of the section A.2.

The view of the project participants on contribution of the project activity to sustainable development is included in PDD version 02.

Clarification is closed.

3.2 Baseline and Additionality The AY-YILDIZ 15 MW Wind Power Plant project uses the approved consolidated baseline methodology ACM0002 (consolidated methodology for grid-connected electricity generation from renewable sources, version 09).

The baseline methodology is applicable for the project activity since;

• The Project is a 15 MW grid connected renewable electr icity generation project,

• The project does not involve switching from fossil fuel use to renewable energy at the site of the project act ivity,

• The geographic and system boundaries for the relevant electr ici ty grid can be clearly identif ied and information on the characteristics of the grid is available.

The possible alternative baseline scenarios are the fol lowing: (a) Proposed project activity without VER; (b)Continuation of the current situation-supply of equal amount of electricity in the grid (c) Construct ion of a thermal power plant with the same installed capacity or the same annual power output.

The baseline options considered do not include those options that:

• Do not comply with legal and regulatory requirements; or

• Depend on key resources such as fuels, materials or technology that are not available at the project site.

Construct ion of a thermal power plant is a signif icant alternative to the project act ivity since the share of thermal power plants have increased and is expected to increase in the future by nearly 100% from the current level of approximately 41,000 MW to 79,000 MW by 2020



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Such alternative is not expected to face any prohibit ive barriers that could have prevented it from being taken up as the project activity. The assessment and demonstration of additionality of the project is done by using UNFCCC Methodological Tool “Tool for the Demonstrat ion and Assessment of Additionality”, Version 05.2.

In the application of this tool both “Step 2: Investment Analysis” and “Step 3: Barrier Analysis” is selected. For demonstrating the investment analysis, the project proponent used Benchmark Analysis. The benchmark is selected to compare if the investment is feasible regarding to another investment tool which is selected as Eurobond in our case. Equity IRR is calculated for the project activity and it shows the f inal return on the init ial equity investment. Both 2025 and 2030 Eurobond rates are 7,54 and 7,31 which are higher than the IRR which is calculated as 6,19. All the input values used for the IRR calculat ion are verif ied with the agreements. (The list of the agreements used for the validat ion is available in references sect ion of this validat ion report.) It is confirmed that assumptions are appropriate and the f inancial calculations are correct. Risk premium for the project country is taken from the Stern University report and it is also using by the banks as a reference to determine the risk premiums. With adding risk premium to the Eurobond rates the total benchmark value comes to 12,78 which is higher than the values al l IRR and sensit ivity analysis. It is verif ied that the investment and sensit ivity analysis shows that the VER revenues will improve the f inancial indicators of the project and make the project more attract ive for investors. It is seen that project is not the most attract ive option. Therefore project is considered as additional to the baseline scenario. Investment Limited incentives for renewable energy defined as a barrier for the project act ivity. Wind projects are more risky than thermal power plants because production is depend on wind and it is not under control of project owner to produce electricity in peak hours. Therefore, these plants cannot produce, control and sell energy at competit ive prices as defined at Electrical Market Financial Balancing Center. Also State dominates the national grid therefore state controls the supply and prices. .In Turkey the maximum guarantee price is 5,5 cents/kWh therefore plants cannot sel l energy to a competit ive prices. On the other hand thermal power plants can define their further production i t is not r isky l ike wind projects and wind power plants, once built, must be operated whatever the market price is whereas thermal power plants can be shut down depending on the market price.



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CL17 - In section B.5 Step 1.a 2 alternatives defined.(Please see question 1.d). Alternative 2 “Continuation of the current situation – supply of equal amount of electricity in the grid was eliminated. In section 3.b “Electricity generation by existing grid defined as an alternative” Please clarify.

The wording “Electricity generation by existing grid defined as an alternative” has been deleted from section 3.b

The clarification is closed.

CL18 - Please give the ref. that thermal power plants require lower investments compared to the renewable energy investments.

Reference from www.ewea.org has been added for high initial investment for wind PPs and attached above (CL16)

The reference document couldn’t be reached, please send the PDF version of the referred pages to the DOE.

The attached document has been reviewed by the validation team. The clarification request closed.

CL19- Please give more detail and ref. that the construction of thermal power plants is easier and meet no barriers.

Discussion about construction barriers is removed from barrier analysis.


3.3 Monitoring Plan The Project uses the approved consolidated monitoring methodology ACM0002 (consolidated methodology for grid-connected electricity generation from renewable sources, version 09). Refer discussions on the validity of the methodology at section 3.2 above.

The adopted monitoring methodology has been chosen based on the following reasons:

• Ayyi ldiz Wind Power Plant Project is a 15 MW grid connected renewable electr icity generat ion project,

• The project does not involve switching from fossil fuel use to renewable energy at the site of the project act ivity; and

• The geographic and system boundaries for the relevant electricity grid can be clearly identif ied and information on the characteristics of the grid is available.

CAR 5 - It is not justified if the methodology is applicable for this project in section B.7 of the PDD.

Applicability of the baseline and monitoring methodology has been justified in section B.1 as requested, since the project uses combined baseline and monitoring methodology, it was not repeated in B.7.

Please state this explanation in PDD.




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Explanation has been added to PDD as requested.

CAR6 - It is not stated in PDD that verification can be done through PMUM pages and invoices.

Since the PMUM web site is accessible through a secure ID and password, it had not been mentioned in PDD but upon request of DOE, it was added in monitoring plan. However, net electricity generation delivered to the grid and figures from PMUM will be different (about 2-3%) due to grid loss factor. Figures from PMUM and meters can be matched considering loss factor to an extend but it may not always end with exactly same figures using loss factor data.

Further clarification was added as requested.

In PMUM pages ISVM and UEVM data’s are available please explain if ISVM data will be different from the plant manager records.

It is clearly stated in PDD 19.08.2009 dated that ISVM (electricity supplied to the grid) data will be used for monitoring. The corrective action request is closed.

CAR7- The selection and discussion of the monitoring methodology is not stated in PDD.

Selection of the methodology has been justified in section B.1 according to the PDD template and guidelines. Details about methodology have been included in PDD and explanation has been added.

The justification of the choice of the baseline has been added to Section B.2 and is also applicable to the monitoring methodology. Please also state the explanation given in the PDD.


3.4 Calculation of GHG Emissions As per Approved consolidated baseline and monitoring methodology ACM0002 “Consolidated baseline methodology for grid-connected electricity generat ion from renewable sources”, the baseline emission sources considered are thermal power plants supplying electr icity to the Turkish grid. As required under ACM0002 version 9, the baseline emission factor of the Turkish grid is calculated by Methodological tool “Tool to calculate the emission factor for an electricity system” (Version 01.1). The detai led algorithms are described later under sections B.6 and Annex 3 of the PDD, also calculation details were given in a separate excel sheet to the validat ion team. As described in Approved consolidated baseline and monitoring methodology ACM0002 “Consolidated baseline methodology for grid-connected electr icity generation from renewable sources”, the project



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emissions are at a negligible level. However the project proponents have also taken the internal combustion of the auxi l iary diesel generator into account in their PDD. The project emissions occurring from the diesel generator is also included in the monitoring plan. As the consumption f igure of the generator is not yet known, the project emission at the stage of validat ion is zero. However, during the verif icat ion stage the fuel consumption of the diesel generator and result ing CO2 emissions shall be taken into account. The estimated total emission reductions wil l be 216,981 tCO2e over the credit ing period of emission reduction represents a reasonable estimation using the assumptions given by the project. The list of CARs and CLs and their resolution/conclusion related with the calculation of GHG emissions are as follows: CAR/CL Resolution Conclusion CL13 - Simple OM method selected regarding to ACM0002. Please state this in section B.6.3 step2

Justification and selection of Simple OM is moved to step 2.

Justification for the selection of Simple OM method has been reviewed by the validation team and has been found appropriate.

Clarification is closed. CAR15 - Are the baseline emissions determined according to the formula BEy = EGy x EFy

Formula for the baseline emission calculation is added together with data used and result of calculation.

The formula has been added to the PDD, however please also add the calculation details (i.e. the values applied and the calculation results).

The values applied are given.

The clarification is closed. CAR 16 - Did the emissions reductions were determined according to the formula ERy = ERheaty + ER electricity y + BE biomassy –PE y – Ly

Emission reduction formula is added with relevant data.

. Emission reduction formula has been added to the PDD, however please also add the calculation details (i.e. the values applied and the calculation results).


The clarification is closed. CAR14 - Were all values chosen in a conservative manner and was the choice justified?

EF values for fuels consumed were revised. New values selected from National GHG Inventory Report of Turkey as in compliance with the tool for calculation of EF.

a) IPCC values have been

a. Turkey uses TIER I approach in national inventory calculations (please see page 66 of the following document: http://unfccc.int/resource/docs/natc/turnc1.pdf) In TIER I approach the EF used are the IPCC default values and



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used as requested and PDD has been revised accordingly.

b) NCV data published by TEIAS has been used in revised baseline calculations.

c) For generation efficiency of the plants, reference for most up to date official records of the government has been used. Since, it is not possible to identify the technology, efficiency etc. of each plant, these values are considered in calculations. BAT data has been used for LPG and Naphta, which are not available in the tool applied as a conservative approach as the values used are close to the upper limit for liquid fuels given in the table referred.

Explanation has been added to step 5. of baseline calculation in PDD

d) The sentence has been revised in PDD.

not the national values. Therefore these values can not be used in the calculations. Please use IPCC default values at the lower limit of the uncertainty at a 95% confidence interval as suggested by the Tool.

The emission factors announced in the Turkish Inventory are IPCC default values and do not reflect the country specific values. Please revise the calculations by using IPCC default values at the lower limit of the uncertainty at a 95% confidence interval. (IPCC min values)

In the version 3 of EF calculations the emission factors has been revised according to IPCC values and these values are accepted.

In page 30 of the PDD, it is stated that for EF of fuels consumed National GHG Inventory report has been used however IPCC values are used in the calculations. Please correct.

In the PDD it is stated that NCV values for lignite and coal are taken from Turkey’s NIR. However these values are calculated using the reference approach of IPCC. This approach is a very rough estimate and it includes all the coals that are extracted and imported to Turkey. It is not only specific to electricity generation. Therefore these values can not be used.

b. Regarding the efficiency of the plants, in the tool it is



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suggested to use the following values:

o Documented manufacturer’s specifications (if the efficiency of the plant is not significantly increased through retrofits or rehabilitations); or

o Data from the utility, the dispatch center or official records if it can be deemed reliable; or

o The default values provided in the table below in annex 1.

IPCC BAT values are not suggested in the tool.

Also Environmental Map of Turkey was published in 2001 and the data given in this document belongs to old power plants and may not reflect new practices, therefore the assumption of the efficiencies of the recent capacity additions are same as the old plants imposes a high risk for the BM calculations.

The justification is acceptable however it is not added to the PDD.

c. It is stated in the PDD that the Emission Factors of coal and lignite have been calculated using country specific heating values, please clarify.

In PDD version 5.1 Generation efficiency values are used from the Annex1 of the methodology which is in line with the methodology.

The clarification request closed.



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CL14 - The EF will remain same over the first crediting period regarding to ACM0002.

a. Please state this in PDD section B.6.3. Step 4.

The sentence stating that EF will remain same over first crediting period was added to step 6 of section B 6.2


CL14 - Please justify the assumptions made in determining the project electricity system.

Assumptions made in feasibility preparation were included in PDD

Main assumptions in calculating the project generation were;

• 2% loss for due to electrical efficiency and

• 1% loss due to utility downtime

Please give which assumptions are added to the PDD.

This clarification is closed.

CL14 - Please state that there is no DNA in Turkey

Nonexistence of DNA is stated in A3

The statement added under section A3 of the PDD has been reviewed. Clarification is closed.

CL15 - Are transmission & Distribution losses neglected as required by the methodology?

By definition, EGY is net electricity generated to the grid by the power plant. However, for clarification, it was included in sections B 6.3 and A.2. Data used and result of calculation has been added as requested.

The comments about the transmission and distribution losses have been added to the PDD. however please also add the calculation details (i.e. the values applied and the calculation results).

The details of the calculations added to the PDD. The clarification is closed.

CAR 24 - Please give detailed list of capacity additions for the year 2007 in the baseline calculation sheet.

The related pages from Turkish electrical energy 10-year generation capacity projection (2008-2017) has been given in worksheet “capacity addition 2007 details” in the baseline calculation.


CAR25 - Please give detailed list of capacity additions for the year 2006 in the baseline calculation sheet.

The related pages from Turkish electrical energy 10-year generation capacity projection (2007-2016) has been given in worksheet “capacity addition 2006 details” in the baseline calculation.




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3.5 Sustainable Development Impacts There exists no settlement or agricultural activity in the project site. Project site is currently used as grassland for grazing activit ies by the local community. Grassland area has been expropriated partially for the project however; however it is st i l l available to the local community for grazing act ivit ies. Since the 5 turbines and the power house which wil l be built for electr icity generat ion occupies about 1,000 m2 land, it wi l l not affect any grazing activity in the region. On the contrary, since the project is allocated for WPP. CAR9 - Regarding to environmental law the project has no environmental impact. Please discuss the social impact since the project area is grassland.

Information about the use of grassland is included in section D of PDD.

This corrective action request is closed.

CAR10 - No, transboundary environmental and social impacts are not considered.

A paragraph about environmental and economic impacts of the project has been included in section D.


3.6 Comments by Local Stakeholders The comments from stakeholder have been posit ive in general. The main concern was related to the located grassland project. Other main issue was about icing of blades which has been replied during the meeting also. Local stakeholder consultat ion meeting to discuss stakeholder concerns on the proposed Gold Standard (GS) project – AY-YILDIZ 15 MW Wind Power Plant at Global Tan Energy was held at t ime on 19/09/2008 at Edincik Municipal ity Hall, Bandırma, Balıkesir, Turkey. The list of participants, not ice invit ing part icipation to interested stakeholders, photographic record of the stakeholder meeting proceedings is maintained by the project part icipants. The stakeholders viewed AY-YILDIZ 15 MW Wind Power Plant project as contributing to local environmental benefits and socio-economy. Overal l, there was agreement that the project activity was a beneficial project from the local sustainable development. These views were endorsed by the local stakeholders interviewed during the site visit of the val idation activity.

CAR11 - There is no evidence that the site can be use as grassland after the commissioning.

CAR 11- Explanations about grassland and ice throw have been added to the relevant section in PDD.




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CAR12 - The turbine blades can be produce ice and it may be harmful. If the area is going to be use as a grassland this should be taken into account and the evidence of the response should be stated in PDD.

CAR 12- Considering the climate of the region and the fact those animals will not be out for grazing at such low temperatures, this is not expected to be a concern for the project.*

Also, as seen during the site visit, area was being used for grazing by local community. The project proponent has declared the intention of allowance for use of the land as grassland after commissioning. Since allocation of the land for WPP will prevent establishment of mining stones in the region, project will also help protecting grassland.

This corrective action request closed.

CL26 - It is stated that the main concern of the local stakeholders is the use of land as grazing land. The project owner states that the use of land for grazing will not be prevented. Please give the total area that will be available for grazing activities together with the total area of the project activity. (Please state the ratio of the total project area that will be available for grazing) Please also support your argument by presenting an official letter from the project owner stating that this area will be available for grazing activities.

Since it does not require any change in the project design, only response of project owner has been given.

The total rented area for the project activity is smaller than 0,01 of the total grazing land. It is stated that the area can be used for grazing after commissioning also the letter from the project owner stating that the area will be available for grazing has been submitted to DOE. The use of the land for grazing activities has also been included to the monitoring plan. The clarification request is closed.

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS According to the Gold Standard requirements the voluntary GS project should be web-hosted in GS Registry for 60 days. The project participant



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is responsible for making the related documents available for global stakeholders. Bureau Veritas Certif ication also published the project documents on the BV website (http:/ /cert if ication.bureauveritas.com.tr) on 06/05/2009 and invited comments within 28/08/2009 by Part ies, stakeholders and non-governmental organizations. No comments received during this period.

5 VALIDATION OPINION Bureau Veritas Certif ication has performed a val idat ion of the AY-YILDIZ 15 MW Wind Power Plant Project in Turkey. The val idation was performed on the basis of UNFCCC – CDM Methodology criteria and Gold Standard Version 02 criteria and also on the cri teria given to provide for consistent project operat ions, monitoring and reporting. The val idat ion consisted of the following three phases: i) a desk review of the project design and the baseline and monitoring plan; i i ) follow-up interviews with project stakeholders; i i i) the resolut ion of outstanding issues and the issuance of the f inal validat ion report and opinion. Project part icipant/s used the latest tool for demonstrat ion of the additionality. In l ine with this tool, the PDD provides investment analysis and investment barriers to determine that the project act ivity itself is not the baseline scenario. By generat ing electr icity from wind the project is expected to result in reductions of GHG emissions partially displacing electr icity that would have otherwise been generated from the grid, the project is l ikely to result in reductions of GHG emissions part ial ly. An analysis of the investment and investment barriers demonstrates that the proposed project act ivity is not a l ikely baseline scenario. Emission reductions attributable to the project are hence additional to any that would occur in the absence of the project activity. Given that the project is implemented and maintained as designed, the project is l ikely to achieve the estimated amount of emission reductions. The review of the project design documentation (version 05.1 dd. 31.05.2010) and the subsequent follow-up interviews have provided Bureau Veritas Certif icat ion with suff icient evidence to determine the fulf i l lment of stated criteria. In our opinion, the project correct ly applies and meets the relevant UNFCCC requirements for the Gold Standard version 02.



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The validat ion is based on the information made available to us and the engagement condit ions detailed in this report.

6 REFERENCES

Category 1 Documents: Documents provided by Type the name of the company that relates directly to the GHG components of the project.

/1/ Ayyildiz PDD Version 1 – March 2009

/2/ Ayyildiz PDD Version 2 – 19 August 2009

/3/ Ayyildiz PDD Version 3 – 17 September 2009

/4/ Ayyildiz PDD Version 05.1 – 31.05.2010

/5/ Ayyildiz Combined Margin Emission Factor Calculation Excel Sheet v.1

/6/ Ayyildiz Combined Margin Emission Factor Calculation Excel Sheet 31.05.2010

/7/ Ayyildiz Financial Model V.4

/8/ GS_Passport_AYYILDIZ_31_05_2010_GS revision2

/9/ GS_Passport_AYYILDIZ_08_03_2010_GS revision

/10/ GS_Passport_AYYILDIZ_09_10_2009_for_GS registration

/11/ AYYILDIZ WIND GS_SC 30.01 2009

Category 2 Documents:

Background documents related to the design and/or methodologies employed in the design or other reference documents.

/1/ Micrositing of Ayyildiz

/2/ Energy Consultant Construction Agreement

/3/ Turbine purchase and maintenance agreement with Vestas. (Service and Availability Agreement, Supply and Installation Agreement, Sales and Assembly Agreement)

/4/ PRD Environmental Consultancy Agreement

/5/ Deutsche Wind Measurement Agreement

/6/ Vestas Service and Availability Agreement.

/7/ Engineering and Consulting Agreement

/8/ Ayyildiz Bird Monitoring Autumn 2009 Report

/9/ Ayyildiz Bird Monitoring Studies 2010 Winter Report

/10/ Pre environmental Assessment Report.



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Persons interviewed:

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

/1/ M.Kemal Demirkol - Global Tan Energy

/2/ Evren Kaleli – Global Tan Energy

/3/ Kemal Atila – Akenerji Elektrik Uretim A.S.

/4/ Huseyin Ozturk – Akenerji Elektrik Uretim A.S.

/5/ Fikri Burmaoglu – Turkish Official Land Registry Surveyor

/6/ Fevzi Ipek - Mayor , Municipality of Edincik

/7/ Atilla Soner – Edincik Villager – Ayyildiz WPP Employee

/8/ Erhan Eren – Edincik Villager – Ayyildiz WPP Employee

/9/ Mesut Dertli – Edincik Villager – Ayyildiz WPP Employee

/10/ Turhan Tura – Edincik Villager

/11/ Cevdet Doğan – Edincik Villager

- o0o -



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APPENDIX A: COMPANY CDM PROJECT VALIDATION PROTOCOL

Table 1 Requirements Checklist

CHECKLIST QUESTION COMMENTS Draft Concl

Final Concl

A. General Description of Project Activity

The project design is assessed.

A.1. Title of the project activity, version number and date of the document

1. Date of the document is not given in dd/mm/yyyy format.

CL1 OK

A.2. Description of the project activity

A.2.1. Is the view of the project participants on the contribution of the project activity to sustainable development included?

No. The view of the project participants on the contribution of the project activity to sustainable development is not included in this section of the PDD.

CL2 OK

A.2.2. Category of the project activity

A.2.2.1. Is it justified how the proposed project activity conforms to the project category selected?

Please justify how the proposed project activity conforms to the project category selected.

CAR1 OK

A.2.3. Technology to be employed

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

A.2.3.1. Does the project use state of the art technology or would the technology result in a significantly better performance than

2. Please clarify if the project uses state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in

CL3 OK



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Final Concl

any commonly used technologies in the host country?

the host country

A.2.3.2. Is the project technology likely to be substituted by other or more efficient technologies within the project period?

Please clarify if the project technology is likely to be substituted by other or more efficient technologies within the project period.

CL4 OK

A.2.3.3. Does the project require extensive initial training and maintenance efforts in order to work as presumed during the project period?

Please explain if the project requires extensive initial training and maintenance efforts in order to work as presumed during the project period

CL5 OK

A.2.3.4. Does the project make provisions for meeting training and maintenance needs?

No the project does not make provisions for meeting training and maintenance needs

CL6 OK

A.2.4. Are the project’s system (components and facilities used to mitigate GHGs) boundaries clearly defined?

The location of project facilities are not identified in section A.4.1 of PDD.

CAR2 OK

A.3. Description of how the anthropogenic GHG emissions by sources are reduced below those that would have occurred in the absence of the proposed project activity

A.3.1. Is the proposed project activity additional? Please see Table 3 - Additionality Protocol of the project. - -



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Final Concl

A.4. Emission Reductions

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

A.4.1. Ex-ante calculations of emmission reductions.

The validation of predicted project GHG emissions focuses on transparency and completeness of calculations.

A.4.1.1. Are all aspects related to direct and indirect GHG emissions, including leakage, captured in the project design?

3. It is not stated in PDD. CL7 OK

A.4.1.2. Have conservative assumptions been used to calculate project GHG emissions?

Ref. ACM0002 Protocol 1.8.4 - -

A.5. Application of the monitoring methodology and 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.

B.7.1. Is the monitoring methodology applicable for this project and is the appropriateness justified?

It is not justified in section B.7 of the PDD. CAR3 OK

B.7.2. Does the monitoring methodology reflect good monitoring and reporting practices?

It is not stated in PDD that verification can be done through PMUM pages and invoices.

CAR4 OK

B.7.3. Is the discussion and selection of the monitoring methodology transparent?

No, the selection and discussion of the monitoring methodology is not stated in PDD.

CAR5 OK



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Final Concl

B.8. Details of the baseline and its development

B.8.1. Is the date of completion provided? It is not stated in the PDD. CAR8 OK

C. Duration of the Project activity / Crediting Period

It is assessed whether the temporary boundaries of the project are clearly defined.

C.1. Are the project’s starting date and operational lifetime clearly defined and reasonable?

Please clearly state the starting date and the operational life time.

CL8 OK

C.2. Is the assumed crediting time clearly defined and reasonable (renewable crediting period of max. two x 7 years or fixed crediting period of max. 10 years)?

The crediting period can be renew for 2 times. Please correct in section C.2.1.2.

CL9 OK

D. Environmental and Social Impacts

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

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

Regarding to environmental law the project has no environmental impact. Please discuss the social impact since the project area is grassland.

CAR7 OK

D.1.2.Are transboundary environmental and social impacts considered in the analysis?

No, transboundary environmental and social impacts are not considered.

CAR8 OK



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Final Concl

E. Stakeholder Comments

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

E.1.1. Has due account been taken of any stakeholder comments received?

Yes, the comments received about grassland area, job opportunities and about the blades.

Job provided to the region people and it is verified during site visit.

There is no evidence that the site can be use as grassland after the commissioning.

The turbine blades can be produce ice and it may be harmful. If the area is going to be use as a grassland this should be taken into account and the evidence of the response should be stated in PDD.

OK

OK

CAR9

CAR10

OK

OK

OK

OK



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Table 2 Baseline and Monitoring Methodologies: ACM 0002

CHECKLIST QUESTION MoV* COMMENTS Draft Concl

Final Concl

• Baseline Methodology

• 1. Applicability

1.1.1. Does the project activity generate electricity from a renewable source?

DR I

Yes, the project generate electricity from the wind. OK OK

1.1.2. Is the power connected to the grid? DR I

Yes, the power is connected to the grid. OK OK

1.1.3 If answer to question above is ‘No’, whether it displaces the electricity generated in grid ?

DR I

n.a..

1.1.4 Is the baseline methodology used in conjunction with the approved monitoring methodology ACM0006

DR No, the methodology is not in conjunction with ACM0006.

OK OK

1.1.5 Does the project activity relate to electricity capacity additions from renewable sources?

DR I

No, it is not relate capacity additions from renewable sources.

OK OK

1.1.6 Does proposed project activity falls in either of the categories – Green filed Power Project, Power capacity expansion, Energy efficiency Improvement / Fuel Switch

DR I

No, it is not falls in the categories defined. OK OK

1.1.7 Can the geographic and system boundaries for the relevant electricity grid be clearly identified?

DR I

Yes, the geographic and system boundaries of the grid can be clearly identified.

OK OK

1.1.8 Is the information on the characteristics of the grid available?

DR I

Yes, the characteristics of the grid available. OK OK

1.1.9 Will the Project activity consume in-house biomass or will it be purchased from outside?

DR No, the project will not consume in-house biomass or not purchased from outside.

OK OK

1.1. 10 Will implementation of Project result in increase in processing capacity of raw input?

DR I

n.a.

1.1.12 Will biomass to be used by Project activity be stored for more than one year?

DR I

n.a.

1.11 Will biomass require significant energies (like Processing) other than transportation?

DR I

n.a.



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Final Concl

1.12 Is material and energy balance (heat and steam requirements for the processes) information available and assessed Old plants Proposed plants

DR I

n.a.

1. 2. Project boundary

1.2.1. Did the project participant account for the CO2 emission from electricity generation in fossil fuel fired power that is displaced due to project activity?

DR n.a.

1.2.2 Did the project participant account for the CO2 emission from Heat generation in fossil fuel based power that is displaced due to project activity?

DR n.a.

1.2.2. Does the spatial extent of the project boundary include the power plant at project site, means of transportation of biomass and all power plants connected physically to the electricity system that the CDM project power plant is connected to?

DR n.a.

1.2.3 Is ‘Biomass dumped or left to decay or burned in uncontrolled manner without utilizing for energy purposes most likely scenario?

DR I

n.a.

1.2.4 If answer to Question 1.2.3 is Yes, then are CH4 emissions in the project boundary are included?

DR n.a.

1.2.5 If answer to Question 1.2.3 is Yes, then are CH4 emissions calculated in a conservative manner using emission factors for uncontrolled burning of biomass?

DR n.a.

1.2.6 Whether choice of inclusion/exclusion CH4 emissions in project and baseline are documented in PDD?

DR n.a.

1.2.7. Is the regional project electricity system identified by the spatial extent of the power plants that can be dispatched without significant transmission constraints?

DR Since there is no DNA in Turkey there is no delineation of the project electricity systems so the criteria for determining the existence of significant transmission constraints were considered according to the ‘’ Tool to calculate the emission factor for an electricity system’’.

OK OK

1.2.8 Whether N2O has been excluded as GHG source within DR n.a.



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Final Concl

the project boundary?

1.2.8. Are the assumptions made in determining the project electricity system defined and justified?

DR Please justify the assumptions made in determining the project electricity system.

CL10 OK

1.2.9. Does the application of this methodology result in a clear grid boundary?

DR Yes application of this methodology result in a clear grid boundary. The boundary of the grid is national grid.

OK OK

1.2.10. Does the application of this methodology result in a given country specific variations in grid management policies?

DR n.a.

1.2.11. If answer to question is yes then whether DNA of the host country provides the delineation of grid boundaries.

DR n.a.

1.2.12. If answer to question is no whether DNA guidance is available for defining the boundary.

DR Please state that there is no DNA in Turkey. CL11 OK

1.2.13. If answer to question is no whether the layered dispatch system (e.g. state/provincial/regional/national) the regional grid is used

DR There is no layered dispatch system in Turkey. The project uses national grid.

OK OK

1.2.14. If the regional grid is not used whether the national or state grid is used.

DR National grid used. It is stated in section B.6.3 OK OK

1.3. Identification of alternative baseline scenarios

1.3.1. Are Realistic and credible alternatives separately determined for power, biomass and Heat?

DR Yes, realistic and credible alternatives are determined for power only, since there is no biomass consumption or heat production.

OK OK

1.3.2. Are the various options for alternatives explained in PDD?

DR Yes, various options for alternatives explained in PDD. OK OK

1.3.3. Is the explanation of these options transparent and DR Yes, the explanations of these options are transparent OK OK



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Final Concl

complete and complete. 1.3.4 Did the project participant provide evidence and supporting documents to exclude baseline options that do not comply with legal and regulatory requirements; or depend on key resources such as fuels, materials or technology that are not available at the project site?

DR Yes, the project participant provide evidence. Figure.5 OK OK

1.3.5 Are the calculations for baseline are as per latest version of ACM 0002 as required by this methodology?

DR 4. Please use version 10 of this methodology. CL12 OK

1.3.6 Are transmission & Distribution losses neglected as required by the methodology?

DR It is not stated in the PDD. CL15 OK

1.3.7 Is quantity of electricity required for operation of plant subtracted?

DR 5. The electricity required for the operation is negliable regarding to methodology.

OK OK

1.3.8 Where EG-historical is the average of historical electricity delivered by the existing facility to the Grid, whether spanning all data from the most recent available year (or month, week or other time period) to the time at which the facility was constructed, retrofit, or modified in a manner that significantly affected output (i.e., by 5% or more), expressed in MWh per year. A minimum of 5 years (120 months) (excluding abnormal years) of historical generation data is required in the case of hydro facilities.

DR n.a.

1.3.9. Whether a minimum of three years data is referred and used in case the project is non-hydro?

DR n.a.

1.3.10. Is it required to estimate the point in time when the existing equipment would need to be replaced in the absence of project activity?

DR The project activity is installation of a new grid connected power plant. It is not required to estimate the point in time when the existing equipment would need to be replaced in the absence of project

OK OK

1.3.11 If the answer to question is Yes Whether project participants have taken any of the two approaches, indicated in the ACM0002 into account?

DR n.a. n.a.



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Final Concl

1.3.12 Whether the typical average technical lifetime of the type equipment is determined and documented taking into account common practices in the sector and country e.g. based on industry surveys, statistics, and technical literature?

DR It is not stated in PDD. CAR11 OK

1.3.13. Whether the common practices of the responsible practices of the responsible company regarding the replacement schedules is evaluated and documented, e.g. based on historical replacement records for such equipment?

DR n.a. n.a.

1.3.14. Whether the baseline emission factor is calculated as a combined margin consisting of the combination of operating margin (OM) and build margin factors according to three steps indicated in the methodology ACM0002?

DR The emission factor calculated as a combined margin. 6 steps followed regarding to methodology ACM0002.

OK OK

1.3.15 Whether the weighted average applied by project participant is fixed for a crediting period.

DR Exante option is selected as stated in PD. So the weighted average is fixed for a crediting period.

OK OK

1.3.16. Whether operating margin emission factors calculations are based on one of the four methods described in the methodology ACM 0002?

DR Simple OM method selected regarding to ACM0002. Please state this in section B.6.3 step2.

OK

CL13

OK

OK 1.3.17 Is the most likely baseline scenario ‘electricity production from other sources feeding into the grid?

DR Yes the most likely baseline scenario is the electricity production from other sources feeding into the grid.

OK OK

1.3.18 If the project activity modifies or retrofits an existing electricity generation facility, is the guidance by EB08 taken into account?

DR I

No, the project does not modify or retrofit an existing electricity generation facility.

OK OK

1.4. Additionality

1.4.1. Was the additionality of the project activity demonstrated and assessed using the latest version of the “Tool for demonstration and assessment of additionality”?

DR Yes. Please see the additionality protocol.



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Final Concl

1.5 Project Emissions

1.5.1. Are the relevant project emissions indicators have been considered ?

DR Regarding to ACM0002 project emissions are negliable for wind projects.

OK OK

1.5.2 Are the project emissions arising out of transportation of biomass and/or on site use of fossil fuel and/or Co2 emissions due to on site electricity consumption and/or Methane emissions from combustion of biomass residues

DR n.a. OK OK

1.5.3 Is the approach for project emissions conservative and transparent ?

DR Ref. 1.5.1 OK OK

1.5.4 In case of Methane emissions due to combustion of biomass, are the relevant IPCC values are taken in to account with appropriate uncertainty ?

DR n.a. OK OK

1.6. Baseline Emissions

1.6.1. Are the baseline emissions determined according to the formula BEy = EGy x EFy ?

DR 6. It is not stated in PDD. CAR12 OK

1.6.2. Were the Emissions Factor for displaced electricity calculated as in ACM0002?

DR Yes. The Emissions Factor for displaced electricity was calculated as in ACM0002

OK OK

1.6.3 Were the baseline emissions for heat correctly represent the existing situation of heat generation?

DR n.a.

1.6.4 Whether ‘life time aspects’ are taken in to account if required so by applicable scenario?

DR No. There is no applicable scenario which required taking in to account “life time aspects”.

OK OK

7. 1.6.5 Does project account for baseline emissions due to natural decay or uncontrolled burning of anthropogenic sources of biomass residues ?

DR n.a.

8. 1.6.6 Does project account for quantity of biomass residues used as a result of the project activity ?

DR n.a.

1.7. Leakage

1.7.1. Are the leakage considered? DR Leakage is negliable regarding to ACM0002 version 09. OK OK 1.7.2. Have any credits been claimed for the project on DR No. No any credits been claimed for the project on OK OK



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Final Concl

account of reducing the emissions due to power plant construction, fuel handling and land inundation below the level of the baseline scenario?

I account of reducing the emissions due to power plant construction, fuel handling and land inundation below the level of the baseline scenario.

1.7.3 Has it been demonstrated that biomass availability from the region is abundant enough & that the use of the biomass residues does not result in increased fossil fuel consumption elsewhere ?

DR n.a.

1.7.4 Is this demonstration done through one of the options L1 to L3 as recommended by the methodology?

DR n.a.

1.7.5 When either L2 or L3 is chosen as a option, the radius for procurement of biomass is at least 20 km and not more than 200 km in any case?

DR n.a.

1.7.6 Where Project cannot demonstrate the procurement of biomass in above stated limits, is leakage penalty applied?

DR n.a.

1.8. Emission Reduction

1.8.1. Did the emissions reductions were determined according to the formula ERy = ERheaty + ER electricity y + BE biomassy –PE y – Ly

DR It is not stated in PDD. CAR13 OK

1.8.2 Are the emission reduction calculations for displacement of power done as appropriate to chosen scenario ?

DR Yes. The emission reduction calculations for displacement of power were done as appropriate to chosen scenario.

OK OK

1.8.4. Were all values chosen in a conservative manner and was the choice justified?

DR I

EF which calculated for coal and lignit should be revised. To calculate operating margin IPCC min. values should be used. Please give detailed list of capacity additions for the year 2007 in the baseline calculation sheet. Detailed list of capacity additions for the year 2006 can be found in the capacity projection report of 2007 which can be found in TEIAS website. Please use this data in

CAR14

CAR21 CAR22

OK

OK

OK



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Final Concl

the BM calculations. 1.8.5. Whether an estimate of likely project emission reductions for the proposed crediting period is prepared as part of the PDD?

DR I

Estimated emission reductions for the proposed crediting period is prepared in section A.4.4. of PDD.

OK OK

1.8.6. Whether the estimate in principle employs the same methodology ACM0006?

DR I

Project is not biomass residue. OK OK

1.8.7. Whether the emission factor is determined ex-post during monitoring?

DR I

The emission factor determined as ex-ante as stated in B.6.3.

OK OK

1.8.8. If yes whether project participants have used models or other tools to estimate the emission reductions prior to validation?

DR I

n.a.

• Monitoring Methodology

2.1. Applicability

2.1.1. Does the project activity generate electricity from a renewable source?

DR I

Yes, the project activity generates electricity from a renewable source.

OK OK

2.1.2. Is the power connected to the grid? DR I

Yes, the power connected to the grid. OK OK

2.1.3. Does the project activity relate to electricity capacity additions from renewable sources?

DR I

Yes. The project relate to electricity capacity additions from wind sources.

OK OK

2.1.4. Is fuel switch done in the process? DR No, OK OK 2.1.5. Can the geographic and system boundaries for the relevant electricity grid be clearly identified?

DR I

Yes, the geographic and system boundaries for the relevant electricity grid can be clearly identified.

OK OK

2.1.6. Is the information on the characteristics of the grid available???????

DR I

Yes, the information on characteristics of the grid is available.

OK OK

2.2. Monitoring Methodology

2.2.1. Does the monitoring plan require monitoring of increased electricity generation from the proposed project activity?

DR Yes, the monitoring plan requires monitoring the amount of electricity generated by the project activity.

OK OK

2.2.2 Does monitoring takes in to account the lower value between (a) the net quantity of electricity generated in the

DR n.a.



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Final Concl

new power unit that is installed as part of the project activity and (b) the difference between the total net electricity generation from firing the same type(s) of biomass at the project site (EG total,y) and the historical generation of the existing power unit(s), (EG historic, 3yr) based on the three most recent years. 2.2.3. Does the methodology requires monitoring of Data needed to recalculate the operating margin emission factor, if needed, based on the choice of the method to determine the operating margin (OM), consistent with ACM0002?

DR Ref. 1.3.14 – 1.3.16 OK OK

2.2.4. Does the monitoring plan require monitoring of Data needed to recalculate build margin emission factor, if needed, consistent with ACM0002?

DR The EF will remain same over the first crediting period regarding to ACM0002.

Please state this in PDD section B.6.3. Step 4.

CL14 OK

2.2.5. Does the monitoring plan require monitoring of data needed to calculate fugitive carbon dioxide and methane emissions and carbon dioxide emissions from combustion of fossil fuels required to operate the geothermal power plant ?

DR n.a.

2.3. Quality Control (QC) and Quality Assunrance (QA) Procedures

2.3.1. Did all measurements use calibrated measurement equipment that is regularly checked for its functioning?

DR

I

In section B.7 QA/QC procedures part of PDD, it is stated that maintenance and calibration of the metering devices will be made by TEIAS periodically. If the difference between the readings of two devices exceeds 0,2%, maintenance will be done before waiting for periodical maintenance.

OK OK

2.3.2. Are the data double checked against commercial data?

DR

I

Yes, the data double checked against commercial data. OK OK

9. 2.3.3 Are frequency of monitoring the parameters defined hourly/daily ?

DR The frequency of monitoring the parameters defined monthly.

OK OK



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Table3 Checklist based on Methodological tool for assessment of additionality

1. Checklist question Comments Draft Concl

Final Concl

1. Additionality of a project activity

a. Does the GS-PDD state the latest version of the additionality tool being used?

Yes, version 05.2 is used to demonstrate additionality. OK OK

OK b. Has the tool used the following steps to assess

additionality

1. Identification of alternatives to the project activity

2. Investment analysis to determine that the proposed project activity is either: 1) not the most economically or financially attractive, or 2) not economically or financially feasible

3. Barriers analysis; and

4. Common practice analysis.

Yes, four steps used to demonstrate additionality in section B.5.

OK OK

c. In Step 1 have all the sub-steps as below followed

1. Sub-step 1a: Define alternatives to the project activity

2. Sub-step 1b: Consistency with mandatory laws and regulations

Yes, all sub-step 1a and 1b followed in section B.5 step 1. OK OK

d. Have the following alternatives been included while defining alternatives as per sub-step 1a

1. (a) The proposed project activity undertaken without being registered as a GS project

Yes, 3 alternatives included while defining alternatives as per sub-step 1a. These are; a.Proposed project not taken as a VER project activity.

OK OK



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activity

2. (b) Other realistic and credible alternative scenario(s) to the proposed GS project activity scenario that deliver outputs services or services with comparable quality, properties and application areas, taking into account, where relevant, examples of scenarios identified in the underlying methodology

3. (c) If applicable, continuation of the current situation (no project activity or other alternatives undertaken).

b. Construction of a termal power plant with the same installed capacity or the same output. c. Continuation of the current situation – supply of a equal amount of electricity in the grid. Alternative a and b selected as an alternative. C is eliminated since it is unrealistic.



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e. Has the project participant included the technologies or practices that provide outputs or services with comparable quality, properties and application areas as the proposed GS project activity and that have been implemented previously or are currently being introduced in the relevant country/region.

No, it is not stated in PD. CAR15 OK

f. Has the outcome of Step 1a: Identified realistic and credible alternative scenario(s) to the project activity done correctly? Please briefly mention the outcome.

The outcome of step 1.a defined as; “Project activity not taken as a VER project” and “Construction of a thermal power plant” alternatives are more likely to happen.

OK OK

g. Is the alternative(s) in compliance with all mandatory applicable legal and regulatory requirements, even if these laws and regulations have objectives other than GHG reductions, e.g. to mitigate local air pollution.

2.

Yes, the alternatives are all in compliance with legal requirements.

OK OK

h. If an alternative does not comply with all mandatory applicable legislation and regulations, has it been shown that, based on an examination of current practice in the country or region in which the law or regulation applies, those applicable legal or regulatory requirements are systematically not enforced and that noncompliance with those requirements is widespread in the country.

n.a.

i. Has the outcome of Step 1b: Identified realistic and credible alternative scenario(s) to the project activity that are in compliance with mandatory legislation and regulations taking into account the enforcement in the region or country and regulations done correctly? Please state the outcome.

The outcome of Step 1.b is The proposed project activity is not the only alternative amongst the project participants that is in compliance with mandatory legislation.

OK OK

j. Has PP selected Step 2 (Investment analysis) or

Step 3 (Barrier analysis) or both Steps 2 and 3.) The PP selected both Investment Analysis and Barrier Analysis to demonstrate additionality.

OK OK

k. In step 2 have all the sub-steps as below followed? 1. Sub-step 2a: Determine appropriate analysis

method

Yes, sub-steps followed as below; 2.a : Determine Appropriate Analysis Method. 2.b : (Option3) Apply benchmark Analysis

OK OK



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2. Sub-step 2b: Option I. Apply simple cost analysis

3. Sub-step 2b: Option II. Apply investment comparison analysis

4. Sub-step 2b: Option III. Apply benchmark analysis

5. Sub-step 2c: Calculation and comparison of financial indicators (only applicable to Options II and III):

6. Sub-step 2d: Sensitivity analysis (only applicable to Options II and III):

2.c : Calculation and Comparision of Financial Indicators. 2.d : Sensitivity Analysis



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l. In sub-step 2a has the determination of appropraite method of analysis done as per the guidance as below 1. Simple cost analysis if the GS project activity and

the alternatives identified in Step 1 generate no financial or economic benefits other than GS related income (Option I).

2. Otherwise, use the investment comparison analysis (Option II) or the benchmark analysis (Option III).

Specify option used with justification

Yes, benchmark analysis has been selected. Since the project generates economic benefits from the sales of electricity and the project activity can be implemented by other parties also Option III bench mark analysis was used

OK OK

m. Has the below guideline followed for sub-step 2b Option I. Apply simple cost analysis 1. Document the costs associated with the GS

project activity and the alternatives identified in Step1 and demonstrate that there is at least one alternative which is less costly than the project activity.

n.a.

n. Has the below guideline followed for sub-step 2b Option II. Apply investment comparison analysis

1. Identify the financial indicator, such as IRR, NPV, cost benefit ratio, or unit cost of service most suitable for the project type and decision-making context.

Please specify

n.a.

o. Has the below guideline followed for Sub-step 2b: Option III. Apply benchmark analysis

1. Identify the financial/economic indicator, such as IRR, most suitable for the project type and decision context.

The calculation on the excel sheet should be clearly shown. IRR identified as an financial indicator for the project activity. Eurobond selected as a benchmark. Please proof with an evidence that tax is included to the Eurobond rates.

CAR16 OK



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2. When applying Option II or Option III, the financial/economic analysis shall be based on parameters that are standard in the market, considering the specific characteristics of the project type, but not linked to the subjective profitability expectation or risk profile of a particular project developer. Only in the particular case where the project activity can be implemented by the project participant, the specific financial/economic situation of the company undertaking the project activity can be considered.

3. Discount rates and benchmarks shall be derived from: (a) Government bond rates, increased by a suitable risk premium to reflect private investment and/or the project type, as substantiated by an independent (financial) expert or documented by official publicly available financial data; (b) Estimates of the cost of financing and required return on capital (e.g. commercial lending rates and guarantees required for the country and the type of project activity concerned), based on bankers views and private equity investors/funds’ required return on comparable projects; (c) A company internal benchmark (weighted average capital cost of the company), only in the particular case referred to above in 2. The project developers shall demonstrate that this benchmark has been consistently used in the past, i.e. that project activities under similar conditions developed by the same company

Please supply the feasibility report with supporting attachments which impact the project starting decision. (Income – expenses (operational, financing, investment) and detail of tangible and intangible assets for the project activity. Please supply documents that supporting the input values in the feasibility report. (price lists of the equipments / other investments from equipment manufacturers / suppliers at the time of decisions) Please provide the local amortisation and depreciation rates and useful life for the investment time and categorize them. (eg. “333339 ve 365 sayılı VUK tebliğleri uyarınca amortismana tabi iktisadi kıymetler” list) Please clarify if there is investment incentive at the decision time. Tax is not considered for 15 years. Please send the details of EPC. 23 years has been taken in IRR calculation, it should be min.10 – max 20 years. Please add the abbreviation list. Please clarify how the revenue calculated. Please give the detail of owner cost. Please write the units of the datas.



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used the same benchmark; (d) Government/official approved benchmark where such benchmarks are used for investment decisions; (e) Any other indicators, if the project participants can demonstrate that the above Options are not applicable and their indicator is appropriately justified.

Please specify benchmark and justify.



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p. Has the below guideline followed for Sub-step 2c: Calculation and comparison of financial indicators (only applicable to Options II and III):

1. Calculate the suitable financial indicator for the proposed GS project activity and, in the case of Option II above, for the other alternatives. Include all relevant costs (including, for example, the investment cost, the operations and maintenance costs), and revenues (excluding CER revenues, but possibly including inter alia subsidies/fiscal incentives, ODA, etc, where applicable), and, as appropriate, non-market cost and benefits in the case of public investors if this is standard practice for the selection of public investments in the host country.

2. Present the investment analysis in a transparent manner and provide all the relevant assumptions, preferably in the GS-PDD, or in separate annexes to the GS-PDD.

3. Justify and/or cite assumptions.

4. In calculating the financial/economic indicator, the project’s risks can be included through the cash flow pattern, subject to project-specific expectations and assumptions

5. Assumptions and input data for the investment analysis shall not differ across the project activity and its alternatives, unless

IRR calculation has been done and all cost included to the calculations.

The input values have been verified with the supported documents.

All income and expenses verified with the supporting documentation like quotations and agreements. However insurance is taken as 145000 in the IRR calculation but in the agreement it is 80000. Please correct.

Maintenance fees were not included in the previous version however they are included in v.3 of IRR calculation. Please explain and proof.



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differences can be well substantiated.

6. Present in the GS-PDD a clear comparison of the financial indicator for the proposed GS activity

Please specify details for above



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q. Has the below guideline followed for Sub-step 2d: Sensitivity analysis (only applicable to Options II and III):

1. Include a sensitivity analysis that shows whether the conclusion regarding the financial/economic attractiveness is robust to reasonable variations in the critical assumptions.

Sensitivity analysis has been done with reasonable variations in the critical assumptions.

OK OK

r. Has the outcome of Step 2 clearly mentioned with justification?

Yes, the outcome of step2 is “The VER revenues will improve the financial indicators of the project and make the project more attractive for investors”

OK OK

s. In step 3: Barrier analysis have all the sub-steps as below followed? 1. Sub-step 3a: Identify barriers that would prevent

the implementation of the proposed GS project activity

2. Sub-step 3 b: Show that the identified barriers would not prevent the implementation of at least one of the alternatives (except the proposed project activity):

Yes, sub-step 3a and 3b followed regarding to barrier analysis. OK OK

t. Has the below guideline followed for Sub-step 3a: Identify barriers that would prevent the implementation of the proposed GS project

1. (a) Investment barriers: For alternatives undertaken and operated by private entities: Similar activities have only been implemented with grants or other non-commercial finance terms. No private capital is available from domestic or international capital markets due to real or perceived risks associated with investment in the country where the proposed GS project activity is to be implemented, as demonstrated by the credit rating of the country or other country investments reports of reputed origin.

Investment Barrier: Please give more detail about “The high level of financing and long payback period” in Turkey and also for your project to support that investment barrier would prevent the implementation of the project. Please give the ref. for the “market prices” and “majority of the power plants owned by state.” In section “Limited incentives for renewable energy. Construction Barrier; Please give the soil structure of the project area and the ref. that the structure is not suitable for the construction.

CL16 OK



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2. (b) Technological barriers: Skilled and/or properly trained labour to operate and maintain the technology is not available in the relevant country/region, which leads to an unacceptably high risk of equipment disrepair and malfunctioning or other underperformance; Lack of infrastructure for implementation and logistics for maintenance of the technology, Risk of technological failure: the process/technology failure risk in the local circumstances is significantly greater than for other technologies that provide services or outputs comparable to those of the proposed GS project activity, as demonstrated by relevant scientific literature or technology manufacturer information, The particular technology used in the proposed project activity is not available in the relevant region.

3. (c) Barriers due to prevailing practice: The project activity is the “first of its kind”.

4. (d) Other barriers, preferably specified in the underlying methodology as examples.



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u. Has the outcome from Step 3a clearly mentioned in PDD?

The outcome of 3 is not mentioned in PDD CAR17 OK

v. Has the below guideline followed for Sub-step 3 b: Show that the identified barriers would not prevent the implementation of at least one of the alternatives (except the proposed project activity):

1. If the identified barriers also affect other alternatives, explain how they are affected less strongly than they affect the proposed GS project activity. In other words, demonstrate that the identified barriers do not prevent the implementation of at least one of the alternatives. Any alternative that would be prevented by the barriers identified in Sub-step 3a is not a viable alternative, and shall be eliminated from consideration.

2. provide transparent and documented evidence, and offer conservative interpretations of this documented evidence, as to how it demonstrates the existence and significance of the identified barriers and whether alternatives are prevented by these barriers.

3. The type of evidence to be provided should include at least one of the following: (a) Relevant legislation, regulatory information or industry norms; (b) Relevant (sectoral) studies or surveys (e.g. market surveys, technology studies, etc) undertaken by universities, research institutions, industry associations, companies, bilateral/multilateral institutions, etc; (c) Relevant statistical data from national or international statistics; (d)

In section B.5 Step 1.a 2 alternatives defined.(Please see question 1.d). Alternative 2 “Continuation of the current situation – supply of equal amount of electricity in the grid was eliminated. In section 3.b “Electricity generation by existing grid defined as an alternative” Please clarify. Please give the ref. that thermal power plants require lower investments compared to the renewable energy investments. Please give more detail and ref. that the construction of thermal power plants is easier and meet no barriers.

CL17

CL18

CL19

OK

OK

OK



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Documentation of relevant market data (e.g. market prices, tariffs, rules); (e) Written documentation of independent expert judgments from industry, educational institutions (e.g. universities, technical schools, training centres), industry associations and others.

Please specify.



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w. Has the outcome from Step 3 clearly mentioned in PDD?

The outcome of Step3 is not clearly identified. CAR18 OK

x. In step 4: Common practise analysis have all the sub-steps as below followed? 1. Sub-step 4a: Analyze other activities similar to

the proposed project activity

2. Sub-step 4b: Discuss any similar Options that are occurring

Yes, sub-step 4a and 4b followed regarding to common practice.

OK OK

y. Has the below guideline followed for Sub-step 4a: Analyze other activities similar to the proposed project activity

1. Provide an analysis of any other activities that are operational and that are similar to the proposed project activity. Other GS project activities are not to be included in this analysis. Provide documented evidence and, where relevant, quantitative information. On the basis of that analysis, describe whether and to which extent similar activities have already diffused in the relevant region.

Please provide an analysis with the similar projects in the region.

CAR19 OK

z. Has the below guideline followed for Sub-step 4b: Discuss any similar Options that are occurring:

1. If similar activities are identified, then it is necessary to demonstrate why the existence of these activities does not contradict the claim that the proposed project activity is financially/economically unattractive or subject to barriers. This can be done by comparing the proposed project activity to the other similar activities, and

Please give the ref. that similar projects are connected at medium voltage level (34.5 kV). Please clearly state why this can be a comparison matter for the project activity.

CL20 OK



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pointing out and explaining essential distinctions between them that explain why the similar activities enjoyed certain benefits that rendered it financially/economically attractive (e.g., subsidies or other financial flows) and which the proposed project activity cannot use or did not face the barriers to which the proposed project activity is subject. In case similar projects are not accessible, the PDD should include justification about non-accessibility of data/information.

æ. Has the outcome from Step 4 clearly mentioned in PDD?

No, the outcome of step 4 is not clearly mentioned. CAR20 OK

ø. Has it been proved that the porject is additional? Yes, the project activity is additional OK OK



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Table 4 Legal Requirements

CHECKLIST QUESTION Ref. MoV* COMMENTS Draft Concl

Final Concl

1. Legal requirements

1.1. Is the project activity environmentally licensed by the competent authority?

2 DR Yes, the project activity environmentally licensed by the environmental and forestry ministry of Turkey.

OK OK

1.2. Are the conditions of the environmental license being met?

2 DR 10. Yes, the conditions of the licence being met. OK OK

1.3 Are the conditions of the Designated National Authority being met?

2 DR There is no DNA in Turkey. OK OK



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TABLE 5 – CHECKLIST BASED ON THE GOLD STANDARD PASSPORT REQUIREMENTS (VERSION 2.1)

CHECKLIST QUESTION GS Ref.

COMMENTS Draft Concl

Final Concl

SECTION A. Project Title

1. Is the Project title given in the Passport same with the Project title given in the PDD and the Registry?

T-1.6 The project title given in the registry is AY-YILDIZ 15 MW WPP, in the PDD it is stated as Ayyıldız 15 MW Wind Power Plant Project, whereas in the passport the project title is given as 15 MW AYYILDIZ WIND POWER PLANT. Please correct the title of the project so that it will be the same with the one in the PDD and the registry. The title of the passport and the GS registry are same now. However PDD and passport are still different.

CL21 OK

SECTION B. Project Description

1. Is the Project description given in the Passport consistent with the one given in the PDD or the non-technical summary used in the Local Stakeholder Consultation?

T-1.6 The project decription given in the Passport is consistent with the one given under section A.2 of the PDD.

OK OK

2. Has the estimated start date of construction been given under the Project description?

T-1.6 Estimated start date of construction is not given in the Passport. Please state the estimated start date of the construction under Section B of the Passport. It is stated in section B that the project construction has started in march 2009. The corrective action request is closed.

CAR23 OK

SECTION C. Proof of project eligibility

C.1. Scale of Project

1. Has the scale of the Project activity been defined as per Gold Standard Toolkit Section 1.2.1?

T-1.2.1 Yes the scale of the Project activity been defined as per Gold Standard Toolkit Section 1.2.1.

OK OK

C.2. Host Country

1. Does the host country have cap on its GHG emissions? T-1.2.2 Turkey does not have cap on its GHG emissions. OK OK

2. If the answer to the above question is yes, then has the Project proponent provided an official approval from the relevant local authorities stating that an equivalent amount of allowances will be retired to back-up the GS VERs issued?

T-1.2.2 N/A

3. If the host country does not have a cap on its GHG T-1.2.2 No, please state in the Passport section C.2 that Turkey CL22 OK



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Final Concl

emissions, has it been stated in the Passport? does not have a cap on its GHG emissions and explain current situation in Turkey briefly. In section c.2 it is stated that Turkey does not have cap. Clarification request is closed.

C.3. Project Type

1. Is the Project a Renewable Energy Supply Project? T-1.2.3 Yes the project is a renewable energy supply project.

OK OK

2. Is the Project an End-use Energy Efficiency Improvement Project?

T-1.2.3 No.

Has the Project type and eligibility of

3. the Project activity been defined as per Annex C of Gold Standard Toolkit?

T-1.2.3 It is stated in the Passport that the sectoral scope of the project is Scope 1 “Energy Industry-Renewable Sources” according to the UNFCCC definition, please also state the project category regarding Toolkit 1.2.c. The project category corrected as GS Toolkit

CL23 OK

4. Has a previous announcement of the project going ahead without the revenues from carbon credits been made?

T-1.2.3 No there is no pre-announcement of the project going ahead without VER revenues. However, the starting date of the project activity should also be given in the Passport Section C.3. The project was not announced previously before the agreement with the carbon consultant (GTE). Also the initial stakeholder consultation is after the agreement.

CL24 OK

5. If the answer to the above question is yes, has the project subsequently been cancelled or the design has been significantly revised?

T-1.2.3 N/A

6. If the answer to question 4 is no, have the Project Proponents provided a pre-announcement statement under section C.3 in the Gold Standard Passport, attesting that no such previous announcement has been made?

T-1.2.3 Yes, it is stated under the pre-announcement section of the GS Passport “This GS VER project activity has been publicly announced with mentioning the carbon Credits nearly at the same time as starting the project activity. The first time which the project was publicly announced was on 29.08.2008, during the announcement of the carbon credit agreement between Akenerji and GTE (Global Tan Energy Limited.)”

OK OK



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Final Concl

C.4. Greenhouse Gas

1. Does the project reduce an applicable GHG? T-1.2.4, 3.5.1

Yes the project reduces CO2. OK OK

C.5. Project registration type

1. Does the project apply the correct project cycle? T-3.5.1 Yes the project activity applies the regular project cycle. OK OK

2. Is the Project activity a regular registration? T-1.2.5 Yes, the Local Stakeholder Consultation has been realized before the start date of the construction. The LSC report has been uploaded to the registry.

OK OK

3. Is the Project activity a retroactive registration? T-1.2.5 No, the project is in a regular registration cycle. OK OK

4. If the answer to the above question is yes, has the Project proponents applied to the Gold Standard for the pre-feasibility assessment?

T-1.2.5 N/A

5. If the answer to the above question is yes, then has the Project proponent provided the Gold Standard pre-feasibility assessment feedback to the DOE?

T-1.2.5 N/A

6. Does the Project activity need preliminary evaluation? (Large hydro or palm-oil related project)

T-1.2.5 No, preliminary evaluation is not required for the project. OK OK

7. If the answer to the above question is yes, has the Project proponents applied to the Gold Standard for the pre-feasibility assessment?

T-1.2.5 N/A


T-1.2.5 N/A

9. Has the Project activity been rejected by UNFCCC? T-1.2.5 N/A. Turkey is not involved in the compliance market.

10. If the answer to the above question is yes, has the Project proponets applied to the Gold Standard for the pre-feasibility assessment?

T-1.2.5 N/A


T-1.2.5 N/A

12. Are there any double counting occuring with other certification schemes?

T-3.5.1 Since Turkey is under a voluntary market, there isn’t any registry system like UNFCCC, however the project activity is not registered under VCS.

OK OK

SECTION D. Unique project identification

D.1. GPS-coordinates of Project location



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Final Concl

1. Has the Project proponent stated the exact GPS coordinates of Project location for point source activities and the boundaries for projects spread over a broader area?

T-1.6 The exact GPS coordinates of Project location for the turbines and the boundaries are given in the Passport Section D.1.

OK OK

2. For Programme of Activity projects have the Project Proponent explained the reasoning behind the definition of the project location and coordinates carefully?

T-1.6 N/A

D.2. Map

1. Have the coordinates been illustrated with a map? (Optional)

T-1.6 Yes the coordinates have been illustrated with a map under section D.2. of the Passport.

OK OK

SECTION E. Outcome stakeholder consultation process

E.1. Assessment of stakeholder comments

1. Has the Project proponent inserted the “Table iii-Assessment of All Comments” in section C3 of the Stakeholder Consultation Report? (Table ii in section B5 of Stakeholder Consultation Report for GSV2)

Annex R, E.1

Yes Table ii from Section B5 has been inserted to the Passport.

OK OK

2. Has the Project proponent inserted a summary of alterations based on stakeholders comments?

Annex R, E.1

A summary of alterations has been inserted under Section E.1. of the Passport. However, although it is stated in the table that the stakeholders have concerns about job opportunities, it is not stated how the project was altered to provide job opportinities to the local stakeholders. It is stated in section e.1 that there will be job opportunities during construction and operation of the project activity. Also, it is stated that the main concern of the local stakeholders is the use of land as grazing land. The project owner states that the use of land for grazing will not be prevented. Please give the total area that will be available for grazing activities together with the total area of the project activity. (Please state the ratio of the total project area that will be available for grazing) Please also support your argument by presenting an official letter from the

CL25 CL26

OK OK



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Final Concl

project owner stating that this area will be available for grazing activities. The total rented area for the project activity is smaller than 0,01 of the total grazing land. It is stated that the area can be used for grazing after commisioning also the letter from the project owner stating that the area will be available for grazing has been submitted to DOE. The use of the land for grazing activities has also been included to the monitoring plan. The clarification request is closed.

E.2. Stakeholder Feedback Round (Can be performed in parallel to the validation process)

1. Has the Project proponent organized a stakeholder feedback round to give feedback to the stakeholders on how their comments have been taken into account?

T-2.11 Yes the project proponent has organised a stakeholder feedback round.

OK OK

2. Did the stakeholder feedback round include a physical meeting? (optional)

T-2.11 N/A

3. Have all the stakeholders invited for participation in the Local Stakeholder Consultation been included in the Stakeholder Feedback Round?

T-2.11 Yes all the stakeholders invited for participation in the Local Stakeholder Consultation have also been included in the Stakeholder Feedback Round.

OK OK

4. Have all of the following documents been made available to the public for a period of at least two months prior to completion of the validation:

• The Latest version of the complete PDD (including the EIA, if applicable);

• A non-technical summary of the project (in appropriate local language(s)); and English summary.

• The (revised) Passport

• if applicable, supporting documentation such as an environmental impact assessment (EIA) (if available, in appropriate local language(s)); in the case of an EIA, at least a one-page English summary is required

• Additional, non-translated information must be

T-3.5.1 The PDD, Passport and LSC report are published on the website of the carbon developer GTE.

OK OK



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Final Concl

made available as well and shall be translated to the local language upon any justified request of a stakeholder.

5. How was the above mentioned documents made public? (Posted on a website, posted on GS registry?)

T-2.11 The above mentioned documents were posted on the Carbon developer website.

OK OK

6. Did the Project proponent also prepare hard copies to be publicly displayed at local places like the post Office, municipality, etc?

T-2.11 It is stated under section E.2. of the Passport that “A summary of the consultation report prepared in Turkish has been sent to identified stakeholders and participants through mail, hand delivery or local representatives.” Please send a copy of this document to the DOE. The non-technical summary of the project has been reviewed by the DOE. The clarification request is closed.

CL27 OK

7. If the Project is a retroactive Project, did the stakeholder feedback round include a site visit by the stakeholders participating in the process?

T-2.11 N/A

8. If the Project is a retroactive Project, did the Project proponent follow the guidance provided by the Gold Standard in the pre-feasibility assessment?

T-2.11 N/A

9. Does the stakeholder feedback round report given in the Passport include the following information:

• How the feedback round was organised (A description of the procedure followed to invite comments, including addressing all the details of the oral hearing such as place, date, participants, language, local or national Gold Standard NGO supporters, etc.),

• What the outcomes of the feedback round are (All written or oral comments received.)

• How did the Project proponents followed up on the feedbacks. (The argumentation on whether or not comments are taken into account and the respective changes to the project design.)

T-3.5.1 It is not explained in the Passport how the stakeholder feedback round was organised. The outcome of the feedback round is not stated in the Passport. The argumentation on whether or not comments are taken into account and the respective changes to the project design is not given in the Passport. It is stated that feedback round was done through web-hosting and no comments received. Also project description web-hosted in BV web page and no comments received for the project activity. The corrective action request is closed.

CAR24 OK

SECTION F. Outcome Sustainability assessment



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Final Concl

F.1. ‘Do no harm’ Assessment

1. Has the Project proponents considered the critical issues for their Project type that are listed in Annex C of Gold Standard?

T-2.4.1 Wind Power Plants are not defined under Annex C of the toolkit. Therefore the checklist question is N/A.

2. Have the Project participants discussed all of the safeguarding principles with the stakeholders?

T-2.4.1 Yes project participants discussed all of the safeguarding principles with the stakeholder consultation.

OK OK

3. Have the Project participants introduced mitigation measures for the safeguarding principles with a medium to high risk?

T-2.4.1 There is no medium or high risk defined for the safe guarding principles. The mitigation measures have been defined for 3 principles that are rated as low risk.

OK OK

4. Does the ‘Do No Harm’ Assessment base on accurate information and have the reference sources been included?

T-3.5.1 The Reference sources of the ‘Do No Harm’ Assessment are not given in the Passport. Please give the reference sources to prove that the assessment is based on accurate information. The refferances given in the do not harm assessment. However for not relevant items, the reason for not being relevant is defined specific to the project activity except items 5-6-7-11 definitions of which are given in more general way. Please define the irrelavance specific to your project activity in the above mentioned items.

CAR25 OK

F.2. Sustainable Development matrix

1. Has the Sustainable Development Matrix table been inserted in the Passport?

AnnexR, F.2

Yes the Sustainable Development Matrix table has been inserted in the Passport.

OK OK

2. Has the project been scored on:

• Environmental

• Social

• Technological

• Economic indicators?

T-2.4.2 Yes the project has been scored on environmental, social, technological and economic indicators.

OK OK

3. Have the corresponding parameters to represent the status of each of the indicators been selected?

T-2.4.2 Yes, the corresponding parameters to represent the status of each of the indicators have been selected.

OK OK

4. Is the baseline situation and the situation aimed for the project described for each parameter?

T-2.4.2 Yes, the baseline situation and the situation aimed for the project described for each parameter.

OK OK

5. Are the indicators connected to the localised MDG’s when possible?

T-2.4.2 Yes, the indicators connected to the localised MDG’s. OK OK



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Final Concl

6. Was the reason for choice of the parameters described? T-2.4.2 Yes, the reason for the choice of the parameters are given. OK OK

7. Have all of the indicators been scored ‘negative’, ‘positive’ or ‘neutral’ in comparison with the baseline situation?

T-2.4.2 Yes, all indicators been scored ‘negative’, ‘positive’ or ‘neutral’ in comparison with the baseline situation.

OK OK

8. If there are any ‘negative’ indicators, are there any mitigation measures for these indicators?

T-2.4.2 There is no negative indicators for the project activity. OK OK

9. Has the matrix been filled by the stakeholders during the local stakeholder consultation ?

T-2.4.2, 3.5.1

Yes, the matrix been filled by the stakeholders during the local stakeholder consultation.

OK OK

10. Were there any negative scores duing the stakeholder consultation?

T-2.4.2 No, there were no negative scores during the stakeholder consultation.

OK OK

11. If the answer to the above question is yes, then has the sustainability assessment been revisited?

T-2.4.2 n.a.

12. Have the project indicators been classified in three categories namely “environment”, “social development” and “economic and technological development” under sustainable development matrix ?

T-2.4.2, 3.5.1

No, the sustainable development matrix is not classified 3 categories.

CAR26 OK

13. Does the project contribute positively to at least two of the three categories and neutral to the third category ?

T-2.4.2, 3.5.1

Ref. F.2.12 Yes, the project contribute positively to at least 2 of the three categories and natural to the third category.

OK OK

14. Is the matrix based on existing sources of information? (can include data from existing reports, results from stakeholder consultations, and experiences with similar projects in similar situations, etc. Where data are unavailable or are of poor quality, or severely outdated, independent opinions and expert judgments can also be used.)

T-3.5.1 Yes, the matrix information based on references and available in the passport.

OK OK

15. Are the data or expert opinions presented in a sufficient degree of detail and transparency?

T-3.5.1 Yes, the data’s are presented transparently. OK OK

16. Are the data uncertainties clearly stated, if possible with associated margins of error?

T-3.5.1 N/A

17. Is the scoring reproducible and verifiable? T-3.5.1 Yes, the scoring is reproducible also most of the items have been verified during site visit.

OK OK

18. Does the project demonstrate clear benefits in terms of sustainable development?

T-2.4.2 Yes, the project demonstrates clear benefits in terms of sustainable development.

OK OK

SECTION G. Sustainability Monitoring Plan



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Final Concl

1. Are the mitigation actions included in the monitoring plan ?

T-2.4.3 Yes, the mitigation actions included in the monitoring plan OK OK

2. Are all the non-neutral indicators included in the monitoring plan?

T-2.4.3 Yes all of the non-neutral indicators are included in the monitoring plan. Please indicate in section “additional remarks monitoring” why parameter 3 is included in the monitoring plan although it is scored zero.

OK OK

3. Is the current status (or expected status under the baseline) of the parameters, the future status and the way they will be monitored described in the monitoring plan?

T-2.4.3 Yes, the current status of the parameters, the future status and the way they will be monitored is described in the monitoring plan.

OK OK

4. Have the project proponents identified parameters that can be used to properly monitor each non-neutral Sustainable Development Indicator according Annex I of the Toolkit?

T-2.4.3 Yes, the parameters have been identified however for item no 7 it is stated that the current situation of the parameter is 0. Please update the current situation.

CL28 OK

5. Are chosen parameters relevant to the indicators? T-3.5.1 Yes,chosen parameters are relevant to the indicators. OK OK

6. Are these parameters planned to be monitored over the crediting period and on a recurrent basis?

T-2.4.3 The parameters are planned to be monitored yearly. Please also indicate for how long these parameters will be monitored.

CL29 OK

7. Are all mitigation measures put in place to prevent violation or the risk of violating a safeguarding principle of the ‘Do No Harm’ Assessment or to ‘neutralise’ a Sustainable Development Indicator included in the monitoring plan?

T-2.4.3 N/A

8. Is the sustainability monitoring plan clear about who will monitor with what frequency?

T-3.5.1 Yes, the sustainability monitoring plan is clear about who will monitor with what frequency

OK OK

9. Is the monitoring plan feasible? T-3.5.1 Yes, the monitoring plan is feasible. OK OK SECTION H. Additionality and conservativeness

H.1. Additionality

1. Does the project additionality follow Gold Standard guidance ?

Yes, the project additionality follows Gold Standard guidance.

OK OK

H.2. Conservativeness

1. Does the project baseline follow Gold Standard guidance ? Yes, the project baseline follows Gold Standard guidance. OK OK



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Final Concl

ANNEX 1 ODA declaration

Is a scanned copy of the Official Development Assistance Declaration statement signed by the project owner given in Annex 1?

AnnexD Yes, ODA declaration statement signed by the project owner.

OK OK



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Table 6 Resolution of Corrective Action and Clarification Requests

Draft report clarifications and corrective action requests by validation team

Ref. to checklist question in table 2/3/4

Summary of project owner response

Validation team conclusion

CAR1- Please justify how the proposed project activity conforms to the project category selected.

A 4.2.2 Justification for the selected category is added to the related section.

The following explanation has been added to the PDD: “Project activity involves electricity generation from renewable sources therefore it is categorized in the sectoral scope 1 “Energy Industry – Renewable Sources” according to the UNFCCC definition.”


CAR2 -The locations of project facilities are not identified in section A.4.1 of PDD.

B.3.2 A site layout has been included in Annex 7 of the PDD.

Site layout has been seen in Annex 7 of the PDD.


CAR 3- It is not justified if the methodology is applicable for this project in section B.7 of the PDD.

B 7.2 Applicability of the baseline and monitoring methodology has been justified in section B.1 as requested, since the project uses combined baseline and monitoring methodology, it was

Please state this explanation in PDD.




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not repeated in B.7.

Explanation has been added to PDD as requested.

CAR4 - It is not stated in PDD that verification can be done through PMUM pages and invoices.

B 7.3 Since the PMUM web site is accessible through a secure ID and password, it had not been mentioned in PDD but upon request of DOE, it was added in monitoring plan. However, net electricity generation delivered to the grid and figures from PMUM will be different (about 2-3%) due to grid loss factor. Figures from PMUM and meters can be matched considering loss factor to an extend but it may not always end with exactly same figures using loss factor data.

Further clarification was added as requested.

In PMUM pages ISVM and UEVM data’s are available please explain if ISVM data will be different from the plant manager records.

It is clearly stated in PDD 19.08.2009 dated that ISVM (electricity supplied to the grid) data will be used for monitoring. The corrective action request is closed.

CAR5- The selection and discussion of the monitoring methodology is not stated in PDD.

B 7.4 Selection of the methodology has been justified in section B.1 according to the PDD template and guidelines. Details about methodology have been included in PDD and

The justification of the choice of the baseline has been added to Section B.2 and is also applicable to the monitoring methodology. Please also state the explanation given in



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explanation has been added. the PDD.


CAR6 - Is the date of completion of baseline provided? B 8.1 Data of completion of baseline is added.

Date of completion of the baseline study is given under section B8 of the PDD as 05/06/2009.


CAR7 - Regarding to environmental law the project has no environmental impact. Please discuss the social impact since the project area is grassland.

D 1.1 Information about the use of grassland is included in section D of PDD.


CAR8 - No, transboundary environmental and social impacts are not considered.

D 1.4 A paragraph about environmental and economic impacts of the project has been included in section D.


CAR9 - There is no evidence that the site can be use as grassland after the commissioning.

E 1.5 CAR 11- Explanations about grassland and ice throw have been added to the relevant section in PDD.




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CAR10 - The turbine blades can be produce ice and it may be harmful. If the area is going to be use as grassland this should be taken into account and the evidence of the response should be stated in PDD.

E.1.5 CAR 12- Considering the climate of the region and the fact those animals will not be out for grazing at such low temperatures, this is not expected to be a concern for the project.*

Also, as seen during the site visit, area was being used for grazing by local community. The project proponent has declared the intention of allowance for use of the land as grassland after commissioning. Since allocation of the land for WPP will prevent establishment of mining stones in the region, project will also help protecting grassland.

This corrective action request closed.

CAR11 – The typical average technical lifetime of the equipment is not mentioned.

1.3.12 The technical life time of the Vestas V90 turbine is 20 years.


CAR12 - Are the baseline emissions determined according to the formula BEy = EGy x EFy

B 6.3.3 Formula for the baseline emission calculation is added together with data used and result of calculation.

The formula has been added to the PDD, however please also add the calculation details (i.e. the values applied and the calculation results).




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CAR13 - Did the emissions reductions were determined according to the formula ERy = ERheaty + ER electricity y + BE biomassy –PE y – Ly

B 6.3.3 Emission reduction formula is added with relevant data.

Emission reduction formula has been added to the PDD, however please also add the calculation details (i.e. the values applied and the calculation results).



CAR14 - Were all values chosen in a conservative manner and was the choice justified?

1.8.4 EF values for fuels consumed were revised. New values selected from National GHG Inventory Report of Turkey as in compliance with the tool for calculation of EF.

e) IPCC values have been used as requested and PDD has been revised accordingly.

f) NCV data published by TEIAS has been used in revised baseline calculations.

a. Turkey uses TIER I approach in national inventory calculations (please see page 66 of the following document: http://unfccc.int/resource/docs/natc/turnc1.pdf) In TIER I approach the EF used are the IPCC default values and not the national values. Therefore these values can not be used in the calculations. Please use IPCC default values at the lower limit of the uncertainty at a 95%



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confidence interval as suggested by the Tool.

The emission factors announced in the Turkish Inventory are IPCC default values and do not reflect the country specific values. Please revise the calculations by using IPCC default values at the lower limit of the uncertainty at a 95% confidence interval. (IPCC min values)

In the version 3 of EF calculations the emission factors has been revised according to IPCC values and these values are accepted.

In page 30 of the PDD, it is stated that for EF of fuels consumed National GHG Inventory report has been used however IPCC values are used in the calculations. Please correct.

It has been corrected. The corrective action request is closed.

In the PDD it is stated that NCV values for lignite and coal are taken from Turkey’s NIR. However these values are calculated using the reference approach of IPCC. This approach is a very rough estimate



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o For generation efficiency of the plants, reference for most up to date official records of the government has been used. Since, it is not possible to identify the technology, efficiency etc. of each plant, these values are considered in calculations. BAT data has been used for LPG and Naphta, which are not available in the tool applied as a conservative approach as the values used are close to the upper limit for liquid fuels given in the table referred.

Explanation has been added to step 5. of baseline calculation in

and it includes all the coals that are extracted and imported to Turkey. It is not only specific to electricity generation. Therefore these values can not be used. NCV Values from the TEIAS web site is used. The corrective action request is closed.

b. Regarding the efficiency of the plants, in the tool it is suggested to use the following values:

o Documented manufacturer’s specifications (if the efficiency of the plant is not significantly increased through retrofits or rehabilitations); or

o Data from the utility, the dispatch center or official records if it can be deemed reliable; or

o The default values provided in the table below in annex 1.

IPCC BAT values are not suggested in the tool.

Also Environmental Map of Turkey was published in 2001 and the data given in this document belongs to old power plants and may not reflect new practices, therefore the assumption of the efficiencies of the recent capacity additions are same



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PDD

g) The sentence has been revised in PDD.

as the old plants imposes a high risk for the BM calculations.

The justification is acceptable however it is not added to the PDD.


c. It is stated in the PDD that the Emission Factors of coal and lignite have been calculated using country specific heating values, please clarify.

In PDD version 5.1 Generation efficiency values are used from the Annex1 of the methodology which is in line with the methodology.


CAR15 -2 Has the project participant included the technologies or practices that provide outputs or services with comparable quality, properties and application areas as the proposed GS project activity and that have been implemented previously or are currently being introduced in the relevant country/region.( No, it is not stated in PD.)

B.5.1 2. The list of operational wind power plants had been given in section B.4 already. A column has been added showing the status of the project (whether developed as VER or not)

2. The given list has been reviewed and accepted by the validation team. The corrective action request is closed.



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CAR16 -3 Please supply the feasibility report with supporting attachments which impact the project starting decision. (Income – expenses (operational, financing, investment) and detail of tangible and intangible assets for the project activity.

B.5.1 3. Micrositing report has been attached together with supporting documents. A separate feasibility report does not exist for the project.

Date of turbine purchase agreement (September 2008)has been selected as start date of the project and average currency rates for September 2008 has been inserted in new version of financial analysis.

3. The attached report is the micrositing of the project. In the report Income – expenses (operational, financing, investment) details are not given. Please send the feasibility report including the relevant data.




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CAR16 - 4Please supply documents that supporting the input values in the feasiblity report. (price lists of the equipments / other investments from equipment manufacturers / suppliers at the time of decisions)

B.5 4. Supporting documents (investment and operational costs, financing, EPCs has been attached)

Figure for insurance has been revised. Also, operational cost has been given in more detail and transmission loss has been included in calculations.

Maintenance fees had been included in previous version and verified already. Maintenance agreement had been provided as confirmed above.

4. The input values has been verified with the supported documents.

All income and expenses verified with the supporting documentation like quotations and agreements. However insurance is taken as 145000 in the IRR calculation but it is a high figure than the insurance proposals.

The insurance figure has been revised as 90000.

The corrective action request has been closed.

Maintenance fees were not included in the previous version however they are included in v.3 of IRR calculation. Please explain and proof.

The maintenance agreement has been seen by the validation team. The corrective action request is closed.



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CAR16 – 5 Please provide the local amortisation and depriciation rates and usefull life for the investment time and categorize them. (eg. “333339 ve 365 sayılı VUK tebliğleri uyarınca amortismana tabi iktisadi kıymetler” list)

B.5 5. Local amortisation and depreciation rates have been used.

VAT has been excluded from depreciation amount is it is already deducted which is given in Cells (Q7-Y7)

5. Please give the link for the depreciation rates. (“333339 ve 365 sayılı VUK tebliğleri uyarınca amortismana tabi iktisadi kıymetler” list)

Investment time Local amortization and depreciation lists have been used and the link given.

Depriciation value is 19044 in IRR calculations however investment cost is 19321. Please clarify.

The corrective action request closed.

CAR16 – 6 Please clarify if there is investment incentive at the decion time. Tax is not considered for 15 years. Please state if there is investment incentive for the project.

B.5.1 6. Taxes has been included in investment analysis. A statement in sub-section 2c has been included in PDD regarding use of ODA and any other incentive.

6. Taxes have been included. Please state that there is no investment incentive at the decision time.


CAR 16 - 7 Please sent the details of EPC. B.5.1 7. EPC was provided as supporting contract.

7. The corrective action request is closed.



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CAR16 - 8 23 years has been taken in IRR calculation, it should be min.10 – max 20 years.

Please add the abbreviation list.

B.5.1 8. IRR period has been revised to include 20 years operation period(+i year investment period). In the methodology it says”

Both project IRR and equity IRR calculations shall as a preference reflect the period of expected operation of the underlying project activity (technical lifetime), or - if a shorter period is chosen - include the fair value of the project activity assets at the end of the assessment period. In general a minimum period of 10 years and a maximum of 20 years will be appropriate.” Since the lifetime of the turbines is 20 years, investment analysis has been carried out for a total of 21 years in revised version(including investment period)

20 years in the guideline is perceived as a recommendation rather than a “must” as copied from guideline.

8. Investment year should be inserted to the IRR calculations and also with the revision total year should be max. 20 years.

The clarification found acceptable. The corrective action request is closed.



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CAR16- 9. Please clarify how the revenue calculated. B.5.1 9. Calculation of the revenue has been given in more detail.

9. Revenue calculations are detailed in the tool and it is acceptable. The corrective action request is closed.

CAR16 - 10. Please give the detail of owner cost. B.5.1 10. Owner cost has been removed and a breakdown of the costs has been added.


CAR16 -11.Please write the units of the datas. B.5.1 11. Units of the data have been added.

11. Units of the data’s have been included. The corrective action request is closed.

CAR16 - 12. Please add Eurobond benchmarking to the IRR excel sheet. Tax should be deducted from Eurobond rates.

B.5.1 12. Eurobond rates are subject to Corporate Tax(20%). A reference was given for the tax rates on Eurobond. Also, the link for Eurobond rates was given in PDD and relevant part was revised in the PDD. For comparison of Eurobond rates and project IRR, corporate tax rate has been deleted from the excel sheet provided.

12. The clarification request closed.

CAR16- 13. Operation cost evidences are missing. For insurance and staff.

B.5.1 13. Details of the operation cost for the plant is given as a separate sheet and documents were provided for 2 operators’ salary and assistant plant manager’s salary as evidence.

13. Operation cost evidences for insurance and staff are provided. The corrective action request is closed.



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Also, quotation from a tender is given for plant insurance.

CAR16- 14. Please give the formulas for Investment and operating cost in the sensitivity analysis.

B.5.1 14. Comment about sensitivity analysis was not answered as discussed with financial expert on the phone. Change in IRR can be monitored by entering value to %fluctuation cell (given in red)for each item included in sensitivity analysis.

14. The corrective action request closed.

CAR16- 15. Please indicate the start date of construction in IRR calculations since it effects the euro rate)

B.5.1 15. Start of construction is March 2009 however since the investment decision is taken as date of Eq. Agreement(September 2008), exchange rate at this time was used


CAR17 - The outcome of 3 is not mentioned in PDD Table3 .u Outcome of step 3 is missing.

Outcome of step 3 is added to PDD. The clarification is closed.

CAR18 - The outcome of Step3 is not clearly identified. Table 3.w Outcome of step 3 is clarified. Outcome of step 3 is added to PDD. The clarification is closed.

CAR19 - Please provide an analysis with the similar projects in the region.

Table 3.y A column has been added to table 5 in PDD showing the status of the project(whether it




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was developed as VER project or not).

CAR20 - No, the outcome of step 4 is not clearly mentioned.

Table3 Outcome of step 4 is given in more detail.

Outcome of step 4 has been reviewed and accepted by the validation team. The corrective action request is closed.

CAR 21 - Please give detailed list of capacity additions for the year 2007 in the baseline calculation sheet.

B 6.3.3 The related pages from Turkish electrical energy 10-year generation capacity projection (2008-2017) has been given in worksheet “capacity addition 2007 details” in the baseline calculation.

The reference document has seen by the validation team. The corrective action request is closed.

CAR22 - Please give detailed list of capacity additions for the year 2006 in the baseline calculation sheet.

B 6.3.3 The related pages from Turkish electrical energy 10-year generation capacity projection (2007-2016) has been given in worksheet “capacity addition 2006 details” in the baseline calculation.

The reference document has seen by the validation team. The corrective action request is closed.

CAR23 - Estimated start date of construction is not given in the Passport. Please state the estimated start date of the construction under Section B of the Passport

Table5 – B.2

Construction Start Date has been given section B.

It is stated in section B that the project construction has started in march 2009.


CAR24- It is not explained in the Passport how the stakeholder feedback round was organised. The outcome of the feedback round is not stated in the

Table5 – E.2.9

Explanation about SFR was added together with the invitations letters and delivery list.

It is stated that feedback round was done through web-hosting and no comments received. Also project description web-hosted



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Passport. The argumentation on whether or not comments are taken into account and the respective changes to the project design is not given in the Passport.

in BV web page and no comments received for the project activity. The corrective action request is closed.

CAR25 - The Reference sources of the ‘Do No Harm’ Assessment are not given in the Passport. Please give the reference sources to prove that the assessment is based on accurate information.

F.1.4 Rev.1

DNH assessment has been carried out according to guidance on Annex H of GS toolkit

Rev.2

References for mentioned items have been selected as suggested in pages 41-43 in toolkit annex.

Rev.1 The refferances given in the do not harm assessment.

However for not relevant items, the reason for not being relevant is defined specific to the project activity except items 5-6-7-11 definitions of which are given in more general way. Please define the irrelavance specific to your project activity in the above mentioned items.

Rev.2.


CAR26 - No, the sustainable development matrix is not classified 3 categories.

F.2.12 Original template of GS has been used for passport which does not include classification in two three categories.

Rev.2

Environmental, social, economic and technological headings added to the sustainable development matrix.

Rev.1

Please categorize the sustainable development matrix regarding to Annex-I requirement.

Rev.2


CAR27 – Please delete high initial investment cost from the barriers.

High initial investment cost deleted from the barriers after Gold



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Standard review. The corrective action request is closed.

CL1- Date of the document is not given in dd/mm/yyyy format.

A1 Format of the date of the document is corrected

Date of the document is given in dd/mm/yyyy format in the PDD version 02.


CL2- The view of the project participants on the contribution of the project activity to sustainable development is not included in this section of the PDD.

A 2.2 The view of project participants on contribution of project is included in end of the section A.2.

The view of the project participants on contribution of the project activity to sustainable development is included in PDD version 02.


CL3- Please clarify if the project uses state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in the host country

A 4.3.2 Clarification about the turbine technology was added based on the product brochure obtained from manufacturer’s website.

The turbine manufacturer is Vestas and the model that used for the project activity introduced in 2002. The technology used for the project activity is the state of art technology.


CL4 - Please clarify if the project technology is likely to be substituted by other or more efficient technologies within the project period..

A 4.3.3 Clarification about turbine and project lifetime is added based on generation license issued and turbine manufacturer’s specifications.

The following explanation has been added to the PDD and has been verified via the reference link of the Vestas Press release given in the PDD:

“Since the Vestas V90 turbines have an average lifetime of 20 years (which is in parallel with the license issued for the Ayyildiz WPP) and project financial analysis is



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made on this fact, the turbines are not likely to be substituted within the project period”


CL5 - Please explain if the project requires extensive initial training and maintenance efforts in order to work as presumed during the project period

A 4.3.4 Clarification was added about training needs for the equipment and plant.

Staff recruited for the project activities will be trained to get high voltage certificate. Also, project staff will be trained by equipment manufacturers for the first line maintanance and operation of the equipments. Second line maintanance of the equipments will be carried out by equipment manufacturer company.

This clarification request is closed.

CL6 - No the project does not make provisions for meeting training and maintenance needs

A 4.3.5 Clarification was added about training needs for the equipment and plant.

It is defined that high voltage and first line maintenance trainings are needed for the project activity. Since second line maintenance is under control of the manufacturer so no training provisions defined for that.

This clarification closed.

CL7 - Are all aspects related to direct and indirect GHG emissions, including leakage, captured in the project design? It is not stated in PDD

B 6.3.1 Leakage and project emissions were included in the emission calculations. Since, project emissions will depend on diesel fuel use, net emission reduction will be calculated during annual

Project Emission: The explanation on how the project emissions will be calculated has been added to the PDD under section B.6.3. However the results of the calculations made by using the given formula, and the



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verification. Leakage from the project was assumed as zero since the equipments used are new and are not transferred from another plant.

values applied to the given formulas are not given. Please give detailed information on the calculation of the project emissions.

Explanation found acceptable, the project emission data added to the monitoring plan. The clarification request closed.

Leakage: If the leakage can be neglected please state in the PDD.

The clarification request is closed.

CL8- Please clearly state the starting date and the operational life time.

C 1 Starting date and lifetime was clarified.

Starting date of the project is given as 05/09/2008 in the section C.2.1.1. of the PDD. The operational lifetime is given as 20 years in section C.1.2. of the PDD according to manufacturers documents. Which were also reviewed by the validation team.


CL9 - The crediting period can be renewed for 2 times. Please correct in section C.2.1.2.

C 2 Crediting period has been revised as requested.

Total crediting time is added.

Please also include the total crediting time of the project.




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CL10- Please justify the assumptions made in determining the project electricity system.

2.8 Rev.1

Assumptions made in feasibility preparation were included in PDD.

Rev.2

Main assumptions in calculating the project generation were;

• 2% loss for due to electrical efficiency and

• 1% loss due to utility downtime

Rev.1

Please give which assumptions are added to the PDD.

Rev.2


CL11- Please state there is no DNA in Turkey 2.12 Nonexistence of DNA is stated in A3

The statement added under section A3 of the PDD has been reviewed. Clarification is closed.

CL12 - It is stated that ACM0002 Version09 has been used. Version 10 is available.

B.5.1 According to UNFCCC, version 10 is valid after 11th of June. Since the project has been submitted in March, latest version (v9) has been used.


CL13 - Simple OM method selected regarding to ACM0002. Please state this in section B.6.3 step2.

B 6.3.3 Justification and selection of Simple OM is moved to step 2.

Justification for the selection of Simple OM method has been reviewed by the validation team and has been found appropriate.


CL14 - The EF will remain same over the first crediting B 6.3.3 The sentence stating that EF The clarification is closed.



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period regarding to ACM0002.

Please state this in PDD section B.6.3. Step 4.

will remain same over first crediting period was added to step 6 of section B 6.2

CL15 - Are transmission & Distribution losses neglected as required by the methodology?

B 6.3.3 By definition, EGY is net electricity generated to the grid by the power plant. However, for clarification, it was included in sections B 6.3 and A.2. Data used and result of calculation has been added as requested.

The comments about the transmission and distribution losses have been added to the PDD. however please also add the calculation details (i.e. the values applied and the calculation results).

The details of the calculations added to the PDD. The clarification is closed.

CL16 - Investment Barrier: Please give more detail about “The high level of financing and long payback period” in Turkey and also for your project to support that investment barrier would prevent the implementation of the project. Please give the ref. for the “market prices” and “majority of the power plants owned by state.” In section “Limited incentives for renewable energy.

Table3.t Detailed information has been added to relevant section with the reference(page 103 of attached document).

Link for the market prices and ownership of the power plants have been inserted in PDD.

The PP’s reply for this clarification request is missing. (CL16)

In PDD dated 19.08.2009 the information about the high level of financing and long payback period is added. The reference has been seen by the validation team. The clarification request closed.

The attached excel file has been reviewed. The clarification is closed.



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Construction Barrier; Please give the soil structure of the project area and the ref. that the structure is not suitable for the construction.

Also, prices for may 2009 has been given in attached excel file as an example.

Construction barrier has been removed from barrier analysis section.

It is concluded that there is no construction barrier for the project and the barrier removed from the PDD. The clarification request closed.

CL17 - In section B.5 Step 1.a 2 alternatives defined.(Please see question 1.d). Alternative 2 “Continuation of the current situation – supply of equal amount of electricity in the grid was eliminated. In section 3.b “Electricity generation by existing grid defined as an alternative” Please clarify.

Table3.v The wording “Electricity generation by existing grid defined as an alternative” has been deleted from section 3.b


CL18 - Please give the ref. that thermal power plants require lower investments compared to the renewable energy investments.

Table3.v Reference from www.ewea.org has been added for high initial investment for wind PPs and attached above (CL16)

The reference document couldn’t be reached, please send the PDF version of the referred pages to the DOE.

The attached document has been reviewed by the validation team. The clarification request closed.

CL19- Please give more detail and ref. that the construction of thermal power plants is easier and meet no barriers.

Table3.v Discussion about construction barriers is removed from barrier analysis.


CL20 - Please give the ref. that similar projects are connected at medium voltage level (34.5 kV). Please clearly state why this can be a comparison matter for the project activity

Table3.z The paragraph about medium voltage level was removed from the PDD.




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CL21- Please correct the title of the project so that it will be the same with the one in the PDD and the registry.

Table.5 – A.1

Project Title has been revised in all Project documents.


CL22.- please state in the Passport section C.2 that Turkey does not have a cap on its GHG emissions and explain current situation in Turkey briefly.

Table.5. c.2.3

Statement of GHG cap of Turkey has been given in section C2

Clarification request is closed.

CL23 - It is stated in the Passport that the sectoral scope of the project is Scope 1 “Energy Industry-Renewable Sources” according to the UNFCCC definition, please also state the project category regarding Toolkit 1.2.c.

C.3.3 Project category has been revised according to toolkit.

The project category corrected as GS Toolkit. The clarification request closed.

CL24 - No there is no pre-announcement of the project going ahead without VER revenues. However, the starting date of the project activity should also be given in the Passport Section C.3.

C.3.4 Starting date of construction has been given in section B and statement has been revised.

The project was not announced previously before the agreement with the carbon consultant (GTE). Also the initial stakeholder consultation is after the agreement.


CL25 - A summary of alterations has been inserted under Section E.1. of the Passport. However, although it is stated in the table that the stakeholders have concerns about job opportunities, it is not stated how the project was altered to provide job opportinities to the local stakeholders.

E.1.2 A paragraph about job opportunities has been added

It is stated in section e.1 that there will be job opportunities during construction and operation of the project activity. The clarification request closed.

CL26 - It is stated that the main concern of the local stakeholders is the use of land as grazing land. The project owner states that the use of land for grazing will not be prevented. Please give the total area that will be available for grazing activities together with the total area of the project activity. (Please state the ratio of the total project area that will be available for grazing) Please also support your argument by presenting an official letter from the project owner stating that this area will be available for grazing activities.

E.1.2 Since it does not require any change in the project design, only response of project owner has been given.

The total rented area for the project activity is smaller than 0,01 of the total grazing land. It is stated that the area can be used for grazing after commissioning also the letter from the project owner stating that the area will be available for grazing has been submitted to DOE. The use of the land



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for grazing activities has also been included to the monitoring plan. The clarification request is closed.

CL27 - It is stated under section E.2. of the Passport that “A summary of the consultation report prepared in Turkish has been sent to identified stakeholders and participants through mail, hand delivery or local representatives.” Please send a copy of this document to the DOE.

E.2.6 A copy of the document has been attached.

The non-technical summary of the project has been reviewed by the DOE. The clarification request is closed.

CL28 - The parameters have been identified however for item no 7 it is stated that the current situation of the parameter is 0. Please update the current situation.

G.4 Current situation refers to absence of project. Since no local people is employed in the absence of the project activitiy, it is given as “0”


CL29 - The parameters are planned to be monitored yearly. Please also indicate for how long these parameters will be monitored.

G.6 Explanation has been added to in section G of the passport.

The explanation has been added to the PDD. The clarification request closed.



VALIDATION REPORT

88

APPENDIX B – VERIFIERS CV’S

Internal Technical Reviewer : Ashok Mammen - PhD (Oils & Lubricants)

Bureau Veritas Certification - Internal Technical Reviewer

Over 20 years of experience in chemical and petrochemical field. Dr. Mammen is a lead auditor

for environment, safety and quality management systems. He is also a lead verifier and tutor for

GHG projects and has been involved in the validation and verification processes of more than

60 CDM/JI/VCS and other GHG projects.

Lead Verifier : Ms. Burcu Mutman – Environmental Engineer

Bureau Veritas Certification – Seniour Technical Specialist

Burcu Mutman is an auditor for environment, safety and quality management systems.

She is also lead verifier for GHG projects. Bureau Veritas Certification Holding SAS – Internal

Technical Reviewer

Baseline Specialist : Mrs. Yildiz Arikan -( Assoc. Professor Dr)

Sabancı University, Faculty of Management, Orhanlı, Tuzla, 34956, Istanbul, Turkey.

Yıldız Arıkan is an Electrical engineer and is working at Sabancı University . She has supported

thesis related with energy . Also she has been conducting research studies on energy including

‘’CO2 Emission Research’’ Studies. Academically, Yıldiz Arıkan is working also on GHG project

since 2005

Investment Analysis Specialist : Haluk Cengiz – Business Administration

Bureau Veritas Certification – Financial Controller

Haluk Cengiz is a financial controller of Bureau Veritas Turkey since 1999. He has been graduated from Marmara University, Business Adminstration.