I would like to comment on the Nam Gion hydropower project as bellows:

Baseline Emission Factor:

In the Baseline Information in Annex 3 of PDD, the project developer provided the fuel consumption volume in Coal Fired Power Plants ( Pha Lai 1, 2, Na Duong, Cao Ngan, Uong Bi, Ninh Binh) was all not precise, for example, in the public report of 35 year of operation of Ninh Binh Coal Fired Power Plant, in 2007, the coal consumption was 564 g/kwh with the total 2007 electricity generated was 728.954 GWh so the total coal consumption in 2007 was 411,130 tons but in the data sheet in annex 3 is 530 kt, it is much higher than actual consumption, the Coal Fuel Consumption in 2005 and 2006 was also much higher than actual data.

NCV of Coal:

The data of NCV of coal used in the power plants in the annex 3 was not precise, for example, for Pha Lai 1 and 2 coal power plant, in the coal purchasing contract No. 25/HĐ/TKV-PLPC signed with Vienam Coal Group dated 24 Feb. 2006 , the plant used standard coal No. 4b and 5 with the public NCV of Vietnam Coal Group was different from the baseline information in annex 3, furthermore, in Pha Lai power plant, it is using sub-fuel is FO not DO as the data in annex 3, the other NCV value in other coal plants (Na Duong, Cao Ngan, Ninh Binh) was also not precise as the actual.