20:18 28 Dec 24
Info Report Check
Submission incomplete:
1: Use of incorrect values of OM and BM emission factor for the Indian grid -
It is noted that the PDD (version 6, dated 16/03/2020), uses values of operating margin (OM) emission factor (EF) and build margin (BM) EF for vintage period of 2009-2012 from CEA database version 8 to calculate combined margin (CM) EF. CM is calculated as per approach provided in ACM0002 and “Tool to calculate the emission factor for an electricity system” Version 07.0. However, review of CEA database version 8 reveals that the OM and BM EF values used in the PDD are for South Grid and not for an Indian Grid.
The DOE in line with para 114, CDM validation and verification standard for project activities, version 2.0, is requested to confirm how it validated that PP has applied correct values of OM and BM EF from CEA database version 08, for calculation of CM EF and emission reductions from the project activity.
2: Assessment of common practice analysis -
It is noted that on page 21 of the validation report the DOE has reported that under Step 4 PP has identified technologies which are different than the wind power technology based on the parameter energy sources as per the common practice tool, whereas under Step 2 DOE has confirmed that PP has considered only wind power projects under this step.
The DOE in line with para 109 of the CDM validation and verification standard for project activities, version 2.0, is requested to provide further details, report and validate: (a) how it assessed the essential distinctions between the proposed CDM project activity and similar projects that are widely observed to further identify number of projects as Ndiff, (b) how the estimation made by PP regarding Ndiff is in line with the requirements prescribed under step 4 of the Tool, and (c) additional information provided by PP regarding different policies and tariff in different states as this was one of the criteria used by PP for identification of ‘Ndiff’ projects.
The DOE is also required to clarify the exact location of the project as information on page 16 of 35 of PDD mention that, “The project activity is located in the state of Gujarat of India and the policy applicable for the wind projects is regulated by Karnataka Electricity Regulatory Commission.”, while section A.2 of the PDD mentions that, “The proposed project site is located in Haveri district of Karnataka.”
1: Use of incorrect values of OM and BM emission factor for the Indian grid -
It is noted that the PDD (version 6, dated 16/03/2020), uses values of operating margin (OM) emission factor (EF) and build margin (BM) EF for vintage period of 2009-2012 from CEA database version 8 to calculate combined margin (CM) EF. CM is calculated as per approach provided in ACM0002 and “Tool to calculate the emission factor for an electricity system” Version 07.0. However, review of CEA database version 8 reveals that the OM and BM EF values used in the PDD are for South Grid and not for an Indian Grid.
The DOE in line with para 114, CDM validation and verification standard for project activities, version 2.0, is requested to confirm how it validated that PP has applied correct values of OM and BM EF from CEA database version 08, for calculation of CM EF and emission reductions from the project activity.
2: Assessment of common practice analysis -
It is noted that on page 21 of the validation report the DOE has reported that under Step 4 PP has identified technologies which are different than the wind power technology based on the parameter energy sources as per the common practice tool, whereas under Step 2 DOE has confirmed that PP has considered only wind power projects under this step.
The DOE in line with para 109 of the CDM validation and verification standard for project activities, version 2.0, is requested to provide further details, report and validate: (a) how it assessed the essential distinctions between the proposed CDM project activity and similar projects that are widely observed to further identify number of projects as Ndiff, (b) how the estimation made by PP regarding Ndiff is in line with the requirements prescribed under step 4 of the Tool, and (c) additional information provided by PP regarding different policies and tariff in different states as this was one of the criteria used by PP for identification of ‘Ndiff’ projects.
The DOE is also required to clarify the exact location of the project as information on page 16 of 35 of PDD mention that, “The project activity is located in the state of Gujarat of India and the policy applicable for the wind projects is regulated by Karnataka Electricity Regulatory Commission.”, while section A.2 of the PDD mentions that, “The proposed project site is located in Haveri district of Karnataka.”
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