Info Report Check
Submission incomplete:
1: The DOE is requested to include description of the process taken to validate the accuracy and completeness of the project description in VR as per VVM v1.2 paragraph 64(a).
Please specify the number of project customers and the quantity of electricity and/or steam to be supplied to them. In doing so, please clarify whether the project customers receiving steam are the group companies or units of the project developer - IRPC Public Company Limited or not.

2: The DOE is requested to describe how each applicability condition of the methodology/ies is fulfilled by the project activity as per VVM v1.2 paragraph 76.
The DOE is requested to clarify how it has validated the applicability conditions based on documentary evidences in line with para 71 of VVM version 1.2. In doing so, the DOE should further validate criteria 3- existing capacity available at project customers previous to the implementation of the project activity and criteria 4- project customers do not co generate steam and electricity currently and/or in the baseline scenario in accordance with AM0048 version 03.

3: The DOE is requested to describe how it has validated the project boundary as per VVM v1.2 paragraph 80.
The DOE is requested to clarify how it has validated the procedure for estimating the remaining lifetime of the equipment included in the project boundary in line with EB22 Annex 2 following two different approaches mentioned on page 3 of the methodology AM 0048 version 03.

4: The DOE is requested to describe the steps taken to assess the identification of the baseline scenario of the project activity as per VVM v1.2 paragraph 87.
a). Please clarify how the baseline scenario for each project
customer as well as for the developer of the project activity was validated in accordance with step 1 (Identification of alternative scenarios) of AM0048 version 03. In addition, the DOE shall take into consideration the effects of national and sectoral policies while identifying alternative baseline scenario.
b). Please clarify the following requirements under step 1(Identification of alternative scenarios) of AM0048 version 03 using documentary evidences in line with para 84 of VVM version 1.2:
i). Existing FO based boilers cannot be modified to use any other fuel
ii). Fuel switch is a legitimate technical option
iii). Plans by self-generating project customer(s), to upgrade or replace generating equipment during the crediting period shall be documented.
c). The DOE is requested to validate the number of customers and the steam consumption/requirement for each of them as indicated in the PDD, page 11.

5: The DOE is requested to state whether the data and parameters are conservative and appropriate if they are fixed ex-ante (not need to monitor) during the project activity crediting period as per VVM v1.2 paragraph 91.
In specific, the DOE is requested to clarify:
a). the sutability of the historical data (2006-07, 2007-08 and 2008-09) used for parameters - total amount of electricity obtained from grid (ELGR,i), total steam generation (HST,i,k) and total fuel consumption (FST,i,fuel oil) which should be the most recent years previous to the implementation of the project activity. In doing so the DOE should clearly report the date when the project started to be implemented.

b). 85% fuel consumption rate of self-generation of steam at IRPC (ηST,i,k) given that it has been determined as per EB 48, Annex 12; where as, the methodology specifies 3 different approaches to determine the same.

c). In line with AM0048 version 03, please clarify the correctness of the parameter mentioned in the PDD - Pressure of steam generated by IRPC considering that the steam pressure should be the pressure of steam purchased by project customer i. In addition, parameters- Total electricity consumption for project customer (ELTC,i) and temperature of steam purchased by project customer are not mentioned in the PDD.
d). suitability of the grid emission factor (EFPC,GR,i,y) considering that the data was published on 30 Dec 2011 which was not available at the time of submission of the CDM-PDD to the DOE for validation.

6: The DOE is requested to include information on how it has validated the input values to the financial calculations as per VVM v 1.2 paragraph 114 (a).
a). The DOE is requested to submit the IRR calculation sheet as indicated in the PDD given that the file (Project IRR_IRPBC.xls) submitted by the DOE is an ER calculation sheet.
b). The DOE is requested to clarify why the IRR of alternative 1 (Project activity without CDM) and IRR of alternative 3 (Project customer could have switched to higher GHG intensive fuel – coal) was not compared as required by AM0048 version 03 which states that "If the IRR of the implementing project activity without CDM is less than the other alternatives and less than accepted benchmark for rate of return within the country, then the implementation of project facility is additional"
c). The DOE should further validate the suitability of total investment cost.
d). The DOE should validate the cross checking method for O&M cost.
e). The DOE is requested to validate the parameters- price of natural gas, price of FO, sale price of electricity and steam and price of station heat as indicated in the PDD.

7: The DOE is requested to provide information on how it has assessed the existence of the similar projects for common practice analysis as per VVM v 1.2 paragraph 121 (b).
a) The DOE is requested to clarify why was the common practice analysis limited to the NG based cogeneration units implemented in refineries only.
b). Please clarify how it has validated that there is no publicly available information/ database on the captive power plants in 7 refineries as mentioned in the PDD in accordance with the additionality tool version 5.2 which states that "In case similar projects are not accessible, the PDD should include justification about non-accessibility of data/information."