17:37 26 Mar 26
Info Report Check
Submission incomplete:
1: The DOE is requested to describe the process taken to validate the accuracy and completeness of the project description as per VVS version 7 paragraphs 66-69 and 70 (a) (b).
It is noted that the pre-project scenario, implementation of the project activity and project start date are defined using inconsistent events:
(a) page 12 of the validation report states "In the pre-project scenario i.e. prior to project investment decision date on 07/04/2004...";
(b) page 13 of the validation report states "Prior to the implementation of the proposed CDM project activity i.e. before 06/02/2008...";
Please address those inconsistency and the DOE is requested to clarify the inconsistency between those dates against the identified project start date (12/07/2004, page 33 of the validation report).
Further, the DOE is also requested to provide information on how it has assessed the accuracy of the project description, in particular what is the nature of the project activity, whether: (a) the project activity was designed and implemented together with the two coal fired boilers as part of the captive power plant to generate electricity; or (b) the project activity was designed and implemented separately, as an installation of waste heat recover boiler to supply steam to a common steam header at the power plant site; or (c) any other scenario.
2: The DOE is requested to describe how it has validated the project boundary and sources of GHG as per VVS version 7 paragraphs 88 and 89.
In the request for clarification on ACM0004 version 4 (i.e. AM_CLA_0229), the Meth Panel clarified to use annex 3 in order to determine the interchangeable application of the WECM in the project activity. However, annex 3 has not been applied in the project activity. The DOE is requested to provide information on how it has concluded on whether annex 3 is applicable to the project activity. In doing so, please also provide validation opinion on whether the implementation of the project activity would have impact on the operation of WHRB 1.
3: The DOE is requested to indicate if the baseline methodology is correctly applied to identify baseline scenario and alternative baseline scenarios as per VVS version 7 paragraphs 93 and 94.
Baseline alternative P7 (on-site or off-site existing renewable energy or other waste energy based captive power plant) and P9 (On-site or off-site Greenfield renewable energy or other waste energy based captive plant) are excluded (page 28 and 29 of the PDD). However, it is noted that: (a) there was one 200 TPD sponge iron kiln, on which a waste heat recovery boiler (WHRB #1) was installed along with a 8 MW TG, which has been registered vide UNFCCC ref No 0432 (page 3 of the PDD); and (b) the WHRB #1 is used to generate electricity to meet the captive power requirement of VGL plant and there is also surplus electricity wheeled through grid to group companies (Page 2 of registered PDD of project activity 0432). The DOE is requested to provide information on how it has validated the exclusion of these two alternatives, given the fact that a waste heat recovery boiler (WHRB#1) was installed along with a 8 MW TG.
4: The DOE is requested to verify the justification of the data used for the ex-ante emission reduction calculations as per VVS version 7 paragraphs 103, 104 (a) (b) (c) and 105.
With regard to the determination of the overall efficiency of Greenfield captive power plant (i.e. ηPlant,j). The DOE is requested to provide information on: (a) the source of boiler efficiency; (b) how it has validated the appropriateness and conservativeness of the assumed value (i.e. 85%) as per page 17 of ACM0012 version 4.
5: The DOE is requested to verify the justification of the data used for the ex-ante emission reduction calculations as per VVS version 7 paragraphs 103, 104 (a) (b) (c) and 105.
With regard to the assessment of extent of use of WECM and determination of ex-ante parameter fpractice for CDM project activity, option 1 of annex 1 of ACM0012 version 4 has been applied, and the PDD has concluded that 100% of the reference facilities do not have any use of waste energy. However, it is observed that: (a) the first reference facility (i.e. Lloyd Metal and Engg Ltd.) has applied CDM; and (b) the second and fifth reference facilities have commissioned their WHRBs in 2005. The DOE is requested to provide information on how it has validated: (a) the inclusion of first reference facility as per paragraph 3 of the applied option 1; (b) the conclusion of all the reference facilities not using waste energy, given the fact that the second and fifth reference facilities have commissioned their WHRBs in 2005, as per paragraph 6 of the applied option 1.
6: The DOE is requested to describe how it has validated the evidence provided for prior consideration of CDM as per VVS version 7 paragraph 114 (b).
It is observed that the termination date of the first CDM consultant in page 154 of the validation report (i.e. 24/03/2007) is not consistent with the termination date in page 33 of the validation report (i.e. 15/12/2006). Please address this inconsistency.
7: The DOE is requested to confirm the appropriateness of the underlying assumptions and the accuracy of the financial calculations carried out for the investment analysis as per VVS version 7 paragraphs 127 and 130 (c).
It is observed that the investment comparison has been conducted based hypothetical project and baseline scenarios with 10 MW capacity, whereas the actual project activity involves an installed captive power plant of 41 MW (page 3 of the PDD) and the baseline scenario identified is a 41 MW coal based captive power plant (page 32 of the PDD). Please address this inconsistency.
8: The DOE is requested to describe how it has validated the suitability of the input values used in the financial calculations as per VVS version 7 paragraphs 127 and 130 (a).
The DOE is requested to provide information on how it has validated the components of the project costs. In doing so, a breakdown of the project costs is requested to be provided, which includes the separate costs of WHRB, turbine generator, and/or coal based-boilers.
1: The DOE is requested to describe the process taken to validate the accuracy and completeness of the project description as per VVS version 7 paragraphs 66-69 and 70 (a) (b).
It is noted that the pre-project scenario, implementation of the project activity and project start date are defined using inconsistent events:
(a) page 12 of the validation report states "In the pre-project scenario i.e. prior to project investment decision date on 07/04/2004...";
(b) page 13 of the validation report states "Prior to the implementation of the proposed CDM project activity i.e. before 06/02/2008...";
Please address those inconsistency and the DOE is requested to clarify the inconsistency between those dates against the identified project start date (12/07/2004, page 33 of the validation report).
Further, the DOE is also requested to provide information on how it has assessed the accuracy of the project description, in particular what is the nature of the project activity, whether: (a) the project activity was designed and implemented together with the two coal fired boilers as part of the captive power plant to generate electricity; or (b) the project activity was designed and implemented separately, as an installation of waste heat recover boiler to supply steam to a common steam header at the power plant site; or (c) any other scenario.
2: The DOE is requested to describe how it has validated the project boundary and sources of GHG as per VVS version 7 paragraphs 88 and 89.
In the request for clarification on ACM0004 version 4 (i.e. AM_CLA_0229), the Meth Panel clarified to use annex 3 in order to determine the interchangeable application of the WECM in the project activity. However, annex 3 has not been applied in the project activity. The DOE is requested to provide information on how it has concluded on whether annex 3 is applicable to the project activity. In doing so, please also provide validation opinion on whether the implementation of the project activity would have impact on the operation of WHRB 1.
3: The DOE is requested to indicate if the baseline methodology is correctly applied to identify baseline scenario and alternative baseline scenarios as per VVS version 7 paragraphs 93 and 94.
Baseline alternative P7 (on-site or off-site existing renewable energy or other waste energy based captive power plant) and P9 (On-site or off-site Greenfield renewable energy or other waste energy based captive plant) are excluded (page 28 and 29 of the PDD). However, it is noted that: (a) there was one 200 TPD sponge iron kiln, on which a waste heat recovery boiler (WHRB #1) was installed along with a 8 MW TG, which has been registered vide UNFCCC ref No 0432 (page 3 of the PDD); and (b) the WHRB #1 is used to generate electricity to meet the captive power requirement of VGL plant and there is also surplus electricity wheeled through grid to group companies (Page 2 of registered PDD of project activity 0432). The DOE is requested to provide information on how it has validated the exclusion of these two alternatives, given the fact that a waste heat recovery boiler (WHRB#1) was installed along with a 8 MW TG.
4: The DOE is requested to verify the justification of the data used for the ex-ante emission reduction calculations as per VVS version 7 paragraphs 103, 104 (a) (b) (c) and 105.
With regard to the determination of the overall efficiency of Greenfield captive power plant (i.e. ηPlant,j). The DOE is requested to provide information on: (a) the source of boiler efficiency; (b) how it has validated the appropriateness and conservativeness of the assumed value (i.e. 85%) as per page 17 of ACM0012 version 4.
5: The DOE is requested to verify the justification of the data used for the ex-ante emission reduction calculations as per VVS version 7 paragraphs 103, 104 (a) (b) (c) and 105.
With regard to the assessment of extent of use of WECM and determination of ex-ante parameter fpractice for CDM project activity, option 1 of annex 1 of ACM0012 version 4 has been applied, and the PDD has concluded that 100% of the reference facilities do not have any use of waste energy. However, it is observed that: (a) the first reference facility (i.e. Lloyd Metal and Engg Ltd.) has applied CDM; and (b) the second and fifth reference facilities have commissioned their WHRBs in 2005. The DOE is requested to provide information on how it has validated: (a) the inclusion of first reference facility as per paragraph 3 of the applied option 1; (b) the conclusion of all the reference facilities not using waste energy, given the fact that the second and fifth reference facilities have commissioned their WHRBs in 2005, as per paragraph 6 of the applied option 1.
6: The DOE is requested to describe how it has validated the evidence provided for prior consideration of CDM as per VVS version 7 paragraph 114 (b).
It is observed that the termination date of the first CDM consultant in page 154 of the validation report (i.e. 24/03/2007) is not consistent with the termination date in page 33 of the validation report (i.e. 15/12/2006). Please address this inconsistency.
7: The DOE is requested to confirm the appropriateness of the underlying assumptions and the accuracy of the financial calculations carried out for the investment analysis as per VVS version 7 paragraphs 127 and 130 (c).
It is observed that the investment comparison has been conducted based hypothetical project and baseline scenarios with 10 MW capacity, whereas the actual project activity involves an installed captive power plant of 41 MW (page 3 of the PDD) and the baseline scenario identified is a 41 MW coal based captive power plant (page 32 of the PDD). Please address this inconsistency.
8: The DOE is requested to describe how it has validated the suitability of the input values used in the financial calculations as per VVS version 7 paragraphs 127 and 130 (a).
The DOE is requested to provide information on how it has validated the components of the project costs. In doing so, a breakdown of the project costs is requested to be provided, which includes the separate costs of WHRB, turbine generator, and/or coal based-boilers.
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