01:23 01 May 25
Info Report Check
Submission incomplete:
1: The PP/DOE are requested to describe on identification of baseline scenario(s) in PDD as per EB 48 Annex 60 paragraph 10 (a).
The PDD has not clearly mentioned what the baseline scenario is.
2: The DOE is requested to state if the baseline methodology is correctly applied to calculate project/baseline emissions, leakage and emission reductions as per VVM v1.2 paragraph 92(d).
The DOE has not confirmed if the calculation of the EFOM and EFBM based on data year 2005-2007 complies with the Tool to calculate the emission factor for an electricity system version 2.2.1 Step 3 (i.e. the use a 3-year generation-weighted average, based on the most recent data available at the time of submission of the CDM-PDD to the DOE for validation) and Step 5 (i.e. the build margin emission factor ex ante based on the most recent information available on units already built for sample group m at the time of CDM-PDD submission to the DOE for validation).
3: The DOE is requested to provide information on the steps taken to validate the project starting date as per VVM v 1.2 paragraph 104 (a).
The additionality spreadsheet sheet "References" shows that the PPA dated 4 May 2007 has considered the CCGT power plant. Hence, the DOE is requested to substantiate the project start date on 18/03/2011 being in accordance with the Glossary of CDM terms, considering this PPA. Furthermore, the DOE should also substantiate how the investment decision on 24/11/2010 is appropriate, as the PPA in 2007 has mentioned the CCGT.
4: 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).
The Validation Report page 30 states that the DOE has verified the assumptions as explained above and observed that they are correct and based on conservative values that are applicable at the time of investment decision making. However, the DOE is required to further explain how it has validated the following input values:
(a) in accordance with the EB62 Annex 5 paragraph 6, as it is not clear if the input values were available at the time of the investment decision: (i) Total Capex (sourced from Investment Decision, and the Spread sheet BC-EON-CCGTCAPEX, VR page 28); (ii) Gas Price (from MEDCO proposal Dtd. 21st December 2010, VR page 30); (iii) Nominal interest rate and the inflation rate; (iv) VAT on EPC contract (from Debit Note dated 07/11/2011, VR page 30); (v) Depreciation (from Indonesian Pocket Tax Book 2011, VR page 30); (vi) Electricity Tariff of 0.058 USD/kWh; (b) in accordance with the VVM version 01.2 paragraph 111a,b,c as the DOE only checked the source of the input values: (i) Gas Price; (ii) O&M cost for OCGT and CCGT; (iii) Total Capex; (iv) Gas consumption by the OCGT and CCGT.;
(c) the natural gas consumption in the project scenario of 5,766,778 mmBTU/y for the Gas Turbine and 907,667 mmBTU/y for duct burner (totaling to 6,674,445 mmBTU/y), as the ER calculation considers only 6,616,366.68 mmBTU (as the project emissions).
5: The DOE is requested to include information on how it has validated sensitivity analysis of the investment analysis as per VVM v1.2 paragraph 111 (e).
(a) The DOE needs to further explain why the decrease in the PLF would make the project more viable (i.e. at PLF of 82.5% the IRR reaches the benchmark). Furthermore, how the decrease is the PLF can be deemed unlikely.
(b) The PDD page 26 states that the PLN will pay for offtake of 85% or more, even if the actual offtake is lower than 85%. And that it makes it uneconomical for PLN. The DOE is required to further substantiate the unlikelihood of the decrease in PLF as the PLN will pay for offtake of 85% even if the actual PLF is lower.
1: The PP/DOE are requested to describe on identification of baseline scenario(s) in PDD as per EB 48 Annex 60 paragraph 10 (a).
The PDD has not clearly mentioned what the baseline scenario is.
2: The DOE is requested to state if the baseline methodology is correctly applied to calculate project/baseline emissions, leakage and emission reductions as per VVM v1.2 paragraph 92(d).
The DOE has not confirmed if the calculation of the EFOM and EFBM based on data year 2005-2007 complies with the Tool to calculate the emission factor for an electricity system version 2.2.1 Step 3 (i.e. the use a 3-year generation-weighted average, based on the most recent data available at the time of submission of the CDM-PDD to the DOE for validation) and Step 5 (i.e. the build margin emission factor ex ante based on the most recent information available on units already built for sample group m at the time of CDM-PDD submission to the DOE for validation).
3: The DOE is requested to provide information on the steps taken to validate the project starting date as per VVM v 1.2 paragraph 104 (a).
The additionality spreadsheet sheet "References" shows that the PPA dated 4 May 2007 has considered the CCGT power plant. Hence, the DOE is requested to substantiate the project start date on 18/03/2011 being in accordance with the Glossary of CDM terms, considering this PPA. Furthermore, the DOE should also substantiate how the investment decision on 24/11/2010 is appropriate, as the PPA in 2007 has mentioned the CCGT.
4: 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).
The Validation Report page 30 states that the DOE has verified the assumptions as explained above and observed that they are correct and based on conservative values that are applicable at the time of investment decision making. However, the DOE is required to further explain how it has validated the following input values:
(a) in accordance with the EB62 Annex 5 paragraph 6, as it is not clear if the input values were available at the time of the investment decision: (i) Total Capex (sourced from Investment Decision, and the Spread sheet BC-EON-CCGTCAPEX, VR page 28); (ii) Gas Price (from MEDCO proposal Dtd. 21st December 2010, VR page 30); (iii) Nominal interest rate and the inflation rate; (iv) VAT on EPC contract (from Debit Note dated 07/11/2011, VR page 30); (v) Depreciation (from Indonesian Pocket Tax Book 2011, VR page 30); (vi) Electricity Tariff of 0.058 USD/kWh; (b) in accordance with the VVM version 01.2 paragraph 111a,b,c as the DOE only checked the source of the input values: (i) Gas Price; (ii) O&M cost for OCGT and CCGT; (iii) Total Capex; (iv) Gas consumption by the OCGT and CCGT.;
(c) the natural gas consumption in the project scenario of 5,766,778 mmBTU/y for the Gas Turbine and 907,667 mmBTU/y for duct burner (totaling to 6,674,445 mmBTU/y), as the ER calculation considers only 6,616,366.68 mmBTU (as the project emissions).
5: The DOE is requested to include information on how it has validated sensitivity analysis of the investment analysis as per VVM v1.2 paragraph 111 (e).
(a) The DOE needs to further explain why the decrease in the PLF would make the project more viable (i.e. at PLF of 82.5% the IRR reaches the benchmark). Furthermore, how the decrease is the PLF can be deemed unlikely.
(b) The PDD page 26 states that the PLN will pay for offtake of 85% or more, even if the actual offtake is lower than 85%. And that it makes it uneconomical for PLN. The DOE is required to further substantiate the unlikelihood of the decrease in PLF as the PLN will pay for offtake of 85% even if the actual PLF is lower.
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