08:02 16 Jan 25
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 2 paragraphs 64-68 and 69 (a) (b).
The DOE is requested to further substantiate how it has confirmed that the project description in the final PDD is accurate and complete, in particular the capacity of the project activity. The following capacities are mentioned: (i) 800 MW (The PDD pages 2 and 4, and VR page 11 ); (ii) 2 x 385.5 NW (The PDD page 4, and VR page 12); and (iii) 2 x 423 MW (The VR page 12).
2: The DOE is requested to describe how each applicability condition of the methodology/ies is fulfilled by the project activity as per VVS version 2 paragraphs 76 and 77.
The DOE is requested to further substantiate how it has validated the applicability conditions 3, in particular how the future natural gas based power capacity additions are not constrained by the use of natural gas in the project activity, as there is no information regarding the future natural gas based power capacity additions.
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 2 paragraphs 89 and 90.
The DOE is requested to further substantiate how it has validated the baseline identification, in particular: (a) the exclusion of natural gas open cycle alternative based on the fact that less 3% open cycle power plant licensed in 2011 (PDD page 9), whereas coal power plant alternative is considered even though the information of the number of coal power plants licensed is not provided; (b) the coal power plant alternative being plausible as 5 x 160 MW, considering the PDD page 11 states: "the Government has decided not to use coal for power generation on a large scale, until the demand for LNG stabilises", and how alternative of 5 x 160 MW is not considered as large scale considering to deliver similar service as the project activity 5 plants have to be operated simultaneously. Furthermore, considering the Validation Report page 20 states that there will not be any coal fired power plant expected in future; (c) electricity import being plausible, considering the reference provided by foot note 29 of PDD (page 12) shows that electricity import project will likely take around 4-5 years to develop and implement, and the importer could start selling electricity to Singapore from 2017/2018, whereas the project activity is expected to be commissioned on 01/01/2014 (PDD page 21); and (d) the fuel oil power plant, as the PDD eliminates the alternative, whereas the Validation Report states that his may be a plausible baseline scenario.
4: The DOE is requested to describe how it has assessed the application of the equations and parameters for the calculation of emission reductions as per VVS version 2 paragraphs 97 and 99 (d) (e).
The DOE is requested to further substantiate why CO2 emissions from fuel combustion/electricity consumption associated with the liquefaction, transportation, regasification and compression into a natural gas transmission or distribution system is accounted for considering the project activity will use LNG (PDD page 33).
5: The DOE is requested to describe how it has validated the project starting date as per VVS version 2 paragraphs 106 and 112 (a).
The DOE is requested to substantiate the project start date being the Notice to Proceed on 08/12/2011, as there is no new EPC contract signed with GMR Energy Pte. Ltd. which may imply the contract on 29/06/2007 was still valid.
6: 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 2 paragraphs 120 and 123 (a).
(a) The DOE is requested to further explain how the input values were valid and applicable at the time of the investment decision in line with EB62 Annex 5 paragraph 6 for the following parameters: Gas price, NCV of gas, plant heat rate, annual capacity utilization and total project cost of the project activity. In doing so, the DOE shall explain what was the source for each input value and how each source was valid and applicable at the time of the investment decision. Furthermore, the DOE is also requested to substantiate the investment decision taken on 15/06/2012 (Validation Report page 51) as the project had already started on 08/12/2011; (b) The DOE is requested to further substantiate the suitability of the O&M cost of the project activity being 4%, in particular how it is considered conservative; (c) The Validation Report does not provide information how the DOE validated validated the levelized cost of electricity imported from other countries being 150 SGD/MWh, in particular how the cost comes to be 150 SGD/MWh; (d) The DOE is requested to substantiate the suitability of net station heat rate of coal power plant alternative based on India CERC for project activity implemented in Singapore.
7: The DOE is requested to include information on how it has validated sensitivity analysis of the investment analysis as per VVS version 2 paragraph 120 (e).
The Validation Report has not provided information how the DOE validated the likelihood of the condition that would make the equity IRR cross the benchmark, in particular the variation of 10% in PLF.
8: The DOE is requested to report how it has validated common practice analysis as per VVS version 2 paragraphs 129 and 130.
The DOE is requested to further explain how it has validated the common practice analysis, in particular Step 3, considering the PDD page 20 shows that Power Seraya was not included from Nall for being in the CDM pipeline, whereas the Validation Report page 43 shows that Tuas Power Generation Pte. Ltd. was not included in Nall.
9: The DOE is requested to describe how it has validated the compliance of the monitoring plan with the applied methodology(ies) as per VVS version 2 paragraph 132 (a).
The DOE is requested to further explain how it has validated the monitoring of Net Calorific Value of Natural Gas, as it is not clear whether it will be from the supplier analysis/report or from the measurement readings recorded by Gas Chromatograph located at the PP plant boundary. Furthermore, it also says: "GC may not be available on project site and within project boundary. Thus, PP will not have control on its calibration frequency.", whereas in the same page it also indicates that Gas Chromatograph is located at the PP plant boundary.
10: The DOE is requested to report details of all CARs, CLs and FARs as per VVS version 2 paragraph 29.
The DOE is requested to further explain how it has closed CL16 and CL19, in particular how it has validated the PP's response that the price of LNG is not escalated, whereas the IRR spreadsheet shows that the price escalates annually.
1: The DOE is requested to describe the process taken to validate the accuracy and completeness of the project description as per VVS version 2 paragraphs 64-68 and 69 (a) (b).
The DOE is requested to further substantiate how it has confirmed that the project description in the final PDD is accurate and complete, in particular the capacity of the project activity. The following capacities are mentioned: (i) 800 MW (The PDD pages 2 and 4, and VR page 11 ); (ii) 2 x 385.5 NW (The PDD page 4, and VR page 12); and (iii) 2 x 423 MW (The VR page 12).
2: The DOE is requested to describe how each applicability condition of the methodology/ies is fulfilled by the project activity as per VVS version 2 paragraphs 76 and 77.
The DOE is requested to further substantiate how it has validated the applicability conditions 3, in particular how the future natural gas based power capacity additions are not constrained by the use of natural gas in the project activity, as there is no information regarding the future natural gas based power capacity additions.
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 2 paragraphs 89 and 90.
The DOE is requested to further substantiate how it has validated the baseline identification, in particular: (a) the exclusion of natural gas open cycle alternative based on the fact that less 3% open cycle power plant licensed in 2011 (PDD page 9), whereas coal power plant alternative is considered even though the information of the number of coal power plants licensed is not provided; (b) the coal power plant alternative being plausible as 5 x 160 MW, considering the PDD page 11 states: "the Government has decided not to use coal for power generation on a large scale, until the demand for LNG stabilises", and how alternative of 5 x 160 MW is not considered as large scale considering to deliver similar service as the project activity 5 plants have to be operated simultaneously. Furthermore, considering the Validation Report page 20 states that there will not be any coal fired power plant expected in future; (c) electricity import being plausible, considering the reference provided by foot note 29 of PDD (page 12) shows that electricity import project will likely take around 4-5 years to develop and implement, and the importer could start selling electricity to Singapore from 2017/2018, whereas the project activity is expected to be commissioned on 01/01/2014 (PDD page 21); and (d) the fuel oil power plant, as the PDD eliminates the alternative, whereas the Validation Report states that his may be a plausible baseline scenario.
4: The DOE is requested to describe how it has assessed the application of the equations and parameters for the calculation of emission reductions as per VVS version 2 paragraphs 97 and 99 (d) (e).
The DOE is requested to further substantiate why CO2 emissions from fuel combustion/electricity consumption associated with the liquefaction, transportation, regasification and compression into a natural gas transmission or distribution system is accounted for considering the project activity will use LNG (PDD page 33).
5: The DOE is requested to describe how it has validated the project starting date as per VVS version 2 paragraphs 106 and 112 (a).
The DOE is requested to substantiate the project start date being the Notice to Proceed on 08/12/2011, as there is no new EPC contract signed with GMR Energy Pte. Ltd. which may imply the contract on 29/06/2007 was still valid.
6: 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 2 paragraphs 120 and 123 (a).
(a) The DOE is requested to further explain how the input values were valid and applicable at the time of the investment decision in line with EB62 Annex 5 paragraph 6 for the following parameters: Gas price, NCV of gas, plant heat rate, annual capacity utilization and total project cost of the project activity. In doing so, the DOE shall explain what was the source for each input value and how each source was valid and applicable at the time of the investment decision. Furthermore, the DOE is also requested to substantiate the investment decision taken on 15/06/2012 (Validation Report page 51) as the project had already started on 08/12/2011; (b) The DOE is requested to further substantiate the suitability of the O&M cost of the project activity being 4%, in particular how it is considered conservative; (c) The Validation Report does not provide information how the DOE validated validated the levelized cost of electricity imported from other countries being 150 SGD/MWh, in particular how the cost comes to be 150 SGD/MWh; (d) The DOE is requested to substantiate the suitability of net station heat rate of coal power plant alternative based on India CERC for project activity implemented in Singapore.
7: The DOE is requested to include information on how it has validated sensitivity analysis of the investment analysis as per VVS version 2 paragraph 120 (e).
The Validation Report has not provided information how the DOE validated the likelihood of the condition that would make the equity IRR cross the benchmark, in particular the variation of 10% in PLF.
8: The DOE is requested to report how it has validated common practice analysis as per VVS version 2 paragraphs 129 and 130.
The DOE is requested to further explain how it has validated the common practice analysis, in particular Step 3, considering the PDD page 20 shows that Power Seraya was not included from Nall for being in the CDM pipeline, whereas the Validation Report page 43 shows that Tuas Power Generation Pte. Ltd. was not included in Nall.
9: The DOE is requested to describe how it has validated the compliance of the monitoring plan with the applied methodology(ies) as per VVS version 2 paragraph 132 (a).
The DOE is requested to further explain how it has validated the monitoring of Net Calorific Value of Natural Gas, as it is not clear whether it will be from the supplier analysis/report or from the measurement readings recorded by Gas Chromatograph located at the PP plant boundary. Furthermore, it also says: "GC may not be available on project site and within project boundary. Thus, PP will not have control on its calibration frequency.", whereas in the same page it also indicates that Gas Chromatograph is located at the PP plant boundary.
10: The DOE is requested to report details of all CARs, CLs and FARs as per VVS version 2 paragraph 29.
The DOE is requested to further explain how it has closed CL16 and CL19, in particular how it has validated the PP's response that the price of LNG is not escalated, whereas the IRR spreadsheet shows that the price escalates annually.
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