06:31 01 Jul 25
Info Report Check
Submission incomplete:
1: 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 further explain how it has validated: (a) the applicability conditions 3 and 4, in particular that within the three most recent years, the T2 Plant has run on LCO and NG, considering the PDD page 39, spreadsheet and the Validation Report page 51show that within the three most recent years, the fuel used was LCO and LDO; (b) the applicability condition 5, in particular how it confirms that with a maximum of 8760 hours per year, the remaining lifetime of the power plant is longer than the crediting period (i.e. 01/01/2015 - 31/12/2024), considering the plant being operational since 2000 and 2001.
2: 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.
The DOE is requested to further explain how it has validated the parameters not to be monitored in line with the applied methodology, in particular: (a) the use of upper limit value from Table 1.2 of of Volume 2 of 2006 IPCC Guidelines on National GHG inventories for parameter NCVSecondary fuel,x (Net calorific value of secondary fuel), and the use of value of 0.0583 tCO2/GJ, being the upper limit, from Table 1.4 of Volume 2 of 2006 IPCC Guidelines on National GHG inventories for parameter EFCO2,min (CO2 emission factor of the least carbon intensive fuel type, in this case, Natural Gas), whereas the methodology requires the use the values at the lower limit. Furthermore, the DOE is also requested to explain why parameter EFCO2,min is based on natural gas whereas LCO and LDO were used during the three recent years; (c) EFgrid,y (the emissions factor for the grid electricity system), in line with the “Tool to calculate the emission factor for an electricity system”, as it is not clear if the EFBM is set ex-ante or ex-post. Furthermore, how the EFgrid,CM,2009 being 0.54134 tCO2/MWh is correct with EFgrid,OM-ave,2007-2009 of 0.252 tCO2/MWh and EFgrid,BM,2009 of 0.879 tCO2/MWh. Furthermore, the DOE is requested to submit the spreadsheet of EFgrid,CM calculation.
3: The DOE is requested to provide information on how it has validated the evidence provided for prior consideration of CDM as per VVM v 1.2 paragraph 104(b).
The DOE is requested to further explain how it has validated the prior consideration of the CDM, in particular that it states in the Validation Report page 49 that the PDD has been published for global stakeholder consultation on 26/12/2011 before the project activity start date, whereas the global stakeholder consultation page shows that the project was uploaded on 28/12/2011.
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 DOE is requested to substantiate the suitability of the input values to the investment analysis in line with the VVM version 01.2 paragraph 111 a,b and c: (a) for the following parameter, as the validation report does not provide any information on how they have been validated and crosschecked: (i) Natural gas heat rate and LCO heat rate; (ii) Gas price; (iii) O&M cost (i.e Foreign Fixed O&M cost for natural gas and its components, Local Fixed O&M cost for natural gas and its components, Natural gas variable cost and its components, Natural gas LTSA cost); (iv) Revenue (i.e. Natural gas capacity charge, Foreign Fixed O&M charge for natural gas, Local Fixed O&M charge for natural gas, Maintenance charge for natural gas and Foreign Variable O&M charge); (v) Tax rate; (vi) Inflation profile (i.e. PPI USA, CPI USA, PPI Ghana, LTSA and real); (vii) Interest rate of term loan (3.36%); (viii) Debt/equity ratio; (b) for the following parameter, as there is no information in the validation report on how they have been crosschecked: (i) project cost, furthermore, as the PDD and Validation Report page 26 describe the expansion CAPEX being 296,902,271 USD, whereas the Validation Report page 28 describes the project cost being USD 440 million; (ii) financing costs and financing fees, furthermore, as the source is not clear and whether it was available at the time of the investment decision; (iii) depreciation rate.
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).
The DOE is requested to further explain how it has validated the sensitivity analysis in line with the EB62 Annex 5 paragraph 20, as the revenue including the electricity generation, being more than 20% of total project revenues is not considered in the sensitivity analysis.
6: The DOE is requested to provide information on how it has assessed each barrier presented as per VVM v 1.2 paragraph 118 (a) and (b).
The DOE is requested to explain how it has validated each barrier in line with the “Guidelines for objective demonstration and assessment of barriers” version 01, in particular: (a) with paragraph 4, as the nature of the companies and entities involved in the financing and implementation of the project have not been provided, when demonstrating the investment barrier and technological barrier; (b) with paragraph 9, as s it has not been demonstrated that the financing of the project was assured only due to the benefit of the CDM when demonstrating investment barrier; (c) the other barrier, as it is not clear what barrier exists as other barrier.
7: The DOE is requested to describe the steps undertaken to assess if the monitoring arrangements are feasible to be implemented within the project design as per VVM v1.2 paragraph 124(b).
Inconsistency is found. For parameter NCVLCO,y, the section B.7.1 of the PDD states the source will be the values provided by the fuel supplier in invoices, onsite measurements, (if possible), or lower limit value as noted from Table 1.2 of Volume 2 of 2006 IPCC Guidelines on National GHG inventories, whereas the Annex 4 of the PDD states as the values provided by the fuel supplier in invoices, onsite measurements, (if possible), or IPCC Guidelines (2006), upper limit value. The same is found in the Validation Report where in page 53 it says "IPCC default values at the lower limit of the uncertainty at a 95% confidence interval as provided in table 1.4 of Chapter1 of Vol. 2 (Energy) of the 2006 IPCC Guidelines on National GHG Inventories.", whereas in page 52 and 53 for parameter NCV it says "IPCC default values will be used at the upper limit ... ".
1: 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 further explain how it has validated: (a) the applicability conditions 3 and 4, in particular that within the three most recent years, the T2 Plant has run on LCO and NG, considering the PDD page 39, spreadsheet and the Validation Report page 51show that within the three most recent years, the fuel used was LCO and LDO; (b) the applicability condition 5, in particular how it confirms that with a maximum of 8760 hours per year, the remaining lifetime of the power plant is longer than the crediting period (i.e. 01/01/2015 - 31/12/2024), considering the plant being operational since 2000 and 2001.
2: 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.
The DOE is requested to further explain how it has validated the parameters not to be monitored in line with the applied methodology, in particular: (a) the use of upper limit value from Table 1.2 of of Volume 2 of 2006 IPCC Guidelines on National GHG inventories for parameter NCVSecondary fuel,x (Net calorific value of secondary fuel), and the use of value of 0.0583 tCO2/GJ, being the upper limit, from Table 1.4 of Volume 2 of 2006 IPCC Guidelines on National GHG inventories for parameter EFCO2,min (CO2 emission factor of the least carbon intensive fuel type, in this case, Natural Gas), whereas the methodology requires the use the values at the lower limit. Furthermore, the DOE is also requested to explain why parameter EFCO2,min is based on natural gas whereas LCO and LDO were used during the three recent years; (c) EFgrid,y (the emissions factor for the grid electricity system), in line with the “Tool to calculate the emission factor for an electricity system”, as it is not clear if the EFBM is set ex-ante or ex-post. Furthermore, how the EFgrid,CM,2009 being 0.54134 tCO2/MWh is correct with EFgrid,OM-ave,2007-2009 of 0.252 tCO2/MWh and EFgrid,BM,2009 of 0.879 tCO2/MWh. Furthermore, the DOE is requested to submit the spreadsheet of EFgrid,CM calculation.
3: The DOE is requested to provide information on how it has validated the evidence provided for prior consideration of CDM as per VVM v 1.2 paragraph 104(b).
The DOE is requested to further explain how it has validated the prior consideration of the CDM, in particular that it states in the Validation Report page 49 that the PDD has been published for global stakeholder consultation on 26/12/2011 before the project activity start date, whereas the global stakeholder consultation page shows that the project was uploaded on 28/12/2011.
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 DOE is requested to substantiate the suitability of the input values to the investment analysis in line with the VVM version 01.2 paragraph 111 a,b and c: (a) for the following parameter, as the validation report does not provide any information on how they have been validated and crosschecked: (i) Natural gas heat rate and LCO heat rate; (ii) Gas price; (iii) O&M cost (i.e Foreign Fixed O&M cost for natural gas and its components, Local Fixed O&M cost for natural gas and its components, Natural gas variable cost and its components, Natural gas LTSA cost); (iv) Revenue (i.e. Natural gas capacity charge, Foreign Fixed O&M charge for natural gas, Local Fixed O&M charge for natural gas, Maintenance charge for natural gas and Foreign Variable O&M charge); (v) Tax rate; (vi) Inflation profile (i.e. PPI USA, CPI USA, PPI Ghana, LTSA and real); (vii) Interest rate of term loan (3.36%); (viii) Debt/equity ratio; (b) for the following parameter, as there is no information in the validation report on how they have been crosschecked: (i) project cost, furthermore, as the PDD and Validation Report page 26 describe the expansion CAPEX being 296,902,271 USD, whereas the Validation Report page 28 describes the project cost being USD 440 million; (ii) financing costs and financing fees, furthermore, as the source is not clear and whether it was available at the time of the investment decision; (iii) depreciation rate.
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).
The DOE is requested to further explain how it has validated the sensitivity analysis in line with the EB62 Annex 5 paragraph 20, as the revenue including the electricity generation, being more than 20% of total project revenues is not considered in the sensitivity analysis.
6: The DOE is requested to provide information on how it has assessed each barrier presented as per VVM v 1.2 paragraph 118 (a) and (b).
The DOE is requested to explain how it has validated each barrier in line with the “Guidelines for objective demonstration and assessment of barriers” version 01, in particular: (a) with paragraph 4, as the nature of the companies and entities involved in the financing and implementation of the project have not been provided, when demonstrating the investment barrier and technological barrier; (b) with paragraph 9, as s it has not been demonstrated that the financing of the project was assured only due to the benefit of the CDM when demonstrating investment barrier; (c) the other barrier, as it is not clear what barrier exists as other barrier.
7: The DOE is requested to describe the steps undertaken to assess if the monitoring arrangements are feasible to be implemented within the project design as per VVM v1.2 paragraph 124(b).
Inconsistency is found. For parameter NCVLCO,y, the section B.7.1 of the PDD states the source will be the values provided by the fuel supplier in invoices, onsite measurements, (if possible), or lower limit value as noted from Table 1.2 of Volume 2 of 2006 IPCC Guidelines on National GHG inventories, whereas the Annex 4 of the PDD states as the values provided by the fuel supplier in invoices, onsite measurements, (if possible), or IPCC Guidelines (2006), upper limit value. The same is found in the Validation Report where in page 53 it says "IPCC default values at the lower limit of the uncertainty at a 95% confidence interval as provided in table 1.4 of Chapter1 of Vol. 2 (Energy) of the 2006 IPCC Guidelines on National GHG Inventories.", whereas in page 52 and 53 for parameter NCV it says "IPCC default values will be used at the upper limit ... ".
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