Sirjan 480MW Combined Cycle Power Plant
Host party(ies) Iran (Islamic Republic of)
Methodology(ies) AM0029 ver. 3
Standardised Baselines N/A
Estimated annual reductions* 639,511
Start date of first crediting period. 01 Jan 16
Length of first crediting period. 10 years
DOE/AE Korean Foundation for Quality
Period for comments 17 Oct 12 - 15 Nov 12
PP(s) for which DOE have a contractual obligation Mehr Renewable Energies Company
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (849 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
2.	No plan has been submitted regarding use of 2% of the net revenue accrued from the sale of CER toward achieving the sustainable development goals.

3.	The investment analysis is incomplete and fails to provide the data and assumptions necessary for reader to reproduce the result.

4.	No information has been provided regarding the cost of fuel switch in the PDD.

5.	As per the EIA report the noise level recorded in the individual process units exceeded the stipulated standards of Central Pollution Control Board (CPCB).

6.	The PDD does not explain about identified training, monitoring and maintenance as per the Technology requirements for contractors / engineers by the client. There is no mention of field quality Assurance systems & procedures that are available at site, field quality plans and their approval.

7.	Chronology of events with corresponding emails, letters need to be validated by DOE.

8.	The leakage calculation is not correct as per applied meth AM29.

9.	What is the basis for arriving discount factor since it has more bearing on the levelised cost.

10.	The input values taken for calculation of levelised cost of generation are not provided. Pls. clarify.

11.	The argument for opting out of other energy sources from the baseline is not adequately demonstrated in the PDD. Where is the proof for each of the argument? PP has duty to provide to all the points it raised to opting out of renewable and other sources. 

12.	The reason for excluding the power generation using natural gas with different technologies is not clear. It is mentioned in the PDD that the project activity is a combined cycle power plant with the modern state of art technology and significant efficiency improvement is not possible with current technology status to reduce GHG intensity any further. As CCPP is very efficient technology there are no higher efficient technologies available to the project proponent for power generation utilizing natural gas.

13.	Project proponent conveniently hides the past history of the project and presents it as if it is a new project. DOE to check the prehistory of the project.

14.	DOE to check the DPR, tender documents inviting proposals, tender correspondence, proposals etc. to clearly validate.

15.	The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax shielding as a result from accelerated depreciation. PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration.  

16.	The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision. Note that considering cash inflows results in an increase in the IRR making wind projects a profitable venture.

17.	Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report which is made after investment decision making - indicates a lower PLF. The PLF seems to be very low. Also check the tariff order.

18.	methodology selection is wrong – applicability condition 1 of AM0029 requires ‘The project activity is the construction and operation of a new natural gas fired grid-connected electricity generation plant.’ This project plant is only a modification of an existing plant that operated for many years now.

19.	If the plant is just a retrofit, how baseline can be a coal based plant? Was it possible to retrofit this GTs to use coal? This is a ridiculous claim by behalf of PP and consultants.

20.	Whether project has got Environment Clearance from Ministry of Environment & Forest, New Delhi? What are major conditions stipulated in Clearance?

21.	Whether uninterrupted supply of Natural Gas has been ensured from suppliers for continuous operation? Whether gas will be provided from existing network of pipeline or modification is needed?

22.	Host country is already encouraging sustainable development on basis of clean technology and cleaner fuel, in this case how this project meet additionality criteria of CDM process?

23.	Whether Environment Public Hearing as process of Environment Clearance was arranged for this gas based power plant? If yes, what were major discussion and decisions of Environment Public Hearing?
24.	Additionality 

The methodology considers a project additional under the following circumstances

a)	There is a more economically attractive and GHG intensive alternative available to the project activity (lower levelized cost when compared to the project activity); and
b)	The project on a standalone basis is not financially attractive (low IRR as compared to standard industry benchmark)

While the PP has demonstrated that there is a more economically attractive option available as compared to the project activity, it has not demonstrated that the project on a standalone basis is not financially viable . As the project activity involves displacement of power on the grid and the alternative can be set up by any other entity as well, it needs to undertake a benchmark analysis. In order to perform benchmark analysis, the PP needs to take into account the tariff that it receives from the sale of power. 

The plant is being setup as a Merchant Power Plant (MPP) and hence may not enter into a long term PPA. It is a well known fact that merchant power plants are very attractive, because they get higher tariff than PPA based power plants. An article in Powernomics is quoted here.

Submitted by: Jhon Pereira

The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs