As per the para 6 (a), EB 62 Annex 13 “ GUIDELINES ON THE DEMONSTRATION AND ASSESSMENT OF PRIOR CONSIDERATION OF THE CDM”, it states that project activity where the start date is before 2nd August 2008 ,”The project participant must indicate awareness of the CDM prior to the project activity start date, and that the benefits of the CDM were a decisive factor in the decision to proceed with the project.  Evidence to support this would include, inter alia, minutes and/or notes related to the consideration of the decision by the Board of Directors, or equivalent, of the project participant, to undertake the project as a CDM project activity.” The PDD mention that the project start date is on 18/05/2007 and CER consideration by the board was done on 26/07/2007.  I would request Bureau Veritas Certification Holding SAS to please justify how the DOE has accepted that the project fulfill the requirement of para 6(a), EB 62, Annex 13. The PDD mention that the CER (Certified Emission Reduction) consideration is demonstrated via draft project feasibility report. Thus, the draft report was not being finalized and was never presented to board during the date (18/05/2007) of signing of EPC contract which is the start date of the project activity. Thus, the project activity does not meet the requirement of above guidelines. 

The page 9 number of the PDD states that project first phase operation was started on 28/03/2009. This justifies that the first stage of 6 MW is then in operation since 28/03/2009. Thus, the project activity briefed in the PDD qualifies under first of its kind guidelines (EB69 , annex 7).Why the PDD then mentions that the first phase “will be implemented” at number of places of the PDD? What is the intention of CDM consultant to state that the status of the first phase of the project activity in future terms in the PDD when it has already been operation since 28/03/2009? The same consultant may be trying to give false information and is trying to save other PDD that has been webhosted for GSC mentioning the first of its kind eligibility criteria.

I would like to clarify that the below links and many more states that 6 MW wind turbine of Zorlu is in operation since 2009. 

 

http://www.vestas.com/en/media/news/news-2010/news-display.aspx?action=3&NewsID=2924

http://maintainableworld.blogspot.in/2012/03/zorlu-plans-another-200-mw-wind-power.html

page 15, http://www.pc.gov.pk/usefull%20links/Taskforces/TFCC%20Final%20Report.pdf

http://www.defence.pk/forums/current-events-social-issues/150185-wind-energy-pakistan-vestas-enters-50-mw-wind-power-order.html

Thus, the source of information that is limiting to energy year book 2011 cant be the only basis to judge whethere wind turbines in Pakistan is in operation of not. I would request BVC to be very specific on their assessment on reasoning why they have not considered other source of information and why tyhey have limited themselves to Energy year book only. Do the DOE is also trying to hide some facts?

I will truly agree that this project qualifies under first of its kind. Then, if 6MW from this project has already been commissioned how come other wind project from Pakistan that has been webhosted are also mentioning them under first of its kind criteria. I would request BVC and other DOE to justify that why they have accepted all these PDD under first of its kind?
  
I am sure the DOE may refer to GUIDELINES ON ADDITIONALITY OF FIRST-OF-ITS-KIND PROJECT ACTIVITIES and can try to justify that 6 MW falls under small scale project. Thus, they are claiming the first of its kind for all wind PDD that has been webhosted.. However, I would like to clarify that the first phase of 6 MW is part of the large scale project of Zorlu website. (http://www.zorlu.com.tr/en/grup/ene_zpakistan.asp)

The same has been also mentioned in many websites.

http://ipek-energy.com/news/

http://www.nepra.org.pk/Tariff/Petitions/Zorlu%20TRF-88.PDF

http://www.ifc.org/ifcext/spiwebsite1.nsf/ProjectDisplay/SPI_DP29251

http://www.onepakistan.com/finance/news/energy/2970-wind-energy-in-pakistan-vestas-enters-with-50mw-wind-power-order.html

Thus, how all the PDD excluding this PDD fulfill the requirement of first of its kind as per the para 5(a), EB 69, Annex 7. Although this need not be answered in this PDD context I would request BVC to answer the same for other project context. I would request the BVC to judge each wind project very careful during their assessment and justify how they have assessed first of its kind for each wind project.

6 MW of wind project by zorlu is commercially in operation since 2009 although the same reference is not available in energy year book 2011. DOE need to search all the document that is available in the public domain. Thus, project other that this does not qualify under first of its kind. It has been observed that BVC in recent past has webhosted number of PDD under first of its kind. How the desk review of BVC justify first of its kind for wind PDD when 6 MW wind turbine is operation and this is part of a large scale project of 56.4 MW. Does the guideline say that all the installed capacity need to be commissioned to make it qualify under the definition of "have started commercial operation in the applicable geographical area"( source 5(a) EB69 annex 6)? why  6 MW part of the 56.4MW cant be treated as commercial operation in case it is in operation? How the BVC desk review clear other wind PDD that has been webhosted in recent past make it eligible under first of its kind? do the DOE get the clarification from EB that part of the commissioning from a large project cant be treated as project is in commercial operation.