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VALIDATION OF THE
GUNUNG MEGANG ADD-ON
COMBINED CYCLE PROJECT
Summary:
Bureau Veritas Certification has made the validation of the Gunung Megang Add-On Combined Cycle Project
project of E.ON Carbon Sourcing GmBH located in JI. Raya Palembang Muara Enim, Km. 152 Gunung
Megang, Muara Enim, South Sumatra, Indonesia on the basis of UNFCCC criteria for the CDM, as well as
criteria given to provide for consistent project operations, monitoring and reporting. UNFCCC criteria refer to
Article 12 of the Kyoto Protocol, the CDM rules and modalities and the subsequent decisions by the CDM
Executive Board, as well as the host country criteria.
The validation scope is defined as an independent and objective review of the project design document, the
projects baseline study, monitoring plan and other relevant documents, and consisted of the following three
phases: i) desk review of the project design and the baseline and monitoring plan; ii) follow-up interviews with
project stakeholders; iii) resolution of outstanding issues and the issuance of the final validation report and
opinion. The overall validation, from Contract Review to Validation Report & Opinion, was conducted using
Bureau Veritas Certification internal procedures.
The first output of the validation process is a list of Clarification and Corrective Actions Requests (CL and
CAR), presented in Appendix A. Taking into account this output, the project proponent revised its project
design document.
In summary, it is Bureau Veritas Certifications opinion that the project correctly applies the baseline and
monitoring methodology ACM 0007 / Version 6.1.0 and meets the relevant UNFCCC requirements for the
CDM and the relevant host country criteria.
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1 INTRODUCTION ................................................................................................... 5
1.1 Objective 5
1.2 Scope 5
1.3 Validation team 5
2 METHODOLOGY .................................................................................................. 6
2.1 Review of Documents 6
2.2 Follow-up Interviews 6
2.3 Resolution of Clarification and Corrective Action Requests 7
2.4 Internal Technical Review 7
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6 REFERENCES ..................................................................................................... 45
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Abbreviations
CAR Corrective Action Request
CDM Clean Development Mechanism
CER Certified Emission Reductions
ER Emission Reduction
CL Clarification Request
CO2 Carbon Dioxide
DOE Designated Operational Entity
GHG Green House Gas(es)
I Interview
EB Executive Board
PDD Project Design Document
UNFCCC United Nations Framework Convention for Climate Change
DNA Designated National Authority
M&P Modalities and Procedure
VVS Validation and Verification Standard
MP Monitoring Plan
NPV Net Present Value
PO Purchase Order
MW Mega Watt
MWh Mega Watt Hour
O&M Operation and Maintenance
PP Project Participant
kW Kilo Watt
MMSCFD Million Standard Cubic Feet per Day
RPM Revolutions Per Minute
KV Kilovolts
EPC Engineering, Procurement & Construction
HRSG Heat Recovery Steam Generator
PLN Perusahaan Listrik Negara
GE General Electricals
Meppogen PT Metaepsi Pejebe Power Generation
EIA Environmental Impact Assessment
SD Support Document
USD United States Dollar
CCGT Combined Cycle Gas Turbine
PLF Plant Load Factor
LOA Letter of Approval
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1 INTRODUCTION
E.ON Carbon Sourcing GmBH has commissioned Bureau Veritas Certification to
validate its CDM project Gunung Megang Add-On Combined Cycle Project (hereafter
called the project) at JI. Raya Palembang Muara Enim, Km. 152, Gunung Megang,
Muara Enim , South Sumatra, Indonesia.
This report summarizes the findings of the validation of the project, performed on the
basis of UNFCCC criteria, as well as criteria given to provide for consistent project
operations, monitoring and reporting.
1.1 Objective
The validation serves as project design verification and is a requirement of all projects.
The validation is an independent third party assessment of the project design. In
particular, the project's baseline, the monitoring plan (MP), and the projects compliance
with relevant UNFCCC and host country criteria are validated in order to confirm that
the project design, as documented, is sound and reasonable, and meets the stated
requirements and identified criteria. Validation is a requirement for all CDM projects and
is seen as necessary to provide assurance to stakeholders of the quality of the project
and its intended generation of certified emission reductions (CERs).
UNFCCC criteria refer to Article 12 of the Kyoto Protocol, the CDM rules and modalities
and the subsequent decisions by the CDM Executive Board, as well as the host country
criteria.
1.2 Scope
The validation scope is defined as an independent and objective review of the project
design document, the projects baseline study and monitoring plan and other relevant
documents. The information in these documents is reviewed against Kyoto Protocol
requirements, UNFCCC rules and associated interpretations.
The validation is not meant to provide any consulting towards the Client. However,
stated requests for clarifications and/or corrective actions may provide input for
improvement of the project design.
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2 METHODOLOGY
The overall validation, from Contract Review to Validation Report & Opinion, was
conducted using Bureau Veritas Certification internal procedures.
In order to ensure transparency, a validation protocol was customized for the project,
according to the version 03.0 of the Clean Development Mechanism Validation and
Verification Standard, issued by CDM Executive Board at its 70th meeting on
23/11/2012 [1]. The protocol shows, in a transparent manner, criteria (requirements),
means of validation and the results from validating the identified criteria. The validation
protocol serves the following purposes:
It organizes, details and clarifies the requirements a CDM project is expected to
meet;
It ensures a transparent validation process where the validator will document
how a particular requirement has been validated and the result of the validation.
The validation findings presented in this report relate to the project as described in the
PDD version 1.0 and 1.2.
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(a) The project participants have made mistakes that will influence the ability of the
project activity to achieve real, measurable additional emission reductions;
(b) The CDM requirements have not been met;
(c) There is a risk that emission reductions cannot be monitored or calculated.
The validation team may also use the term Clarification Request (CL), if information is
insufficient or not clear enough to determine whether the applicable CDM requirements
have been met.
To guarantee the transparency of the verification process, the concerns raised are
documented in more detail in the verification protocol in Appendix A.
The ITR is an independent process performed to examine thoroughly that the process
of validation has been carried out in conformance with the requirements of the validation
scheme as well as internal Bureau Veritas Certification procedures.
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The Lead Verifier provides a copy of the validation report to the reviewer, including any
necessary validation documentation. The reviewer reviews the submitted
documentation for conformance with the validation scheme. This will be a
comprehensive review of all documentation generated during the validation process.
- The validation activity has been performed by the team by exercising utmost
diligence and complete adherence to the CDM rules and requirements.
- The review encompasses all aspects related to the project which includes project
design, baseline, additionality, monitoring plans and emission reduction
calculations, internal quality assurance systems of the project participant as well
as the project activity, review of the stakeholder comments and responses,
closure of CARs, CLs and FARs during the validation exercise, review of sample
documents.
The reviewer compiles clarification questions for the Lead Verifier and Validation Team
and discusses these matters with Lead Verifier.
After the agreement of the responses on the Clarification Request from the Lead
Verifier as well as the PP(s) the finalized validation report is accepted for further
processing such as uploading on the UNFCCC webpage.
3 VALIDATION CONCLUSIONS
In the following sections, the conclusions of the validation are stated.
The findings from the desk review of the original project design documents and the
findings from interviews during the follow up visit are described in the Validation
Protocol in Appendix A.
The Clarification and Corrective Action Requests are stated, where applicable, in the
following sections and are further documented in the Validation Protocol in Appendix A.
The validation of the Project resulted in 09 (Nine) Corrective Action Requests (CARs)
and 23 (Twenty Three) Clarification Requests (CLs).
The CARs and CLs were closed based on adequate responses from the Project
Participant(s) which meet the applicable requirements. They have been reassessed
before their formal acceptance and closure.
The number between brackets at the end of each section correspond to the VVS
paragraph
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DNAs were not submitted to Validation Team by the PP, hence 02(Two) CARs were
reported.
EON Carbon sourcing GmbH obtained Annex I DNA i.e. The Netherlands (Vide Letter
Ref: ANL2011-571, Dated 02/04/2012)/Ref-3b/. The project participant provided both
copies of these letters to the validation team. The validation team confirmed the
authenticity of the approval by reviewing the letter. The letter of approval clearly states
that both parties have ratified Kyoto protocol and the approval is for voluntary
participation in CDM project activity. The title and contents of the letter of approval refer
to the precise proposes CDM project activity title in the PDD being submitted for the
registration. Also the letter of approval confirms that proposed project activity
contributes to the sustainable development in the host country Indonesia.
The letter of approval from the host party DNA and Annex I DNA are unconditional with
respect to party to Kyoto Protocol, Voluntary participation and project contribution to the
sustainable development.
The project title and the project participant specified in the PDD are consistent with the
letter of approval and hence it can be concluded that the letter of approval refers to the
project activity described in the PDD. Hence, the Validation team confirms that host
country approval is in accordance with paragraphs 43 44 of VVS version 0.3.0[1].
The validation team concluded this by checking the status of ratification of each party
involved in the project activity from the UNFCCC website through the links provided
below.
Ratification status of both host party and Annex I found valid and LOAs is representing
the correct information.
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The validation team noted that there is no LoA (Letter of Approval) has been obtained
from the Host country DNA as well as annex I party involved in this projects activity,
hence CAR 1 was raised and issued. Subsequently PP has submitted the LOA from
host country, on the basis of validation of LOA CAR 1 was closed.
While verifying the requirement of Host country DNA for proving sustainable
development due to implementation of the proposed project activity, PP has to fulfill
established criteria and submit a formal report to the DNA during application of statutory
compliance. It was observed that Carbon Trading Mechanism Division of Host Country
Indonesia calls for demonstrating compliance towards established sustainable
development criteria by PP through a formal Method "check" used to evaluate the
proposed CDM project, through which Project proponent should provide an explanation
and justification that the proposed project meets all indicators. A clarification CL-01 was
raised to provide sufficient evidences on the compliance towards this requirement and
please explain how PDD is aligned with the applicable indicators. PP provided
satisfactory information on the submission of the LOA Application to Host country DNA,
which includes sustainability checklist as well, based on the validation of the
sustainability checklist submitted to the Host country DNA CL1 was closed.
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The final PDD version 1.3 has following changes as compared to PDD ver 1.0 that was
webhosted. Validation Team has verified these changes and found correct and
appropriate.
The combined-cycle facility capacity was verified during the site visit and through the
review of Annual Operational Reports for year 2008 2010, Daily operation logbooks
for current Single Cycle power plant, LM6000 Gas Turbine Specifications, Inception
Report, Slot Agreement for the purchase of Steam Turbine with Siemens. The original
gas turbines started commercial operation in the Year 2007 /Commissioning Close out
Milestone task for both Gas Turbines and Annual Operation Reports for year 2008 -
2010/.
The Conversion package to convert Single Cycle Power plant to Combined Cycle power
plant consists of following important equipments.
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Units to be
Equipment Specification
installed
Make : DELTAK
Type: Dino 3328
HRSG (Heat Recovery Rated Capacity 132.64 t/h
Steam Generating HP Steam Pressure:66.79 bar 02 Units
System) LP Steam Pressure: 6.42 bar
HP Steam Temp: 400.7oC
LP Steam Temp: 191.2oC
Make: Siemens AG
Type: SST 400
Steam Turbine Rated Capacity : 132.3 t/h 01 Unit
Steam Pressure: 64.01 bar
Steam Temp: 397.8oC
Apparent O/P : 42,947 kVA
Rated Capacity: 34,350 KW
Generator 01 Unit
Voltage: 11KV (With +/- 5% Range)
Speed: 1500 rpm
Fuel Supply System
Capacity : 18 MMSCFD 01 unit
(Natural Gas)
Validation Team has reviewed the main equipment purchase contract with Siemens
dated 18/03/2011
The project adds 31.8 MW of generating capacity to the North Sumatra national grid in
Indonesia with minimal incremental additions to greenhouse gas (GHG) emissions. The
project has a total installed capacity of 114.42 MW, generating on an average
approximately 819,060 MWh of electricity annually which will be displaced to North
Sumatra National Grid. It is expected to reduce emissions by 106,172 tCO2e per year,
which will amount to 1,061,720 tCO2e for the selected fixed crediting period of 10 years.
The fixed crediting period starts 01/03/2013 (or on the date of registration of the CDM
project activity, whichever is later).
The projects system boundaries are clearly defined as the Sumatra Grid and all power
connected to the Sumatra Grid. The project will be connected to Sumatra Grid through
the Gunung Megang Power Plant substation located at the project facility.
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construction of the project activity, hence The project starting date is 18/03/2011/5/ and
is in accordance with the CDM Glossary of terms for the project starting date.
Based on the expertise of validation team , as well as the review of the final equipment
purchase contracts /5/ and project engineering design, it is concluded that the proposed
project activity for conversion of single cycle power plant to combined cycle power plant
reflects current good practice.
Currently site preparation and piling work is in progress at project site for installation of
HRSGs and Steam Turbine. The project will become fully operational in March 2013,
which is a targeted completion date and is found documented in the EPC contract. The
PPA is in place, which is mutual agreement signed between PT Metaepsi Power
Generation (Meppogen) /42/ and PLN on Dtd. 11/10/2011/, the contractual quantity of
power to be purchased by PLN is matching with the proposed capacity of the combined
power plant i.e. 115 MW.
However the project activity is dependent on the waste heat from existing gas turbines,
the project activity can only continue to operate till the completion of lifetime of existing
Gas Turbines. Hence the lifetime of the project is calculated as 14 years.
PP has selected fixed crediting period of 10 Years, which in compliance with the
Remaining life time calculated by PP using Tool to calculate remaining life time of the
equipment
The crediting period of the project activity will start on either 01/03/2013 or after the
registration of the proposed project activity. The validation team noted that the expected
date for start date of crediting period is appropriate. In case, the registration of the
proposed project later than this date, the PDD provides confirmation that crediting
period will start only after the registration of the project activity.
Validation team considers the project description to be complete and accurate, and the
PDD is in compliance with relevant forms and guidance.
The validation team hereby confirms that the project description in PDD Version 1.0
Dtd.11/11/2011, Version 1.2 Dtd. 08/06/2012 and Version 1.3 is accurate and complete
in all respects and that there are no changes to the project activity/design or boundary
as compared to the webhosted PDD.
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Applicability condition (a):The unit(s) have an operational history of at least one year
with no major retrofit, and at least one unit has an operational history of more than three
years with no major retrofit. There is no major retrofit in these time periods.
Project baseline scenario consists of two Natural Gas turbine for power generation in
single cycle mode, both turbines were installed in year 2006 and were commissioned in
year 2007 for final commercial operation, this was confirmed through verification of
various documents i.e. Annual Operational Report of year 2008 / 2009 /2010 / 2011
where first firing and first synchronization dates are captured for both turbine units and it
is substantiated with documents i.e. Commissioning Closeout milestone task,
Certification of completion and commercial Operation date documented in the official
documents by PLN for both baseline turbine units installed and commissioned by GE.
Hence it is concluded that both baseline turbine units are having operational history of
more than three years.
As far as major retrofit condition is concern, both baseline turbine units faced
breakdowns immediately after commissioning and during site visit maintenance reports
verified which confirms that both turbines were taken off and transported back to
Germany for repair and during this period the plant was running using spare turbine
supplied by GE on rental basis. However PP has not provided transparent calculations
on cost of maintenance to justify how it is not exceeding 20% threshold of cost of
construction for a new unit. Hence one CAR was raised. Subsequently PP explained
through response to the CAR, that both breakdowns were reported immediately after
the commissioning of turbines in April 2007 and thereafter no major maintenance was
reported which is seen from the maintenance records provided to validation team for
validation. Since both turbines have three years operational history subsequent to the
initial maintenance/repairs, the costs of the repairs was deemed not necessary/relevant
and hence it is concluded that this methodological condition is fulfilled.
Applicability Condition (b):In the case that a unit has less than three years operational
history: all project power unit(s) were designed and commissioned for operation in
single cycle mode only. This shall be demonstrated by the project participants by
providing relevant documents, such as original process diagrams and schemes from the
construction of the plant, licenses and/or by an on-site check by the DOE prior to
the implementation of the project activity.
Project baseline scenario consists of two Natural Gas turbine for power generation in
single cycle mode, both turbines were installed in year 2006 and were commissioned in
year 2007 for final commercial operation, this was confirmed through verification of
various documents i.e. Annual Operational Report of year 2008 / 2009 /2010 / 2011
where first firing and first synchronization dates are captured for both turbine units and it
is substantiated with documents i.e. Commissioning Closeout milestone task,
Certification of completion and commercial Operation date documented in the official
documents by PLN for both baseline turbine units installed and commissioned by GE.
Hence it is concluded that both baseline turbine units are having operational history of
more than three years.
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Applicability Condition (c): During the most recent three years prior to the
implementation of the project activity and during the crediting period the project power
unit(s) use(d) only the following fuel types:
(a) Fossil fuels; and/or (b) Blends of fossil fuels and biofuels, where the biofuel is
blended to the fossil fuel in a situation that is outside the control of the project
participants (such as regulatory requirements to blend
biodiesel with diesel or biogas with natural gas).
During site visit it was confirmed that during the most recent three years prior to the
implementation of the project activity only Natural gas was used as fuel to generate
power, which was further substantiated by the Gas supply contract signed with the Gas
Supplying company M/s PT Medco E&P Indonesia, Dtd. 20th January 2006, as per the
contract only Natural gas will be supplied to the Baseline single cycle power plant and
Combined cycle plant in project scenario. From the existing facility at site it was
confirmed that there is no other blend of fuel is used or will be used.
Applicability condition (d) : The type(s) of fossil fuels used by the project power unit(s)
during the crediting period were also used during the most recent three years prior to
the implementation of the project activity, except, where applicable, any auxiliary fuel
consumption (e.g. for start-ups) which shall not exceed 3% of the total fuel consumption
in the unit(s) (measured on an energy basis).
During site visit it was confirmed that PP has decided to continue usage of natural gas
of same specification during project scenario and there is no auxiliary fuel is being used.
Applicability Condition (e) :Moreover, this methodology is applicable under the condition
that the project activity does not increase the lifetime of the existing gas turbine or
engine during the crediting period, as determined using the .Tool to determine the
remaining lifetime of equipment. (i.e. this methodology is applicable up to the end of the
lifetime of existing gas turbine or engine, if shorter than crediting period).
Conversion of Single cycle Power plant to Combined cycle power plant does not
increases the life time of the existing gas turbines as the remaining lifetime of the
turbines is calculated as 14 years as per the Tool to determine remaining life time of
equipment which higher than that of selected fixed crediting period of 10 years, without
renewal. Hence the applicability condition is fulfilled.
The validation team hereby confirms that the selected baseline and monitoring
methodology ACM 0007 (Version 6.1.0), combined tool to identify the baseline scenario
and demonstrate additionality (Version 5.0.0), Tool to determine the remaining lifetime
of equipment (Version 01) and other methodology component are previously approved
by the CDM Executive Board, and is applicable to the project activity, which, complies
with all the applicability conditions therein.
The validation Team hereby confirms that, as a result of the implementation of the
proposed CDM project activity, there are no greenhouse gas emissions occurring within
the proposed CDM project activity boundary, which are expected to contribute more
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than 1% of the overall expected average annual emissions reductions, which are not
addressed by the applied methodology.
The PP has correctly delineated the project boundary in the PDD section B.3 and it is
explained through process flow diagram. The validation team validated the project
boundary by:
a) During site visit to confirm the project boundary various documents were assessed
i.e. Power purchase agreement with PLN for power supply, Statistics book of electricity
and energy number issued by Directorate General of Electricity and energy utilization
for the Year 2007 - 2009 and commissioning report of Single cycle power plant turbine
units Dtd. 22.04.2007. Which confirms that the project boundary identification is in line
with approved Large scale Methodology ACM 0007,
b) The Single Cycle Power plant operating in baseline scenario is located 35 KM away
from town Muara Enim and situated on the top of a small hill, which is surrounded by
forest. The physical Project boundary involves following process equipments
Based on the above assessment, the validation team hereby confirms that the identified
boundary and the selected sources and gases are justified for the project activity.
PP has demonstrated step by step approach adopted to identify the possible alternative
scenarios and to select most plausible baseline scenario in the PDD Section B.4. The
validation team has validated the same as below
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4. Implementation of Coal fired power plant with the installed capacity equal to
proposed project activity.
5. Oil fired power plant with the installed capacity equal to proposed project activity.
6. Renewable power plant with installed capacity equal to proposed project activity.
The baseline scenarios of power from other fossil fuel power plant (coal, fuel oil) were
not considered as plausible because they are not realistic due to the following reason.
The project activity is the conversion of a natural gas based Single cycle power
generation unit to combined cycle Power plant.
Since the baseline two turbine units were already running on natural gas, and a well-
established Natural gas distribution network is available near to the project site. During
site visit it was noticed that a booster station is located in the project premises. Hence
the use of alternate fossil fuels is not practical. Also the fact that natural gas is the easily
available fossil fuel in the region, the switching of fuels is not practical and feasible as it
calls for huge investment and will result into increased GHG emission than the
proposed project activity.
Renewable energy, such as hydroelectric, wind, solar or biomass power plants, were
not considered as an alternative for the proposed project activity since it is not
comparable in terms of the availability of facilities and the scope of decision.
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As per the Presidential Decree of Host country private sector power producers
are required to supply power under the second phase of the governments fast
track power generation program and under this phase government is intended to
get away from Coal and increase its power generation capacity to 10000 MW by
2012 2014.
AMDAL Regulations 2006 for the Pollution control norms in Host Country.
The baseline scenario alternative selected in step 1 are in compliance with existing
national regulations.
The validation did not reveal any specific regulation neither for the utilization of waste
heat nor for energy efficiency norms for power projects in the host country Indonesia.
In regards to pollution control norms for Air emission for the Gunung Megang power
Plant, validation team has verified that the project is in compliance and is addressing
pollution control norms for air emissions in the host country Indonesia as per the project
EIA as well as regular submissions of compliance report to government authority found
in line with AMDAL (Analisis Mengenai Dampak Lingkungan) regulation. This is been
specifically verified by the local legal expert engaged for the validation during Site visit.
All current regulation pertaining to power sector and environment in host country does
not prevent the implementation of the identified alternatives.
In the baseline, electricity would be supplied to the grid by the existing open-cycle gas
turbine power plant with same configuration and operating parameters i.e. PLF and
Efficiency as well as other power plants connected to the grid and hence Validation
Team considers the identified baseline scenario is applicable to the proposed project
activity and is realistic.
Based on the above assessment, the validation team hereby confirms that:
(a) All the assumptions and data used by the project participants are listed in the
PDD, including their references and sources;
(b) All documentation used is relevant for establishing the baseline scenario and
correctly quoted and interpreted in the PDD;
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(c) Assumptions and data used in the identification of the baseline scenario are
justified appropriately, supported by evidence and can be deemed reasonable;
(d) Relevant national and/or sectoral policies and circumstances are considered and
listed in the PDD;
(e) The approved baseline methodology has been correctly applied to identify the
most reasonable baseline scenario and the identified baseline scenario
reasonably represents what would occur in the absence of the proposed CDM
project activity.
The Baseline scenario is the generation of electricity by the operation of the existing
project power unit in single cycle mode as well as by the grid connected power plants.
The project will partially displace electricity generated by the project power unit in the
baseline scenario. In addition it is also expected to displace electricity in the grid, as the
quantity of electricity generation by the plant is expected to increase as a result of the
project activity. The increase in the electricity generation is unknown to what extent
such an increase is due to the project activity or would have occurred anyway due to a
change in the electricity demand or availability of other power plants in the grid.
PP has evaluated following three cases to assess the applicability to arrive at baseline
emissions.
Case 1 The quantity of electricity generated in the project power unit, adjusted for
changes to efficiency (EGPJ,adj.y) is lower than or equal to the historical average
annual generation level (EGBL,AVR) Case 1 is not applicable for the project for
calculating baseline emissions as the electricity generated by the combined cycle power
plant will exceed the maximum electricity generation capacity of the single cycle plant.
The project activity increases the capacity from 80MW to 110MW.
Case 2 - The quantity of electricity generated in the project power unit(s), adjusted for
changes to efficiency, (EGPJ,adj,y) exceeds the historic average annual generation
level (EGBL,AVR) but is lower than or equal to the maximum annual quantity of
electricity that the project power unit(s) could have produced prior to the implementation
of the project activity (EGMAX). Baseline emissions are calculated as Case 2 is also
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not applicable for arriving at the baseline emissions as the electricity generated by the
combined cycle power plant will exceed the maximum electricity generation capacity of
the single cycle plant. The project activity increases the capacity from 80MW to
110MW.
Case 3 - The quantity of electricity generated in the project power unit(s), adjusted for
changes to efficiency, (EGPJ,adj,y) exceeds the maximum annual quantity of electricity
that the project power unit(s) could have produced prior to the implementation of the
project activity (EGMAX). Baseline emissions are calculated as Case 3 is applicable
for this project as as the electricity generated by the combined cycle power plant will
exceed the maximum electricity generation capacity of the single cycle plant. The
project activity increases the capacity from 80MW to 110MW. Operating the 110MW
CCGT plant at the planned 85% availability factor is equivalent to 93.5MW, which is
more than the total possible from the existing 80MW plant.
As per the Case 3 baseline emissions are calculated using following formulae
Where
BEy - Baseline emissions in year y (tCO2/yr)
EGPJ,adj, - Quantity of electricity supplied by all project power units to the electricity grid in year y,
y adjusted for changes to efficiency (MWh/yr)
EGBL,AV - Average annual quantity of electricity supplied by all project power units to the electricity
R grid during the defined operational history (MWh/yr)
EGMAX - Maximum annual quantity of electricity that could be generated by all project power units in
the baseline scenario (MWh/yr)
EFCO2,B - Baseline emission factor of all project power units operated in single cycle mode
L (tCO2/MWh)
EFgrid,y - Emission factor of the electricity grid to which the project power unit is connected
(tCO2/MWh)
PP has referred to the Tool to calculate the emission factor for an electricity system in
the PDD however PP has not demonstrated that the the Emission factor for the grid is
calculated using step by step approach as prescribed by the Tool, hence CAR 5 was
raised.
In response to CAR 5 PP has revised PDD Section B.6.1 to demonstrate step by step
approach for calculating Emission Factor for an electricity system. Grid emission factor
calculations are taken from the calculations done by Badan Pengkajian dan Penerapan
Teknologi (BPPT) and approved by the Directorate General of Electricity and Energy
Utilization (DJLPE). The Indonesian DNA uses this calculation as their official grid
emission factor for the Sumatera grid. The original source of all the data was obtained
by BPPT from PT PLN Pembangkitan Sumbagut, PT PLN Pembangkitan Sumbagsel
Statistics from 2005 to 2007 and PT PLN P3B Sumatera (IPP data).
PP has submitted this official document to validation team for validation purpose and it
is observed that all steps of the prescribed tool are followed to arrive at the emission
factor for Sumatra grid
Following key assumptions are considered while calculating the value of emission factor
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Validation team verified all assumptions presented, and based on the revision of PDD
and submission of an official document for demonstrating calculation of Emission factor
of Sumatra grid, validation team concludes that these assumptions are in line with the
prescribed tool and found transparent, hence the CAR 5 was closed. The Validation
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team herewith confirms that the Calculation of Simple OM (EFOM) and Build Margins is
in accordance the Tool to calculate the emission factor for an electricity system,
version 3.0.0.
Combustion of fossil fuels to operate the project power units to supplement the exhaust
heat in operating the steam turbine
CO2 emissions from fossil fuel combustion in process j are calculated based on the
quantity of fuels combusted and the CO2 emission coefficient of those fuels, as follows:
PE FC , j , y FCi , j , x COEFi , y
i
Therefore,
Where:
PEFC,j,y - CO2 emissions from fossil fuel combustion in process j during the year y (tCO2/yr);
FCi,j,y - Quantity of fuel type i combusted in process j during the year y (mass or volume unit/yr)
COEFi,y - CO2 emission coefficient of fuel type i in year y (tCO2/mass or volume unit)
NCVi,j - Net calorific value of the fuel type i in year y (GJ/mass or volume unit)
EFCO2,i, - Weighted average CO2 emission factor of fuel type i in year y (tCO2/GJ)
y
As per the 2nd scenario project activity involves increase in consumption of fossil fuel
i.e. natural gas due to addition of Steam turbine for operating the power plant in
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Based on above assumptions PP has calculated leakage emission associated with the
project activity using Formulae
LE y LE upstream, y LE HR, y
Where
LEy - Leakage emissions in year y (tCO2e/yr)
LEupstrea - Leakage emissions associated with the upstream emissions of an increase in fossil fuel use in the
m,y project activity in year y (tCO2e/yr)
LEHR,y - Leakage emissions due to a decrease in the amount of heat recovered from exhaust heat for purposes
other than power generation in the project, compared to the most recent year prior to the
implementation of the project activity, in year y (tCO2e/yr)
As project activity only involves Leakage emissions due to the additional consumption of
natural gas, LHR.y=0, and above equation becomes
LE y LE upstream, y
LE upstream, y
PP has calculated using following equation
1 3
FC i,x NCVi , x
max 0, FC i, y NCVi, y EFi,upstream,CH4 GWPCH4 LE LNG,CO2, y 1
3 x =1 i
LE upstream,y
i
FC i, y NCVi , y
i
Where
LEupstream,y - Leakage emissions associated with the upstream emissions of an increase in fossil fuel use in the
project activity in the year y (tCO2e/yr)
FCi,y - Quantity of fuel type i used by the project power unit(s) in year y (mass or volume unit/yr)
NCVi,y - Average net calorific value of the fuel type i used by the project power unit(s) in year y (GJ/mass or
volume unit)
EFi,upstream, - Emission factor for upstream fugitive methane emissions from production, transportation, distribution
CH4 of fossil fuel i used by the project power unit(s) in year y (tCH4/GJ)
GWPCH4 - Global warming potential of methane valid for the relevant commitment period (tCO2e/tCH4)
LELNG,CO2,y : - Leakage emissions due to fossil fuel combustion/electricity consumption associated with the
liquefaction, transportation, re-gasification and compression of LNG into a natural gas transmission
or distribution system in year y (tCO2e/yr)
FCi,x - Quantity of fuel type i used by the project power unit(s) in year x (mass or volume unit/yr)
NCVi,x - Net calorific value of fuel type i used by the project power unit(s) in year x (GJ/mass or volume unit)
X - Each year of the three years operational history
As, the project activity involves electricity generation using in Combined Cycle power
plant, PP has calculated emission reductions due to the implementation of project
activity in accordance with the Approved Methodology ACM 0007 (Version 06.1.0).
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ER y BE y PE y LE y
ER y
- Emissions reductions in year y (tCO2)
BE y
- Baseline emissions in year y (tCO2)
PE y
- Project emissions in year y (tCO2)
LE y
- Leakage emissions in year y (tCO2)
Total Installed 83.178 - Gas Turbine Generator Set The installed capacity of Power plant
Capcity (Before MW Product Specification for before combined cycle mode is as per
Combined Cycle LM6000-60 the documents verified and as
Mode) observed during site visit on
-Gas turbine Performance
09/01/2012.
Sheet Dtd. 01/03/2006
- Annual Operational Report
for last three years.
Total Installed 110 MW - Proposal for Gunung Total installed capacity (after
Capcity (After Megang CCPP Project combined cycle mode) is found
Combined Cycle Add on Dtd. 27/04/11 satisfactory after verifying listed
Mode) - EPC contract with PT documents.
satyamitra Surya Perkasa
Dtd. 14/09/11
- Steam Turbine
Specification sheet
- HRSG Specification
Sheets
- Slot Agreement with
Siemens for the supply of
Steam Turbine.
Qty. of electricity 525,248 Annual operational Reports Qty of Electricity supplied by the
supplied by the MWh/yr for year 2008 to year 2010. project power plant is found derived
project power plant from the Annual operation reports.
with three years Values taken from the annual
operational history operational report found authentic as
this is also endorsed by the PLN
Maximum annual 677,051 Calculated value based on Calculation provided in the CER sheet
quantity of electricity MWh/Yr the installed capacity of the found in line with formulae provided in
that could be Power plant in baseline the Approved Methodology.
generated in the scenario and operation
Baseline hours
Average annual 525,248 Annual operational Reports Qty of Electricity supplied by the
quantity of electricity MWH/yr for year 2008 to year 2010. project power plant is found derived
supplied by all project from the Annual operation reports.
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From the baseline and project emission calculations and IRR Calculation perspective, it
is concluded that Gas consumption is an important aspect of the project activity. PP has
used two different approaches to calculate gas consumption as provided below.
1. For IRR Calculation: using the original PPA equations/ estimates and an estimate
of gas consumed by the Duct Burners
2. For Baseline and Project emissions Calculations: Using EPC Calculations and
Methodological Formulae to estimate conservative estimate of gas cost.
The detailed EPC calculations for gas consumption were not available at the time of the
investment decision and so are not used in the IRR analysis. The PPA equations were
available and so are used to estimate gas consumption for both the project and baseline
scenarios (thus providing consistency). This source of data has been validated as
providing a conservative estimate of gas consumption from the perspective of the IRR
(i.e. compared to other methods/ data sources, it slightly under-estimates gas
consumption by the project and thus over-estimates the project IRR).
The detailed EPC calculation of gas consumption was only available after the
investment decision. This is considered more technically accurate than the
assumptions used in the PPA and so is used in the calculation of emissions reductions.
As such, the estimate of gas consumption by the project activity that is used in the
calculation of emission reductions is not the same as the estimate used in the financial
analysis. The EPC calculation estimates a lower heat rate and a slightly lower
consumption of gas by the project activity (6,674,445 6,616,366 = 58,079 mmbtu
less).
However, note also that the estimate of the total amount of gas consumed in the
baseline is also different for the financial and the emission reduction calculations. The
technical estimate of baseline gas consumption, and so baseline emissions, is
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calculated based on actual historical data in accordance with the methodology. This
technical estimate of baseline gas consumption is less than the estimates based on the
heat rate specified in the PPA and used in the financial analysis (4,733,253 mmbtu
versus 5,536,881 = 803,628 mmbtu).
The gas consumption data used in the financial analysis apparently over-estimates the
gas consumption in both the baseline and project scenarios. However, because the
baseline gas consumption is over-estimated by more than the project gas consumption
(803,628 vs 58,079 mmbtu), the estimate of the additional gas consumed by the project
is thus under-estimated. Re-estimating the additional gas consumed by the project
based on the technical gas consumption data gives 1,221,477 mmbtu (6,282,573
5,954,730). As this is more than the estimate used in the financial analysis (1,137,565
mmbtu), the financial estimates are conservative from an IRR perspective as they
underestimate the gas costs of the project.
The gas consumption estimates used in the calculation of emissions reductions are
accurate and have been calculated in accordance with the methodology. The gas
consumption estimates used in the financial analysis are not the same as that used in
the emissions calculations. However, the gas consumption estimates used in the
financial analysis are based on a consistent data source that was available at the time
of the investment decision and is pertinent to financial calculations (including the tariff).
The estimates used in the financial analysis are also conservative from a point of view
of additionality.
The estimated annual average of approximately 106,172 tCO2e over the crediting
period of emission reduction represents a reasonable estimation using the assumptions
given by the PP. All the assumptions for this estimate either come from the assumptions
used for investment analysis and other technical documents i.e. PPA, Design capacity,
Historical data of operation of of gas turbine or grid emission factor. These are already
validated in sections 3.7.3 of this report. The validation team confirms that the estimates
of baseline emissions can be replicated using the information provided. It can also be
verified using the spread sheet for calculations of CERs. The baseline methodology is
correctly applied for calculation of baseline emissions and emission reductions.
In section B.6.1 of the web hosted PDD, Explanation of methodological choices refers to
the determination of the emission factor for the grid electricity system (EFgrid.y) using
tool to calculate the emission factor for an electricity system; however the step by step
approach prescribed by the tool to arrive at EFgrid.y was not demonstrated transparently
in the PDD, hence CAR 5 was raised. In response to the CAR 5 PP has incoprporated
the calculation of EFgrid in the revised PDD and presented the same in accordance with
the Tool to calculate the emission factor for an electricity system, Version 3.0.0, PP has
opted to use the Emission factor provided by the Host country DNA, which is found
acceptable and hence CAR 5 was close.
Based on the above assessment, the validation team hereby confirms that:
- All assumptions and data used by the project participants are listed in the PDD,
including their references and sources;
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- All documentation used by project participants as the basis for assumptions and
source of data is correctly quoted and interpreted in the PDD;
- All values used in the PDD are considered reasonable in the context of the
proposed CDM project activity;
- The baseline methodology has been applied correctly to calculate project
emissions, baseline emissions, leakage and emission reductions;
- All estimates of the baseline emissions can be replicated using the data and
parameter values provided in the PDD.
Baseline scenarios identified as 1 & 2 in the PDD section B.4 faces Investment barrier
and hence PP has selected Investment Analysis as an appropriate too to demonstrate
additionality of the proposed large scale project activity.
The validation team has validated the project activity start date as per following table:
18/03/2011 Date of contract Signed with Siemens 06/05/2011 Intimation to UNFCCC for
for supply of Steam Turbine. It is the prior consideration
earliest date at which real action of the notification is within 6
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The PP informed UNFCCC secretariat in writing of the Prior consideration of the CDM
for proposed project activity and the same has been reviewed from the UNFCCC
website, which shows received date as 06/05/2011. The Validation team also confirmed
that the project activity is listed in the UNFCCC secretariats publicly available list of
such notifications
Hence, it is established that the PP has intimated the UNFCCC and Indonesian DNA
within six months from the start date of the Project.
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Hence the validation team concludes that in accordance with 2 of Annex 13 of EB 62,
CDM was seriously considered while making the investment decision for the project
activity.
Based on the above assessment, the validation team hereby confirms that the CDM
benefits were considered necessary in the decision to undertake the project as a
proposed CDM project activity. Thus the proposed CDM project activity complies with
the requirements of the latest version of the Guidance on prior consideration.
Since the high investment by the PP behaves a commensurate return for the PP, the
validation team concluded that the financial indicator selected is appropriate for the
project type and decision making context. Therefore, the selected financial indicator is in
conformity with the Guidelines on Investment Analysis.
From the outcome of Step 1.a of Combined tool to identify the baseline scenario and
demonstrate additionality, the alternative scenarios remaining after Step 2 are
Alternative (1) and Alternative (2). Since one of the alternatives, Alternative (2), is the
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continuation of current practice that does not require any investment, it is not possible to
conduct an investment comparison analysis. Therefore, benchmark analysis is
conducted in order to evaluate the financial attractiveness of Alternative (1), the
proposed project activity without being registered as a CDM project activity.
Hence, the validation team has concluded that the Benchmark Analysis is selected by
the project participant is the most appropriate method of demonstrating the additionality
of the project activity and is also in conformity with the Guidance ( 19) of Annex 05 of
EB 62.
All input data and assumptions used in E-IRR computation have been checked against
the evidences provided by the PP, published information available, Indonesian Taxation
Law and the standard accounting principle. The detailed assessment incorporating the
means of validation is provided below.
P a r am et er V al u e So ur c e o f val u e V ali d a ti on ju s t i fi ca t io n
u se d
Contracted 110 Draft Agreement for increased Verified the Draft PPA However the PPA
Capacity of installed capacity of power plant has not having relevant authorization, it
Combined from 80 MW (As per PPA dtd is showing draft status.
cycle power 04 January 2007) to 110 MW.
plant (MW)
Plant Load 85% PPA signed with PT PLN. CAR 02 raised during site visit is closed
Factor based on the evidence provided and
(AFEA) explained in the response.
Net Electricity 258,420 PPA Document, Calculated Value from the Investment
Generation Power invoices of PLN during Analysis spread sheet and CER Spread
(MWh/Yr) baseline scenario, sheets. Inputs for calculation are
Installed capacity of the Baseline Electricity Generation qty. (from
Combined cycle power plant the Power bills of PLN and annual
and CER spread sheets. operational reports for last three years.
and estimated electricity generation in
project scenario based on the
Contracted capacity of the Combined
cycle plant.
Total Capex 54,405,543 - EPC Proposal initially This was further tallied using the EPC
(USD) submitted by the contractor Proposal first submitted in October
Dtd.in October 2010. 2010./Ref-6d/ and Revised Proposal
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Quantity of 1,137,565 Calculated value based on Baseline Gas consumption figures are
Gas Baseline Gas consumption data provided transparently through the Gas
Consumption and estimated Gas bills of MEDCO (Gas suppliers) verified
(mmBTU) consumption during project Gas bill summary and gas bills for the
scenario. last three years, monthly bills and
metering reports are maintained by the
PP at site. These historical records are
used to calculate the baseline gas
consumption, in accordance with the
Methodology.
Project scenario gas consumption can
be estimated in two ways: (i) based on
the formulae and estimates in the PPAs
and (ii) based on detailed EPC
estimates. The first method is used to
calculate gas consumption for the IRR
analysis, as the PPAs were available at
the time of the investment decision. This
method is also conservative from the
perspective of the IRR analysis (as this
slightly under-estimates additional gas
consumed by the project and thus over-
estimates the IRR). The second method
is based on detailed estimates of gas
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project developer has taken into account profit before tax, depreciation value (in the
terminal year) in the computation of E-IRR. The principle adopted in making projections
and computing post tax E-IRR conforms to the accepted and standard accounting and
taxation principles. An independent financial expert has verified the IRR calculations
and observed them to be in order.
In the above background, the validation team concludes that underlying assumptions
are appropriate, accounting principles adopted in calculations and calculations per se
are correct and the guidance vide paragraph 117 - 121 of the VVS has been taken care
of. Based on the above, the Post Tax E-IRR works out to 9.5%.
Benchmark:
The project participant has chosen Default value for the expected return on equity as
per the Annex A of EB 62 Annex 05. The default value selected by Project participant is
12.5% under Group 1 for host country Indonesia. This value is classified under Ba2
category of Moodys Risk Rating for bonds.
The selection of default value is appropriate as there is no external funding is utilized for
this project, project participant has utilized internal equity and loan from Bank to finance
the project.
Hence the validation team was of the view that the expected return of 12.5% from the
project was commensurate with the risk involved in the Group 1 project activity. Thus,
the benchmark determined for the project activity (12.5%) was found in line with VVS
version 3 Para 121 and EB 62 Annex 05..
The E-IRR was calculated based on the above input values and it is less than default
benchmark return value of 12.5%. This clearly shows that the project is not financially
feasible without financial incentive in term of CDM revenue.
The validation team noted that with CDM revenues, the E-IRR improves to meet the
benchmark return. Hence the validation team concludes that it is critical for the project
activity to get the CDM revenue in order to make the project financially feasible.
Sensitivity Analysis:
In order to demonstrate the robustness of the conclusion arrived at above, viz., that the
project is additional, the PP had subjected the five critical parameters of the project
activity i.e. Tariff, Load Factor (AFEA), Capital Expenditure (Cap-Ex), O&M Expenses
and Gas price to reasonable variations. It has been noted that the above five
parameters are the only factors, which are likely to affect the E-IRR significantly
because of their variation.
The Load Factor was arrived using calculations done internally based on the PPA
conditions and electricity generation records, however as per EB 48 Annex 11,
validation of PLF can be done using two options
(a)The plant load factor provided to banks and/or equity financiers while applying the
project activity for project financing, or to the government while applying the project
activity for implementation approval;
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(b) The plant load factor determined by a third party contracted by the project
participants (e.g. an engineering company); Hence the note provided as SD45- PLF
Justification is not accepted, CAR 02 was raised and submitted. Subsequently PP
provided response to the CAR 02 and explained that the PLF utilized for calculation of
emission reductions and investment analysis is taken from the PPA signed with PT.
PLN, hence the CAR 02 is closed.
O & M cost is arrived at using default values provided by the PP are based on ETSAP
study for Gas fired Power plants available publicly at IEA ETSAP - Technology Brief
E02 April 2010 (www.etsap.org).
The PP has subjected the Tariff, Load Factor (AFEA), Capital Expenditure (Cap-Ex),
O&M Expenses and Gas price to +/-10% variation and has presented the calculations.
In the web hosted PDD. The project cost, at the time of investment decision itself, is a
negotiated cost compared to the project cost specify in the proposal provided by the
technology supplier and represents the actual project cost (this was also validated from
purchase orders). Hence, the project cost available at the time of investment decision is
already actual project cost and any variation in the project cost is not applicable (as the
project is already implemented).
Similarly the tariff considered for the project lifetime is the prevailing rate in the region of
Host country Indonesia at the time of decision-making and is verified through the Draft
PPA Agreement (Appendix G for tariff calculation) and is noted that it is fixed for 20
years, so the variation in tariff is highly unlikely.
Other parameters like Interest rate, D/E ratio do not contribute 20% of project cost or
revenues from project and hence not subjected to sensitivity analysis.The results of the
sensitivity analysis are as follows:
Variation
Parameters Bench Mark
-10% -5% 00% +5% +10%
Tariff 1.65% 5.48% 9.50% 13.74% 18.14%
Plant Load Factor 12.5% 21.64% 14.98% 9.50% 2.40% -0.77%
Cap-Ex 17.82% 12.50% 9.50% 7.42% 5.84%
O&M 10.60% 10.05% 9.50% 8.95% 8.42%
Gas Price 12.82% 11.15% 9.50% 7.88% 6.30%
NOTE: Threshold Values below indicate the percentage of existing value at which
calculated IRR reaches benchmark value
NOTE: Threshold Values below indicate the exact value of corresponding parameter at
which calculated IRR reaches benchmark value
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In the case of tariff, beyond an increase of 5%, the E-IRR crosses benchmark value.
However it is highly unlikely as PPA agreement with PLN clearly states that the
Power purchase agreement will be for a fixed period of 20 years. Validation team
has further verified the PPA between PT. PLN and PT Metaepsi Pejebe Power
Generation (Meppogen) and found that the preferential fixed tariff of 0.058/ KWh is
applicable for the entire 20 year period. Hence, even if there are amendments in the
power purchase tariff from the PLN, the amended price will not be available to the
project participant. Hence, based on this evidence, the sensitivity analysis on the tariff
was accepted by the validation team which is in compliance Para 20 &21 of EB 62
Annex 05
Similarly for project cost, variation of -10 % is highly unlikely as the price quoted
in the Board note minutes is less than the initial offer price by all suppliers for project
components. The investment analysis considers the final negotiated price 54,405,543
USD of (which was available to the PP at the time of investment decision). Validation
team further verified the same with the actual purchase order values raised by the
PP. Hence it is highly unlikely to have any reduction in the Cap-Ex (as the project
is already started and is in construction phase and actual project cost is taken in the
investment analysis), so the project IRR crossing the bench mark is unrealistic. Thus
sensitivity of project cost has been validated in compliance to Para 20 &21 of EB 62
Annex 05.
Subjecting the O& M to +/-10 % variation reveals the project IRR do not cross the
bench mark , hence no probability of occurrences conducted as per Para 21 of EB
62 Annex 05.
Gas price has to decrease by 10% for the project to be financially viable. The gas price
is assumed to be (5.20USD/mmBtu) in the IRR calculation. This in line with market
prices based on PGN presentation to investors /Ref-44/ /Ref-43/ & /Ref-45/. The market
expects the gas price to increase in the future, but this increase has not been taken into
account for the IRR calculation for conservative reasons.
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The validation team also verified the assumption values with the actual values of the
term loan and debt equity ratio. It was observed that the actual term loan sanctioned by
the bank is on 8 % interest rate which is confirmed using bank mandate letter for loan
(Loan Sanction Document). This is considered as nominal interest rate and PP has
Applied 6.53 as real interest rate after deducting the inflation rate of 1.48% as per the
WORLD ECONOMIC OUTLOOK REPORT Published by IMF in September 2011, as
the loan amount sanction is in USD.
Hence, the Equity IRR (Post tax), after applying the actual values applicable after
commissioning such as Tariff, Plant Load Factor (AFEA), Capital Expenditure (Cap-Ex),
O&M Expenses and Gas price also remain under the benchmark value of 12.5%.
Further, the validation team would like to state that the post-tax equity IRR computed by
the project participant are based on the very conservative computation approach has
been adopted in the cash flows. The investment analysis applied by the project
participant has also been validated by an independent financial expert. In the above
background, validation team concurs with the PP that the project activity is financially
not viable without the benefits from CDM. IRR with CDM revenues worked out to be
16.63%. Hence the IRR with CDM revenues crosses the benchmark. Thus the project is
viable with CDM revenues. Validation team is, therefore, convinced that the project is
additional.
PP has identified Investment barrier as one of the barrier which described in detail in
section 3.7.3 of this validation report.
From the common practice analysis presented in the PDD it is evidenced that PP has
considered similar activities to the project activity to perform common practice analysis.
PP has utilized World electric Power plants Data base from PLATTS and identified
single and combined cycle gas fired power plants in Indonesia with comparable installed
capacity in the range of 55 165 MW using same fossil fuel i.e. Natural Gas. There
were 19 power plants identified by PP which are in operation in Host country. Input data
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source verified by visiting the web site and found authentic, hence Validation Team
confirms that the input data selection is in line with the requirement of methodological
condition.
PP has identified all 19 power plant located in the same host country i.e. Indonesia
hence it is confirmed that all plants are within the relevant geographical area and there
is no variations in the framework conditions prevails in the geographical area, hence this
methodological condition is also fulfilled.
From the data made available during validation it was concluded that there are totally
Fifty four (54) number of natural gas fired power plant are currently in operation in Host
country in different states and 19 amongst them are of comparable capacity i.e.
between 55- 165 MW. Out of these 19 Power plants of comparable capacity, only 04
are working in combined cycle mode, which is contributing to 21%. As per the
methodological condition the project activity will be regarded as Common practice if
more than 50% of the assessed power plants operate in combined cycle mode, hence
based on the study result the project activity is not a common practice and it is
additional.
The validation team hereby confirms that the proposed CDM project activity is not
common practice.
- FCi.y is the measured quantity of natural gas consumed by the project activity
which is monitored Ex Post using calibrated metering system installed at Gas
receiving station managed by MEDCO (Gas supplier) The quantity of natural gas
consumed will be measured using a gas flow meter which will be calibrated by
the gas supply company (Medco), in accordance with national standards.
- pj.y Efficiency of the combined cycle power plant, is a calculated value using
direct method i.e. A calculation based on the energy of total electricity generated
divided by the total amount of gas energy used by the power plant during a given
time period (i.e. one year).
- NCVi.y is the Parameter, which will be monitored Ex post based on the monthly
natural gas consumption quantity as per the invoices submitted by the Natural
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gas supplier. It is derived from Weighted average annual values of Net Calorific
Value of Natural gas which provided by the supplier through monthly gas
invoices. This is found in accordance with the Option (a) of Data Source
mentioned in the Section III of Approved methodology for the same parameter.
NCV is derived from the GCV which is monitored and reported on the gas
invoices by the gas supply company (i.e. not measured or calculated by the
PP)Project participant has provided a systematic mechanism for archiving
electronic and hard form of all the monitored data. This is stated transparently in
section B.7.2 of the revised PDD.
Project participant has made a provision of retention for project relevant monitoring data
for keeping the data for 2 years after the end of the last crediting period.
The monitoring plan includes requirements for meter testing and calibration. The meters
used for monthly joint meter recording are tested and calibrated by the authorized
agency of the state electricity Board.
During validation it was observed that PDD section B.6.2 is providing information on the
data and parameters available at validation, however the data and parameters
presented in this section are found wrongly addressed i.e. EGOCH , FCNG.OCH as
well it was seen that there are various data parameters used by PP to arrive at emission
calculations are not found described in section B.7.1 e.g. EFupstream.CH4, EFCO2
Max, CAPmax, Tmax, QHRx, HMRy etc. which is also required by the approved
methodology, hence CAR 08 was raised and issued.
The validation team has reviewed the revised PDD and confirms that the QA / QC
procedures described in section B.7.1 are adequate and satisfactory. The validation
team has cross checked the accuracy class and type of meter during the onsite visit and
finds the description as correct. The responsibility of meter reading is jointly held by the
PT Metaepsi Pejebe Power Generation (Meppogen) and the representatives of PLN
and the responsibility of meter accuracy testing and calibration is with the Meppogen.
The meters are calibrated annually. The validation team hereby confirms that the
monitoring plan complies with the requirements of the applied methodology.
The validation team hereby confirms that the project participants are able to implement
the monitoring plan.
PP has done the EIA process in December 2009 as a part of obtaining operating
license. The EIA was conducted based on the AMDAL Regulation 2006. It was
noticed that during EIA there is no significant environmental impacts identified due to
implementation of the project activity. However PP has arrived at a comprehensive
Environmental Management plan for various stages of project implementation.
Monitoring, measurement and reporting mechanism is found in line with the regulatory
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Necessary permits to start the project has been obtained by the PP and and were
verified during site visit by the local legal expert, who was the part of Validation team.
Hence the validation team confirms that the project complies with the environmental
regulations of Host Country i.e. Indonesia.
The PP have utilized appropriate media to invite these stakeholders. The PP had invited
the stakeholders on 23/09/2011 by Invitation Letter No. 4.014/L/GM/GMR/UND/IX/2011.
The validation team have verified the related documents and found it acceptable. Also,
the date of invitation to the meeting is prior to the publication of the PDD on the
UNFCCC website i.e., From 17 November 2011 16 December 2011.
The project participant has made a presentation of the project activity to the participants
of the Local Stakeholders during Local stakeholders consultation meeting on
27/09/2011, in unbiased manner. During meeting, the PP invited comments of the
stakeholders on the project. The project has not received any adverse comments. The
validation team has checked the summary of comments received during the meeting
and it has verified the same by way of interviews with some local stakeholders during
the site visit.
The validation team hereby confirms that the process of local stakeholder consultation
is observed to be adequate.
5 VALIDATION OPINION
Bureau Veritas Certification has performed a validation of the Gunung Megang Add-on
Combined Cycle Project Project in Indonesia . The validation was performed on the
basis of UNFCCC criteria and host country criteria and also on the criteria given to
provide for consistent project operations, monitoring and reporting.
The validation consisted of the following three phases: i) a desk review of the project
design and the baseline and monitoring plan; ii) follow-up interviews with project
stakeholders; iii) the resolution of outstanding issues and the issuance of the final
validation report and opinion.
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Project participants used Combined tool to identify the baseline scenario and
demonstrate additionality,(Version 6.1.0), the latest tool for demonstration of the
additionality. In line with this tool, the PDD provides analysis of investment barrier and
Common practice analysis to determine that the project activity itself is not the baseline
scenario.
By synthetic description of the project, the project is likely to result in reductions of GHG
emissions partially. An analysis of the investment barrier and Common practice analysis
demonstrates that the proposed project activity is not a likely baseline scenario.
Emission reductions attributable to the project are hence additional to any that would
occur in the absence of the project activity. Given that the project is implemented and
maintained as designed, the project is likely to achieve the estimated amount of
emission reductions i.e. 106,172 tCO2 over selected fixed crediting period of 10 Years.
The review of the project design documentation (Version 1.0, Version 1.2 & Version 1.3)
and the subsequent follow-up interviews have provided Validation Team with sufficient
evidence to determine the fulfilment of stated criteria. In our opinion the project correctly
applies and meets the relevant UNFCCC requirements for the CDM and the relevant
host country criteria. Bureau Veritas Certification thus requests registration of Gunung
Megang Add-on Combined Cycle Project as CDM project activity.
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6 REFERENCES
Category 1 Documents:
Documents provided by Type the name of the company that relate directly
to the GHG components of the project.
/1/ PDD [initially published version (web hosted)], Version- 1.0, Date- 11/11/2011
/2/ PDD Version 1.1 Date 15/03/2012
/3/ Letter of Approvals from parties involved in Project activity:
a. LOA from Host Party Indonesia (Vide Letter Ref : B082/KNMPB/06/2012,
Dated. 25/06/2012)
b. LOA from Annex I DNA i.e. The Netherlands (Vide Letter Ref: ANL2011-571,
Dated 02/04/2012).
/4/ Proof of Serious consideration of CDM (in accordance with the UNFCCC guidelines
provided in EB 62 ANNEX 13
a) UNFCCC CDM portal, Prior consideration notification indicating the date
received as 06/05/2011
b) Intimation to Indonesia DNA Letter dated 12/05/2011
/5/ Proof of the implementation timeline presented in the PDD in accordance with the
UNFCCC guidelines provided in EB 62 ANNEX 13
a) Manufacturing Slot Agreement with Manufacturer of Steam Turbine and
investment decision date.
b) Intimation to UNFCCC dated 06/05/2011 and intimation to Indonesian DNA
Dated 12/05/2011
c) Business license obtained for 230 MW combined cycle power plant
implementation Dated 09/02/2010
/6/ Evidences against all Techno-economic input data and assumptions used in Investment
analysis
a) Land Use Agreement with PT MEDCO E&P LEMATANG Dated 10/09/2009
b) Bank Approval with Terms and conditions for financing Dated 14/12/2009
c) Business license obtained for 230 MW combined cycle power plant
implementation Dated 09/02/2010
d) Proposal for the project activity from Satyamitra Surya Perkasa (SSP) and Black
& Veatch International (BVI) for EPC job dated 30/10/2010
e) Inception Report (Technical Feasibility Study Report)
/7/ Relevant proofs of local stakeholder consultation process
a) Intimation Letter dated: 23/09/2011b) MOM of Stake holder meeting & feedback
form dt: 27/09/2011
/8/ Annual reports of the Project Proponent
/9/ SD1: Turbine Gen Set Performance For PT. MetaEpsi Dated 01/03/2006 - issued by
GE for Baseline Gas turbines
/10/ SD3: EPC- Latest Depicting Selection of technology and plant configuration for
combined cycle plant performance.
/11/ SD4: Press Release on Indonesian Government Policy on Fast Track Phase 2 to open
energy sector for private energy producers Dated June 2011
/12/ SD7a SD7C: Annual Operational Report for year 2008 2010 for Baseline
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information
/13/ SD8: HRSG Specification Sheet
/14/ Proof of start date:18/03/201108(based on the purchase order issued by PP to purchase
Steam Turbines)
SD9: ST-Specification Sheet (Steam Turbine specification sheet Ref M-09.0369/
Dated 18/03/2011)
/15/ Proof of PLF Power purchase agreement with PT PLN
SD10a: Initial PPA signed between Meppogen and PLN (For Operation and purchase
of Power from Open Cycle power plant Baseline Scenario)
/16/ SD10b & c:
- Letter of intent (LOI) Dtd. 07th September 2010 (Surat No. 02428/122/DIRDANS/10)
- Draft PPA between Meppogen and PLN for power purchase from Combined cycle
power plant(Project Scenario)
/17/ SD11: LM6000 Specification Sheet Baseline Gas turbine for power generation in
Open cycle
/18/ SD12: Recommended scope of Material Inspection for Steam Turbine with Siemens.
/19/ SD15b: Gas supply contract document signed between Meppogen and Medco E&P
Indonesia (existing)
/20/ SD20: Prior Consideration Note Dated 06/05/2011
/21/ SD24: Bank Mandate Letter Dated 14/12/2009 for loan approval issued by BII (Ref No.
S2009/427/Dir.Corp- Corporate)
/22/ SD32a: Proposal for Gunung Megang CCCP Project (SSP/063/IV/11/Q) Dated
27/03/2011 submitted by PT Satyamitra Surya Perkasa.
/23/ SD32b: EPC Contract Signed between Meppogen and PT Satyamitra Surya Perkasa,
Dated 14/09/2011
/24/ SD33: Inception Report Internal Technical Feasibility Study for Meppogen
Combined Cycle Addition
/25/ SD38: Slot Reservation Agreement between Meppogen and Siemens for Manufacturing
of Steam Turbine, Dated 24/11/2010
/26/ SD39: Prior Consideration for Indonesia Project communication with Indonesian
DNA.
/27/ Spreadsheet for Annual electricity generation in Single Cycle and Combined Cycle
mode and consequently emission reduction
SD44: CER Spread Sheet
/28/ SD55: GE Commissioning Close out For Start Date of the baseline open cycle gas
turbines
/29/ SD56: Meppogen Plant History for maintenance history of Gas Turbines in
Baseline open cycle power plant.
/30/ SD57: Exclusive Service Agreement for open cycle gas turbines between Meppogen
and MTU Maintenance Berlin, Dated 06/06/2008
/31/ SD58: SOP for Gas turbine Operation & Maintenance developed by Meppogen, Dated
17/06/2009
/32/ SD59: MTU Maintenance Reports for Gas turbines During 2008 2009 period.
/33/ SD60: Sumatra Grid Power Generating Capacity Press release by Energy authority in
Host Country.
/34/ SD62: Gas Meter Readings for 2010 2011 for cross checking the gas consumption
in baseline.
/35/ SD63: MTU Gas turbine Repair Report T2 Silica 2007 During Period 26/06/2007
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to 15/08/2007
/36/ SD64: Repair Report T1 2007, Sulzer final for gear box breakdown and repair Dated
14/12/2007
/37/ SD65: Compliance report towards sustainable development criteria established by host
country DNA.
/38/ SD66: Invitation letter for stake holder Consultation process.
/39/ SD67: EF Sumatra: Calculation Spread sheet
/40/ SD68: Grid Emission Factor Calculation Demonstration of how Emission factor is
calculated by the DNA.
/41/ SD69: Investment Analysis Spread sheet.
/42/ Proof of PLF Power purchase agreement with PT PLN
SD70: Signed PPA for purchase of power between Meppogen and PLN Dated.
11/10/2011
/43/ Indonesias domestic Gas Price should give fair return : BP Migas Press release by
PLATTS Dtd. 23/02/2011
(http://www.platts.com/RSSFeedDetailedNews/RSSFeed/NaturalGas/8578885)
/44/ SD47: Market prices based on PGN presentation to investors
/45/ Retrospective Gas Price :http://www.questpetroleum.com/i/pdf/presentations/2011-11-
30-QPN-Investor-Update.pdf
/46/ SD-50 - Additional_Gas_Price_MEDCO_MEPPOGEN (For Project Scenario)
Category 2 Documents:
Background documents related to the design and/or methodologies
employed in the design or other reference documents.
[1] CDM Validation and Verification Standard (Version 03.0)
[2] Approved consolidated methodology ACM0007: Conversion from single cycle to
combined cycle power generation Version 6.1.0
[3] Tool to calculate the emission factor for an electricity system, version 3.0.0
[4] Combined Tool to identify the baseline scenario and demonstrate additionality
Version 5.0.0
[5] Tool to calculate project leakage CO2 emissions from fossil fuel combustion Version
2
[6] Tool to determine the remaining lifetime of equipment, Version 01
[7] Guideline for Completing the Project Design Document (CDM-PDD) And the
Proposed New Baselien and Monitoring Methodology (CDM-NM), Version 7 EB
41 Annex 12,
[8] CLEAN DEVELOPMENT MECHANISM PROJECT DESIGN DOCUMENT
FORM (CDM-PDD) Version 03 - in effect as of: 28 July 2006
[9] Annex 05 of EB 62; Guidance on the demonstration and assessment of prior
consideration of the CDM, version 4.0
[10] Annex 13 of EB 62; Guidance on the assessment of Investment
analysis, Ver. 5.0.
[11] SD4: Press Release on Indonesian Government Policy on Fast Track Phase 2 to open
energy sector for private energy producers Dated June 2011
[12] SD4a: Sustainable Development Criteria Host Country
(http://PAsarkarbon.dnpi.id/web/index.php/komnasmpb/cat/5/kriteria-p)
[13] SD5: Indonesia Energy-67% 2010 to 2020 Energy Development policy of host
country http://www.theindonesiatoday.com/energy-headline)
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Persons interviewed:
List persons interviewed during the validation or persons that contributed with other
information that are not included in the documents listed above.
/1/ Ms. Fumi Harap (PP Representative)
/2/ Mr. Tim Smith (Meppogen Representative)
/3/ Mr. Peter Harris (PP Representative)
/4/ Mr. Tukidjan (Meppogen Representative)
/5/ Dr. Angus McEwin (Consultant)
/6/ Mr. Sandeep Jaganath (Consultant)
/7/ Mr. Panchaksharam Thirumalavan (Consultant)
/8/ Mr. Niplan Syed (Local Stake Holder)
/9/ Mr. Dorman (Local Stake Holder)
/10/ Mr. Robin (Local Stake Holder)
/11/ Mr. Sukini (Local Stake Holder)
/12/ Mr. Arizul Anwar (Local Stake Holder)
/13/ Mr. Yanseri (Local Stake Holder)
/14/
1. o0o -
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Environmental Engineer with over all 13 years of experience in various industries related to Water & Waste water
engineering design, installation & Commissioning, Integrated Facility Management for Environmental Services
operations in various industries i.e Automotive, Pharmaceutical , IT & Electronics (With Clean Room).
Management System Implementation and Maintenance, Green Building concept implementation, Lean Management
Implementation, Water & Waste Water engineering Design & project Management, Project Environmental
Compliance etc. for a construction company.
He is the lead auditor for Environment management system, Quality management system and Occupational health
and safety management system and his auditing experience spans for 3 year with BVCI & BVCS. He has undergone
intensive training on Clean Development Mechanism and was trained as Lead Verifier for CDM in the year 2005
and working as a lead Verifier for validation and verification of CDM/VCS projects
So Shuk Ling ( Team Member) : She is a Bachelor in Chemistry and statistic and Master degree in
Manufacturing and Polymer Science. She has been working in auditing for quality and Environmental management
system for more than 9 years and in Electronics Manufacturing company for more than 8 years. She has undergone
intensive training on Clean Development Mechanism.
Sushil Budhia (External Financial Expert): He has been practicing as Chartered Accountant for 25 years and he
has very wide experience on project finance, taxation and financial auditing. He has undergone training on Clean
Development Mechanism and has conducted verification of financial indicators like IRR for more than 70 CDM
projects.
H B Muralidhar: (ITR) Lead auditor in Bureau Veritas Certification for Environment Management System,
Quality Management System and Occupational Health and Safety Management System. Graduate in Electrical
Engineering with 25 years of experience power generation and distribution related fields as well as in management
system auditing. He is the Lead auditor for Environmental Management System, Quality Management system and
Occupational Health and Safety Management System. He has undergone intensive training on Clean Development
Mechanism. He is the technical expert & conducted Validation / Verification for more than 50 CDM Projects
2. o0o -
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iii. Explanation and justification for all EB 41 Ann Yes, has justified relevant methodological choices including
relevant methodological choices, 12 different cases, options and default values while calculating
including different scenarios or cases, Baseline emissions, Project emissions, Leakage emission OK OK
options and default values and emission reductions for the proposed CDM Project
activity
Closed
d. In CDM-PDD section B.6.2 are following EB 41 Ann
provided? 12
i. A compilation of information on the EB 41 Ann Four parameters defined that are available at validation: CAR 8 OK
data and parameters that are not 12 1) EGoCH Historical net electricity generation by the power Closed
monitored throughout the crediting plant in open cycle mode
period but that are determined only 2) FCNG, OCH Historical fuel (natural Gas) consumption by the
once and thus remains fixed power plant in open cycle mode
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CAR 8
ii. The actual value applied EB 41 Ann 1) EGoCH Historical net electricity generation by the power OK OK
12 plant in open cycle mode = 525,248 MWh/yr , the value
is obtained by averaging last three years operation
reports (Year 2008 to 2010)
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Based on the EIA report host country DNA approval has been
obtained by the PP and the EIA Approval Letter has been
validated by the validation team Dtd. 28th January 2010
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i.3 Does Project power units only uses ACM 0007 The open cycle power plant is found using only one fossil fuel OK
fuel types i.e. a) Fossil Fuels and /or b) i.e. Natural Gas since its Commissioning the same was
blends of fossil fuels and biofuels, where verified using Natural Gas supply Contract and report on Fuel
the biofuel is blended to the fossil fuel in Consumption since Commissioning.
a situation that is outside the control of
the project participants (such as Initial Design documents and The Process flow diagram of
regulatory requirement to blend biodiesel Open Cycle Power plant verified to confirm this condition.
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i.4Does the type(s) of fossil fuels used by the ACM 0007 Yes. OK OK
project power unit(s) during the crediting The same fossil fuel i.e. Natural Gas shall be used by the
period were also used during the most recent project power unit (Combined cycle Power Plant) and it is
three years prior to the implementation of the observed that the natural gas was used during most recent
project activity, except, where applicable, three year period ie. 2008 2010. Natural Gas consumption
any auxiliary fuel consumption (e.g. for start- records are maintained for last three years by the PP to
ups) which shall not exceed 3% of the total demonstrate compliance to this Condition.
fuel consumption in the unit(s) (measured on
an energy basis? Physical verifications were done during site visit and found
that there is no provision for the any other auxiliary fuel
consumption. PP has one emergency generator in case of
failure of grid, fuel for this generator is also natural gas. P&ID
Diagram of the baseline plant confirms that there is no
possibility of other fuel been used in baseline scenario.
i.5 Does project activity increases the lifetime ACM 0007 Implementation of project activity will not be resulting into the
of the existing gas turbines or engines during increase in lifetime of existing gas turbines or generators OK
the crediting period. during the crediting period of 10 years.
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CL 15:
PP has applied tool to determine the remaining lifetime of
the equipment and utilized default value provided in the tool
to calculate remaining lifetime of baseline equipment, please
provide clear information how each condition mentioned in
the tool for utilizing default value is complied by the PP and
provide necessary evidences to confirm the same.
i.6 Whether the life time of the project ACM 0007 Yes, current version i.e version 01 of tool to calculate the OK OK
equipments is determined using remaining lifetime of equipment is used
approved tool i.e. Tool to determine the
remaining lifetime of equipment?
i.7 Does crediting period identified by the ACM 0007 Yes PP has identified 10 Years fixed Crediting period and OK OK
PP is in line with the remaining life time which is less than the calculated remaining life time of
of the project equipment determined existing equipments
using the approved tool as mentioned in
the approved methodology?
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k. Can a determination regarding the VVS 77 Yes, The selected methodology found appropriate to the OK OK
applicability of the selected methodology proposed project activity based on the Validation of each
to the proposed CDM project activity be applicability condition prescribed by the Approved
made? methodology. Refer to 5.b.a.i.1 5.B.a.i 7
l. If no, clarification of the methodoloy was VVS 77 NA OK OK
requested, in accordance with the
guidance provided by the CDM Executive
Board?
m. If answer to (5.b.d) above is no, VVS 77 NA OK OK
revision or deviation from the
methodology was requested, in
accordance with the guidance provided
by the CDM Executive Board?
n. If yes to (5.b.l) and (5.b.m) above, a VVS 77 NA OK OK
request for registration was submited
before the CDM Executive Board has
approved the proposed deviation or
revision?
c. Project boundary
a. Does the PDD correctly describe the VVS 86 Yes OK OK
project boundary, including the physical The project boundary delineation is done as per the approved
delineation of the proposed CDM project methodology and the description is provided in the PDD
activity included within the project section B.3.
boundary for the purpose of calculating
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vi. Does PDD demonstrates inclusion and ACM 0007 Yes. The information on the exclusion and inclusion emission OK OK
exclusion of emission sources from the sources from the project boundary has been provided in a
project boundary? Does PP has tabular manner in PDD section B.3
provided justification on the inclusion
and exclusion of all emission source
appropriately in the PDD?
b. Is the delineation in the PDD of the VVS 87 Yes OK OK
project boundary correct and include
identification of all locations, processes
and equipment including secondary
equipment and associated processes
such as logistics etc.?
c. Does the delineation in the PDD of the VVS 87 Yes OK OK
project boundary meet the requirements
of the selected baseline?
d. Have changes been made to the project VVS 87 No, there are no changes to Project boundary in comparison OK OK
boundary in comparison to the to the web hosted PDD.
webhosted PDD. If yes please comment
on the reason for the changes.
e. Have all sources and GHGs required by VVS 87 Only CO2 OK OK
the methodology been included within
the project boundary?
f. Does the methodology allow project VVS 87 NO OK OK
participant to choose whether a source or
gas is to be included within the project
boundary
g. If yes, have the project participants VVS 87 NA OK OK
justified that choice?
h. If yes, is the justification provided VVS 87 NA OK OK
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b.2 Does Project participants uses the latest ACM 0007 NO CAR 3 OK
approved version of the .Combined tool to CAR 3:
identify the baseline scenario and Closed
PDD Section B.1 refers to the tools used by PP to develop
demonstrate additionality to demonstrate
this proposed Large Scale CDM Project, however the PP has
additionality and identify the most plausible
not used current revision of tools i.e. Combined tool to
baseline scenario?
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b.4 Does future estimated load factor is ACM 0007 CAR 4: CAR 4 OK
reflecting the changes due to new conditions
PDD does not demonstrate how Methodology condition
in the grid When the current practice Closed
pertaining to selection of baseline scenario and the
condition (to continue the operation in open
demonstration of additionality is fulfilled specifically when the
cycle) is assessed?
current practice condition (to continue the operation in open
cycle) is assessed, the future estimated load factor should
reflect the changes due to new conditions in the grid.
b.5 Does revenue generated from the possible ACM 0007 Yes OK OK
increase in electricity produced from the
open cycle component in the project situation
is considered by the PP while undertaking
investment analysis to demonstrate
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b.7 IF yes whether following conditions are Yes PP has demonstrated that all three conditions prescribed OK OK
fulfilled by the PP in the Approved methodology are satisfied and the
i. Similar activities to the project information used to arrive at conclusion that project is not a
activity shall mean all single cycle common practice in region found transparently presented in
and combined cycle power plants the PDD.
that have an installed capacity
within a range of 50% of the The Information obtained to justify that the project is not a
project power plant and that are common practice in the given geographical area i.e, host
using one the fossil fuel types used country Indonesia is from the authentic source i.e. World
by the project power unit(s) (except Electric Power plant data base (www.platts.com)
start-up and auxiliary fuels)
ii. Relevant geographical area shall in
principle be the host country of the
proposed CDM project activity. A
region within the country could be
the relevant geographical area if the
framework conditions vary
significantly within the country.
However, the relevant geographical
area should include preferably ten or
more such power plants. If less than
ten power plants are found in the
region the geographical area may be
expanded to an area that covers, if
possible, ten such power plants
within the national grid boundary. In
cases where this definition of
geographical area is not suitable, the
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b.2 Have the equations and ACM 007 Yes Equations applied in PDD section B.6 are found correct OK OK
parameters in the PDD been correctly
applied with respect those in the select
approved methodology?
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b.5 The formulae used to determine ACM 007 Yes Baseline emissions calculated by PP found correct OK OK
baseline emissions are correctly
applied and baseline emissions
calculated are correct?
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b.8 Does Project participant uses ACM 007 Refer CAR 5 CAR 5 OK
dispatch data analysis method to Closed
calculate emission factor using Tool to
calculate emission factor for an electric
system?
b.9 If Yes then relevant modifications ACM 007 Refer CAR 5 CAR 5 OK
to the calculations are applied as Closed
recommended by the approved
methodology?
b.10 Are the leakage calculations ACM 007 Yes the description on Leakage calculation found OK OK
documented according to the approved transparently mentioned in the PDD section B.6.1 under
methodology and in a complete and leakage emissions
transparent manner?
PP has utilized prescribed equation as per the approved
methodology
LE y LE upstream, y LE HR, y
Where:
LEy - Leakage emissions in year y (tCO2e/yr)
LEupstream,y - Leakage emissions associated with the upstream
emissions of an increase in fossil fuel use in the
project activity in year y (tCO2e/yr)
LEHR,y - Leakage emissions due to a decrease in the amount
of heat recovered from exhaust heat for purposes
other than power generation in the project,
compared to the most recent year prior to the
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b.17 Will data and parameters be ACM 007 The description on the monitoring of data and parameters OK OK
monitored throughout the crediting monitored throughout the crediting period is provided in the
period of the proposed CDM project PDD Section B.7.1 and those parameters and data which will
activity? not be monitored throughout the crediting period are provided
in the PDD section B.6.2
b.18 If no, and these data and ACM 007 The description on those parameters and data which will not OK
parameters will remain fixed be monitored throughout the crediting period are provided in OK
throughout the crediting period, are all the PDD section B.6.2
data sources and assumptions:
i.Appropriate and correct? CAR 7:
ii.Applicable to the proposed CDM
PP uses tool to calculate the emission factor for an electricity
project activity? CAR 7 OK
system, however relevant data and parameters
iii.Resulting in a conservative estimate Closed
recommended by the tool are not found included in the PDD
of the emission reductions?
section B.6.2.
b.19 Will data and parameters be ACM 007 No, There are few Data and parameters used for arriving at CAR 7
monitored on implementation and project emissions, baseline emissions, leakage emissions are Closed
hence become available only after found available at the time of validation of the project activity,
validation of the project activity? These data and parameters are found partially provided in
the PDD section B.6.2
Refer CAR 7
b.20 If yes, are the estimates provided ACM 007 Refer CAR 7 CAR 7
in the PDD for these data and Closed
parameters reasonable?
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v. Sub-step 2c: Calculation and EB 39 Ann E-IRR (Equity Internal Rate of Return ) or return on Equity OK OK
comparison of financial indicators (only 10 (ROE) is selected as the financial indicator
applicable to Options II and III);
vi. Sub-step 2d: Sensitivity analysis (only EB 39 Ann Yes sensitivity analysis on capital expenditure, electricity OK OK
applicable to Options II and III). 10 tariff, amount of electricity supplied to the grid, gas costs/
price and operational expense has been performed by the PP
to check changes in the E-IRR calculated by subjecting
above identified Key Project indicators to +/- 5% to +/- 10
%variations.
l. In sub-step 2a has the determination of EB 39 Ann
appropraite method of analysis done as 10
per the guidance as below?
i. Simple cost analysis if the CDM project EB 39 Ann NA OK OK
activity and the alternatives identified in 10
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ii. When applying Option II or Option III, EB 39 Ann Yes PP has opted to carry out Benchmark analysis as OK OK
the financial/economic analysis shall 10 prescribed under option III and PP has selected E-IRR as the
be based on parameters that are financial indicator which in accordance with the EB guideline
standard in the market, considering the EB 62 Annex 5 Version 5.
specific characteristics of the project
type, but not linked to the subjective PP has considered standard market values for the
profitability expectation or risk profile of parameters to arrive at E-IRR Calculations. The justification
a particular project developer. Only in for the utilization of these values has been provided in the
the particular case where the project spread sheet, which is found transparent and correct.
activity can be implemented by the
project participant, the specific
financial/economic situation of the
company undertaking the project
activity can be considered.
iii. Discount rates and benchmarks shall EB 39 Ann PP has utilized default benchmark value 12.5 % as OK
be derived from: (a) Government bond 10 prescribed by the Appendix A of EB 62 Annex 5, version 5.
rates, increased by a suitable risk
premium to reflect private investment The project participant has chosen Default value for the
and/or the project type, as expected return on equity as per the Appendix A of EB 62
substantiated by an independent Annex 05. The default value selected by Project participant is
(financial) expert or documented by 12.5% under Group 1 for host country Indonesia. This value
official publicly available financial data; is classified under Ba2 category of Moodys Risk Rating for
(b) Estimates of the cost of financing bonds.
and required return on capital (e.g.
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ii. Present the investment analysis in a EB 39 Ann Yes. PP has presented investment analysis in transparent OK OK
transparent manner and provide all the 10 manner using Spread sheet and all assumptions are found
relevant assumptions, preferably in the correct.
CDM-PDD, or in separate annexes to
the CDM-PDD.
iii. Justify and/or cite assumptions. EB 39 Ann Yes. Justification for the assumptions used in the investment OK OK
10 analysis is found provided in the Spread sheet.
iv. In calculating the financial/economic EB 39 Ann Yes PP has provided cash flow pattern which is presented in OK OK
indicator, the projects risks can be 10 the spreadsheet in transparent manner.
included through the cash flow pattern,
subject to project-specific expectations
and assumptions.
v. Assumptions and input data for the EB 39 Ann CL 16: CL 16 OK
investment analysis shall not differ 10 Closed
During site visit Financial Additionality Spread sheet was
across the project activity and its
discussed and found that the pretax IRR mentioned in PDD
alternatives, unless differences can be
was 6.26% and the pre tax IRR in the Spread sheet was
well substantiated.
8.34%. Please justify why there a discrepancy in the IRR
value presented in the PDD for validation.
Also it was found that gas price used in the spread sheet is
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v. Has the below guideline followed for EB 39 Ann Identified the proposed project activity (alternative 1) does OK OK
Sub-step 3 b: Show that the identified 10 face an investment barrier but not for the continuation of the
barriers would not prevent the current scenario (alternative 2) which do no requires no
implementation of at least one of the investment.
alternatives (except the proposed project
activity)?
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n. Is the timing of the investment decision EB 51 Ann Refer 6.c.m. above. CAR 9 OK
consistent and appropriate with the input 58 Closed
values?
o. Are all the listed input values been EB 51 Ann Refer 6.c.m. above. CAR 9 OK
consistently applied in all calculations? 58 Closed
p. Does the investment analysis reflect the EB 51 Ann This condition is not applicable to the proposed CDM project OK OK
economic decision making context at 58 activity as proposed activity is a greenfield installation of
point of the decision to recomence the HRSG and Steam turbine for additional electricity generation.
project in the case of project activities for The implementation of the project activity did not cease.
which implementation ceases after the
commencement and where
implementation is recommenced due to
consideration of the CDM?
q. Have project participants supplied the EB 51 Ann Yes, the spreadsheet version of investment analysis has OK OK
spreadsheet versions of all investment 58 been provided. Refer 6.c.m. above.
analysis?
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Hence the validation team was of the view that the expected
return of 12.5% from the project was commensurate with the
risk involved in the Group 1 project activity under sectoral
Scope 1. Thus, the benchmark determined for the project
activity (12.5%) was found in line with EB 62, Annex 05.
bb. Has local commercial lending rates or EB 51 Ann PP has utilized default benchmark value 12.5 % as OK OK
weighted average costs of capital 58 prescribed by the Appendix A of EB 62 Annex 5, version 5.
(WACC) selected as appropriate
benchmarks for a project IRR?
cc. Has required/expected returns on equity EB 51 Ann PP has utilized default benchmark value 12.5 % as OK OK
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e. Are the parameters clearly described? VVS 133 Yes, the parameters have been described as per the OK OK
requirements of the methodology.
f. Does the means of monitoring described VVS 133 Refer 7.g, below OK OK
in the plan comply with the requirements
of the methodology?
g. Has project participant identified the Yes, the necessary monitoring parameter net electricity OK OK
monitoring parameter Net electricity supplied to the grid (export import) has been included by PP
supplied to the grid? Has it been in the monitoring plan. The cross-checking mechanism for net
ensured by the project participant that electricity supplied to the grid has also been incorporated by
hourly measurment and monthly the project participant. Hourly measurement and monthly
recording of energy will be carried out? recording of the energy has been ensured by PP in the
Has project participant identifed the monitoring plan.
cross-checking mechanism for net
electricity supplied?
h. Are the monitoring arrangements VVS 133 Yes OK OK
described in the monitoring plan feasible
within the project design?
i. Does the monitoring plan provide details EB 24 37 Accuracy and calibration standard has been defined for the 3 OK OK
regarding calibration of monitoring parameters mentioned in the section B7.2 monitoring plan
equipments/ instruments or does it
include zero check as a substitute for
calibration. As per EB guidance related
to calibration (monitoring) requirements,
zero check can not be considered as a
substitute for calibration?
j. Are the following means of VVS 133
implementation of the monitoring plan
sufficient to ensure that the emission
reductions achieved by/resulting from the
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Draft report clarifications and corrective Ref. to Summary of project owner response Validation team conclusion
action requests by validation team checklist
question
in table 1
and 2
CL 1: 3.d.iii
Carbon Trading Mechanism Division of Host
Country Indonesia calls for demonstrating The Check method has been used in the
compliance towards established sustainable LoA Application for this project, which is
development criteria by PP through a formal evidence for the compliance of this project
Method "check" used to evaluate the towards the sustainable development Verified SD 65 and found in line with
proposed CDM project, through which Project criteria required by the Indonesian DNA. the Host country DNA criteria hence
proponent should provide an explanation and SD65 is now provided to the DOE the CL is closed.
justification that the proposed project meets demonstrating this Check Method.
all indicators. Please provide sufficient
evidences on the compliance towards this
requirement and please explain how PDD is
aligned with the applicable indicators.
CL 2 3.h.ii This sentence indicates that the additional
PDD Section A.4.3 Para 3 states that In the power produced in the project scenario
Baseline scenario, the additional electricity would have been supplied by the electricity Correction in PDD verified and
produced in the project scenario is supplied grid in the baseline. found satisfactory, hence the CAR is
by the electricity grid, which is confusing. The PDD has been revised to read In the closed.
Please clarify. Baseline scenario, electricity is supplied by
the grid and additions to the grid
CL 3: 3.h.ii The predicted Plant Load Factor is 85% for Verified Revised table 3 in Section
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CAR 4 3.n.i The future load factor of the open cycle PDD Section B.4 is now amended
5.a.g.i plant in the baseline is unlikely to change with the Relevant details on the
PDD does not demonstrate how Methodology
condition pertaining to selection of baseline 6.a due to new conditions in the grid. The methodological condition When th
scenario and the demonstration of baseline plant has a valid PPA for 20 years current practice condition is
additionality is fulfilled specifically when the that specifies the operational parameters. assessed, the future estimated load
current practice condition (to continue the The baseline PLF is based on the technical factor should reflect the changes
operation in open cycle) is assessed, the capacity of the existing open-cycle plant due to new condition in the grid the
future estimated load factor should reflect the and the cost of generating the electricity by justification provided by PP was
changes due to new conditions in the grid. the baseline plant relative to other power verified against following available
plants in the grid. evidences
The project activity will increase the 1. PPA term 20 Years, which
efficiency of the power plant by converting confirms that PLF shall not
to combined cycle technology. As such, change till 20 years, which is
the relative cost of electricity generated by more than the selected
the plant will decrease. As a result, PLN crediting period of
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CAR 7: 5.e.b.18
The relevant parameters contained by the PDD Section B.6.2 is now amended
PP uses tool to calculate the emission factor with the parameters recommended
for an electricity system, however relevant Tool to calculate the emission factor for an
electricity system have been now included by the Tool in the Ex Ante
data and parameters recommended by the Monitoring plan. Corrections verified
tool are not found included in the PDD in the PDD section B.6.2.
and found Acceptable and hence
section B.6.2. CAR is closed.
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