VALIDATION OF “GOKGEDIK 24.882 MWM / 24.266 MWE … Validation Report... · MWM / 24.266 MWE...

VALIDATION REPORT: VCS Version 3

v3.2 1

VALIDATION OF “GOKGEDIK 24.882

MWM / 24.266 MWE RUNOFF RIVER

HEPP, TURKEY”

Document Prepared By

TÜV SÜD Industrie Service GmbH

Contact Information

TÜV SÜD Industry Service GmbH

Westendstrasse 199, D-80686 München

Project Title Gokgedik 24.882 MWm / 24.266 MWe Runoff River Hepp, Turkey

Version 04

Report ID 600500785

Report Title Validation of VCS Project “Gokgedik 24.882 MWm / 24.266 MWe Runoff River

Hepp, Turkey”

Client Uhud Enerji Uretim Tic. ve San. A.S.

Pages 24 (without annexes)

Date of Issue 26th July 2013

Prepared By TÜV SÜD Industrie Service GmbH

Contact TÜV SÜD Industrie Service GmbH

Westendstrasse 199, D-80686 München

telephone: +49 89 57911501

[email protected]

www.tuev-sued.de

Approved By Eric Tolcach, Deputy Head of Certification Body ”Climate and Energy”

Work Carried

Out By

Mr. Khalid Mahmood

Mr. Bhai Raja Maharjan

mailto:[email protected]


v3.2 2

Mr. Praveen Tekchandani

Mr. Nuri Mol

Summary:

’Gokgedik 24.882 MWm / 24.266 MWe Runoff River HEPP, Turkey’ Project (hereafter referred as Gokgedik HEPP) is a grid connected hydroelectric power plant which uses the water supply of Korsulu river passing through the Andirin district of the Province of Kahramanmaras. The installed capacity of the proposed project activity is 24.266 MWe or 24.882 MWm. The project activity involves installation of three sets of turbine units (10.497 MWm x 2) + (3.888 MWm X 1) = 5.846 MWm) & respective three sets of alternators ((12053x2) + 4443 kVA (Total: 28549 kVA)), with an estimated electricity supply to the grid of 58.90 GWh/ yr.

The purpose of proposed project activity is to utilize the hydro electrical resources in order to generate zero emission electricity and sell it to the Turkish National Grid via TEIAS (Türkiye Elektrik İletim A.Ş / Turkish Electricity Transmission Corporation) which is mainly dominated by fossil fuel-fired power plants.

TÜV SÜD Industrie Service GmbH was contracted by Uhud Enerji Uretim Tic. ve San. A.S. to conduct the validation of the project activity. The utilization of the available hydropower sources for power generation will help to reduce the fossil fuel consumption and support the sustainable development in Turkey. The project will also support the economic and social development in the region. The construction and routine operation of the facilities will offer employment opportunities for skilled and unskilled workers in the region. The income generation will create higher economic and social conditions.

The validation objective included an assessment of compliance with VCS Standard (version 3.3), VCS Program Guide (version 3.4) and the likelihood that the implementation of the planned GHG project will result in the quantified GHG emission reductions as stated by the project participant. This validation assessed the GHG emission reductions of a hydropower project against the CDM methodology ACM0002 ver 13.0.0 in Sectoral Scope 1 (Energy – renewable/non-renewable). The scope of the validation included the GHG project and baseline scenarios; physical infrastructure, technologies and processes of the GHG project; GHG sources, sinks and/or reservoirs; types of GHG’s; and time periods covered. The validation criteria followed the guidance documents provided by VCS and included the following: VCS Program Guide (v3.4) and VCS Standard (v3.3). A summary of all findings is included in Annex 1, the information references is attached in Annex 2. There are no restrictions of uncertainty.

TÜV SÜD confirms all validation activities including objectives, scope and criteria, level of assurance and the VCS PD adherence to the VCS Standard (v3.3, 4 October 2012) as documented in this report are complete and conclude that the project description (PD) of Gokgedik HEPP meets the requirements of VCS Standard (v3.3, 4 October 2012).


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Table of Contents

CONTENTS 1 Introduction ............................................................................................................................................ 5

1.1 Objective ....................................................................................................................................... 5

1.2 Scope and Criteria ........................................................................................................................ 5

1.3 Level of assurance ........................................................................................................................ 5

1.4 Summary Description of the Project ............................................................................................. 5

2 Validation Process ................................................................................................................................ 6

2.1 Method and Criteria ....................................................................................................................... 6

2.2 Document Review ......................................................................................................................... 6

2.3 Interviews ...................................................................................................................................... 6

2.4 Site Inspections ............................................................................................................................. 7

2.5 Resolution of Any Material Discrepancy ....................................................................................... 7

3 Validation Findings ................................................................................................................................ 7

3.1 Project Design ............................................................................................................................... 7

3.2 Application of Methodology ......................................................................................................... 10

3.2.1 Title and Reference ............................................................................................................. 10

3.2.2 Applicability ......................................................................................................................... 10

3.2.3 Project Boundary ................................................................................................................. 14

3.2.4 Baseline Scenario ............................................................................................................... 15

3.2.5 Additionality ......................................................................................................................... 15

3.2.6 Quantification of GHG Emission Reductions and Removals .............................................. 21

3.2.7 Methodology Deviations ...................................................................................................... 22

3.2.8 Monitoring Plan ................................................................................................................... 22

3.3 Environmental Impact ................................................................................................................. 22


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3.4 Comments by stakeholders ......................................................................................................... 22

4 Validation conclusion ........................................................................................................................... 24

Annex 1: Validation Protocol (List of findings)

Annex 2: Information Reference List


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1 INTRODUCTION

1.1 Objective

The objective of the validation is an assessment of compliance with VCS Standard (version 3.3),

VCS Program Guide (version 3.4) and the likelihood that the implementation of the planned GHG

project will result in the quantified GHG emission reductions as stated by the project proponent.

This validation assessed the GHG emission reductions of a hydropower project against the CDM

methodology ACM 0002 version 13.0.0, Sectoral Scope 1 (Energy – renewable/non-renewable).

1.2 Scope and Criteria

The scope of the validation included the GHG project and baseline scenarios; physical infrastructure, activities, technologies and processes of the GHG project; GHG sources, sinks and/or reservoirs; types of GHG’s; and time periods covered. The geographic validation scope was defined by the project boundary, which included the public electricity system of Turkey. The scope of the Gokgedik HEPP in Turkey was outlined by the project proponent prior to the validation initiation as follows:

Subject Application

Baseline scenario Power supply from the public grid.

Project activity Hydroelectric power plant operation and electricity supply to the grid.

GHG sources/sink Hydro Power

GHG type Carbon dioxide

Duration Renewable crediting period for 21 yrs

Project activity Public electricity system in Turkey.

1.3 Level of assurance

TÜV SÜD assessed the project (general principles, data, monitoring descriptions, documentation, calculations, etc.) to provide reasonable assurance to meet the Project Level requirements of the VCS Program. The evidence used to achieve a reasonable level of assurance is specified in the following sections of this report.

1.4 Summary Description of the Project

Gokgedik HEPP is a grid connected hydroelectric power plant which uses the water supply of Korsulu river passing through the Andirin district of the Province of Kahramanmaras. The installed capacity of the proposed project activity is 24.266 MWe or 24.882 MWm (IRL #32, 20). The project activity involves installation of three sets of turbine units (10.497 MWm x 2) + (3.888 MWm X 1) = 3.888 MWm) & respective three sets of alternators ((12053x2) + 4443 kVA (Total: 28549 kVA)), with an estimated electricity supply to the grid of 58.90 GWh/ yr (IRL #10, 32, 20).

The purpose of proposed project activity is to utilize the hydro electrical resources in order to generate zero emission electricity and sell it to the Turkish National Grid via TEIAS (Türkiye Elektrik İletim A.Ş / Turkish Electricity Transmission Corporation) which is mainly dominated by fossil fuel-fired power plants. The utilisation of the available hydropower sources for power


v3.2 6

generation will help to reduce the fossil fuel consumption and support the sustainable development in Turkey. The project will also support the economic and social development in the region. The construction and routine operation of the facilities will offer employment opportunities for skilled and unskilled workers in the region. The income generation will create higher economic and social conditions.

2 VALIDATION PROCESS

2.1 Method and Criteria

The validation criteria followed the guidance documents provided by VCS and included the following: VCS Program Guide (4

th Oct 2012), VCS Standard (4

th October 2012, v3.3), Program

Definitions (4th Oct 2012, v3.4) and CDM methodology ACM0002 ver 13.0.0: “Consolidated

baseline methodology for grid-connected electricity generation from renewable sources” and its linked tools. The validation process applied standard auditing techniques outlined in the documents above and procedures indicated within TÜV SÜD’s Quality Management System Manual.

2.2 Document Review

A detailed review of all project documentation was proceeded to ensure consistency with, and identify any deviation from VCS program requirements (VCS v3.3), and the CDM methodology (ACM0002 ver 13.0.0). Initial review focused on the VCS-PD and included an assessment of the project details, design data and parameters, and quantification of GHG emission reductions and removals. The following final reference documents have been reviewed during this validation:

Project Description VCS-PD (IRL #02)

Feasibility Study Report (IRL#10)

Water usage right agreement (IRL #26)

Investment decision (IRL #24)

Further reviewed reference documents have been listed in the Information Reference List in

Annex 2.

2.3 Interviews

Interviews were conducted with representatives of the project proponent Uhud Enerji Uretim Tic. ve San. A.S.. Interviews included on-site discussions with the carbon manager, design engineer and site manager. The information in the VCS-PD has been cross checked against the reference sources such as the feasibility study reports (IRL #10, 32), the power generation license (IRL #5, 34), EIA report (IRL #31) to assess also if the project on-site is implemented in accordance with the validated PD. The list of the interviewed people is as follows:

Enes Kutlarer, Engineer onsite

Memis Elmas, Technology provider

Ahmet Akdmir, PP

Bugra Ulugurt, consultant


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2.4 Site Inspections

Following the interviews and discussions of the desk review, an on-site visit has been conducted to assess also if the project is implemented in accordance with the specifications in the VCS-PD on 15

th to 16

th Nov 2011.

2.5 Resolution of Any Material Discrepancy

During the course of the validation, various material discrepancies were identified and documented in Annex 1 of the validation protocol. After three loops, the discrepancies were successfully addressed by the project proponent and the issues were closed.

3 VALIDATION FINDINGS

3.1 Project Design

Project scope, type, technologies and measures implemented, and eligibility of

the project

The project activity belongs to scope 1 which is renewable energy and project activity also lies in

type 1. The scope of the proposed project activity is the electricity generation with hydro power

and the supply to the project electricity system. The use of the renewable energy source will help

to displace fossil fuel consumption.

The installed capacity of the proposed project activity is 24.266 MWe or 24.882 MWm (IRL #10,

32). The project activity involves installation of three sets of turbine units (10.497 MWm x 2) +

(3.888 MWm X 1) = 3.888 MWm) & respective three sets of alternators ((12053x2) + 4443 kVA

(Total: 28549 kVA)), with an estimated electricity supply to the grid of 58.90 GWh/ yr. (IRL #10,

32).

The power plant has been hydroelectric power plant which uses the water supply of Korsulu River

at Gokgedik Village of Andirin District. The validated designed flow rate of project activity is 19

m3/s (IRL #10, 32).

Project proponent

Uhud Enerji Uretim Tic. ve San. A.S is the project proponent.

Project start date

Start date of the project has been validated to be 16-03-2012 (date of commercial operation of

the project activity).

Project crediting period

Three times renewable crediting period of 10 years

Project scale and estimated GHG emission reductions or removals

The scale of the project has been validated as:

Project X

Mega-project

The estimated GHG reductions of the project in the first crediting period are summarised in the

table below:

Years Estimated GHG emission


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reductions or removals (tCO2e)

2012 16.03.2012 – 15.03.2013 31,688

2013 16.03.2013 – 15.03.2014 31,688

2014 16.03.2014 – 15.03.2015 31,688

2015 16.03.2015 – 15.03.2016 31,688

2016 16.03.2016 – 15.03.2017 31,688

2017 16.03.2017 – 15.03.2018 31,688

2018 16.03.2018 – 15.03.2019 31,688

2019 16.03.2019 – 15.03.2020 31,688

2020 16.03.2020 – 15.03.2021 31,688

2021 16.03.2021 – 15.03.2022 31,688

Total estimated ERs 316,880

Total number of crediting years 10

Average annual ERs 31,688

Project activities

The project details have been validated from the Feasibility study report (IRL #10, 32) & the

signed agreement with technology provider, with Andritz Hydro S.A.S., Andritz Hyrdo Ltd. Şti. and

Moteurs Leroy-Somer (IRL #20). The Project Activity is a new hydro power plant and the main

construction involves the following major components:

Gokgedik Weir and Water Intake Structure

Type Solid body

Thalweg Level 660.00 m

Base Level 653.80 m

Height from Thalweg 6.00 m

Height from Base 12.20 m

Cycled Water 169.82 hm3

Water intake base level 662.20 m

Water intake design flow rate 19.00 m3/s

Weir crest elevation 666.00 m

Maximum water level 669.79 m

Penstock

Penstock diameter 2600 mm

Penstock wall thickness Between 10 – 20 mm

Penstock height 620.70 m

Design flow rate 19.00 m3/s

Manifolds 3

Power Plant

Type Aboveground

Dimensions 20.10 x 52.50 m

Height 26.10 m

Installed Capacity 24.882 MW

Tailwater level 514.00 m


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Turbine

Turbine 2+1

Type Horizontal Axis Francis Turbine

Normal Power (2x10.497) + 3.888 MW (Total: 24.882 MW)

Design flow rate (2x8.00) + 3.00 m3/s (Total:

19.00 m3/s)

Gross head 152.00 m

Design net head 141.62 m

Syncronization speed (2x600) + 1000 rpm

Efficiency 0.943

Generator

Quantity 2+1

Type Horizontal axis synchronous generator

Operation type Continuous

Normal power (12053x2) + 4443 kVA (Total: 28549 kVA)

Power factor 0.85 (inductive)

Frequency 50 Hz

Rotation speed (2x600) + 1000 rpm

Actuator type Directly coupled with francis turbine shaft

Exciting type Rotating type without brushes

Short circuit ratio Higher than 1

Isolation class F

Project location

The coordinates of the project location has been validated as indicated in the table below:

Regulator Turbines

Latitude (N) Longitude (E) Latitude (N) Longitude (E)

1 37° 35' 42.936" 36° 30' 12.042" 1 37° 37' 30.188" 36° 34' 19.911"

2 37° 35' 43.120" 36° 30' 18.693" 2 37° 37' 32.833" 36° 34' 19.834"

3 37° 35' 47.705" 36° 30' 23.686" 3 37° 37' 32.839" 36° 34' 23.733"

4 37° 35' 50.168" 36° 30' 16.517" 4 37° 37' 30.266" 36° 34' 23.831"

Project compliance with applicable laws, statutes and other regulatory

frameworks

The project has been implemented in accordance with the current legislation. The most important

of the related regulations are listed below:

1. Renewable Energy Law (IRL #19)

2. Directive on Environmental Impact Assessment (EIA) (IRL#17)

3. Energy Market Law (IRL #18)

4. Law on Land Acquisition and Expropriation (IRL #14, 15)

Right of use

Uhud Enerji Uretim Tic. ve San. A.S has been validated to have the electricity generation license

approved by Electricity Market Regulatory Committee (EPDK) for Gokgedik HEPP for 49 years as


v3.2 10

of 25-06-2009 (IRL #05, 34). Hence it has been validated that Uhud Enerji Uretim Tic. ve San. A.S

has the right to install the hydropower plant and is a project proponent for the project activity.

Emission trading programs and other binding limits

The declaration letter from project participant confirms that the project activity is not part of any

emissions trading programs and other binding limits (IRL #23).

Participation under other GHG programs

The declaration letter from project participant confirms that the project activity is not part of any

emissions trading programs and other binding limits (IRL #23).

Other forms of environmental credit sought or received

The declaration letter from project participant confirms that the project activity will not claim other

forms of environmental credit sought or received (IRL #23)

Rejection by other GHG programs

The declaration letter from project participant confirms that the project activity did not apply any

other GHG programmes and not rejected by other GHG programmes (IRL#23).

Eligibility criteria for grouped projects

The project does not belong to a grouped project, hence it is not applicable.

Leakage management for AFOLU projects

It is a non-AFOLU project.

Commercially sensitive information

All commercially sensitive information has been treated confidential and is excluded from public

access:

- Feasibility Study Report (IRL#10)

- Investment Analysis calculation excel workbook (IRL#29)

3.2 Application of Methodology

3.2.1 Title and Reference

The approved baseline and monitoring methodology has been determined in accordance with the approved CDM methodology ACM0002 ver 13.0.0: “Consolidated baseline methodology for grid-connected electricity generation from renewable sources” has been used to determine the baseline emissions and the emission reductions of the project activity. The methodology refers to the “Tool to calculate the emission factor for an electricity system” for determining the emission factor of the project electricity system. This tool is applied to determine the weighted average combined margin emissions factor of the baseline scenario.

3.2.2 Applicability

Applicability criteria

from ACM0002 ver

Details mentioned in VCS PD Validation opinion Validation

conclusion


v3.2 11

13.0.0

This methodology is applicable to grid-connected renewable power generation project activities that (a) install a new power plant at a site where no renewable power plant was operated prior to the implementation of the

project activity

(greenfield plant); (b)

involve a capacity

addition; (c) involve a

retrofit of (an) existing

plant(s); or (d) involve

a replacement of (an)

existing plant(s).

The methodology is

applicable under the

following conditions:

• The project activity is

the installation,

capacity addition,

retrofit or replacement

of a power plant/unit of

one of the following

types: hydro power

plant/unit (either with a

run-of-river reservoir or

an accumulation

reservoir), wind power

plant/unit, geothermal

power plant/unit, solar

power plant/unit, wave

power plant/unit or

tidal power plant/unit;

Gokgedik HEPP Project is the

installation of a grid connected

renewable power generation

project which adds electricity

capacity to the grid from hydro

power sources and which

supplies electricity to a system

that is supplied by at least one

fossil fuel fired generating unit.

The project involves

construction of new units in a

brand new plant, in other words

the project does neither involve

the addition of renewable

energy generation units at an

existing renewable power

generation facility nor does it

foresee to retrofit or modify an

expired facility of renewable

energy generation. The project

is a renewable electricity

generation plant, in the form of a

runoff river type hydropower

plant. It is located at a site

where no renewable power plant

was operated prior to the

implementation of the project

activity (greenfield plant). All

related files which justify the

situation of being a grid

connected greenfield plant are

provided as supplementary

documents (Check 25-

EIA_Report/Gokgedik.CED.2.jpg

for the coordinates of the facility

and 25-

EIA_Report/Gokgedik.CED.1.jpg

for EIA approval from Provincial

Department of Environment and

Forestry). EIA Approval Letter

was given by the authorized

body on 18.02.2010 and the

construction was started on

07.2010 (See 27-

It has been

validated during

the onsite visit that

a hydro power

plant has been

under

construction.

Furthermore, it

has also been

validated from the

following

documents:

1. electricity

generation license

approved by

Electricity Market

Regulatory

Committee

(EPDK) (IRL #05,

34)

2. Feasibility study

report, IRL #10,

32

It has been

successfully

validated that

the project

activity

complies with

this

applicability

criterion.


v3.2 12

Construction_Agreement). In the

host country (Turkey), projects

are obligated to get EIA

approval letter before the

implementation of a project to a

greenfield.

In the case of capacity

additions, retrofits or

replacements (except

for wind, solar, wave or

tidal power capacity

addition projects which

use Option 2: on page

11 to calculate the

parameter EGPJ,y):

the existing plant

started commercial

operation prior to the

start of a minimum

historical reference

period of five years,

used for the calculation

of baseline emissions

and defined in the

baseline emission

section, and no

capacity expansion or

retrofit of the plant has

been undertaken

between the start of

this minimum historical

reference period and

the implementation of

the project activity; In

the case of capacity

additions, retrofits or

replacements (except

for capacity addition

projects for which the

electricity generation of

the existing power

plant(s) or unit(s) is not

affected): the existing

plant started

commercial operation

The project activity does not

include any capacity addition,

retrofit or replacement.

Therefore above statement is

not considered within the scope

applicability.

It has been

validated that the

project activity is a

Greenfield hydro

power plant which

shall export

electricity to

regional grid.

Furthermore,

following

documents have

been validated for

the same:

1. electricity

generation license

approved by

Electricity Market

Regulatory

Committee

(EPDK) (IRL #05,

34)


report, IRL #10,

32

It has been

successfully

validated that

the project

activity

complies with

this

applicability

criterion.


v3.2 13

prior to the start of a

minimum historical

reference period of five

years, used for the

calculation of baseline

emissions and defined

in the baseline

emission section, and

no capacity addition or

retrofit of the plant has

been undertaken

between the start of

this minimum historical

reference period and

the implementation of

the project activity;

In case of hydro power

plants:

One of the following conditions must apply: o The project activity is

implemented in an existing single or multiple reservoirs, with no change in the volume of any of reservoirs; or

o The project activity is implemented in an existing single or multiple reservoirs, where the volume of any of reservoirs is increased and the power density of each reservoir, as per the definitions given in the Project Emissions section, is greater than 4 W/m

2;

or o The project activity

results in new single or

multiple reservoirs and

the power density of

each reservoir, as per

the definitions given in

the Project Emissions

The project activity is not

implemented in an existing

reservoir, where the volume of

reservoir is increased and the

power density of the project

activity is identified as far greater

than 4 W/m2 by considering that

Gokgedik project is a run-of river

type HEPP and does not include

water storage as clearly stated in

“Revised Feasibility Study

Report” (pdf page 171) and EIA

report.

From page 1 (.pdf page 10) of

the approved EIA Report (See

25-EIA_Report file) which was

provided as a supplementary

document, the following

paragraph (last paragraph) can

be taken as a reference within

the scope of small reservoir

capacity:

“In the scope of Gokgedik Weir

and HEPP Project, water

storage is out consideration

because the project is a runoff

river type project and energy

producing water shall be

It has been

validated from the

EIA report and

onsite visit that the

proposed project

is a Greenfield run

of the river Hydro

power plant

without any

reservoir, IRL #25,

31, 10, 32.

Furthermore, it

has also been

validated from the

electricity

generation licence

that the project

activity is a run of

a river hydro

power plant

without any

reservoirs (IRL

#05, 34).

It has been

successfully

validated that

the project

activity

complies with

this

applicability

criterion.


v3.2 14

section, is greater than

4 W/m2

regulated by the weir. Therefore

operational policy for the

reservoir, optimization studies,

dam type and height choice is

not provided.”

The methodology is not applicable to the following: o Project activities

that involve switching from fossil fuels to renewable energy sources at the site of the project activity, since in this case the baseline may be the continued use of fossil fuels at the site.

o Biomass fired power plants.

o A hydro power plant that results in the creation of a new single reservoir or in the increase in an existing single reservoir or in the increase in an existing single reservoir where the power density of the power plant is less than 4 W/m2.

o

The project does not involve

switching from fossil fuels to

renewable energy at the site of

the project activity.

The project is not a biomass

fired power plant.

See the 3rd

applicability

consideration above.

It has been

validated that the

project activity is a

Greenfield hydro

power plant which

shall export

electricity to

regional grid.

Hence it is

validated that it is

not a fossil fuel

switch or biomass

fired power plants.

Furthermore,

following

documents have

been validated for

the same:

1. electricity

generation license

approved by

Electricity Market

Regulatory

Committee

(EPDK) (IRL #05,

34)


report, IRL #10,

32

It has been

successfully

validated that

the project

activity

complies with

this

applicability

criterion.

3.2.3 Project Boundary

As per applied methodology, the project boundary has been validated to include the following:

1. The proposed hydro plant, which is the physical, geographical site of the renewable generation source.

2. Electricity system and power plants physically connected to the grid.


v3.2 15

3.2.4 Baseline Scenario

As per applied methodology, baseline scenario is ‘Electricity delivered to the grid by the project

activity would have otherwise been generated by the operation of grid-connected power plants

and by the addition of new generation sources, as reflected in the combined margin (CM)

calculations described in the “Tool to calculate the emission factor for an electricity system”. The

same has been confirmed based on on-site observations and interviews with PP (IRL 3).

3.2.5 Additionality

The additionality of the project activity has been assessed using ‘Tool for the demonstration and

assessment of additionality’.

Investment Analysis

Investment analysis has been done to demonstrate the additionality. The financial returns of the

proposed project are insufficient to justify the investment. A benchmark analysis has been used to

demonstrate the investment barrier for the project activity. The project participants selected the

project IRR as the financial indicator and compared it against the calculated benchmark.

The parameters used in the financial calculations (for calculating IRR) have been validated based

on a review of the sources presented in the PD, inter alia

Parameter Validated

value

Validated data source IRL

Investment

decision date 08/06/2010

It has been validated from the board resolution of the PP

that investment decision date for the project activity &

voluntary carbon credit is 8th June 2010.

Furthermore, it has been validated that the first contract for

the project activity (construction contract) was signed on 25th

June 2010. Hence June 2010 has been validated as an

appropriate investment decision date for the project activity.

24, 37

Installed

capacity

The project

activity

involves

installation of

three sets of

turbine units

((2x10.497) +

3.888 MW

(Total:

24.882 MW))

& respective

three sets of

alternators

((12053x2) +

Capacity of the project activity has been validated from the

following documents:

Primary source available:

a. Feasibility study report (FSR).

Cross-check source:

a. Electricity generation license.

b. it has also been cross-checked with the technical contract

signed with the supplier, Andritz Hydro S.A.S., Andritz

Hyrdo Ltd. Şti. and Moteurs Leroy-Somer

10, 05,

34, 20


v3.2 16

4443 kVA

(Total: 28549

kVA) with a

power factor

of 0.85,

hence an

installed

capacity of

24.266 MWe)

Annual

assumed net

electricity

supply

58.90 GWh

Net generation of electricity has been validated from

Primary source available at the time of investment decision:

FSR June 2009.

Cross-check source: It has also been cross-checked with

Electricity Generation License.

10, 05, 34

Electricity

sales tariff

73 $/MWh of

feed-in tariff

as per RES

law;

however, 85

$/MWh has

been

considered

as a

conservative

price (which

could be

available

from spot

market).

73 $/MWh has been validated from the Renewable Energy

law; however, 85 $/MWh has been considered as a

conservative price (which could be available for project

activity from spot market).

Spot market price has been validated to vary a lot;;

therefore, sensivity analysis has also been validated for the

IRR fluctuation considering a long range of 70 to 100 $/MWh

of spot market price.

Hence, 85 $/MWh has been validated as a conservative

figure for investment analysis.

19

US $/TL

Parity 1.5936

It has been validated from publically available source,

http://evds.tcmb.gov.tr/

Available at the time of investment decision – 8th June 2010.

Weblink

mentioned

http://evds.tcmb.gov.tr/


v3.2 17

Total

investment

43,653

kUSD

Total investment for the project activity has been validated

from the FSR developed from a third party and approved by

Turkish Government.

Detailed breakdown has been validated as below :

Breakdown of investment cost as per FSR

USD

Construction house 314

Roads 220

Regulator 4,584

Tunnels 19,156

Sedimentation pool 3,369

Power house building 2,873

Penstock 1,690

Turbine and generator 2,934

Supporting equipment 1,707

Other equipment 694

Transmission line + trafo 455

Auxilary for construction (15%) 4,830

Ehud, consultancy, project costs 741

Expropriation 87

Total investment cost 43,653

The investment costs have been cross checked against the

turbines purchasing contract (IRL 20) and construction

contract of the project activity (IRL 37).

Furthermore, based on its local and sectoral expertise and

financial knowledge of this sector, TÜV SÜD can confirm

that the investment costs of this project activity are

appropriate for this project.

10, 20,

32, 37

Annual O&M

costs 376 kUSD

Annual O&M for the project activity has been validated from

FSR.

Total annual O&M cost is validated to be less than 1% of the

investment cost. Based on its local and sectoral expertise

and knowledge in this sector, TÜV SÜD confirms that he

annual O&M costs considered for this project activity are

appropriate and realistic for the project activity.

10, 32

Transmission

expenses 123.4 kUSD

The location of the project activity is validated to be in

K.Maras or region 102, the costs has been validated for

generation use and transmission costs from EPDK, decision

Weblink

mentioned


v3.2 18

2913, 09/12/2010, http://www.epdk.gov.tr/web/elektrik-

piyasasi-dairesi/iletim-tarifesi1

The validated cost is 8097 TL/MW, which has been

converted to kUSD using installed capacity and currency

conversion rate validated above.

As per ‘Guidelines on the assessment of investment analysis’, the input values used in the

investment analysis have been found to be valid and appropriate for the project activity. .

Furthermore, it has been validated that residual value for the project activity is considered as zero

(after 20 yrs of installation), IRL #48.

Investment analysis has been carried out by PPs using all the key assumptions mentioned above.

The pre-tax project IRR of the project activity during investment decision is validated to be 7.26%

(IRL #29).

Benchmark:

As per para 12 of EB 62 annex 05, “In cases where a benchmark approach is used the applied

benchmark shall be appropriate to the type of IRR calculated. Local commercial lending rates or

weighted average costs of capital (WACC) are appropriate benchmarks for a project IRR” –

hence prime lending rate has been validated as an appropriate benchmark for the proposed

project activity.

Lending rate at the time of investment decision, 8th June 2010 has been validated as 12.30%

from State Planning Organisation, which publishes “Main Economic Indicators” on a monthly

basis (IRL #49). Lending rate for medium term investment has been validated as the benchmark.

Hence it has been validated that project IRR is less than the validated benchmark. Furthermore,

sensitivity analysis has been carried out for 10% variation in following key parameters: investment

cost, Energy yield, electricity price & O&M cost. The variation of +/- 20 % of these parameters still

does still not result in IRR crossing the benchmark (IRL #29). Please find below the details on the

validated sensitivity analysis:

Electricity price: Project IRR was calculated by subjecting electricity price to variation (considering

70 to 100 $/MWh of tariff rate), it was validated that the best case scenario in this variation has an

IRR of 9.71% when electricity export is increased to 100 $/MWh (which is more than 20%

variation).

Change in investment cost: Project IRR was calculated by subjecting investment cost to variation,

it was validated that the best case scenario in this variation has an IRR of 10.34% when

investment cost is reduced by 20%.

Energy Yield: Project IRR was calculated by subjecting energy yield to variation. At the time of

investment decision, the estimated electricity generation was validated as 58.9 GWh/year;

however feasibility study was revised again after the investment decision and estimated

generation was revised to 60.26 GWh/ year. It was validated that the best case scenario in this

variation has an IRR of 10.02% when yield is increased by 20% (increase of 20% in yield results

http://www.epdk.gov.tr/web/elektrik-piyasasi-dairesi/iletim-tarifesi1

http://www.epdk.gov.tr/web/elektrik-piyasasi-dairesi/iletim-tarifesi1


v3.2 19

in estimated generation of 71 GWh/yr, which is much higher than estimated generation of 60.26

GWH/yr in the revised FSR).

Change in O&M cost: Project IRR was calculated by subjecting O&M cost to variation, it was

validated that the best case scenario in this variation has an IRR of 7.55% when O&M cost is

reduced by 20%.

All in all the sensitivity analysis indicates that the benchmark 12.30% is not crossed by variation

of the above mentioned parameters; thereby indicating that the economic un-attractiveness is

robust to reasonable variations in the critical assumptions.

Common practice analysis:

Common practice analysis for the project activity has been validated using “Guidelines on

Common Practice”, EB 69 annex 08. Please find below the validation of each step mentioned in

the guideline:

Steps mentioned in “Guidelines on

Common Practice”, EB 69 annex 08

Validation opinion Validation conclusion

Step 1: calculate applicable capacity or

output range as +/-50% of the total

design capacity or output of the

proposed project activity.

The validated range of +/- 50%

is 12.4-37.3 MW.

Installed capacity for the project

activity has been validated from

the following documents:

1. electricity generation license

approved by Electricity Market

Regulatory Committee (EPDK)

(IRL #05, 34)

2. Feasibility study report, IRL

#10, 32

3. Contract signed with supplier,

IRL #20

It has been successfully

validated that PP has

appropriately followed the

step mentioned in the

“Guidelines on Common

Practice”,

Step 2: identify similar projects (both

CDM and non-CDM) which fulfil all of

the following conditions:

(a) The projects are located in the

applicable geographical area;

(b) The projects apply the same

measure as the proposed project

Geographical area for the

consideration of common

practice analysis has been

validated as the following

provinces: Kahramanmaras-

Malatya-Adana-Osmaniye.

This has been validated to be

derived from 26 basins divided






Practice”,


v3.2 20

activity;

(c) The projects use the same energy

source/fuel and feedstock as the

proposed project activity, if a

technology switch measure is

implemented by the proposed project

activity;

(d) The plants in which the projects are

implemented produce goods or services

with comparable quality, properties and

applications areas (e.g. clinker) as the

proposed project plant;

(e) The capacity or output of the

projects is within the applicable capacity

or output range calculated in Step 1;

(f) The projects started commercial

operat ion before the project design

document (CDM-PDD) is published for

global stakeholder consultation or

before the start date of proposed project

activity, whichever is earlier for the

proposed project activity.

by State Hydraulic Works (DSI)

based on regional conditions.

The proposed project activity

falls within Ceyhan (20) basin –

this area include the provinces

mentioned above.

8 hydro power plants have been

validated as an outcome of this

step.

Step 3: within the projects identified in

Step 2, identify those that are neither

registered CDM project activities,

project activities submitted for

registration, nor project activities

undergoing validation. Note their

number, Nall.

.

It has been validated that 7 out

of those 8 hydro power plants

identified above are under the

pipeline to consider revenues

from carbon offsets.

Hence, Nall has been validated

as 1.






Practice”,

Step 4: within similar projects identified

in Step 3, identify those that apply

technologies that are different to the

technology applied in the proposed

project activity. Note their number Ndiff.

It has been validated that out of

2 projects identified in step-3

above, one of them has different

technology; hence Ndiff is

validated as 1







v3.2 21

Practice”,

Step 5: calculate factor F=1-Ndiff/Nall

representing the share of similar

projects (penetration rate of the

measure/technology) using a

measure/technology similar to the

measure/technology used in the

proposed project activity that deliver the

same output or capacity as the

proposed project activity

Factor F has been validated as 0

using the formula provided by

the guideline.






Practice”,

The proposed project activity is a

“common practice” within a sector in the

applicable geographical area if the

factor F is greater than 0.2 and Nall-

Ndiff is greater than 3.

It has been validated that factor

F is less than 0.2 and Nall-Ndiff

is less than 3.

Hence it has been

validated that the project

activity is not a common

practice in the region.

Based on the analysis done above, the project activity has been validated as additional.

3.2.6 Quantification of GHG Emission Reductions and Removals

The calculation of the baseline emissions have been conducted using procedures described in

the methodology AMC0002 ver13.0.0.

As per applied methodology, the baseline emissions are the product of electrical energy baseline

EGfacility,y expressed in MWh of electricity produced by the hydropower plant multiplied by the grid

emission factor (IRL #04). The estimated annual amount of net electricity generation for the

proposed project activity is 58,900 MWh (IRL #10, 34).

Calculation of emission factor of the grid has been validated to be done in accordance with “Tool

to calculate the emission factor for an electricity system” version 2.2.1. Please find below the

details on the validated information & approach:

The operating margin emission factor (EFOM) was determined based on the simple OM method as

the validated low-cost/must run resources in Turkey less than 50%. It was further validated that

ex-ante option was chosen for this calculation. The validated value for operating margin emission

factor is 0.6534 tCO2/MWh (IRL#30).

For Build margin emission factor (EFBM), PPs have opted for option-1 (calculation of build margin

ex-ante using most recent information for each crediting period). Calculation of EFBM for first

crediting period has been validated. As per “Tool to calculate the emission factor for an electricity

system”, sample group of power units m has been identified and it was validated that sample

group supplying 20% of electricity to grid is higher than last five power units which started


v3.2 22

exporting power. Hence using this sample group EFBM has been calculated and it is validated to

be 0.4226 tCO2/MWh (IRL#30).

The value for the combined margin emission factor (EFCM) was determined using the weighted

average of the EFBM and EFOM using the default values for the factors as described in the applied

“ Tool to calculate the emission factor for an electricity system” (i.e. 0.5 for hydro plants). Hence,

the validated combined margin emission (EFCM) for first crediting period is 0.5380 tCO2/MWh

(IRL#30).

As per applied methodology, ACM0002 ver 13.0.0, following could be potential emission source

for hydropower plants

Project emission from water reservoir of hydropower plants in year y (tCO2/yr), PEHP,y: However it

has been validated that it is a run of river hydro plant without any reservoir.

No uncertainties associated with the emission reductions calculation procedure have been

identified.

3.2.7 Methodology Deviations

There is no methodological deviation found in the project activity.

3.2.8 Monitoring Plan

The monitoring plan presented in the PD complies with the requirements of the applicable

methodology. The assessment team has verified all parameters in the monitoring plan against the

requirements of the methodology and no deviations have been found.

The procedures have been reviewed by the assessment team through document review and

interviews with the relevant personnel. The information provided and a physical inspection has

allowed the assessment team to confirm that the proposed monitoring plan is feasible within the

project design. The relevant points of monitoring plan have been discussed with the PPs.

Specifically; these points include the location of meters, data management, and the quality

assurance and quality control procedures to be implemented in the context of the project.

Following are the key parameters which would be monitored as per the applied methodology:

EGfacility,y, Quantity of net electricity supplied to the grid by the project in year “y”: This parameter

shall be continuously measured by an energy meter and recorded monthly. The recorded data

will be cross-checked with the records of electricity sold (using invoices).

Therefore, the PPs will be able to implement the monitoring plan and the achieved emission

reductions can be reported ex-post and verified.

3.3 Environmental Impact

The project has been assessed related to the environmental impacts. The Gokgedik HEPP has

been validated to have a clearance from the ministry that the EIA report is positive (IRL #25, 31).

EIA report prepared by TEKSTILA MUHENDISLIK has been validated successfully to assess the

impact of the project on the environment as per local host country regulation (IRL #17).


v3.2 23

3.4 Comments by stakeholders

TÜV SÜD published the project documents on the netinform website and invited comments by

affected parties, stakeholders and non-governmental organizations during a 30 day period.

All key information gathered is presented in table below:

website:

Error! Hyperlink reference not

valid.http://www.netinform.de/KE/Wegweiser/Guide2.aspx?ID=7314&Ebene1_ID=49&Ebene2_ID=2457&mode=4

Starting date of the global stakeholder consultation process:

20/09/2011

Comment submitted

by:

None

Issues raised:

-

Response by TÜV SÜD:

-

http://www.netinform.de/KE/Wegweiser/Guide2.aspx?ID=7314&Ebene1_ID=49&Ebene2_ID=2457&mode=4


v3.2 24

4 VALIDATION CONCLUSION

TÜV SÜD has performed the validation of the following proposed VCS project activity:

“Gokgedik 24.882 MWm / 24.266 MWe Runoff River Hepp, Turkey”

Standard auditing techniques have been used for the validation of the project. Methodology specific protocol of the project has been prepared to carry out the audit in order to present the outcome in a transparent and comprehensive manner.

The review of the project design documentation, subsequent follow-up interviews and further verification of references have provided TÜV SÜD with sufficient evidence to determine the fulfilment of stated criteria in the protocol. In our opinion, the project meets all requirements of VCS standard (version 3.3, 4

th Oct 2012). Therefore, TÜV SÜD will recommend the project for

registration by the VCS Association.

An analysis as provided by the applied methodology demonstrates that the proposed project activity is not a likely baseline scenario. Emission reductions attributable to the project are additional to any that would occur in the absence of the project activity. Given the project is implemented as designed; the project is likely to achieve the estimated amount of emission reductions as specified in the final VCS-PD. The validation has been performed following the requirements of VCS Standard (Version 3.3), VCS Program Guide (version 3.4), the CDM methodology ACM0002 ver 13.0.0 and its tools.

Based on the work described in this report, nothing has come to our attention that causes us to believe that any project component or issue has not been covered by the validation process

Annex 1: Final VCS-Validation Protocol Project Title: Gokgedik 24.882 MWm / 24.266 MWe Runoff River Hepp, Turkey

Date of Completion: 26th July 2013 Number of Pages: 26

Table 1 is applicable to ACM0002, version 13.0.0 with ex-ante determination of CM Page A-1

Table 2 Resolution of Corrective Action and Clarification Requests

Clarifications and corrective action requests by validation team

Ref. to table 1

Summary of project owner response Validation team conclusion

Correct Action request :1

PP shall update the title of the project to indicate the correct capacity of the hydro power plant which is validated as 24.88 MW.

1.1.1 Corrected accordingly.

Related evidence sheets regarding the licence revi-sions are presented as separate sheets. (See 1- Li-cence_and_Revised_Licence)

PD has been revised to have an ap-propriate project title. Hence it is ac-ceptable and this issue is closed




Clarification Request 1.

PP shall provide us the revised license by EMRA for the validated capacity of 24.88 MW.

2. Project plan and evidence in English.

3. Power purchase agreement with the grid.

4. Connection & usage agreement with grid.

5. Single line diagram.

6. Water usage agreement.

1.1.4 1. Revised licences are presented as separate sheets (See 1- Licence_and_Revised_Licence)

2. Project plan is presented as a separate file. (See 18- Project_Implementation_Plan / Time_Plan_Final.jpg)

3. Power purchase agreements could be signed be-tween the energy producing company and EMRA (the regulator) after taking the power plant into operation. However, most hydro producers prefer to sell to the spot market where a higher price can be obtained than the feed in tariff of 73 $/MWh in the RES law. Since the facility is still in the construction stage, such an agree-ment is not yet undertaken.

4. Connection agreement is presented as a separate file. (See 30- Connection_ Agreement) System usage agreement is not signed for now, since the agreement can’t be signed before temporary commissioning of en-ergy transmission line. However within 1 month, trans-mission line shall be completed and agreement will be signed. After then, document will be submitted to TUV-SUD.

5. Single line diagram is presented as a separate file. (See 16- Single_Line_Diagram)

6. Water usage agreement is presented as a separate file. (See 31- Water_Usage_Agreement)

2nd protocol:

1. Special provisions parts of licences are translated into English and submitted in the file “1- Li-cense_and_Revised_License\English_Versions”

4. Most important page of the agreement is the 12th page. Therefore it is translated into English and sub-mitted as a supplementary document in the file “Gokgedik.Documents\30- Connec-tion_Agreement\Connection_Agreement_pdfpage12_English.doc.x”

6. Water usage agreement must be considered as a whole document, this is why it can not be translated partially. PP shall consult with your local auditor re-

1. PP shall provide us the English translated licenses.

2. Project plan has been submitted and validated.

3. Using the local expert knowledge it was confirmed that PPA can only be signed after commissioning of the plant. However, plant license has been validated and grid connection agree-ment is also validated.

4. Connection agreement is validated with Turkiye Elektric Iletim Anonim Sirketi, however PP shall submit the English summary.

5. Single line diagram has been vali-dated and its implementation shall be verified during verification.

6. PP shall provide us the English translation of the document.

Second response:

1. Translated license has been submit-ted & validated.

4. Translated connection agreement has been submitted and validated.

Hence it is acceptable and this issue is closed.





PP shallPP shall provide us the documentary evi-dence to validate the capacity projection indicated in section 1.8 of the PD by TEIAS.

1.1.4 Since this question relates to table 4, footnote (no 12) provides a reference to the capacity projection by TEIAS, which can be downloaded from their website in english.

2nd Review:

Web link for Turkish Version: http://www.teias.gov.tr/projeksiyon/KAPASITE%20PROJEKSIYONU%202010.pdf

Web link for English Version: http://www.teias.gov.tr/eng/ApkProjection/CAPACITY%20PROJECTION%202009-2018.pdf

Web links for the TEIAS’ capacity projection reports are presented above. Besides, related .pdf documents are also attached as supplementary documents. Within the report latest available “capacity projection report” was used which is 2010-2019 version. However 2010-2019 version does not have an English version yet. Therefore a previous translated version (2009-2018) is also attached as a reference file.

See: “33- TEIAS_Capacity_Projection_Reports”

PP shall provide us the weblink and al-so the pdf print out of the discussed evidences.

Second response:

Documentary evidence for capacity projection has beeb submitted and val-idated.

Hence it is accepted and this issue is closed.


PP shallPP shall update the details in PD with re-spect to revised license from EMRA (including the generation, installed capacity & corresponding emission reduction).

1.1.4 All mentioned points are corrected according to the new capacity and corresponding emission reduction.

Revised generation license has been submitted and the generation figures (intended installation capacity, elec-tricity generation, number of turbine & generators). Hence it is acceptable and this issue is closed.

http://www.teias.gov.tr/projeksiyon/KAPASITE%20PROJEKSIYONU%202010.pdf

http://www.teias.gov.tr/projeksiyon/KAPASITE%20PROJEKSIYONU%202010.pdf

http://www.teias.gov.tr/eng/ApkProjection/CAPACITY%20PROJECTION%202009-2018.pdf

http://www.teias.gov.tr/eng/ApkProjection/CAPACITY%20PROJECTION%202009-2018.pdf





PP shallPP shall update the PD to include the ex-act start date in the format of dd/mm/yy. Also pro-vide us the documentary evidence to justify the start date considered for the project activity. PP shall keep it consistent with other sections of the PD.

1.5 Starting date of the project activity is considered as the construction agreement date between the contractor and Uhud Energy which is 25.06.2010. This date is consistent at every section of the document.

2nd review:

Starting date of the project activity is updated through-out the document as the date on which project starts GHG reduction (15.03.2012)

3rd review:

16th of March is the exact date on which the power plant has started GHG reduction. Documentary proof is the temporary commissioning record of Energy Market Regulatory Authority (EMRA) which is submitted in the file -> “36- Temporary_Comissioning /”. English trans-lation can also be found within the same file.

PP shall update the start date of the project activity based on description given by VCS standard version 3.0 (date on which project starts GHG re-duction).

Second response:

PP shall provide us the documentary evidence for considering 15th March 2012 as the start date of the project activity.

Conclusion:

16th March 2012 has been successful-ly validated as the start date of the pro-ject activity.






PP shallPP shall provide us the project implemen-tation plan in english to verify the indicated project operation date of 1st July 2013. Further, it was in-dicated by the PP during the onsite visit that in-stallation would be complete by end of 2012, therefore PP shall clarify why PD indicates 1st Ju-ly 2013 as the start of crediting period.

1.6 Start of crediting period is 1st of January 2012 as seen onsite. Contractor company for civil construction did their job well enough to stick to the plan.

Within the old PDD, year 2013 is indicated as the start-ing date of the crediting period because it was written by following another plan (old schedule) completed by the company itself.

Related old and new implementation plans are provid-ed as supplementary documents (See 18- Pro-ject_Implementation_Plan).

2nd protocol:

All construction including the generator, electrome-chanical units, turbines and their installation are com-pleted however a delay (30 to 40 days) has been caused because of the penstock. Therefore, currently the company has just applied to General Directorate of State Hydraulic Works (DSI) and Ministry of Energy and Natural Resources for temporary commissioning. Related documents are attached as supplementary files (See 34- Applica-tion_Letters_for_Temporary_Comissioning)

By considering this delay ER calculations and crediting period start date is shifted to 15th of March 2012, just to stay on the safe side.

PP shall clarify whether the plant has commissioned electricity supply to grid. If yes, PP shall provide us documen-tary evidence for the commissioning of the plant.

Second response:

The crediting period has been revised to a more realistic figure. Hence it is accepted and this issue is closed.





PP shall update section 1.8 of the PD to indicate on which stream or river this proposed project ac-tivity shall be built. Further, PP shall update the PD to indicate on the details on the civil construc-tion involved in the project activity.

1.8 Corrected accordingly.

Response:

Because of the delay in the submission of this re-sponse originated from unexpected planning reasons, shifting the crediting period became mandatory. There-fore the crediting period of the facility has been shifted to 15th of April 2012. All related parts of the document is updated accordingly with track-changes tool.

2nd protocol:

Details about the civil construction is indicated in the requested section of the document.

Response:

Source of the civil construction details are mentioned in the report as requested under the related informative table.

(Ref: Revised Feasibility Study Report (See “24- Fea-sibility_Study_Report_Revised” file in supplementary documents))

3rd protocol:

Civil structures are clearly indicated in the “24- Feasi-bility_Study_Report_Revised” between .pdf pages 171-180. The text between these pages is also trans-lated and attached into the same file.

Details of the river stream is validated in the revised PD. PP shall update the PD to indicate the requested civil con-struction details in section 1.8.

Second response:

PD has been updated to indicate the details on civil structure, further PP shall indicate the source of these de-tails as well.

Third response:

PP needs to indicate the page number and provide translated text for details on civil structure.

Conclusion

Civil structure details have been vali-dated and the same has been validat-ed to be included in the PD.



PP shall update the PD to indicate the intended capacity of alternators used for the project activity.

1.8 Both mechanical and electrical power of the facility is mentioned in the document.

PD is updated to indicate the mechani-cal and electrical installed capacity. Further, it was checked from the gen-eration license and signed contract from supplier. Hence it is acceptable and this issue is closed.





PP shall provide us the following documents re-lated to the project activity: - PP shall provide the equipment purchase con-

tract and technical specification of the turbine-generator units.

- PP shall provide the technology transfer in-formation in VCS-PD (Country of origin for supplied technology).

- PP shall provide the training certificates man-ual and training of staff.

- Contract on Service & Maintenance Works with the technology Supplier

1.8 1. Equipment purchase contract is presented in sup-plementary documents (See 5- Electromechani-cal_Agreements / Andritz Hydro Ön Sözleşme.pdf). Technical specifications of Turbines and generatorsare written in the Annex 1 of file named as “Andritz Hy-dro_Gokgedik HES_Consortioum Agreement_Section 3 of Contract_Rev 0.pdf”

2. Technology transfer information is considered in the document. (See Section 1.8.1.)

3. High voltage training certificates of staff is presented in supplementary documents. (See 7- High_Voltage_Certificates)

4. Contracts related to the service and maintenance works are submitted in a folder named as “5-Electromechanical Agreements” together with other agreements signed with Andritz.

2nd protocol:

There isn’t any separate file or document as service and maintenance agreement. According to the agree-ment; after commissioning, there exists 2 years of guarantee. Before this period ends, the company is go-ing to sign a service agreement with Andritz.

1. Signed contract with ANDRITZ Hy-dro has been submitted and validated.

2. It has been clarified that technology is imported from France.

3. High voltage training cert for em-ployee working there has been submit-ted and validated.

4. service and maintenance contract is not submitted. PP shall indicate the exact file name.

Second response:

Service & maintenance contract has been validated to be available for be-ginning two years. Hence it is accepta-ble and this issue is closed.


PP shall provide documentary evidence to vali-date the operational life time of 50 yrs indicated in the PD.

1.8 An approximation was made by telling 50 years. The economic life of an HEPP in Turkey is assumed as 48 years, 2 months and 15 days by regulations (As indi-cated on the “Generation Licence” (See 1- Li-cense_and_Revised_License) This issue is also cor-rected within the document.

Generation license has been validated to have the operational life time as in-dicated in the revised PD. Hence it is acceptable and this issue is closed.





PP shall provide us the following documents dis-cussed in the GSP PD:

1. English translation of Board of directors deci-sion.

2. Electromechanical agreement with Andritz Hy-dro.

3. Expropriation license for the forest land.

1.10 1. It is translated and submitted inside the folder to-gether with the original one (See 2- Board_of_Directors_Decision)

2. Electromechanical agreement with Andritz Hydro is presented in the folder named as “5- Electromechani-cal_Agreements”

3. All the documents related to expropriation are sub-mitted in the file named as “6- Expropria-tion_Decisions_and_Permits_for_Forest_Areas”

1. Translated board of director decision has been submitted and validated.

2. Electromechanical agreement with Andritz Hydro has been submitted and validated to check the installation ca-pacity and other details mentioned in the PD.

3. Expropriation decision and permit for forest area has been submitted and validated.



PP shall update the PD to indicate all the steps in the chronology table indicated in section 1.10 in-cluding the first issuance of license, FSR, registra-tion of company, etc.

1.10 All steps are indicated in the chronology table.

Revised PD has been validated and updated to have the chronology, and supporting documents have been submitted and validated. Hence it is accepted and this issue is closed.





PP shall update the PD to indicate which of the indicated regulation requires approval, permit or license. If yes, PP shall provide us the respective documents.

1,11 English version of related regulations are presented in a folder named as “4- Regulation”.

According to the rules indicated in the 4628 numbered Electricity Market Law, permission is granted to a legal entity by the board of EMRA (Electricity Market Regu-latory Authority) in order to enable it to engage in mar-ket activities.

Above statement is inserted into the PD file.

2nd review:

The permission means the licence (The generation li-cence is the permit which is granted by EMRA.). The document is submitted as a supplementary document (see 1- Li-cense_and_Revised_License\English_Versions) The English summary is also provided after the second pro-tocol.

Applicable regulations have been submitted and validated. However PP shall provide us the permit from EMRA discussed in the response (also pro-vide us the English summary).

Second response:

EMRA license has been submitted & validated, the details are validated to be in line with the details mentioned in PD.



PP shall provide us the generation license for the revised capacity of 24,88 MW validated during the onsite visit.

1.11 Revised license is presented as separate sheet (See 1- Licence_and_Revised_Licence)

Revised license has been submitted and validated. Other details in PD have also been cross-checked with this re-vised. Hence it is accepted and this is-sue is closed.





PP shall provide the written confirmation or decla-ration that

The project is not registered under any oth-er GHG-Programs,

The project has not been rejected by other GHG programs,

The project will not get other forms of envi-ronmental credits

3.4.1 Written confirmation is given by the participant compa-ny. (See 32- Decleration)

Declaration letter has been submitted by the PP. Hence it is acceptable and this issue is closed.


PP shall clarify whether the project activity has any fossil fuel consumption onsite.

1.13 Clarified as requested.

2nd protocol:

The project will not have any fossil fuel consumption onsite. Related clarification has already inserted within the document (See section 1.13)

“As an additional information related to the project activity, it must be clarified whether the project activity has any fossil fuel consumption onsite. The facility will use its self-produced electricity during the operational stage, but in emergency situations, electricity will be taken from TEIAS by paying its price (which will be cut from the generation income). The use of a diesel generator is the last resort to be used in these kind of situations and carbon emissions from the diesel generator is taken as 0 (zero) in the ER calculations by considering un-planned and momentary usage during opera-tional stage.”

PP shall write an appropriate response to the requested clarification request.

Second response:

It is clarified that project activity plans not to have any fossil fuel consumption onsite. further, it shall be checked dur-ing periodic verifications.






PP shall update the PD to consider the latest ver-sion of applied “Tool for the demonstration and assessment of additionality” & “Tool to calculate the emission factor for an electricity system”.

2.4.1 Within the document latest tools that were available during PD preparation were used as requested.

2nd protocol:

There are minor updates in the “Tool to calculate the emission factor for an electricity system” which does not effect any calculation for the facility. However tool version is updated throughout the PD as requested.

PP shall use the latest version of “Tool to calculate the emission factor for an electricity system” available during val-idation (which is version 2.2.1).

Second response:

PD has been updated to use the latest version of the applicable tool to calcu-late emission factor. Hence it is ac-ceptable and this issue is closed.





PP shall update the VCS-PD to include the com-pliance for each applicability criteria mentioned in the applied methodology (compliance justification is presented; however PP shall keep it transparent that the justification given in PD could be related to corresponding applicability criteria for example using a table for demonstration).

2.2.1 A table is inserted into the related part of the document in which every applicability criteria is considered. Clari-fied as requested.

2nd protocol

Applicability criterias were copied from the methodolo-gy and related discussions were made below the ap-propriate criteria.

From page 1 (.pdf page 10) of the approved EIA Re-port (See 25-EIA_Report file) which was provided as a supplementary document, the following paragraph (last paragraph) can be taken as a reference within the scope of small reservoir capacity:

“In the scope of Gokgedik Weir and HEPP Project, wa-ter storage is out consideration because the project is a runoff river type project and energy producing water shall be regulated by the weir. Therefore operational policy for the reservoir, optimization studies, dam type and height choice is not provided.”

Therefore storage volume data is not available howev-er for a run-off type facility 30000 m3 of storage vol-ume was estimated with a depth fo 2 meters in order to provide an idea about the situation and the volume.

Response:

Estimations are deleted from the document.

Statements having appropriate evidences are inserted into the document. It is clearly indicated within the PD file that Gokgedik project is a run-of river type project and does not have a reservoir as stated in the same way in approved EIA document and revised feasibility study report.

PP shall copy the exact applicability criteria and discuss all the criteria and provide justification in PD if it is not applicable for the project activity.

Further PP shall provide documentary evidence for the following:

1. Storage volume used for calculating power density.

Second response:

PD has been updated to include all the applicability criteria along with appro-priate justification. However, PP shall provide the documentary evidence for assuming 30000 m3 & 2 meters height given in the response.

Third response:

Revised PD has been validated to have no storage of water (no reser-voir), further it has been validated from the EIA report and FSR.






It is mentioned in the GSP PD that the project ac-tivity has a small reservoir, PP shall provide doc-umentary evidence to verify the power density of the reservoir.

2.2.4 This issue has been discussed with the investor and further information as to the (small) size of the storage reservoir has been optained and this has been updat-ed in the PDD accordingly

PD has been revised to indicate the details on small reservoir used for the project activity.


As per applied methodology, PP shall update the project boundary to include all the power plants connected physically to the electricity system that the VCS project power plant is connected to.

2.3.7 As requested during on site meeting. Figure 2 is cor-rected by including another box that clarifies where all the other plants are connected to. Clarified according-ly.

Revised PD has been validated to have an appropriate boundary as per applied methodology.

Correct Action request :11 PP shall update seciton 2.5 of the VCS-PD to include the timeline of the project activity and kindly demonstrate the early consideration of VCS in the timeline.

2.5.2 The timeline of the project activity is inserted in section 1.10 by following CAR:6. A single sentence is inserted in this section in order to mention the location of the table that can be assessed within the scope of additionality.

Revised PD has been validated to have details on the chronology of the events and consideration of carbon revenue has also been validated from the supporting documents.






PP shall provide us justification with documentary evidences to validate as to how the proposed project is first of its kind. Further,also provide us the following justification: 1. Evidencs to validate the data mentioned in table 8 & 9 of the PD.

2. PP shall provide details on the 87 projects which are operating in Turkey.

2.5.11 We have added further details on the 87 HEPP which were completed more than 50% according to the Jan-uary 2011 EMRA progress report, as published bian-nually by EMRA (in “BaselineCO2.xls”)

Note that the 87 projects referred to are still under construction, where the rate of construction completion is more than 50% as of January 2011.

2nd protocol:

Progress report of the facilities are reflected in EPDK’s web site (www2.epdk.org.tr/lisans/elektrik/proje/yenilenebilir.xls). The recent situation of the facilities can be found by following the link mentioned above. However the file is periodically updated by EPDK, therefore some values may deviate from the previous version.

On the other hand the file is also provided as a sup-plementary document after the second protocol (See 26- ER_Calculations/yenilenebilir.xls )

Revised PD has been validated to re-move the statement of first of its kind. Further PP shall provide us the source of progress report shown in “BaselineCO2.xls” (eg weblink or letter, etc).

Second response:

The provided weblink has been vali-dated and the information has been checked. Hence it was found that this project is not first of its kind and com-mon practice has been validated as per applied tool for additionality.


It was validated during the onsite visit that there is another run of river hydropower plant in the same region of more than 25 MW, so PP shall clarify how do PP claim that it is first of its kind.

2.5.11 It is not “first of its kind”, this has been corrected in the new PDD, by excluding this statement

Revised PD has been validated and it does not claim to be first of its kind an-ymore.



PP shall explain why project IRR is applied and why not equity IRR.

2.5.19 Project IRR is applied as it is more transparent in the calculations and the result is the same: the project needs carbon credits due to its low profitability.

It is justified and validated to be appro-priate to use project IRR. Hence it is acceptable and this issue is closed.





PP shall provide us justification & evidence for se-lecting 15% benchmark for the project activity. Further, also clarify why did PD says that it should be preferably 20%. Also update the PD to indicate the source of benchmark used in the project ac-tivity.

2.5.20 See http://www.ere.com.tr/pdf/HIDRO-POT-TR.pdf a benchmark of 12.09% is given for river runoff hydro.

2nd protocol:

Discussion regarding the benchmark values (15% and 20%) is removed from the document since it was writ-ten based on common sense and market experience with investors.

On the other hand on page 25 of the document HIDRO-POT-TR there exists a table named as “Typical Hydroelectricity Plant (Dam and Runoff) and Natural Gas Plant’s General and Economical Comparison. If you refer to the last row you can clearly see the inter-nal rate of return (IRR) as 12.09. For further details we kindly request from you to consult with the local audi-tor.

Response:

The response is correct. Justification is needed. Relat-ed correction is made in section “SUB-STEP 2b: Op-tion III: Benchmark analysis” accordingly.

3rd protocol:

Excel file already has English translated text included inside however translated text is not easy to capture by eye. Therefore Eng. texts are highlighted after your re-sponse. Pls see “28-IRR/Benchmark_Ver02.xls”

PP shall provide us the english transla-tion of the provided document. PD still discuss about 15% & 20%, so PP shall provide documentary evidence for this figure presented in PD also.

Second response:

12.09% has been validated from the document in the weblink. However, it was observed that this value comes from published document on 2001. PP shall justify how this figure is still valid at the time of investment decision.

Third response:

Benchmark has been changed to lend-ing rate, however PP needs to provide the translated xl file submitted for benchmark..

Conclusion:

Benchmark as lending rate has been validated successfully from an authen-ticated publically available source.


http://www.ere.com.tr/pdf/HIDRO-POT-TR.pdf





PP shall provide the documentary evidences for all the input values used in the calculation of pro-ject IRR including but not limited to: 1. Investment cost (capital investment) 2. Operation & management cost. 3. Transmission cost of 8097 TL/MW considered in the analysis. 4. Electricity generation 5. Tariff rate or selling price of the electricity ex-ported to grid 6. Loss & theft rate of 4% used. 7. Depreciation rate considered in the investment analysis. 7. Source for conversion rate from $ to TL used in calculation.

2.5.23 All the values in the investment analysis have been referenced with their sources

See excel on project IRR also added to PDD

2nd protocol:

1. In the non-updated feasibility (since it was consid-ered on-site that investment items must be taken from the non-updated feasibility) pdf page 176. Page is also translated into English and submitted within the loca-tion “Gokgedik.Documents\23- Feasibil-ity_Study_Report\page176_English.docx)

2. In the non-updated feasibility pdf page 188.

3. Web Link: www.epdk.gov.tr/documents/10157/c673c7b7-0a33-4a54-8577-2f6ce985ad0c

All related files can be fetched from the web link pro-vided above or from “28- IRR\2913_iletisim” which is located in the supplementary files.

5. PP shall find “28- IRR/tariff.xlsx”. Related explana-tion is presented within that file.

6. The related file is “Kayıp-Kaçak TEDAŞ-İl Bazında.xls” and excel cell J24 is the exact place of reference.

1. PP shall indicate the relevant page number where information on invest-ment cost can be validated from the feasibility report (also provide english summary of relevant page).

2. Same as above for operation cost.

3. PP shall provide us the document from the relevant weblink.

4. Electricity generation has been vali-dated from generation license & FSR. Hence it is accepted.

5. PP shall indicate the document from which electricity tariff is taken? Also provide us the same.

6. Many files are present in the weblink given in xl files, PP shall indicate from which file loss and theft rate is consid-ered.

7. Conversion rate has been validated and is acceptable.

Second response:

1. Capital investment has been vali-dated from provided FSR. Hence this point is acceptable.

2. Operation cost has also been vali-dated from provided FSR. Hence this point is acceptable

http://www.epdk.gov.tr/documents/10157/c673c7b7-0a33-4a54-8577-2f6ce985ad0c

http://www.epdk.gov.tr/documents/10157/c673c7b7-0a33-4a54-8577-2f6ce985ad0c




3rd protocol:

3. Weblinks are explained step by step below. Some links

are being changed time to time and this causes our provided links to become vacant. PP shall follow the explanation be-low:

a. Enter to the domain using your browser -> www.epdk.org.tr

b. Hover over menu button on the top side and then click on the button ->”Tarifeler” which means in English tariffs.

c. On the appeared page PP shall click on the hyperlink -> “İletim Tarifesi” which means Transmission Tariff in English.

d. Opened page indicates Transmission Tariffs which is ap-plied by TEIAS in the Electricity Market date by date. Invest-ment decision of project was considered as 08.06.2010. By considering this date PP shall open the document which is listed on 09.12.2010 which is appropriate for the time during the investment.

e. A .rar file will be downloaded on your computer. PP shall first open the file named as “2913_EK1.xls” file. The file in-cludes tariff zones for different regions. If you scroll down the document you can see “Kahramanmaraş” region has the number “102”

f. Now PP shall open the document named as “2913.doc” in this file PP shall which is decided and signed down on 09.12.2010. This file has a table which represents production and consumption tariffs for various regions. We can find the number 102 there and sum up the 2nd and 3rd columns in order to find transmission tariff for the Kahramanmaraş re-gion which is “8097 TL/MW” (7682.67 + 414.48). This .rar file is also attached to the updated document into the file named as “28- IRR\2913_iletisim”

5. You may find the calculation of 85$/MWh by following the filepath “28- IRR/Tariff.xlsx”. Cells of excel sheet are open for examination. File is resubmitted again after your response. PP shall refer to the comments written in that file.

3. It could not validated from the pro-vided weblink, further PP shall justify how this information was available at the time of investment decision.

5. Tariff rate has also been validated using the website of TEIAS. It was val-idated that minimum guranteed tariff rate by government is 73 $/MWh, however PP has taken 85 $/MWh con-servatively based on market rate de-termined from TEIAS website.

6. Theft rate has been validated for the provided documents. Hence this point is closed

Conclusion:

All input values have been validated from respective sources.






PP shall clarify & justify the distribution of the capital investment shown in the IRR sheet. Also provide us the feasibility study report discussed in the GSP PD.

2.5.23 The investment analysis has been redone. The in-vestment cost are distributed according to the first fea-sibility study.

Revised distribution of the capital in-vestment has been validated and is found appropriate. Hence it is ac-ceptable and this issue is closed.


PP shall clarify how the generated electricity of 58.9 GWh is in line with the latest guideline on calculation of plant load factor.

2.5.23 Both generation and capacity are mentioned in the li-cense implying a PLF of 27%.

2nd Protocol:

PP shall check the revised feasibility pdf page number 142 for related monthly based generation values which were calculated according to “flow observation sta-tions” data. 60,200 GWh of generation was reported.

Generation license has been validated and cross-checked. PP shall cross-check the generation based on the availability of water.

Second response:

It was validated using the revised fea-sibility report that generation has been cross-checked based on the availabil-ity of water.



PP shall clarify the investment decision date con-sidered for the project activity. Also update the PD to indicate the same transparently.

2.5.23 Investment decision date is the date on which con-struction agreement with the contractor company was signed (08.06.2010). The situation is clarified by insert-ing a schedule table in section 2.5.

Investment decision date has been ex-plained and validated. Hence it us ac-ceptable and this issue is closed.





It was validated during the onsite visit that the in-tended capacity of the project activity is revised and the corresponding cost associated with the project. PP shall clarify whether the values taken in investment analysis are conservative when compared to values for the revised capacity.

2.5.23 Old investment estimates are still being used in the IRR calculations, these are conservative estimates leading to 1754 $/kW, which can be considered as via-ble.

2nd protocol:

It is a good and a correct point. We have inserted the old capacity to the IRR sheet after considering the clar-ification. Updated accordingly.

3rd protocol:

CR-15 is corrected accordingly. PP shall refer to the comments given in CR-15 above.

IRR sheet has been submitted and it was validated that 24.882 MW has been used in IRR computation. PP shall clarify whether this updated in-formation of revising the capacity to 24.882 MW was present during the in-vestment decision. PP shall note that all the input values used in the IRR sheet should be available during the investment decision.

Second response:

PP shall refer to CR-15 above.

Conclusion:

CR-15 has been closed successfully.





As indicated in the FSR, the capacity factor (or load factor) of the power plant is close to 27%, PP shall clarify the reason why did PP decide to im-plement such a high capacity power plant, con-sidering the fact that load factor is low.

2.5.23 The project developer expects a higher market price. But even under the high price scenario the IRR is ra-ther low (see sensitivity analysis with 100 $/MWh).

2nd protocol:

Capacity factor is low. However related 10-20 year forecasts ofTurkey’s growth factor and energy demand were being identified and the energy prices were ex-pected to become higher within this period (See the English version of TEIAS Capacity Projection Report, 2009 dated report but reflects similar projections with the 2010 dated one1). On the other hand it was known by the participant company from the beginning that plant’s return period is going to be long but the invest-ment costs were not being expected to become higher as it is now. Costs became higher because of revet-ment necessity originated from loose soil through the water conveyance tunnel (8.2 km). It can be said that the company was mislead because of unsufficient drill-ing. If necessary studies are not being completed dur-ing planning stage, it becomes harder for a company to turnback from any mistakes. However it was consid-ered that the generation profits will be higher. In some situations data taken from State Hydraulic Works (DSI) do not reflect the whole picture.

PP shall provide us an appropriate re-sponse with justification for the raised clarification request.

Second response:

Load factor of 27% has been calculat-ed from the gross generation men-tioned in the license & FSR.



It was validated during the onsite visit that project would start generating power from 2012 (not 2013 as mentioned in IRR sheet). Therefore PP shall include the revenue from sale of electricity for 2012 & full 2013 as well.

2.5.23 IRR and income from ER is updated accordingly.

Revised IRR sheet has been validated to have revenue generation from 2012. Hence it is acceptable and this issue is closed.

1 Gokgedik.Documents\33- TEIAS_Capacity_Projection_Reports





PP shall provide the complete list of the hydro-power project in Turkey in table formation and clearly describe that why other existing hydro-power project are different from the proposed pro-ject activity in term of technology, scale, invest-ment climate, access to technology, access to fi-nancing.

2,5,28 Common practice analysis section is now more exten-sive to deal with this issue

2nd protocol:

The section is revised according to the provision of the additionality tool mentioned below;

“Projects are taken to be similar if they are in the same country/region and/or rely on a broadly similar technol-ogy, are of a similar scale, and take place in a compa-rable environment with respect to regulatory frame-work, investment climate, access to technology, ac-cess to financing, etc.”

Response:

Selected facilities can be cross-checked from Energy Market Regulatory Authority’s (EMRA) web page. PP shall see http://www2.epdk.org.tr/lisans/elektrik/lisansdatabase/verilentesistipi.asp

Also a seperate excel sheet with references is built accordingly. PP shall also see

\Gokgedik.Documents\35- Common_Practice_Analysis

for the licences of all energy producing facilities in Tur-key. Their energy generation data can also be checked from TEIAS Capacity Projection Reports (See 33- TEIAS_Capacity_Projection_Reports) and related webs page of EMRA.

Weblink: www2.epdk.org.tr/lisans/elektrik/proje/yenilenebilir.xls

3rd protocol:

All projects within the boundaries of region Kahra-manmaraş is considered. Only projects in Kahraman-maraş region is considered because different regions have different factors effecting the project’s develop-ment and planned financial properties. On the other hand in the PD file Turkey is also considered and compared with the proposed project activity. Pls see the new submitted files and considerations in ->

Revised justification of common prac-tice still doesn’t justify why other hy-dropower project are different from the proposed project.

Second response:

PD has been revised to give details on similar plants. However, PP shall justi-fy the region (Kahramanmaraş) con-sidered for common practice as per applied tool to demonstrate additionality.

Third response:

PP needs to provide appropriate justi-fication for the following:

1. For considering range of similar pro-jects as 20 to 40 MW.

2. For considering projects only in Kahramanmaras region.

3. PP needs to provide the list of oper-ational project in the identified region.

Conclusion:

Revised PD has been validated to have appropriate steps as per guide-line for common practice analysis. It has been validated that factor F is less than 0.2 and Nall-Ndiff is less than 3.

http://www2.epdk.org.tr/lisans/elektrik/lisansdatabase/verilentesistipi.asp

http://www2.epdk.org.tr/lisans/elektrik/lisansdatabase/verilentesistipi.asp





PP shall update the PD to calculate baseline emission from the applicable formula from the methodology, which equation 6 & 7.

3.1.1 The formulas are changed.

Revised PD has been validated to have the correct formula for emission reduction calculation. Hence it is ac-ceptable and this issue is closed.


PP shall provide the revised emission factor cal-culation sheet considering the latest available tool to calculate emission factor for the electricity sys-tem, which is version 2.2.1.

3.1.2 Updated as requested

Revised sheet for emission factor cal-culation has been submitted and vali-dated. Relevant sources have also been validated.






PP shall clarify whether the project activity has any onsite fossil fuel consumption, any diesel genset for emergency power generation

3.2.2 The facility will use its self-produced electricity during the operational stage, but in emergeny situations, elec-tricity will be taken from TEIAS by paying it price (Will be cut from the generation income). Diesel generator is the last system that shall be used in these kind of situ-ations and carbon emissions from that diesel generator is taken as 0 (zero) in ER calculations by considering unplanned and momentary usage during operational stage.

The situation is clarified in “Section 1.13” and in sec-tion “3.2. Project Emissions”. A monitoring parameter regarding the emission from diesel generator is insert-ed into the monitoring table.

2nd protocol:

It is not correct to update the PDD with a monitoring parameter which does not exist in the applied method-ology or in the tools. Therefore it is uncorrect to include such parameter to the PD. Every hydroelectric power plant must have its own secondary (it is generally the third, see the clarification above) energy supply unit and if we look into similar projects, we shall see that no such monitoring parameter is included in their project files by considering the momentary usage. Emissions from the secondary unit becomes a meaningless value when compared to the carbon offset of the facility.

Section 4.2 of the PD is still not updat-ed to have the discussed monitoring parameter.

Second response:

As indicated in the response, it is clari-fied that PP don’t intend to use fossil fuel during operation, further it shall be checked during verification.



As per applied tool to calculate emission factor, PP shall consider the correct weighing factors for combined margin, as per tool it should be 0.5, whereas the PD indicates it as 0.75 & 0.25 for OM & BM respectively.

3.2.5 Changed as requested

Revised sheet for emission factor cal-culation has been submitted and vali-dated. Relevant sources have also been validated.





Correct Action request :17 PP shall update section 4.1 of the VCS-PD to in-dicate the combined margin, build margin & oper-ating margin for the region.

3.4.1.12 Updated with more extensive information

2nd protocol:

Related updates are made in section 3.4.2.

Section 4.1 of the PD is still not updat-ed to include combined margin & build margin which is available during vali-dation.

Second response:

Revised PD has been updated to in-clude details on combined margin. Hence it is acceptable and this issue is closed.


PP shall indicate the value used in the calculation of emission factor (currently it indicates “error! Reference source not found”).

3.4.1.15 See above

2nd protocol:

Related updates are made in section 3.4.2.

Section 4.1 of the PD is still not updat-ed to include combined margin & build margin which is available during vali-dation.

Second response:

Revised PD has been updated to in-clude details on combined margin & build margin in section 3.4.2. Hence it is acceptable and this issue is closed.





PP shall indicate the calibration frequency for the monitoring parameter of EGfacility,y .

4.2.1.2 Information about the calibration of metering devices is inserted in section “4.2 Data and Parameters Moni-tored / Monitoring equipment”

2nd protocol:

The translation is given below:

b) It is an obligation to complete the inspections of electric, water and gas meters once in 10 years.

Periodic inspections of meters and metering devices which are mentioned in (a) and (b) articles of the sub-section 1, are being done by Ministry Metering and Calibration Organisation, following the application of related entities to the authority.

Periodic inspections of these meters and metering de-vices are calculated by starting with the year of ap-proval.

PP shall provide us the english transla-tion of the relevant text from the regu-lation.

Second response:

It is clarified that main meter is main-tained by TEIAS, it shall be sealed & calibrated by TEIAS itself. The fre-quency of calibration has been validat-ed from the provided regulation.



PP shall update section 4.3 of the VCS-PD to in-dicate transparently on the following points:

1. Identify organizational structure, responsibilities and competencies.

2. Describe procedures for handling internal audit-ing and non-conformities.

4.3.1.1 Section 4.3 is updated accordingly.

Section 4.3 of the PD has been updat-ed to include organizational structure, responsibilities & quality control. Hence it is acceptable and this issue is closed.


PP shall provide the diagram of location of in-stalled electricity meters.

4.3.3 The diagram is provided as a supplementary document located in “…\Gokgedik.Regulator.and.HEPP.ver.1.00\Gokgedik.Weir.and.HEPP.ver02\Gokgedik.Documents\21- Maps”

Coordinates of the metering devices were also includ-ed.within the .jpg document.

Location has been submitted and vali-dated. It shall be verified during verifi-cation. Hence it is acceptable and this issue is closed.





PP shall clarify whether stakeholder consultation meeting is required by the host country rules & regulation. If yes, PP shall provide us the relevant requirements.

6.3 Detailed explanation is presented in section “6.Stakeholder Comments”

It has been clarified in the revised PD that regulation requires local stake-holder for capacity more than 25 MW. In any case, stakeholder meeting has been validated as per VCS require-ment. Invitation letter, filled question-naire & meeting photograph have been submitted and verified.


PP shall provide us the documentary evidence like attendance list, minutes of meeting, etc to val-idate the stakeholder meeting conducted for the project activity.

6.3 Related evidence sheets are provided as supplemen-tary documents. (See 29- Local Public Meeting)

Requested documents on the attend-ance sheet has been provided and val-idated. Hence it is acceptable and this issue is closed.


The applied version of methodology ACM0002 version 12.3.0 in VCS-PD has been expired.

3.1.2 VCS-PD has been revised with applicable version of methodology.

TÜV SÜD has checked the revised version 10 of VCS-PD and can confirm that applied version 13.0.0 of ACM0002 has been applied which is applicable to project activity. Hence it is accepted and this issue is closed.

Table 3 Unresolved Corrective Action and Clarification Requests (in case of denials)

Clarifications and / or corrective action requests by validation team

Id. of CAR/CR

Explanation of Conclusion for Denial

- - -

26-07-2013


Validation of the VCS project : “Gokgedik 24.882 MWm / 24.266 MWe Runoff

River Hepp, Turkey”

Page 1 of 6

TÜV SÜD INDUSTRIE SERVICE GMBH

Ref. No.

Issuance and/or submission

date(dd/mm/yyyy) Title/Type of Document

Author/Editor/ Issuer

Additional Information (Relevance in VCS

Context)

1. 30/12/2011 VCS Association homepage:

www.v-c-s-org VCSA -

2. 26/03/2011

VCS-PD for GSP Uhud Enerji Uretim Tic. ve San. A.S.

-

3.

15/11/2011 to 16/11/2011

Participants from DOE Praveen Tekchandani TÜV SÜD Nuri Mol TÜV SÜD Turkey Participant from PP

Enes Kutlarer, Engineer onsite

Memis Elmas, Technology provider

Ahmet Akdmir, PP

Bugra Ulugurt, consultant

TÜV SÜD Uhud Enerji Uretim Tic. ve San. A.S

-

4. 25/11/2011

ACM0002 ver 13.0.0 UNFCCC

Applied methodology for the project activity

5. 25/06/2009 Electricity Generation License issued by EMRA for Gokgedik HEPP TEIAS To validate the project

details

6. -

Guidelines on the Assessment of Investment Analysis UNFCCC

Used to validate the investment analysis

7. 30/12/2011 (date

of download) Tool to calculate the emission factor for an electricity system, UNFCCC

Used to validate the emission factor

8. 30/12/2011 (date

of download) IPCC National GHG Inventories : ipcc-V2_2_Ch2_Stationary_Combustion UNFCCC

Used to validate the sources of fuel emission factor

9. 29/05/2012 (date of submission to

19- Official_Gazette_Registration of PP PP Used to validate the status of PP

26-07-2013




Page 2 of 6


Ref. No.





Context)

DOE)

10. 01/06/2009 Feasibility Study Report Mühendislik

Hizmetleri Ltd. Şti.

Used to validate the project details


DOE) Project plan to validate the start date of the project activity. PP

Used to validate the start date


DOE) The geological coordinates of Power house PP

Used to validated the project location


DOE) Energy Efficiency Law

Government of Turkey

Used to validated the local laws and regulation


DOE) Forest Law




DOE) Environment Law




DOE)

Regulation on procedures and principles of signing the agreement of utilization of water resources




DOE) Regulation on Environmental Impact Assessment



18. 20/02/2001 Electricity Market Law No. 4628

www.teias.gov.tr

Min. of Energy Turkey


http://www.teias.gov.tr/

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Context)

19. 10/05/2005 Law on Renewable Energy No. 5346

www.enerji.gov.tr, www.epdk.gpv.tr

Ministry of Energy Turkey


20. 28/07/2010 Equipment purchase contract and specification of the turbine-generator units with Andritz Hydro S.A.S., Andritz Hyrdo Ltd. Şti. and Moteurs Leroy-Somer

Contract Used to validate the project details


DOE) Training certificates manual and training of staff onsite PP

Used to validate the training done and required for the power plant


DOE)

Documents for stakeholder meeting - Filled questionnaire

PP To validate the stakeholder process within the company

23. 07/12/2011

The written confirmation & declaration that

The project is not registered under any other GHG-Programs,

The project has not been rejected by other GHG programs,

The project will not get other forms of environmental credits

Proof of title.

PP Used to validate the VCS requirements

24. 08/06/2010 Decision of the board of directors to proceed with the Gokgedik HPP investment (including

carbon revenues). PP Used to validate the

investment decision

25. 18/02/2010 EIA approval from Provincial Department of Environment and Forestry

T.C. Kahramanmaras ValiliGi

Il Cevre Ve Orman Mudurlugu

To validate the environmental impacts from the project activity

26. 08/04/2010 Water usage agreement Government of Turkey

-


Maps showing metering devices for the project activity PP To validate the monitoring plan for the

http://www.enerji.gov.tr/

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Context)

DOE) project activity

28. 16/11/2011 Signed Participation List TÜV SÜD


DOE)

IRR calculaiton sheet for the project activity PP To validate the investment analysis


DOE)

The calculation spreadsheet for emission factor and emission reduction indicating the input values and calculation of each step as per tool to calculation emission factor.

PP To validate the grid emission factor


DOE)

EIA Report TEKSTILA MUHENDISLIK

To validate the environmental impacts from the project activity

32. 01/05/2011 Revised Feasibility Study Report Yolsu

Engineering Services Pte Ltd

Used to validate the project details

33. 26/11/2010 Acceptance of Grid Connection and Usage by TEIAS including the name TEIAS To validate the grid

connection

34. 01/06/2011 Revised Electricity Generation License EMRA To validate the project

details.


DOE)

Main Single line Diagram PP To validate the project details


DOE)

Declaration on double counting for VER projects PP To validate the VCS requirements

37. 25/06/2010 Construction aggreement PP To validate the

construction details

38.

29/05/2012 (date of submission to

DOE)

Documents for stakeholder meeting -

Printed article in the news paper

Photographs of the meeting

PP To validate the stakeholder process within the company

39. 01/07/2012 (date Future prospects of Turkish National Energy Demand and Supply World Enery -

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of submission to DOE)

http://www.dektmk.org.tr/upresimler/Enerji_Raporu_20106.pdf Council


DOE)

Turkish Energy Generation Mix

Energy Ministry -


DOE)

EPDK-Energy Production Licenses Issued

EPDK -


DOE)

Electricity Generation Breakdown of the Turkish Grid for the Last 3 Years95

TEIAS -


DOE)

Fuel Generation Sources Connected to the Grid (2006-2009)

TEIAS -

44. 20/09/2011 GSP announcement of the project activity

http://www.netinform.de/KE/Wegweiser/Guide2.aspx?ID=7314&Ebene1_ID=49&Ebene2_ID=2457&mode=4

TÜV SÜD -


DOE)

The Energy Market Regulatory Authority

http://www.epdk.gov.tr/web/elektrik-piyasasi-dairesi/lisans-islemleri

EPDK -

46.

17/07/2008 Directive on Environmental Impact Assessment (EIA)

http://www.cedgm.gov.tr/CED/AnaSayfa/yonetmelikler.aspx?sflang=tr

Ministry of Environment and Forestry

-

47.

NA Registry of VER Climate projects in Turkey http://karbonsicil.cevreorman.gov.tr/

Ministry of Environment and Forestry, Dept. Of Climate Change

-


DOE)

HYDROPOWER IN TURKEY: POTENTIAL AND MARKET ASSESSMENT

Norwegian Renewable Energy partners

To validate the lifetime of the project

http://www.dektmk.org.tr/upresimler/Enerji_Raporu_20106.pdf

http://karbonsicil.cevreorman.gov.tr/

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Context)

49.

29/05/2012 (date of submission to

DOE)

Main Economic Indicators http://ekutup.dpt.gov.tr/tg/index.asp?yayin=teg&yil=0&ay=0 Temel Ekonomik Göstergeler, 2010, Haziran 7. Bolum, 13th Excel Sheet. (Please also see \Gokgedik.Documents\28- IRR\Benchmark.xlsx in order to reach to the same document

State Planning Organization To validate the

benchmark for the project activity

50. 23/07/2013

VCS-PD of Gokgedik 24.882 MWm / 24.266 MWe Runoff River Hepp, Turkey” version 9 Uhud Enerji Uretim Tic. ve San. A.S.

51. 24/07/2013


52. 26/07/2013


http://ekutup.dpt.gov.tr/tg/index.asp?yayin=teg&yil=0&ay=0

VALIDATION OF “GOKGEDIK 24.882 MWM / 24.266 MWE … Validation Report... · MWM / 24.266 MWE...

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