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PROJECT DESIGN DOCUMENT FORM (CDM-SSC-PDD) - Version 03

CDM Executive Board

CLEAN DEVELOPMENT MECHANISM PROJECT DESIGN DOCUMENT FORM (CDM-SSC-PDD) Version 03 - in effect as of: 22 December 2006 CONTENTS A. B. C. D. E. General description of the small scale project activity Application of a baseline and monitoring methodology Duration of the project activity / crediting period Environmental impacts Stakeholders comments Annexes Annex 1: Contact information on participants in the proposed small scale project activity Annex 2: Information regarding public funding Annex 3: Baseline information Annex 4: Monitoring Information

PROJECT DESIGN DOCUMENT FORM (CDM-SSC-PDD) - Version 03

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Revision history of this document

Version Number 01 02

Date 21 January 2003 8 July 2005

Description and reason of revision Initial adoption The Board agreed to revise the CDM SSC PDD to reflect guidance and clarifications provided by the Board since version 01 of this document. As a consequence, the guidelines for completing CDM SSC PDD have been revised accordingly to version 2. The latest version can be found at <http://cdm.unfccc.int/Reference/Documents>. The Board agreed to revise the CDM project design document for small-scale activities (CDM-SSC-PDD), taking into account CDM-PDD and CDM-NM.

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22 December 2006

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SECTION A. General description of small-scale project activity A.1 Title of the small-scale project activity: >> Waste Heat Recovery CDM Project at Attock Cement Pakistan Ltd. Version: 2.3 28/03/2012 A.2. Description of the small-scale project activity: >> The Attock Cement Waste Heat Recovery for Power Generation Project, herein referred to as the project or the project activity, will comprise the installation of waste heat recovery and electricity generation technology at the Attock Cement Pakistan Ltd. (ACPL) cement plant in Hub Chowki, Pakistan. Project owner is the cement plant owner Attock Cement Pakistan Ltd., international cooperation partner (CERbuyer) of this bilateral CDM project is the German company UPM Umwelt-Projekt-Management GmbH. The Attock Cement plant has a rated clinker output of 5,700 tons of clinker per day produced in two production lines. Line 1 (operational since 1988) has a capacity of 2,400 tons/day and Line 2 (operational since 2006) has a production capacity of 3,300 tons per day. The waste heat of these two production lines will be recovered and utilized to drive a 12 MW power plant that generates electricity for captive use of the cement plant. The average power available for consumption will be 8.1 MW. Based on the rated capacity of the two production lines (7,200 operations hours per year), the electricity consumption of the cement plant will be reduced by 58,320,000 KWh. In the absence of the project activity all waste heat that will be recovered and utilized during the project activity is vented to the atmosphere. During the project lifetime, the generated electricity will be used for captive purposes and thereby reduce the total power uptake of the cement plant. The power generated by the project activity will therefore replace electricity provided by the national electricity grid of the Karachi Electric Supply Company (KESC) Since the electricity provided by the KESC grid is mainly generated using fossil fuels, the replacement of 58,320,000 KWh will result in an annual emission reduction of 34,417 tCO2e. Project emissions will occur due to electricity and fossil fuel consumption of water pumps that will provide the additional water demand of 2,800 m3/day to the waste heat recovery plant. The proposed project activity will contribute to a local sustainable development with the following effects: Economic development: Pakistan is passing through an acute energy crisis. Under the circumstances, the power plant will at least cut short its 8.1 MW demand of power from the national grid. This should contribute to a reduction in the number of black-outs and brown-outs experienced by other grid users, which can help to improve the economic performance of other businesses connected to the grid. Social development: During its construction period of about 15 months, about 500 people of all categories will get jobs -

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though for a short period. While during its regular operations, it will engage around 40-45 staff members. Environmental development: By resulting in a significant reduction of greenhouse gas emissions and reducing the so-called heat-isle effect, the project contributes to a sustainable development of the local environment. Technological development: By installing Chinese technology in Pakistan, the project facilitates technology transfer and therefore promotes technological development.

A.3. Project participants: >> Name of Party involved (host) indicates a Host Party)

Private and/or public entity(ies) project participants (as applicable)

Kindly indicate if the Party involved wishes to be considered as project participant (Yes/No) No No

Islamic Republic of Pakistan United Kingdom of Great Britain and Northern Ireland

Attock Cement Pakistan Ltd. UPM Umwelt-ProjektManagement GmbH

Project owner: Attock Cement Pakistan Ltd. Attock Cement Pakistan Limited (ACPL) was incorporated in Pakistan on October 14, 1981 as a Public Limited Company and listed on the Karachi Stock Exchange. The company started its commercial production in June, 1988. CER buyer: UPM Umwelt-Projekt-Management GmbH UPM Umwelt-Projekt-Management GmbH was originally founded at the beginning of the 1990s to provide project management and consulting services in the field of lean gas utilization projects. Today, UPM is mainly working in the field of Clean Development Mechanism (CDM) within the framework of the Kyoto Protocol. A.4. Technical description of the small-scale project activity: A.4.1. Location of the small-scale project activity: >> A.4.1.1. >> Islamic Republic of Pakistan A.4.1.2. >> Host Party(ies):

Region/State/Province etc.:

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Baluchistan A.4.1.3. >> Hub Chowki, Lasbella A.4.1.4. Details of physical location, including information allowing the unique identification of this small-scale project activity : >> The proposed project activity is located at the Attock Cement plant 16 km north-west of the city centre of Hub Chowki in the Baluchistan Province of Pakistan. Its coordinates are: Latitude: 258'23.75" Longitude 6654'55.65". City/Town/Community etc:

Figure 1: Geographical location of the project activity.

A.4.2. Type and category(ies) and technology/measure of the small-scale project activity: >> In accordance with Appendix B of the simplified modalities and procedures for small-scale CDM project activities, the Project activity is categorized under the following type and category: Type III. Other project activities Category Q: Waste Energy Recovery (gas/heat/pressure) Projects Sectoral Scope 04 Manufacturing industries. As the project also uses ACM0012 to calculate the capping factor, Sectoral Scope 1 Energy industries (renewable -/ non-renewable sources) is applied in addition. With the proposed project, waste heat boilers will be installed at the outlet of cooler and at the exit of preheater of each line, introducing water into the boilers and producing superheated steam by using waste hot gases from Cooler and pre-heater. The superheated steam produced from all the boilers merges together and is introduced to a turbine for power generation. The power thus produce will be connected with the existing grid station. Exhaust steam of turbine after work condense to water and pump back to the boilers. After passing from boilers the temperature and volume of hot gases reduced significantly and further reduced when pass through the dust-collecting filter and then exhausted in the atmosphere. The following flow chart shows the complete process of WHRS.

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The additional water demand of 2,800 m3 per day will be provided by additional pumps. While the existing cement factory operates a 90 kW water pump and two 45 kW pumps as backup using grid electricity and diesel generators during grid load sheds, three 90 kW pumps will be operated during the project activity. Of the three pumps, two will be in constant operation, while the third will be kept as a back-up system.

From Line- 2 Pre-Heater

Settling Chamber

FLOW DIAGRAM
Y STEAM HOT GASES DUST WATER ELECTRICIT

SP Boiler # 2

Cooling Tower

ID Fan

COOLER LINE-2 From Line- 1 Pre-Heater Settling Chamber

SP Boiler # 1

AQC Boiler # 2

ID Fan

AQC Boiler # 1

STEAM TURBINE GENERATOR CONDENSER

TO GRID STATION

COOLER LINE-1 WATER TO BOILER MAKEUP WATER WATER COOLING TOWER

POWER GENERATION THRU WHRS


Figure 2: Flow chart of the proposed project.

The waste heat recovery equipment is purchased from China. Therefore, technology transfer from China to Pakistan will take place through the proposed project. A.4.3 >> Years Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Estimation of annual emission reductions in tonnes of CO2e 34,417 34,417 34,417 34,417 34,417 34,417 Estimated amount of emission reductions over the chosen crediting period:

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Year 7 Year 8 Year 9 Year 10 Total estimated reductions (tonnes of CO2e) Total number of crediting years Annual average of estimated reductions over the crediting period (tonnes of CO2e) A.4.4. Public funding of the small-scale project activity: >> No public funding is involved in the project financing.

34,417 34,417 34,417 34,417 344,170 10 34,417

A.4.5. Confirmation that the small-scale project activity is not a debundled component of a large scale project activity: >> Appendix C of the Simplified Modalities and Procedures for Small-Scale CDM project activities gives the definition of a debundled component of a large project activity1: A proposed small-scale project activity shall be deemed to be a debundled component of a large project activity if there is a registered small-scale CDM project activity or an application to register another small-scale CDM project activity: (a) With the same project participants; (b) In the same project category and technology/measure; and (c) Registered within the previous 2 years; and (d) Whose project boundary is within 1 km of the project boundary of the proposed smallscale activity at the closest point. There is no registered small-scale CDM project activity or an application to register another small-scale CDM project activity that meets all of the above mentioned criteria. Therefore, the Project activity is not a debundled component of a large scale project activity. SECTION B. Application of a baseline and monitoring methodology

B.1. Title and reference of the approved baseline and monitoring methodology applied to the small-scale project activity: >> Title of the baseline methodology: AMS III.Q Waste energy recovery (gas/heat/pressure) projects (Version 04).
Appendix C of the Simplified Modalities and Procedures for Small-Scale CDM project activities (contained in annex II to decision 21/CP.8, see document FCCC/CP/2002/7/Add.3).
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Reference: AMS-III.Q., Version 04 (EB 61, Sectoral Scope: 04) It has been referred from the list of approved methodologies for CDM project activities in the UNFCCC CDM website (http://cdm.unfccc.int/methodologies/SSCmethodologies/approved.html). The baseline for the proposed project activity is determined using the Tool to calculate the Emission Factor for an electricity system (Version 2.2.1, EB 63). To calculate the project emissions, the Tool to calculate baseline, project and/or leakage emissions from electricity consumption (Version 01, EB 39) and the Tool to calculate project or leakage CO2 emissions from fossil fuel combustion (Version 02, EB 41) are applied. To estimate the capping factor, corresponding section of ACM0012 Consolidated baseline methodology for GHG emission reductions from waste energy recovery projects (version 4.0.0, EB560) is referred. B.2 Justification of the choice of the project category: >> In the applied methodology AMS-III.Q., v. 04, several applicability conditions are listed. Table 1 demonstrates the applicability of all listed requirements. No. 1. Applicability criteria The category is for project activities that utilize waste gas and/or waste heat at existing facilities as an energy source for: a) Cogeneration; or b) Generation of electricity; or c) Direct use as process heat; or d) Generation of heat in elemental process (e.g., steam, hot water, hot oil, hot air); e) Generation of mechanical energy. 2. The category is also applicable to project activities that use waste pressure to generate electricity at existing facilities. The recovery of waste gas/heat/pressure should be a new initiative (no waste gas/heat/pressure was recovered from the project activity source prior to the implementation of the project activity). No waste pressure utilization is included in the project activity. Criteria not applicable. The projects plant is a new facility and no similar technology has been installed at the cement plant prior to the project activity. Y Project situation The project activity utilizes waste heat from existing facilities to generate electricity, i.e. option b. Methodology Applicability (y/n) Y

3.

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No. 4.

Applicability criteria Measures are limited to those that result in emission reductions of less than or equal to 60 ktCO2 equivalent annually. The energy produced with the recovered waste gas/heat should be measurable. Energy generated in the project activity may be used within the industrial facility or exported to other industrial facilities (included in the project boundary). Electricity generated in the project activity may be exported to the grid or used for captive purposes. However, the methodology is not applicable to projects where the waste gas/heat/pressure recovery project is implemented in a single-cycle power plant (e.g. gas turbine or diesel generator) where heat (energy) generated on-site is not utilizable for any other purposes on-site except to generate power. Such project activities shall consider AMS-III.AL. Conversion from single cycle to combined cycle power generation.. Projects recovering waste energy from such power plants for the purpose of generation of heat only can apply this methodology; For a project activity which recovers waste gas/heat/pressure for power generation from multiple sources (e.g. kiln and single-cycle power plant), this methodology can be used in combination with AMS-III.AL provided that2: The emission reductions are claimed by the generator of energy using waste energy.

Project situation The emission reduction will not exceed 60 ktCO2e per year during the crediting period. This will be shown in chapter B.6.4 of this PDD. The energy produced with the recovered waste heat is measurable. All electricity generated by the project activity will be utilized within the Attock cement plant. All electricity generated by the project activity will be used for captive purposes. The project is not implemented in a singlecycle power plant. The project activity recovers waste heat from the clinker production process and utilizes it for power generation.

Methodology Applicability (y/n) Y

5. 6.

Y Y

7.

8.

9.

Not applicable. The project will only recover waste heat from the cement plant, no combination with methodology AMS-III.Al is required. The emission reductions are claimed by the project owner and generator of energy Attock Cement Pakistan Ltd.

The sub-criteria are not listed here, as the criteria is not applicable to the project.

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No. 10.

Applicability criteria
In cases where the energy is exported to other facilities (included in the project boundary), the following are required: (i) All historical information from the recipient plants; (ii) An official agreement exists between the owners of the project energy generation plant (henceforth referred to as generator, unless specified otherwise) with the recipient plant(s) that the emission reductions would not be claimed by the recipient plant(s) for using a zero-emission energy source; For those facilities and recipients included in the project boundary, that prior to implementation of the project activity (current situation) generated energy on-site (sources of energy in the baseline), the credits can be claimed for minimum of the following time periods: i. The remaining lifetime of equipment currently being used; and

Project situation The project activity will not export energy to other facilities.

Methodology Applicability (y/n) Y

11.

No energy was generated onsite prior to the project activity. The project activity will reduce the electricity uptake from the national grid (source of energy in the baseline). Not applicable.

ii. Crediting period. 12. The waste gas/heat/pressure utilized in the project activity would have been flared or released into the atmosphere in the absence of the project activity. This shall be proven by one of the following options: i. By direct measurements of energy content and amount of the waste gas/heat/pressure for at least three years prior to the start of the project activity. ii. Energy balance of relevant sections of the plant to prove that the waste gas/heat/pressure was not a source of energy before the implementation of the project activity. For the energy balance the representative process parameters are required. The energy balance shall demonstrate that the waste gas/heat/pressure was not used and also provide conservative estimations of the energy content and amount of waste gas/heat/pressure released. iii. Energy bills (electricity, fossil fuel) to demonstrate that all the energy required for the process (e.g., based on specific energy The baseline situation will be demonstrated using method 1. The necessary data will be provided to the DOE during the validation. Y

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No.

Applicability criteria consumption specified by the manufacturer) has been procured commercially. Project participants are required to demonstrate through the financial documents (e.g., balance sheets, profit and loss statement) that no energy was generated by waste gas/heat/pressure and sold to other facilities and/or the grid. The bills and financial statements should be audited by competent authorities. iv. Process plant manufacturers original specification/information, schemes and diagrams from the construction of the facility could be used as an estimate of quantity and energy content of waste gas/heat/pressure produced for rated plant capacity per unit of product produced.

Project situation

Methodology Applicability (y/n)

For the purpose of this category waste energy is The waste heat recovered defined as: a by-product gas/heat/pressure from from the clinker making machines and industrial processes having process complies with the potential to provide usable energy, for which it definition provided above can be demonstrated that it was wasted. For and it can be demonstrated example gas flared or released into the that it was wasted prior to the atmosphere, the heat or pressure not recovered start of the project activity (therefore wasted). Gases that have intrinsic value (see explanation in the in a spot market as energy carrier or chemical sections below). No gases (e.g., natural gas, hydrogen, liquefied petroleum with intrinsic value are gas, or their substitutes) are not eligible under this included in the project category. activity. Table 1: Applicability criteria of methodology AMS-III.Q. 13.

As meeting all criteria listed above, the chosen methodology AMS-III.Q. can be deemed as applicable to the actual project activity. B.3. Description of the project boundary: >> In the small-scale methodology AMS-III.Q, the project boundary is described in paragraph 83: 7. The physical, geographical site of the facility where the waste gas/heat/ pressure is produced and transformed into useful energy delineates the project boundary. The geographical extent of the project boundary shall include the following:

Cited from AMS-III.Q Waste energy recovery (gas/heat/pressure) projects , v.04, p.3

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The industrial facility where waste energy is generated, including the part of the industrial facility where the waste gas was utilized for generation of captive electricity prior to implementation of the project activity; The facility where steam/process heat in the element process/electricity/mechanical energy is generated (generator steam/ process heat/electricity/mechanical energy). Equipment providing auxiliary heat to the waste energy recovery process shall be included within the project boundary; and The facility(ies) where steam/process heat in the element process/electricity/ mechanical energy is used (the recipient plant(s)) and/or grid where electricity is exported, if applicable. Based on this definition, the project boundary is defined as illustrated in Figure 3 and defined as follows: The project boundary comprises the Attock Cement Pakistan Ltd. cement plant in Hub Chowki, Pakistan including the two clinker production lines where the waste heat is generated. and the equipment that will be installed by the project activity, mainly four waste heat boilers, a steam turbine and a generator.

As the generated electricity will be consumed on-site, the national grid that provides electricity to the project in the baseline scenario will not be included.

Figure 3: Project boundary of the project activity.

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The project activity will generate electricity by utilizing waste heat from the two production lines of the cement plant and reduce the energy consumption of the cement plant. In the baseline, the electricity is completely provided by the national KESC grid. Therefore, the baseline emission of the proposed project results from the CO2 emissions of the KESC electricity grid. The only additional equipment that will not be operated using electricity from the WHRS plant itself, are additional water pumps that provide water to the project. These pumps will be operated using grid electricity and diesel generators for cases of grid electricity load shedding. Therefore, the project emissions comprise the emissions from consumption of grid electricity and combustion of fossil fuel to operate the pumps. B.4. Description of baseline and its development: >> The proposed project comprises the installation of a new waste heat recovery power plant, generating electricity for the cement plant that purchases the energy from the KESC grid in absence of the project. Therefore, in line with paragraph 8 of the applied methodology, the baseline scenario is the generation of electricity by grid-connected power plants. The baseline emissions can be calculated using the Tool to calculate the emission factor for an electricity system". B.5. Description of how the anthropogenic emissions of GHG by sources are reduced below those that would have occurred in the absence of the registered small-scale CDM project activity: >> Date 01/2010 10/02/2010 24/03/2010 23/04/2010 05/2010 13/05/2010 24/05/2010 14/07/2010 03/08/2010 30/08/2010 Item Feasibility Study completed CDM needed to make the proposed project financially attractive. Board decision to put project into practice if CDM is feasible Letter of Intent issued to UPM GmbH cooperation between UPM GmbH and Attock Cement Pakistan Ltd. fixed ERPA signed between Attock Cement Pakistan Ltd. (seller) and UPM GmbH (buyer) Initial Environmental Evaluation (IEE) - Report Equipment purchase contract signed (Project starting date) Note on Prior Consideration of CDM submitted to Pakistani DNA Response from Pakistani DNA Stakeholder meeting Note on Prior Consideration of CDM submitted to UNFCCC Evidence FSR (Doc001) Board resolution (Doc002) LOI (Doc003) ERPA (Doc004) IEE (Doc005) Purchase Contract (Doc007) Prior Consideration Note (Doc008) DNA response (Doc009) Prior Consideration note (Doc010)

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Table 2: Project development timeline Assessment and demonstration of additionality To assess and demonstrate the additionality, attachment A to Appendix B of the simplified Modalities and Procedures for Small-Scale CDM project activities is used. According to this guideline, a small-scale project activity is considered additional, if at least one of the following barriers prevents the project from being installed: a) Investment barrier b) Technological barrier c) Barrier due to prevailing practice d) Other barriers For this project, the demonstration of existence of an investment barrier is chosen. By demonstrating, that a financially more feasible option (baseline scenario as described in B.4) is leading to more emissions. Since an investment is not required for the project owner, and the project does generate economic benefits other than the CDM related income, the benchmark analysis is chosen as appropriate to demonstrate the additionality of the project. Therefore, the Guidelines on the assessment of investment analysis are to be used in the following. Table 3 demonstrates the fulfilment of all guidelines provided in the Guidelines on the assessment of investment analysis, v. 055. No. 3. Guidance The period of assessment should not be limited to the proposed crediting period of the CDM project activity. Both project IRR and equity IRR calculations shall as a preference reflect the period of expected operation of the underlying project activity (technical lifetime), or - if a shorter period is chosen - include the fair value of the project activity assets at the end of the assessment period. In general a minimum period of 10 years and a maximum of 20 years will be appropriate. The IRR calculation may include the cost of major maintenance and/or rehabilitation if these are expected to be incurred during the period of assessment. Project participants are requested to justify and DOEs are requested to validate the appropriateness of the period of assessment in the context of the underlying project activity, without reference to the proposed CDM crediting period. Project activity The period of assessment is limited to the technical project lifetime of 20 years. This is in line with the company accounting policy.

All guidances listed in Table 3 are cited from Guidelines on the assessment of investment analysis, v. 05.

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No. 4.

5.

6.

Guidance The fair value of any project activity assets at the end of the assessment period should be included as a cash inflow in the final year. The fair value should be calculated in accordance with local accounting regulations where available, or international best practice. It is expected that such fair value calculations will include both the book value of the asset and the reasonable expectation of the potential profit or loss on the realization of the assets. Depreciation, and other non-cash items related to the project activity, which have been deducted in estimating gross profits on which tax is calculated, should be added back to net profits for the purpose of calculating the financial indicator (e.g. IRR, NPV). Taxation should only be included as an expense in the IRR/NPV calculation in cases where the benchmark or other financial indicator is intended for post-tax comparisons. Input values used in all investment analysis should be valid and applicable at the time of the investment decision taken by the project participant. The DOE is therefore expected to validate the timing of the investment decision and the consistency and appropriateness of the input values with this timing. The DOE should also validate that the listed input values have been consistently applied in all calculations.

Project activity According to the companys policy, a project lifetime of 20 years and a residual value of 1% has been considered.. Tax benefit on depreciation is included in the IRR calculation.

7.

In the case of project activities for which implementation ceases after the commencement and where implementation is recommenced due to consideration of the CDM the investment analysis should reflect the economic decision making context at point of the decision to recommence the project. Therefore capital costs incurred prior to the revised project activity start date can be reflected as the recoverable value of the assets, which are limited to the potential reuse/resale of tangible assets.

All input values reflect to values applicable at the time of investment decision. As can be seen from the timeline presented in Table 2, the project starting date comes shortly after the financial analysis has been conducted. It can therefore be assumed that the input data did not change significantly between the calculation and the final investment decision. No capital costs that incurred prior to the revised project activity start are reflected as recoverable value of assets.

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No. 8.

9. 10.

Guidance Project participants should supply spreadsheet versions of all investment analysis. All formulas used in this analysis be readable and all relevant cells be viewable and unprotected. The spreadsheet will be made available to the Executive Board, UNFCCC secretariat and others contracted to assess the request for registration on behalf of the Board including assigned members of the Registration and Issuance Team. In cases where the project participant does not wish to make such a spreadsheet available to the public an exact read-only or PDF copy shall be provided for general publication. In case the PP wishes to black-out certain elements of the publicly available version, a clear justification for this shall be provided to the UNFCCC secretariat by the DOE when requesting registration. The cost of financing expenditures (i.e. loan repayments and interest) should not be included in the calculation of project IRR. In the calculation of equity IRR only the portion of investment costs which is financed by equity should be considered as the net cash outflow, the portion of the investment costs which is financed by debt should not be considered a cash outflow. Due to the impact of loan interest on income tax calculations it is recommended that when a project IRR is calculated to demonstrate additionality a pre-tax benchmark be applied. In cases where a post-tax benchmark is applied the DOE shall ensure that actual interest payable is taken into account in the calculation of income tax. In such situations interest should be calculated according to the prevailing commercial interest rates in the region, preferably by assessing the cost of other debt recently acquired by the project developer and by applying a debt-equity ratio used by the project developer for investments taken in the previous three years. 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. Required/expected returns on equity are appropriate benchmarks for an equity IRR. Benchmarks supplied by relevant national authorities are also appropriate if the DOE can validate that they are applicable to the project activity and the type of IRR calculation presented. In the cases of projects which could be developed by an entity other than the project participant the benchmark should be based on parameters that are standard in the market. The DOE.s validation of the benchmark shall also include its opinion on whether a company-specific benchmark or a benchmark based on parameters that are standard in the market is suitable in the context of the underlying project activity.

Project activity The spreadsheets are provided to DOE and EB.

The project will be financed through equity. The project is completely financed by equity. Not applicable.

11.

12.

13.

The benchmark used is taken from Appendix A of the guidelines on the assessment of investment analysis. The benchmarks in this Appendix are appropriate benchmarks for the equity IRR. Source of benchmark is publicly available (EB62, Annex 5) and can be validated by the DOE.

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No. 14.

15.

Guidance Internal company benchmarks/expected returns (including those used as the expected return on equity in the calculation of a weighted average cost of capital WACC), should only be applied in cases where there is only one possible project developer and should be demonstrated to have been used for similar projects with similar risks, developed by the same company or, if the company is brand new, would have been used for similar projects in the same sector in the country/region. This shall require as a minimum clear evidence of the resolution by the companies Board and/or shareholders and will require the validating DOE to undertake a thorough assessment of the financial statements of the project developer including the proposed WACC to assess the past financial behavior of the entity during at least the last 3 years in relation to similar projects. If the benchmark is based on parameters that are standard in the market, the cost of equity should be determined either by: (a) selecting the values provided in Appendix A; or by (b) calculating the cost of equity using best financial practices, based on data sources which can be clearly validated by the DOE, while properly justifying all underlying factors. The values in the table in Appendix A may also be used, as a simple default option, if a company internal benchmark is used.

Project activity No internal benchmark is used.

The values provided in Appendix A are chosen as benchmarks.

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No. 16.

17.

Guidance If a company.s internal benchmark is used for the expected return on equity, the cost of debt should be based on the weighted average cost of debt financing of the legal entity owning the CDM project activity. For loans, use the weighted average cost of outstanding long-term debt. For bonds, use the weighted average yield of the bonds during the last three months prior to the submission of the CDM-PDD for validation or prior to the investment decision, whichever is earlier. The use of bonds to determine the cost of debt is only appropriate for corporate bonds issued in the host country of the CDM project. In cases where the debt finance structure of the project is not yet available (e.g. a letter of intent for debt funding is not available), the cost of debt can be assumed as the commercial lending rate in the country or the yield of a 10 year bond issued by the government of the host country or, if this is not available, the bond with the maturity which is closest to 10 years. The following should be documented in the CDM-PDD: (a) for bonds: the key parameters of the bond including the time of maturity, yield, registration issuance in the financial system and set-up in the market; (b) for loans from a financial institution: the contract of lending between the financial institution and the legal entity owning the assets of the project activity, or, in absence of the contract, a letter from the bank stating its intention to award the loan and the key terms for the loan; (c) for debt financing from a parent company: the transfer of capital to the legal entity, documented with the contract of lending between the parent company and the legal entity owning the assets of the project activity and/or the parameters of the corporate bonds as mentioned above. This latter option is only valid for corporate bonds issued in the host country of the CDM project activity. If the benchmark is based on parameters that are standard in the market, the cost of debt should be calculated as the cost of financing in the capital markets (e.g. commercial lending rates and guarantees required for the country and the type of project activity concerned), based on documented evidence from financial institutions with regard to the cost of debt financing of comparable projects. In cases where this data is not available, use the commercial lending rate in the host country to calculate the cost of debt. If a company.s internal benchmark is used for the expected return on equity, then the percentage of debt financing and equity financing should reflect the long-term debt/equity finance structure of the legal entity owning the assets of the project activity. The percentage should be determined based on the latest balance sheet provided under local fiscal/accounting standards and rules if: (a) the legal entity owning the assets of the project activity has balance sheets audited by a third party within two years prior to the submission of the CDM-PDD for validation; and (b) the accounting books of the legal entity reflect at least the total value of all the assets needed for the project activity. If the debt/equity finance structure is not yet available, 50% debt and 50% equity financing may be assumed as a default.

Project activity No companys internal benchmark is used, but the default values published in the guidelines on the assessment of investment analysis.

No companys internal benchmark is used, but the default values published in the guidelines on the assessment of investment analysis.

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Guidance If the benchmark is based on parameters that are standard in the market, then the typical debt/equity finance structure observed in the sector of the country should be used. If such information is not readily available, 50% debt and 50% equity financing may be assumed as a default. If the proposed baseline scenario leaves the project participant no other choice than to make an investment to supply the same (or substitute) products or services, a benchmark analysis is not appropriate and an investment comparison analysis shall be used. If the alternative to the project activity is the supply of electricity from a grid this is not to be considered an investment and a benchmark approach is considered appropriate. Only variables, including the initial investment cost, that constitute more than 20% of either total project costs or total project revenues should be subjected to reasonable variation (all parameters varied need not necessarily be subjected to both negative and positive variations of the same magnitude), and the results of this variation should be presented in the PDD and be reproducible in the associated spreadsheets. Where a DOE considers that a variable which constitute less than 20% have a material impact on the analysis they shall raise a corrective action request to include this variable in the sensitivity analysis

19.

Project activity The benchmark used is the default value given in the guidelines on the assessment of investment analysis. Baseline scenario is BAU scenario.

20.

The DOE should assess in detail whether the range of variations is reasonable in the project context. Past trends may be a guide to determine the reasonable range. As a general point of departure variations in the sensitivity analysis should at least cover a range of +10% and -10%, unless this is not deemed appropriate in the context of the specific project circumstances. In cases where a scenario will result in the project activity passing the benchmark or becoming the most financially attractive alternative the DOE shall provide an assessment of the probability of the occurrence of this scenario in comparison to the likelihood of the assumptions in the presented investment analysis, taking into consideration correlations between the variables as well as the specific socio-economic and policy context of the project activity. Table 3: Guidelines on the assessment of investment analysis. 21.

The variables total investment, electricity savings and O&M costs have been varied in a range of +10% to 10%, and sensitivity has been conducted. The same is reflected in the investment analysis spreadsheet. The variables total investment, electricity savings and O&M costs have been varied in a range of +10% to 10%, and sensitivity has been conducted. The same is reflected in the investment analysis spreadsheet.

Benchmark definition: Based on the guidelines on the assessment of investment analysis, v.05, the default benchmark for the sectoral scope 4 (Manufacturing industries, as per the applied methodology AMS III.Q) is used. Since version 4 of the guidelines on the assessment of investment analysis, these benchmarks are provided as a simple default option. The applied post-tax equity benchmark is therefore 15.5%. Following these guidelines, a financial analysis is conducted with the following main input values: Item Total investment Equity Value 1,583,699,389 100 Unit PKR %

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Item Net capacity Annual operation hours Annual electricity savings Electricity price Water requirement Water price Repair & Maintenance Replacement costs Annual inflation for utilities Annual inflation for repair & maintenance Annual inflation for salaries Statutory charges Insurance Project lifetime Income tax Residue or residual rate/Fair value CERs

Value 8,100 7,200 58,320,000 6.5 184,800,000 0.052 5 3 5 7 10 7 0.28 20 35 1 35,000

Unit KW h KWh PKR/KWh Imperial gallons/yr PKR/gallon % of total investment % of total investment % % % % of net profit before tax % of total investment years % % CERs (Based on an estimation) EUR

initial

CER price 11.7 Table 4: Main input parameters of the financial analysis.

With these input values, two post-tax equity IRRs are calculated; one excluding CER revenues, one including CER revenues:

IRR excluding CERs IRR including CERs

12.13% 16.22%

Since the IRR excluding CER revenues is below the benchmark of 15.5% and the IRR including the CER revenue surpasses this benchmark, it can be concluded that the proposed project is financially additional with CDM. Sensitivity analysis To show the robustness of the results, a sensitivity analysis is carried out for the variation of the decisive variables of the project activity. These are the total investment, electricity savings and yearly O&M costs. The results of the sensitivity analysis are shown in the following:

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18.00% 16.00% 14.00% 12.00% 10.00% 8.00% 6.00% 4.00% 2.00% 0.00% -10% -5% 0% 5% 10% Total Investment Electricity Production O&M Costs

Figure 4 Sensitivity analysis for the parameters total investment, electricity savings and annual O&M costs. -10% Total investment Electricity savings 15.90% 8.61% -5% 13.92% 10.44% 0% 12.13% 12.13% 12.13% 5% 10.49% 13.73% 11.49% 10% 8.46% 15.27% 10.84%

Annual O&M costs 13.35% 12.75% Table 5: Detailed results of the sensitivity analysis.

The sensitivity analysis shows that the results of the Investment analysis are robust. For a change of +/10% in electricity savings and annual O&M cots, the IRR for the project activity is still below the benchmark, thus strengthening the conclusions about the additionality of the project activity. Only in once scenario, total investment -10%, the IRR would exceed the benchmark. A further analysis shows that if the total investment would be lower than -9.05% of the initially assumed value, the IRR would reach the benchmark of 15.5% and the project would become financially feasible. However, such scenario can be excluded, as the total paid amount (as of 03/03/2012) already reached 1,490, 047,673 PKR. This is already 94.1% of the originally assumed 1,583,699,389PKR. A scenario, in which the project IRR exceeds the benchmark of 15.5% due to a lower total investment is therefore impossible and can be excluded. By demonstrating, that the investment is not financially viable for the project owner and a financially attractive scenario is impossible to occur, even taken into consideration a variation of input parameters (sensitivity analysis), it is clearly shown that an investment barrier prevents the project from being implemented and it is therefore considered additional. B.6. >> Emission reductions: B.6.1. Explanation of methodological choices:

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Baseline emissions According to the methodology, in the situation where the electricity is obtained from a specific existing power plant or from the grid, mechanical energy is obtained by electric motors and heat from a fossil fuel based element process (e.g., steam boiler, hot water generator, hot air generator, hot oil generator), baseline emissions can be calculated as follows: 1

!"!#,! = !"# !"#


! !

(!,!,! !"#$,!,!,! )

With the input values Baseline emissions due to displacement of electricity during the year y in tons of CO2. !"!#,! Capping factor to exclude increased waste energy utilization in the project year y due !"# to increased level of activity of the plant, relative to the level of activity in the base years before project start. Fraction of total electricity generated by the project activity using waste energy. With !"# reference to the methodology, this factor is considered 1 as the electricity generated is driven purely by utilization of waste heat. The quantity of electricity supplied to the recipient j by generator, that in the absence !,!,! of the project activity would have been sourced from ith source (i can be either grid or identified source) during the year y in MWh. The CO2 emission factor for the electricity source i (i=gr (grid) or i=is (identified !"#$,!,!,! source)), displaced due to the project activity, during the year y in tons CO2/MWh Two factors have to be defined in more detail: To calculate !"# , the methodology refers to the large-scale methodology ACM0012 (latest version: v. 4.0.0). There, the following alternatives are listed6: Method-1: Where the historical data on energy released by the waste energy carrying medium is available, the baseline emissions are capped at the maximum quantity of waste energy released into the atmosphere under normal operation conditions in the three years previous to the project activity. Method-2: If three-year historical data is not available, the manufacturers data for the facility shall be used to estimate the amount of waste energy the facility generates per unit of product. The product is produced by the process that generates waste energy (departmental process or process of entire project facility, whichever is more justifiable and accurate). If any modification is carried out by the project proponent or if the manufacturers data is not available for an assessment, this should be carried out by independent qualified/certified external process experts such as a chartered engineer on a conservative quantity of waste energy generated by the project facility per unit of product manufactured by the process generating waste energy. The value arrived at based on above sources of data, shall be used to estimate the baseline cap (fcap).

Cited from ACM0012 - Consolidated baseline methodology for GHG emission reductions from waste energy

recovery projects, v. 4.0.0, pp. 29-32

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Method-3: In some cases, it may not be possible to measure the waste energy (heat, sensible heat, heat of reaction, heat of combustion, etc.) enthalpy or pressure content of WECM (Method-1 requirement), nor the specific amount of WECM per unit of product (Method-2 requirement). In such cases, the capping shall be based on indirect information about specific parameters allowing to estimate the amount of waste energy available. These parameters should be related to the characteristics of a product or a by-product of the facility from which waste energy can be recovered (e.g. volume and heat content of hot clinker produced by a kiln in a cement plant, if this heat can be recovered using air as the WECM). These cases may be of the following two types. Since three years of historical data are available, for this project, Method 1 is chosen to determine the capping factor for waste heat recovering projects:

!"#,!" !"# !"#,!" !"# + !"#,!" + !"# = !"#,! !"# !"#,! !"#

!"#,!" !"# 9.81 10! !"#,!"

!"#,! !"# 9.81 10! + !"#,! + !"#,!

With the input values: !"#,!" Average quantity of WECM released (or flared or wasted) in atmosphere in three years prior to the start of the project activity [kg]. !"#,! Quantity of WECM used for energy generation during year y [kg]. !"# Specific Heat of waste energy carrying medium (WECM) [TJ/kg/C]. !"#,!" Average temperature of Waste Energy Carrying Medium (WECM) in three years prior to the start of the project activity [C]. !"#,! Average temperature of Waste Energy Carrying Medium (WECM) in year y [C]. !"# Reference temperature to be used to determine available energy in WECM y [25 C]. !"#,!" Average net calorific value of waste gas (if WECM is waste gas), three years prior to implementation of project activity which has unburnt components such as carbon particles, CO or CH4 that will provide energy in waste energy recovery equipment on combustion of gas [TJ/kg]. !"!,! Average net calorific value of waste gas in year y (if WECM is waste gas), which has unburnt components such as carbon particles, CO or CH4 that will provide energy in waste energy recovery equipment on combustion of gas [TJ/kg]. !"#,!" Average pressure of WECM in three years prior to the start of the project activity [kg/cm2]. !"#,! Average pressure of WECM in year y [kg/cm2]. !"# Reference pressure of WECM [1 atm]. !"#,!" Average density of WECM at actual temperature and pressure in three years prior to the start of the project activity [kg/m3] !"#,! Average density of WECM at actual temperature and pressure in year y [kg/m3]. Factor to convert kg-m into TJ (To be used when pressure is expressed in kg/m2. 9.81 10! ,,,

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The calculation of the grid emission factor is carried out and described in Annex 3. Project emissions In the methodology, the project emissions are defined as7: 14. Project Emissions include emissions due to combustion of auxiliary fuel to supplement waste gas and emissions due to consumption of electricity by the project activity. 15. If the waste gas contains carbon monoxide or hydrocarbons, other than methane, and the waste gas is vented to the atmosphere in the baseline situation, project emissions have to include CO2 emissions due to the combustion of the waste gas. No waste gas is combusted during the project activity. Therefore, the project emission will only comprise the baseline emissions from auxiliary fuel and electricity consumption of the project equipment. The only project equipment that is not driven by the self consumption by the power plant and thereby reduces the electricity sent to the grid, but consumes electricity from a separate line and diesel in cases of grid load sheds are the pumps that provide water for the project. The emissions caused by the energy consumption the pumps can be expressed as: ! = !" ,!,! + !" ,! Where: ! !" ,!,! !" ,! Project emissions during the year y in tons of CO2. Are the CO2 emissions from fossil fuel combustion in process j during the year y (tCO2/yr); Project emissions from electricity consumption in year y (tCO2/yr) 3

The emissions from electricity consumption can be calculated following the Tool to calculate baseline, project and/or leakage emissions from electricity consumption, version 01. As the electricity is consumed from the grid, scenario A, described in this tool is applicable and the project emissions from electricity consumption will be calculated accordingly: 4

!" ,! =
!

!",!,! !",!,! (1 + !,! )

Where: !" ,! !",!,! !",!,!

Project emissions during the year y in tons of CO2. Quantity of electricity consumed by the project electricity consumption source j in year y (MWh/yr) Emission factor for electricity generation for source j in year y (tCO2/MWh). In this one case, this factor is the grid emission factor of the KESC grid !"#$,!,!,! and will be calculated in Annex 3.

Cited from AMS-III.Q Waste energy recovery (gas/heat/pressure) projects, v.04, p.11

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!,! j

Average technical transmission and distribution losses for providing electricity to source j in year y. In line with the tool, a conservative standard factor of 20% is assumed here. Sources of electricity consumption in the project. Here only the pumps are considered as source of electricity consumption, therefore j is 1.

To calculate the project emissions due to fossil fuel consumption during grid load sheds, the carbon emission from the diesel generators are calculated following the Tool to calculate project or leakage CO2 emissions from fossil fuel combustion, version 02: !" ,!,! = !,!,! !,! Where: !" ,!,! !,!,! !,! i j 5

Are the CO2 emissions from fossil fuel combustion in process j during the year y (tCO2/yr); Is the quantity of fuel type i combusted in process j during the year y (mass or volume unit/yr); Is the CO2 emission coefficient of fuel type i in year y (tCO2/mass or volume unit) Are the fuel types combusted in process j during the year y. As only diesel is used in the generators, i is 1. Fossil fuel combusting process. As only the diesel generators consume fossil fuel, j is 1.

To calculate the emission coefficient, the emission factor of diesel and its NCV are used: !,! = !,!,! !"! ,!,! Where: !,! !,!,! !"! ,!,! 6

Is the CO2 emission coefficient of fuel type i in year y (tCO2/mass or volume unit) Is the weighted average net calorific value of the fuel type i in year y (GJ/mass or volume unit) Is the weighted average CO2 emission factor of fuel type i in year y (tCO2/GJ)

Leakage Since no transfer of equipment is considered in the project activity, the leakage is zero. ! = 0 Emission reduction With the data calculated above, the emission reduction can be calculated: ! = ! ! LE! = ! ! 8 7

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B.6.2. Data and parameters that are available at validation: Data / Parameter: Data unit: Description: Source of data used: Value applied: Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description: Source of data used: Value applied: Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description: Source of data used: Value applied: !"#$,!,!,! tCO2/MHh Emission factor of the grid Pakistan Energy Yearbook, Ministry of Minerals & Natural Resources 0.595 Calculated as per Tool to calculate the emission factor for an electricity system v. 2.2.1. For the detailed way of calculation, see Annex 3.

!,! Average technical transmission and distribution losses for providing electricity to source j in year y Tool to calculate baseline, project and/or leakage emissions from electricity consumption 20% The default value of 20% will not be measured, but chosen in line with the methodology.

!"#,!" kg of energy carrying medium Average quantity of WECM released (or flared or wasted) in atmosphere in three years prior to the start of the project activity. Calculated from emission records Year 1 prior to the project activity: 7,088,493,600 Year 2 prior to the project activity: 7,132,089,600 Year 3 prior to the project activity: 6,768,691,200 Calculated from data based on gas temperature, pressure and composition.

Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment:

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Data / Parameter: Data unit: Description: Source of data used: Value applied:

Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description: Source of data used: Value applied:

!"#,!" TJ/kg/deg C Specific Heat of waste energy carrying medium vented from the preheaters and coolers of the two production lines. Calculated from emission records Line 1: Preheater: 1.05E-09 Cooler: 1.04E-09 Line 2: Preheater: 1.05E-09 Cooler: 1.04E-09 Calculated from data based on gas composition.

Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description: Source of data used: Value applied:

!"#,! TJ/kg/deg C Specific Heat of waste energy carrying medium vented from the preheaters and coolers of the two production lines. Calculated from emission records Line 1: Preheater: 1.05E-09 Cooler: 1.04E-09 Line 2: Preheater: 1.05E-09 Cooler: 1.04E-09 Calculated from data based on gas composition.

!"#,!" deg C Average temperature of Waste Energy Carrying Medium (WECM) vented from the preheaters and coolers of the two production lines in three years prior to the start of the project activity. Calculated from emission records One year prior to project activity Two years prior to project activity Three years prior to project activity

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Line 1 Preheater Line 1 Cooler Line 2 Preheater Line 2 Cooler

393 290 339 409

397 284 343 372

391 274 332 341

Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description: Source of data used: Value applied: Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description:

Calculated from temperature data.

!"# deg C Reference temperature to be used to determine available energy in WECM. Chosen according to methodology. 25 Chosen according to methodology.

!"#,! TJ/kg Average net calorific value of waste gas in year y (if WECM is waste gas), which has unburnt components such as carbon particles, CO or CH4 that will provide energy in waste energy recovery equipment on combustion of gas. 0 As the WECM is not waste gas, the applied value is 0.

Source of data used: Value applied: Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment:

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Data / Parameter: Data unit: Description:

!"#,!" TJ/kg Average net calorific value of waste gas (if WECM is waste gas), three years prior to implementation of project activity which has unburnt components such as carbon particles, CO or CH4 that will provide energy in waste energy recovery equipment on combustion of gas. 0 As the WECM is not waste gas, the applied value is 0.

Source of data used: Value applied: Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description: Source of data used: Value applied:

!"#,!" kg/cm2 Average pressure of WECM vented from the preheaters and coolers of the two production lines in three years prior to the start of the project activity.

One year prior to project activity Line 1 Preheater Line 1 Cooler Line 2 Preheater Line 2 Cooler 0.972 1.03 0.973 1.03

Two years prior to project activity 0.972 1.03 0.973 1.03

Three years prior to project activity 0.975 1.03 0.973 1.03


Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Data / Parameter: Data unit: Description: Measurement records.

!"#,!" kg/m3 Average density of WECM vented from the preheaters and coolers of the two production lines at actual temperature and pressure in three years prior to the start of the project activity.

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Source of data used: Value applied: One year prior to project activity Line 1 Preheater Line 1 Cooler Line 2 Preheater Line 2 Cooler 0.6 0.66 0.65 0.51 Two years prior to project activity 0.59 0.63 0.65 0.54 Three years prior to project activity 0.6 0.64 0.66 0.57


Justification of the choice of data or description of measurement methods and procedures actually applied : Any comment: Calculated based on measurement records.

B.6.3 Ex-ante calculation of emission reductions: >> According to B.6.1, the emission reductions are defined as:

ERy = BE y PE y LE y = BE y PE y = fcap fwcm ( EGi, j, y EFElec,i, j, y )


j i

( ECPJ , y EFElec,i, j, y (1 + TDLy ) + FCy NCVy EFCO2 , y )


with the following input values used: Abbreviation !"# !"# Description Capping factor to exclude increased waste energy utilization in the project year y due to increased level of activity of the plant Fraction of total electricity generated by the project activity using waste energy. With reference to the methodology, this factor is considered 1 as the electricity generated is driven purely by utilization of waste heat. The quantity of electricity supplied to the recipient j by generator, that in the absence of the project activity would Value 1 1 Unit 1 1

!,!,!

58,320

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!"#$,!,!,! !",! ! ! ! !"! ,! Therefore:

have been sourced from ith source (i can be either grid or identified source) during the year y in MWh. The CO2 emission factor for the electricity source i (i=gr (grid) or i=is (identified source)), displaced due to the project activity, during the year y in tons CO2/MWh Quantity of electricity consumed by the project electricity consumption source j in year y (MWh/yr) Average technical transmission and distribution losses for providing electricity to source j in year y. In line with the tool, a conservative standard factor of 20% is assumed here. Is the quantity of fuel type i combusted in process j during the year y NCV of Diesel consumed by the project Default CO2 emission factor for diesel combustion

0.595 387.60 20% 19,175 43.3 74,800

! / MWh l TJ/Gg Kg/TJ

! = 34,417 ! e B.6.4 Summary of the ex-ante estimation of emission reductions: >> Total ex ante estimation of emission reductions: Year Estimation of project activity emissions (tCO2e) 283 283 283 283 283 283 283 283 283 283 2,830 Estimation of baseline emissions (tCO2e) 34,700 34,700 34,700 34,700 34,700 34,700 34,700 34,700 34,700 34,700 347,000

10

Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Total (tonnes of CO2e) B.7

Estimation of Estimation of leakage (tCO2e) overall emission reductions (tCO2e) 0 34,417 0 34,417 0 34,417 0 34,417 0 34,417 0 34,417 0 34,417 0 34,417 0 34,417 0 34,417 0 344,170

Application of a monitoring methodology and description of the monitoring plan:

B.7.1 Parameter:

Data and parameters monitored: EGi,j,y

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Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment: Parameter: Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied:

MWh Quantity of electricity supplied by the project activity during the year y. Continuous on-site measurements Will be monitored ex-post Electricity meters

The electricity meters will undergo maintenance/calibration according to national and industrial standards.

QA/QC procedures to be applied (if any): Any comment:

ECPJ,j,y MWh Quantity of grid electricity consumed by the water pumps Continuous on-site measurements 387.60 During normal operation of the plant, the pumps that will provide water will be operated by grid electricity. Since the pumps will not only provide the electricity to the WHRS plant, but also to the cement factory, the consumption of electricity caused by the WHRS will be determined by the electricity consumption of the pumps scaled with the share of water that will be consumed by the WHRS plant. The electricity meters will undergo maintenance/ calibration according to industrial standards.

Parameter: Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment: Parameter: Unit: Description: Source of data: Value of data: Brief description

!,!,! litres Is the quantity of fuel type i combusted in process j during the year y Diesel transportation bills between the central storage tank and the pumping station. 25,188.60 During normal operation of the plant, the pumps that will provide water will be operated by grid electricity. During load sheds, a diesel-driven generator will provide electricity. The diesel consumption will be monitored annually. All bills will be signed by the responsible staff and collected centrally for data archiving.

of

!,!,! TJ/Gg NCV of Diesel consumed by the project IPCC2006. The chosen value reflects the conservative upper limit of the 95% confidence interval. 43.3 New IPCC publications will be checked and values be updated if necessary.

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measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment:

Parameter: Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment: Parameter: Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment: Parameter: Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any):

!"! ,!,! kg/TJ Default CO2 emission factor for diesel combustion IPCC2006. The chosen value reflects the conservative upper limit of the 95% confidence interval. 74,800 New IPCC publications will be checked and values be updated if necessary.

!"#,! Tonnes of energy carrying medium Average quantity of WECM released (or flared or wasted) in atmosphere in year y. Continuous on-site measurements Will be monitored ex-post Measurements of gas temperature and pressure.

The meters will undergo maintenance/ calibration according to industrial standards.

!"#,! deg C Average temperature of Waste Energy Carrying Medium (WECM) vented from the preheaters and coolers of the two production lines in year y. Continuous on-site measurements Will be monitored ex-post Measurements of gas temperature.

The meters will undergo maintenance/ calibration according to industrial standards.

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Any comment: Parameter: Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment: Parameter: Unit: Description: Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment: Parameter: Unit: Description: !"#,! kg/cm2 Average pressure of WECM vented from the preheaters and coolers of the two production lines in year y. Continuous on-site measurements Will be monitored ex-post Measurements of gas pressure.

The meters will undergo maintenance/ calibration according to industrial standards.

!"#,! kg/m3 Average density of WECM vented from the preheaters and coolers of the two production lines at actual temperature and pressure in year y. Continuous calculation based on on-site measurements. Will be monitored ex-post Calculation based on temperature and pressure.

The meters will undergo maintenance/ calibration according to industrial standards.

Source of data: Value of data: Brief description of measurement methods and procedures to be applied: QA/QC procedures to be applied (if any): Any comment: B.7.2

!"# 1 Average density of WECM vented from the preheaters and coolers of the two production lines at actual temperature and pressure in three years prior to the start of the project activity. Continuous calculation based on on-site measurements. Will be monitored ex-post Calculation according to the mathematical procedures described above.

The meters will undergo maintenance/ calibration according to industrial standards.

Description of the monitoring plan:

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>> For the operation of the Waste Heat Recovery Power Plant and monitoring of all the parameters, ACPL has adopted the following procedures: a) Responsibility of the Project Management ACPL will be responsible for the execution of the monitoring plan. It will collect and store relevant data in a systematic and reliable way, evaluate them regularly and ensure the availability of all the relevant information for verification. Both paper and an electronic spreadsheet file will be kept for record keeping. ACPL shall manage all monitored variables and will regularly present the same to the DOE for verification. b) Quality Assurance and Quality Control The WHR Power Plant shall be considered as a separate section and effectively controlled by section incharge under the supervision of GM (Works). The quality assurance and quality control for recording, maintaining and archiving data shall be maintained by ACPL. It will also make sure that it provides the staff in charge of data collection and monitoring with necessary training opportunities to enhance their job skills and efficiencies. c) On-site Procedures Operation and Maintenance Logs (O&M) Daily operational parameters will be logged and maintained for each equipment such as boilers, turbine and generator by the operator on real time basis. The maintenance of each equipment will be recorded in the history file of each equipment. This will be reviewed by the section incharge on a regular basis. Any event of significance will be reported and recorded in a special log, which will be reviewed by relevant Senior Staff Members on regular basis. Operation and Maintenance Report The Section In-charge of WHR Power plant shall prepare a monthly report on the performance of WHR Power Plant and submit the same to top management for their review and comments. The report will include the following topics: - Summary - Production achieved - Major cost elements - Stoppages report - Accidents, malfunctions and remedial measure taken - Safety and environment - Meter records - Any other material information Procedure for handling of erroneous measurement, monitoring data adjustment and data uncertainty Respective Area supervisors are responsible for reporting and erroneous measurement, and any uncertainty of parameters. The report will be sent to the section incharge for review and further action.

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Any erroneous measurement and uncertainty found will be recorded and the section incharge will be required to immediate corrective actions under the supervision of GM (Works). Procedure for training of monitoring staff ACPL has detailed training programs for the relevant staff based on their technical knowledge requirements that will help them to ensure smooth operations of the plant. When new equipment is installed and/or the maintenance for the monitoring equipment is carried out, training for the proper management and operation of the equipment will be provided to the operators. Procedure for handling of emergencies situations In accordance with the internal regulations, an Emergency Management Plan will be prepared. Personal safety appliances will be provided to the shift operators according to their requirements. Regular training for safety is provided to the shift operators by the Safety Incharge during the regular training as mentioned above. Data Storage and Filing Electric Workbook All relevant data will be monitored and electronically stored at least 2 years after the end of the crediting periods. d) Operational and Management structure The tentative operational and management structure of the personnel who will be involved in the project activity is shown below:

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While the structure of the CDM responsibilities are displayed in a separate chart:

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B.8 Date of completion of the application of the baseline and monitoring methodology and the name of the responsible person(s)/entity(ies) >> Date of completion of the application of the baseline and monitoring methodology: 11/11/2010 Henning Huenteler Senior CDM Services Manager UPM Umwelt-Projekt-Management GmbH PRC 100125 Beijing Chaoyang District 42 Liangmaqiao Road Guangming Hotel 0708 (B) hhuenteler@upm-cdm.eu UPM Umwelt-Projekt Management GmbH is a project participant as listed in section A.3 and Annex 1. SECTION C. Duration of the project activity / crediting period C.1 Duration of the project activity:

C.1.1. Starting date of the project activity: >> 13/05/2010 (Date of signature of main equipment purchase contract, it is the earliest date of real action of the project) C.1.2. Expected operational lifetime of the project activity: >> 20 years, 0 months C.2 Choice of the crediting period and related information: A fixed crediting period is chosen. The relevant information is given in section C.2.2. C.2.1. Renewable crediting period C.2.1.1. >> Not applicable C.2.1.2. >> Not applicable Length of the first crediting period: Starting date of the first crediting period:

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C.2.2. Fixed crediting period: C.2.2.1. >> 15/05/2012 C.2.2.2. >> 10 years, 0 months Length: Starting date:

SECTION D. Environmental impacts >> D.1. If required by the host Party, documentation on the analysis of the environmental impacts of the project activity: >> Electric power will be produced by using the heat going waste in the exhaust gases of two coolers and two preheaters of the already operational two cement lines. Therefore, the adoption of this technology will contribute positively to conserve resource (heat) so far going waste while at the same time it will further improve the environment. M/S HCRDI, China will supply technology/plant. The total covered area for the power plant will be 1500 m2. No fuel will be used as waste heat of the exhaust gases from two pre-heaters and two clinker coolers of the already two operational cement lines will be used. Resultantly, there will not be any emissions of gases into the atmosphere. Further, the process will result in lowering of the temperature of the discharged flue gases, thus avoiding the phenomenon of "heat island". The cooling water requirement will be about 4,500 m3 for one time charging in the cooling circuit of the plant and 106 m3/h will be used as make-up water for the minor windage / cooling losses. Effluent from all the areas of power plant including cooling tower and the sewage from toilets will be mixed up with the effluent from the already operational cement plant and power plant and after its anaerobic treatment it will be reused within the battery limits of the plant area for irrigation of vegetation, trees, plants and sprinkling on road sides to minimize fugitive dust. There will be no contribution of sulphur dioxide (SO2), Nitrogen Oxides (NOx), Carbon monoxide (CO) and Particulate Matter (PM) from the power plant will not take place due to the fact that heat from the waste gases (flue gases) of two coolers and two preheaters of the already operational cement plant presently going waste, will be harnessed through use of Heat Exchangers (HEs). This heat will be used for the power plant. Resultantly, zero emissions from the power plant will be achieved. Solid wastes, to be generated from power generation activity, will be disposed off in environmentally sustainable fashion. The plant inbuilt mechanism will help restrict the noise levels below their limiting value of 85 dB(A) as prescribed by the National Environment Quality Standards (NEQS). Additionally, because the plant is to be housed in a closed building, there will be further drastic cut in noise levels. From the IEE (Initial Environmental Evaluation), it is concluded that the project requires only IEE and there is no need of environmental studies in the form of an Environmental Impact Assessment (EIA).

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D.2. If environmental impacts are considered significant by the project participants or the host Party, please provide conclusions and all references to support documentation of an environmental impact assessment undertaken in accordance with the procedures as required by the host Party: >> As described above, it is expected that there will be no significant negative environmental impacts associated with the Project activity. Therefore, no EIA going further than the IEE-Report is necessary. Additionally, Attock Cement Pakistan Ltd. will adopt measures to implement the issued recommended in the IEE report. SECTION E. Stakeholders comments >> E.1. Brief description how comments by local stakeholders have been invited and compiled: >> A formal stakeholder meeting was conducted on August 03, 2010 at Officers Mess of ACPL after the event was published by public notices on the 28th of July on the factory gate, the workers union office and the public market near the project site. A list of the meeting participants is presented on page 49. During the meeting brief project description, likely environmental and socio-economic impacts, their mitigation measures and project alternatives were defined to the stakeholders. After description of the project, participants were to encourage asking the question regarding the project environmental, socio- economic impacts and their mitigation measures. Their queries are incorporated to this section. After the introduction of the project, the stakeholders have filled out questionnaires regarding their opinion towards the project. A summary of all answers can be reviewed in chapter E.2.

E.2. Summary of the comments received: >> The questionnaires comprised eleven questions. A total number of 20 questionnaires have been returned by the stakeholder meeting participants. The results are displayed in the following table: Question Do you understand the nature of the project Do you understand the positive impacts of this project Do you understand the negative impacts of this project Do you think this project is beneficial for the common man What you think are the advantages of this project What you think are the disadvantages of this project Do you think advantages are more than disadvantages Yes No 20 0 20 0 17 3 19 1 Majority people said that this project is for the industrial growth & give them job opportunities. Majority people said that this project has no disadvantages. 18 2

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What is your impression regarding this meeting

What you like about this project

What you do not like about this project Do you think this project should be initiated?

People said that this type of meeting will be conducted in future again as this provide us the project details and their positive and negative impacts. Some said this will increase the production and some said that generation of electricity through this reduces the electricity dependence. Turbine noise although the impact is localized. 20 0

E.3. Report on how due account was taken of any comments received: >> One local resident addressed a concern during the meeting. Although the turbine will be located within the factory area, people were concerned about noise pollution that might be generated. However, according to the IEE, the noise level generated by the turbine will stay well below the national restrictions and will be decreased even further as the turbine is installed within a closed building8: The plant inbuilt mechanism will help restrict the noise levels below their limiting value of 85 dB(A) as prescribed by the National Environment Quality Standards (NEQS). Additionally, because the plant is to be housed in a closed building, there will be further drastic cut in noise levels.

Cited from Initial Environmental Evaluation.

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Annex 1 CONTACT INFORMATION ON PARTICIPANTS IN THE PROJECT ACTIVITY Organization: Attock Cement Pakistan Ltd. Street/P.O.Box: D-70, Block 4,Kehkashan-5 Building: City: Clifton Karachi State/Region: Postfix/ZIP: 75600 Country: Pakistan Telephone: FAX: E-Mail: URL: Represented by: Irfan Amanullah Title: General Manager Salutation: Mr. Last Name: Amanullah Middle Name: First Name: Irfan Department: Finance & Coordination Mobile: 0092-301-8284446 Direct FAX: 0092-21-3530-9775 Direct tel: 0092-21-3530-9819 Personal E-Mail: irfan@attockcement.com

Organization: Street/P.O.Box: Building: City: State/Region: Postfix/ZIP: Country: Telephone: FAX: E-Mail: URL: Represented by: Title: Salutation: Last Name: Middle Name: First Name: Department: Mobile: Direct FAX:

UPM Umwelt-Projekt-Management GmbH Lamonstrasse 11 Munich 81679 Germany +49 89 41419690 +49 89 41419692 ngarbers@upm-cdm.eu www.upm-cdm.eu Norbert Garbers Managing Partner Mr. Garbers Norbert

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Direct tel: Personal E-Mail:

ngarbers@upm-cdm.eu

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Annex 2 INFORMATION REGARDING PUBLIC FUNDING

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Annex 3 BASELINE INFORMATION Calculation of the grid emission factor To calculate the last factor of equation (1), the Tool to calculate the emission factor for an electricity system has to be used. Following the tool, this factor is calculated as a combined margin (CM), consisting of the simple average of the operating margin emission factor (OM) and the build margin (BM) emission factor by utilizing an ex-ante 3-year data period: !"#$,!",! = !"#$,!",! !" + !"#$,!",! !" With the input values: !"#$,!",! Combined margin grid emission factor in year y (tCO2/MWh) !"#$,!",! Operation margin grid emission factor in year y (tCO2/MWh) !"#$,!",! Build margin grid emission factor in year y (tCO2/MWh) Weighting of operation margin factor (%) !" Weighting of build margin factor (%) !" For the calculation of these input values, the Tool to calculate the emission factor for an electricity system describes seven steps: STEP 1. Identify the relevant electricity systems. STEP 2. Choose whether to include off-grid power plants in the project electricity system (optional). STEP 3. Select a method to determine the operating margin (OM). STEP 4. Calculate the operating margin emission factor according to the selected method. STEP 5. Identify the group of power units to be included in the build margin (BM). STEP 6. Calculate the build margin emission factor. STEP 7. Calculate the combined margin (CM) emissions factor. Step 1: Identify the relevant electricity systems Pakistan comprised two electricity grids, the Karachi Electric Supply Company (KESC) grid and the national electricity grid, managed by the Water and Power Development Authority (WAPDA). The national grid covers the whole of Pakistan, except the city of Karachi, which is supplied by the KESC grid. The proposed project will be connected to the national electricity grid. According to the Tool to calculate the emission factor for an electricity system, the project electricity system can be identified as the national grid. By the spatial extent of the power plants that are physically connected through transmission and distribution lines to the project activity (e.g. the renewable power plant location or the consumers where electricity is being saved) and that can be dispatched without significant transmission constraints. According to the KESC website, 620 MW out of the total 2,350 MW capacity of the KESC electricity is provided by imports from the WAPDA grid. Therefore, the operation margin will be applied as weighted average of the both grids, using the capacity figures published on the KESC website as weighting factor. The spatial extend of the build margin is limited to the project electricity system, as per definition of the tool. 11

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Electricity exports are not subtracted from the electricity generation data, as advised in the Tool to calculate the emission factor for an electricity system. Step 2: Choose whether to include off-grid power plants in the project electricity system (optional) According to Option I of step 2, off-grid power plants are not included in the calculation. Step 3: Select a method to determine the operating margin (OM) Four alternatives for the calculation of OM are given in the tool: a) Simple OM; or b) Simple adjusted OM; or c) Dispatch data analysis OM; or d) Average OM. The KESC grid does not include any low-cost/must-run resources as per the definition of the used tool. Therefore, the Simple OM method can be chosen to determine the operation margin. For the WAPDA grid, the share of low-cost/must-run resources was not above 50% in the last three years. Therefore, for the WAPDA grid also the Simple OM method is applied. Two ways of calculating the operating margin can be applied according to the EB guideance9: Ex ante option: If the ex ante option is chosen, the emission factor is determined once at the validation stage, thus no monitoring and recalculation of the emissions factor during the crediting period is required. For grid power plants, use a 3-year generation-weighted average, based on the most recent data available at the time of submission of the CDM-PDD to the DOE for validation. For off-grid power plants, use a single calendar year within the 5 most recent calendar years prior to the time of submission of the CDM-PDD for validation. Ex post option: If the ex post option is chosen, the emission factor is determined for the year in which the project activity displaces grid electricity, requiring the emissions factor to be updated annually during monitoring. If the data required to calculate the emission factor for year y is usually only available later than six months after the end of year y, alternatively the emission factor of the previous year y-1 may be used. If the data is usually only available 18 months after the end of year y, the emission factor of the year proceeding the previous year y-2 may be used. The same data vintage (y, y-1 or y-2) should be used throughout all crediting periods. For the proposed project, the ex ante option is chosen. The grid emission factor is calculated prior to the project registration based on the latest available data (2008 2010). Step 4: Calculate the operating margin emission factor according to the selected method The simple OM emission factor is calculated as the generation-weighted average CO2 emissions per unit net electricity generation (tCO2/MWh) of all generating power plants serving the system, not including low-cost/must-run power plants/units.

Cited from Tool to calculate the emission factor for an electricity system, v.2.2.1, pp.5-6

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Two ways of calculation are described in the tool10: Option A: Based on the net electricity generation and a CO2 emission factor of each power unit; or Option B: Based on the total net electricity generation of all power plants serving the system and the fuel types and total fuel consumption of the project electricity system. Whereas Option B can only be applied if: a) The necessary data for Option A is not available; and b) Only nuclear and renewable power generation are considered as low-cost/must-run power sources and the quantity of electricity supplied to the grid by these sources is known; and c) Off-grid power plants are not included in the calculation (i.e., if Option I has been chosen in Step 2). The electricity generation, fuel type and fuel consumption are available for all connected power plants. Therefore, option A can be chosen to calculate the operation margin. In this option, the net electricity generation of each power unit and its emission factor shall be used for the calculation:
! !,!

!"#$,!"#$%&'(,! = Where: !"#$,!"#$%&'(,! !,! !,! m y

!,! ! !,!

12

Simple operating margin CO2 emission factor in year y (tCO2/MWh) Net quantity of electricity generated and delivered to the grid by power unit m in year y (MWh) CO2 emission factor of power unit m in year y (tCO2/MWh) All power units serving the grid in year y except low-cost / must-run power units The relevant year as per the data vintage chosen in Step 3.

To determinate the emission factor for each power unit, again several options are offered by the tool. As for all power units m data on fuel consumption and electricity generation is available (as required by option A), the first alternative is chosen: !,! =
!

!,!,! !,! !"! ,!,! !,!

13

!,! !,!,! !,! !"! ,!,!


10

CO2 emission factor of power unit m in year y (tCO2/MWh) Amount of fossil fuel type i consumed by power unit m in year y (mass or volume unit) Net calorific value (energy content of fossil fuel type i in year y (GJ/mass or volume unit) CO2 emission factor of fossil fuel type i in year y (tCO2/GJ)

Cited from Tool to calculate the emission factor for an electricity system, v.2.2.1, p.6

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! y

Net electricity generated and delivered to the grid by all power sources serving the system, not including low-cost/most-run power plants/units, in year y (MWh) All fossil fuel types combusted in power sources in the project electricity system in year y The relevant year as per the data vintage chosen in Step 3.

As a result of this calculation11, the simple operation margin for the year 2010 is: !"#$ ,!"#$%&'(,!"!" = 0.589 ! 14 ! 15

!"#$",!"#$%&'(,!"!" = 0.675

With these two factors and a weighting of the two grids of 620 MW to 2,350 MW, the combined grid emission factor is: !"#$%&'(,!"#$%&'(,!"#" = 0.612 ! 16

Step 5: Identify the group of power units to be included in the build margin The Tool to calculate the emission factor for an electricity system provides two approaches to identify the group of plants that will be included in the calculation of the build margin12: a) The set of five power units that have been built most recently;or b) The set of power capacity additions in the electricity system that comprise 20% of the system generation (in MWh) and that have been built most recently. Project participants should use the set of power units that comprises the larger annual generation. As a general guidance, a power unit is considered to have been built at the date when it started to supply electricity to the grid. Since it comprises the larger annual generation, for the proposed project, the second approach (b) is chosen. For the calculation of the operation margin, the latest available data is the average data from 2008 to 2010. For new plants, data that is more accurate is available. For the terms of data vintage, the tool offers two options13: Option 1: For the first crediting period, calculate the build margin emission factor ex ante based on the most recent information available on units already built for sample group m at the time of CDM-

11 12 13

All relevant input values and calculations will be provided to the DOE(s) during validation and verification. Cited from Tool to calculate the emission factor for an electricity system, v.2.2.1, p.14 Cited from Tool to calculate the emission factor for an electricity system, v.2.2.1, p.15

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PDD submission to the DOE for validation. For the second crediting period, the build margin emission factor should be updated based on the most recent information available on units already built at the time of submission of the request for renewal of the crediting period to the DOE. For the third crediting period, the build margin emission factor calculated for the second crediting period should be used. This option does not require monitoring the emission factor during the crediting period. Option 2: For the first crediting period, the build margin emission factor shall be updated annually, ex post, including those units built up to the year of registration of the project activity or, if information up to the year of registration is not yet available, including those units built up to the latest year for which information is available. For the second crediting period, the build margin emissions factor shall be calculated ex ante, as described in Option 1 above. For the third crediting period, the build margin emission factor calculated for the second crediting period should be used. The option chosen should be documented in the CDM-PDD. For the proposed project, option 1 is chosen and the build margin will calculated once before the project is registered. As for the operation margin, the result will be used for the entire crediting period. Step 6: Calculate the build margin emission factor According to the Tool to calculate the emission factor for an electricity system, the build margin emissions factor is the generation-weighted average emission factor of all power units m during the most recent year y, for which power generation data is available. It can be calculated using the following formula: !"#$,!",! = Where: !"#$,!",! !,! !",!,! m y
! !,!

!",!,! ! !,!

17

Build margin CO2 emission factor in year y (tCO2/MWh). Net quantity of electricity generated and delivered to the grid by power unit m in year y (MWh). CO2 emission factor of power unit m in year y (tCO2/MWh). Power units included in the build margin. Most recent historical year for which power generation data is available.

Whereas14: The CO2 emission factor of each power unit m (FEEL,m,y) should be determined as per the guidance in Step 4 (a) for the simple OM, using options A1, A2 or A3, using for y the most recent historical year for which power generation data is available, and using for m the power units included in the build margin. As a result of this calculation15, the build margin for 2010 is:

14 15

Cited from Tool to calculate the emission factor for an electricity system, v.2.2.1, p.16 All relevant input values will be provided to the DOE(s) during validation and verification.

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!"#$ ,!",!"#" = 0.579 ! /

18

Step 7: Calculate the combined margin emissions factor As described above, the combined margin emission factor for an electricity system is calculated using the following formula: !"#$,!",! = !"#$,!",! !" + !"#$,!",! !" 19

The weighting factors !" and !" are defined by the Tool to calculate the emission factor for an electricity system16: Wind and solar power generation project activities: wOM = 0.75 and wBM = 0.25 (owing to their intermittent and non-dispatchable nature) for the first crediting period and for subsequent crediting periods; All other projects: wOM = 0.5 and wBM = 0.5 for the first crediting period , and wOM = 0.25 and wBM = 0.75 for the second and third crediting period,9 unless otherwise specified in the approved methodology which refers to this tool.

As the proposed project is no wind or solar power generation project, the combined emission factor for the national grid in Pakistan is: !"#$,!",!"#" = 0.612 ! ! ! 0.5 + 0.579 0.5 = 0.595 20

16

Cited from Tool to calculate the emission factor for an electricity system, v.2.2.1, p.16

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Annex 4 MONITORING INFORMATION ----

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A. List of Stakeholder Meeting Participants

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