Project On ONGC Validation

VALIDATION REPORT
51 MW wind power project of ONGC at Surajbari, Gujarat in India
REPORT NO. 2008-0065

REVISION NO. 02
DET NORSKE VERITAS
DET NORSKE VERITAS
VALIDATION REPORT
Date of first issue: Project No.: DET NORSKE VERITAS CERTIFICATION AS
Veritasveien 1, 1322 HVIK, Norway Tel: +47 67 57 99 00 Fax: +47 67 57 99 11 http://www.dnv.com Org. No: NO 945 748 931 MVA
17-12-2008
Approved by:
PRJC-105320-2008-CCS-IND
Organisational unit:
Michael Lehmann
Client:
Climate Change Services

Client ref.:
Oil and Natural Gas Corporation Limited
Mr. Ashok B. Chakraborty
Project Name: 51 MW wind power project of ONGC at Surajbari, Gujarat in India Country: India Methodology: ACM0002 Version: 07 GHG reducing Measure/Technology: Grid connected renewable electricity generation ER estimate: 85 762 t CO2 per year. Size Large Scale Small Scale Validation Phases: Desk Review Follow up interviews Resolution of outstanding issues Validation Status Corrective Actions Requested Clarifications Requested Full Approval and submission for registration Rejected In summary, it is DNVs opinion that the 51 MW wind power project of ONGC at Surajbari, Gujarat in India, as described in the PDD, version 04 of 16 February 2010, meets all relevant UNFCCC requirements for the CDM and all relevant host Party criteria and correctly applies the baseline and monitoring methodology ACM0002 version 07. DNV thus requests the registration of the project as a CDM project activity.
Report No.: Date of this revision: Rev. No. Key words:
2008-0065
Report title:
2010-02-22
02
51 MW wind power project of ONGC at Surajbari, Gujarat in India in India

Work carried out by:
Climate Change Kyoto Protocol Validation Clean Development Mechanism

No distribution without permission from the Client or responsible organisational unit Limited distribution Unrestricted distribution
Shivraj Sharma, G. Murali, Ravi Kumar Prabhu

Work verified by:
Kakaraparthi Venkata Raman (Draft) Anjana Sharma (Final)
DET NORSKE VERITAS DNV report No: 2008-0065, rev. 02 VALIDATION REPORT
Abbreviations
BM CAR CDM CEA CEF CER CL CO2 CO2e CM CUF DNV DNA DPR EB EPC GEDA GETCO GHG GWP GWh IRR IPCC kWh MW MP NGO ODA O&M OM ONGC PDD PLF PPA SEL UNFCCC WEG Build Margin Corrective Action Request Clean Development Mechanism Central Eclectricity Authority Carbon Emission Factor Certified Emission Reduction Clarification request Carbon dioxide Carbon dioxide equivalent Combined Margin Cost Utilization Factor Det Norske Veritas Certification AS Designated National Authority Detailed Project Report Executive Board Engineering, Procurement and Construction Gujarat Energy Development agency Gujarat Energy Transmission Corporation Ltd. Greenhouse gas(es) Global Warming Potential Giga Watt Hour Internal Rate of Return Intergovernmental Panel on Climate Change Kilo Watt hour Mega Watt Monitoring Plan Non-governmental Organization Official Development Assistance Operation and Maintenance Operating Margin Oil and Natural Gas Corporation Ltd. Project Design Document Plant Load Factor Power Purchase Agreement Suzlon Energy Limited United Nations Framework Convention on Climate Change Wind Energy Generators
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TABLE OF CONTENTS
1 2 2.1 2.2 3 3.1 3.2 3.3 3.4 3.5 4 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 EXECUTIVE SUMMARY VALIDATION OPINION ..........................................1 INTRODUCTION ....................................................................................................2 Objective 2 Scope 2 METHODOLOGY ...................................................................................................3 Desk Review of the Project Design Documentation 3 Follow-up Interviews with Project Stakeholders 5 Resolution of Outstanding Issues 5 Internal Quality Control 7 Validation Team 7 VALIDATION FINDINGS ......................................................................................8 Participation Requirements 8 Project Design 8 Baseline Determination 9 Additionality 10 Monitoring 15 Estimate of GHG Emissions 16 Environmental Impacts 16 Comments by Local Stakeholders 16 Comments by Parties, Stakeholders and NGOs 16
Appendix A: Validation Protocol Appendix B: Certificates of Competence
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1 EXECUTIVE SUMMARY VALIDATION OPINION

Det Norske Veritas Certification AS (DNV) has performed a validation of the 51 MW wind power project of ONGC at Surajbari, Gujarat in India. The validation was performed on the basis of UNFCCC criteria for the Clean Development Mechanism and host Party criteria, as well as criteria given to provide for consistent project operations, monitoring and reporting. The review of the project design documentation and the subsequent follow-up interviews have provided DNV with sufficient evidence to determine the fulfilment of stated criteria. The host Party is India and project participant is Oil and Natural Gas Corporation Ltd (ONGC). No Annex I Party is involved in the project at this stage. The Host Party India fulfils the participation criteria and has approved the project and authorized the project participant. The DNA of India confirmed that the project assists in achieving sustainable development. The project correctly applies ACM0002 Consolidated baseline methodology for grid connected electricity generation from renewable sources, version 7. The project involves generation of renewable energy by installing wind turbine generators (WTGs), which will displace the electricity generation in the fossil fuel dominated Western regional grid of India, thereby resulting in the reduction of GHG emissions that are real, measurable and give longterm benefits to the mitigation of climate change. It is demonstrated that the project is not a likely baseline scenario. Emission reductions atributable to the project are hence additional to any that would occur in the absence of the project activity. The total emission reductions from the project are estimated to be on the average 85 762 tCO2e per year over the selected 7 year renewable crediting period. The emission reduction forecast has been checked, and it is deemed likely that the stated amount is achieved given that the underlying assumptions do not change. The monitoring plan makes sufficient provision for monitoring relevant project and baseline emission indicators. Detailed responsibilities and authorities for project management, monitoring and reporting and QA/QC procedures have also been addressed. In summary, it is DNVs opinion that the 51 MW wind power project of ONGC at Surajbari, Gujarat in India, as described in the PDD, version 04 of 16 February 2010, meets all relevant UNFCCC requirement for the CDM and all relevant host Party criteria and correctly applies the baseline and monitoring methodology ACM0002, version 7. DNV thus requests the registration of the project as a CDM project activity.
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2 INTRODUCTION
Oil and Natural Gas Corporation Ltd. has commissioned Det Norske Veritas Certification AS (DNV) to perform a validation of the 51 MW wind power project of ONGC at Surajbari, Gujarat in India (hereafter called the project). This report summarises the findings of the validation of the project, performed on the basis of UNFCCC criteria for the CDM, as well as criteria given to provide for consistent project operations, monitoring and reporting. UNFCCC criteria refer to Article 12 of the Kyoto Protocol, the CDM modalities and procedures and the subsequent decisions by the CDM Executive Board. This revised validation report addresses the corrections required by the CDM Executive board in decision 44 (aa) of the EB 52 meeting report.
2.1 Objective
The purpose of a validation is to have an independent third party assess the project design. In particular, the project's baseline, monitoring plan, and the projects compliance with relevant UNFCCC and host Party criteria are validated in order to confirm that the project design, as documented, is sound and reasonable and meets the identified criteria. Validation is a requirement for all CDM projects and is seen as necessary to provide assurance to stakeholders of the quality of the project and its intended generation of certified emission reductions (CERs).
2.2 Scope
The validation scope is defined as an independent and objective review of the project design document (PDD). The PDD is reviewed against the criteria stated in Article 12 of the Kyoto Protocol, the CDM modalities and procedures as agreed in the Marrakech Accords and the relevant decisions by the CDM Executive Board, including the approved baseline and monitoring methodology ACM0002 version 07. The validation is not meant to provide any consulting towards the project participants. However, stated requests for clarifications and/or corrective actions may have provided input for improvement of the project design.
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3 METHODOLOGY
The validation consisted of the following three phases: I a desk review of the project design documents II follow-up interviews with project stakeholders III the resolution of outstanding issues and the issuance of the final validation report and opinion. The following sections outline each step in more detail.
3.1 Desk Review of the Project Design Documentation

The following table lists the documentation that was reviewed during the validation: /1/ ONGC: CDM-PDD version 1 dated 8 April 2008, version 3 dated 22 June 2009 and version 4 dated 16 February 2010 /2/ CDM Executive Board: Validation and Verification Manual. Version 01 CDM Executive Board: ACM0002, Consolidated baseline methodology for grid connected /3/ electricity generation from renewable sources, version 7 /4/ CDM Executive Board: Tool for the demonstration and assessment of additionality, version 05.2. DNA of India: Letter of Approval dated 17 April 2009 /5/ CEA: CO2 Baseline Database for the Indian Power Sector dated 12 December 2007, /6/ www.cea.nic.in /7/ MoEF: Notification on requirement of environmental clearance, dated 14 September 2006 /8/ ONGC: Notification of Award for purchase of 34 numbers of WEGs issued to Suzlon, dated 6 November 2007 /9/ ONGC: Inviting quotations for turnkey supply of wind power project in Gujarat on 30 March 2007 /10/ ONGC: Inviting tenders for CDM consultancy services, 3 July 2007 /11/ ONGC: Internal office memo on approval of the project and demonstrating CDM awareness, 26 October 2007. /12/ ONGC: Letter of Award to consultants "Deloitte for the CDM development of wind power project in Gujarat, 26 October 2007. /13/ ONGC: Awarding contracts for land lease, civil and electrical works, erection and commissioning, 4 January 2008 /14/ GEDA: Permission for power transmission, 24 March 2008. /15/ /16/ /17/ /18/ /19/ /20/ /21/ /22/ GEDA: Commissioning certificates of WEGs, dated 16 April 2008, 12 June 2008,and 23 October 2008, GETCO: Agreement with ONGC for wheeling of power to installations in the state of Gujarat, 27 May 2008. ONGC: Invitation of tender for CDM validation of the project, 6 June 2008. ONGC: Public notice regarding stakeholder consultation in Kutch Mitra, a local newspaper, 9 August 2008. ONGC: MOM of Stake holder consultation at the project site, 18 August, 2008. ONGC: Notification of Award (NOA) for CDM validation the project 27 October 2008 ONGC: Host Country Approval meeting at the National CDM authority, New Delhi on 17 November 2008. ONGC: Invitation letters for stakeholder consultation meeting, Page 3
DET NORSKE VERITAS DNV report No: 2008-0065, rev. 02 VALIDATION REPORT /23/ /24/ /25/ /26/ /27/ /28/ /29/ /30/ /31/ /32/ /33/ /34/ /35/ /36/ /37/ ONGC order on benchmark No. MUM/PAS/PROJ/APPR/RR/2007 dated June 11, 2007 SBI: Letter issued by Assistant General Manager dated 23 November 2008 regarding interest rates for advances for the period of March 1992 to December 2008. ONGC: Contract awarded to Suzlon Energy Limited for operation and maintenance of wind mills dated 28 April 2009. Uttar Gujarat Vij Company Limited: Electricity bill for supply of power to ONGC installation dated 20 March 2007, proof for tariff. Gujarat government Wind power policy 2007 ONGC: Estimated energy generation worked out by the independent consultants for the bids received ONGC letter of 13 September 2008 on price bid opening for WEGs http://www.windpowerindia.com/statest.html ONGC: IRR spreadsheet calculations ONGC: Test certificates of energy meters by Secure Meters Limited, dated 7 November 2007. CEA web site: Data on hydropower stations in India
http://www.cea.nic.in/hydro/List%20of%20HE%20Stations%20in%20the%20country.pdf
/38/ /39/ /40/ /41/ /42/ /43/
/44/ /45/
/46/
GEDA: Availability of biomass in the state of Gujarat and potential for power generation: http://www.geda.org.in/bio/bio_summarybiomass.htm Ministry of new and renewable energy: Cost of solar energy http://mnes.nic.in/press-releases/press-release-21042008-2.pdf ONGC: Policy on climate change and sustainability, approved by the executive committee of the Board, dated 2 October 2007. ONGC: Project cases, wherein internal benchmark was applied - Re-development of Mumbai High North Phase dated 24 November 2008 and Expenditure Sanction for replacement of 12 OSV's 15 June 2007 and "Tender No L26BC07013 for construction of water injection plant at GGS-I, Nambar, A&AA basin, Jorhat dated 18 December 2008 GERC: Tariff order for Gujarat Vij Company Limited, Case number 945 of 2008 dated 17 January 2009. The, Directory Indian Wind Power 2007, GEDA: Windfarm generation report of Gujarat for the year 2005-06 & 2006-07 http://geda.org.in/pdf/wind/Windfarms-PowerGeneration.pdf UNEP Risoe Centre: Data base of CDM projects CDMpipeline.xls ONGC: Annual report for 2007-08. Department of Public Sector Enterprises: Revised scales of pay of board and below board level executives in Central Public Sector Enterprises. http://dpe.nic.in/newgl/glch04a23.pdf Indian Income Tax Act 1961: Section 32 (Rule 5) Appendix 1 and Section 80-1A, paragraph 2.0. GERC: Tariff orders http://www.gercin.org/docs/Orders/Tariff%20Orders/Year%202006/ugvcl.zip, http://www.gercin.org/docs/Orders/Tariff%20Orders/Year%202007/Tariff%20order07_UGVCL.zip, http://www.gercin.org/docs/Orders/Orders%202008/UGVCL%20Order.pdf GEDA: Average capacity utilization of wind mills in Gujarat during 2006-07
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3.2 Follow-up Interviews with Project Stakeholders

On 3 December 2008 DNV performed the site visit (Surajbari and Jakhav) with project stakeholders to confirm selected information and to resolve issues identified in the document review. Representatives of ONGC, Suzlon, and Deloitte were interviewed. The main topics of the interviews are summarized below. Name Interview Topics Host country approval /47/ ONGC Emission reduction calculations and CEA Mr. Ratendra Kumar, SE(M) data used Mr. Satendra Mohan, SE(P) Baseline selection SUZLON Training and maintenance schedule Additionality and financial analysis Mr. Dwijal Mamtora, Senior Proof for CDM consideration Executive, Marketing Start date of the project Mr. S.K. Behena, Deputy Manager Stakeholder consultation (O&M) Deloitte Mr. Vivek. P. Adhia, Senior Consultant
3.3 Resolution of Outstanding Issues

The objective of this phase of the validation was to resolve any outstanding issues which needed be clarified prior to DNVs positive conclusion on the project design. In order to ensure transparency a validation protocol was customised for the project. The protocol shows in a transparent manner the criteria (requirements), means of verification and the results from validating the identified criteria. The validation protocol serves the following purposes: It organises, details and clarifies the requirements a CDM project is expected to meet; It ensures a transparent validation process where the validator will document how a particular requirement has been validated and the result of the validation. The validation protocol consists of three tables. The different columns in these tables are described in the figure below. The completed validation protocol for the 51 MW wind power project of ONGC at Surajbari, Gujarat in India is enclosed in Appendix A to this report. Findings established during the validation can either be seen as a non-fulfilment of CDM criteria or where a risk to the fulfilment of project objectives is identified. Corrective action requests (CAR) are issued, where: i) mistakes have been made with a direct influence on project results; ii) CDM and/or methodology specific requirements have not been met; or iii) there is a risk that the project would not be accepted as a CDM project or that emission reductions will not be certified. A request for clarification (CL) may be used where additional information is needed to fully clarify an issue.
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Validation Protocol Table 1: Mandatory Requirements for CDM Project Activities Requirement The requirements the project must meet. Reference Gives reference to the legislation or agreement where the requirement is found. Conclusion This is either acceptable based on evidence provided (OK), a Corrective Action Request (CAR) of risk or non-compliance with stated requirements or a request for Clarification (CL) where further clarifications are needed.
Validation Protocol Table 2: Requirement checklist Checklist Question The various requirements in Table 2 are linked to checklist questions the project should meet. The checklist is organised in different sections, following the logic of the large-scale PDD template, version 03 - in effect as of: 28 July 2006. Each section is then further sub-divided. Reference Gives reference to documents where the answer to the checklist question or item is found. Means of verification (MoV) Explains how conformance with the checklist question is investigated. Examples of means of verification are document review (DR) or interview (I). N/A means not applicable. Comment The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. Draft and/or Final Conclusion This is either acceptable based on evidence provided (OK), or a corrective action request (CAR) due to noncompliance with the checklist question (See below). A request for clarification (CL) is used when the validation team has identified a need for further clarification.
Validation Protocol Table 3: Resolution of Corrective Action and Clarification Requests Draft report clarifications and corrective action requests If the conclusions from the draft Validation are either a CAR or a CL, these should be listed in this section. Ref. to checklist question in table 2 Reference to the checklist question number in Table 2 where the CAR or CL is explained. Summary of project owner response The responses given by the project participants during the communications with the validation team should be summarised in this section. Validation conclusion
This section should summarise the validation teams responses and final conclusions. The conclusions should also be included in Table 2, under Final Conclusion.
Figure 1 Validation protocol tables
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3.4 Internal Quality Control

The validation report underwent technical review. The technical review was performed by a technical reviewer qualified in accordance with DNVs qualification scheme for CDM validation and verification.
3.5 Validation Team

Role/Qualification Type of involvement
Site visit / Interviews Supervision of work Technical review
Desk review
Project Manager/ CDM validator GHG auditor GHG auditor Technical Reviewer (Draft) Technical Reviewer (Final)
Last Name Govindarajulu Kaliaperumal Prabhu Sharma Kakaraparthi Sharma
First Name Murali Ravi Kumar Shivraj Venkata Raman Anjana
Country India India India India India
The qualification of each individual validation team member is detailed in Appendix B to this report.
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Expert input
Reporting
4 VALIDATION FINDINGS
The findings of the validation are stated in the following sections. The validation criteria (requirements), the means of verification and the results from validating the identified criteria are documented in more detail in the validation protocol in Appendix A. The final validation findings relate to the project design as documented and described in the revised and resubmitted project design documentation, version 03, 16 February 2010.
4.1 Participation Requirements

The project participant is the public sector undertaking Oil and Natural Gas Corporation Ltd. of the host Party India. Host Party India meets all the requirements for participating in a CDM project. The Ministry of Environment and Forests, the DNA of India has approved the project with a letter of approval dated 17 April 2009 /5/, which also confirms that the project assists in achieving sustainable development in India. No Annex I Party has yet been identified for the project. The validation did not reveal any information that indicates that the project can be seen as a diversion of official development assistance (ODA) funding towards India.
4.2 Project Design

The project activity is the installation of 34 Wind Electricity Generators (WEGs) of 1500kW aggregating to an installed capacity of 51 MW. The entire power generated from the wind farm is being exported to the Gujarat state grid which is a part of the western regional electricity grid. The power generated by the project will be wheeled through the grid to various installations of ONGC within the state of Gujarat to meet the power requirements of these installations. All the WEGs installed under the project are supplied by Suzlon. The installation, commissioning, operation and maintenance of the WTGs are in the scope of M/s Suzlon. The technology used in the project activity is indigenously available in India and no transfer of technology is envisaged. Proposed project is expected to export 95.56 GWh per year after 4% wheeling charges, at a plant load factor (PLF) of 22.28%. The power generated from the project is wheeled through the state grid which is part of the western regional grid thereby replacing an equivalent amount of fossil fuel based power generation. Therefore, the project activity results in an equivalent amount of CO2 emission reduction which otherwise would have resulted from fossil fuel combustion. The power generated by the project will be used to meet the power consumption of various ONGC installations in Gujarat, which are presently consumers of the local grid. The expected operational lifetime of the project technology is 20 years, which has been verified from the inter office memo of ONGC /11/ and is deemed reasonable for a new wind mill. The starting date of the project activity has been indicated as 6 November 2007 which is the date of the purchase order for supply of the 34 Suzlon make 1500 KW WEGs/8/. The project has selected a renewable crediting period of 7 years starting from the date of registration of the project, which is expected to be 1 November 2009. The project is estimated to reduce 85 762 t CO2e per year for the duration of the crediting period chosen. The validation did not reveal any information that indicates that the project can be seen as a diversion of ODA.
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4.3 Baseline Determination

The project applies the approved consolidated baseline methodology ACM0002, version 7 titled Consolidated baseline methodology for grid-connected electricity generation from renewable sources/3/. The methodology is applicable to the project since the project activity involves grid-connected wind energy generation and the geographic and system boundaries for the relevant electricity grid can be clearly identified and information on the characteristics of the grid is available. Four alternatives to the project activity have been considered as the baseline scenario. These are i) project activity without CDM benefits; ii) continuation of current scenario of power generation from existing grid-connected power plants; iii) project activity based on other renewable energy sources like hydropower, solar energy and biomass iv) The proposed project activity is taken up as a fossil fuel based project. Alternative i) - Project activity without CDM revenue is a potential baseline scenario. Alternative ii) - Continuation of current scenario i.e. generation of same amount of electricity in the state grid does not involve any investment neither face any barrier and hence, is an attractive option in the absence of project activity. Alternative iii) PP has carried out analysis of power generation units based on renewable energy sources and the results are as follows: a) Hydropower generation: The state of Gujarat lacks hydro resources for setting up small and medium scale hydropower plants. According to the data published by CEA /33/, there are only 5 hydropower stations in Gujarat, all of them with installed capacities of 240 MW and above. b) Biomass based power generation: According to report of Gujarat Energy Development Agency (GEDA) /34/ the installed capacity of the biomass based power projects in the state is only 0.5 MW and the report also indicates that it is not feasible to transport the biomass to faraway locations. Based on the above mentioned statements it has been verified that the availability of surplus biomass in the state is limited to support power plants. . c) Solar Energy based power generation: The solar power generation is yet to gain ground in the country because of the high cost. According to the data available in the ministry of new and renewable energy website, the cost of setting up 1MW solar plant is in the range of INR 160 to 200 million and the generation cost is around INR 12 to 15 per unit /35/ Based on the above analysis, none of the renewable energy based power generation units can be considered as credible alternatives for the project developer in the absence of project activity. Alternative iv) - Fossil fuel based power generation unit: The fossil fuel based power plant was not considered by PP because of its commitment to develop alternative energy sources. ONGCs Policy on climate change and sustainability /36/ states that We shall develop and invest in advanced low carbon technologies to meet growing demand for affordable energy products while improving security of supply and reducing environmental impacts. It has been verified from the annual report of ONGC for the year 2007-08 /42/ that no fossil fuel based captive power plant is under implementation and that state of the art - ONGC Energy Center for alternative energy is being set up as part of this policy.
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DET NORSKE VERITAS DNV report No: 2008-0065, rev. 02 VALIDATION REPORT Thus alternatives iii) and iv) are eliminated due to the non-availability of other renewable sources in Gujarat and the commitment of the project proponent to take up environment friendly and pollution free energy production, respectively. This leaves only alternates i) and ii) for further analysis. Both alternatives are in compliance with the laws and regulations of India and might be considered as baseline scenarios. However, as discussed in the section 4.4. below, the proposed project activity (without CDM income alternative i) faces barriers compared to other alternative i.e. continuation of current practice (alternative ii) which does not require any investment. Hence, alternative (ii) has been selected as a baseline scenario. The selected baseline scenario is also in line with the approved baseline methodology ACM0002. DNV considers the list of realistic and credible alternatives to be complete. As the project activity supplies electricity to the Gujarat state electricity grid which forms a part of the western region electricity grid, the baseline for this project activity is a function of the generation mix of the western region grid. The selection of the western region grid as the grid system boundary for the project activity is in line with the EB guidance for large countries such as India. In line with the guidance provided in the methodology, the weights for OM and BM have been taken as 75:25. The OM emission factor in the CEA database is calculated ex-ante using the simple OM approach based on the generation-weighted average emissions per electricity unit over a three year period of 2004-2005, 2005-2006 and 20062007. The BM emission factor is calculated ex-ante based on 20% most recent capacity additions in the grid based on net generation as described in ACM0002 version 07. The operating margin has been determined to be 0.99 kg CO2e/kWh and the build margin to be 0.59 kg CO2e/kWh. Taking the weight of OM:BM as 75:25, the combined margin emission coefficient for the western grid of India has been calculated at 0.89 kg CO2e/kWh. These values have been sourced from data by the Central Electricity Authority (CEA) of the Ministry of Power, Government of India /6/. CEA has published a database of carbon dioxide emission factors from the power sector in India based on detailed authenticated information obtained from all operating power stations in the country. This CO2 baseline database provides information about the OM and BM factors of all the regional electricity grids in India. DNV confirms that the database is an official publication of the Government of India for the purpose of CDM baselines. The selected sources and gases are justified for the project activity.
4.4 Additionality
The additionality of the project activity is demonstrated using the Tool for demonstration of additionality, version 5. /4/
4.4.1 CDM consideration and continued action to secure CDM status

The chronology of events and the evidences provided to demonstrate the prior consideration of the CDM and the real and continued actions undertaken to secure CDM status are given below: CDM was seriously considered in the decision to proceed with the project activity in accordance with EB41 annex 46 and was evidenced through the four activities listed below, which were completed before the start date of the project:
a) Inviting quotations for turnkey supply of wind power project in Gujarat on 30 March 2007 /9/. b) Inviting tenders for CDM consultancy services, 3 July 2007 /10/.
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DET NORSKE VERITAS DNV report No: 2008-0065, rev. 02 VALIDATION REPORT c) Internal office memo of ONGC demonstrating CDM awareness, 26 October 2007 /11/. d) Letter of Award to consultants "Deloitte" for the CDM development of wind power project in Gujarat, 26 October 2007 /12/. e) Notification of Award (NoA) for purchase of 34 numbers of WEGs issued to Suzlon /8/ on 6 November 2007, which is the start date of the project. Efforts to secure CDM status in parallel with the physical implementation was shown by the following sequence that was consider satisfactory by DNV: a) Awarding contract for land lease, civil and electrical works, erection and commissioning, 4 January 2008 /13/. b) Permission from GEDA for power transmission, 24 March 2008 /14/. c) Commissioning of first set of WEGs, 4 April 2008 /15/ d) Agreement with GETCO for wheeling of power to various installations of ONGC in Gujarat, 27 May 2008 /16/. e) Invitation of tender for CDM validation of the project, 6 June 2008 /17/. f) Public notice in local newspaper on stakeholder consultation, 9 August 2008 /18/. g) Stake holder consultation at the project site, 18 August, 2008 /19/. h) Commissioning of last set of WEGs, 29 September 2008 /15/. i) Notification of award (NOA) for CDM validation the project 27 October 2008 /20/. j) Host Country Approval meeting at the National CDM authority, New Delhi on 17 November 2008./21/. k) Start of validation (global stakeholder consultation) on 4 November 2008. l) Receipt of host country approval, 17 April 2009 /5/.
4.4.2 Identification of alternatives to project activity

Two alternatives to the project activity have been considered as the baseline scenario. These are i) project activity without CDM benefits and ii) continuation of current scenario of power generation from existing grid-connected power plants. Both alternatives are in compliance with the laws and regulations of India and might be considered as baseline scenarios. However, as discussed in the following sections of this report, the project without CDM benefits faces barriers in implementation. 4.4.3 Investment analysis: Choice of approach To demonstrate the additionality of the project, the project proponent has calculated the IRR of the project for a period of 20 years. The project generates revenues without CDM and the alternative of grid based electricity generation does not involve any investment on the part of the project participant. Therefore, a benchmark analysis is considered suitable for demonstrating the additionality of the project. 4.4.4 Investment analysis: Benchmark selection ONGC being a government of India public sector undertaking has an established benchmark of 12 % post tax return on the investment for the development projects, according to ONGC order No. MUM/PAS/PROJ/APPR/RR/2007 dated June 11, 2007 /23/. This internal benchmark has been consistently applied by the project participant for other projects also. This has been verified by DNV in project cases Re-development of Mumbai High North Phase dated 24 November 2008/37/ and Expenditure Sanction for replacement of 12 OSV's 15 June 2007 internal benchmark was used for acceptance of projects and project case "Tender No L26BC07013 for construction of water injection plant at GGS-I, Nambar, A&AA basin, Jorhat dated 18 December 2008 was rejected using the same benchmark. DNV verified the circular on internal benchmark and the project documents related to these three development projects with comparable investment to confirm that internal benchmark has been applied consistently while taking decision on implementation of these projects.
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DET NORSKE VERITAS DNV report No: 2008-0065, rev. 02 VALIDATION REPORT The lending rate of the largest bank in India State Bank of India (SBI) at the time of taking decision to go ahead with the project was 12.75% /24/. The internal benchmark of ONGC is therefore deemed to be conservative when compared with the applicable bank lending rate at the time of decision making for the project. The applied benchmark is thus comparable to the benchmark that would apply to a different entity potentially developing this project. 4.4.5 Investment analysis: Input parameters DNV has verified the input parameters for the financial analysis, which were mainly sourced from the approval note of the 51 MW wind energy project of Oil and Natural Gas Corporation Ltd. (ONGC) dated 26 October 2007 /11/, submitted to the management of ONGC. The investment decision of the project activity was taken by the management comprising of the General Manager (Finance & Accounts), the Executive Director (Corporate Finance) and the Director (Finance). The note elaborates in detail the project activity parameters like the total project cost, O&M cost and the internal rate of return (IRR). The ultimate approval for the project was provided by the Chairman and Managing Director on 26 October 2007, based on the recommendation of the above mentioned management team. The input parameters used in the investment analysis has been sourced from the approval note, and has been cross checked with publicly available sources and actual invoices, in line with paragraph 109 of the VVM. Input parameter used in the financial analysis Project cost Source of input value used by DNV for verification Project approval note /11/ Source of input value used by DNV for cross checking Notification of award of contract to Suzlon dated 6 November 2007 (project starting date) /8/. O&M contract entered into between ONGC and Suzlon Energy Limited dated 28 April 2009 /25/. Revised scales of pay of board and below board level executives in Central Public Sector Enterprises, from the official website of Department of Public Sector Enterprises /43/. Notification of award of contract to Suzlon dated 6 November 2007 /8/. Indian Income Tax Act 1961, Section 32 (Rule 5) Appendix 1 and Section 80-1A, paragraph 2.0 /44/.
O&M costs
Project approval note /11/
Cost of 2 ONGC Project approval note /11/ officers for project supervision
GEDA certification Project approval note /11/ fee and lease rental Tax benefits: Project approval note /11/ Accelerated depreciation @ 80% & Corporate tax @ 33.99% PLF of 22.28% Project approval note /11/
Report of the third party consultant /28/, engaged by ONGC for evaluation of offers received against open tender call. This is in line with the guidance on PLF, EB 48 Annexure 11 paragraph 3(b), which states that The plant load factor determined by a third party contracted by the project participants (e.g. an engineering Page 12
DET NORSKE VERITAS DNV report No: 2008-0065, rev. 02 VALIDATION REPORT company). The estimated PLF as suggested by the consultant was used in the commercial evaluation of the offers received. Wheeling Gujarat government wind power Gujarat government wind power policy 2007 policy 2007 /27/. Project approval note Electricity bill of ONGC for the month of October 2007 /26/.
4% charges Tariff
The incentives in the form of accelerated depreciation and tax holidays from the Government of India for the renewable energy projects have been taken into consideration for the financial analysis. The estimates of project cost and O&M costs were further verified from the actual costs incurred from the following documents and deemed appropriate. Contracts for supply of the equipments for verification of equipment cost /8/ Contracts for erection and commissioning /13/ Contracts for operation and maintenance, for verification of O&M costs /25/ The input parameters were verified to be valid at the time of decision making and hence in line with the VVM requirements, and section 6 of the Guideline on Investment Analysis, EB 41 Annexure 45, which states the Input values used in all investment analysis should be valid and applicable at the time of the investment decision taken by the project participant. 4.4.6 Investment analysis: Calculation and conclusion The IRR calculations were provided in a spreadsheet and verified by DNV. The project IRR was verified to be 10.59% which is less than the benchmark IRR of 12%. The assumptions and the source documents used for the financial calculations have also been verified. The project IRR increases to 12.69% with CDM benefits and thus makes the project feasible. 4.4.7 Investment analysis: Sensitivity analysis A sensitivity analysis has been carried out for the parameters PLF, project cost, operational cost and tariff which contribute to more than 20% of revenues or costs to check the robustness of the financial analysis. The level of variation assumed for the sensitivity analysis has been suitably justified with relevant documents pertaining to the presented analysis and has been verified by DNV, such as The basis for the assumed annual electricity generation/ plant load factor (PLF) of 22.28% in the PDD is based on the estimated generation figures of the machines provided by the machine supplier, and ratified by the external independent consultant /28/ engaged by ONGC for evaluation of bids received against the tender for wind mills. It was observed that with an increase of 10%, the plant load factor works out to be 24.5 % and the project IRR of 12.73% is crossing the benchmark of 12.0%. The PLF used in the financial analysis is sourced from the third party (MP Wind farms Limited) assessment of the wind potential in the region /28/. The PLF was also used for evaluating the various offers received by ONGC against the open tender call. DNV has verified the third party assessment report and the letter informing the bidders that the estimated PLF will be the basis for the evaluation of the tender. Thus the PLF of the project activity is in line with the guidance on PLF as per paragraph 4 and 5 of Annex 11, EB 48. DNV has also cross checked the PLF against the Gujarat Electricity Regulatory Commission (GERC) tariff order on wind energy projects, dated 11 August 2006 /45/, which discusses the factors affecting the capacity utilization factor (CUF) and the CUF achieved at various locations in Gujarat. While the Commission report states the maximum CUF achieved at the four sites of Jamnagar Coastal, Jamnagar Inland Patelka, Bhavanagar Sonadar and Surajbari Kutch to be 23.97%, 20.2%, 22.5% and Page 13
DET NORSKE VERITAS DNV report No: 2008-0065, rev. 02 VALIDATION REPORT 25.68% respectively, a standard CUF of 23% is stated for all the wind energy projects in Gujarat for tariff calculation. DNV has also verified from the Directory Indian Wind Power 2007 /39/, Page 50 which reports the annual average power generation in four locations in Gujarat (Dhank in district Rajkot, Kalyanpur, Lamba and Navadra in district Jamnagar), that the highest CUF is 14.5%. The report is attached as Annex II to this response. Further, DNV has verified the wind-farm generation report for the year 2006-07 from the official web site of Gujarat energy development authority (GEDA) /46/, which states the average capacity utilization of wind mills in Gujarat during 2006-07 to be 9% with the highest at 18.8 % in the Kutch district where the project activity is located. The figures for the year 2005-06 given in the report for locations in Kutch are still lower. DNV has concluded that a variation of +10% from 22.28% is unlikely after scrutiny of the above mentioned data. Hence it is DNVs opinion that the selection of the PLF of the project activity of 22.28%, which a) has been estimated by third party consultants, b) has been the basis for the evaluation of the offers and c) the financial analysis, is reasonable. The project has been contracted on a turn key basis to Suzlon Energy Limited by the project proponent ONGC Ltd. /13/&/25/. It was also observed that if the project cost goes down by 10% then the IRR touches the benchmark of 12.0%. However, this is not a likely scenario in DNVs opinion as the project has been contracted on a turn key basis and the project cost is not likely to have any increase or decrease. The turn key price of INR 3072.8 million constitutes 98.6% of the total project cost, which points to the fact that 10% reduction in project cost is not plausible. It was also observed that if the O&M cost goes down by 10% then the IRR touches the benchmark of 12.0%. ONGC has signed a long term fixed rate O&M contract with Suzlon for a period of 20 years /25/ and the same rates were used for financial analysis. Therefore, any chances of reduction in O&M costs is not plausible The applicable industrial tariff of INR 4.05 + 15% surcharge for ONGC at the time of decision making has been used in the investment analysis of the project activity. This has been verified from the energy bill for the month of October 2007 from Uttar Gujarat Vij Company Ltd. The HT industrial consumer tariff for the period from 2002-03 to 2010-11 as per the tariff orders of GERC sourced from their official web site /45/ is stated hereunder: - For the years 2002-03, 2003-04, 2004-05 and 2005-06: INR 4.10 - For the year 2006-07 and 2007-08: INR 4.05 - For the year 2008-09, 2009-10 and 2010-11: INR 4.15 The tariff trend in Gujarat over the period of 9 years from 2002-03 to 2010-11 shows that the increase in tariff for the period is only 1.22%. Since the industrial tariff in Gujarat is one of the highest in India and a number of large scale power plants with better efficiency are due for commissioning in the near future, the tariff increase in future is expected to be small and no significant changes are expected. Based on the assessment of the above mentioned sources, it was DNV opinion that the increase in tariff by 10% is unlikely and this is in line with the requirements of 16 & 17 of Annex 45, EB The spread sheet for financial analysis, including the assumptions for the sensitivity analysis /31/, has been verified by DNV and no material mistakes were found. Page 14
Step 3: The project participant has not opted for other barrier analysis. 4.4.8 Common practise analysis Step 4 (a). Analyze other activities similar to the proposed project activity: The generation of wind energy depends on local or region specific wind patterns and the tariff regime prevalent in the region/state. Based on the above mentioned facts, installation of WEGs in state of Gujarat in India has been considered for assessing the common practice. In India, Gujarat has the highest gross potential for wind power generation among all the states, which can be verified from the web site www windpowerindia.com /30/. However, the installed capacity for wind power generation in the state is only 13% till 31 March 2006. Thus, it can be verified that despite of huge potential for developing wind power projects in the state of Gujarat, only a minimum potential has been tapped so far and that installation of WEGs in Gujarat has been heavily dependent on the revenues from CERs. Step 4(b). Discuss any similar options that are accruing: In Gujarat, the wind power projects with a size of 15 MW and above are being implemented as CDM projects, as the projects are not financially viable otherwise. This has been verified as per cdmpipeline published by UNEP Risoe Centre /41/. At the time of decision making to go ahead with the project activity, there were 14 other large scale projects in Gujarat with a combined capacity of 542.5 MW and all these projects were under validation claiming for CDM benefits. As all the wind power projects of similar size and capacity are being implemented with CDM benefits in the state of Gujarat, establishment of large scale wind projects without CDM is not a common practice. In conclusion, the assessment of the arguments presented above is deemed to sufficiently demonstrate that the project activity itself is not a likely baseline scenario and that emission reductions resulting from the project are additional.
4.5 Monitoring
The monitoring methodology selected complies with requirements of ACM0002, version 7. The monitoring plan will give opportunity for real measurements of achieved emission reductions.
4.5.1 Parameters determined ex-ante

The combined margin emission coefficient for the western grid of India has been calculated at 0.89 kg CO2e/kWh based on the data sourced from CEA. CEA has published a database of carbon dioxide emission factors from the power sector in India based on the detailed authenticated information obtained from all operating power stations in the country. This CO2 baseline database provides information about the OM and BM factors of all the regional electricity grids in India. DNV confirms that the database is an official publication of the Government of India for the purpose of CDM baseline. The OM emission factor in the CEA database is calculated ex-ante using the simple OM approach based on the generationweighted average emissions per electricity unit over a three year period of 2004-2005, 20052006 and 2006- 2007. The BM emission factor is calculated ex-ante based on 20% most recent capacity additions in the grid based on net generation as described in ACM0002 version 7. The operating margin has been determined to be 1.00 kg CO2e/kWh and the build margin to be 0.59 kg CO2e/kWh.
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4.5.2 Parameters monitored ex-post

The net amount of electricity dispatched by the WEGs to the western regional electricity grid will be monitored continuously ex-post. It is determined using the meter installed at the substation, which is the point of uploading power to the grid. O&M contractor Suzlon will maintain daily records of the electricity generated from each wind turbine. The readings at the main meter at the grid uploading point are jointly noted by GETCO, GEDA and Suzlon officials every month. All data will be archived for 2 years after the crediting period. Since the project involves electricity generation from wind sources, no monitoring is required for project emissions or leakages due to the project activity.
4.5.3 Management system and quality assurance

The authority and responsibility of project management as well as registration, monitoring, measurement and reporting lies with ONGC and O & M staff of Suzlon Energy. The joint electricity measurement will be carried out once in a month in presence of both parties (the developers representative and officials of the GETCO). Both parties will sign the recorded reading. The meters will be tested for accuracy and calibration of the machines would be taken care of as per the established practice. The monthly electricity generation and export data will be archived until 2 years after the crediting period to facilitate crosschecking during the crediting period.
4.6 Estimate of GHG Emissions

The calculations are well documented in line with the consolidated baseline and monitoring methodology ACM0002, version 7. The project is electricity generation from the wind power and no project emissions and leakage is associated with the project activity. The emission factor has been computed to be 0.89 kg CO2e/kWh of electric power generated and is fixed ex-ante for the first crediting period of seven years. The project is expected to result in emission reductions of 85 762 t CO2 per year during the crediting period. The baseline emission estimate can be replicated using the data and parameter values provided in the PDD. The data sources mentioned have been verified by DNV. The calculations are transparently documented and verified to be correct.
4.7 Environmental Impacts

As per the Ministry of Environment and Forests (MoEF), India Environment Impact Notification S.O. 1533 (http://envfor.nic.in/legis/eia/so1533.pdf) dated 14 September 2006, wind power projects are not covered under any Schedule and thus Environmental Impact Assessment is not required for the project activity. The project is not likely to create any adverse environmental effects. The project complies with environmental regulations in India.
4.8 Comments by Local Stakeholders

The local stakeholders were invited for comments through letters as well as by publishing a notice in a widely circulated local newspaper /18/. The representatives of the local administration, village panchayat, local villagers, farmers and technology suppliers have been consulted. A meeting was held on 18 August 2008 at the Jhakau site for consultation with the stakeholders /19/. The project did not receive any adverse comments from the local stakeholders and hence no mitigating actions were necessary.
4.9 Comments by Parties, Stakeholders and NGOs

The PDD of 8 April 2008 was made publicly available on DNVs climate change website and Parties, stakeholders and NGOs were through the CDM website invited to provide comments during a 30 days period from 4 November 2008 to 3 December 2008. Two comments were received and are given (in unedited form) in the below text box.
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Comment by: Accredited NGO Inserted on: Subject: Comment: 1. As the PDD clearly states that the power will be wheeled to different assests of ONGC the benchmark used in the PDD is not applicable. Please refer to Additionality tool version 05 that states that "Only in the particular case where the project activity can be implemented by the project participant, the specific financial/economic situation of the company undertaking the project activity can be considered". As the same wind based energy can be supplied by other party to ONGC internal benchnmark cannot be applied. DOE is requested to check the suitability of benchmark during validation process. 2. The power tariff has been taken as 4.05 Rs/kWh. Is the basis of this value taken from PPA? If yes than it is not correct value applied for financial analysis. As wind energy supplied to ONGC assests and it is displacing the assest electricity the cost of electricity to the assests have to be used in financial analysis. DOE is requested to check the basis of this parameter in financial analysis. 3. As per the latest guidance on investment analysis the sensitivity has to be done for positive as well as negative variation. The Generation parameter has only be varied towards negative variation. As evident from many Wind Projects installed in India the generation value fluctuates based on the Wind speed and also seasons and the generation can also increase than the value committed by the supplier. This parameter have to be varied for positive side atleast towards +10% as stated in the guidance and than it has to be compared against suitable benchmark. Submitted by: Mahendra Jadhava Comment by: Accredited NGO Inserted on: Subject: Comment: 1. How road network of area has been increased due to this particular project as mentioned in social aspect because other windmills are also in same area? 2. What is total energy requirement of all ONGC operations as listed in PDD? Whether this weather based wind energy will certainly fulfill electricity demands of all location round the year? 3. What would be impact of negative environmental conditions in area upon project? What would be alternatives? 4. How many skilled/unskilled people from surrounding area were employed at this project during commissioning and operation? 5. Whether NOC from state departments has been issued to this project? 6. Whether local villagers would be beneficiary of CDM revenue earned by company? Any plan has been develop to earmark certain fund from CDM revenue for community welfare to improve social well being of local people? From Hiral Mehta/Mahesh Pandya Environmental Engineers Paryavaran mitra 502, Raj Avenue, Bhaikakanagar road Thaltej, Ahmedabad 380059 Telefax - 079-26851321/1801
Party
Stakeholder
Party
Stakeholder
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Submitted by: paryavaranmitra
.
The response received from the project participant to the comments:

S.No. Comments from Global Stakeholder Process (GSP) A 1 Stakeholder : Mahendra Jadhava As the PDD clearly states that the power will be wheeled to different assets of ONGC the benchmark used in the PDD is not applicable. Please refer to Additionality tool version 05 that states that "Only in the particular case where the project activity can be implemented by the project participant, the specific financial/economic situation of the company undertaking the project activity can be considered". As the same wind based energy can be supplied by other party to ONGC internal benchmark cannot be applied. DOE is requested to check the suitability of benchmark during validation process. The power tariff has been taken as 4.05 Rs/kWh. Is the basis of this value taken from PPA? If yes than it is not correct value applied for financial analysis. As wind energy supplied to ONGC assests and it is displacing the assest electricity the cost of electricity to the assests have to be used in financial analysis. DOE is requested to check the basis of this parameter in financial analysis. As per the latest guidance on investment analysis the sensitivity has to be done for positive as well as negative variation. The Generation parameter has only be varied towards negative variation. As evident from many Wind Projects installed in India the generation value fluctuates based on the Wind speed and also seasons and the generation can also increase than the value committed by the supplier. This parameter have to be varied for positive side atleast towards +10% as stated in the guidance and than it has to be compared against suitable benchmark. The project activity replaces the grid based power generation which is being used by the project proponent in the absence of the project activity. This grid based power is now being replaced by captive power generation by ONGC using wind energy. As captive generation of power for own requirements can be done by ONGC in this case, thus the use of the internal benchmark is appropriate. The benchmark used by the project proponent is a common benchmark applicable to ONGC development projects and the ONGC Circular No. MUM/PAS/PROJ/APPR/RR/2007 dated June 11, 2007 is submitted as Annexure II to establish this internal benchmark. Thus, the internal benchmark has been applied correctly and in line with the guidance of the CDM Executive Board as provided in the Additionality Tool, Version 5.2, Clause 13. As the project baseline is the grid power purchased by the ONGC assets, the power tariff considered for the financial analysis is the power tariff applicable to these assets. The power tariff considered for financial analysis is the power tariff drawn from the electricity bills of the ONGC assets. Copy of the power bill is submitted as Annexure XXIV to the validator at Dehradun visit. Thus, the power tariff used is Rs.4.05 Rs./Kwh + 15% surcharge = Rs.4.66 Rs./Kwh. PP Response
The sensitivity analysis has been conducted for the entire range between +10% to -10% of three parameters Capex, Opex and Generation in the updated PDD. The results of the sensitivity analysis are presented in Section B.5 of the updated PDD.
Stakeholder: Hiral Mehta / Mahesh Pandya
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1 How road network of area has been increased due to this particular project as mentioned in social aspect because other windmills are also in same area? Section A.2 of the PDD states that The project activity requires additional investment to be made to set up the wind turbines, including additional infrastructure like approach roads, substations, transport of construction materials, etc. by way of which the project is leading to development of additional sectors, generation of new jobs and avenues of employment for the local people. The project proponent has set up 34 machines in an underdeveloped area in District Kutch. The road network in the area is largely underdeveloped. To establish this project activity, ONGC has signed a contract with the equipment supplier for machine supply, land, infrastructure, civil works for erection and commissioning of the project activity. Please see submitted Annexures V and VI. The contract price is inclusive of the internal roads and approach roads that Suzlon would need to construct / pay fees to local authorities to construct. Thus, the project proponent has funded the road network that is being used for the project activity. Section 4.3 of the PDD lists out the percentage of electricity that would be wheeled to each asset location from each machine. The electricity demands of these locations will be met from the project activity as long as the project activity generates wind power and it is wheeled to the asset locations. The plant load factor used to calculate the estimated generation from the project activity has already factored in the inherent intermittent nature of wind power. The wind potential pattern of the project area has been mapped out by responsible agencies and it is expected that the wind potential as estimated would not change substantially within the next twenty years (the lifetime of the project activity).The only environmental condition to have a negative impact on the project activity is the case of zero or less than 5m/s wind speed. However, since Surajbari area in District Kutch is an identified wind power site, the probability of this site not having any wind speeds is remote. During the construction phase, 38 skilled and 152 unskilled locals were employed in the project. During the operation phase, 14 unskilled locals are employed. The clearances received for the project activity have been submitted as Annexure-X (GEDA Transfer permission) and Annexure-XI (Chief Electrical Inspector Certificate) at Dehradun. The benefits from CDM have boosted the IRR of the project activity to commit the project proponent to go ahead with implementing the wind power project that would lead to development of living conditions of the local people. This is because the project has led to development of infrastructure like approach roads, employment generation for the local people and
What is total energy requirement of all ONGC operations as listed in PDD? Whether this weather based wind energy will certainly fulfill electricity demands of all location round the year?
What would be impact of negative environmental conditions in area upon project? What would be alternatives?
How many skilled/unskilled people from surrounding area were employed at this project during commissioning and operation? Whether NOC from state departments has been issued to this project?
Whether local villagers would be beneficiary of CDM revenue earned by company? Any plan has been develop to earmark certain fund from CDM revenue for community welfare to improve social well being of local people?
Page 19
increased business opportunities for the local people as more people related to the project come to visit the project site.
How DNV has considered the comments received in its validation: ONGCs responses are considered acceptable in the light of the explanations given. Since the project is connected to the local grid and the power generated will be used for meeting ONGCs own electricity consumption, applying an internal benchmark of ONGC is considered appropriate. Also, it was verified that the internal benchmark has been consistently applied across for other projects. Moreover, as mentioned under section 4.4.4, the lending rate of the largest bank in India State Bank of India (SBI) at the time of taking decision to go ahead with the project was 12.75% /24/. The internal benchmark of ONGC is therefore deemed to be conservative when compared with the applicable bank lending rate at the time of decision making for the project. The applied benchmark is thus comparable to the benchmark that would apply to a different entity potentially developing this project. The power tariff (4.05 Rs./kWh + 15% surcharge) applicable to the ONGC installations is evidenced by the monthly bills from Uttar Gujarat Vij Company Ltd. /26/. Sensitivity analysis has been done for +/- 10% variation in the applicable parameters, as per the EB guidelines. This has been detailed in section 4.4.7 of this report. The construction of road network to the project activity has been included the EPC contract for setting up of the WEGs, which is verified from the purchase order placed on Suzlon. The estimated power generation is based on the PLF evaluated by an independent consultant and is likely to meet the power requirement of the ONGC installations listed in the PDD. Negative environment conditions in the area are unlikely to affect the project activity. The project employed 38 skilled and 152 unskilled locals during the construction phase and 14 unskilled locals in the operation phase, as confirmed by ONGC. The project has obtained all the applicable statutory approvals. The project will result in overall development of the area through construction of road network and employment generation.
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DET NORSKE VERITAS
APPENDIX A
CDM VALIDATION PROTOCOL
DET NORSKE VERITAS
Table 1
Requirement
Mandatory Requirements for Clean Development Mechanism (CDM) Project Activities

Reference Conclusion
About Parties 1. The project shall assist Parties included in Annex I in achieving Kyoto Protocol Art.12.2 compliance with part of their emission reduction commitment under Art. 3. 2. The project shall assist non-Annex I Parties in contributing to the Kyoto Protocol Art.12.2. ultimate objective of the UNFCCC. 3. The project shall have the written approval of voluntary participation Kyoto Protocol from the designated national authority of each Party involved. Art. 12.5a, CDM Modalities and Procedures 40a The project has been proposed as an unilateral project. OK CAR 1 The letter of approval from the host country is pending. OK
4. The project shall assist non-Annex I Parties in achieving sustainable Kyoto Protocol Art. 12.2, OK development and shall have obtained confirmation by the host country CDM Modalities and thereof. Procedures 40a 5. In case public funding from Parties included in Annex I is used for the Decision 17/CP.7, project activity, these Parties shall provide an affirmation that such CDM Modalities and funding does not result in a diversion of official development assistance Procedures Appendix B, 2 and is separate from and is not counted towards the financial obligations of these Parties. 6. Parties participating in the CDM shall designate a national authority for CDM Modalities the CDM. Procedures 29 OK The validation did not reveal any information that indicates that the project can be seen as a diversion of official development assistance (ODA) funding towards India
and The Designated National Authority (DNA) of India is National Clean Development Mechanism Authority The host country India has ratified the Kyoto protocol on August 26,
7. The host Party and the participating Annex I Party shall be a Party to CDM Modalities 30/31a the Kyoto Protocol.
CDM Validation Protocol Report No.2008-0065, rev. 02
A-1
DET NORSKE VERITAS
Requirement
Reference
Conclusion
2002. 8. The participating Annex I Partys assigned amount shall have been CDM Modalities calculated and recorded. Procedures 31b 9. The participating Annex I Party shall have in place a national system CDM Modalities for estimating GHG emissions and a national registry in accordance Procedures 31b with Kyoto Protocol Article 5 and 7. About additionality 10. Reduction in GHG emissions shall be additional to any that would Kyoto Protocol Art. 12.5c, CL 2 Modalities and occur in the absence of the project activity, i.e. a CDM project activity CDM is additional if anthropogenic emissions of greenhouse gases by sources Procedures 43 OK are reduced below those that would have occurred in the absence of the registered CDM project activity. About forecast emission reductions and environmental impacts 11. The emission reductions shall be real, measurable and give long-term Kyoto Protocol Art. 12.5b benefits related to the mitigation of climate change. For large-scale projects only 12. Documentation on the analysis of the environmental impacts of the CDM Modalities project activity, including transboundary impacts, shall be submitted, Procedures 37c and, if those impacts are considered significant by the project participants or the Host Party, an environmental impact assessment in accordance with procedures as required by the Host Party shall be carried out. About small-scale project activities (if applicable) 13. The proposed project activity shall meet the eligibility criteria for small Simplified Modalities and NA scale CDM project activities set out in 6 (c) of the Marrakech Procedures for Small Scale Accords and shall not be a debundled component of a larger project CDM Project Activities and OK CAR 2 OK and NA and NA
A-2
DET NORSKE VERITAS
Requirement
Reference
Conclusion
activity.
12a,c
14. The proposed project activity shall confirm to one of the project Simplified Modalities and NA categories defined for small scale CDM project activities and use the Procedures for Small Scale simplified baseline and monitoring methodology for that project CDM Project Activities 22e category. 15. If required by the host country, an analysis of the environmental Simplified Modalities and NA impacts of the project activity is carried out and documented. Procedures for Small Scale CDM Project Activities 22c About stakeholder involvement 16. Comments by local stakeholders shall be invited, a summary of these CDM Modalities provided and how due account was taken of any comments received. Procedures 37b 17. Parties, stakeholders and UNFCCC accredited NGOs shall have been CDM Modalities invited to comment on the validation requirements for minimum 30 Procedures 40 days, and the project design document and comments have been made publicly available. Other 18. The baseline and monitoring methodology shall be previously approved CDM Modalities by the CDM Executive Board. Procedures 37e 19. A baseline shall be established on a project-specific basis, in a CDM Modalities transparent manner and taking into account relevant national and/or Procedures 45c,d sectoral policies and circumstances. 20. The baseline methodology shall exclude to earn CERs for decreases in CDM Modalities activity levels outside the project activity or due to force majeure. Procedures 47 and OK and OK and OK and OK
and OK
21. The project design document shall be in conformance with the CDM Modalities and OK UNFCCC CDM-PDD format. Procedures Appendix B, EB Decision
A-3
DET NORSKE VERITAS
Requirement
Reference
Conclusion
22. Provisions for monitoring, verification and reporting shall be in CDM Modalities accordance with the modalities described in the Marrakech Accords Procedures 37f and relevant decisions of the COP/MOP.
and OK
A-4
DET NORSKE VERITAS
Table 2 A.
Requirements Checklist
CHECKLIST QUESTION Ref. MoV* COMMENTS Draft Concl. Final Concl.
General Description of Project Activity

The project design is assessed.
A.1. Project Boundaries

Project Boundaries are the limits and borders defining the GHG emission reduction project.
A.1.1. Are the projects spatial boundaries (geographical) clearly defined? A.1.2. Are the projects system boundaries (components and facilities used to mitigate GHGs) clearly defined?
/1/
DR/I
Yes, the projects spatial boundaries are defined. The project site is located at villages Jakhau and Budiya in Abdasa taluka. The project system boundaries are clearly CAR 2 defined and consist of the 34 WEG of Suzlon make and each having a capacity of 1.5 MW. The spatial boundary also includes the Western regional grid of India to which the project is connected. India electricity grid which earlier had 5 regional grid has been reorganized in to two regional grids (South and NEWNE) vide the CEA database of version 04 released on 8the September 2008. Hence the project activity is connected to the NEWNE regional grid as per the latest CEA data. PDD is to be corrected to reflect this change.
OK
/1/ /6/
DR/I
OK
A.2. Participation Requirements Referring to Part A, Annex 1 and 2 of the PDD as well as the CDM glossary with respect to the terms Party, Letter of Approval, Authorization and Project Participant.
* MoV = Means of Verification, DR= Document Review, I= Interview CDM Validation Protocol Report No.2008-0065, rev. 02
A-5
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV* /1/ DR/I
COMMENTS
Draft Concl.
Final Concl.
A.2.1. Which Parties and project participants are participating in the project? A.2.2. Have all involved Parties provided a valid and complete letter of approval and have all private/public project participants been authorized by an involved Party? A.2.3. Do all participating Parties fulfil the participation requirements as follows: - Ratification of the Kyoto Protocol - Voluntary participation - Designated a National Authority A.2.4. Potential public funding for the project from Parties in Annex I shall not be a diversion of official development assistance. A.3. Technology to be employed
Validation of project technology focuses on the project engineering, choice of technology and competence/ maintenance needs. The validator should ensure that environmentally safe and sound technology and know-how is used.
/1/ /5/
DR/I
India is the host party and Oil and Natural Gas Corporation Limited (ONGC) is the Project participant. The LoA from the DNA, India need to be CAR 1 provided.
OK
OK
/1/ /5/
DR/I
The Designated National Authority of India CAR 1 is Ministry of Environmental and Forests. India ratified the Kyoto Protocol on 22 August 2002. The letter of approval is to be provided. No public funding has been taken for this project activity.
OK
/1/
DR/I
OK
A.3.1. Does the project design engineering reflect current good practices?
/1/
DR/I
The wind turbines have been manufactured and erected by Suzlon Energy Limited. The turbines are designed for cut in speed of 4m/s and cut out speed of 20m/s. The salient
OK
A-6
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
features of the project include an independent electromechanical pitch system for each blade and via Suzlon-Flexi-Slip-System. These features indicate the project proponents intention for adopting good engineering design and practices. The Purchase order has been witnessed during the site visit. A.3.2. Does the project use state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in the host country? A.3.3. Does the project make provisions for meeting training and maintenance needs?
/1/ DR/I
The Project utilizes manufactured equipments generation.
indigenously for power
OK
/1/
DR/I
The operation and maintenance of the project is contracted to the manufacturers and suppliers of the equipment Suzlon. Hence the training is not envisaged.
OK
A.4. Contribution to Sustainable Development

The projects contribution to sustainable development is assessed.
A.4.1. Has the host country confirmed that the project assists it in achieving sustainable development?
/1/ /5/
DR/I
B.1.1. Will the project create other environmental or social benefits than GHG emission reductions?
/1/
DR/I
The letter of approval from the DNA CAR 1 confirming that the project assists in achieving sustainable development needs to be provided for verification. The host country LoA needs to be provided. Yes. Apart from GHG reductions, the project envisages following benefits: The project will help to decrease the dependence on fossil fuels for power
OK
OK
A-7
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
generation. The project activity will create employment opportunities during construction and operation phases. B. Project Baseline
The validation of the project baseline establishes whether the selected baseline methodology is appropriate and whether the selected baseline represents a likely baseline scenario.
B.1. Baseline Methodology

It is assessed whether the project applies an appropriate baseline methodology.
B.1.2. Does the project apply an approved methodology and the correct version thereof?
/1/ /3/
DR/I
The project correctly applies the approved baseline methodology Consolidated baseline methodology for grid-connected electricity generation from renewable sources ACM 0002, version 07 for large scale CDM projects. The applicability criteria is discussed below: CAR 2 The project activity is the installation or modification/retrofit of wind power plant/unit. The project activity is the installation of 51 MW wind energy based power plant. The geographic and system boundaries for the relevant electricity grid can be clearly identified and information on the characteristics of the grid is available. The geographic and system boundaries for the western regional grid (WR) of India have
OK
B.1.3. Are the applicability criteria in the baseline methodology all fulfilled?
/1/ /6/
DR/I
OK
A-8
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
been clearly identified. The information on the characteristics of the WR is available. This however needs to be corrected to be in line with the latest CEA bifurcation of grid. B.2. Baseline Scenario Determination
The choice of the baseline scenario will be validated with focus on whether the baseline is a likely scenario, and whether the methodology to define the baseline scenario has been followed in a complete and transparent manner.
B.2.1. What is the baseline scenario?
/1/
DR/I
The baseline scenario as per the methodology is that in the absence of the project activity, electricity would have been generated in the existing or by new additions in the fossil fuel dominated grid. Other alternatives for the project activity are mentioned below: Alternative 1: The proposed project activity not undertaken as a CDM project activity Alternative 2: No project activity However, the PP is requested to discuss and justify on the other alternatives available like, fossil fuel, renewable sources like hydro etc and state why these are not likely baseline scenarios. CL 1
OK
B.2.2. What other alternative scenarios have been considered and why is the selected scenario the most likely one?
/1/
DR/I
OK
B.2.3. Has the baseline scenario been determined according to the methodology? B.2.4. Has the baseline scenario been determined using
/1/
DR/I
Yes, the baseline scenario has been CL-1 determined according to the methodology. However CL-1 needs to be addressed. Refer to B.2.2 CL-1
OK
/1/
DR/I
OK A-9
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
conservative assumptions where possible? B.2.5. Does the baseline scenario sufficiently take into account relevant national and/or sectoral policies, macro-economic trends and political aspirations? B.2.6. Is the baseline scenario determination compatible with the available data and are all literature and sources clearly referenced? B.4.1. Have the major risks to the baseline been identified? B.3. Additionality Determination
The assessment of additionality will be validated with focus on whether the project itself is not a likely baseline scenario. /1/ DR/I
Yes, national and sectoral policies have been taken into account.
OK
/1/
DR/I
Yes.
OK
/1/
DR/I
The baseline scenario has been determined using conservative assumptions.
OK
B.3.1. Is the project additionality assessed according to the methodology?
/1/ /4/ /31/ /23/ /28/ /30/
DR/I
The assessment and demonstration of the CL-2 additionality has been done as per the latest additionality tool, version 5.2. Step 1a: Define alternatives to the project activity: Alternative 1: The proposed project activity not undertaken as a CDM project activity Alternative 2: No project activity, or the continuation of the present scenario of drawing power from the grid. Both alternatives are realistic and credible to the project activity.
OK
A-10
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
Step 1b: Consistency with mandatory laws and regulations: Both the identified alternatives are in compliance with the laws and regulations. Step 2: Investment Analysis: The benchmark analysis has been selected to demonstrate the additionality of the project. The internal rate of return (IRR) has been considered as the benchmark parameter. The project proponent, ONGC is public sector undertaking and has its established internal benchmark (hurdle rate) of 12 % (post tax) for developmental projects. The document confirming the internal benchmark ONGC Order No. MUM/PAS/PROJ/APPR/RR/2007 dated 11 June, 2007, Para 3.1.has been evidenced and is reasonable compared to the 14% CERC benchmark. The order also clarifies that the target IRR for acceptance of investment proposals (development projects) would now be considered at a minimum rate of 12% (post tax). However, in respect of projects with IRR of less than 12% (post tax), the right to reject such projects would continue to vest with the Corporate Management. The IRR of the project activity has been calculated to be at 10.59% (without CDM revenues) and lower than the hurdle rate of
A-11
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
12% and hence project is not financially attractive. The following need to be clarified with evidence. a) The appropriateness of the benchmark selected As per the EB 41, Annex 45, Point 13, the PP is also requested to demonstrate that the internal benchmark has been consistently applied by the company for at least 3 years in relation to similar projects thorough the financial statements, and also provide evidence on the acceptance and rejection of project with this benchmark (hurdle rate). b) It also needs to be clarified on the plant load factor used in the IRR calculation. The PDD states the PLF as 22.28%. (based on consultants recommendations) The excel worksheet uses a PLF of 23.44%. The PLF is also to be justified as the GERC order dated 11 August 2006 states the CUF at Surajbari site to be 25.68%. c) The PP is requested to clarify on application of MAT to the project activity and ONGC and also on the value of 11.33% used in the calculation. It also needs to be clarified if the MAT is to be payable for the entire 20 years or till the time the income tax holiday exists. d) O& M values used for ONGC are to be
A-12
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
justified with a split-up. Step 2d: Sensitivity Analysis: The sensitivity analysis has been done considering the parameters of a) Capex Capital Expenditure on the project b) Opex - Operating expenses for the project c) Generation - Electricity generated by the project. considering an variation of + 10 % and + 20 % in Capex and Opex values and reduction on 10 % to 20 % in generation results in decrease of the IRR for the project activity. The sensitivity analysis is to be carried out considering increase in generation. The analysis is also to be carried out for variations at which the IRR crosses the benchmark and also justify why the variation is not likely. Step 3: Barrier Analysis: As per the PP, after conducting sensitivity analysis, the CDM project activity is not financially attractive, the PP has not discussed the Barrier Analysis. Step 4: Common Practice Analysis: Step 4a: Analyze other activities similar to the proposed project activity: The PP has provided information on wind
A-13
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
power generation capacity of India and the respective state along with installed capacities. As per the information, India has gross potential of 45195 MW of wind power against which only 5340.6 MW has been utilized. Thus only 4.2 % of the total installed capacity for power generation (including fossil fuel based power plants) For the case of Gujarat state, the highest gross potential for wind power generation is 9675 MW and out of that only 338.1 MW has been utilized as of 31/03/2006. The data provided for installed capacity for Gujarat state needs to be updated to 2007. The PP is requested to also provide cross reference of gross potential and installed capacity from more authentic body. Step 4b: Discuss any similar options that are occurring: As argued by the PP, a couple of wind of energy based power projects acting as independent power projects (IPP) of this capacity similar to the proposed project activity in Gujarat. However, all such projects are being implemented as CDM projects. Its because IPPs of such size are not financially attractive with CDM benefits. The PP is requested to provide data on how
A-14
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
many projects are implemented in Gujarat, out such project how many have implemented keeping CDM in focus. It is also to be clarified as to how many projects of similar capacity at the Surajbari location are CDM projects or applying for CDM revenues? B.3.2. Are all assumptions stated in a transparent and conservative manner? B.3.3. Is sufficient evidence provided to support the relevance of the arguments made? B.3.4. If the starting date of the project activity is before the date of validation, has sufficient evidence been provided that the incentive from the CDM was seriously considered in the decision to proceed with the project activity?
/1/ DR/I
Refer to B.3.1
CL 2
OK
/1/
DR/I
Refer to B.3.1
CL 2
OK
/1/ /8/
DR/I
The starting date of the project activity is CAR 3 stated to be 06 November 2007, (Notification of Award for the project activity to Suzlon). And it is before the start of validation. The serious consideration of incentives from CDM has been demonstrated by the board note mentioning the expected IRR would be less than the benchmark and the considering revenue from CDM project, the same has been implemented. Chronological order of events from the conceptualization of the project activity till approaching the DOE for validation along with reasons for delay need to be provided with supporting evidences.
OK
B.4. Calculation of GHG Emission Reductions Project

A-15
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
emissions
It is assessed whether the project emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified.
B.4.2. Are the calculations documented according to the approved methodology and in a complete and transparent manner? B.4.3. Have conservative assumptions been used when calculating the project emissions? B.4.4. Are uncertainties in the project emission estimates properly addressed? B.5. Calculation of GHG Emission Reductions Baseline emissions
It is assessed whether the baseline emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified.
/1/
DR/I
There are no project emissions in this project activity.
OK
/1/
DR/I
Refer to B.4.1
OK
/1/
DR/I
Refer to B.4.1
OK
B.3.5. Are the calculations documented according to the approved methodology and in a complete and transparent manner?
/1/ /6/
DR/I
Baseline emissions have been estimated as CAR 2 the product of net electricity displaced to the Western regional grid by the project activity per year and grid emission factor of the Western regional grid, which has been obtained from the official website of the Central Electricity authority (CEA) CO2 Baseline Database for the Indian Power Sector User Guide - Version 3.0.
OK
A-16
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
Baseline emission factor for the western regional grid is established ex-ante based on the approved methodology using a combined margin approach consisting 75% operating margin and 25% build margin approach. The combined margin emission coefficient for the southern regional grid of India has been determined to be 0.89 t CO2e/MWh. The operating margin has been estimated to be 1.00 t CO2/MWh and the build margin to be 0.59 tCO2/MWh. The PP needs to apply the latest version of the CEA database for fixing the emission factor. B.3.6. Have conservative assumptions been used when calculating the baseline emissions? B.3.7. Are uncertainties in the baseline emission estimates properly addressed? B.6. Calculation of GHG Emission Reductions Leakage
It is assessed whether leakage emissions are stated according to the methodology and whether the argumentation for the choice of default factors and values where applicable is justified. /1/ DR/I
Yes. The chosen baseline is in accordance with the baseline methodology. There are no uncertainties in the baseline emissions.
OK
/1/
DR/I
OK
B.6.1. Are the leakage calculations documented according to the approved methodology and in a complete and transparent manner?
/1/
DR/I
For Wind based energy generation projects Project the PP do not need to calculate leakage in applying this methodology.
OK
A-17
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV* /1/ DR/I
COMMENTS
Draft Concl.
Final Concl.
B.6.2. Have conservative assumptions been used when calculating the leakage emissions? B.6.3. Are uncertainties in the leakage emission estimates properly addressed? B.7. Emission Reductions The emission reductions shall be real, measurable and give long-term benefits related to the mitigation of climate change. B.7.1. Are the emission reductions real, measurable and give long-term benefits related to the mitigation of climate change.
NA
OK
/1/
DR/I
NA
OK
/1/
DR/I
The project activity is expected to result in CAR 2 emission reduction of 85 762 tCO2e annually through out the first crediting period of 7 years. This figure is to be recalculated using the latest grid emission factors published by the CEA.
OK
B.8. Monitoring Methodology

It is assessed whether the project applies an appropriate monitoring methodology.
B.8.1. Is the monitoring plan documented according to the approved methodology and in a complete and transparent manner?
/1/ /3/
DR/I
The monitoring plan documented is as per the CAR 4 approved consolidate methodology ACM 0002, version 07 and in a complete & transparent manner. The monitoring of the net electricity generated is not clear in the PDD and needs to be elaborated considering that the uploading meter is not dedicated to the
OK
A-18
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
project activity. B.8.2. Will all monitored data required for verification and issuance be kept for two years after the end of the crediting period or the last issuance of CERs, for this project activity, whichever occurs later? B.9. Monitoring of Project Emissions
It is established whether the monitoring plan provides for reliable and complete project emission data over time. /1/ DR/I
Yes, all monitored data required for verification and issuance will be kept for two years after end of the crediting period.
OK
B.9.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for estimation or measuring the greenhouse gas emissions within the project boundary during the crediting period? B.9.2. Are the choices of project GHG indicators reasonable and conservative? B.9.3. Is the measurement method clearly stated for each GHG value to be monitored and deemed appropriate? B.9.4. Is the measurement equipment described and deemed appropriate? B.9.5. Is the measurement accuracy addressed and deemed appropriate? Are procedures in place on how to deal with erroneous measurements?
/1/
DR/I
Being a wind power project no project emissions are expected to occur.
OK
/1/
DR/I
NA
OK
/1/
DR/I
NA
OK
/1/
DR/I
NA
OK
/1/
DR/I
NA
OK
A-19
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV* /1/ DR/I
COMMENTS
Draft Concl.
Final Concl.
B.9.6. Is the measurement interval identified and deemed appropriate? B.9.7. Is the registration, monitoring, measurement and reporting procedure defined? B.9.8. Are procedures identified for maintenance of monitoring equipment and installations? Are the calibration intervals being observed? B.9.9. Are procedures identified for day-to-day records handling (including what records to keep, storage area of records and how to process performance documentation) B.10. Monitoring of Baseline Emissions
It is established whether the monitoring plan provides for reliable and complete baseline emission data over time.
NA
OK
/1/
DR/I
NA
OK
/1/
DR/I
NA
OK
/1/
DR/I
NA
OK
B.10.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining baseline emissions during the crediting period?
/1/
DR/I
For baseline calculations, net electricity CAR 4 exported to the grid by the project activity will be monitored by the receipt of uploaded electricity by GETCO. The same would be determined using meters installed at the substation. During the site visit, it was observed that there are five meters installed at the substation where the net generated electricity generated would be uploaded to the grid; the PP is requested to elaborate on the determination of net electricity generation
OK
A-20
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
that would be uploaded to the grid along with calibration certificates for those five meters. The PP is requested to clarify on para 3 described in the section B.7.2 for determination of electricity generated which is inconsistent with section B.7.1 of the PDD. B.10.2. Are the choices of baseline GHG indicators reasonable and conservative? B.10.3. Is the measurement method clearly stated for each baseline indicator to be monitored and also deemed appropriate?
/1/ DR/I
The choice of CO2 as GHG indicator is reasonable and conservative. Yes. The project uses the ex-ante determination of emission factor for grid. The project proponent will monitor the net amount of electricity delivered to the grid through receipt received from GETCO and same value will be used for Emission reduction calculation. The PP is requested to include measurement CL 3 equipment used for determination of grid uploaded electricity. The PP is requested to address the accuracy CL 3 of measurement equipment and also the tag numbers. Procedures to deal with erroneous measurements have been addressed in the PDD. The measurement interval for baseline data
OK
/1/
DR/I
OK
B.10.4. Is the measurement equipment described and deemed appropriate?
/1/
DR/I
OK
B.10.5. Is the measurement accuracy addressed and deemed appropriate? Are procedures in place on how to deal with erroneous measurements?
/1/
DR/I
OK
B.10.6. Is the measurement interval for baseline data

/1/
DR/I
OK A-21
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
identified and deemed appropriate? B.10.7. Is the registration, monitoring, measurement and reporting procedure defined? B.10.8. Are procedures identified for maintenance of monitoring equipment and installations? Are the calibration intervals being observed?
/1/ DR/I
has been identified as monthly basis which is appropriate. Yes, the registration, monitoring, measurement and reporting procedure has been defined and addressed in the PDD. Procedures for maintenance of monitoring CL 3 equipment and installations have been identified. The calibration intervals of monitoring equipment and installations need to be addressed in the PDD. The PP is requested to clarify on validity of O & M contract with the manufacturer of turbines. Procedures for day-to-day records handling CL 3 need to be identified. OK
/1/
DR/I
OK
B.10.9. Are procedures identified for day-to-day records handling (including what records to keep, storage area of records and how to process performance documentation) B.11. Monitoring of Leakage
It is assessed whether the monitoring plan provides for reliable and complete leakage data over time.
/1/
DR/I
OK
B.11.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining leakage? B.11.2. Are the choices of project leakage indicators reasonable and conservative?
/1/
DR/I
Monitoring plan for leakage emission is not required for wind project.
OK
/1/
DR/I
NA
OK
A-22
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV* /1/ DR/I
COMMENTS
Draft Concl.
Final Concl.
B.11.3. Is the measurement method clearly stated for each leakage value to be monitored and deemed appropriate? B.12. Monitoring of Sustainable Development Indicators/ Environmental Impacts
It is assessed whether choices of indicators are reasonable and complete to monitor sustainable performance over time.
NA
OK
B.12.1. Is the monitoring of sustainable development indicators/ environmental impacts warranted by legislation in the host country? B.12.2. Does the monitoring plan provide for the collection and archiving of relevant data concerning environmental, social and economic impacts? B.12.3. Are the sustainable development indicators in line with stated national priorities in the Host Country? B.13. Project Management Planning
It is checked that project implementation is properly prepared for and that critical arrangements are addressed.
/1/
DR/I
The DNA of India does not warrant monitoring of sustainable development indicators. NA
OK
/1/
DR/I
OK
/1/
DR/I
Project activity is in line with Host country sustainable development indicators.
OK
B.13.1. Is the authority and responsibility of overall project management clearly described?
/1/
DR/I
The overall authority and responsibility of the project management is with the project proponent whereas the O & M responsibility lies with Suzlon Energy. The responsibility
OK
A-23
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
for registration, monitoring, measurement and reporting is with ONGC. B.13.2. Are procedures identified for training of monitoring personnel? B.13.3. Are procedures identified for emergency preparedness for cases where emergencies can cause unintended emissions? B.13.4. Are procedures identified for review of reported results/data? B.13.5. Are procedures identified for corrective actions in order to provide for more accurate future monitoring and reporting? C. Duration of the Project/ Crediting Period
It is assessed whether the temporary boundaries of the project are clearly defined. /1/ DR/I
Provisions for training of monitoring personnel have been undertaken by SEL which is contracted for O&M of the plant. No GHG emission related to project is expected to occur.
OK
/1/
DR/I
OK
/1/
DR/I
Procedures for review of reported results/data CL 3 need to be addressed in the PDD. Yes
OK
/1/
DR/I
OK
C.1.1. Are the projects starting date and operational lifetime clearly defined and evidenced?
/1/ /8/
DR/I
Starting date of the project activity is stated to be November 06, 2007. Operational lifetime of the project has been addressed as 20 years which is reasonable. Start date of the project is 01 November 2009 CAR 5 or the date of registration. The start date of the project activity needs to be changed as it taken minimum eight weeks for large scale project activity once the
OK
C.1.2. Is the start of the crediting period clearly defined and reasonable?
/1/
DR/I
OK
A-24
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
project is submitted for registration. D. Environmental Impacts

Documentation on the analysis of the environmental impacts will be assessed, and if deemed significant, an EIA should be provided to the validator.
D.1.1. Has an analysis of the environmental impacts of the project activity been sufficiently described?
/1/ /7/
DR/I
Indian legislation does not warrant an EIA to be done for this type of project activity; the PDD sufficiently describes the possible impacts during construction & operation. No specific environmental clearances are required for wind farm projects in India.
OK
D.1.2. Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, is an EIA approved? D.1.3. Will the project create any adverse environmental effects? D.1.4. Are transboundary environmental impacts considered in the analysis? D.1.5. Have identified environmental impacts been addressed in the project design? D.1.6. Does the project comply with environmental legislation in the host country? E. Stakeholder Comments
The validator should ensure that stakeholder comments have been invited with appropriate media and that due account has been taken of any comments received.
/1/
DR/I
OK
/1/
DR/I
No the project will not create any adverse environmental effects. As, the proposed project is a wind farm project, the impacts are expected to be minimal. No negative impact has been identified.
OK
/1/
DR/I
OK
/1/
DR/I
OK
/1/
DR/I
Yes
OK
A-25
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV* /1/ /18/ /19/ DR/I
COMMENTS
Draft Concl.
Final Concl.
E.1.1. Have relevant stakeholders been consulted?
Yes, Stake-Holder Consultation Meeting was held at the Jakhau site of the Wind Power Project set-up by ONGC, on 18th August 2008. The stakeholders identified are: Local resident villagers, farmers and land owners Civic Bodies/ Statutory Authorities Internal Employees Technology supplier The same has been evidenced through the minutes of meeting with local stake holders. The invitation was published in local language news paper along with letters to respective gram panchayat prior to the stake holder consultation meeting. The same has been evidenced during the site visit. A stakeholder consultation is not required by the DNA of India for such kind of project activity.
OK
E.1.2. Have appropriate media been used to invite comments by local stakeholders?
/1/ /18/ /22/
DR/I
OK
E.1.3. If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws? E.1.4. Is a summary of the stakeholder comments received provided? E.1.5. Has due account been taken of any stakeholder comments received?
/1/
DR/I
OK
/1/
DR/I
No negative comments were received.
OK
/1/
DR/I
Not accounted for, as no negative comments were received.
OK
A-26
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
A-27
DET NORSKE VERITAS
Table 2b: Additional requirements checklist for VVM version 1 (EB 44)
CHECKLIST QUESTION Ref. MoV* COMMENTS Draft Concl. Final Concl.
A.5. Letter of approval A.5.1 Is the LoA received directly from the DNA or through the project participant. /1/ /5/ DR/I The LoA was received through the project participant. OK
A.6. Project design A.6.1 Does the PDD describe the CDM project activity with all relevant elements in a transparent and accurate way? A.6.2 Has the CDM project activity at the start of the validation been constructed or does the CDM project activity use existing facilities or equipment? A.6.3 Is the project a large scale project, a small scale project with average annual emission reductions above 15 000 tonnes or a bundled small scale project? Has on-site visit been carried out? A.6.4 Does the project activity involve alteration of existing installations? If so, have the differences between pre-project and post-project activity been clearly described in the PDD? /1/ DR/I Yes, the PDD describes the CDM project activity with all relevant elements in a transparent and accurate way. DR/I The CDM project activity (installation of wind mills) has been constructed at the start of the validation. Project activity does not use any existing facilities or equipment. DR This is a large scale project, with estimated annual emission reductions of 85 762 tonnes. The on-site visit was carried out by the GHG auditor of DNV. No. The project activity involves installation of new wind energy generators. Sinc this is a new project, the differences between preproject and post-project activity are not described in the PDD Yes. The methodology sufficiently describes all project emission sources for the project OK
/1/
OK
/1/
OK
/1/
DR
OK
A.7. Project emissions not addressed by the methodology A.7.1 Does the methodology describe all project emission source for the project activity that contributes all 1% of the emission
/1/
DR
OK
A-28
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
reductions? Sources that the methodology considers not to take into account are not relevant (e.g. cement and iron consumption for building hydropower plants). A.8. Documentation of baseline emissions A.8.1 Documentation of the baseline determination: a. All assumptions and data used by the project participants are listed in the PDD and related document to be submitted for registration. The data are properly referenced. b. All documentation is relevant as well as correctly quoted and interpreted. c. Assumptions and data can be deemed reasonable d. Relevant national and/or sectoral policies and circumstances are considered and listed in the PDD. e. The methodology has been correctly applied to identify what would occurred in the absence of the proposed CDM project activity A.9. Documentation of the calculations A.9.1 Algorithms and/or formulae used to determine emission reductions All assumptions and data used by the project participants are listed in the PDD and related document submitted for registration. The data are properly referenced All documentation is correctly quoted and interpreted.
/3/
activity that contributes to more than 1% of the emission reductions. Sources that the methodology considers not to take into account are not relevant DR Yes. All assumptions and data used by the project participants are listed in the PDD and related document to be submitted for registration. The data are properly referenced. Yes. All documentation is relevant as well as correctly quoted and interpreted. Yes. Assumptions and data can be deemed reasonable Yes. Relevant national and/or sectoral policies and circumstances are considered and listed in the PDD. Yes. The methodology has been correctly applied to identify what would have occurred in the absence of the proposed CDM project activity OK
/1/ /3/
/1/ /3/
DR/I Yes. All assumptions and data used by the project participants are listed in the PDD and related document submitted for registration. The data are properly referenced Yes. All documentation is correctly quoted and interpreted. Yes. All values used can be deemed
OK
A-29
DET NORSKE VERITAS
CHECKLIST QUESTION
Ref. MoV*
COMMENTS
Draft Concl.
Final Concl.
All values used can be deemed reasonable in the context of the project activity The methodology has been correctly applied to calculate the emission reductions and this can be replicated by the data provided in the PDD and supporting files to be submitted for registration.
reasonable in the context of the project activity Yes. The methodology has been correctly applied to calculate the emission reductions and this can be replicated by the data provided in the PDD and supporting files to be submitted for registration. /1/ DR/I The project participant has entered into an agreement with the supplier of WEGs for O&M contract for 20 years. The PDD describes in detail the QA/QC procedures proposed. The projected emission reductions are expected to be achieved depending on the actual PLF during operation of WEGs. DR Yes
A.10. Implementation of the monitoring plan A.10.1 How were the plans for implementation of the monitoring plan, data management, QA/QC procedures assessed? To what extent can the emission reductions achieved by the project by monitored ex-post and verified later by a DOE?
A.11. CDM consideration prior to starting date A.7.1 The prior consideration of CDM for the project activity complies with EB41 annex 46 /1/ /14/ The prior consideration of CDM in the project is demonstrated through the Internal office memo demonstrating CDM awareness dtated 26 October 2007. The parallel action to secure CDM revenues is demonstrated by chronology of events, described in section B.5 of the PDD. This is in compliance with EB 41 annex 46 guidelines. Yes
A-30
DET NORSKE VERITAS
Table 3
Resolution of Corrective Action and Clarification Requests

Summary of project owner response Validation team conclusion
Draft report clarifications and corrective action requests by validation team
Ref. to checklist question in table 2 Table 1, CAR 1 A.2.2, The LoA from the DNA, India need to be A.2.3, provided. A.4.1 CAR 2
The Host Country Approval dated 17 OK. Copy of Host Country Approval /5/ April 2009 has been provided to DOE. has been provided. CAR 1 is closed. In line with the VVM requirements, the original emission factor selected in the web-hosted PDD based on CO2 Baseline Database for the Indian Power Sector, Version 3.0, December 2007 has been retained in the revised PDD. OK. At the time web hosting of PDD, CEA database version 03 was applicable. The same is retained for CER calculations. CAR 2 is closed. OK. Chronological order of events from the conceptualization of the project activity till the starting of validation has been described in section B.5 of the revised PDD. CAR 3 is closed. OK. The monitoring procedure is described in section B.7.1 and B.7.2 of the PDD. The test certificates of the meters /32/ were provided for validation. CAR 4 is closed.
PDD is to be corrected to reflect the change project boundaries as per CEA database version 04. The PP needs to apply the latest version of the CEA database for fixing the emission factor.
CAR 3
Table 1, A.1.2, B.1.3, B.3.5, B.7.1
B.3.4
Chronological order of events from the conceptualization of the project activity till approaching the DOE for validation along with reasons for delay need to be provided with supporting evidences. The chronology is to be elaborated in the PDD.
CAR 4
The Section B.5 of the revised PDD presents chronology of the activities undertaken by the project. The internal office memo demonstrating CDM awareness and the appointment of CDM consultant had taken place prior to the starting date of the project. The monitoring plan for the project activity has been detailed in the updated PDD. The electricity generated by the 34 machines moves to the Suthari substation through feeder numbers 3, 4 and 5 and is uploaded to the grid via the main meter managed by GETCO at
The monitoring of the net electricity generated is not clear in the PDD and needs to be elaborated considering that the uploading meters are not dedicated to the project activity. During the site visit, it was observed that there are five meters installed at the substation where
B.8.1, B.10.1
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Ref. to checklist question in table 2
Summary of project owner response
Validation team conclusion
the net generated electricity generated would be uploaded to the grid; the PP is requested to elaborate on the determination of net electricity generation that would be uploaded to the grid along with calibration certificates for those five meters. The PP is requested to clarify on para 3 described in the section B.7.2 for determination of electricity generated which is inconsistent with section B.7.1 of the PDD.
CAR 5 C.1.2
Suthari substation. The meter serial numbers, test certificates and calibration certificates have been provided to DOE. Please see Sections B.7.2 and B.7.1 of the updated PDD for clarifications.
The start date of the project crediting period needs to be changed as it takes a minimum of eight weeks for large scale project activity once the project is submitted for registration.
CL 1.
The Section C.2.1.1 of the updated PDD has been updated with the estimated date of registration of the project activity that is also the start date of crediting period of the project activity.
OK, Start date of the crediting period is corrected to 1 September 2009 in the revised PDD CAR 5 is closed
The PP is requested to discuss and justify on the other alternatives available like, fossil fuel, renewable sources like hydro etc and state why these are not likely baseline scenarios.
CL 2
B.2.2, B.2.3, B.2.4
The other alternatives like fossil fuel OK. The alternative scenarios have been power plants, renewable sources like discussed in the updated PDD. hydro power etc. have been discussed in the Section B.5 of the updated PDD. CL 1 is closed. a) The common benchmark applicable to ONGC development projects and the ONGC Circular No. MUM/PAS/PROJ/APPR/RR/2007 dated June 11, 2007. The internal benchmark has been applied by the a) The internal benchmark of 12% / 23/ has been applied correctly and in line with the guidance of the CDM Executive Board as provided in the Para 13, Annex 45, EB 41. PP has also provided evidence for use of the internal A-32
a) The PP is requested to justify on appropriateness of the benchmark selected As per the EB 41, Annex 45, Point 13, the PP is also requested to demonstrate that the internal benchmark has been consistently applied by the
Table 1, B.3.1, B.3.2, B.3.3
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company for at least 3 years in relation to similar projects thorough the financial statements, and also provide evidence on the acceptance and rejection of project with this benchmark (hurdle rate). b) It also needs to be clarified on the plant load factor used in the IRR calculation. The PDD states the PLF as 22.28%. (based on consultants recommendations) The excel worksheet uses a PLF of 23.44%. The PLF is also to be justified as the GERC order dated 11 August 2006 states the CUF at Surajbari site to be 25.68%. c) The PP is requested to clarify on application of MAT to the project activity and ONGC and also on the value of 11.33% used in the calculation. It also needs to be clarified if the MAT is to be payable for the entire 20 years or till the time the income tax holiday exists. d) O& M values used for ONGC are to be justified with a split-up. e) The sensitivity analysis is to be carried out considering increase in generation. The analysis is also to be carried out for variations at which the IRR crosses the benchmark and also justify why the variation is not likely.
project proponent on other projects also. Such project cases dated 24 November 2008 and 15 June 2007 have been provided as evidence of using the benchmark for acceptance of projects, and project case dated 18 December 2008 for use of bechmark for rejection. The conservativeness of the internal benchmark is demonstrated by the State Bank of India's lending rate at the time of decision to go ahead with the project was 12.75%, which is higher than the benchmark of 12%. b) The GERC order refers to the Capacity Utilization Factor(CUF) that depends on several factors such as wind velocity, air density, quality, capacity and age of machines, height of hub, and length of the blades. The maximum CUF achieved at Surajbari Kutch was 25.68% based on the analysis of performance of different WTGs and based on the divergent responses received by the GERC. The CUF would thus vary from project to project depending upon the actual factors at the project site. The PLF of
benchmark for acceptance/ rejection of other projects to the DOE. The reasonableness of the benchmark is demonstrated by the 12.75% interest rate for advances charged by SBI for the period of October and November 2007 /24/. b) PP has used the PLF estimated by the independent consultant /28/ for each of the offers before the opening of price bids. The estimated PLF for the 1500 kW WEGs of Suzlon at Jakhau site was 22.28%. IRR spread sheet is available for review. c) MAT is not applicable to ONGC, since it is a profitable company, paying income tax at normal rates. d) The evidence for other O&M costs have been provided. e) Sensitivity analysis corrected. f) In the revised PDD, wind energy data of Gujarat is updated with data from Windpower India.com /30/. g) PP corrected the Common practice analysis. In the revised PDD, PP has detailed the wind projects in Gujarat applying for CDM.
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f) The data provided for installed capacity for Gujarat state is to be updated to 2007 data. The PP is requested to also provide cross reference of gross potential and installed capacity from more authentic body. g) The PP is requested to provide data on how many projects are implemented in Gujarat, out such project how many have implemented keeping CDM in focus. It is also to be clarified as to how many projects of similar capacity at the Surajbari location are CDM projects or applying for CDM revenues?
22.28% determined for the project is based on the estimated energy CL 2 is closed. generation worked out by the projects external consultant MPWL after applying correction factors to the bidders proposed generation figures and the same was used for evaluation of bids. The soft copy of the updated IRR sheet with the PLF of 22.28% is provided. c) It has been clarified that the MAT is not applicable to the project activity and ONGC. The IRR sheet has been updated accordingly. d) The break up of the O & M values for ONGC are as follows: GEDA Certification fee @ Rs.0.10 Lac/MW; lease rental to government agency @ Rs.0.10 lac per hectare and department support assuming 2 officers for supervision (Rs.10 lakhs/person with 100% overhead). An escalation of 5% every year for OPEX costs is also considered. e)The sensitivity analysis has been carried out for the increase in generation figures also. f) Updated data on the gross wind A-34
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energy potential of Gujarat for 2007 and details on similar CDM projects in Gujarat region are provided in Section B.5, Substep 4a of the updated PDD. g) The data from publicly available reliable sources has been used to compile the list of projects in Gujarat that are comparable to the project activity. This list is presented in Section B.5, Substep 4a of the revised PDD. It is also analysed that similar projects are also being developed as CDM projects. Thus, it has been shown that development of similar wind power projects in Gujarat without CDM is not a common practice.
CL 3
The PP is requested to include measurement equipment used for determination of grid uploaded electricity. The PP is requested to address the accuracy of measurement equipment and also the tag numbers. The calibration intervals of monitoring equipment and installations need to be addressed in the PDD. The PP is requested to clarify on validity of O
B.10.4, B.10.5, B.10.8, B.10.9, B.13.4
The measurement equipment used for determination of grid uploaded electricity and the tag numbers are provided in Annexure CAR4B . The accuracy class of the measurement equipment is provided in the calibration certificates at 0.2s and the calibration certificates providing accuracy class of the main meters is appended as Annex CL3. The calibration intervals of monitoring equipment has been addressed in the Section B.7.1 of the
The calibration certificates of electricity meters and their accuracy class has been provided /32/. The revised PDD addresses the issues relating to calibration of equipment, day to day handling of records and procedure for review of data and corrective actions. The CL 3 is closed.
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& M contract with the manufacturer of turbines. Procedures for day-to-day records handling need to be identified. Procedures for review of reported results/data need to be addressed in the PDD.
PDD. The O & M contract has not been finalized yet, however, the draft O & M Agreement mentions the validity of the contract for the first 10 years to be renewed later. The procedure for daily recording is that Suzlon sends in the daily generation reports of all machines to the Technical services team at ONGC Dehradun office. The reported data is stored and maintained by the Technical Services at Dehradun office in electronic format.
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APPENDIX B
CERTIFICATES OF COMPETENCE
CERTIFICATE OF COMPETENCE Murali Govindarajulu

Qualification in accordance with DNVs Qualification Scheme CDM/JI (ICP-9-8-i1-CDMJI-i1 GHG Auditor: Technical Area Landfill gas Renewables Hydro power Wind power Other renewable Jan 2009 Jan 2009 Yes CDM Validator CDM Verifier Sector Expert Methodology Expert Technical Reviewer
Biomass Grid connection of isolated system Cement Waste-heat / waste-gas recovery Efficiency of thermal power plants Coal mine methane Fuel switch Manure management Waste / wastewater treatment Energy efficiency N2O HFCs Flare reduction PFCs Charcoal CO2 recovery Transport Non-renewable biomass Biofuel Pipeline leakage reduction SF6
Jan 2009
Hvik, 9 January 2009
Michael Lehmann Technical Director, Climate Change Services
CERTIFICATE OF COMPETENCE Ravi Kumar Prabhu

Qualification in accordance with DNVs Qualification Scheme CDM/JI (ICP-9-8-i1-CDMJI-i1 GHG Auditor: Technical Area Landfill gas Renewables Hydro power Wind power Other renewable Yes CDM Validator CDM Verifier Sector Expert Methodology Expert Technical Reviewer
Hvik, 1 December 2008 Michael Lehmann Technical Director, Climate Change Services
CERTIFICATE OF COMPETENCE Shivraj Sharma

Qualification in accordance with DNVs Qualification Scheme CDM/JI (ICP-9-8-i1-CDMJI-i1 GHG Auditor: Technical Area Landfill gas Renewables Hydro power Wind power Other renewable Yes CDM Validator CDM Verifier Sector Expert Methodology Expert Technical Reviewer
Hvik, 9 January 2009 Michael Lehmann Technical Director, Climate Change Services
CERTIFICATE OF COMPETENCE Raman Venkata Kakaraparthi

Qualification in accordance with DNVs Qualification Scheme CDM/JI (ICP-9-8-i1-CDMJI-i1 GHG Auditor: Technical Area Landfill gas Renewables Hydro power Wind power Other renewable Yes CDM Validator Jan 2009 Jan 2009 Jan 2009 Jan 2009 CDM Verifier Sector Expert Methodology Expert Technical Reviewer
Jan 2009
Jan 2009
Jan 2009
Jan 2009
Jan 2009
Jan 2009 Jan 2009 Jan 2009
Jan 2009 Jan 2009 Jan 2009
Jan 2009 Jan 2009
Jan 2009
Jan 2009
CERTIFICATE OF COMPETENCE Anjana Sharma

Qualification in accordance with DNVs Qualification Scheme CDM/JI (ICP-9-8-i1-CDMJI-i1 GHG Auditor: Technical Area Landfill gas Renewables Hydro power Wind power Other renewable Jan 2009 Jan 2009 Jan 2009 Yes CDM Validator CDM Verifier Sector Expert Methodology Expert Jan 2009 Technical Reviewer Jan 2009

Project On ONGC Validation

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Project On ONGC Validation

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VALIDATION REPORT

51 MW wind power project of ONGC at Surajbari, Gujarat in India

REPORT NO. 2008-0065

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Climate Change Services

Oil and Natural Gas Corporation Limited

Mr. Ashok B. Chakraborty

51 MW wind power project of ONGC at Surajbari, Gujarat in India in India

Climate Change Kyoto Protocol Validation Clean Development Mechanism

Shivraj Sharma, G. Murali, Ravi Kumar Prabhu

Kakaraparthi Venkata Raman (Draft) Anjana Sharma (Final)

Appendix A: Validation Protocol Appendix B: Certificates of Competence

1 EXECUTIVE SUMMARY VALIDATION OPINION

3.1 Desk Review of the Project Design Documentation

/38/ /39/ /40/ /41/ /42/ /43/

3.2 Follow-up Interviews with Project Stakeholders

3.3 Resolution of Outstanding Issues

Figure 1 Validation protocol tables

3.4 Internal Quality Control

3.5 Validation Team

Last Name Govindarajulu Kaliaperumal Prabhu Sharma Kakaraparthi Sharma

First Name Murali Ravi Kumar Shivraj Venkata Raman Anjana

Country India India India India India

4.1 Participation Requirements

4.2 Project Design

4.3 Baseline Determination

4.4.1 CDM consideration and continued action to secure CDM status

4.4.2 Identification of alternatives to project activity

Project approval note /11/

4.5.1 Parameters determined ex-ante

4.5.2 Parameters monitored ex-post

4.5.3 Management system and quality assurance

4.6 Estimate of GHG Emissions

4.7 Environmental Impacts

4.8 Comments by Local Stakeholders

4.9 Comments by Parties, Stakeholders and NGOs

The response received from the project participant to the comments:

Stakeholder: Hiral Mehta / Mahesh Pandya

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Mandatory Requirements for Clean Development Mechanism (CDM) Project Activities

CDM Validation Protocol Report No.2008-0065, rev. 02

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CDM Validation Protocol Report No.2008-0065, rev. 02

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CDM Validation Protocol Report No.2008-0065, rev. 02

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CDM Validation Protocol Report No.2008-0065, rev. 02

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General Description of Project Activity

A.1. Project Boundaries

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Ref. MoV* /1/ DR/I

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The Project utilizes manufactured equipments generation.

indigenously for power

A.4. Contribution to Sustainable Development

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B.1. Baseline Methodology

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B.2.1. What is the baseline scenario?