Larion Power Corporation Limited: V 12 MW G C B P P

TUV Industrie Service GmbH
TUV Rheinland Group
VALIDATION REPORT
CLARION POWER
CORPORATION LIMITED
VALIDATION OF THE
12 MW GRID CONNECTED
BIOMASS POWER PLANT
REPORT NO. 4002IS

REVISION NO. 05
CDM Validation Report Template

Version 3.0, December 2003
TUV INDUSTRIE SERVICE GMBH TUV RHEINLAND GROUP
VALIDATION REPORT
Date of first issue: Project No.:

2005-01-13 4002is TUV Rheinland Group
Approved by: Organisational unit:
Systems Certification Group, Am Grauen Stein
Christian Rathje Industrial Engineering Services 51105 Koln, Germany
Client: Client ref.: Certificate Number

Clarion Power Corporation Limited R. S. Sreenivas 01 997 9105025753
Executive Summary:
M/s Clarion Power Corporation Limited (CPCL) has established a 12 MW grid connected biomass based
power project at village Tanguturu; district Prakasam, Andhra Pradesh, India. The project intends to use locally
produced low cost biomass waste and biomass generated through agro forestry projects. It is assumed that
the biomass energy generation is carbon neutral when biomass is harvested sustainably (reference: Revised
IPCC Guidelines 1996, Volume 1) and hence, considered net zero emitting for carbon-di-oxide (CO2)
emissions. Thus, CPCL proposes a cleaner electricity generation project compared to the existing fossil fuel
dominated local grid.
This report summarizes the results of the document review, background investigation, follow-up interviews with
local stakeholders and the staff at the project site during the visit to the CPCL power plant at Tangutur (Andhra
Pradesh). This has been during and after the process of the stakeholder consultation wherein the draft CDM
PDD of the proposed project was available on the UNFCCC CDM web site.
This process enabled the team to conduct a risk-based review of material issues with impact on future claims
of the emission reduction from the project. The concerns thereof, in the form of draft validation findings have
been registered in the Validation protocol.
The process of validation was performed on the basis of the UNFCCC established criteria, which refer to the
Kyoto Protocol criteria and the simplified modalities and procedures for small-scale CDM project activities.
The relevant host country criteria CDM interim approval criteria as available on the Ministry and Environment
and Forests (MoEF) web site are also considered.
Several concerns as elicited in the validation protocol have been raised in the form of 14 clarifications and 2
corrective action requests resulting in corrections required to the draft CDM PDD and its annexes as well as
evidences on meeting with the host country “sustainability development indicators’ of the CDM – interim
approval criteria (http://envfor.nic.in/divisions/ccd/cdm_iac.html). The report summarizes TUV Rheinland
Group’s opinion of the project activity as described in the project design document of (January 05) has met
with all the requirements of CDM and correctly applied the methodology suggested (I.D small-scale CDM
project activities). The relevant host country criteria have been evaluated by TUV Rheinland and are also
noted in the Authorization Letter (F.NO. 4/10/2003-CCC dated April 12, 2004) granted to the project by the
DNA for the project meeting with the sustainability criteria.
Therefore, TUV Rheinland Group requests the registration of the above-mentioned project as a CDM project.
Report No.: Subject Group:

4002is Environment & Energy Indexing terms
Report title:
Clarion 12 MW (Gross) Renewable Sources Biomass Climate Change
Power Project Kyoto Protocol
Small Scale Project Validation
Clean Development Mechanism
Work carried out by:
Mayuresh Sarang (Team Leader) No distribution without permission from the
Dr. Manfred Brinkmann Client or responsible organisational unit
Limited distribution
Date of this revision: Rev. No.: Number of pages:
th
11 February 05 05 26 Unrestricted distribution
Validation Report Template 3.0, December 2003

This document is a part of the Validation and Verification Manual
TüV Industrie Service GmbH - TüV Rheinland Group
Report No: 4002is, rev. 05

VALIDATION REPORT
Abbreviations
Abbreviation Full Form
AP Andhra Pradesh
APERC Andhra Pradesh Electricity Regulatory Commission
APGENCO Andhra Pradesh Power Generation Corporation Limited
APITCO Andhra Pradesh Industrial and Technical Consultancy Organisation
APPCB Andhra Pradesh Pollution Control Board
APTRANSCO Transmission Corporation of Andhra Pradesh
ASCI Administrative staff College of India
CAR Corrective Action Request
CDM Clean Development Mechanism
CFC Chlorofluorocarbons
CH4 Methane
CL Clarification Request
CO2 Carbon Dioxide
CPCL Clarion Power Corporation Limited
DNA Designated National Authority
DR Document Review
EIA Environment Impact Assessment
EPS Electric Power Survey
FBC Fluidised Bed Combustion
GhG Greenhouse Gases
I Interview
IETA International Emissions Trading Association
INR Indian Rupees
IPCC Intergovernmental Panel on Climate Change
IRR Internal Rate of Return
Kg Kilogram
kJ Kilo Joule
kW Kilo Watt
Kcal/Kg Kilo calorie per kilogram
kWh Kilo Watt Hour
LoI Letter of Intent
MW Mega Watt
MoEF Ministry of Environment and Forest
MoV Means of Verification
MWe Mega Watt Electrical
MWth Mega Watt Thermal
NEDCAP Non Conventional Energy Development Corporation of Andhra Pradesh
NGO Non Government Organisation
NOC No Objection Certificate
OP Open Clarification Request
PCF Prototype Carbon Fund
PDD Project Design Document
PFC Perfluorocarbons
PLF Plant Load Factor
t Tonne
tCO2 Tonnes Carbon-di-oxide
SARDS Social Activity for Rural Development Society
SCADA Supervisory Control and Data Acquisition
SF6 Sulphur Hexafluoride
SV Site Visit
UNFCCC United Nations Framework Convention on Climate Change
Page i
Reference to part of this report which may lead to misinterpretation is not permissible.

VALIDATION REPORT
Table of Contents Page

1 INTRODUCTION ....................................................................................................... 3
1.1 Objective 3
1.2 Scope 3
1.3 GhG Project Description 3
2 METHODOLOGY....................................................................................................... 5
2.1 Review of Documents 6
2.2 Follow-up Interviews 8
2.3 Resolution of Clarification and Corrective Action Requests 8
3 VALIDATION FINDINGS ......................................................................................... 9

3.1 Project Design 9
3.2 Baseline 11
3.3 Monitoring Plan 13
3.4 Calculation of GhG Emissions 14
3.5 Environmental Impacts 16
3.6 Comments by Local Stakeholders 18
4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS .............................. 19
5 VALIDATION OPINION ......................................................................................... 21
6 REFERENCES........................................................................................................... 24
Appendix A: Validation Protocol
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VALIDATION REPORT
1 INTRODUCTION
Clarion Power Corporation Limited (CPCL), India has commissioned TUV Industrie
Service GmbH TUV Rheinland Group to validate their 12 MW (Gross) biomass based
power project in Prakasam district of Andhra Pradesh as a CDM project. The project is
expected to avoid 275,281 tCO2 due to replacement of some of the grid electricity by
clean biomass based electricity generation as per draft CDM PDD (June 2004).
CPCL is a small scale project as per the applicability criteria of small-scale modalities and
procedures and is, therefore, applying the simplified methodologies for baseline
determination and monitoring plans as specified in Appendix B of Annex II of Decision
21/CP.8 (Type I – D).
The objective of the validation report is to give validation opinion on this CDM project. The
scope of the work is to review the draft CDM PDD, its annexes, other relevant documents,
publish draft PDD and get opinion of global stakeholders arrive at a validation opinion and
submit the report to CDM executive board.
The service of the entire validation was performed by members of the TUV Rheinland
Group. The members of the validation team are as follows:
Team Member Office Role

Mayuresh Sarang India Team Leader
Dr. Manfred Brinkmann Japan GhG Auditor, Energy Sector Expert
1.1 Objective
This report is representing the findings of the validation exercise along with the
methodology applied for validation, compliance of the project with the requirements of
- Kyoto protocol,
- Small-scale modalities and procedures (appendix B of Annex II to decision
21/CP.8)
- Guidelines issued by UNFCCC for validation of the project
- IETA/PCF Validation and Verification Manual v 4.0
It has checked
- Format of the documents as required by UNFCCC
- Additionality of the project
- Criteria for sustainable development by the host country (India),
- Baseline of the project
- GhG emission accounting practice
TUV Rheinland group when arriving at its opinion applied the above-mentioned criteria.
The project has followed the methodology as explained in quotation numbered
TUV/PNE/Qvs4002is/0602/ms dated February 5, 2004 and to the revisions thereof.
1.2 Scope
The scope of the audit is as follows
Review of the draft CDM PDD for preparation to publish the PDD (s) exclusive of
confidential data
Publication of draft CDM PDD without confidential data
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VALIDATION REPORT
Collection and publication of all comments of global stake holders
Significance evaluation of global stake holder comments received and site visit
Validation of the proposed CDM project activity
Submission of the validation report to the executive board
The validation report referred to the Validation and Verification Manual in preparation and
has been prepared as per CDM report template version 3, December 03 published by IETA.
TUV Rheinland Group employed risk-based approach to validation, focusing on the
identification of significant risks for project implementation and reduction in greenhouse
gases, was used as a basis for assessing the project baseline scenario and the claimed
emission reductions from the project.
Additionality of the project was demonstrated on basis of the project having to overcome
financial and/or policy-related and/or technical barriers.
Validation was performed based on information made available to TUV Rheinland Group
and for arriving at the validation opinion. This information is as referenced in the draft CDM
PDD (version of June, 04 and its revised version of January 2005) and related annexes or
used by TUV Rheinland Group to arrive and accept closure of the CLs and CARs.
To ensure transparency in arriving at its validation opinion TUV Rheinland Group has
performed alternate calculations based on the data procurement and/or availability1 of the
accountable and key parameters of validation as referenced in the draft CDM PDD. These
considerations are the emission factors in the baseline scenario and demonstration of
additionality of the proposed CDM project.
Further, the validation is not meant to provide any consulting to the project proponent.
However, stated requests for clarifications and/or corrective actions may provide input for
improvement of the project design.
1.3 GhG Project Description

CPCL is a part of Lanco group having major focus on energy related projects. This project is
conceived as a 12 MW gross installed capacity biomass based power project. It is situated in
village Tangutur, Prakasam district, Andhra Pradesh, India. The power plant intends to use
locally available biomass as well as permissible amount of coal (to the extent of 30 per cent)
as co-firing fuel for production of electricity. The power plant consists of the following main
equipments
• A travelling grate type boiler capable of generating of 57 t, 64 Kg / cm2 pressure and 480
degree centigrade temperature steam
• A 12 MW turbo generator having condensing turbine with extractions for boiler feed water
heating.
• The plant also has fuel storage and fuel preparation plant
The plant exports the power to Ongole substation situated about 18 km away from the
plant site to local APTRANSCO grid.
As mentioned in the description of the project activity in the revised draft CDM PDD (January
2005), it is noted that Andhra Pradesh is a fossil fuel dominated grid. Each unit (kWh) of
electricity generated in the baseline is claimed to have a net baseline emission factor (NBEF)
0.749 Kg CO2 for the baseline year (2002-2003) and leading to a NBEF of 0.720 Kg CO2 at
1
Data as referenced in the draft CDM PDD and information as available from www.cea.nic.in, www.mnes.nic.in,
www.ercap.org and www.npcil.org
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VALIDATION REPORT
the end of the crediting period implying a reduction of CO2 emissions resulting from this
expansion.
Andhra Pradesh is realized having surplus biomass, which goes as waste (ASCI).
Furthermore, biomass burning (to generate electricity as in this case) is seen as being CO2
neutral and leading to net zero emission of CO2 if harvested in a sustainable manner2. Thus, a
biomass based power project is essentially considered as being environmentally friendly and
will be helpful in reducing average emission of GhG to the atmosphere.
Further, the project activity was estimated to save 275,281 tCO2 over a period of 7 years from
being released in to the atmosphere as per draft CDM PDD (June 2004). Subsequently, the
total tCO2 is, based on the closure of CLs and CARs, where pertinent in the PDD, been
conservatively modified and now estimated at 184,090 tCO2 in the draft CDM PDD for the
same period of crediting (as revised and re-submitted in January 2005).
2 METHODOLOGY
The validation process consists of the following phases:
I Review of documents
A. Review of the CPCL’s documentation both on-site and off-site
B Desk review of identified supporting documents
II Site visit and follow-up interviews with project stakeholders (22-23 September 2004)
III Issue of the Draft Validation Report
IV Resolution of outstanding issues and the issuance of the final validation report and
opinion.
2
Reference: ASCI, Centre for Energy Environment and Technology, Hyderabad, February 2002, Biomass Resource Assessment
Studies for Andhra Pradesh, Vol. II and NEDCAP, 1997, District wise biomass assessment of Andhra Pradesh by prepared by
expert committee constituted by government of Andhra Pradesh through GO No. 5, dated 20th January 1997
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VALIDATION REPORT
2.1 Review of Documents

Documents are most important evidences in validation process. Document Review was
done as per the following criteria –
• Review of Documents of project proponent (Category-1 documents, both on-site and
off-site, Chapter-6 of this report)
• Desk review of identified supporting documents (Category-2 documents, Chapter-6
of this report)
As mentioned, all the documents reviewed are listed in Chapter-6 of this report so as to
result in the conclusion of TUV Rheinland Group’s validation opinion.
In order to ensure transparency in the process, the validation protocol is customised for
the project. The protocol shows in a transparent manner, criteria, 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 TUV Rheinland Group
documented how a particular requirement has been validated and the results of
validation.
The validation protocol consists of three tables. The different columns in these tables are
described in table 1, 2 and 3 of figure 1 – validation protocol tables.
The study generated number of questions regarding the project additionality and
environmental sustainability. Explainations to these questions were sought from the
project proponents and based on the submitted details having addressed / when
addressing these concerns a validation opinion was formed. These queries are available
within the text of this report as well as enclosed in completed and up-dated validation
protocol annexed (Annexure I) to the report.
Findings established during the validation can either be seen as a non-fulfilment of
validation criteria or where the risk to the fulfilment of project objectives is identified.
Corrective Action Requests (CAR) are issued, where:
a. mistakes have been made with a direct influence on project results
b. CDM or host party requirements have not been met;
c. there is a risk that the project would not be accepted as a CDM project or that the
emission reductions will not be certified
The validation team, will also use the additional labels in the form of request for
Clarification where additional information is needed through the reporting of draft
implications after having performed the document review and/or telephonic or personal
interview (I) and/or as when during the site visit (SV). This is along with the identification
as Open for CLs that could not be completely closed during the formulation of the
validation opinion and as a trail prior to or during the verification process.
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Validation Protocol Table 1: Mandatory Requirements
Requirement Reference Conclusion Cross reference
The requirements the Gives reference to the This is either acceptable Used to refer to the relevant
project must meet. legislation or based on evidence provided checklist questions in Table
agreement where the (OK), or a Corrective Action 2 to show how the specific
requirement is found. Request (CAR) of risk or non- requirement is validated.
compliance with stated This is to ensure a
requirements. The corrective transparent Validation
action requests are numbered process.
and presented to the client in
the Validation report.
Validation Protocol Table 2: Requirement checklist

Checklist Question Reference Means of Comment Draft and/or Final
verification (MoV) Conclusion
The various Gives Explains how The section is This is either acceptable
requirements in Table 1 reference to conformance with used to elaborate based on evidence
are linked to checklist documents the checklist and discuss the provided (OK), or a
questions the project where the question is checklist question Corrective Action Request
should meet. The answer to investigated. and/or the (CAR) due to non-
checklist is organised in the checklist Examples of means conformance to compliance with the
seven different sections. question or of verification are the question. It is checklist question (See
Each section is then item is document review further used to below). Clarification (CL)
further sub-divided. The found. (DR) or interview explain the is used when the validation
lowest level constitutes a (I) or site visit (SV). conclusions team has identified a need
checklist question. N/A means not reached. for further clarification.
applicable. Open (OP) is used in the
final validation report
when, and in case, a
justifiable exception is
made in terms of pending
clarifications residual to
those identified in the draft
validation stage and those
that do not affect the
validation opinion
Validation Protocol Table 3: Resolution of Corrective Action and Clarification Requests

Draft report clarifications Ref. to checklist Summary of project Validation conclusion
and corrective action question in table 2 owner response
requests
If the conclusions from the Reference to the The responses given by This section should summarise
draft Validation are either checklist question the Client or other the validation team’s
a Corrective Action number in Table 2 project participants responses and final
Request or a Clarification where the Corrective during the conclusions. The conclusions
Request, these should be Action Request or communications with the should also be included in
listed in this section. Clarification Request is validation team should Table 2, under “Final
explained. be summarised in this Conclusion”.
section.
Figure 1 Validation protocol tables
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VALIDATION REPORT
2.2 Follow-up Interviews
In order to reach a validation opinion a site visit was performed on the 21st-23rd September
2004 which followed the submitted site visit audit plan. Prior to the interview all the salient
points to be discussed with each identified person was planned. Date of interview,
interviewee and points to be discussed are given in the table below:
Table 4: Details of Follow up Interviews On-Site
Sr. No Interviewee Planned Activity and Points of Discussion
Date of interview: 22nd September 2004

1 Sarpanch of Gram • Implication of CPCL operating within the local environment
Panchayat, (Head
of Village) Village • Employment generation opportunities in local area due to
Velagapudi CPCL
• Implication of CPCL generation on the overall electicity
supply to the immediate surrounding community
2 Member of Zilla • Overall impact on local environment due to CPCL
Parishad, (District
local body) District • Socio-economic impact of the local population
Prakasam
3 Secretary, Social • Impact on local environment due to project
Activity for Rural
Development • Potential threat, if any, to local forestry due to CPCL
Society (Govt. operation
recognised NGO) • Improvement in the social well-being of the project activity
from a NGO perspective
Date of interview: 23rd September 2004
1 Clarion Power • Review of established procedures as applicable to the
Corporation Monitoring and verification protocol
Limited
• Analysis of the interview conducted with identified local
stake-holders
• Roles and responsibilites of the staff members with respect
to monitoring and verification
• Systematic data collection for energy generation, fuel
consumption and other regulatory mechanism
2 Managing Director • Availability of biomass in and around CPCL
NEDCAP • Information on the methodology of allocation of biomass
based power projects within AP
• Influence of other biomass based projects on CPCL
• Data on generation of electricity from all renewable energy
sources in AP
• Best practice and technological assessment for biomass-
based power projects in terms of available technology
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Sr. No Interviewee Planned Activity and Points of Discussion
3 Dy. Director - • Principles of tariff fixation

Transmission
APERC • Net heat rate of all power projects of AP
• Biomass availability in AP
•
Best practice with respect to technology available for
biomass-based power projects
TUV Rheinland Group has considered the views obtained in these interviews while arriving
at the validation opinion.
2.3 Resolution of Clarification and Corrective Action Requests

The objective of this phase of the validation was to resolve the requests for corrective
actions and clarification and any other outstanding issues, which needed to be clarified for
TUV Rheinland Group's validation of the project as a valid small-scale CDM project.
To maintain transparency in the process a draft validation report (dated October 2004) was
prepared and submitted to CPCL by TUV Rheinland Group. CPCL was asked to give
clarification on the issues raised in the draft validation report and also thereby an option to
revising the draft CDM PDD, June 2004, in the case project proponents found it necessary
to resolve the issues raised by TUV Rheinland Group.
CPCL responded to the CLs and CARs issued by TUV Rheinland Group with necessary
revisions to the draft CDM PDD of June 2004 to result in the revised draft CDM PPD of
January 2005 that was resubmitted to TUV Rheinland Group.
These responses have been accounted for while preparing the final validation report and
formulating the validation opinion.
3 VALIDATION FINDINGS
In the following paragraphs observations of TUV Rheinland Group with respect to the review
of documents as well as observations and interviews during the site visit are noted. The
project was observed for compliance with requirements of Kyoto Protocol, Decision CP/21.8,
host country’s criteria for sustainable development and guidelines provided by UNFCCC. A
detailed account of the findings is documented in the “validation protocol” appended as
Appendix-A to the main report.
Where TUV Rheinland Group has identified issues that needed further inputs or those that
represent a risk to the fulfilment of the project objectives, a Clarification Request (CL) or
Corrective Action Request (CAR) respectively, have been raised upon identification of these
issues. The CL and CAR are stated, where applicable, in the following sections and are
further documented in the Validation Protocol.
The validation of the project resulted in two (2) Corrective Action Requests and fourteen (14)
Clarification Requests.
During the preparation of draft validation report two main issues that were identified as
CARs, it was found necessary for the project proponents to initiate immediate corrective
actions (CA) and therefore also their closure before proceeding to the validation stage.
The project proponent has hence submitted the CA to the satisfaction of TUV Rheinland
Group. The details of the CARs raised and the closure are as follows:
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CAR 01 Corrections with respect to assumption of GhG reduction.
Here, the following assumptions are required to be looked into again and adjusted to as
declared below:
1. The PLF of the power plant should be at 80 per cent
2. The auxiliary consumption of the plant may be available at 9 per cent (leading to
a slight increase in the exported electricity for CPCL)
3. The co-firing of coal should be reconsidered to the actual allocated percentage
available to the maximum coal consumption allowed on an annual basis, which is 30 per
cent
A final conclusion on the CAR 01 resulted in the project proponent revising the submitted
draft CDM PDD, June 2004 as made available for public commentary to the revised draft
CDM PDD, January 05.
The revised draft CDM PDD, January 2005 of CPCL has resulted in the inclusion of all these
points and thereby the resulting deductions in the project claimed emission reductions. The
review of the revised and resubmitted project documentation resulted in the issue and
framing of the validation opinion included in this report.
CAR 02 Correction with respect to use of biomass as fuel
Neem wood and Mango wood are non-permitted biomass species for use as fuel in biomass
based power projects as per consent to operate of AP Pollution Control Board. Hence, their
continued use requires either explicit approval and/or should be completely discontinued
until such a time.
An extensive discussion resulted between TUV Rheinland Group and CPCL and a dialogue
was also established with relevant authorities by CPCL to establish that no risk presented to
the project due to the use of non-permitted biomass as a late receipt of the Consent to
Operate, which included this specific requirement.
Final conclusion:
Subject to regulatory implications on the use of the non-permitted biomass fuels in the
form of Neem and Mango, a deduction of the exported generation from CPCL to
APTRANSCO for the period commencing from operation until stoppage will be deducted
at the rate of 20 per cent per month (please find details addressed in the section below)
A guarantee of non-usage of the non-permitted biomass fuels is made available to TUV
Rheinland Group by CPCL
This has led to the revision of the draft CDM PDD, June 2004 at the relevant locations. The
project proponents have made revisions in the draft CDM PDD, June 2004 and submitted a
revised draft CDM PDD, January 2005. The changes were made in section A.2, A.4, A.4.3,
B.3, E.1.2.1, Table E.2, F.1 and Enclosure 1, of the revised draft CDM PDD, January 2005,
respectively.
The validation criteria (requirements), the means of their verification and the results from
validating the identified criteria are detailed in the Validation Protocol appended as
Appendix-A for both the raised CARs as well as CLs.
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3.1 Project Design

The project is using a proven technology to convert biomass to electricity. 64 Kg / cm2 at
480 degree centigrade steam is generated for driving turbine and hence, in turn the
generator. Maximum rated capacity of the turbo-generator is 12 MW as per the specification
sheets available on site. The steam from the turbine is sent to the condenser and is returned
as boiler feed water. The boiler pressure rating is one of the highest for a given size of plant
and fuel type in this part of India.
Additionally, the project has also used wood chipper, which is generally not used in other
biomass-based power plants. This is an adoption of technology used in paper mills. Chipped
wood ensures better combustion efficiency for the plant.
Observations on project with respect to India’s sustainable development criteria are as
follows -
• Social Well Being
The project has resulted in direct employment to about 100 people. Apart from these,
indirect employment for farmers, farm labours, suppliers and supporting activities is also
generated.
• Economic well being
It was noted that the power supply situation has improved in the area due to distributed
generation of this project. This would improve the productivity of the industries in the area
and will ensure better living conditions.
• Environmental Well being
The present project is in an area where the commercial plantation is practiced on large
scale. This activity will have an additional revenue source in form of plantation for
biomass. Hence, biomass plantation will be increasing.
• Technological well being
This project has employed a 64 kg / cm2 steam pressure with temperature of 480 degree
centigrade.
The project is designed to use the locally available biomass within average radius of about
80 km. The biomass includes waste biomass and biomass available by energy plantation.
For energy plantation about 6500 acres of cultivatable wasteland is identified and farmers
are willing to supply wood to the company as per the draft CDM PDD submitted in June
04.
Ministry of Environment and Forest, Government of India is the Designated National
Authority for India (http://cdm.unfccc.int/DNA) for granting the host country approval for
projects located in India. It has granted host country approval to CPCL vide its letter F.NO.
4/10/2003-CCC dated April 12, 2004.
The project proponents have given details of debt and equity participants of the CPCL,
which clarifies that the project is not receiving any official development assistance from,
Annex–1 countries.
The project is designed for 25 years life. The promoters have opted for a renewable
crediting period where, starting date of first crediting is February 2004. The end of 3rd
crediting period of the project is noted as being less than the project life.
The above project design is evaluated by review of available documents and observation
during site visit. The clarification and corrective action requests in this area are as follows:
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VALIDATION REPORT
CL 1
Qualified personnel, as per the requirement of the statutory obligations, perform the boiler
operation, the certificates and qualification process is to be made available.
Procedures for maintenance operations of the identified critical equipments by the
organization are to be made available.
CL 2
There is a possibility of degradation of the local environment if the project is not able to
attract local biomass producers or the waste biomass is not available during a condition
such as a prolonged drought.
It is foreseeable that under the given situations the fuel suppliers may resort to
unsustainable cutting of trees indirectly affecting the sustainability of the project.
CAR 02
Project proponent should clarify whether the use of neem and mango trees are allowed as
fuel in biomass based power projects
Final Conclusion:
CL1: CPCL has employed qualified professionals for operation and maintenance of the plant.
Employee qualification certificates have been presented to the satisfaction of the CL.
CL2: CPCL is ensuring procurement of biomass through vendors who are following the norms
set by the forest department, which will be verified subsequently
CAR 02:
Evidence to the nature has been provided by CPCL that the project is granted clearance by the
Forest Department of Government of Andhra Pradesh (Ref No. 2733/2001/F.3 dated
2.07.2001). The project proponent has further provided a guarantee to TUV RHEINLAND for
non-use of the non-permitted biomass
Furthermore, as a conservative measure TUV Rheinland Group proposes to deduct 20 per cent
of the total emission reduction on an equivalent basis for the period amounting to the first 226
days (from February 21, 2004 to October 03, 2004 amounting to a total of 7.5 months) of
operation, in the first verification period, the time wherein non-permitted biomass was
consumed. Such a measure will compensate for inadvertently not meeting the operating
conditions set by APPCB.
Further, a list of biomass suppliers from where CPCL purchases its biomass has been provided
to TUV Rheinland Group. These suppliers are understood to be regulated under the Forest Act
and the relevant sections thereof.
So when the purchase has been guaranteed by CPCL, through listed sources, CPCL also
guarantees that CPCL procurement policy is within the ambit of its own responsibility to ensure
that biomass procurement, storage and transport is by applying approved means.
Issues pending from CLs (OP): In case of CL2 exception has been made in terms of evidence
Justification for exceptions: CPCL has assured TUV Rheinland Group that it will present the
necessary evidences before verification
Implications of exceptions: As information will not hamper the validation opinion it is
considered for this stage as justifiable
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3.2 Baseline
The baseline for the project is selected on basis of methodology for small grid
connected renewable energy projects (category I - D). Here the average emission factor
of the grid is selected (Chapter 6, category-2, 9)
The methodology is correct for given application. In order to verify the project suitability
for the given methodology the following validation checks were made
Validation whether the project is small scale in line with the definition of the
UNFCCC requirement
Validation whether the project has selected correct baseline for the category it
represents
In terms of application of the results following from answering the above queries, TUV
Rheinland Group ascertains that the project is applied correctly.
As a detailed explanation on this acceptance, following is noted:
CPCL is a biomass based power project. Biomass is carbon neutral if used in a
sustainable way and hence, there is no addition of CO2 if sustainability criteria are
met. The availability of biomass is checked for the area of biomass procurement for
CPCL. There is enough biomass to cater the needs of these projects and hence,
the project is not posing threat to the forests or plantations in the area as
suggested by NEDCAP.
The forest department of Government of Andhra Pradesh has given a NOC to
the project vide its letter no.27433 / 2001 / F.3 / dated 24.07.01.
The project activity is also given host country approval by DNA of India for CDM,
which states that the project meets the host country requirements in terms of
sustainability and environmental concerns thereof.
In the application of the approved methodology, CPCL has considered average current
generation mix of the grid as the baseline emission and the project emissions are deducted
out of the GhG saved. Energy generation by CPCL is multiplied with the average grid
emission to arrive at the GhG saved by the project. This methodology is correct and is in line
with the small-scale methodology I-D.
During the validation process the following clarifications were sought by the TUV Rheinland
Group from the project proponent in respect to the project baseline and its demonstration of
additionality:
CL 3
Regulatory barrier is identified as the most relevant barrier to the project and when
accepting the arguments on the `wide fluctuations in the policy related enforcements with
respect to price to be paid to biomass based power plants by APTRANSCO, it may
require to be clarified by the project proponent how the project IRR or Net Present Value
(NPV) has stood readjusted after the policy has come into effect
CL 4
Estimation of grid emission factor is conservative and acceptable to the TUV Rheinland
Group. However, calculation of the grid emission factor is not transparent and clarity on
the eventual outcome so as to arrive at the estimated value of emission factor needs
elaboration
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VALIDATION REPORT
CL 5
The recent political election with the installation of a new State government in Andhra
Pradesh has made a policy decision to distribute electricity to farmers free. Project
proponent may well need to reflect its stand on this late development in the draft CDM
PDD, June 2004
Final Conclusion:
CL 3 Change in regulatory policy has further resulted in reduction to the financial
returns of CPCL the endorsement of these changes will be verified subsequently
CL 4 Grid emission factor calculation has been revised and incorporated in section
1.2.4 of the revised draft CDM PDD, January 2005. The response is deemed sufficient
and the request for clarification is closed.
CL 5 This has been verified with the Indian Electricity Act 2003. The response is
deemed sufficient and the request for clarification is closed.
Issues pending from CLs (OP): In case of CL3 exception has been made in terms of evidence
Justification for exceptions: CPCL has assured TUV Rheinland Group that it will present the
necessary evidences before verification
considered for this stage as justifiable
3.3 Monitoring Plan

The monitoring plan required incorporating certain parameters so as to report the GhG emission
more correctly as seen in the measurement of the change in coal calorific value at every batch
rather than at a prescribed interval.
This addition in the monitoring plan is considered to be adequately transparent as the use of
alternate equation is direct in its application in evaluating the GhG emissions resulting from use
of coal in the project activity (project related emissions) and its subsequent deduction. The
related change to the formula resulting from the change in the monitoring plan has been
demonstrated in section E.1.2.1 of the revised draft CDM PDD (January 2005)
Monitoring of emissions within the project boundary are discussed below
A CPCL is permitted to use coal to the tune of 30% as per the consent to operate by
APPCB. A monitoring plan for the same is now available in the revised draft CDM PDD,
January 2005. The parameters incorporated in the monitoring are:
Recording frequency (daily)
Amount of coal used (Metric tonnes)
Calorific value per day of usage (Kcal / kg)
Archiving of data for 2 years
Storage of data in paper form
The data is sufficient for estimation of GhG from usage of coal in the project activity
B During the interview it was realized that CPCL uses SF6 Breakers in switchyard, which
have a maintenance free life of about 25 years. Therefore, the SF6 is never released to
atmosphere as part of the process. Emission of SF6 may take place during emergency
breakdown in Breakers or at the time of change of Breakers.
However, given the high value of CO2 equivalence, a monitoring mechanism of the SF6
breaker may be considered by the project proponent.
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VALIDATION REPORT
The baseline emission is determined on the basis of publicly available data on generation
by various sources. The baseline determined by the project proponents is conservative
and may be used for determining the emission saved during the verification & certification
stage.
As claimed in revised draft CDM PDD (January 2005), transportation of biomass can be
neglected as a potential area of leakage since emission from fuel transportation to the
conventional power plants is also not considered in the baseline emissions.
However, the estimated emission due to transportation of fuel is calculated in section E
1.2.2 of the revised draft CDM PDD (January 2005).
The frequency and the type of measurement indicators of GhG project performance
selected and in its evaluation are relevant to the estimation of baseline emissions and the
project related emissions, respectively. During the site visit and review of the draft CDM
PDD (June 2004), TUV Rheinland Group was unclear in limited areas on the CPCL
prescribed roles and responsibilities in the achievement of the monitoring plan. TUV
Rheinland Group posed the following clarifications from the project proponents for their
clarity:
CL 6
Energy content of biomass and coal, with a monthly monitoring as indicated in the
monitoring plan, needs to elaborate on how the same is evaluated if either of the fuel
batches was to change within the prescribed monitoring frequency
CL 7
The distance over which the biomass will be collected has to be fixed as per the
recommendations of NEDCAP or other appropriate authorities so as to ensure continuous
compliance on the distance as well as the indicated leakage factors incorporated in the
draft CDM PDD (June 2004). This needs to be verified and authenticated by the project
proponent
CL 8
While emergency preparedness have been identified for various situations special
attention to the unintended emissions need to be provided
CL 9
Maintenance procedures for monitoring equipments and installations are identified but
their maintenance and management is yet to be performed
CL 10
Procedures for internal audits of GhG emissions project compliance are identified but the
last scheduled audit for project GhG compliance was cancelled and remained
unscheduled
Final Conclusion:
CL 6 Changes have been made in section D3 (revised draft CDM PDD, January 2005)
and biomass as well as coal are now monitored for each batch. The response is deemed
sufficient and the request for clarification is closed
CL 7 The response states that the likely3 (as discussed with the project proponent)
purchase of the biomass is within 50 kms and is deemed sufficient for clarification to be
closed.
3
The following words have been used throughout the text relating to the Synthesis Report to the Third Assessment
Report: virtually certain (greater than 99% chance that a result is true); very likely (90-99% chance); likely (66-
90% chance); medium likelihood (33-60% chance); unlikely (10-33% chance); very unlikely (1-10% chance) and
exceptionally unlikely (less than 1% chance), and were used in this validation report
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VALIDATION REPORT
CL8 The emergencies are identified and the preparedness is demonstrated in the
submitted documents. The response is deemed sufficient and the request for clarification
is closed.
CL 9 The procedure for maintenance of monitoring equipments shall be demonstrated
by the project proponents at the time of verification.
CL 10 Whereas the internal audit procedure has been submitted by the project
proponent, “CPCL GhG performance procedures, version 1’, the application of these
internal procedures shall be verified at the verification stage of the project.
Issues pending from CLs (OP): For CL 9 and CL10 exceptions have been made in
terms of evidences
Justification for exceptions: CPCL has assured TUV Rheinland Group that it will
present the necessary evidences before verification
considered for this stage as justifiable exception.
3.4 Calculation of GhG Emissions

Project boundary is identified as physical boundary of the project, fuel collection points to
project and project location to electricity despatch point to the grid. These boundaries are
covering all the activities related to the project and will be sufficiently covering the GhG emission
from the project.
Emissions due to project activity include:
CO2 emission due to combustion of biomass, which is actually carbon neutral if biomass
is used in a sustainable way
Emission due to combustion of coal
Emission due to SF6 used in breakers of the switchyard. These are almost negligible and
hence, can be avoided safely
Emission due to transportation of fuel to the power plant from the fuel and emission due
to transportation of ash to the brick manufacturers from the power plant. This emission is
neglected as a conservative estimate when compared to the CO2 emission due to
transportation in conventional power projects
No CFCs or PFCs are used in the plant and hence, they are neglected NO2 emission is
neglected since, other combustion technologies would also have led to NO2 emission
and so, and net change can be thought of as zero.
The formulas used in the project were revisited during the preparation of the revised draft CDM
PDD, January 2005, and made amply transparent so as to determine the emission reduction
resulting from the project (see section E.1.2.4).
The assumptions for estimation of GhG emission reduction in the draft CDM PDD, June 2004
are
The plant load factor is average 90%
Coal usage is 15% average
The auxiliary consumption of the plant is 11%
Leakages from the renewable energy is to be neglected
These assumptions were verified by TUV Rheinland Group against the guidance of the APERC
tariff order of renewable energy as well as appendix B of Annex II of Decision 21/CP.8. Upon
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VALIDATION REPORT
evaluation, corrective actions as well as clarifications were sought from the project proponents
wherever required.
The clarity on these assumptions as sought by TUV Rheinland Group are particularly evident in
CL 7, CL 11 and CAR 1 to understand the implications resulting from these assumptions on
arriving at the final validation opinion.
While arriving at the emission reduction due to project, as seen through the data
representation in the revised draft CDM PDD (January 2005), the likely uncertainties4 are:
1. Measurement instrument uncertainties is identified by TUV Rheinland Group
as being very low since, the instruments are calibrated regularly and as seen
addressed in Annexure I, Table 3
2. Uncertainties due to coal usage in the electricity generation is established as
low as biomass availability is high in the region and that the calculations are
based on 30 per cent coal consumption, the maximum allowable to the
project
The first uncertainty can be reduced by regular calibration of equipments. CPCL has
provided a plan for calibration of the instruments, which is considered sufficient to address
the first uncertainty.
In case of the other uncertainty, coal proportion and calibration values are monitored in
the monitoring plan for the project. Adherence to the monitoring plan will eliminate this
uncertainty.
The draft CDM PDD (June 2004) was checked and the following CAR and CL were issued
by TUV Rheinland Group with respect to GhG calculations:
CL 7
The distance over which the biomass will be collected has to be fixed as per the
recommendations of NEDCAP or other appropriate authorities so as to ensure continuous
compliance on the distance as well as the indicated leakage factors incorporated in the
CDM PDD. This needs to be verified and authenticated by the project proponent
CL 11
Uncertainties related to distance of biomass procurement need to be identified
4
An explicit uncertainty range (±) is a likely range. Estimates of confidence relating to Working Group II (Synthesis
Report to the TAR) findings are used in the text as: very high (95% or greater); high (67-95%); medium (33-67%);
low (5-33%); and very low (5% or less), and were used in this report to describe these uncertainty range
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VALIDATION REPORT
CAR 01
The gross capacity of the CPCL unit is stated to not exceed 12 MW gross of which 11.04
MW is for export to the grid. However, considering an auxiliary consumption of 9 per cent
as denoted in the Order R. P. No. 84/2003 dated March 20, 2004 this would result in the
export of 10.92MW). Organization may, therefore, reconsider the auxiliary consumption of
9 per cent.
Co-firing in the form of coal usage is proposed to the tune of 23 per cent at the end of the
crediting period (running for 7 years). However, as per the Consent Order (APPCB /VJA/
NLR/ 636/ HO/ 2004/ A/ 129 dated 22/09/2004) Schedule-B coal consumption is subject
to a maximum of 30 per cent on an annual basis. This as per the TUV Rheinland Group
requires to be incorporated into the project emissions, over the crediting period, to
assimilate the vintage of equipment.
Estimation of PLF is optimistic. Instead of 90% PLF of 80% shall be considered as
described by the APERC order R.P. No. 84 dated 20th March 2004 based on and keeping
in line with the philosophy of two-part tariff5.
The grid emission factor selected for estimating the avoided generation is conservative
and valid. However, for the plant availability and plant load factors the value appeared to
be on the higher in comparison of the draft CDM PDD (June 2004). They require a
conservative estimate to arrive at the generation figures for the plant in the draft CDM
PDD (June 2004).
Final Conclusion:
CL 7 and CL 11 Section 1.2.2 of the revised draft CDM PDD (Jan’05) has considered
emission due to transportation. The distance considered is conservative. The response is
deemed sufficient and the request for clarification is closed.
CAR 01 Revised draft CDM PDD (Jan’05) has incorporated all the changes in the
assumptions to arrive at the emission reduction for the project. The incorporated changes
are
• The auxiliary consumption is considered as 9%
• The plant load factor is considered as 80%
• The coal consumption is reconsidered as 30% throughout the crediting period
This CAR is closed by TUV Rheinland Group.
3.5 Environmental Impacts

According to Ministry of Environment and Forests Environment, Government of India,
Impact Assessment Notification S.O.60(E), dated 27/01/1994 a new project having
investment of less than INR 1000 million is not required to carry out an EIA
(http://www.envfor.nic.in/legis/eia/so-60(e).doc).
Possible impact of the project on the environment in which it is placed will be through
felling of trees in an unsustainable manner. For the implication of this environmental
5
Two part tariff consists of a ”fixed cost tariff” and a ”variable cost tariff”, respectively. The fixed cost tariff is the cost
calculated on a per kWh of generation (includes cost of depreciation, return on equity, interest on working capital, operation
and maintenance costs) whereas the basis for variable cost tariff is the cost of the fuel (which may vary with the plant
generation)
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VALIDATION REPORT
aspect the NOC from the Forest Department of AP as well as the NOC from NEDCAP are
taken into account to support the environmental sustainability criteria of the project
activity.
Further support is sought from the report presented by the Administrative Staff College of
India, Hyderabad that is indicative of the surplus biomass in the district Prakasam wherein
the project activity lies.
The project has also been granted Consent to Operate by APPCB subject to fulfilling
certain conditions of APPCB.
In order to satisfy the environmental impact due to CPCL, the following clarifications and
corrective actions were sought:
CL 12
CPCL is required to give an action plan for usage of Municipal solid waste, market yard
waste as fuel within 3 months as per G.O Ms. No. 3. dtd. 08/01/2004. A copy of the same
should be submitted
CL 13
CPCL is required to submit an action plan for development of energy plantation within one
month. A copy of the same should be submitted
CAR 02
Project proponent may clarify whether the use of neem and mango trees are allowed as
fuel in biomass based power projects.
Final Conclusion:
CL 12 CPCL has asked for an extension for submission of plan to use municipal solid
waste with APPCB. The extension request and plan will be submitted to TUV Rheinland
Group before verification.
CL 13 CPCL will submit plan for energy plantation to APPCB and a copy of the same
will be submitted to TUV Rheinland Group before verification.
CAR 02 The project proponent have stopped usage of Neem and Mango as fuel after
receipt of the consent to operate form APPCB. This CAR is closed by TUV Rheinland
Group.
Issues pending from CLs: For CL 12 and CL 13 exceptions have been made in terms of
evidences
Justification for exceptions: CPCL has assured TUV Rheinland Group that it will
present the necessary evidences before verification
considered for this stage as justifiable exception.
3.5 Comments by Local Stakeholders

As a part of the validation process, the comments by local stakeholders were sought. The
local stakeholders approached included, the representatives of
- Local NGO
- Representatives of village local self government
- Representatives of local Zilla Parishad
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VALIDATION REPORT
All the representatives mentioned above are appropriate since, they have an
understanding of the local environmental conditions and can identify if the project can
adversely affect the environment. However, a formal consultation process and conclusion
of the same was not available to TUV Rheinland Group, which was asked for by TUV
Rheinland Group as part of validation process.
CPCL was asked for the following clarification
CL 14
The project proponent shall describe the process of identifying the local stakeholders and
the manner in which these comments were received from these identified local
stakeholders and accounted for.
During the consultation process, no adverse comment was received from any stakeholder
and no action plan was required.
Final conclusion:
CL 14 Section G1 of revised draft CDM PDD (Jan’05) has explained the procedure of
identifying the stake holders and Section G.2 has summarised the views of the local
stakeholders.
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VALIDATION REPORT
4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS
Stakeholder Comment
TUV Rheinland Group published the project documents on its own website along with a
link to UNFCCC website. from 15 August to 14 September 2004. during this period 1
comment was received from Mr. Ben Pearson of CDM Watch. Mr. Pearson’s comment
was –
The additionality of this project is highly questionable given that the plant has been in
operation since February 2004. The additionality demonstration in the PDD claims that
CDM funding “was initially considered” to cover the risk of rising biomass fuel prices.
However, the fact that the plant was actually constructed and entered commercial
operation before the developer knew whether CDM funding would be available stronger
suggests that it was not essential for the project to go ahead and that the risks are
manageable in the absence of CDM registration.
Furthermore, this assertion that the CDM was considered at an earlier stage of project
development must be documented, as per the Methodologies Panel’s recent Consolidated
Tools for Demonstration of Additionality which require that “evidence should be publicly
provided that the incentive provided by the CDM was seriously considered in the decision
to proceed with the project activity” [emphasis added] in the case of project activities that
start before registration. Assertions such as those contained in this PDD are insufficient.
Ben Pearson
CDM Watch
16 August 2004
TUV RHEINLAND’s response:
The starting date of the project activity in the revised Draft CDM PDD (January 2005) is
mentioned as the Boiler inspection date of 24th November 2003. We were also submitted
by the project proponent the copy of the contract with the project consultants, in response
to this comment, whose contract with the project proponents is dated 19th February 2003.
Taking into account these time frames it can be acceptably concluded that the project
proponents thought of CDM benefits prior to time of the stated ‘starting date’ for the project
activity.
Furthermore, the recent decision of the State government of Andhra Pradesh to provide
free power to the farmers has put additional strain on the demand-supply gap.
This was not an anticipated barrier during the conceptualization of the project activity and
the project continues to operate within these constraints as of date.
All these conditions mentioned are now reflected in the revised Draft CDM PDD (January
2005).
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VALIDATION REPORT
5 VALIDATION OPINION
UNQUALIFIED VALIDATION OPINION

TUV Rheinland Group has performed a validation of the “Clarion Power Corporation Limited’s
biomass based power project” in Ongole, India (hereafter called “the project”).
The validation was performed on the basis of UNFCCC criteria for small-scale CDM project
activities and relevant Indian sustainability criteria, as well as criteria given to provide for
consistent project operations, monitoring and reporting.
The validation consisted of the following three phases:
i) a desk review of the project design and the baseline and monitoring plan (June to
November 2004),
ii) follow-up interviews with project stakeholders (22nd-23rd September 2004); and
iii) the resolution of outstanding issues and the issuance of the final validation report and
opinion (September 2004 to January 2005).
Global stakeholders were invited to provide comments and one comment was received. The
validation of the initial Draft CDM PDD (June 2004) raised several concerns in the form of CLs
and CARs. To resolve TUV Rheinland’s concerns, the Draft CDM PDD was revised (January
2005) and resubmitted for validation by the project proponent.
Since all fossil fuel fired generation units in the grid system, to which the electricity is delivered,
use coal or gas, the project applies the understanding that all biomass-based projects are net
zero carbon emitting and therefore chooses I.D of the simplified baseline methodologies
proposed for this project activity category.
The proposed biomass-based power project will have a nominal capacity of generation of 12
MW. Being a renewable energy project activity with an output capacity of less than 15 MW, the
project qualifies as a “Renewable electricity generation for a grid project activity” (Type I.D)
defined in the simplified modalities and procedures for small-scale CDM project activities.
For the biomass-based power project activity the environmental impacts resulting from the
project activity are considered to be not significant as defined in the relevant Indian laws
pertaining to the said project. A local consultation process with relevant agencies and ministries
has been conducted and due account was taken of the comments received by the project
proponent.
The project has received the Letter of Approval by the DNA of India. In its Letter of Approval
(F.No.4/10/2003-CCC dated 12th April 2004) the Indian DNA confirmed that the project assists
India in achieving sustainable development.
The additionality of the project is demonstrated and confirmed through the existence of
regulatory barrier and is as explained in the draft CDM PDD (January 2005).
By displacing a dominant fossil fuel-based electricity grid, the project results in reductions of
CO2 emissions that are real, measurable and give long-term benefits to the mitigation of climate
change. Given that the project activity is implemented as designed, the project is likely to
achieve the emission reductions to the amount of 184090 tCO2 over a period of 7 years.
This opinion is accompanied with an additional deduction in the total emission reduction
achieved by the project activity resulting for a period of the first 7.5 months of verification and
certification.
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VALIDATION REPORT
This deduction, as a conservative measure, is a consequence of the project activity’s
inadvertent use of non-permitted biomass in the form of Neem and Mango wood for that period
(from operation commencement until stoppage) and will amount to 20 per cent of the monthly
generation (equalling the per cent of non-permitted biomass constituting the total biomass
composition for that period).
The monitoring plan sufficiently specifies the monitoring requirements of the main project
indicators and is along with established QA/QC procedures. Some of the concerns that remain
to be verified are identified clearly in the validation report and would be ascertained at the time
of (or) prior to verification so as to remove the low uncertainty remaining from the validation
process.
In summary, it is TUV Rheinland Group’s opinion that the project, as described in the project
design document of January 2005, meets all relevant UNFCCC requirements for the CDM and
all relevant host country criteria and correctly applies the simplified baseline and monitoring
methodology for category I.D small-scale CDM project activities.
Hence, TUV Rheinland Group requests the registration of the “Clarion Power Corporation
Limited biomass based power project” as a CDM project.
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VALIDATION REPORT
6 REFERENCES
Category 1 Documents:
Documents provided by the Project Proponent
On-site documents
• CPCL, 24/02/04, 1st invoice of Clarion for power generation to AP TRANSCO Letter no.
CPCL / APTRANSCO / INV / 115
• CPCL, 15/09/04, Copy of manpower status as on 15 / 09 / 04
• CPCL, 21/09/04, Daily Generation Report
• CPCL, 23/09/04, (September 2004, which is the date of submission of the report to TUV
Rheinland), Characteristics of coal available at the plant
• CPCL, 23/09/2004, (September 2004, which is the date of submission of the report to
TUV Rheinland), Lanco group profile
• CPCL. 23/09/04, (September 2004, which is the date of submission of the report to TUV
Rheinland), Copy of Performance guarantee parameters from turbo generator supplier
• CPCL, 20/10/04, Letter No. CPCL/E&Y/77/04, Roles and responsibilities of various
officials in CPCL
• Director of Boilers, Andhra Pradesh, Hyderabad, 31/05/04, letter no. F/6382/03
Certificate no. 8, dated 20/05/04 issued to boiler no. AP 3784
• ENERGOMACEXPORT dated nil, Turbine operation manual supplied by. Document no.
103 – M – 0898PE
• SARDS 22/09/04 (submission date), NGO Profile
• TUV Rheinland Group, January 04, (Submission date), Completed Questionnaire in
Application for Validation and Registration or Verification and Certification of CDM
Projects of TUV Rheinland Group, submitted by CPCL
• Walchand Nagar Industries, 18/10/02, Technical data sheet of document no. 44801 Rev-
A
Off-Site Documents Review
• Airport authority of India, 8/12/2000, NOC . Letter no. AAI / 20012 / 310 / 2000- ARI
• APITCO, August 1997, Biomass assessment study conducted by for CPCL
• APPCB, 22/02/01 Consent order for establishment issued by Order no.
132/PCB/C.Estt/ROH-II//EE-N/69-2000
• APPCB March 02, Amendment to Consent to Establish Letter no. 132/PCB/C.Estt./RO-
NLR/AEE-N/200202688
• APPCB, 22/09/04, Consent to operate, Consent order no. APPCB / VJA / NLR / 636 /
HO 2004 /A / 129
• CPCL, 7/1/98, MoU between NEDCAP and CPCL
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VALIDATION REPORT
• CPCL, 17/02/01, Power Purchase Agreement between CPCL and APTRANSCO
• Draft CDM-PDD, June 2004
• Draft CDM PDD, January 2005 (revised posting and closure of CLs and CARs)
• Fitchner India, (September 2004, which is the date of submission of the report to TUV
Rheinland), Detailed project report
• MoEF, Government of India, 12/04/04, Copy of host country approval F. no. 4/10/2003-
CCC dated 12 April 2004, confirming that the project contributes to sustainable
development and of voluntary participation from the DNA’s of the participating parties
• P. Murli & Co. Chartered Accountants, Hyderabad, 29/07/2004, Auditor’s report of CPCL
for the year 2003 - 04
• Tanguturu Gram Panchayat, 15/03/04, Permission to set up 12 MW biomass based
Power Plant
Category 2 Other Documents & Information Sources:
1. APERC, 20/03/04, order no. R.P. No. 84 / 2003 in O.P No. 1075 / 2000
2. ASCI, Centre for Energy Environment and Technology, Hyderabad, February 2002,
Biomass Resource Assessment Studies for Andhra Pradesh, Vol. II
3. CEA, September 2000, Sixteenth Electric Power Survey of India
4. IETA/PCF, March 2004, Validation and Verification Manual, Version3.3
5. IPCC: 2000, Good Practice Guidance and Uncertainty Management in National Greenhouse
Gas Inventories, 2000
6. NEDCAP, 1997, District wise biomass assessment of Andhra Pradesh by prepared by
expert committee constituted by government of Andhra Pradesh through GO No. 5, dated
20th January 1997
7. UNFCCC, 10/12/97, Text of Kyoto Protocol http://unfccc.int/cop4/l07a01.pdf
8. UNFCCC, 21/01/2002, Report of the conference of parties on its seventh session held at
Marrakesh from 29 October to 10 November, 2001
9. UNFCCC, 22/10/04, Indicative simplified baseline and monitoring methodologies for
selected small-scale CDM project activity categories Version 4
10. Vimta Labs, Hyderabad, 02/09/2003, Fuel analysis reports for various fuels
As Part of the validation process, the following web sites were also referred to:
• Website of UNFCCC, http://unfccc.int
• Website of International Emission trading Association (IETA) www.ieta.org
• Website of Ministry of Power, Government of India www.powermin.nic.in
• Website of Ministry of Environment and Forest, Government of India http://envfor.nic.in
• Website of Central Electric Authority of India www.cea.nic.in
• Website of Central Electricity Regulatory Commission of India www.cercind.org
• Website of Nuclear Power Corporation of India www.npcil.org
• Website of Andhra Pradesh Electricity Regulatory Commission www.ercap.org
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VALIDATION REPORT
• Website of Andhra Pradesh Transmission Corporation Limted www.aptranscorp.com
• Website of Andhra Pradesh Generation Corporation Limited www.apgenco.com
Persons interviewed:
List persons interviewed during the validation, or persons contributed with other information
that are not included in the documents listed above.
Sr. No Interviewee
1. Sarpanch of Gram Panchayat, Village Velagapudi
2. Member of Zilla Parishad, Dist. Prakasam
3. Secretary, Social Activity for Rural Development Society (Govt. recognised NGO
4. Managing Director NEDCAP
5. Dy. Director - Transmission APERC
- o0o -
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VALIDATION REPORT
APPENDIX A
VALIDATION PROTOCOL
Page 27
TÜV Industrie Service GmbH - TÜV Rheinland Group
SMALL-SCALE CDM VALIDATION PROTOCOL

Project: Clarion 12MW (Gross) Renewable Sources Biomass Power Project
INTRODUCTION
This document contains a generic Validation Protocol for small-scale CDM projects, which must be seen in conjunction with the Validation and
Verification Guidelines and the Validation Report Template.
This validation protocol serves the following purposes:
• It organises, details and clarifies the requirements a project is expected to meet; and
• It ensures a transparent validation process by inducing the validator to document how a particular requirement has been validated and which
conclusions have been reached;
This protocol contains two tables with generic requirements for validation projects. Table 1 shows the requirements that the GhG emission
reduction project will be validated against. Table 2 consists of a checklist with validation questions related to one or more of the requirements in
Table 1. The checklist questions may not be applicable for all investors, and should not be viewed as mandatory for all projects. Where a
finding is issued, a corrective action request or clarification request are stated. The resolution and final conclusions of these requests should be
described in Table 3 of this protocol.
Before this generic validation protocol can be applied to validate a specific project, the validator must
Guideline
review and adjust/amend the protocol to make it applicable to individual project characteristics and
circumstances as well as individual investor criteria. The application of the validator’s professional
judgement and technical expertise should ensure that checklist amendments cover all necessary specific
project requirements that have impact on project performance and acceptance of the project. Given the
above, the checklist part of the protocol is neither exhaustive nor prescriptive. Report Protocol
Template (Requirements)
Version 3.0, December 2003

Table 1 Mandatory Requirements for Small Scale Clean Development Mechanism (CDM) Project Activities
Cross Reference/
REQUIREMENT REFERENCE CONCLUSION Comment
1. The project shall assist Parties included in Annex I in Kyoto Protocol Art. 12.2 The Annex 1 party is unknown
achieving compliance with part of their emission and the parties listed in Annex-
reduction commitment under Art. 3 1 to the revised draft CDM
PDD only addresses the main
equity fund-raiser who is the
Project Proponent and the
beneficiary of the Annex I
country is to be identified in the
future (at the earliest prior to
registration)
2. The project shall assist non-Annex I Parties in Kyoto Protocol Art. 12.2, Ok Host country approval
achieving sustainable development and shall have Simplified Modalities and granted vide Letter F.
obtained confirmation by the host country thereof Procedures for Small No. 4 / 10 / 2003 –
Scale CDM Project CCC dated 12 April
Activities §23a 2004 by Govt. of
India, Ministry of
Environment and
Forest, (DNA for
India)
3. The project shall assist non-Annex I Parties in Kyoto Protocol Art. 12.2. OK Host country approval
contributing to the ultimate objective of the UNFCCC granted vide Letter F.
No. 4 / 10 / 2003 –
CCC dated 12 April
2004 by Govt. of
India, Ministry of
Environment and
Page A-6-1
Report No. 4002is, rev. 05
Cross Reference/
Forest, (DNA for
India)
4. The project shall have written approval of voluntary Kyoto Protocol Art. OK Letter F. No. 4 / 10 /
participation from the designated national authorities 12.5a, Simplified 2003 – CCC dated 12
of each party involved Modalities and April 2004 by Govt. of
Procedures for Small India, Ministry of
Scale CDM Project Environment and
Activities §23a Forest
5. The emission reductions should be real, measurable Kyoto Protocol Art. 12.5b Ok Section E of the
and give long-term benefits related to the mitigation of revised draft CDM
climate change PDD (Jan’05)
6. Reduction in GhG emissions must be additional to any Kyoto Protocol Art. OK Section B3 (revised
that would occur in absence of the project activity, i.e. 12.5.c, Simplified draft CDM PDD
a CDM project activity is additional if anthropogenic Modalities and Jan’05): Policy related
emissions of greenhouse gases by sources are Procedures for Small barrier is the most
reduced below those that would have occurred in the Scale CDM Project relevant to the present
absence of the registered CDM project activity Activities §26 project
7. Potential public funding for the project from Parties in Marrakech Accords OK CPCL has sent the
Annex I shall not be a diversion of official development (Decision 17/CP.7) debt and equity
assistance participant’s list.
No Annex-1 country is
involved in financing
this project and so,
any diversion of the
ODA is not expected
8. Parties participating in the CDM shall designate a Marrakesh Accords OK http://cdm.unfccc.int
national authority for the CDM (CDM modalities§ 29) DNA of India is
Page A-6-2
Cross Reference/
Ministry of
Environment and
Forest, Govt. of India
9. The host country shall be a Party to the Kyoto Protocol Marrakesh Accords OK http://cdm.unfccc.int
(CDM modalities§ 30) Accession on
26/08/02
10. The proposed project activity shall meet the eligibility Simplified Modalities and OK By referring to web
criteria for small scale CDM project activities set out in Procedures for Small site of Lanco group
§ 6 (c) of the Marrakesh Accords and shall not be a Scale CDM Project and SV it seen that
de-bundled component of a larger project activity Activities §12a,c the group is not
having another CDM
project within 1 km, in
the same area and
within same sectoral
scope as CPCL.
Thus, this is not a de-
bundled activity from
a large CDM project.
The project is also
fulfilling criteria of a
small-scale project.
11. The project design document shall conform with the Simplified Modalities and OK Revised draft CDM
Small Scale CDM Project Design Document format Procedures for Small PDD, January 2005
Scale CDM Project
Activities, Appendix A
12. The proposed project activity shall confirm to one of Simplified Modalities and OK Revised draft CDM
the project categories defined for small scale CDM Procedures for Small PDD, January 2005,
project activities and uses the simplified baseline and Scale CDM Project Performance
Page A-6-3
Cross Reference/
monitoring methodology for that project category Activities §22e guarantee of turbo
generator and boiler
suppliers The project
is falling in I – D of
small scale project
13. Comments by local stakeholders are invited, and a Simplified Modalities and OK The project proponent
summary of these provided Procedures for Small has invited comments
Scale CDM Project from local
Activities §22b stakeholders and a
summary of the same
has been provided in
revised draft CDM
PDD, January 2005,
sections G.1 and G.2
14. If required by the host country, an analysis of the Simplified Modalities and OK Ref. Revised draft
environmental impacts of the project activity is carried Procedures for Small CDM PDD, F1The
out and documented Scale CDM Project host country does not
Activities §22c require EIA for a
project having less
than Rs. 1000 million
investment
15. Parties, stakeholders and UNFCCC accredited NGOs Simplified Modalities and OK Section G of draft
have been invited to comment on the validation Procedures for Small CDM PDD (June
requirements and comments have been made publicly Scale CDM Project 2004). Yes, web site
available Activities §23b,c,d of validator has
published the PDD
from 15 August 2004
to September 14 2004
Page A-6-4
Cross Reference/
on the TUV website
www.tuvdotcom.com
with a linkage to the
site of UNFCCC site.
Page A-6-5
Table 2 Requirements Checklist

Draft Final
CHECKLIST QUESTION Ref. MoV* COMMENTS Concl. Concl.*
A. Project Description
The project design is assessed.
A.1. Small scale project activity
It is assess whether the project qualifies as small
scale CDM project activity.
A.1.1. Does the project qualify as a small scale Perf DR / The project’s installed capacity is less than 15 OK
CDM project activity as defined in orm SV MWe.
paragraph 6 (c) of decision 17/CP.7 on the ance
modalities and procedures for the CDM? guar
ante
e
docu
ment
s
verifi
ed at
site
A.1.2. The small-scale project activity is not a Inter DR / The project promoter of CPCL are not having any OK
de-bundled component of a larger project view I other small scale CDM project in same category as
activity? with the CPCL 12 MW project within one Kilometre of
Proj the project boundary in last two years. Thus, it is
ect not a de-bundled project from large scale project
pro
mote
* MoV = Means of Verification, DR= Document Review, I= Interview, SV = Site Visit, OP = Open Page A-6-6
Report No. 4002is rev. 05 This document is a part of the Validation and Verification Manual
Draft Final
rs
and
web
site
of
Lanc
o
grou
p/
PDD
A.4.
5
A.1.3. Does proposed project activity confirm to PDD DR Yes. This project is falling under small scale OK
one of the project categories defined for A.4. methodology I – D i.e. Grid connected electricity
small-scale CDM project activities? 2 / generation by renewable energy sources
PDD
D.1
A.2. Project Design

Validation of project design focuses on the choice
of technology and the design documentation of
the project.
A.2.1. Are the project’s spatial (geographical) PDD DR/ Boundaries of the project are defined as the project OK
boundaries clearly defined? B4 Site site, biomass collection points to site and project
Visit site and up to the electricity grid point (the actual
evacuation point to the State Electricity Grid, which
is 18 kilometres away from the site).
A.2.2 Are the project’s system (components PDD DR Yes, project sub systems are included in the project OK
Draft Final
and facilities used to mitigate GhG) boundaries B4 boundary.
clearly defined?
A.2.3 Does the project design engineering Draft DR/ For a given project type and size CPCL has OK
reflect current good practices? CD SV/ highest-pressure boiler in the region as per
M I discussions with officials of NEDCAP. However, it
PDD is also opined that a higher-pressure boiler may
A.2 lead to problems in combustion.
While selecting a boiler firing type, the argument
within the text of the draft CDM PDD (June 2004)
favouring travelling grate type boiler to that of the
fluidised bed boiler (FBC) is that travelling grate OK
has a lower auxiliary consumption of 11% against
16% of FBC.
A.2.4 Will the project result in technology PDD DR The technology employed here can be supplied by
transfer to the host country? A.4 the manufacturers within India and hence, no OK
technology transfer is taking place to the host
country.
A.2.5 Does the project require extensive initial Site DR / Qualified personnel, as per the requirement of the CL 1 OK
training and maintenance efforts in order to work Visit I statutory obligations, perform the boiler operation,
as presumed during the project period? Does the / the certificates and qualification process is to be
project make provisions for meeting training and PDD made available.
maintenance needs? Procedures for maintenance operations of the
identified critical equipments by the organization CL 1 OK
are to be made available.
Draft Final
A.3. Contribution to Sustainable Development
The project’s contribution to sustainable
development is assessed
A.3.1. Will the project create other PDD DR/ The project will allow usage of wastelands for OK
environmental or social benefits than GhG A2 SV / energy plantation in the region.
emission reductions? I In addition, about 100 persons will be directly
employed by the project as per the employment
record supplied by CPCL. Indirect employment and
their dependents will be additional benefit of the
project
The project has also given stability to the local grid
and has ensured that the quality of power is
improved. These factors, however, cannot be
quantified in terms of tangible returns.
A.3.2. Will the project create any adverse SV / DR / There is a possibility of degradation of the local CL 2 OP
environmental or social effects? APP I environment if the project is not able to attract local
CB biomass producers or the waste biomass is not
cons available during a condition such as a prolonged
ent drought.
to It is further understood that the biomass from this OK
oper region may also be consumed by the paper
ate industry. This competition for the resource may
and escalate the price of biomass.
cons It is foreseeable that under the given extreme CL 2 OP
ent situation the fuel suppliers may resort to
to unsustainable cutting of trees indirectly affecting
esta the sustainability of the project.
blish
Draft Final
blish As per the draft CDM PDD (June 2004) the project
/ proponents have considered purchase of biomass
PDD from a radius of 80 Kilometres from the farmers.
A.2
The company has also identified cultivable OP
wastelands and the farmers are willing to grow
energy plantation. The identified wasteland records
and Memorandum of Understanding with the
farmers need to be documented.
As per the Consent to Operate CAR 02 OK

(APPCB/VJA/NLR/636/HO/2004/A/129 dated
22/09/2004), the project proponent shall use only
permitted biomass fuels as listed in Schedule B to
the Consent. It is noted that both Mango Wood
(Mangifera Indica) and Neem Wood (Azardirachata
Indica) is not included in the permitted biomass
fuels but used in the operations
The project is also likely to promote monoculture of OK

the species supplying the required type of fuel but
at the same time utilization of wastelands.
A.3.3. Is the project in line with sustainable PDD DR The Indian DNA has established 4 criteria for OK
development policies of the host country? 1.2 demonstration of the projects sustainable
development (the terms in bracket suggests the
way in which these criteria are met by CPCL)
• Social well being (Employment generation)
Draft Final
• Economic well being (Income generation)
• Environmental well being (afforestation)
• Technical well being (Highest pressure
boiler)
All of them have been addressed by the project.
(Host country approval granted vide Letter F. No. 4
/ 10 / 2003 – CCC dated 12 April 2004 by Govt. of
India, Ministry of Environment and Forest, (DNA for
India))
A.3.4. Is the project in line with relevant APP DR AP Pollution control board has given consent to
legislation and plans in the host country? CB establish (Order no. 132 / PBC / C.Estt./ ROH – I /
Con EE-N / 69 – 2000 dt. 22 / 02 / 01), consent to
sent operate no. APPCB / VJA / NLR / 636 / HO / 2004 /
to A / 29 dated 22 / 09 / 2004)
oper According to this consent to operate, CPCL is not
ate permitted to use Mango and Neem wood as CAR 02 OK
and biomass fuels. During site visit the same was
cons noticed being consumed. A corrective action to this
ent effect is required by the project proponents
to
esta
blish
Draft Final
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.1.1. Is the selected baseline methodology in PDD DR CPCL proposes to use biomass (renewable OK
line with the baseline methodologies D.2 energy) based co-generating system to supply
provided for the relevant project category? electricity to the APTRANSCO grid.
Therefore, the application of the category I.D. to the
project is considered appropriate. The reasons are
as stated below (reference: Appendix B of the
simplified modalities and procedures for small-
scale CDM project activities Version 03)
Point 23: CPCL comprises renewable in the form of
biomass that supply electricity to an electricity OK
distribution system. It is also connected and
supplying to a non-renewable dominated grid.
Point 24: The gross capacity of the CPCL unit is
CAR 01 OK
stated to not exceed 12 MW gross of which 11.04
MW is for export to the grid. However, considering
an auxiliary consumption of 9 per cent as denoted
in the Order R. P. No. 84/2003 dated March 20,
2004 this would result in the export of 10.92MW).
Organization therefore has to reconsider the
Draft Final
Organization, therefore, has to reconsider the
auxiliary consumption of 8 per cent. CAR 01 OK
Co-firing in the form of coal usage is proposed to
the tune of 23 per cent at the end of the crediting
period (running for 7 years). However, as per the
Consent Order (APPCB /VJA/ NLR/ 636/ HO/ 2004/
A/ 129 dated 22/09/2004) Schedule-B coal
consumption is subject to a maximum of 30 per
cent per annum. This as per the TUV Rheinland
Group requires to be incorporated into the project
emissions, over the crediting period, to assimilate
the vintage of equipment
B.1.2. Is the baseline methodology applicable PDD DR CPCL is expected to replace and substitute fossil OK
to the project being considered? D2 fuels dominated grid electricity with biomass
B.2. Baseline Determination

It is assessed whether the project activity itself is
not a likely baseline scenario and whether the
selected baseline represents a likely baseline
scenario.
B.2.1. Is it demonstrated that the project PDD DR / Regulatory barrier is identified as the most relevant CL 3 OP
activity itself is not a likely baseline B.3 I barrier to the project and when accepting the
scenario due to the existence of one or / RP arguments on the `wide fluctuations in the policy
more of the following barriers: investment no. related enforcements with respect to price to be
barriers, technology barriers, barriers due 84 of paid to biomass based power plants by
to prevailing practice or other barriers? APE APTRANSCO, it may require to be clarified by the
RC project proponent how the project IRR or NPV has
dtd stood readjusted after the policy has come into
Draft Final
20 effect.
marc
h
2004
B.2.2. Is the application of the baseline PDD DR -There has been a drastic fall in hydro electricity
methodology and the discussion and B.5 / generation over last 10 years, which can be
determination of the chosen baseline PDD attributed to drought and other policy decision for OK
transparent and conservative? E/ the state. In case of good monsoon year the energy
RP generation from hydel sources will be better. -
no. Andhra Pradesh has also found off shore natural
84 of gas, which can be used for power generation. All
APE the above factors will make the grid cleaner and the
RC resulting emission factor for the grid will hence
dtd improve over time.
20 Estimation of grid emission factor is conservative
marc CL 4 OK
and acceptable to TUV Rheinland Group. However,
h calculation of the grid emission factor is not
2004 transparent and clarity on the eventual outcome so
as to arrive at the estimated value of emission
factor needs elaboration.
Estimation of PLF is optimistic. Instead of 90 per CAR 01 OK
cent a PLF of 80% shall be considered as
described by the APERC order R.P. No. 84 dated
20th March 2004 based on and keeping in line with
the philosophy of two-part tariff
Draft Final
B.2.3. Are relevant national and/or sectoral PDD DR The recent political election with the installation of a CL 5 OK
policies and circumstances taken into B.3 new State government in Andhra Pradesh has
account? made a policy decision to distribute electricity to
farmers free. Project proponent may well need to
reflect its stand on this late development in the
PDD
B.2.4. Is the baseline selection compatible with PDD DR The baseline is verified by publicly available OK
the available data? Ann authentic data source for the current year. The
ex 3 baseline is conservative by taking into account
/ these data.
CEA
web
site
B.2.5. Does the selected baseline represent PDD DR Yes. Small-scale methodology I – D has chosen for OK
the most likely scenario describing what E the baseline analysis the route of the weighted
would have occurred in absence of the average emissions of the current generation mix.
project activity? Therefore, even as the Andhra Pradesh grid in the
near future is likely to add more gas based projects
making the current generation mix rather cleaner
then it currently is. However, the baseline selected,
based upon the data represented in the PDD
baseline calculations is sufficiently conservative to
give the most likely scenario.
Further, according to APERC (R.P. No. 84) there
will be no additions to the Biomass projects until
review three years hence. Therefore, the stalled
capacity additions for renewable energy projects
from biomass could result in CO2 intensity within
Draft Final
the grid (provided that other renewable projects
also lag in their planned installation)
C. Duration of the Project / Crediting Period
It is assessed whether the temporary boundaries of the
project are clearly defined.
C.1 Are the project’s starting date and PDD DR Form 4, dated 20 May, 2004 issued by Andhra OK
operational lifetime clearly defined? C.1. Pradesh boiler inspection department for registry
1/ number AP – 3785 has been submitted as a proof
PDD that the hydraulic test was conducted on 24
C.1. November, 2003. The same date is now referred in
2 section C.1.1 of the revised draft CDM PDD of
January 05 as the starting date of the project
activity. The operational life of the project is stated
as 25 years
C.2 Is the crediting period clearly defined PDD DR A renewable crediting period is planned for the OK
(seven years with two possible renewals or 10 C.2. project as submitted vide the revised draft CDM
years with no renewal)? 1 PDD (January 2005) with a commencement of the
crediting period from February 2004 (in place of
February 2005 of earlier draft CDM PDD – June
2004)
Draft Final
D. Monitoring Plan
The monitoring plan review aims to establish whether
all relevant project aspects deemed necessary to monitor
and report reliable emission reductions are properly
addressed.
D.1. Monitoring Methodology
It is assessed whether the project applies an
appropriate monitoring methodology.
D.1.1. Is the selected monitoring methodology PDD DR/ Yes, however, clarification is sought on the
in line with the monitoring methodologies D.1 / I/ SV monitoring for
provided for the relevant project category? D.2 1. Energy content of biomass and coal, which CL 6 OK
at the moment is with a monthly monitoring
frequency but how is the same evaluated if
either of the fuel batches was to change
within the prescribed monitoring frequency
2. The calculation of GhG emission by sources
is indicating that the carbon percentage in OK
coal will be monitored. However, the same
is not calculated but obtained from the
supplier
OK
3. The CO2 emission from the transportation
is calculated at 1466 tonnes per annum
(TPA) and is found conservative
Draft Final
D.1.2. Is the monitoring methodology PDD DR Yes, With inclusion of above modifications OK
applicable to the project being D.3
considered?
D.1.3. Is the application of the monitoring PDD DR Yes, the methodology is transparent OK
methodology transparent? D.3
D.1.4. Will the monitoring methodology give PDD DR Yes, With inclusion of above modifications OK
opportunity for real measurements of D.3
achieved emission reductions?
D.2. Monitoring of Project Emissions

It is established whether the monitoring plan
provides for reliable and complete project
emission data over time.
D.2.1. Are the choices of project emission PDD DR For the six (6) identified GhG by UNFCCC, CFC OK
indicators reasonable? D.3 and PFC are not foreseeable in the project activity.
CH4 may be generated as a result of decay of the
biomass; however, it is assumed very small and
can be justifiably neglected as the biomass is not
expected to be stored for less than a year
SF6 is likely from use of electrical equipment such
as gas-insulated switchgear and circuit breakers in
the switch yard but leaks are considered remote
Additional NO2 generation is not likely by the
project activity in comparison to other generating
power plants such as coal
D.2.2. Will it be possible to monitor / measure PDD DR CO2 measurement can be performed by the OK
the specified project emission indicators? D.3 method prescribed, this is the calculation of the
Draft Final
the specified project emission indicators? D.3 carbon content of the coal as mentioned in D.3.7 of
the revised draft CDM PDD (January 2005) and
subsequently through the formula of E.1.2.1
D.2.3. Do the measuring technique and PDD DR SCADA system is installed to monitor various OK
frequency comply with good monitoring D.3 parameters related to the project. Other data are to
practices? be noted manually.
D.2.4. Are the provisions made for archiving PDD DR Yes. The data will be archived for a sufficient time OK
project emission data sufficient to enable D.3 interval and records are to be taken at frequent
later verification? intervals
D.3. Monitoring of Leakage

It is assessed whether the monitoring plan
provides for reliable and complete leakage data
over time.
D.3.1. If applicable, are the choices of leakage PDD DR / Leakage from off-site transportation of fuels is OK
indicators reasonable? E I identified by the project proponent and is
1.2.2 reasonable
D.3.2. If applicable, will it be possible to PDD DR/I Though the fuel transportation is not within the OK
monitor / measure the specified leakage E /SV control of the project proponents prescribed project
indicators? 1.2.2 boundary calculations to estimates leakages in the
revised draft CDM PDD (January’05) are based
upon a strong rationale that the distance to be
covered for biomass collection is limited to 80
kilometres.
However, the distance over which the biomass will CL 7 OK
be collected has to be fixed as per the
recommendations of NEDCAP or other appropriate
authorities so as to ensure continuous compliance
Draft Final
authorities so as to ensure continuous compliance
on the distance as well as the indicated leakage
factors incorporated in the revised draft CDM PDD.
This needs to be verified and authenticated by the
project proponent OK
Further, the conventional power plants and their
fuel transportation is considered to offset the effect
of GhG emission from transportation of biomass.
D.3.3. If applicable, do the measuring PDD DR Yes OK
technique and frequency comply with good E
monitoring practices? 1.2.1
D.3.4. If applicable, are the provisions made for E DR Data collection due to leakage of biomass OK
archiving leakage data sufficient to enable 1.2.1 transportation, as per argument of the draft CDM
later verification? PDD, on a comparison with transportation with coal
need not be substantiated
D.4. Monitoring of Baseline Emissions

It is established whether the monitoring plan
provides for reliable and complete project
emission data over time.
D.4.1. Is the choice of baseline indicators, in PDD DR The choice of baseline indicators such as the grid OK
particular for baseline emissions, D.3 generation mix, the specific emission factors and
reasonable? the energy generation are found to be reasonable.
D.4.2. Will it be possible to monitor / measure PDD DR Yes the monitoring on electricity generated by OK
the specified baseline emission indicators? D.3 various sources of the grid can be obtained from
publicly available data source.
Draft Final
D.4.3. Do the measuring technique and PDD DR Yes, Monitoring plan is following good practise OK
frequency comply with good monitoring D.3
practices?
D.4.4. Are the provisions made for archiving PDD DR Yes OK
baseline emission data sufficient to enable D.3
later verification?
D.5. Project Management Planning

It is checked that project implementation is
properly prepared for and that critical
arrangements are addressed.
D.5.1. Is the authority and responsibility of Orga DR / Authority and responsibility along with the reporting OK
project management clearly described? nogr I structure is given in the organogram published by
am the project proponent
D.5.2. Is the authority and responsibility for Orga DR / Yes it is described in the organorgam CL 9 OP
registration monitoring measurement and nogr I
reporting clearly described? am
D.5.3. Are procedures identified for training of PDD DR / Procedures for training of monitoring personnel OK
monitoring personnel? D.3 I though identified need to be evaluated for any
subsequent requirements as and when they arise
during the crediting period of the project
D.5.4. Are procedures identified for emergency PDD DR / While emergency preparedness have been CL 8 OK
preparedness for cases where D.3 I identified for various situations especial attention to
emergencies can cause unintended the unintended emissions need to be provided
emissions?
D.5.5. Are procedures identified for calibration PDD DR / Yes, calibration has been performed on a regular OK
I
Draft Final
CHECKLIST QUESTION Ref.MoV* COMMENTS Concl. Concl.*
of monitoring equipment? D.3 I basis and organization is to submit the list of
monitoring equipment along with their calibration
schedule to TUV Rheinland Group
D.5.6. Are procedures identified for PDD DR / Yes, procedures are identified but their CL 9 OP
maintenance of monitoring equipment and D.3 I maintenance and management is yet to be
installations? performed
D.5.7. Are procedures identified for monitoring, PDD DR / Yes as seen in the monitoring and verification plan OK
measurements and reporting? D.3 I of the revised draft CDM PDD (January 2005)
D.5.8. Are procedures identified for day-to-day PDD DR / Yes, but needs elaboration on the tracking of OK
records handling (including what records D.3 I information
to keep, storage area of records and how
to process performance documentation)
D.5.9 Are procedures identified for dealing with PDD DR / Yes will be performed by the calibration agency OK
possible monitoring data adjustments and D.3 I
uncertainties?
D.5.10 Are procedures identified for internal PDD DR / Yes but the last scheduled audit for project GhG CL 10 OP
audits of GhG project compliance with D.3 I compliance was cancelled and remained
operational requirements as applicable? unscheduled
D.5.11 Are procedures identified for project PDD DR / Yes OK
performance reviews? D.3 I
D.5.12 Are procedures identified for corrective PDD DR / Yes procedures for identifying non-conformances OK
actions? D.3 I and their corrective actions are identified for both
operations as well as management function
Draft Final
E. Calculation of GhG emission
It is assessed whether all material GhG emission
sources are addressed and how sensitivities and data
uncertainties have been addressed to arrive at
conservative estimates of projected emission reductions.
E.1.Project GhG Emissions
The validation of predicted project GhG
emissions focuses on transparency and
completeness of calculations.
E.1.1. Are all aspects related to direct and PDD DR All direct emissions related to CO2 emissions have OK
indirect project emissions captured in the E.1. been considered in the project design, however,
project design? 2.5 / the design neglects emissions from other
E.2 greenhouse gases with justification for CH4 but no
elaboration of indirect emissions from SF6 and N2O
within the project design but TUV RHEINLAND
considers them to be negligible
E.1.2. Have all relevant greenhouse gases and PDD DR As mentioned in E1.1 OK
sources been evaluated? E
E.1.3. Do the methodologies for calculating PDD DR / Yes OK
project emissions comply with existing E/ I
good practice? Exp
ert
View
E.1.4. Are the calculations documented in a PDD DR Yes calculations of emission reductions while being OK
complete and transparent manner? E /I complete and transparent the calculation of arriving
125 at grid emission factor should be made transparent;
Draft Final
1.2.5 at grid emission factor should be made transparent;
Further, step 4 of the calculation ‘units exported to OK
APTRANSCO’ is incomplete in respect to
deductions of project related emissions due to use
of fossil fuels within the text of the PDD, however,
the same is seen elaborated in ‘enclosure-1:
baseline calculations’
E.1.5. Have conservative assumptions been PDD DR / Yes the emission factor is conservatively assumed. OK
used? E1 I However, see CAR 01 for more details on
conservativeness
E.1.6. Are uncertainties in the project PDD DR Yes, due to monitoring instrument related OK
emissions estimates properly addressed? E.1. uncertainties
2.5
E.2.Leakage
It is assessed whether there leakage effects, i.e.
change of emissions which occurs outside the
project boundary and which are measurable and
attributable to the project, have been properly
assessed.
E.2.1. Are leakage calculation required for the PDD DR Yes and leakage effects have been assessed. OK
selected project category and if yes, are E
the relevant leakage effects assessed? 1.2.2
E.2.2. Are potential leakage effects properly PDD DR The leakage due to biomass transportation is OK
accounted for in the calculations (if E accounted for and may be neglected as per
applicable)? 1.2.2 reasons identified in revised draft CDM PDD (also
see point D.3.2)
Draft Final
E.2.3. Do the methodologies for calculating PDD DR The leakage calculation is conservative and is OK
leakage comply with existing good practice E matching with good practices.
(if applicable)? 1.2.2
E.2.4. Are the calculations documented in a PDD DR Calculations are complete and transparent. OK
complete and transparent manner and (if E
applicable)? 1.2.2
E.2.5. Have conservative assumptions been PDD DR Yes as seen in the reply to the closure of CL 7 and CL 7 & OK
used (if applicable)? E CL 11 CL 11
1.2.2
E.2.6. Are uncertainties in the leakage PDD DR Uncertainties related to distance of biomass CL 11 OK
estimates properly addressed (if E procurement need to be identified
applicable)? 1.2.2
E.3.Baseline GhG Emissions

The validation of predicted baseline GhG
emissions focuses on transparency and
completeness of calculations.
E.3.1. Are the baseline emission boundaries PDD DR Yes baseline emission sources are clearly defined OK
clearly defined and do they sufficiently B.4 along with the sources of emission
cover sources for baseline emissions?
E.3.2. Are all aspects related to direct and PDD DR Yes, sufficiently covered OK
indirect baseline emissions captured in the E.1.
project design? 2.4
E.3.3. Have all relevant greenhouse gases and PDD I Yes, project proponent has evaluated and identified OK
sources been evaluated? E.1. that the only greenhouse gas of relevance is CO2
2.4
Draft Final
E.3.4. Do the methodologies for calculating PDD DR Yes, methodologies for calculating baseline OK
baseline emissions comply with existing E.1. emissions are complying with existing good
good practice? 2.4 practice
E.3.5. Are the calculations documented in a PDD DR Yes, calculations are complete and transparent OK
complete and transparent manner? E1.2
.4 /
E.2
E.3.6. Have conservative assumptions been PDD DR Assumptions on existing baseline are conservative OK
used? E.1.
2.4
E.3.7. Are uncertainties in the baseline PDD DR Key assumptions and uncertainties are based upon OK
emissions estimates properly addressed? E.1. the external data received from utilities of Andhra
2.4 Pradesh, future capacity additions and export of
power to APTRANSCO and these are seen to be
sufficiently addressed and recognised as being
conservative by TUV Rheinland Group
E.4.Emission Reductions
Validation of baseline GhG emissions will focus
on methodology transparency and completeness
in emission estimations.
E.4.1. Will the project result in fewer GhG PDD DR It is anticipated that due to power generation from OK
emissions than the baseline case? B.3 / the combustion of biomass (such as rice husk,
E.2 Juliflora, Chilli Stalk) would result in emission
reduction for the same amount of electricity/power
generated by means of combusting fossil fuels.
This is due to the reason that low cost biomass
Draft Final
generating stations have net zero emissions
(carbon neutral).
F. Environmental Impacts
It is assessed whether environmental impacts of the
project are sufficiently addressed.
F.1.1. Does host country legislation require an CA DR No, the project cost is less than Rs. 1000 million for OK
analysis of the environmental impacts of repo which no EIA is required.
the project activity? rt
F.1.2. Does the project comply with APP DR Yes, AP Pollution Control Board has issued
environmental legislation in the host CB consent to establish and consent to operate.
country? cons According to consent to operate Clarion Power
ent Corporation Ltd-
to CAR 02 OK
• Cannot use Mango and Neem as a biomass
esta fuel. However, during the site visit the same
blish was found to be used freely
/
• Is also required to give an action plan for usage CL 12 OP
Con
of Municipal solid waste, market yard waste as
sent
fuel within 3 months as per consent to operate.
to
A copy of the same should be submitted
oper
ate • Is required to submit an action plan for CL 13 OP
development of energy plantation within one
month. A copy of the same should be
submitted
Reference: APPCB consent to establish (Order no.
132 / PBC / C.Estt./ ROH – I / EE-N / 69 – 2000 dt.
22 / 02 / 01), consent to operate no. APPCB / VJA /
Draft Final
NLR / 636 / HO / 2004 / A / 29 dated 22 / 09 / 2004)
F.1.3. Will the project create any adverse PDD DR Adverse effects on environment can come into OK
environmental effects? A.2 / picture if no sustainable biomass plantation or
waste biomass collection systems are devised. The
project proponents are required to explain how they
are ensuring environmentally sustainable biomass
usage (see A.3.2).
F.1.4. Have environmental impacts been PDD DR Mango Wood and Neem Wood usage CAR 02 OK
identified and addressed in the PDD? F.1
G. Comments by Local Stakeholder
Validation of the local stakeholder consultation process.
G.1.1. Have relevant stakeholders been Site I AP Electricity Regulatory Authority, Zilla Panchayat OK
consulted? visit (District Local body) and Local NGO have been
consulted. However, draft CDM PDD has no
reference to their identification but now stand
identified in the revised draft CDM PDD
(January’05)
G.1.2. Have appropriate media been used to Visit I Personal communication is used for inviting OK
invite comments by local stakeholders? to comments from the stakeholders.
site
G.1.3. If a stakeholder consultation process is PDD DR / India doesn’t require stakeholder consultation for OK
required by regulations/laws in the host G.1 I/ the given size of the project. During TUV Rheinland
country, has the stakeholder consultation SV Group’s interview with head of Velagapudi village, it
process been carried out in accordance was pointed out that due to CPCL local grid is
with such regulations/laws? experiencing better quality of power in terms of
Draft Final
voltage.
G.1.4. Is a summary of the comments received PDD DR / Summary of the comments received from OK
provided? G.2 I stakeholders is received by TUV Rheinland Group.
G.1.5. Has due account been taken of any PDD DR / The project proponent shall describe the process of CL 14 OK
comments received? G.3 I identifying the local stakeholders and the manner in
which these comments were received from these
identified local stakeholders and accounted for
Table 3 Resolution of Corrective Action and Clarification Requests
Page A-6-30
Report No. 4002is, rev. 05 This document is a part of the Validation and Verification Manual
Draft report clarifications and corrective Ref. To Summary of project owner response Validation team conclusion
action requests by validation team checklist
question in
table 2
Clarifications (CL)
CL 1 A.2.5 CPCL has appointed qualified CPCL has submitted copy of qualifying
Qualified personnel, as per the requirement personnel for operation and certificates of the boiler operators
of the statutory obligations, perform the boiler maintenance of boiler as per statutory
operation, the certificates and qualification requirements. The list of the qualified
process is to be made available. personnel along with supporting
documents can be given as proof on a
sample basis.
The procedure for maintenance and Procedure for maintenance of critical

Procedures for maintenance operations of operation of the critical operations is equipments is provided.
the identified critical equipments by the existing and it is attached as a proof to The response is deemed sufficient and
organization are to be made available. TUV RHEINLAND the request for clarification is closed
CL 2 A.3.2 CPCL is following the regulations laid CPCL has provided confidence to TUV
There is a possibility of degradation of the down by APPCB and NEDCAP, which Rheinland Group the biomass suppliers
local environment if the project is not able to are taking care of local environment. In from whom CPCL purchases the
attract local biomass producers or the waste case of non-compliance with the biomass are following rules related to
biomass is not available during a condition regulations, the licence of CPCL can be cutting, collection, transportation, and
such as a prolonged drought. cancelled. Moreover, the suppliers of storage of biomass.
CPCL are also following rules laid down TUV Rheinland Group is of the opinion
Page A-6-31
question in
table 2
by AP forest department. CPCL will try that a strict observation of the relevant
It is foreseeable that under the given to use alternate fuels like, agro crop environment and forest laws will ensure
situations the fuel suppliers may resort to residue, agro industrial residues, that the plant does not affect the
unsustainable cutting of trees indirectly energy plantation or coal. The region environment.
affecting the sustainability of the project. does not foresee draught as a The compliance of rules by suppliers
possibility in view of the past history. and its cross check by CPCL will be
seen during the verification process.
CL 3 B.2.1 The IRR of the project was 31% and The project IRR is reduced
Regulatory barrier is identified as the most 33% respectively prior to considerably due to introduction of new
relevant barrier to the project and when implementation of the new tariff without tariff policy by APERC. However, CPCL
accepting the arguments on the `wide CDM and with CDM respectively. With will provide endorsed IRR calculations
fluctuations in the policy related introduction of the new tariff, the IRR of the project to TUV Rheinland Group.
enforcements with respect to price to be paid were 13 and 15% for the case when,
to biomass based power plants by CDM is not considered and CDM is
APTRANSCO, it may require to be clarified considered.
by the project proponent how the project IRR
or NPV has stood readjusted after the policy
has come into effect
CL 4 B.2.2 Grid emission factor calculation has The response is deemed sufficient and
Estimation of grid emission factor is been revised and incorporated in the request for clarification is closed.
conservative and acceptable to the TUV section 1.2.4 of the revised draft CDM
RHEINLAND. However, calculation of the PDD (January 2005)
grid emission factor is not transparent and
clarity on the eventual outcome so as to
arrive at the estimated value of emission
factor needs elaboration.
Page A-6-32
question in
table 2
CL 5 B.2.3 As per Electricity act 2003, the This has been verified with the
The recent political election with the government shall deposit the money Electricity Act 2003 (Pg. 33, para 65).
installation of a new State government in equivalent to the value of supply of free The response is deemed sufficient and
Andhra Pradesh has made a policy decision power / subsidised power with the request for clarification is closed.
to distribute electricity to farmers free. Project APTRANSCO.
proponent may well need to reflect its stand
on this late development in the CDM PDD
CL 6 D.1.1 The company has in-house facility to The monitoring plan in section D3 of the
Energy content of biomass and coal, with a check the energy content of the fuel at revised draft CDM PDD has introduced
monthly monitoring as indicated in the any given point of time. For each batch measurement of calorific value of coal
monitoring plan, needs to elaborate on how of the fuel the energy content is and biomass for each batch.
the same is evaluated if either of the fuel measured and is available in the The response is deemed sufficient and
batches was to change within the prescribed records. the request for clarification is closed
monitoring frequency
CL 7 D.3.2, E.2.5 The distance from which biomass is Emission due to transportation of fuel is
The distance over which the biomass will be procured ranges from 5 to 150 km. As a not considered in the baseline
collected has to be fixed as per the conservative practice the distance is calculations. However, section E.1.2.2
recommendations of NEDCAP or other calculated at an average of 80 km. has considered biomass transportation
appropriate authorities so as to ensure for the plant. This calculation has
continuous compliance on the distance as considered average distance for the
well as the indicated leakage factors biomass transport.
incorporated in the CDM PDD. This needs to The response is deemed sufficient and
be verified and authenticated by the project the request for clarification is closed
proponent
CL 8 D.5.4 Emergencies are not expected to lead The emergencies are identified and the
While emergency preparedness have been to unintended emissions. However, a preparedness is demonstrated in the
Page A-6-33
question in
table 2
identified for various situations especial procedure for preparedness for submitted documents.
attention to the unintended emissions need to unintended emissions from the project The response is deemed sufficient and
be provided is submitted as a separate document. the request for clarification is closed.
CL 9 D.5.2, D.5.6 The procedures for maintenance of the The procedure for maintenance of
Maintenance procedures for monitoring monitoring equipments are identified monitoring equipments is understood
equipments and installations are identified and performed regularly. by TUV Rheinland Group to be
but their maintenance and management is maintained by CPCL as noted.
yet to be performed Implementation of these procedures will
be observed during the verification
stage.
CL 10 D.5.10 The GhG compliance internal audit will The internal audit procedures are
Procedures for internal audits of GhG be performed in the month of January submitted by the project proponent to
emissions project compliance are identified 2005 TUV Rheinland Group.
but the last scheduled audit for project GhG Implementation of the internal audit will
compliance was cancelled and remained be seen during verification stage
unscheduled
CL 11 E.2.5, E.2.6 CPCL states that it procures the CPCL has given assurance to TUV
Uncertainties related to distance of biomass biomass from distance of less than 50 Rheinland Group that the maximum
procurement need to be identified km. As a conservative practice the biomass coverage is less than 50 km
distance is considered to be 80 km, radius and maximum distance to some
which will be eliminating the extent is also procured from 150 km. As
uncertainties. a conservative practice, 80 km average
distance is considered. This
consideration is reducing the
uncertainty related biomass
Page A-6-34
question in
table 2
transportation to a large extent.
The response is deemed sufficient and
the request for clarification is closed.
Page A-6-35
question in
table 2
CL 12 Usage of municipal waste is TUV Rheinland Group is expecting a
CPCL is required to give an action plan for F.1.2 recommended by APPCB and it is not supporting document of the response
usage of Municipal solid waste, market yard compulsory for CPCL to implement from the project proponent. During the
waste as fuel within 3 months as per G.O Ms. these measures. However, CPCL has verification stage the document seeking
No. 3. dtd. 08/01/2004. A copy of the same asked for extension from APPCB for extension and action plan submitted to
should be submitted submission of the action plan. APPCB will be verified.
CL 13 As per biomass survey, adequate TUV Rheinland Group is expecting a

CPCL is required to submit an action plan for F.1.2 biomass is available to run the plant in supporting document of the response
development of energy plantation within one the region. Captive farming is at a from the project proponent. During the
month. A copy of the same should be conceptual stage. CPCL will submit the verification stage action plan submitted
submitted action plan once need for captive to APPCB will be verified.
farming is envisaged with techno
economic support
CL 14 G.1.5 Section G of the revised draft CDM Section G 1 of the revised draft CDM
The project proponent shall describe the PDD has demonstrated the process of PDD has given the process of
process of identifying the local stakeholders identifying the local stake holders and identifying local stakeholders. G.2 of
and the manner in which these comments the manner in which their comments the revised draft CDM PDD
were received from these identified local were addressed summarised the views of the local
stakeholders and accounted for stakeholders. Since there is no adverse
comment for the project, these
comments are not to be addressed.
The response is deemed sufficient and
the request for clarification is closed
Page A-6-36
question in
table 2
Corrective Action Required (CAR)
CAR 1 The auxiliary consumption is All the issues raised in CAR 1 have
The gross capacity of the CPCL unit is stated B.1.1 reconsidered at 9% in the revised draft been resolved by the project
to not exceed 12 MW gross of which 11.04 CDM PDD. proponents while submitting the revised
MW is for export to the grid. However, PDD.
considering an auxiliary consumption of 9 per
cent as denoted in the Order R. P. No.
84/2003 dated March 20, 2004 this would
result in the export of 10.92MW).
Organization, therefore, has to reconsider the
auxiliary consumption of 8 per cent.
Co-firing in the form of coal usage is B.1.1 The revised PDD has considered 30%
proposed to the tune of 23 per cent at the usage of coal throughout the crediting
end of the crediting period (running for 7 period.
years). However, as per the Consent Order
(APPCB /VJA/ NLR/ 636/ HO/ 2004/ A/ 129
dated 22/09/2004) Schedule-B coal
consumption is subject to a maximum of 30
per cent on an annual basis. This as per the
TUV RHEINLAND requires to be
incorporated into the project emissions, over
the crediting period, to assimilate the vintage B.2.2
of equipment
Estimation of PLF is optimistic. Instead of 90 PLF is made to 80% in the revised draft
Page A-6-37
question in
table 2
per cent a PLF of 80% shall be considered as CDM PDD of January 2005.
described by the APERC order R.P. No. 84
dated 20th March 2004 based on and
keeping in line with the philosophy of two-part
tariff
CAR 2 Neem and mango ware acceptable Neem and Mango have constituted
Project proponent may clarify whether the A.3.2/A.3.4 biomass fuels as per NEDCAP about 20% of the total biomass used as
use of neem and mango trees are allowed as / F.1.2/F.1.4 guidelines as well as consent to per the data submitted to TUV
fuel in biomass based power projects. establish given by APPCB. Consent to Rheinland Group. This was not
operate received on October 3, 2004 permitted as per consent to operate of
has banned use of Neem and Mango. APPCB. CPCL used this non-permitted
Since than CPCL has stopped the biomass from February 21, 2004, (date
usage of these species. Biomass power of plant commissioning) to October 3,
producers will approach APPCB for 2004 (receipt of consent to operate
inclusion of Neem and Mango in the list from APPCB) for a period of 226 days.
of biomass fuel to be used. Till the time Hence, TUV Rheinland suggests a
Neem and Mango are permitted, CPCL deduction of 20% emission reduction
will not use Neem and Mango. from certified emission reduction for
first 226 days of crediting period to
CPCL.
The use of Neem and Mango has been
stopped as noted in revised draft CDM
PDD of January 2005.
o0o -
Page A-6-38

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TUV Rheinland Group

REPORT NO. 4002IS

CDM Validation Report Template

Date of first issue: Project No.:

Client: Client ref.: Certificate Number

Report No.: Subject Group:

Validation Report Template 3.0, December 2003

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

Table of Contents Page

3 VALIDATION FINDINGS ......................................................................................... 9

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS .............................. 19

5 VALIDATION OPINION ......................................................................................... 21

Appendix A: Validation Protocol

Report No: 4002is, rev. 05

Team Member Office Role

Report No: 4002is, rev. 05

1.3 GhG Project Description

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

2.1 Review of Documents

Report No: 4002is, rev. 05

Validation Protocol Table 2: Requirement checklist

Validation Protocol Table 3: Resolution of Corrective Action and Clarification Requests

Figure 1 Validation protocol tables

Report No: 4002is, rev. 05

Date of interview: 22nd September 2004

Report No: 4002is, rev. 05

3 Dy. Director - • Principles of tariff fixation

2.3 Resolution of Clarification and Corrective Action Requests

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

3.1 Project Design

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

3.3 Monitoring Plan

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

3.4 Calculation of GhG Emissions

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

3.5 Environmental Impacts

Report No: 4002is, rev. 05

3.5 Comments by Local Stakeholders

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS

TUV RHEINLAND’s response:

Report No: 4002is, rev. 05

UNQUALIFIED VALIDATION OPINION

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

Report No: 4002is, rev. 05

SMALL-SCALE CDM VALIDATION PROTOCOL

Version 3.0, December 2003

Table 2 Requirements Checklist

A.2. Project Design

As per the Consent to Operate CAR 02 OK