PROJECT DESIGN CDM !
PROJECT DESIGN CDM !
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CONTENTS
D. Environmental impacts
E. Stakeholders’ comments
Annexes
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250.000
1996 and currently holds in excess
200.000 of 3.2 million tonnes of waste. In
Total SW
150.000 disposed, t 2008, the disposed waste amount
100.000 reached 354,620 tonnes1,
50.000 corresponding to 1000 t/day on
0
average. The landfill is a managed
landfill with no landfill gas
In 2008, the Gaziantep Metropolitan Municipality opened a tender for managing its solid waste at the
landfill. The Project owner has acquired the right to commercially operate the landfill in 2008.The Project
does not only aim at utilizing the already existing waste but it will also make use of the new waste until
2018. The Project is expected to operate until 20382 and will have two phases; in the initial phase the
capacity will be 1.131 MW. In the second phase, the capacity will be expanded up to 5.655 MW:
1
Source: Gaziantep Environmental and Forestry Department (http://www.gaziantep-
cevreorman.gov.tr/sayfalar/cevysb.php?Gel=Bak&id=76)
2
Source: Feasibility Study, section 4.2.2.
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During the registration process of the Project, the construction of the 1 st and 2nd stages have been
completed and full operation has started. Gaziantep Landfill is a landfill in use today, vehicle weighing
stations are installed near the administration building to record landfill amount and emitted leachate is
being stored in the storage tank and moved to the treatment facility using tank lorries. The proposed
Project consists of covering the landfill site with soil, installation of vertical and horizontal pipes for
collecting and transporting the recovered LFG, combusting the LFG for electricity generation and flaring
the remaining LFG. The Project’s objective is to utilize LFG generation from almost all the waste
disposed in former years as well as the coming years, therefore the Project covers the Gaziantep landfill
as a complete waste management project. At the time of PDD preparation, the waste at the Project site has
been covered with soil and the LFG collection piping system has been completed. The Project owner is
responsible both of utilisation of the LFG, and the landfill site’s management.
The purpose of LFG flaring is to dispose of the flammable constituents (particularly methane) safely and
to control odour nuisance, health risks and other adverse environmental impacts. The electricity
generation will be used to cover the own electricity consumption of the Project and the excess power will
be sold to the national electricity grid. The proposed Project will reduce GHG emissions by:
i. Preventing methane emissions to the atmosphere: Municipal waste decays under normal
conditions at the landfill site and this leads to the production of large amounts of potent
greenhouse gases. Methane is the largest constituent of LFG and its global warming potential
(GWP) is 21 times than CO2. The LFG produced at the landfill site will be captured and
destroyed.
ii. The recovered methane will be combusted for power generation. The produced electricity will be
supplied to the national power grid and substitute the electricity which otherwise would have
been generated by the thermal power plants. Thus, it will reduce the fossil fuel consumption and
associated CO2 emissions indirectly.
3
Source: Acceptance permits by the Ministry of Energy and Natural Resources.
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CEV Enerji Üretim San. ve Tic. Ltd. Sti. (private entity) is the project owner and shall be defined as the
project participant. Mavi Consultants act as carbon consultants for the Project. Contact details are
provided in Annex 1.
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Landfill Cover:
The waste will be covered with soil to block
methane emissions to the atmosphere to provide
sufficient containment and prevent air or rainwater
to get into the waste.
This cover will include clay, sand and soil layers
for erosion control and plant growth.
LFG Collection:
The Project aims at efficiently collecting LFG generated at the
landfill site by using vertical wells, which are easy to maintain.
The technical properties of this system are as follows;
Considering the inclination and landfill depth, there will
be 38 units of vertical gas wells covering the landfill.
These wells are able to effectively collect LFG from a
radius of 30 m.
The gas will go through: Vertical collection well →
Horizontal collection pipe → Manifold Station
→Connecting pipe → Header pipe → Pre-treatment
facility
A modular piping network will connect groups of gas
wells to 3 manifolds. The manifolds are connected to the
main pipe which delivers the gas to the extraction plant
and the flare, and have the following properties:
The manifold station will control collection pressure, flow
rate and properties of each vertical well, prevent
condensation in pipes and keeps balance of pressure
Figure 6. Arrangement of vertical wells between individual pipes with automatic gas pressure
control valves.
The condensate in the horizontal LFG collection lines (10-
15 lines) will be returned to the landfill by collecting
condensates at dewatering traps at lower points of the
LFG collection system.
The LFG will be drawn from the landfill with the help of
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Electricity Generation:
The Project will generate electricity from LFG to cover its own electricity consumption and to feed the
rest to the national power grid. The Project employs 1 gas engine generator with 1.131 MWe capacity, and
by adding new generators with 1.131 MW each the Project’s capacity will be increased up to 5.655 MW,
depending on actual gas extraction. The generator is driven by a turbocharged gas engine with 16
cylinders. The installed gas engine is JGC 416 GS-L.L with a rated power of 1.131 MWe and electrical
efficiency of 41.6%.
The Project uses two buildings at the landfill site, one for operational activities and the other one for the
personnel. Electricity will be generated in container type engine generation system and transmitted to
national grid after being consumed within the site. Each engine/alternator unit will contain a transformer,
switch gear, synchronization system and system protection device. The mechanical energy will be
converted into electrical power.
An electrical sub-station contains all suitable switching gear and metering equipment to facilitate a proper
connection to the national grid network. Parallel to the gas production rate, each unit will be operated
depending on the need. All engine units will be fitted with an internet-based remote monitoring and
controlling feature which allows engines to be monitored, started and stopped remotely to be used for
emergency cases or maintenance purposes4. Regardless of this system, the Project will employ full time
staff for operation, routine servicing and repairs.
Flare
In addition to the power generation equipment, the Project owner plans installing a flare. This will ensure
that the LFG, which could not be combusted in the power generation units, is destroyed. Enclosed stacks
will provide conditions for high temperature combustion to effectively destruct methane with other
combustible LFG components and end up with low GHG emissions.
Project Instrumentation
The Project will include sophisticated instrumentation that will allow for the accurate measurement of
captured and destroyed LFG, including the following components:
Flow meters will be installed to measure and monitor accurately the flow of the LFG through the
system. The measurement points will be: the main delivery pipe, the pipe going to the flare and
the pipes going to each of the generation units. These flow meters will also be able to accurately
measure various parameters such as pressure, temperature and the gas contents (e.g. methane,
carbon dioxide and oxygen). The measurement sampling intervals of the flow meters will be in
agreement with the UNFCCC requirements.
The measurement system will be able to store the measured data electronically. The control and
monitoring system will allow these readings to be obtained remotely.
The flare will include flame and temperature control. Ultraviolet cameras will monitor the
presence of the flame and thermocouples will monitor both the temperature of the flame and
temperature of the exhaust gas in the stack. This way, the temperature of the stack gas will be
regulated with an automated air louver.
4
Provided that the site gets connected with a phone line.
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A.4.4. Estimated amount of emission reductions over the chosen crediting period:
The Project is expected to achieve the following emission reductions:
Table 2. Expected Emission Reductions of the Project
Year Ex-ante estimation of emission reduction in tCO2e
2010 (partial) 30,384
2011 114,654
2012 163,729
2013 167,037
2014 169,217
2015 170,445
2016 171,245
2017 (partial) 157,417
Total estimated reductions, tCO2e 1,144,128
Total number of crediting years 7
Annual average over the crediting period of
163,447
estimated reductions (tonnes of CO2 e)
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B.1. Title and reference of the approved baseline and monitoring methodology applied to the
project activity:
For the emission reductions stemming from LFG capture, the ACM0001 v.11, “Consolidated baseline and
monitoring methodology for landfill gas project activities”, hereinafter referred to as the methodology, is
used. The methodology refers to the following tools:
“Tool for the demonstration and assessment of additionality”; v.5.2 (“Additionality Tool”)
“Tool to determine methane emissions avoided from disposal of waste at a solid waste disposal
site”; v.4
“Tool to determine project emissions from flaring gases containing methane”; EB28, Annex 13
For the emission reductions stemming from electricity generation, the ACM0002 v.12.1 “Consolidated
baseline methodology for grid-connected electricity generation from renewable sources is used. This
methodology refers to the following tool:
“Tool to calculate the emission factor for an electricity system”, v.2
B.2. Justification of the choice of the methodology and why it is applicable to the project
activity:
ACM0001 Applicability:
This methodology is applicable to landfill gas capture project activities, where the baseline scenario is the
partial or total atmospheric release of the gas and the project activities include situations such as:
(a) The captured gas is flared; and/or
(b) The captured gas is used to produce energy (e.g. electricity/thermal energy). Emission reductions
can be claimed for thermal energy generation, only if the LFG displaces use of fossil fuel either
in a boiler or in an air heater. For claiming emission reductions for other thermal energy
equipment (e.g. kiln), project proponents may submit a revision to this methodology;
(c) The captured gas is used to supply consumers through natural gas distribution network. If
emissions reductions are claimed for displacing natural gas, project activities may use approved
methodology AM0053.
Since the Project involves both flaring and electricity generation, options (a) and (b) are satisfied and the
methodology is applicable to the Project.
ACM0002 Applicability:
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The small scale AMS I.D methodology can be applied if the Project has a maximum capacity of 15 MWe.
The Project will have a maximum capacity up to 5.65 MW and is therefore eligible for the use of AMS
I.D. However, for the sake of conservative approach, the large scale methodology is preferred.
B.3. Description of the sources and gases included in the project boundary:
According to ACM0001, the project boundary is the site of the Project activity where the gas is captured
and destroyed/used. The Project boundary shall include the power generator, which is connected to the
grid.
According to ACM0002, the project boundary should encompass the physical, geographical site of the
renewable generation source.
Waste production
LFG production
Fugitive emissions
Own consumption LFG collection
Project boundary
End Use
The spatial extent of the Project boundary is defined as the Project site and the plants connected to the
grid system to which the Project will be connected to.
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B.4. Description of how the baseline scenario is identified and description of the identified
baseline scenario:
As the ACM0001 suggests, the baseline scenarios are identified and assessed according to the “Tool for
the demonstration and assessment of additionality”. The ACM0001 further requires certain scenarios to
be included among alternatives. These default scenarios are included in the assessment.
The Project includes the LFG and electricity generation components; therefore different alternatives to
these two components will be described;
There is no incentive to utilise the LFG to produce thermal energy, since there is no demand for thermal
energy in the surroundings of the Project site. The Project is a green field investment, which does not
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modify or retrofit any existing facility. There is no national regulation which would require the recovery
or flaring of the LFG emitted from landfill sites. Based on the barrier and investment analyses, it is clear
that the P1 and LFG1 scenarios are not feasible for the Project owner and are therefore not applicable.
The Project being a voluntary initiative, the only plausible baseline scenario would be:
P2: Generation of grid-connected power, which would have otherwise been generated by the
operation of already existing grid-connected power plants and by the addition of new generation
sources; and,
LFG2: Maintaining the status quo, where LFG is emitted into the atmosphere without conducting
any management, collection or utilization on the landfill site.
The Project owner does not have other fossil fuel fired power plants or control over the emissions
stemming from the baseline scenario. The Project will partially reduce LFG emissions from the landfill
and substitute the electricity generation from grid-connected fossil fuel fired thermal power plants,
thereby reducing the overall greenhouse gas emissions.
B.5. Description of how the anthropogenic emissions of GHG by sources are reduced below
those that would have occurred in the absence of the registered CDM project activity (assessment
and demonstration of additionality):
This section utilizes the “Tool for the demonstration and assessment of additionality”, as required by the
methodology. In agreement with the ACM0001, when defining alternative scenarios, relevant policies
and regulations related to the management of landfill sites are taken into account.
Step 1: Identification of alternatives to the project activity consistent with current laws and
regulations
Realistic and credible alternatives to the project activity(s) are defined through the following Sub-steps;
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LFG3: The Project activity is realized using the VER revenues. This scenario corresponds to the
Project activity, where the Project only becomes feasible with the use of VERs. Under this
alternative, the Project will partially capture the LFG emissions from the landfill site and use it
for power generation. The rest will be flared in order to minimize GHG emissions and safety
risks, which were present in the scenario LFG2.
The alternative scenario is defined as the combination of both Landfill Gas and Power Generation
components, since the Project has both components. Realistic and credible alternative scenarios to the
Project activity are identified.
5
Source: Energy Market Regulatory Authority (http://www.epdk.gov.tr/english/regulations/electricity.htm)
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For the landfill gas component, the following laws and regulations may apply;
Table 5. Laws and Regulations governing the landfill gas component
Legal Framework Concerning the Environment
The Environment Law Packaging Waste Control Regulation
Air Quality Control Regulation Soil Protection Law
Noise Control Regulation Air Pollution from Heating Regulation
Water Pollution Control Regulation Hazardous Chemicals Regulation
Control of Solid Waste Regulation Waste Batteries Regulation
Environmental Impact Assessment Soil Pollution Control Regulation
Regulation
Medical Waste Regulation Air Pollution from Vehicles Regulation
Toxic Chemical Substance and Prod Medical Waste Control Regulation
Regulation
Hazardous Waste Regulation Water Resources Protection from Hazardous Materials
Regulation
Waste Oils Control Regulation Urban Waste Water Treatment Regulation
Industrial Air Pollution Control Regulation Drinking Water Quality Regulation
The Environment Law6 does not require a tipping fee for accepting municipal solid waste at the sanitary
solid waste disposal sites. There is an “environment tax” and another “waste water surcharge” collected
by municipalities from households for waste management activities. The collected taxes are mostly used
for maintenance of city parks and gardens and managing waste. Municipalities generally subsidize waste
6
The Environmental Law (Nr. 2872), dated to 11.08.1983 is a comprehensive law describing relevant public bodies
and their responsibilities, principles of environmental protection, limitations and prohibitions, penalties etc. It is also
supported by various specific communiquees and regulations.
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collection and dumping activities from the municipal budgets. Under these circumstances, municipalities
or households are not familiar with additional costs of proper waste management. Therefore, waste
management is one of the everlasting problems of municipalities and is an unattractive field for private
companies.
The “Metropolitan Municipalities Law7” sets out the legal framework of solid waste management in
metropoles. Accordingly, the Gaziantep Metropolitan Municipality is responsible for the collection,
management and proper disposal of municipal waste and shall build and operate the necessary facilities or
let 3rd parties do so. In agreement with this law, a tender shall be organized for certain types of goods and
services the municipalities purchase. Therefore, the Municipality has organized a tender and the Project
owner has won it by offering landfill site management with no cost to the Municipality.
The Project is a voluntary investment managed by a special contract between the Gaziantep Metropolitan
Municipality and the Project owner. Therefore the Project has to be in compliance with all relevant
legislation. The Project is licensed and permitted by public authorities. All scenarios are valid according
to national laws, regulations and communiqués.
For scenario LFG2, the most relevant regulation governing landfill sites is the “Control of Solid Waste
Regulation”. According to its Article 27, landfill sites are not enforced to capture and/or to destroy LFG
emissions. This regulation does not set any obligations or penalties but only suggests the reduction of
GHG emissions. Therefore, this alternative reflects current practice and is in agreement with current laws
and regulations.
For scenario P2, maintaining the status quo, without the realization of the Project activity, is by definition
in agreement with the relevant legislation.
As a result, it is shown that these realistic and credible alternative scenarios to the Project activity are in
compliance with mandatory legislation and regulations.
7
Law Nr: 5216, Article 7
(http://www.mevzuat.gov.tr/Metin.Aspx?MevzuatKod=1.5.5216&MevzuatIliski=0&sourceXmlSearch=)
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8
Only relevant guidance items are included from “Guidelines on the Assessment of Investment Analysis” v.3, EB51
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Outcome of Sub-step 2b: The benchmark analysis is applied and the approach is explained.
9
Weighted average cost of capital (WACC) is the rate that a company is expected to pay on average to all its
security holders to finance its assets. The WACC is the minimum return that a company must earn on existing asset
base to satisfy its creditors, owners, and other providers of capital, or they will invest elsewhere.
10
Weighted average cost of capital (WACC) is the rate that a company is expected to pay on average to all its
security holders to finance its assets. The WACC is the minimum return that a company must earn on existing asset
base to satisfy its creditors, owners, and other providers of capital, or they will invest elsewhere.
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According to the agreement between the Municipality and the Project owner, the Project owner does not
receive any revenues from the Municipality.
In this scenario, the Project IRR calculations are carried out without considering carbon credit sales. The
calculations conservatively assume that the revenues from electricity sales are obtained without delay
(which may not reflect the actual case), that there are no major unforeseen malfunctions or other
unforeseen expenses, and that the LFG generation occurs as expected.
The results indicate that without carbon credits, the Project is not feasible. Under these circumstances, the
Project would not be attractive for a private investor.
In this case, it is observed that the IRR improves considerably with the inclusion of the carbon credit
component and thus exceed the benchmarks. The Project IRR reaches investment levels because it
exceeds the benchmarks.
Outcome of Sub-step 2c: Financial indicators are calculated and compared.
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The purpose of the sensitivity analysis is to check how much the Project’s financial performance depends
on main variables of the investment analysis. The Additionality Tool requires including those financial
parameters in the analysis, that have 20% or more impact on the results. The following parameters are
identified which satisfy this condition;
a) Electricity Prices (impact on revenues)
b) Capital expenditures (impact on costs)
c) LFG Collection ratio (impact on revenues)
d) Operation and Maintenance Costs (impact on costs)
Both parameters are changed in the negative and positive directions to check how far they affect the
Project profitability. The Additionality Tool suggests to at least cover an interval from -10% to +10%
when varying the chosen input parameters. In order to assess the behaviour of the Project feasibility to a
wider range of variations, an interval from -15% to +15% is chosen, with steps of 5% change. The results
are as the following;
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Sensitivitiy of IRR
30.0%
Sensitivitiy of IRR
30.0%
The figure above depicts the reaction of the financial viability of the Project to the most important
changing input parameters. Accordingly, the following conclusions can be made:
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a) Impact of electricity prices on Project IRR (“Power IRR”): There are two Power IRR lines in
the Figure 7 above, the lower one representing the baseline scenario (LFG1&P1) without carbon
revenues, and the upper line representing the proposed Project activity, including carbon
revenues. The figure shows that the Project is quite sensitive to electricity prices. The Project
would become feasible only if the electricity price would increase by 15% or higher, which is
unlikely considering current market conditions, legal incentives for renewable energy and trends.
b) Impact of capital expenditures on Project IRR (“CapEx IRR”): The figure shows that as
CapEx increases the IRR decreases (and vica versa) and that it is unlikely the Project becoming
feasible even if CapEx would drop at significant amounts. Even if capital expenditures would
increase by 20%, the IRR would be below the benchmark.
c) Impact of Operation and Maintenance Costs (“O&M IRR”): The figure shows that as O&M
costs increases the IRR decreases (and vica versa) and that it is unlikely the Project becoming
feasible even if O&M costs would drop by 15%.
During the registration process of the Project, the construction of the 1st and 2nd stages have been
completed and full operation has started. In the meantime, actual realized financial figures (CAPEX, loan
interest rate, E/D ratio) have also been finalized. The real figures and a comparative IRR analysis with
these real values show that the Project is not feasible and real IRR is considerably below the benchmark.
Conclusion: It is seen that in case the parameters change in positive direction, the Project does not
exceed the benchmark threshold.
Outcome of Sub-step 2d: The sensitivity of financial indicators to input parameters is assessed.
Outcome of Step 2: The sensitivity analysis clearly demonstrates that the proposed Project activity is
unlikely to be most financially/economically attractive and LFG1 & P1 is not a plausible alternative.
According to the Additionality Tool, this satisfies the requirement of Step 2.
11
Source: Turkish Statistical Institute (http://www.turkstat.gov.tr/PreIstatistikTablo.do?istab_id=496)
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Incineration plants
Number 2
Capacity (thousand tonnes/year) 44
Composting plants
Number 4
Capacity (thousand tonnes/year) 551
The Project is not common practice and it has not diffused in energy generation industry in the host
country. This is demonstrated below;
Sub-step 4a: Analyze other activities similar to the proposed project activity:
As the geographical scope the host country is selected, because there is no sufficient evidence that
suggests landfills in a specific region have considerably different characteristics than other regions or the
host country.
The proposed Project activity is an IPP12 investment by a private company for the purpose of generating
electricity from LFG. In Turkey, the permission process starts with obtaining a generation license. In this
context, license holders can be defined as companies who have a certain extent of intention for an
investment. IPP license holders are particularly similar to the Project activity, as they have the same
purpose of generating and selling power to the national grid with similar legal framework. BOT and
Autoproducer models cannot be regarded as similar, as they are based on different legal, financial and
organizational conditions.
12
Independent Power Producer, generating and selling energy to the grid on commercial basis
13
Source: http://www.epdk.gov.tr/lisans/elektrik/lisansdatabase/verilentesistipi.asp
14
Autoproducer: Companies who generate energy mainly for their own consumption.
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Enerji
Ortadogu IPP Istanbul 7.6 Yes Power generation from LFG
Enerji
ITC-KA IPP Ankara 11.3 Yes Power generation from LFG
ITC IPP Ankara 25 Yes Power generation from LFG
ITC IPP Adana Yes Power generation from LFG
Ekolojik IPP Istanbul 1.0 Unknown Gasification facility for
Enerji hazardous waste
Aksa BOT15 model Bursa 1.4 Unknown Power generation from LFG
Enerji
CEV IPP Bolu 3.3 Yes Power generation from LFG
Marmara
Avdan IPP Samsun 1.2 Yes Power generation from LFG
Enerji
The first private power generation facilities which are in operation have been realized under BOT or
Autoproducer models. Autoproducers generate electricity primarily for their own electricity consumption,
and they are allowed to feed only a fraction of their generation to the grid. The BOT model is not
applicable in Turkey anymore, as the existent BOT projects have special contracts with the government
and will be handed over to the government after a certain period of time. As BOT and autoproducer
power plants are not completely liberal electricity market players and are limited in terms of number and
installed capacity, they cannot be considered as common practice or similar projects.
After the “liberalization” of the electricity market, which is still in a transformation period, investors have
been allowed to build and operate their own power plants for electricity production and sales to the
national grid as IPPs. Since the Project activity is an IPP, it cannot be compared to BOT or Autoproducer
projects. Therefore, ISTAC and AKSA projects cannot be regarded as similar activities. The Ekolojik
Enerji project deals with hazardous waste and is out of the scope. The remaining Ortadogu and ITC-KA
projects are similar activities, as they are IPPs that generate power from LFG. All these 3 projects have
considered VERs. There are no other similar project activities which have been realized without the
consideration of carbon credits.
Demonstration of additionality
Due to some time constraints, macroeconomic conditions and ongoing talks with the Gaziantep
Metropolitan Municipality, there have been some delays in the development of carbon project. Since
banks refused to fund the Project, the Project owner had to devote its scarce resources to meeting its
deadlines. However, the Project has been designed and planned from the beginning by considering carbon
credits. The feasibility study of the Project activity clearly suggests that emission reductions and carbon
revenues have been an integral part of the Project from the start. The project owner has considered carbon
revenues earlier than project implementation, demonstrating early consideration of VER revenues.
The chronological history of the Project is as the following;
15
Build-Operate-Transfer: This model enables parties to have specific, undisclosed contracts with particular
exemptions, incentives and other mechanisms. This business model was applicable before the electricity market
liberalization and cannot be regarded as a similar activity.
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The identified barriers and results of the investment analysis are sufficient grounds for demonstration of
additionality since they prevent potential project proponents from carrying out the proposed project
activity undertaken without being registered as a VER project activity. The waste-to-energy concept
constitutes a very limited portion of the Turkish electricity market and the Project Activity goes beyond
of “business as usual” scenario and cannot be considered as a common practice.
The regulations in the host country regarding landfill gas capture or destruction are not mandatory and
there is a distinct lack of policies promoting efficient use of LFG (e.g. production of renewable energy,
processing of organic waste etc.). Landfill site operators are not required to capture or destroy LFG,
therefore the Project would have reduced GHG emissions compared to the case where it would not be
realized at all. As a result, the Project is considered to be additional.
Outcome of Sub-step 4b: Other similar options are discussed and the additionality of the Project is
demonstrated.
The methodology ACM0001 requires that ‘Project proponents should provide an ex-ante estimate of
emission reductions, by projecting the future GHG emissions of the landfill”. For the Project, a model
based on the first order decay model was used in Project’s feasibility study to determine estimated
emission reductions ex-ante. Based on this model, the ex-ante emissions will be estimated. After the
operation, the real emission reductions will be monitored ex-post.
Emission Reductions
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According to the ACM0001, leakage does not need to be accounted. The emission reduction is the
difference between the baseline emissions and project emissions;
The definitions of all the parameters used in the formulae below are provided in Annex 3 of this PDD.
Baseline emissions
The baseline emissions prior to the Project implementation consist of:
The methane emitted to the atmosphere from the landfill; and
The grid emissions due to electricity generation;
As the Project does not involve thermal power generation or gas supply to any pipeline, according to
ACM0001 the methane destruction by the Project is calculated as;
MDproject,y = MDflared,y + MDelectricity,y ( 4)
The project emissions due to flaring will be calculated by using the “Tool to determine project emissions
from flaring gases containing methane”;
8760
PEflare,y = ∑ TMRG,h*(1-ηflare,h)*GWP CH4/1000 ( 6)
h=1
The LFG generation is calculated using the first order decay method using the “Tool to determine
methane emissions avoided from disposal of waste at a solid waste disposal site”. Accordingly, the
methane emissions avoided is found as;
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electricity generation with fossil fuel fired power plants by renewable electricity. ACM0002 offers two
options for preparing the baseline calculation:
(a) A combined margin, consisting of the combination of operating margin (OM) and build margin
(BM) according to the procedures prescribed in the ‘Tool to calculate the emission factor for an
electricity system’, or;
(b) The weighted average emissions (in kg CO2e/kWh) of the current generation mix. The data of the
year in which project generation occurs must be used.
Option (a) above will be applied for the Project. The combined emission factor CEFelec,BL,y for the Project
activity is calculated as a weighted average of Operating Margin and Build Margin emission factors. The
operation margin refers to a cohort of power plants that reflect the existing power plants whose electricity
generation would be affected by the proposed project activity. The build margin refers to a cohort of
power plants that reflect the type of power units whose construction would be affected by the proposed
project activity;
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Any comment:
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Data / Parameter: AF
Data unit: N/A
Description: National legislation and mandatory regulations
Source of data used: The national legislation: “Control of Solid Waste Regulation” Article 27
Value applied: Equation (3)
Justification of the The relevant national regulations regarding solid waste disposal do not require
choice of data or any LFG destruction or reduction. Therefore AF is taken as 0.
description of
measurement methods
and procedures actually
applied :
Any comment:
Data / Parameter: φ
Data unit: N/A
Description: Model correction factor to account for model uncertainties
Source of data used: “Tool to determine methane emissions avoided from disposal of waste at a solid
waste disposal site”
Value applied: 0.9
Justification of the Given the uncertainties associated with the model and in order to estimate
choice of data or emission reductions in a conservative manner, a discount of 10% is applied to
description of the model results.
measurement methods
and procedures actually
applied :
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Any comment:
Data / Parameter: OX
Data unit: N/A
Description: Oxidation factor (reflecting the amount of methane from SWDS that is oxidized
in the soil or other material covering the waste)
Source of data used: IPCC 2006 Guidelines for National Greenhouse Gas Inventories
Value applied: 0.1
Justification of the The Project site will be covered with soil, therefore OX=0.1 according to the
choice of data or “Tool to determine methane emissions avoided from disposal of waste at a solid
description of waste disposal site”.
measurement methods
and procedures actually
applied :
Any comment:
Data / Parameter: F
Data unit: N/A
Description: Fraction of methane in the SWDS gas (volume fraction)
Source of data used: IPCC 2006 Guidelines for National Greenhouse Gas Inventories
Value applied: 0.5
Justification of the A preliminary sampling carried out on the Project site indicates a methane
choice of data or fraction around 0.6. A default value of 0.5 is recommended by IPCC, therefore
description of 0.5 is used in a conservative manner.
measurement methods
and procedures actually
applied :
Any comment:
page 32
measurement methods
and procedures actually
applied :
Any comment:
page 33
Data / Parameter: kj
Data unit: N/A
Description: Decay rate for the waste type j
Source of data used: For kj values: IPCC 2006 Guidelines for National Greenhouse Gas Inventories
For climate data (1975-2006 Averages): National General Directorate for
Meteorology (http://www.dmi.gov.tr/veridegerlendirme/il-ve-ilceler-
istatistik.aspx?m=GAZIANTEP ;
http://www.dmi.gov.tr/veridegerlendirme/yillik-toplam-yagis-
verileri.aspx?m=GAZIANTEP )
Value applied: For different waste types, the decay rate varies;
W j,x kj
Wood, wood products and straw 0.02
Pulp, paper and cardboard (other than sludge) 0.04
Food, food waste, sewage sludge, beverages and tobacco 0.06
Textiles 0.04
Other (non-food) organic putrescible garden and park waste 0.05
Glass, plastic, metal, other inert waste 0.00
Justification of the The “Tool to determine methane emissions avoided from disposal of waste at a
choice of data or solid waste disposal site” lists decay rates for different waste types.
description of
Average temperate in Gaziantep over the year is 15.0 °C and annual
measurement methods
precipitation is 553.3 mm. Based on these data, the selection of appropriate kj
and procedures actually
values are made according to a “boreal and temperate” and “dry” climate.
applied :
Unclassified SW types of nappies, rubber and leather are covered in the “Pulp,
paper and cardboard” classification. Ceramics, soil and sand are covered in the
“Glass, plastic, metal, other inert waste” classification.
Any comment:
page 34
Any comment:
page 35
measurement methods value”. The flare will be monitored with probes with an adequate frequency;
and procedures actually
0%, if the temperature in the exhaust gas of the flare (Tflare) is below
applied :
500 °C for more than 20 minutes during the hour h .
50%, if Tflare is above 500 °C for more than 40 minutes during the hour
h, but the manufacturer’s specifications on proper operation of the flare
are not met at any point in time during the hour h.
90%, if Tflare is above 500 °C for more than 40 minutes during the hour
h and the manufacturer’s specifications on proper operation of the flare
are met continuously during the hour h.
For estimating the amount of flared methane ex-ante, 90% is used.
Continuous monitoring of compliance with manufacturer’s specification of flare
will be performed. If in a specific hour any of the parameters are out of the limit
of manufacturer’s specifications, a 50% default value for the flare efficiency
will be used for the calculations for this specific hour.
Any comment:
The Project’s emission reductions stem from the prevention of methane emissions to the atmosphere from
the SWDS as well as substitution of electricity by generation of electrical power from the LFG. There are
basically two components of the baseline emissions;
i. Landfill gas, and;
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Using appropriate decay rates kj and fractions of degradable organic carbon DOCj and taking the
capacities of the generator and the flare, the Equation (7) results in the following LFG generation figures:
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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The project emissions from flaring shall be subtracted from the methane destroyed by flaring, using the
Equation (6), as explained in the “Tool to determine project emissions from flaring gases containing
methane. It is assumed that an enclosed flare will be operated in agreement with its manufacturer’s
specifications and will be monitored. Accordingly, the PEflare,y is found as;
Using these results, the net methane amount destroyed by flaring is found with the Equation (5);
Table 15. Calculation of destroyed methane by flaring
page 38
These figures for the first and last year of the crediting period are not given for the entire year but only
partially depending on the crediting start date of the proposed Project activity.
16
Since 2001: Exports to Georgia, Azerbaijan, Iraq, Syria. Imports from Bulgaria, Iran, Turkmenistan, Georgia.
Sources: http://www.teias.gov.tr/ist2006/49.xls, http://www.teias.gov.tr/ist2006/47.xls
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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The UNFCCC methodology suggests using local, publicly available data whenever possible. In the lack
of local data, industry guidelines shall be used in a conservative manner. 2005-2007 national emissions
figure stemming from electricity generation is publicly available and used for OM calculations.
STEP 3. Calculate the operating margin emission factor according to the selected method
According to the “Tool to calculate the emission factor for an electricity system”, the OM emission
factor, EFGRID,OM,y, is found as;
EFGRID,OM,y = EMgrid,y / EGy, (9)
Using official CO2 emissions data instead of calculated figures, the Operating Margin Emission Factor,
EFGRID,OM, is found to be as the following;
Table 17. Calculation of the OM emission factor
Operating Margin EF 2006 2007 2008 Note
CO2 Emissions, ktCO2 (Official Data) 85,312 100,662 101,473 used
CO2 Emissions, ktCO2 (Calculation) 82,844 98,099 103,714 not used
Net Electricity Supplied to grid, GWh 127,208 149,198 157,558
OM Emission Factor in year y, tCO2/MWh 0.671 0.675 0.644
Operating Margin EF 2006-2008,
tCO2/MWh 0.663
STEP 4. Identify the cohort of power units to be included in the build margin
In this step, a generation-weighted average emission factor is calculated based on a sample of power
plants, which have been taken into operation recently. The sample group of power plants/units m used to
calculate the build margin consists of either:
(a) The set of five power units that have been built most recently
(b) The set of power capacity additions in the electricity system that comprise 20% of the system
generation (in MWh) and that have been built most recently.
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For conducting the calculations, option (b) is selected, because this option results in a larger electricity
generation. The data of the most recent commissioned power plants are being published by the Turkish
Electricity Transmission Company (TEİAŞ) on an annual basis. For build margin calculations, the power
plants/units taken into operation between 2003-2007 are included in the cohort of power units.
Performance revisions, modifications, retrofits and dismantlings of power plants or are stand-alone have
been excluded from the samples list for the build margin calculations.
Based on these requirements and conditions, the final list of selected power plants is summarized in
Annex 3.
EG * EF m, y EL , m , y
EFGRID , BM , y m
(10).
EG m
m, y
Using the sample list of recently built power plants, the Build Margin Emission Factor, EFGRID,BM, is
found as;
page 41
2008, tCO2/MWh
Power plant-specific data are unavailable in Turkey; therefore CO2 emissions are calculated based on fuel
type consumed in sample power plants/units. Data regarding electricity generation efficiency rates in
Turkey are not available for each power plant in the sample list. Efficiency rates of already operating
large power plants do exist17, however they are not included in the sample list. Conservatively, the
average efficiency for each fuel type from the existing efficiency rates are assumed as efficiency for
calculation purposes.
The “Tool to calculate the emission factor for an electricity system” requires the sample list of recent
capacity additions to constitute at least 20% of the system generation. This requirement is met;
Table 19. Generation of Recent Capacity Additions
Generation Sample List Generation [GWh]
2008 Generation, GWh 191,558
UNFCCC Threshold, % of Generation 20%
UNFCCC Threshold, GWh 38,311.6
Capacity Additions, 2004-2008 GWh 42,929.0
17
Environmental Map of Turkey, 2004 (Published by General Directorate of Environmental Works of Turkey)
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Estimation of Estimation of
Estimation of Estimation of
project activity overall emission
Year baseline emissions leakage (tonnes
emissions (tonnes of reductions (tonnes
(tonnes of CO2 e) of CO2 e)
CO2 e) of CO2 e)
B.7. Application of the monitoring methodology and description of the monitoring plan:
page 43
Data / Parameter: T
Data unit: °C
Description: Temperature of the landfill gas
Source of data to be Reading from the flow meter
used:
Measurement N/A
procedures (if any):
Monitoring frequency: Continously
QA/QC procedures: The flow meter is subject to a regular maintenance and testing, to ensure
accuracy.
Any comment: Measured continuously to determine the density of methane.
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Data / Parameter: P
Data unit: Bar
Description: Pressure of the landfill gas fed into gas engine
Source of data to be Reading from the flow meter
used:
Measurement
procedures (if any):
Monitoring frequency:
QA/QC procedures: The flow meter is subject to a regular maintenance and testing, to ensure
accuracy.
Any comment: Measured continuously to determine the density of methane.
page 45
used:
Measurement This parameter will be measured by a dedicated measurement device in
procedures (if any): accordance with UNFCCC and device manufacturer’s requirements.
Monitoring frequency: There will a separate flow meter for each of the generator units, as required by
the Methodology.
Data will be measured continuously with a flow meter by the Project owner.
The flow meter will be maintained and calibrated regularly in line with the
manufacturer’s recommendations. This will ensure that the accuracy of the
measurement instrument is maintained.
QA/QC procedures: Data will be aggregated monthly and yearly for each generator unit. Flow
meters will be subject to a regular maintenance and testing regime to ensure
accuracy. The measurement interval will be equal to or more than one sampling
each hour.
Any comment:
page 46
Data / Parameter: AF
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Data unit: %
Description: Regulatory requirements relating landfill gas projects
Source of data to be National laws and regulations.
used:
Measurement 0. (No enforced regulations relating to landfill gas recovery or power generation
procedures (if any): projects)
Monitoring frequency: This information will be checked yearly.
QA/QC procedures: In case of a change of the Article 27 of the relevant regulation “Control of Solid
Waste Regulation”, this change will be included in the monitoring report.
Any comment:
page 48
accuracy etc.
PMUM is owned and operated by the public transmission line operator TEIAS,
which purchases the electricity from the project owner. Therefore, PMUM
reports offer a conservative, dependable and correct way for monitoring net
electricity supplied to the grid.
There is no sampling involved in monitoring. All data used will be measured,
increasing the accountability of the calculated emission reductions.
In order to maintain uninterrupted measurement and to prevent technical errors,
a back-up measurement device will also be installed, which will continuously
measure and store generation and consumption data real-time, parallel to the
main measurement device.
Before installation, both measurement devices will be calibrated by TEIAS. If a
malfunctioning is observed during operation, the measurement device will again
be inspected and calibrated by TEIAS.
Both measurement devices will be sealed and only accessible by TEIAS
personnel. Project staff or any other personnel will have no control over or
access to the measurement devices.
Measured data will be both kept by the project owner and the PMUM web site
for at least 2 years.
The net electricity supplied to the grid will be calculated by subtracting
Project’s own consumption from gross generation figure. This calculation will
be done with a spreadsheet in order to allow easy understanding, transparency
and correct computation purposes with minimum human intervention.
Any comment: The annual emissions reductions will be updated by multiplying the ex-ante
calculated baseline emission factor by the PMUM-reported amount of net
electricity supplied to the grid. The emission factor will not be updated.
page 49
The monitoring instruments to be installed include LFG flow meters, methane meters, pressure and
temperature gauges and electricity measurement devices. All the monitoring instruments will meet the
relevant accuracy requirements.
page 50
All data used for the monitoring plan will be archived electronically and backed up regularly. These data
will be kept for the full crediting period and a further two years after the end of the crediting period or the
last issuance of VERs, whichever occurs later. The monitoring plan mainly involves proper preparation of
a spreadsheet and reporting of it. Monitoring will be carried out with the help of a spreadsheet.
Please refer to section B.7.1 for details.
The responsible person for the monitoring of the Project is the general
manager of the Project owner. The Project owner will appoint a project
manager who will collect the data. The data will be processed and
reported in agreement with the monitoring plan by the general
manager. The general manager can assign a carbon consultant for
these tasks.
The general manager of the Project owner is responsible for
overseeing the implementation of the monitoring procedure.
Competency requirements for these tasks will be applied to ensure that
the general manager is able to implement and/or supervise this
procedure. The general manager will be responsible of the emission
reduction calculations and the preparation of necessary documents for
verification.
The general manager will appoint the power plant manager for data collection, checking instrumentation,
record keeping, data handling and data processing, filing, reporting, organising repair and maintenance of
monitoring equipment and ensuring the monitoring plan is adhered to as indicated in the approved PDD.
The general manager will ensure that the personnel of the Project owner acquire the skills to carry out
these tasks properly through capacity building practices and trainings.
The maintenance staff will receive technical trainings, as well as health and safety trainings to minimise
exposure to workplace hazards. At every shift, at least one trained technical personnel will be present. All
relevant information such as data files, maintenance and defect records and other monitoring related
records will be kept at a designated location in a transparent and organised manner.
The SCADA monitoring system of the Project in general follows the requirements of methodology
ACM0001 version 11. The Figure 8 shows the overview of the monitoring system and the measurement
devices.
page 51
Manual Recording of Data: The general manager will implement a manual data recording system to act as
a back-up for the on-line monitoring system. This basic back-up system will consist of regular updating of
a spreadsheet manually that includes the main key parameters.
Data Archiving: The electronic monitoring system will periodically archive the readings data. Written
documents (e.g. equipment replacement protocols, accident logs, maintenance records, back-ups etc.) will
be kept safely. These data will be stored until 2 years after the end of the crediting period. The general
manager will implement a document control system that ensures that the correct versions of
documents that might be necessary for verification purposes are available whenever needed.
Data corruption: If data in the SCADA system are corrupted or missing during the operational hours
(which can be proven by the records of the electricity meters), the missing data can be estimated by the
following procedure: the value of that parameter one hour before the error, one hour after the system
restart, and the average from the previous 24 hours will be determined and the lowest figure of those will
be used. For other cases, any deficiencies in methane flow monitoring data will be rectified by calculation
from power generation in a conservative manner.
18
“Measurement and Measuring Tools Inspection Regulation”, Date: 24/07/1994, Official Gazette Number: 22000
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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monitored and to be used for baseline emissions, is the net electricity generation, without the cut,
which is the difference of gross electricity generation and self electricity consumption.
At the end of each monitoring period, the data from the monthly meter readings will be added up
to obtain the total monitoring period net electricity generation. This figure will be multiplied with
the combined margin emission factor, which has been calculated ex-ante.
The procedure will be repeated for each month. The sum of emission reductions of each month
will give the total offsets achieved by the Project.
Data Source:
At the first day of each month, a TEIAS personnel comes to the sites and makes a reading regarding the
last period from the beginning to the end of the previous month. After making the reading from the
metering device, a standard protocol showing the generation and consumption data is signed by the site
manager and the TEIAS personnel. Under normal conditions, these figures are used for invoicing
purposes.
Based on these monthly protocols, a detailed breakdown of generation and consumption figures is also
supplied by the TEIAS Market Financial Clearing Center (PMUM) website. The project participant can
access its own consumption and generation data through the web site of PMUM
(http://pmum.teias.gov.tr) by using a secured ID and password. After accessing this web site, the project
participant is able to call actual and historical data. These data are used by TEIAS for invoicing, and the
same data source will be used for the determination of emission reductions.
TEIAS invoices according to the net electricity supply, which takes transmission line losses into account.
This means that the invoiced amount of electricity is the difference of gross generation, self consumption
and transmission line losses, which is determined by TEIAS every month as a certain percentage.
For emission reductions calculations, however, transmission line losses shall not be subtracted; therefore
the invoiced amount of energy cannot be used. Instead, EGfacility,y (Annual net electricity amount fed to
the grid by the project activity) will be used, which is the monitoring parameter, is the difference between
the Gross Electricity Generation (GEGy) and project activity’s Self Electricity Consumption (SECy):
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B.8. Date of completion of the application of the baseline study and monitoring methodology and
the name of the responsible person(s)/entity(ies):
This monitoring methodology and baseline study application was completed on September 2nd, 200919 by
Yagmur Karabulut.
Consultant: Mavi Sürdürülebilir Kalkinma Proje ve Danismanlik Hiz. Ltd. Sti.
Address: Baba Efendi S. 5/2 34357 Akaretler, Istanbul - TURKEY
Telephone: +90 212 3270922
Fax: +90 212 3270925
19
The baseline study application date is later than the construction start date. However, the CDM revenues have
been considered from the start in the tender document and the feasibility study.
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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E-Mail: [email protected]
Web: www.maviconsultants.com
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C.2.2.2. Length:
N/A
20
CDM Glossary of Terms, Version 03
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D.2. If environmental impacts are considered significant by the project participants or the host
Party, please provide conclusions and all references to support documentation of an environmental
impact assessment undertaken in accordance with the procedures as required by the host Party:
N/A
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E.1. Brief description how comments by local stakeholders have been invited and compiled:
The Project is not required to follow an official stakeholder consultation procedure. Since an EIA report
was not required by the Ministry of Environment and Forest, no official EIA meeting was organized.
Instead, various unofficial meetings have been carried out between the project owner and local
communities.
E.3. Report on how due account was taken of any comments received:
Stakeholder did not raise any critical issues which would require the Project design to be revisited.
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Annex 1
Building:
City: Istanbul
State/Region:
Postcode/ZIP: 34662
Country: Turkey
Telephone: +90 216 651 92 85
FAX: +90 216 651 92 87
E-Mail: [email protected]
URL: www.cev-tr.com
Represented by:
Title: General Manager
Salutation: Mr.
Last name: Lee
Middle name:
First name: Yong Woo
Department:
Mobile:
Direct FAX:
Direct tel:
Personal e-mail: [email protected]
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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page 60
Annex 2
page 61
Annex 3
BASELINE INFORMATION
page 62
x Year during the crediting period: x runs from the first year of the first crediting period (x =
1) to the year y for which avoided emissions are calculated (x = y)
y Year for which methane emissions are calculated
page 63
page 64
page 65
page 66
Emission Factor,
NCV Calculations [TJ/kt or TJ/mil m3] 2004 2005 2006 2007 2008 [tCO2/TJ]
Hard Coal 15.1 13.6 18.1 18.2 17.9 90.8
Imported Coal 25.5 24.7 24.5 25.0 24.9 90.8
Lignite 7.6 5.9 6.9 6.9 6.8 90.9
Fuel Oil 39.9 40.2 40.2 39.8 39.7 75.5
Diesel Oil 42.4 42.8 42.7 43.1 42.3 72.6
Lpg 45.9 46.0 0.0 0.0 1.0 61.6
Naphta 44.0 44.3 43.9 43.2 44.6 69.3
Natural Gas 36.9 37.3 37.0 36.7 36.6 54.3
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Table 27. Electricity Generation of Selected Recent Capacity Additions by Fuel Type
Indicative
Capacity Additions 2004 2005 2006 2007 2008 Total Efficiency
Coal 0.0 1125.0 0.0 0.0 0.0 1125.0 40.0%
Lignite 0.0 4420.0 7020.0 11.1 0.0 11451.1 40.0%
Fuel Oil 466.2 99.1 0.0 806.4 103.2 1474.9 46.0%
Diesel oil 0.0 0.0 0.0 0.0 0.0 0.0 46.0%
LPG 0.0 0.0 0.0 0.0 0.0 0.0 60.0%
Naphtha & Asphaltite 322.9 0.0 0.0 0.6 0.0 323.5 46.0%
Natural Gas 8810.4 6995.4 3457.4 3274.2 2546.5 25083.9 60.0%
Renewables and wastes 0.0 85.0 12.0 0.0 22.0 119.0 N/A
Hydro 241.8 945.8 432.3 146.4 1477.0 3243.3 N/A
Geothermal & Wind 0.0 2.4 56.0 0.0 50.0 108.4 N/A
Total 9,841.4 13,672.7 10,977.7 4,238.6 4,198.7 42,929.0
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Annex 4
MONITORING INFORMATION
Responsibility:
The methodology requires monitoring of net electricity supply of the Project. Archiving the daily power
generation reports, performance report and monthly meter reading is handled by project proponent on
regular basis. The data collection on daily basis is done by project O&M staff, who are responsible for
preventive maintenance, handling emergency situations and improvement measures under the overall
responsibility of project manager on site.
Data Quality:
The generation and consumption data will be used for invoicing purposes. The data is of high quality,
because the monthly reports are signed both by the project proponent and by TEİAŞ, the public
transmission line operator. Measuring devices will have accuracy better than UNFCCC requirements,
thus fulfilling quality conditions.
21
http://www.teias.gov.tr/mali/maliuz.htm
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Monitored Data:
Net Electricity Generation of the Project = Gross Generation of the Project – Consumption of the Project
Gross Generation of the Project and Consumption of the Project will be monitored and recorded to
calculate Net Electricity Generation of the Project.
Storage of Data:
Data involving consumption and generation will be kept by PMUM, the market financial settlement
centre and users (project proponents included) can access its website with its unique ID and password to
be able to see these data. Storage will be done by PMUM for an unlimited period of time, which ensures
UNFCCC criteria.
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Annex 4
ATTACHMENTS
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