VALIDATION REPORT

ANEMON INTEPE 30.4 MW

WIND FARM PROJECT
TURKEY
REPORT NO. 2007-44002
REVISION NO. 01

CDM Validation Report Template

Version 5.0, November 2006
This is a report template to be used for the validation of CDM
projects. Guiding text is presented in italic letters, as here.
This document must be seen in conjunction with the Validation
and Verification Guidelines

Date of first issue:

Project No.:

04/07/2007

44002

Organisational unit:

TIE
Client:

Client ref.:

Ecofys / OneCarbon

Project Name: Anemon Intepe 30.4 MW Wind Farm Project

Country: Turkey
Methodology: ACM0002
Version: 06
GHG reducing Measure/Technology: Wind Power
ER estimate: 79,136 tCO2e per annum
Size
Large Scale
Small Scale
Validation Phases:
Desk Review
Follow up interviews
Resolution of outstanding issues
Validation Status
Corrective Actions Requested
Clarifications Requested
Full Approval and submission for registration
Rejected
In summary, it is TV Rheinlands opinion that the Anemon Intepe 30.4 MW Wind Power Project in
Turkey, as described in the PDD of 29 May 2007, meets all main UNFCCC requirements for the CDM
and all main host country criteria as well as requirements for Voluntary Offset Projects under the Gold
Standard and correctly applies the baseline and monitoring methodology ACM0002 version 06. After
resolving of a few corrective action and clarification requests TV Rheinland recommends to submit
the request for registration for the project activity directly to Gold Standard Foundation (GS-TAC).
Report No.:

2007-44002

Date of this revision:

21/09/2007

01

Rev. No.

Report title:Anemon Intepe 30.4 MW Wind Farm Project,Turkey

Work carried out by:

Kurt Seidel

No distribution without permission from

the Client or responsible organisational unit

Work verified by:

Limited distribution
Unrestricted distribution

CDM Validation, No. 2007-44002, rev. 01

Abbreviations
Explain any abbreviations that have been used in the report here.
BM
Build Margin
CAR
Corrective Action Request
CDM
Clean Development Mechanism
CEF
Carbon Emission Factor
CER
Certified Emission Reduction
CL
Clarification request
CO2
Carbon dioxide
CO2e
Carbon dioxide equivalent
DNA
Designated National Authority
FCAR
Forward Corrective Action Request
FCL
Forward Clarification Request
GHG
Greenhouse gas(es)
GJ
Giga joule
GWP
Global Warming Potential
IPCC
Intergovernmental Panel on Climate Change
IRR
Internal rate of return
LOA
Letter of Approval
MP
Monitoring Plan
MVP
Monitoring and Verification Plan
NGO
NPV
ODA

Non-governmental Organisation
Net Present Value
Official Development Assistance

O&M

Operation and maintenance

PDD

Project Design Document

UNFCCC

United Nations Framework Convention on Climate Change

CDM Validation, No. 2007-44002, rev. 01

TABLE OF CONTENTS
ANEMON INTEPE 30.4 MW WIND FARM PROJECT ......................................................... 1
1

EXECUTIVE SUMMARY VALIDATION OPINION ........................................... 5

2
2.1
2.2

INTRODUCTION ....................................................................................................... 6
Objective
6
Scope
6

3
3.1
3.2
3.3
3.4
3.5

METHODOLOGY....................................................................................................... 6
Desk Review of the Project Design Documentation
7
Follow-up Interviews with Project Stakeholders
8
Resolution of Outstanding Issues
9
Internal Quality Control
11
Validation Team
11

4
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9

VALIDATION FINDINGS ....................................................................................... 12

Participation Requirements
12
Project Design
12
Baseline Determination
13
Additionality
14
Monitoring
17
Estimate of GHG Emissions
20
Environmental Impacts
21
Comments by Local Stakeholders
21
Comments by Parties, Stakeholders and NGOs
22

Appendix A: Validation Protocol

CDM Validation, No. 2007-44002, rev. 01

1 EXECUTIVE SUMMARY VALIDATION OPINION

The DOE E-0013 TV Rheinland Japan Ltd. ( TV Rheinland ) has performed a
validation of the Anemon Intepe 30.4 MW Wind Farm Project in Turkey. The validation
was performed on the basis of UNFCCC criteria for the Clean Development Mechanism and
host country criteria, as well as the Gold Standard Validation & Verification Manual for
Voluntary Offset Projects and criteria given to provide for consistent project operations,
monitoring and reporting. The review of the project design documentation and the subsequent
follow-up interviews have provided TV Rheinland ( the verifier ) with sufficient evidence to
determine the fulfilment of stated criteria. After resolving of a few corrective action and
clarification requests TV Rheinland considers to submit the request for registration to Gold
Standard Foundation for the project activity.
The host party is Turkey and the participating Annex I party is not yet identified at this stage
of validation. Turkey was not a Party to the UNFCCC when the Kyoto Protocol was adopted
in 1997. Hence, no quantified emissions limitation or reduction commitment was defined for
Turkey in Annex-B of the Kyoto Protocol. Thus, Turkey is not a Party to the Kyoto Protocol
yet. Turkey acceded as the 189th Party to the UNFCCC on 24 May 2004. Turkey is therefore
now listed in Annex-I to the UNFCCC, but not listed in Annex-B to the Kyoto Protocol (no
quantified emissions limitation or mitigation commitment yet), therefore, not a Party to the
Kyoto Protocol yet! Because Turkey as host country fulfils currently not the participation
criteria under the Kyoto Protocol for CDM-projects or JI-projects respectively, it can not
officially approve the project and authorize the project participants of the host country.
The validation did not reveal any information that indicates that the project can be seen as a
diversion of official development assistance (ODA) funding towards Turkey. The project
correctly applies ACM0002 version 06: Consolidated baseline & monitoring methodology
for grid-connected electricity generation from renewable sources. By generating renewable
energy the project will displace fossil fuel based grid electricity. The project results in
reductions of CO2 emissions that are real, measurable and give long-term benefits to the
mitigation of climate change. It is demonstrated that the project is not a likely baseline
scenario. Emission reductions attributable to the project are hence additional to any that
would occur in the absence of the project activity.
The total emission reductions from the project are estimated to be on the average 79,136
tCO2e per year over the first 7-year crediting period.
The emission reduction forecast has been checked, and it is deemed likely that the stated
amount is achieved given that the underlying assumptions do not change. Adequate training
and monitoring procedures have been implemented.
In summary, it is TV Rheinlands opinion that the Anemon Intepe 30.4 MW Wind Farm
Project in Turkey as described in the PDD version 02 of 11 September 2007 meets all
relevant requirements for Voluntary Offset Projects under the Gold Standard and all relevant
host country criteria and correctly applies the baseline and monitoring methodology
ACM0002 version 06. The verifier TV Rheinland thus considers to recommend the
registration of the Anemon Intepe 30.4 MW Wind Farm Project as a Gold Standard VER
project activity after a few corrective action and clarification requests will have been
resolved .

CDM Validation, No. 2007-44002, rev. 01

2 INTRODUCTION
Ecofys BV / OneCarbon has commissioned TV Rheinland to perform a validation of the
Anemon Intepe 30.4 MW Wind Farm Project in Turkey (hereafter called the project).
This report summarises the findings of the validation of the project, performed on the basis of
UNFCCC criteria for the CDM, as well as criteria given to provide for consistent project
operations, monitoring and reporting. UNFCCC criteria refer to Article 12 of the Kyoto
Protocol, the CDM modalities and procedures and the subsequent decisions by the CDM
Executive Board and the requirements for Voluntary Offset Projects under the Gold Standard.

2.1 Objective
The purpose of a validation is to have an independent third party assess the project design. In
particular, the project's baseline, monitoring plan, and the projects compliance with relevant
UNFCCC and host Party criteria are validated in order to confirm that the project design, as
documented, is sound and reasonable and meets the identified criteria. Validation is a
requirement for all CDM projects as well as Voluntary Offset projects under the Gold
Standard and is seen as necessary to provide assurance to stakeholders of the quality of the
project and its intended generation of verified emission reductions (VERs).

2.2 Scope
The validation scope is defined as an independent and objective review of the project design
document (PDD). The PDD is reviewed against the criteria stated in Article 12 of the Kyoto
Protocol, the CDM modalities and procedures as agreed in the Marrakech Accords, the
requirements for Voluntary Offset Projects under the Gold Standard and the relevant
decisions by the CDM Executive Board, including the approved baseline and monitoring
methodology. The validation team has, based on the recommendations in the Validation and
Verification Manual employed a risk-based approach, focusing on the identification of
significant risks for project implementation and the generation of VERs.
The validation is not meant to provide any consulting towards the project participants.
However, stated requests for clarifications and/or corrective actions may have provided input
for improvement of the project design.

3 METHODOLOGY
The validation consists of the following three phases:
I
a desk review of the project design documents
II
follow-up interviews with project stakeholders
III
the resolution of outstanding issues and the issuance of the final validation report and
opinion.

CDM Validation, No. 2007-44002, rev. 01

The following sections outline each step in more detail.

3.1 Desk Review of the Project Design Documentation

The following table outlines the documentation reviewed during the validation:
Ecofys, PDD Anemon Intepe 30.4 MW Wind Farm Project Turkey, Version 01, 29
/1/
May 2007
/2/
Ecofys, Report of the Initial Stakeholder Consultation, Version 01, 10th of April 2007
/3/
/4/

International Emission Trading Association (IETA) & the World Banks Prototype
Carbon Fund (PCF): Validation and Verification Manual. http://www.vvmanual.info
ACM0002 Consolidated methodology for grid-connected electricity generation from
renewable sources version 06 of 19 May 2006.

/5/

Board Decision of Demirer Holding on Consideration of VERs for the Anemon Intepe
Project of ( please clarify the date of the decision see CL1 )

/6/

ENERCON GmbH Aurich, Energy yield estimation of Anemon Intepe, 02.03.2006

/7/

ENERCON GmbH Aurich, Technical Specifications Wind Turbines

/8/

Letter of T. Garanti Bank A.S. of February 16, 2007

/9/

Certificates for participation of training measures of ENERCON

/10/

Training Documents of ENERCON

/11/

Maintenance Manuals of ENERCON

/12/

Layout and Design Documents

/13/

Licence for Anemon Intepe Project

/15/

Monthly Documents of Electricity Production of Anemon Intepe 30.4 MW Wind Farm

/15/

Law on Utilzation of Renewable Energy Resources for the Purpose of Generating

Electrical Energy ( Law No. 5346 ) of 10 May 2005 and actual updates of 2007

/16/

Personnel list of Anemon Intepe 30.4 MW Wind Farm

/17/
/18/

Stakeholder consultation questionnaires

CDM Executive Board: Tool for the demonstration and assessment of additionality,
version 03, EB 29 meeting.

/19/

Revised 2006 IPCC Guidelines for National Greenhouse Gas Inventories

/20/

Turkish Electricity Generation Transmission Statistics ( TEIAS )

CDM Validation, No. 2007-44002, rev. 01

3.2 Follow-up Interviews with Project Stakeholders

Identify any personnel who have been interviewed and/or provided additional information to
the presented documentation.
/1/

Date
2007-06-19

Name
Mr. Ugur Yksel

/2/

2007-06-18

Mr. Sarper Basak

/3/

2007-06-19

Mr. Fatih
Yenign

Organization
Director of Canakkale
Province Provincial
Public Works
Technical Supervisor
Mare Manastir &
Anemon Intepe
Site Manager Anemon
Intepe

/4/

2007-06-19

/6/

2007-06-20

Mr.Muammer
Topcu
Mr. nder
Demirer

Mukhtar of
Kizilcaoren Village
Vice President
Demirer Holding A.S.

/6

2007-06-20

Mr. Salih Uysal

/7/

2007-06-20

Mr. Mjdat
Doganca

/8/

2007-06-18, Mrs. Cagla

2007-06-19, BalciEris
2007-06-20

Board Director
Demirer Holding
A.S.
Commercial Manager
Demirer Holding
A.S.
Commercial
Coordinator Asst.

/9/

2007-06-20

/10/

2007-06-19, Mr. Christian

2007-06-20 Oberbeck

Project Manager
ENERCON GmbH
Bremen

/11/

2007-06-18, Mr. mer

2007-06-19, Akyrek
2007-06-20

Ecofys Trkiye

Mr. Halil
Durutrk

CDM Validation, No. 2007-44002, rev. 01

Technical Manager
ENERCON Servis
Limited Sirketi

Topic
Environmental impacts
Project technology,
operation, maintenance
and monitoring
Project technology,
electrical measurements
and recording
Follow up stakeholder
consultation process
Project background,
project licences, local
content
Project background,
financial issues,
personnel
Project background,
financial issues,
contractors and personnel
Local stakeholder process,
on-site assessments,
background information,
personnel
Project technology,
operation, maintenance
and monitoring
capability, other technical
issues, energy yield
estimation
Project technology,
operation, maintenance
and monitoring
capability.
Baseline determination,
emission reductions
Calculation, emission
reduction monitoring plan,
monitoring plan of
sustainable indicators,
additionality

/12/

05 07 /
2007
05 07 /
2007

Ir. Edwin
Dalenoord.
Mr. Stefan
Leclaire

Ecofys BV

/14/

05 07 /
2007

Mr. Haike van de

Vegte

OneCarbon

/15/

2007-06-19

/16/

2007-06-19

Prof. Dr. Osman

Demircan
Further residents

University of
Canakkale
Follow up stakeholder
of the neighbouring
consultation process
villages
Kizilcaoren,Canakalan,
Denizgrnd

/13/

OneCarbon

Project design, stakeholder

process
Global stakeholder
process, on-site
assessment
Global stakeholder
process, local stakeholder
process,
on-site assessment
Environmental impacts

3.3 Resolution of Outstanding Issues

The objective of this phase of the validation is to resolve any outstanding issues which need
be clarified prior to TV Rheinlands positive conclusion on the project design. In order to
ensure transparency a validation protocol is customised for the project. The protocol shows in
transparent manner criteria (requirements), means of verification and the results from
validating the identified criteria. The validation protocol serves the following purposes:
It organises, details and clarifies the requirements a GS-VER project is expected to meet;
It ensures a transparent validation process where the validator will document how a
particular requirement has been validated and the result of the validation.
The validation protocol consists of two tables. The different columns in these tables are
described in the figure below. The completed validation protocol for the Anemon Intepe 30.4
MW Wind Farm Project in Turkey is enclosed in Appendix A to this report.
Findings established during the validation can either be seen as a non-fulfilment of CDM or
GS-VER criteria or where a risk to the fulfilment of project objectives is identified.
Corrective action requests (CAR) are issued, where:
i)
mistakes have been made with a direct influence on project results;
ii)
CDM / GS-VER and/or methodology specific requirements have not been met; or
iii)
there is a risk that the project would not be accepted as a GS-VER project or that
emission reductions will not be certified.
A request for clarification (CL) may be used where additional information is needed to fully
clarify an issue.

CDM Validation, No. 2007-44002, rev. 01

Validation Protocol Table 1: Mandatory Requirements for CDM Project Activities

Requirement

Reference

Conclusion

The requirements the

project must meet.

Gives reference to the

legislation or
agreement where the
requirement is found.

This is either acceptable based on evidence provided (OK), a

Corrective Action Request (CAR) of risk or non-compliance
with stated requirements or a request for Clarification (CL)
where further clarifications are needed.

Validation Protocol Table 2: Requirement checklist

Checklist Question

Reference

Means of
verification (MoV)

Comment

Draft and/or Final

Conclusion

The various
requirements in Table 2
are linked to checklist
questions the project
should meet. The
checklist is organised in
different sections,
following the logic of the
large-scale PDD
template, version 03 - in
effect as of: 28 July
2006. Each section is
then further sub-divided.

Gives
reference to
documents
where the
answer to
the checklist
question or
item is
found.

Explains how
conformance with
the checklist
question is
investigated.
Examples of means
of verification are
document review
(DR) or interview
(I). N/A means not
applicable.

The section is
used to elaborate
and discuss the
checklist question
and/or the
conformance to
the question. It is
further used to
explain the
conclusions
reached.

This is either acceptable

based on evidence
provided (OK), or a
corrective action request
(CAR) due to noncompliance with the
checklist question (See
below). A request for
clarification (CL) is used
when the validation team
has identified a need for
further clarification.

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

Draft report clarifications
and corrective action
requests

Ref. to checklist
question in table 2

Summary of project
owner response

Validation conclusion

If the conclusions from the

draft Validation are either
a CAR or a CL, these
should be listed in this
section.

Reference to the
checklist question
number in Table 2
where the CAR or CL is
explained.

The responses given by

the project participants
during the
communications with the
validation team should
be summarised in this
section.

This section should summarise

the validation teams
responses and final
conclusions. The conclusions
should also be included in
Table 2, under Final
Conclusion.

Figure 1 Validation protocol tables

CDM Validation, No. 2007-44002, rev. 01

10

3.4 Internal Quality Control

The draft validation report including the initial validation findings is based on the results of
the desk-review, study of background information and the results of the on-site assessment.
Comments from the global stakeholder consultation process were not received. The final
validation report will undergo a technical review before submission to the project participants
and subsequent requesting registration of the project activity with Gold Standard Foundation.
The technical review will be performed by a technical reviewer qualified in accordance with
TV Rheinlands qualification scheme for CDM validation and verification.

3.5 Validation Team

Role/Qualification
CDM validator,
renewable energy
and energy
efficiency expert
Sector expert
GHG senior expert,
Technical reviewer

Last Name
Seidel

First Name

Country

Kurt

Germany

Glombik
Prof. Dr. Schock

Katja
Guenter

Germany
Germany

The CV of each individual validation team member is available upon request.

CDM Validation, No. 2007-44002, rev. 01

11

4 VALIDATION FINDINGS
The main findings of the validation are stated in the following sections. The validation criteria
(requirements), the means of verification and the complete list of results from validating the
identified criteria are documented in more detail in the validation protocol in Appendix A.

4.1 Participation Requirements

Referring to Part A, Annex 1 and 2 of the PDD.
The project participants are Demirer Enerji retim A.S., a Turkish private company and
ADO Enerji A.., another Turkish private company and cooperation partner of Demirer
Enerji retim A.S. The host Party Turkey does not meet the requirements to participate in
the CDM. Therefore no Designated National Authority exist, which can officially authorize
the project participant. The Ministry of Environment and Forestry has designated REC
Turkey as the National Focal Point on UNFCCC Article 6. The CO2 consultant Ecofys has
asked both The Ministry of Environment and Forestry and REC to confirm that the project
assists Turkey in achieving sustainable development. A reply letter from the Ministry of
Environment and Forestry of Turkey, General Directorate Of Environmental Management
was received on 18th of September 2007 which contains a positive comment towards the two
investments, the Mare Manastir project and the Anemon Intepe project. The statement within
the above letter points out, that a request for an official Letter of Endorsement can only be
issued after the adequate infrastructure of a DNA is established. It is deemed reasonable to
close therefore FCAR1 and go ahead with the voluntary offset projects Mare Manastir and
Anemon Intepe as GS-VER projects.
The participating Annex I party is not yet identified at this stage of validation. The DNA of
the Annex I country involved could therefore not yet officially authorize a project participant
The validation did not reveal any information that indicates that the project can be seen as a
diversion of official development assistance (ODA) funding towards Turkey.
CAR1: The mentioned letter of endorsement of REC has to be submitted to the verifier, as
soon it is received by the project proponent. Any Letter of Intent or similar, which indicates,
that a potential VER buyer is in place should also be submitted to the validation team.
FCAR1: A copy of the letter of endorsement of the national focal point of Turkey, which
confirms that the project is voluntary and contributes to the sustainable development has to be
submitted to the validation team as soon as the relevant letter has been received.

4.2 Project Design

Referring to Part A and C of the PDD.
The project involves the development of a 30.4 MW onshore wind farm in the region of
anakkale-Intepe, anakalan-Karacaviran-Kurttepe Region in Turkey. The project is
constructed and operated by Demirer Holding, under the name Anemon Enerji Elektrik
retim Anonim irketi and consists of 38 wind turbines of type E 48 af 800 kW, supplied by
Enercon GmbH.

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12

27 units are installed at an altitude of 65m, 9 units are installed at an altitude of 55m and 2
units are installed at an altitude of 50m. The proposed project activity includes the
construction of 2000 m of new transmission line to establish a connection between the
proposed project and the national grid. The project will be connected to the 154 kV highvoltage transmission lines between the anakkale and Ezine transformer stations. The
Anemon Wind Farm will generate 108 GWh/year which is delivered to the Turkish national
grid. The estimated emission reductions amount to 79,136 tCO2-eq/year.
The projects system boundaries are clearly defined as the Turkish national power grid. The
project started construction on 30 November 2005.
Being a renewable electricity project, the project activity will generate greenhouse gas (GHG)
emission reductions by avoiding CO2 emissions from electricity generation by fossil fuel
power plants. Because of the significant contributions of the project activity to technology
transfer from Germany to Turkey and to the regions sustainable development is the project
activity designed as Voluntary Offset Project under the Gold Standard.
The project owner has seriously considered VERs in the decision to develop the project,
which has been confirmed with relevant documents during the on-site assessment. The
expected operational lifetime of the project activity is 20 years. A renewable crediting period
of 7 years has been chosen for the project, starting from 1 August 2007. The emission
reductions are estimated to be 79,136 tCO2e per year and 553,955 tCO2e over the first sevenyear crediting period.
CL1: Please clarify the date of the Board Decision of Demirer Holding on Consideration of
VERs for the Anemon Intepe Project.
Additional revenues such as emission credits, green certificate, VER certificate were taken
into consideration in the contents of the feasibility studies which were executed before the
construction of the investment projects ( see statement Demirer Holding of 19/07/2007, in the
PDD, annex 10 ) .

4.3 Baseline Determination

Referring to Part B and Annex 3 of the PDD.
The project applies the approved baseline methodology ACM0002 (version 06), titled
Consolidated methodology for grid-connected electricity generation from renewable
sources. The applied baseline methodology is justified as it has been demonstrated that the
project activity ensures that:
It is a grid connected zero emission renewable power generation activity from wind
energy.
The project does not involve switching from fossil fuel to renewable energy at the
project site.
The spatial extent of the project boundary is clearly defined as the site of the project activity
and all power plants connected physically to the Turkish national grid.

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13

The defined project boundary is in line with ACM0002 (version 06). Emission sources and
gases included in the project boundary are:
GHGs involved

Description

Baseline emissions

CO2

Project emissions

N/A

Leakage

N/A

Turkish National Grid

Project emission is regarded as zero as
the project is a renewable energy (wind
source) project.
There are no leakages that need to be
considered in applying this methodology.

In the baseline scenario the electricity delivered from the project activity to the grid would
have been generated by fossil fuels grid-connected power plants and by the addition of new
generation sources. This is reflected in the combined margin (CM) - the weighted average of
the operating margin (OM) emission factor and the build margin (BM) emission factor. The
weighting is set to respectively 75% and 25%, the default values stipulated by ACM0002
version 06 for wind farm projects.
The Turkish National Grid is dominated by fossil fuel-fired power plants ( coal, lignite,
natural gas and fuel oil ). It is deemed likely that these fossil fuel-fired power plants will
continue to dominate the power sector due to the local availability of low-cost coal and
lignite. It is expected that renewable capacity additions will not have significant effects on the
mix of the Turkish National Grid during the first crediting period. The baseline determination
is transparent and reasonable.

4.4 Additionality
Referring to Part B of the PDD.
The additionality of the project has been established using the Tool for the demonstration
and assessment of additionality version 02 approved by the CDM-EB.
Step 1: Identification of the alternatives to the project activity consistent with the current laws
and regulations.
The alternate baseline scenarios for the project activity have been suitably identified as,
a) The proposed project activity not undertaken as a VER project activity;
b) Same amount of electricity produced by other facilities not under the control of project
proponent ( no action from the investors )
The proposed project activity not undertaken as a CDM project activity is not a realistic and
credible alternative, as discussed in the analysis below.

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14

Power plants of the similar installed capacity as the proposed project utilizing renewable
energy such as biomass are not economically attractive due to undeveloped technology status
and the high cost of power generation. Furthermore, the hydro resources are limited and
lacked in this region and are not able to provide a comparable output or the same services as
the proposed project.
The installed capacity of the Turkish National Grid for both the existing power plants and the
power plants to be built in a foreseeable future makes it possible as an alternative to provide
electricity from the grid.
The only realistic and credible alternative for the proposed project is thus the provision of an
equivalent amount of annual power output by the Turkish National Grid.
Step 2: Investment analysis.
As the proposed project generates financial and economic benefits through the sales of
electricity other than VER related income, a simple cost analysis (option I of the
methodology) can not be applied. The alternative for the baseline scenario of the proposed
project is not a similar investment project, so option II is also not an appropriate choice.
Hence, a benchmark analysis (option III of Step 2 of tool for the demonstration and
assessment of additionality) is selected for conducting the investment analysis.
An investor in Turkey will find it impossible to borrow long-term in the Turkish market.
Firstly, there is no domestic supply of long term commercial credit. Secondly, it would be
prohibitively expensive. The current real interest rate on short term debt is more than 12%
( 20 - 25% for short term borrowing, inflation close to 10% ). These points to a discount rate
for long term credit in excess of 12% in real terms in YTL. Also supply of long term
international commercial credit to Turkish debtors is limited.
In Turkey an IRR of 10% for the total investment of a project is regarded as a benchmark for
investments in hydropower plants and fossil fuel fired plants. According to a feasibility study
on wind farms from the Department of Mechanical Engineering, Izmir Institute of
Technology of 18 April 2006 is the required minimum IRR value 15%.
The IRR improves by 0.73 % ( 20 years ) with VER revenues, but is still low ( 2.99 % ). The
VER benefits increases the equity IRR of the project thus providing the project with necessary
financial back-up. Revenues from these Voluntary Emission Reduction Units (VERs )
commercialisation, which are widely nominated in or $, will provide a natural hedge to this
investment. The additional income which will result from the sale of VERs has positively
influenced the bank decision to issue the loan. Since the income from VERs, in Euros
stabilises the income of the project, and consequently reduces the risk of the bank which
issued the loan.
The calculation was performed on the assumption of 20 years operational lifetime with a
constant baseline. The selected crediting period of 7 years can be two times renewed, which
includes also a re-calculation of the baseline. It is expected, that within the next 21 years the
combined margin emission factor will decrease.

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According to the Tool for the Demonstration and Assessment of Additionality (version 03)
is a sensitivity analysis applicable to options II (investment comparison analysis) and and III
(benchmark analysis).
CAR2: A sensitivity analysis has to be performed in order to show that the project activity is
not the most financially attractive option. For this sensitivity analysis has to be taken into
account also the previous revision of the Renewable Energy Law in Turkey ( 18th of April,
2007 ), which guarantees now a higher electricity feed in tariff for 10 years, which was not
known, when the bank decision on the project financing was on the agenda. The financial
spread sheet calculations need to be provided for verification including sensititivity analysis (
including 5% change in PLF ).
A sensitivity analysis, which is considering the impact of changes in the total investment,
annual O&M cost, variations of electricity tariff and annual output on project financial
performance, is not part of the PDD. It would show that when the total investment, electricity
tariff and O&M costs fluctuate within the range of -10% and 10%, that the IRR for total
investment will probably not reach the benchmark.
A sensitivity analysis is performed to demonstrate the effect of the new guaranteed price
(5cent/kWh) on the project IRR of the proposed project. The IRR values for the project in
Table 13 are corrected accordingly to the most up to values of VER revenues.
A reduced sensitivity analysis is performed to demonstrate the effect of the new guaranteed
price (5cent/kWh) on the project IRR of the proposed project. The IRR values for the project
in Table 13 are corrected accordingly to the most up to values of VER revenues. Nevertheless
this reduced sensitivity analysis according to step 5 of additionality tool, version 2 ( impact of
VER registration ) is deemed to be sufficient for the assessment and evaluation of the project
activity. Under these circumstances CAR2 can finally be closed.
Step 3: Barrier analysis.
A barrier analysis has been conducted as supplementary to the investment analysis.
Investment barriers: The investment cost has been higher than originally planned because of
an increase of the cost of the equipment, additional cost for the grid connection. The high
initial investment cost leads to higher investment risk and more difficulties in project
financing. The letter of T. Garanti Bank A.S. of February 16, 2007 is evidence, that the
prospect of generating tradeable Verified Emission Reductions ( VERs ) and the expected
revenues from carbon credits was basis for the positive loan decision of the above bank.
Technological barriers: The 800 kW wind turbines lack operation experience in Turkey. The
project owner lacks skilled labour to operate and maintain the technology, which will lead to a
high risk of equipment disrepair and malfunctioning and other under- performance. Thus
training on required technology for the staffs is carried out during implementation of the
proposed project.

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The proposed project faces a number of market barriers of which the economic
unattractiveness, lack of technical know-how and lack of availability of equipment are the
most important.
One of the advantages of the direct drive design of Enercon, which so far is more or less
exclusively the domain of Enercon is especially for connection to existing grids, that in
general, no flicker problems occur. The direct drive variable speed turbines of Enercon also
allow the grid voltage to be controlled, as the reactive power generation can be varied.
However, none of the barriers mentioned above would prevent the alternative equivalent
capacity or electricity service provided by the Turkish National Power Grid from
implementation.
Step 4: Common practice analysis.
Existing wind farms with installed capacity above 10 MW in Turkey are listed in the common
practice analysis. It shows that earlier wind farms enjoyed a very favourable electricity tariff
( 8.54 $cents/kWh until 2001 ) that is impossible for nowadays wind farm projects. Other
similar wind farms have all applied for VER projects due to the same financial
unattractiveness and investment barrier as the proposed project activity. Therefore the project
activity cannot be said to represent common practice.
In summary, it is sufficiently demonstrated that the project is not a likely a baseline scenario
and that emission reductions occurring from this will hence be additional.

4.5 Monitoring
Referring to Part B and Annex 4 of the PDD.
The project applies the approved monitoring methodology ACM0002 version 06
Consolidated monitoring methodology for zero emissions grid-connected electricity
generation from renewable sources. The selected monitoring methodology is applicable for
the project activity as it involves grid-connected renewable power generation using wind
energy.

4.5.1 Parameters determined ex-ante

The combined margin emission factor is determined ex-ante based on the most recent
information available. More detailed information is provided below.
CL2: It has to be clarified, if meanwhile more updated information is public available from
the Turkish grid operator TEIAS in order to ensure, that the project activity, which is
considered as Gold Standard Project applies the most conservative emission factor in
comparison to standard VER projects in Turkey.

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FCL2: The project proponent is requested to consider the latest public available OM and BM
data provided by TEIA to calculate the most conservative CM.
At the time of the PDD writing the latest publicly available information has been used. This
was the 2005 Statistical yearbook. An official request was send to the Turkish grid operator
TEIA. They replied that According to 5429 numbered Turkish Statistical Act (law) and the
Official Statistical Program, the data that are produced or published by our institution has
gained the official statistics status in 2007. According to the definition of confidential data
and individual data use in the 13th and 14th articles of the mentioned law, the requested
detailed data that belongs to private sector cannot be provided1Therefore, for the generation
plants commissioned in year 2006, only the general data as below can be provided.
After completion of the PDD the 2006 statistical yearbook was published. Based on the
clarification request the emission factor calculations have been updated based on the figures
from the 2006 statistical yearbook. The PDD, version 02 was updated accordingly.
1

Source: Annex D of Ecofyss respond on CARs and CL sent 02/082007

4.5.2 Parameters monitored ex-post

This section shall include an evaluation of the data and parameters that need to be monitored.
The methodology requires monitoring of the following for wind farm projects:
Electricity generation from the proposed project activity;
Data needed to recalculate the operating margin emission factor, if needed, based on the
choice of the method to determine the operating margin (OM), consistent with Consolidated
baseline methodology for grid-connected electricity generation from renewable sources
(ACM0002);
Data needed to recalculate the build margin emission factor, if needed, consistent with
Consolidated baseline methodology for grid-connected electricity generation from renewable
sources (ACM0002);
The operating margin and build margin emission factor are determined ex-ante, therefore the
parameter monitored ex-post is the electricity generation from the proposed project activity.
The net electricity generated from the project will be measured continuously and recorded
monthly. This data will be cross verified against the sales receipt from the grid. A cross-check
during the on-site assessment showed, that the measured and recorded electricity values are
correct and traceable by verifiers.
Other data to be monitored ex-post are the sustainable development indicators. These
indicators are shortly described in table 13 of the PDD.
During the on-site assessment the verifier came to the conclusion, that the project activity has
resulted in more positive effects for sustainable development in the region of the wind power
projects than described in the PDD.

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Such samples are the high local content of sub-contracts during operation and also the mainly
employment of local residents and their further professional education throughout Demirer
Holding with support and long-term commitment of the German manufacturer Enercon. Other
factors not mentioned is the positive effect on tourism and on technology and know how
transfer for visitors from schools and universities.
Especially is the project attracting visitors throughout the widely visible exposure on the hills
near to the strait of the world wide known Dardanelles ( Turkish: anakkale Boaz ), which
connects the Mediterranean Sea with the Black Sea and divides the Balkans (Europe) along
the Gallipoli peninsula from Asia Minor.
CL3: It has to be clarified, how these sustainable indicators can be monitored in practice
( more details on procedures and forms of reporting ).
Based on the clarification request and according to Gold Standard requirements, was decided,
that only the sustainable indicators that score +2 on positive contribution to sustainable
development have to be monitored. Considering this ID2: Air quality and ID3: Other
pollutants will be removed from the monitoring plan in the PDD. The sustainable indicators
ID4: Employment (job quality), ID5: Employment (job number) and ID6: Technological self
reliance will remain in the PDD. For these indicators a simplified monitoring format have
been developed based on the monitoring plan described in the PDD, which results in the
closure of the above clarification request.

4.5.3 Management system and quality assurance

The projects operation and maintenance manual needs to include:
- A description of the responsibilities and authorities for project management,
- Procedures for monitoring and reporting, and QA/QC procedures,
- A description of the installation of metering equipment,
- Procedures for the calibration of metering equipment,
- A description of training and maintenance needs.
These procedures have to be maintained and implemented to enable subsequent verification of
emission reductions.
CL4: It has to be clarified, if detailed procedures have been elaborated and are in place and if
a CO2 consultant will be subcontracted to ensure the data preparation for a smooth
verification execution.
A comprehensive set of procedures was developed by the responsible CO2 consultant One
Carbon, which covers all raised issued to the full satisfaction of the verifier, see validation
protocol for more details. CL4 is therefore resolved and closed.

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4.6 Estimate of GHG Emissions

Referring to part B and Annex 3 of the PDD.
The emission reduction ERy by the project activity during the crediting period is the
difference between baseline emissions (BEy), project emissions (PEy) and emissions due to
leakage (Ly), as follows:
1) Baseline emissions: baseline emissions (BEy in tCO2) are the product of the baseline
emissions factor (EFy in tCO2/MWh) times the electricity supplied by the project activity to
the grid (EGy in MWh).
2) Project emissions: there are no emissions from the project which is a renewable energy
project.
3) Leakage: no leakage has to be considered for the proposed project activity.
4) Emission reduction: ERy= BEy- PEy- Ly= BEy.
For the calculation of the operating margin (OM) emission factor, the simple OM emission
factor calculation method is selected because low cost must run projects constitute less than
50% of the total grid generation and data is not available for applying the dispatch data
analysis.
The aggregated generation and fuel consumption data are used due to the fact that more
disaggregated data are not available in the Turkish National Power Grid.
Country specific data for net calorific value (NCVi) of each type of fossil fuel, the IPCC 2006
default values for the oxidation factor of each type of fossil fuel and the total electricity
delivered to the ECPG are selected and are deemed reasonable.
Vintage data for the years 2002, 2003 and 2004 from Statistical Yearbook 2005 are used for
operating margin calculation. The OM is calculated to be 0.761 tCO2/MWh as a generationweighted average for the three years.
Because plant specific fuel consumption and electricity generation data is not public available
in Turkey, the following approach approved by the CDM Executive Board for such cases deemed to be applicable for this project:
- Use of capacity additions for estimating the build margin emission factor for grid
electricity.
- Use of weights estimated using installed capacity in place of annual electricity generation.
- Use the efficiency level of the best technology commercially available in the National grid
of Turkey, as a conservative proxy, for each fuel type in estimating the fuel consumption to
estimate the build margin (BM).
Following the EBs guidance the build margin is calculated as follows:
- The capacity additions from the years 2003 to 2005 is chosen, which comprise 20% of total
system generation and that have been built most recently was established using public
available data from the official website of the Turkish National Power Grid Company TEIAS.
The referred website www.teias.gov.tr has been accessed on 04/09/2007 by Ecofys / One
Carbon.
- The generation efficiencies per power plant were obtained due to non-availabilty of data per
power plant from the Integral Pollution Prevention and Control ( IPPC ) reference document
on best available techniques for large scale combustion plants as a conservative approach,
since not all power plants reach these efficiencies:

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- For the conversion into t CO2 / GWh were the default emission factors of 2006 IPCC
National GHG inventory applied.
- The EFBM is calculated as 0.649 tCO2/MWh.
The weights OM and BM are selected as 0.75 and 0.25, respectively, as stipulated for wind
project by ACM0002 (version 06). The combined margin of 0.733 tCO2/MWh is fixed exante
for the entire first crediting period.

4.7 Environmental Impacts

Referring to Part D of the PDD.
An Environmental Impact Assessment (EIA) has been conducted on a voluntary basis,
because there is no legal obligation for wind power projects according to the Ministry of
Environment and Forestry of Turkey, see letter of 18/01/2005.
The potential environmental impacts have been sufficiently identified. No significant
environmental impacts are expected from the project activity. The local authorities could
confirm this issue during a visit in June 2007.

4.8 Comments by Local Stakeholders

Referring to Part E of the PDD.
There is no mandatory requirement to conduct a local stakeholder consultation for wind
projects in place in Turkey.
A voluntary stakeholder consultation process has been performed through inviting local
residents to comment on the project activity. A summary and a written report was submitted
to the validation team. In April 2007, the staff from the project owner carried out a survey
through questionnaires on the local residents in the area where the project will be sited. There
were no adverse comments on the project activity and all comments are supportive of the
project which has created new job opportunities in the region including Kizilcaoren Village.
A summary of comments is provided and has been verified by TV Rheinland. Follow-up
interviews of the Mukhtar of Kizilcaoren Village and other local residents were performed
during the on-site assessments. During the visit the residents expressed all positive opinions
about the project with the employment opportunities for the region, which are not so manifold
with local agriculture and forestry in the villages and tourism in the cities. The Mukhtar of
Kizilcaoren Village introduced some further demand with regard to voluntary commitments
of the project proponent to Kizilcaoren Village. No final decision on these issues was taken
during the on-site assessment.

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CL5: It has to be clarified, which additional community benefits were offered to the residents
of Kizilcaoren Village and if during the main stakeholder consultation and global stakeholder
consultation period further comments have been received.
The project did not receive any negative comment. The project developer is offering
additional community benefits with exemplary character, which is further explained within
the report of the main consultation and in the validation protocol.
CAR2 The output of the main consultation with a overall duration of 60 days, which is a
report including all written and oral comments given as well as the argumentation on whether
or not the comments are taken into account, has to be submitted to the validation team.
The report of the main consultation was completed on 12th of September 2007.

4.9 Comments by Parties, Stakeholders and NGOs

The PDD; Version 01 of 09 May 2007 was made publicly available on TV Rheinlands
website (http://www.tuv.com/de/en/mare_manastir_wind_farm.html)and Parties, stakeholders
and NGOs were through the website invited to provide comments during a 30 days period
from 24 May to 23 June 2007. No comment was received during this period.
CL5: It has to be clarified, which other publications (on websites, etc.) and media
( newspapers, etc. ) were used in Turkey during the main stakeholder consultation and global
stakeholder consultation period.
For the Main Stakeholder Consultation requests have been made to WWF Turkey and
Greenpeace Turkey to publish the Anemon PDD on their websites. Both these organisations
are supports of the Gold Standard.
However no response from both organisations has been received and the PDD was not
published on their website.
Furthermore for the Initial Stakeholder consultations invitations were sent via e-mail by
Demirer Holding (23/03/2007). An advertisement was placed in Olay and Boaz (daily local /
regional newspaper) on 22 March 2007. News regarding the meeting was published in
Kalem (daily local newspaper) on the day of the meeting (10 April 2007) (Section G.1 of
the PDD).

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Comment by:
Accredited NGO
Inserted on:
Subject:

Party

Stakeholder

Comment: No comments were received during the above global stakeholder consultation
process.

How has considered the comment received in its validation:

A description of how the has taken due account of the comment received.
N/A

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