VALIDATION REPORT

Kipeto Wind Energy Project in Kenya

12 December, 2012

Japan Consulting Institute

REPORT NO. JCI-CDM-VAL-11/183
REVISION NO. 00

JCI CDM Center

Abbreviations

Add Tool

The approved consolidated baseline and monitoring methodology ACM0002 - Consolidated

baseline methodology for grid-connected electricity generation from renewable sources;
version 13.0.0
Tool for the demonstration and assessment of additionality (Version 06.1.0)

BM

Build Margin

CAR

Corrective Action Request

Carbon Africa

Carbon Africa Limited

CDM

Clean Development Mechanism

CERs

Certified Emission Reductions

CL

Clarification Request

CM

Combined Margin

CO2

Carbon dioxide

CO2e

Carbon dioxide equivalent

DNA

Designated National Authority

DOE

Designated Operation Entity

EB

Executive Board

ESIA

Environmental and Social Impact Assessment

Emission Tool

Tool to calculate the emission factor for an electricity system (Version 02.2.1)

ERPA

Emission Reduction Purchase Agreement

ERs

Emissions Reductions

FAR

Forward Action Request

Galetech

Galetech Energy Developments

GHG

Greenhouse Gas

JCI

Japan Consulting Institute

Kenya

Republic of Kenya

Kipeto Energy

Kipeto Energy Limited

KP

Kyoto Protocol

KPLC

Kenya Power and Lighting Company Limited

Kurrent

Kurrent Technologies Limited.

LoA

Letter of Approval

MP

Monitoring Plan

NEMA

National Environment Management Authority

OM

Operating Margin

PDD

Project Design Document

UNFCCC

United Nations Framework Convention on Climate Change

VVS

CDM Validation and Verification Standard

ACM0002

JCI CDM Center

CONTENT
I.

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

II.

INTRODUCTION OF VALIDATION ............................................................................................. 5

1.
2.
3.

Objective of CDM validation ...........................................................................................................5

Validation approach .........................................................................................................................6
Means of validation ..........................................................................................................................6
3.1 Corrective action requests, clarification requests and forward action requests ...........................6
4. Global Stakeholder Consultation......................................................................................................7
III.

1.
2.
3.
4.
5.
IV.

1.
2.
3.
4.
5.

6.

7.

8.
9.

VALIDATION WORK ................................................................................................................. 9

Validation Team ...............................................................................................................................9

Appointment certificate of the DOEs validation team member ....................................................10
Quality Control within the team of the validation process .............................................................10
Desk Review ..................................................................................................................................10
Follow-up actions (Interviews with relevant stakeholders in the host country) .............................14
VALIDATION FINDINGS ........................................................................................................ 15

Approval and authorization ............................................................................................................15

Modalities of Communication ........................................................................................................17
Project Design Document...............................................................................................................17
Description of project activity ........................................................................................................17
Application of the selected baseline and monitoring methodology ...............................................18
5.1 Applicability of the selected baseline and monitoring methodology to the project activity .....18
5.2 Project boundary........................................................................................................................20
5.3 Baseline scenario identification and description .......................................................................21
5.4 Algorithms and/or formulae used to determine emission reductions ........................................22
Additionality of project activity .....................................................................................................24
6.1 Assessment of prior consideration of the clean development mechanism ................................24
6.2 Identification of alternatives ......................................................................................................26
6.3 Investment analysis ...................................................................................................................27
6.4 Barrier analysis ..........................................................................................................................32
6.5 Common practice analysis.........................................................................................................32
6.6 Conclusion of assessment of additionality ................................................................................33
Monitoring plan ..............................................................................................................................34
7.1 Compliance with the requirements of the methodology ...........................................................34
7.2 The steps for monitoring arrangements ....................................................................................34
7.3 JCIs opinion on monitoring plan .............................................................................................35
Environmental impacts ...................................................................................................................35
Local stakeholder consultation .......................................................................................................35

Appendix A: Validation Protocol

Appendix B: Certificate of Appointment of Validation Team

JCI CDM Center

I.

EXECUTIVE SUMMARY - VALIDATION OPINION

Japan Consulting Institute (JCI) has performed a validation of the Kipeto Wind Energy Project. The
validation was performed on the basis of UNFCCC criteria for the Clean Development Mechanism and
host country criteria, as well as criteria given to provide for consistent project operations, monitoring and
reporting.
The review of the project design documentation and the subsequent follow-up interviews have
provided JCI with sufficient evidence to determine the fulfilment of stated criteria.
The PDD reports only the host country and then the project is a unilateral project.
The host country is the Republic of Kenya that fulfils the participation criteria and has approved the
project and authorized the project participants. The DNA from the Republic of Kenya confirmed that the
project assists in achieving sustainable development.
The project correctly applies the approved consolidated baseline and monitoring methodology
ACM0002 - Consolidated baseline methodology for grid-connected electricity generation from renewable
sources; version 13.0.0 and referenced Tool to calculate the emission factor for an electricity system
(Version 02.2.1)
JCI provides the validation opinion that the all of coverage for the project components or issues are
deemed being validated through the validation process.
The total emission reductions from the project are estimated to be on the average 254,125 tCO2e per
year over the selected 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 will be planned before commissioning of the project activity featuring the
contracted CDM consultant and monitoring procedures will appropriately established for implementation.
In summary, it is JCIs validation conclusion that the Kipeto Wind Energy Project as described in
the PDD version 03 dated 12/12/2012 /2/ meets all relevant UNFCCC requirements for the CDM and all
relevant host country criteria and correctly applies the ACM0002 version 13.0.0.
JCI thus provides a positive validation opinion and requests for the registration of the proposed
project as a CDM project activity.

II. INTRODUCTION OF VALIDATION

Kipeto Energy Limited has commissioned JCI to perform the validation of the Kipeto Wind Energy
Project (hereafter called the project).
This report summarises the findings of the validation of the project, performed on the basis of CDM
VVS version 03.0, and related 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.

1. Objective of CDM validation

The objective of the validation is to have an independent assessment of proposed project activities
against the applicable CDM requirements as set out in decision 3/CMP.1, its annex and relevant decisions
of the COP/MOP, on the basis of the project design document.
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.

JCI CDM Center

Validation is a requirement for all CDM projects and is seen as necessary to provide assurance to
stakeholders of the quality of the project and its intended generation of certified emission reductions
(CERs).

2. Validationapproach
The validation approach is to determine whether the proposed project activity complies with the
requirements of paragraph 37 of the CDM M&Ps, the applicability conditions of the selected
methodology and guidance issued by the Board and to assess the claims and assumptions made in the
PDD.
The validation is not meant to provide any consultancy towards the project participants.
However, stated requests for clarifications and/or corrective actions may have provided input for
improvement of the project design.

3. Means of validation
JCI applies the means of validation specified throughout the VVS and where appropriate standard
auditing techniques, including, but not limited to:
(a) Document review, involving:
(i) A review of data and information;
(ii) Cross checks between information provided in the PDD and information from sources other
than those used, if available, the DOEs sectoral or local expertise and, if necessary, independent
background investigations.
(b) Follow-up actions (e.g. on-site visit and telephone or email interviews), including:
(i) Interviews with relevant stakeholders in the host country, personnel with knowledge of the
project design and implementation;
(ii) Cross checks between information provided by interviewed personnel (i.e. by checking sources
or other interviews) to ensure that no relevant information has been omitted.
(c) Reference to available information relating to projects or technologies similar to the proposed
CDM project activity registered and under validation; and
(d) Review, based on the approved methodology being applied, of the appropriateness of formulae and
correctness of calculations.

3.1 Corrective action requests, clarification requests and forward action requests
If, during the validation of a project activity, JCI identifies issues that need to be further elaborated
upon, researched or added to in order to confirm that the project activity meets the CDM requirements
and can achieve credible emission reductions, JCI shall ensure that these issues are correctly identified,
discussed and concluded in the validation report.
JCI shall raise a corrective action request (CAR) if one of the following occurs:
(a) The project participants have made mistakes that will influence the ability of the project
activity to achieve real, measurable additional emission reductions;
(b) The CDM requirements have not been met;
(c) There is a risk that emission reductions cannot be monitored or calculated.
JCI shall raise a clarification request (CL) if information is insufficient or not clear enough to
determine whether the applicable CDM requirements have been met.
JCI shall raise a forward action request (FAR) during validation to highlight issues related to project
implementation that require review during the first verification of the project activity. FARs shall not
relate to the CDM requirements for registration.

JCI CDM Center

JCI shall resolve or close out CARs and CLs only if the project participants modify the project
design, rectify the PDD or provide adequate additional explanations or evidence that satisfies the DOEs
concerns. If this is not done, the DOE shall not recommend the project activity for registration to the
CDM Executive Board.
JCI shall report on all CARs, CLs and FARs in its validation report. This reporting shall be
undertaken in a transparent and unambiguous manner that allows the reader to understand the nature of
the issue raised, the nature of the responses provided by the project participants, the means of validation
of such responses and clear reference to any resulting changes in the PDD or supporting annexes.
The validation protocol consists of two tables. The different columns in these tables are described as
followings:
Validation protocol tables
Table 1: Requirements checklist
Requirement (Checklist Question) :
The various requirements in Table 1 are checklist questions the project should meet. The checklist is
organised in different sections, following the logic of the latest VVS, the PDD Guidelines and the largescale PDD template, version 04.1- in effect as of:11 April 2012. Each section is then further sub-divided.
Reference :
Gives reference to documents where the checklist question or item is found. Paragraph No. of VVS is
referred.
Check Comment :
The column is used to elaborate and discuss the checklist question and/or the conformance to the
question.
ID No. of CAR, CL and FAR :
ID No. of CAR, CL and FAR is described.
Corrective Action Request (CAR) is used due to non-compliance with the checklist question.
Clarification Request (CL) is used when the validation team has identified a need for further
clarification.
Forward Action Request (FAR) is used to highlight issues related to project implementation that
require review during the first verification of the project activity.
Table 2: Resolution of Corrective Actions, Clarification Requests and Forward Action Requests
Clarifications and corrective action requests :
If the conclusions from the draft Validation are a CAR, a CL or a FAR, these should be listed in this
section.
Ref. to checklist question in Table1 :
Reference to the checklist question number in Table1 where the CAR, CL or FAR is explained.
Summary of project owner response :
The responses given by the project participants during the communications with the validation team
should be summarised in this section.
Validation team conclusion :
This section should summarise the validation teams responses and final conclusions.

The completed validation protocol for Kipeto Wind Energy Project is enclosed in Appendix A to
this report.

4. Global Stakeholder Consultation

JCI made the PDD version 01 /1/ of 05 June 2012 of the project activity under consideration publicly
available on UNFCCC website and Parties, stakeholders and NGOs were through the CDM website
invited to provide comments during a 30 days period from 08 June 2012 to 07 July 2012.
As a result of consultation, the following comment has been received during above 30 days period. This
comment showed the personal information of the submitters then JCI judged the comment was effective
and comply with the CDM requirement to take account as official comment.

JCI CDM Center

JCI have discussed with the project participants regarding this comments. JCI concluded that some
description in the PDD will be revised to make easy understanding for readers and that the Ministry of
Energy has approved the project implementation of Kipeto Energy.
Secretariat of UNFCCC
Name
Department
Phone
Fax
E-Mail
Your reference

Dr. Hans-Jurgen Mielisch

International Climate Projects/Project Development
+4972 1 63 -231 10
+4972163- 23 119
h.mielisch@enbw.com
HJM

KIPETO WIND ENERGY PROJECT, KENYA, COMPLETION DATE POD 05.06.2012

June 26, 2012

Dear Madam / Sir,

We comment on the above mentioned POD as follows.
1. We seriously doubt that the project area marked by the coordinates as per page 5 of the above
mentioned POD is completely leased and thereby secured by the project applicant. Since we have through our project company Esikipeto Power Generation Limited- signed and registered a
substantial amount of land lease contracts within the project area, claimed to be solely secured by
Kipeto Energy Limited for wind farming
2. We want to point out that the project area defined by Figure 2 on page 4/5 and the coordinates
given in table 1 on page 5 do not reflect the same area. The difference is considerable and is
misleading.
3. We emphasize on verifying in particular the land lease contracts for the project area The DOE
must ensure that the land lease contracts for the project area [as described and on which the
turbines, substation and project roads are located] is secured by valid land lease agreements, which
are registered at the land registrar's office as part of the Kenyan Ministry of Lands for Kipeto
Energy Limited.
4. We request the DOE to ensure that the coordinates of the turbines, substation and project roads
as per the POD are located on a property for which a properly signed and registered land lease
contract on behalf of the applying project company [Kipeto Energy Limited] exists.
5. Due to the questionable secured project area, it is also our understanding that the affected
environmental issues have to be looked at closely. With regard to the Environmental Impact
Assessment [EIA] / Environmental and Social Impact Assessment [ESIA] it must be taken into
account that only part of the claimed secured project area is actually secured by Kipeto Energy
Limited. Therefore, just the actual secured areas can be accounted for environmental studies. This
refers especially to studies on migrating birds, bats, bird flyways and affected wildlife breeding.
6 We have noticed that the EIA License has not been granted.
Yours sincerely
Dr. Hans-Jurgen Mielisch
Senior Manager International Climate Projects
Cc.
Mr. Harris Horn
Windgen Venture Ltd.
P.O. Box 25128
00603 Nairobi,
Kenya

JCI CDM Center

JCI undertook the following process to validate the comment;

Process:

Document review, follow-up action (on-site visit, interviews), etc.

Follow-up action; Observation/inspection of the physical site during on-site visit and interviews
with the project participants, Ministry of Energy and Kenyan DNA
Document review: Wind report, ESIA report, technical specifications, design data/drawings, the
letter issued by Ministry of Energy.
Regarding the comment the project owner has submitted the following clarification /75/ to JCI as
DOE.
1. Kipeto Energy Limited is holding the sole rights to develop a wind power plant in the
proposed area and evidenced by the letter from the Ministry of Energy. Kipeto Energy has
secured almost all parcels relevant for the development of the wind power plant (turbines,
substation, roads etc.) in the project boundary. Agreements for a few parcels are still
undergoing negotiation and are expected to be finalized soon. However, Kipeto Energy has not
leased all land in the project boundary assigned to it by the Ministry of Energy as some of
them are not required to develop the wind power plant. Some parcels in the project area might
be leased by Esikipeto Power who has however no rights to develop a wind power plant on
those parcels. Kipeto Energy has made all land lease agreements and related coordinates for
turbines and power plant equipment available to DOE.
2. The figure of the project boundary included in the PDD has been updated in version 02 of the
PDD.
3. And 4. See answer 1.
4. Kipeto Energy has been granted the sole rights to develop a wind power plant in the area as
indicated by the letter from the Ministry of Energy. The Environmental and Social Impact
Assessment has therefore been carried out for the whole project area as it is not feasible to
limit an environmental study to certain land parcels.
5. The EIA license was granted on 30 July 2012 by NEMA.
JCI has conducted interviews with Ministry of Energy and NEMA during on-site assessment and
confirmed that both Governmental Organizations have justified the adequate process of the project
development in accordance with Governmental regulations. And JCI confirmed the letter issued by
Ministry of Energy that Kipeto Energy Limited has already been granted the sole rights in the relevant
area. JCI have confirmed by interview with NEMA that the EIA license has been issued already and the
LoA as CDM project was under processed and would be issued soon. The LoA has issued on 03/09/2012.
From above information JCI concluded that the proposed project could be credible and applicable as
CDM project. The PDD has been revised the project area map in A.2.4.

III. VALIDATION WORK

JCI carried out the validation work to ensure that the project activity complies with the requirements
of paragraph 37 of the CDM modalities and procedures.

1. Validation Team
Details of the validation team are shown in below Table.
Role/Qualification

All relevant issues /

Team Leader

Qualified Technical Areas

related to the Project

Name

Takayuki ABE

Wind power (TA1.2)

On-site Visit

JCI CDM Center

CDM auditor /
Team Member

Moritaka KATO

Wind power (TA1.2)

Details of the technical reviewer are shown in below Table.

Name
Masatoshi SHIBATA

Qualified Technical Areas related to the Project

Wind power (TA1.2)

2. Appointment certificate of the DOEs validation team member

The certificate of appointment of validation team member is attached in Appendix B to this report.

3. Quality Control within the team of the validation process

The validation report worked out by the team underwent an internal review process for the assurance
of being in compliance with the applicable requirement of the latest version of VVS.
JCI applies internally established Quality Management Program for the required review process,
which is defined as follows;
1) Internal Review for the interim check by the internal audit team and the technical reviewer
2) The evaluation of the validation work in the CDM evaluation committee consists of outside
experts
3) Internal review for the final check by the internal audit team and the technical reviewer
The review and evaluation including the technical review are implemented for every validation work
by the competent personnel assigned in accordance with JCIs qualification scheme for CDM validation
and verification.

4. Desk Review
Document review, involving:
(i) Review of data and information to verify the correctness, credibility and interpretation of
presented information;
(ii) Cross checks between information provided in the PDD and information from sources other
than that used, if available, and if necessary independent background investigations
Thefollowingtableoutlinesthedocumentationreviewedduringthevalidation:

Documents list
No.

Title

PDD, IRR Spreadsheet, F/S Report, EIA Report

/1/

PDD of Kipeto Wind Energy Project, Version 01, 05/06/2012 (for GSC)

/2/

PDD of Kipeto Wind Energy Project, Version 03, 12/12/2012

/3/

CDM Financial Model (Spread Sheet) of Kipeto Wind Energy Project, Version 03.2

/4/

Emission reduction Calculation (Spread Sheet) of Kipeto Wind Energy Project, Version 01 and
Version 3.3

/5/

Wind Report, by Galetech, 09/2011

/6/

Updated Wind Report, by Galetech, 07/2012

/7/

Electricity Generation Calculation Sheet, by Carbon Africa, 11/07/2012

10

JCI CDM Center

/8/
/9/

Environment Impact Assessment Study Report for Kipeto Wind Energy Project (ESIA Report),
by Kurrent, 03/2012
Technical Description Report, by Galetech, 09/2011, 28/02/2012

Feasibility Study for Grid Connection of Kipeto Wind Power Project, by GIBB International,
05/2012
Letter of Approval
/10/

/11/

Letter of Approval by Kenya DNA (NEMA), 03/09/2012

/12/

EIA Approval, by NEMA, 22/05/2012

/13/

Certificate of Incorporation for Kipeto Energy Limited, 04/06/2010

/14/

Project Approval Letter, by Ministry of Energy, 04/06/2012

/15/

MoC of Kipeto Wind Energy Project, by Kipeto Energy Limited, 18/09/2012

/16/

EIA License, by NEMA, 30/07/2012

/17/

Letter on Expression of Interest to construct a 100 Megawatt Wind Farm, by Craftskills,

10/06/2009

/17a/

Letter on Expression of Interest to construct a 100 Megawatt Wind Farm, by Ministry of

Energy, 12/08/2009

/18/

Letter on Development of Wind Farm in Kipeto, by Ministry of Energy, 14/04/2011

/19/

Letter on Expression of Interest to construct a 100 Megawatt Wind Farm, by Ministry of

Energy, 26/09/2012

Contracts, Agreements, Quotation

/21/

CDM Consultancy Contract between Kipeto Energy and Carbon Africa, 09/12/2011

/22/

/25/

Joint Development Agreement between General Electric and Craftskills, 04/02/2011

Budgetary estimate for the KIPETO Wind Farm (47xGE1.6-100+16xGE1.6-82.5), by GE
Energy, 01/09/2011
Budgetary estimate for the KIPETO Wind Farm of Full Service Agrement, by GE Energy,
01/09/2011
EPC Cost Estimates, by Galetech, 03/09/2011

/26/

Land lease Agreements, 09/09/2011

/23/
/24/

Documentary Evidence, Records

/31/

Resolution of Board of Directors to decide Project development and CDM application of

Kipeto Wind Energy Project, 08/09/2011

/32/

Notification to NEMA for CDM Prior Consideration, by GE Energy, 14/06/2011

/33/

Notification to UNFCCC for CDM Prior Consideration, by GE Energy,

06/06/2011(submission) 14/06/2012 (published)

/34/

NEMA web site of 07/04/2012, Project List for prior consideration projects

/35/

Confirmation of NEMA receipt of LoA application from Carbon Africa, 11/05/2012

/36/

1.6-82.5 Wind Turbine Fact Sheet, By GE Energy

/36a/

GEs 1.6-82.5 Wind Turbine, By GE Energy

/37/

1.6-100 Wind Turbine Fact Sheet, By GE Energy

/37a/

Introducing GEs 1.6-100 Wind Turbine, By GE Energy

11

JCI CDM Center

/38/

Invitation Letter to Local Stakeholder Consultation Meeting, by Kipeto Energy

/39/

Publish on Newspaper of Local Stakeholder Consultation, by Kipeto Energy

/40/

Report on the CDM Local Stakeholder Consultation, by Kipeto Energy, 06/02/2012

/41/

Attendant List of the CDM Local Stakeholder Consultation

/42/

Monetary Policy Statement, by Central Bank of Kenya, June 2011,

/43/

Economic Projections of Federal Reserve Board Members and Federal Reserve Bank Presidents, by USFed, April 2011

/44/

GHG Market Sentiment Survey, by International Emissions Trading Association, 2011

/45/

Evaluation Form (Questionnaire and Answer), Kipeto Energy, 06/02/2012

/46/

Confirmation of model input for finance analysis by Standard Bank, 12/07/2011

/47/

Kipeto Project Description, Kipeto Energy

/48/

Galtech Company Profile

/49/

On-site summary report of DOE, JCI, 18/07/2012

Methodology, Tools, Guidance, Guidelines and Manual of UNFCCC

/51/

The approved consolidated baseline and monitoring methodology ACM0002 - Consolidated

baseline methodology for grid-connected electricity generation from renewable sources;
version 13.0.0

/52/

Tool to calculate the emission factor for an electricity system (Version 02.2.1)

/53/

Tool for the demonstration and assessment of additionality (Version 06.1.0)

/54/

Guideline for completing the project design document form (Version 01.0)

/55/

Guidelines on the assessment of investment analysis (Version 05.0)

/57/

Glossary of CDM terms (Version 07.0)

/58/

CDM validation and verification standard (Version 03.0)

/59/

Guidelines for the reporting and validation of plant load factors (Version 01.0)

/60/

Tool to determine the remaining lifetime of equipment (Version 01)

/61/

Modalities and procedures for a clean development mechanism, as defined in Article 12 of the
Kyoto Protocol

/62/

Procedures for processing and reporting on validation of CDM project activities (Version 01.0)

Drawings
/71/

Single Line Diagram, by Galetech, 06/07/2012

/72/

Preliminary Design for Kipeto Substation, by GIBB Africa, 05/2012

/73/

Preliminary Design for Transmission Line, by GIBB Africa, 05/2012

/74/

Preliminary Transmission Line Route

/75/

Explanation regarding Project development, Kipeto Energy, 25/08/2012

/76/

Land Status Map, by Galetech, 09/2012

/77/

Kipeto development Cost, Kipeto Energy, 10/2012

General Local References

/81/

Annual Report & Financial Statements, by KPLC, 2010/2011

12

JCI CDM Center

/82/

Updated Least Cost Power Development Plan, by Ministry of Energy, 03/2011

/83/

Kenya Vision 2030, by Government of the Republic of Kenya, 2007

/84/

The Energy Act, Approval of Schedule of Tariff for Supply of Electricity by KPLC, 2006

/85/

Feed-In-Tariff Policy (1st revision), by Ministry of Energy, 01/2010

/86/

KenGen web site, http://www.kengen.co.ke,

/87/

Kenya Electricity Grid Code, by Energy Regulation Commission, 03/2008

/88/

Power System Operation Statistics for 7 years (2004 to 2010), by KPCL, 22/08/2011

/89/

The Environmental (Impact Assessment and Audit) Regulations, 2003

/90/

The Income Tax Act, 2010

/90a/

Income Tax at a Glance, by Kenya Revenue Authority, 2011- 2012

/91/

The Electricity Power Act, by Government of the Republic of Kenya, 1997

/92/

The Energy Act, by Government of the Republic of Kenya, 2006

/93/

Guide for Investors regarding Feed-in-Tariffs, by Ministry of Energy, 05/2008

/94/

Act No.8 of 1999 Environmental Management and Co-ordination Act

/95/

Inflation Adjustment by KPMG, 03/17/2012

/96/

The Economics of Wind Energy, by European Wind Energy Association, 03/2009

Main changes in the PDDs between the version published for the 30 days stakeholder commenting
period and the final version submitted for registration:
Table 3 Major Changes in the Content of the PDDs.
Subject and section
in the PDD

Original content in the

PDD version 01 /1/

Revised content in the

PDD version 03 /2/

Issued CAR or CL.

Relevant methodology,
tool, guidance, or
guidelines applied.

Project area map, A.2.4

Only Kenya map

Kenya map and Project are

map

Guidance for Project

Design Document
(CDM-PDD)

Project description, A.3

Original plant design

(base condition for the
proposed project)

Original plant design (base

condition for the proposed
project) and alternative
layout

Project investment and

CDM application have
been decided based on
the original plant design.
The alternative layout
has added to explain
actual plant design and to
confirm no change of
additionality.

Project timetable, B.5

Lack of major events

related to CDM activity
Without CDM = 13.17 %
With CDM = 19.88 %

Additions of major events

related to CDM activity
Without CDM = 14.41%
With CDM = 20.75%

The similar project has

listed up unit by unit.

The similar project has

listed up project by project.

Equity IRR, B.5

Common practice
analysis, B.5

13

Check results of
calculation spread sheet
CL-21

JCI CDM Center

Emission Factor, B.6

OM = 0.66
BM = 0.49
CM = 0.62

OM = 0.6613
BM = 0.4928
CM = 0.6213

CL-28

Emission reduction

253,469 tCO2/year

254,125 tCO2/year

CL-28

Sketch diagram for

monitoring plan, B.7.

Not provided.

Provided.

CL-22

5. Follow-up actions (Interviews with relevant stakeholders in the host

country)
The on-site visit and interviews with project stakeholders were held from 16 to 18 July 2012 at the
project site in the Republic of Kenya.
The names of interviewees are listed as follows
Table 4 List of interviewees
No.
/101/

Date
16/07/201

Name

Organization

Dr. Kenneth Namunje

Mr. George Njenga
Mr. Simon M. Guyo
Ms. Joyce Kimani
Ms. Juliana Kainga
Mr. Willy Ireri

Kipeto Energy

GE Energy

/102/

16/07/2012

Mr. Adriaan Tas

Mr. Carsten Jung

Carbon Africa

/103/

16/07/2012

Mr. Sanjay Gandhi

Kurrent

/104/

16 & 18
/07/2012

Mr. Herman Busschots

Mr. Cormac Philips

Galetech

/105/

16/07/2012

Eng. Isaac N. Kiva

Ministry of
Energy

/106/

17/07/2012

Mr. Mwangi Kahiro

District Commissioner
Pasture

Mr. Wilson Saitaga

Mr. Ezekiel Nkanoni
Mr. Simon Somoine,
Ms. Parsimari Rorua
Mr. Kuya Koitee
Mr. Simangua Ngukuu
Mr. Noah Lantei
Mr. Kuyaa Sankaire

14

Topics
Interview with Project Owner
Outline of the Company
Outline of the project
Confirmation of the following major
items
Timeline, Serious consideration,
Executive Board, Monitoring , etc.
Interview with the PDD Author
Discussion on Initial Findings
Project timeline
Document list
Interview with the EIA Author
Preparation of EIA Report
Environmental Issue of the Project
Interview with FS Report Author
Design base of the project
Investment estimation
Financial Analysis
Organization of O&M
Interview with Ministry of Energy
Energy policy of Kenya
Project approval
Interview with Local Residents
Consultation with stakeholders
Comments on the project
Environmental or ecological issues
Future concerns

JCI CDM Center

/107/

18/07/2012

/108/

18/07/2012

Mr. Lesicar Lantei

Mr. John Sironka
Mr. Mayon Turume
Mr. Moses Kiria
Mr. Nashar Toimasi
Mr. Kudate Nkurayia
Mr. Mukue Pulei
Ms. Naomi Letuya
Mr. Sammy Muita

Ms. Anne N Omambia

Ms. Wilkister Magangi

KPLC

NEMA

Interview with the Power Grid

Operation
Electricity Supply in Kenya
Electricity Meter of the Project
Electricity Tariff
Interview with NEMA
Environmental Issue of Wind Farm
Approval of ESIA Report

IV. VALIDATION FINDINGS

The findings of the validation are stated in the following sections. The validation criteria
(requirements), the means of verification and the results from validating the identified criteria are
documented in more detail in the validation protocol in Appendix A.
The final validation findings relate to the project design as documented and described in the revised
and resubmitted project design documentation.
Findings issued through the validation
JCI issued the four (4) CARs, thirty one (31) CLs and one (1) FAR as shown in the Validation
Protocol, Appendix A of this report. All the four CARs and thirty one CLs were resolved and then closed
as shown in the Table 2 of the Appendix A. One FAR has been remained as not closed and will be cleared
until the starting operation of the project.
Major issues and its resolution process through the CARs and CLs are described in following items
according to VVS /58/.

1. Approval and authorization

1) Approval
The project is without an Annex I Party being involved at the stage of registration request (unilateral
project). The PDD reports only host Party in A.4.
JCI has received the Letter of Approval from Kenya /11/ as host Party through the project participant
and the PDD author, who were Kipeto Energy and Carbon Africa. Kipeto Energy as project participant
which was clearly referenced by the letter itself and all supporting documentations;

DNA of Kenya issued the LoA dated on 03/09/2012.

JCI has confirmed the approval of the project activity with the interview with NEMA which was the
DNA of Kenya. Then the LoA is authentic. JCI has concluded that the LoA confirmed the followings;
1)
2)
3)
4)

DNA of Kenya approved the Kipeto Wind Energy Project of Kipeto Energy Limited.
The Republic of Kenya has ratified the Kyoto Protocol.
Participation is voluntary.
The proposed CDM project activity contributes to the sustainable development of the Republic of
Kenya.

15

JCI CDM Center

5) The LoA refers to the precise proposed CDM project activity title in the PDD being submitted for
registration.
6) The DNA of Kenya issued the LoA to Kipeto Energy Limited.
There found no indication during the validation process that the project uses the official development
assistance funding for Kenya.
JCI concludes that the LoA is credible and fully comply with the requirements by the CDM.

2) Authorization
JCI confirmed that the project participant is Kipeto Energy Limited of Republic of Kenya as being listed
in the table of section A.4 in the PDD /2/, and also confirmed that this information was consistent with the
contact details provided in Annex 1 of the PDD /2/. It is also confirmed that no entities other than this
entity approved as project participants are included in these sections of the PDD /2/.
As described above, the project participants are authorized with the LoA issued by the DNA of
Republic of Kenya as a voluntary participant to the project activity.

3) Contribution to sustainable development

The PDD /2/ states the following points of contribution to the Kenyas sustainable development.
The project is expected to provide reliable electricity to the national electricity system. This is in
line with Kenyas Vision 2030, which recognizes reliable and cheap energy as one of the
foundations for economic growth and essential for making Kenya a middle-income country by
2030.
The project is expected to provide local employment opportunities during the construction and
operation phase.
The project is expected to contribute to Kenyas fiscal revenues through payment of taxes, and
attract foreign direct investment.
The project will improve the hydrocarbon trade balance through reduction of oil imports used for
electricity generation.
The project will have a positive impact on the transfer of wind energy technology to Kenya, as
well as know-how skills of local workers. The transfer of technology and know-how will be
directly replicable to other future wind energy projects.
The project will reduce the consumer price of electricity: In line with the 2008 Schedule of
Tariffs for Supply of Electricity by the Kenya Power and Lighting Company Limited, all
electricity tariffs in Kenya are liable to a Fuel Cost Charge, which is calculated monthly and
published in the Kenya Gazette. The Fuel Cost Charge is transferred directly to the consumer and
depends directly on the specific fuel consumption of the thermal power plants. The higher the
fuel consumption (and fuel price) by the thermal power plants, the higher the Fuel Cost Charge
and, therefore, the higher the electricity bill for the consumer. It is expected that the
implementation of a large-scale wind project will reduce Kenyas reliance on expensive thermal
power, especially thermal emergency power, and therefore the Fuel Cost Charge will be lower.
JCI has confirmed that the LoA issued by Kenya DNA of the host Party /11/ stated regarding the
projects contribution to the sustainable development of the Republic of Kenya as follows: The project
will contribute to Kenyas sustainable development. We wish to note and confirm that this project,
amongst other issues, will contribute to the overall realization of Kenya Vision 2030 through generation
of more environmentally friendly energy and assist in increasing energy security for the country. It is
however to be noted that the project must comply with all the required national regulatory and /or
planning requirements.
JCI has validated, through on-site assessment etc, that these above items were appropriate for
contribution of sustainable development of the Host Party.

16

JCI CDM Center

2. Modalities of Communication
JCI has validated the corporate identity of all project participants and focal points included in the
MoC statement, as well as the personal identities, including specimen signatures and employment status,
of their authorized signatories, through directly checking the evidence for corporate, personal identity and
also through interview with the relevant personal of project participants.
JCI has confirmed in writing that it has performed due diligence on the MoC statement in accordance
with the requirements established in the VVS. And also JCI has confirmed in writing that the MoC
statement complied with all relevant forms and requirements.

3. Project Design Document

Through desk reviews and Q&A sessions with the PDD author, JCI confirmed that the PDD was
described based on and referring to the following relevant tools, guidance, guidelines, and manual in
addition to the applied methodology; ACM0002, Consolidated baseline methodology for grid-connected
electricity generation from renewable sources (Version 13.0.0) /51/:
(1)
(2)
(3)
(4)
(5)
(7)

Tool to calculate the emission factor for an electricity system (Version 02.2.1) /52/
Tool for the demonstration and assessment of additionality (Version 06.1.0) /53/
Guideline for Completing the Project Design Document Form (Version 01.0) /54/
Guidelines on the Assessment of Investment Analysis (Version 05.0) /55/
Glossary of CDM terms (Version 07) /57/
CDM VVS (Version 03.0) /58/

The project design was described using the latest Project Design Document Form (CDM PDD) Version 04.1 as shown in the PDD /2/, which was confirmed through comparison with the template listed
on the UNFCCC website.
As described above, JCI concluded that the PDD was compiled with use of the appropriate format and
was described based on appropriate tools, guidelines, manual and guidance which were specified and
requested by the CDM procedures.

4. Description of project activity

JCI undertook the following process to validate the accuracy and completeness of the project
description;
Process:

Document review, follow-up action (on-site visit, interviews), etc.

Document review: Findings (CARs, CLs), FSR, ESIA report, technical specifications, design
data/drawings, relevant laws/regulations/codes, internet websites
Follow-up action; Observation/inspection of the physical site and/or equipment during on-site visit
and interviews with stakeholders
As a result of the above process, JCI concluded that the descriptions of the PDD /2/ were accurate and
its contexts were complete, and well outlined the nature and technical aspects of the project activity.
The major features of the project activity described in the PDD /2/ are summarized below:
Sectoral scope: 01 (Energy industries (renewable / non-renewable sources))
Project type: Grid connected Wind power generation in wind farm
Installed capacity: 102.06 MW (63 units x 1.62 MW)
Project location: Ol Doinyo Narok plateau, Kajiado County, Rift Valley Province, Kenya
Northwest Corner; E 36.64621698, S 1.649020623
Northeast Corner; E 36.70916197, S 1.655110755
Southwest Corner; E 36.63031162, S 1.772545744
Southeast Corner; E 36.70165766, S 1.775223102
Connecting grid: Kenya Power and Lighting Company (KPLC)
Estimated net electricity: 410,476 MWh/year

17

JCI CDM Center

Estimated emission reductions: 254,125t-CO2e/year

Project lifetime: 20 years (Operation period)
1st crediting period: 7years
JCI has confirmed the accuracy and completeness of the project description.

5. Application of the selected baseline and monitoring methodology

5.1 Applicability of the selected baseline and monitoring methodology to the
project activity
JCI concluded from the following steps that ACM0002 Grid Connected renewable electricity
generation Version 13.0.0 /51/ was appropriately applied to the project activity;
Steps:
Document review, follow-up action (on-site visit, interviews), etc.
Document review: Findings (CARs, CLs), FSR, ESIA report, technical specifications, design
data/drawings, relevant laws/regulations/codes, internet websites
Follow-up action; Observation/inspection of the physical site and/or equipment during on-site visit
and interviews with stakeholders
1) Document review
JCI has reviewed the Wind Report /5/ and other documents considered as FSR and as ESIA Report /8/
of the project and confirmed that the proposed project would be newly introduced to the pasture and the
wind resources in the relevant region would be utilized for the power generation.
2) On-site visit on 16 to 18 July 2012
JCI has confirmed the area for the wind power plant would be installed but that the construction work
has not started yet. By the documents JCI has confirmed that the total installed plant capacity was 102.06
MW (GE1.6-100 x 47 units and GE 1.6-82.5 x 16 units). The operation start of the project is scheduled at
August 2014.
3) Confirmation of the Applicability
JCI has confirmed about applicability of the project to the applied methodology as follows:
Table 5-1 Applicability of the selected methodology to the project activity
Applicability criteria

PDD Comments

JCI Check

This methodology is applicable to grid-connected

renewable power generation project activities that:
(a) install a new power plant at a site where no
renewable power plant was operated prior to the
implementation of the project activity (greenfield
plant); (b) involve a capacity addition; (c) involve
a retrofit of (an) existing plant(s); or (d) involve a
replacement of (an) existing plant(s).

The proposed project activity

meets the applicability criteria
(a). It is a grid-connected wind
power generation project activity
that will install a new power
plant at a site where no
renewable power plant was
operated prior to the
implementation of the project
activity (greenfield plant)

OK
applicable

The project activity is the installation, capacity

addition, retrofit or replacement of a power
plant/unit of one of the following types: hydro
power plant/unit (either with a run-of-river
reservoir or an accumulation reservoir), wind
power plant/unit, geothermal power plant/unit,
solar power plant/unit, wave power plant/unit or
tidal power plant/unit.

The project activity is the

installation of a wind power
plant. Therefore it meets this
applicability criterion.

OK
applicable

18

JCI CDM Center

n/a. The project activity is a

In the case of capacity additions, retrofits or
replacements (except for wind, solar, wave or tidal greenfield activity.
power capacity addition projects which use Option
2: on page 10 [of the methodology] to calculate the
parameter EGPJ,y): the existing plant started
commercial operation prior to the start of a
minimum historical reference period of five years,
used for the calculation of baseline emissions and
defined in the baseline emission section, and no
capacity expansion or retrofit of the plant has been
undertaken between the start of this minimum
historical reference period and the implementation
of the project activity.

OK
The project
is not
capacity
addition,
retrofit or
replacement.

In case of hydro power plants one of the following

conditions must apply:
The project activity is implemented in an
existing single or multiple reservoirs, with no
change in the volume of any of the reservoirs; or
The project activity is implemented in an
existing single or multiple reservoirs, where the
volume of any of reservoirs is increased and the
power density of each reservoir, as per
definitions given in the Project Emissions
section, is greater than 4 W/m2; or
The project activity results in new single or
multiple reservoirs and the power density of each
reservoir, as per definitions given in the Project
Emissions section, is greater than 4 W/m2.

n/a. The project activity is not a

hydro power plant.

OK
The project
is not a
hydro
power plant.

In case of hydro power plants using multiple

reservoirs where the power density of any of the
reservoirs is lower than 4 W/m2 all of the
following conditions must apply:
The power density calculated for the entire
project activity using equation 5 is greater than 4
W/m2;
Multiple reservoirs and hydro power plants
located at the same river and where are designed
together to function as an integrated project that
collectively constitute the generation capacity of
the combined power plant;
Water flow between multiple reservoirs is not
used by any other hydropower unit which is not
a part of the project activity;
Total installed capacity of power units, which
are driven using water from the reservoirs with
power density lower than 4 W/m2, is lower than
15MW;
Total installed capacity of the power units,
which are driven using water from reservoirs
with power density lower than 4 W/m2, is less
than 10% of the total installed capacity of the
project activity from multiple reservoirs.

n/a. The project activity is not a

hydro power plant.

OK
The project
is not a
hydro
power plant.

19

JCI CDM Center

n/a. The project activity is a gridThe methodology is not applicable to the

connected wind power
following:
generation project.
Project activities that involve switching from
fossil fuels to renewable energy sources at the
site of the project activity, since in this case the
baseline may be the continued use of fossil fuels
at the site
Biomass fired power plants
A hydro power plant that results in the creation
of a new single reservoir or in the increase in an
existing single reservoir where the power density
of the reservoir is less than 4 W/m2.
n/a. The project activity is a
greenfield plant

In the case of retrofits, replacements, or capacity

additions, this methodology is only applicable if
the most plausible baseline scenario, as a result of
the identification of baseline scenario, is the
continuation of the current situation, i.e. to use the
power generation equipment that was already in
use prior to the implementation of the project
activity and undertaking business as usual
maintenance.

OK
The project
is not a
switching
project from
fossil fuels,
a biomass
fired power
plant and a
hydro
power plant.
OK
The project
is not
retrofit,
replacement or
capacity
addition.

In addition, the project meets the applicability criteria of the Tool to calculate the emission factor for
an electricity system (version 02.2.1) /22/ as follows:
Table 5-1 Applicability of the selected Tool (Emission Factor) to the project activity
Applicability criteria

PDD Comments

JCI Check

This tool may be applied to estimate the OM,

BM and/or CM when calculating baseline
emissions for a project activity that substitutes
grid electricity, i.e. where a project activity
supplies electricity to a grid or a project activity
that results in savings of electricity that would
have been provided by the grid (e.g. demand-side
energy efficiency projects).

This tool is applicable since the

proposed project activity involves
the generation of electricity from
wind energy and its supply to the
Kenyan national grid system.

OK
The project
supplies
electricity to
the Kenyan
national
grid.

The tool is not applicable if the project electricity

system is located partially or totally in an AnnexI country.

The project electricity system is

the Kenyan national-grid-system.
Kenya is not an annex I country.

OK
The project
is not in an
Annex-I
country.

JCI has checked and validated through the on-site assessment, the desk review of project related
documents and the subsequent follow-up interviews. JCI confirmed that project activity meets all the
applicability criteria of the methodology and the relevant Tool in accordance with the CDM requirements
with sufficient evidences.

5.2 Project boundary

JCI identifies the project boundary from the following steps;
Steps:
Document review, follow-up action (on-site visit, interviews), etc.
Document review: Findings (CARs, CLs), plant layout, FSR, ESIA report, technical specifications,
design data/drawings, contracts, grid baseline emission factors

20

JCI CDM Center

Follow-up action; Observation/ inspection of the physical site and/or equipment when on-site visit
and interviews with stakeholders
The PDD /2/ defines correctly the system boundary to include the project activity site and the energy
source and gases, which are shown in the Figure 3 in the PDD.
The electricity generated by the project activity will be finally transmitted to KPLC in Kenya and will
replace part of electricity from KPLC which has many fossil fuel-fired power plants within the network.
The emissions sources are summarized in the Table in B.3 of the PDD, according to the applied
methodology ACM0002. As shown in the Table, the project does not discharge emissions within the
project boundary as a result of implementation of the project activity, which was confirmed through the
onsite assessment.
JCI concluded that the identified project boundary and selected sources and gases were appropriately
defined in the PDD /2/ and fully complied with the ACM0002 /51/.
JCI validated all potential sources of GHG emissions within the boundary of proposed project and
concluded that all sources, which are expected to contribute more than 1% of the overall expected average
annual emissions reductions are included in the estimation of the PDD.

5.3 Baseline scenario identification and description

JCI has confirmed that the baseline identification of the project was conducted in appropriate manner
by confirming of following steps and sources;
Steps:
Document review, follow-up action (on-site visit, interviews), etc.
Document review: Findings (CARs, CLs), plant layout, FSR, ESIA report, technical specifications,
design data/drawings, Contracts, Grid baseline emission factors
Follow-up action; Observation/ inspection of the physical site and/or equipment when on-site visit
and interviews with stakeholders
Identification of baseline scenario should be comply with Identification of the baseline scenario of
the methodology ACM0002 (version 13.0.0) /51/. The PDD identified the baseline scenario for the
project as follows:
Electricity delivered to the grid by the project activity would have otherwise been generated by the
operation of grid-connected power plants and by the addition of new generation sources, as reflected in
the combined margin (CM) calculations described in the Tool to calculate the emission factor for an
electricity system.
JCI concluded the baseline scenario for the project was identified appropriately in accordance with
applied Methodology.
JCI has confirmed the followings according to CDM VVS ver. 03 paragraph 94 /58/;
(a) All the assumptions and data used by the project participants are listed in the PDD/2/, including
their references and sources;
(b) All documentation used is relevant for establishing the baseline scenario and correctly quoted and
interpreted in the PDD/2/;
(c) Assumptions and data used in the identification of the baseline scenario are justified
appropriately, supported by evidence and can be deemed reasonable;
(d) Relevant national and/or sectoral policies and circumstances are considered and listed in the PDD
/2/;
(e) The approved baseline methodology has been correctly applied to identify the most reasonable
baseline scenario and the identified baseline scenario reasonably represents what would occur in
the absence of the proposed CDM project activity.
JCI has further cross-checked the information contained in the PDD by the similar CDM projects
and/or actual evidences etc. according to paragraph 88 of CDM VVS /58/.

21

JCI CDM Center

5.4 Algorithms and/or formulae used to determine emission reductions

JCI has validated and concluded that the algorithms and/or formulae including data and values, used
to determine the emission reductions of the proposed project in the PDD /2/ and the calculation
spreadsheets /3/ /4/, complied with the methodology /51/ and relevant tool /52/ though taking into
consideration on following steps in accordance with the paragraphs 96, 97, 98 and 99 of VVS /58/.
1) Step-1 Validation work:
JCI has verified the data and parameters used in the equations, including references to any other data
sources used.
2) Step-2 Results of Validation work (Providing the opinion of validation):
JCI has provided the opinion by taking following steps to assess whether the algorithms and/or
formulae used to determine emission reductions for CO2 emission of the project activity is appropriate or
not.
(a) All assumptions and data used by the project participants are listed in the PDD, including their
references and sources are appropriate.
(b) All documentation used by project participants as the basis for assumptions and source of data is
correctly quoted and interpreted in the PDD.
(c) All values used in the PDD are considered reasonable in the context of the proposed CDM project
activity.
(d) The baseline methodology has been applied correctly to calculate project emissions, baseline
emissions, leakage and emission reductions.
(e) All estimates of the baseline emissions can be replicated using the data and parameter values
provided in the PDD.
JCI confirmed the emission reduction calculation through the excel spread sheet for ER calculation /4/
and concluded that the ER calculation was correctly conducted.
5.4.1. Application of baseline and monitoring methodology
JCI confirmed that the PDD /2/ fully complied with the methodology and the relevant tool based on
the baseline defined as per the applied methodology of ACM0002 /51/. The calculations were conducted
first to work out work out the project emissions based on the applied methodology of ACM0002, and then
the baseline emissions were calculated including the emission factor calculation with the 6-step method
specified by the relevant tool /52/. Finally the emission reductions were calculated from the project
emissions and the baseline emissions (no leakage in the project).
JCI also confirmed that the data and parameters used in the calculations were correctly interpreted and
applied, through cross-checks with comparison of the data given by KPCL /86/. Main parameters for the
component are summarized in the tables in Appendix 4 of the PDD /2/ and the detailed parameters are
shown in the emission reduction calculation Spread Sheet /4/.
5.4.2. Project emissions; PEy
The project is a renewable energy project as wind power and there is no energy consumption to
generate GHG emission in the project. Therefore the project emission PEy is zero.
JCI concluded that the project emission is calculated correctly to be zero complying with ACM0002.
5.4.3. Baseline emissions; BEy
(a) Combined margin emission factor; EFgrid,CM,y
The combined margin (CM) as Emission Factor of the KPLC /4/ was calculated by the operating
margin (OM) and build margin (BM) according to the procedures prescribed in the relevant tool /52/.
According to the relevant tool /52/, those were calculated in the following steps:
Step 1. Identify the relevant electricity systems

22

JCI CDM Center

According to the relevant tool /52/, the PDD has identified the Kenyan national grid as the relevant
project electricity system. The KPCL is only one electricity grid system in Kenya and publishes the data
related to the electricity grid system and the power generation data of the connected to the grid /81//88/.
Step 2. Choose whether to include off-grid power plants in the project electricity system
The project activity has selected Option I, therefore only the grid power plants are included in the
operating margin and build margin emission factor calculation of the project.
Step 3. Select a method to determine the operating margin (OM)
The Dispatch data analysis OM method option c) in the relevant tool is selected, since the lowcost/must-run resources constitute more than 50% of total grid generation in Kenya. So then the OM will
be updated annually using the data which actual project electricity generation will be monitored.
Step 4. Calculate the operating margin emission factor according to the selected method.
The PDD selected the Dispatch data analysis OM according to the relevant tool. The CO2 emission
factor of the grid power units n (EFEL,DD,h) was determined as per the guideline for the simple OM using
Option A1. As a result, the OM emission factor EFgrid,OM,y is calculated to be 0.6613 tCO2e/MWh, as
shown in B.6. of the PDD /2/ and emission reduction calculation spread sheet /4/, fully complying with
the methodology /51/ and the tool /52/.
Step 5. Calculate the build margin emission factor (BM)
According to the relevant tool, Option 2 is chosen for the vintage of data. Regarding the sample group
of power unit, SET20% is chosen as the SETsample.
Since for a power unit data on fuel consumption and electricity generation is available, Option A1 is
chosen. The factor is the generation-weighted average emission factor of all power units with reference to
most recent year. As a result, EFgrid,BM,y has been correctly worked out to be 0.4928 tCO2e/MWh
complying with the relevant methodology, and the tool which are shown in B.6.1. of the PDD /2/ and
emission reduction calculation spread sheet /4/.
Step 6. Calculate the combined margin (CM) emissions factor
The default weights of wOM = 0.75 and wBM = 0.25 are applied to both OM and BM emission factors
for calculation of CM emission factor EFgrid,CM,y for the first crediting period according to the related tool.
JCI has confirmed that CM emission factor EFgrid,CM,y was calculated appropriately to be 0.6191
tCO2e/MWh in the PDD /2/.
(b) Baseline emission; BEy
According to the applied methodology /51/ and based on the above seven steps, the baseline emission
BEy is calculated as follows:
BEy = EGPJ,y EFgrid,CM,y
Where:
BEy = Baseline emissions in year y (tCO2/yr)
EGPJ,y = Quantity of net electricity generation that is produced and fed into the grid as a result of the
implementation of the CDM project activity in year y (MWh/yr)
EFgrid,CM,y = Combined margin CO2 emission factor for grid connected power generation in year y
(tCO2/MWh).
The quantity of net electricity generation that is produced and fed into the grid as a result of the
implementation of the CDM project activity in year y is measured as EGPJ,y = EGfacility,y which will be
used as the base for emission reductions calculation. So the baseline emissions are calculated as:
BEy = EGPJ,y EFgrid,CM,y = EGfacility,y EFgrid,CM,y
The estimated net electricity generation of the project is estimated according to the document
considered as Wind Report /5/.

23

JCI CDM Center

EGPJ,y = 410,476 MWh/y

Where:
Net full load operation hours = 4,021.91 h (= 410,476 MWh/y / 102.06 MW)
Plant load factors = 45.9122 % (= 410,476 MWh/y / 102.06 MW / 24hr / 365 day x100)
In-house consume rate = 4 % (Energy efficiency of 96.0 % in the Table 3 of the PDD)
Transmission loss rate = 0 %*
* The PDD shows that the Sales of Electricity (electricity supplied to the Grid) is same value as the
net electricity generation (electricity generated in the project). It means 0% for transmission rate. JCI
concluded those are conservative assumption for demonstration of CDM additionality.)
And then the baseline emission BEy is calculated as follows;
BEy = EGfacility,y EFgrid,CM,y
= 410,476 x 0.6191
= 254,125 tCO2e/year
JCI issued the finding of CL-3 to clarify the above calculation procedure. It was clarified
appropriately and then the finding of CL-3 has been resolved and closed.
5.4.4. Leakage; LEy
JCI confirmed that the PDD stated no leakage considered for the project appropriately according to
the applied methodology.
5.4.5. Emission reductions; ERy
The total emission reduction is calculated as follows.
ERy = BEy PEy
= 254,125 0
= 254,125 tCO2e/y
In conclusion, JCI has concluded that the emission reductions are appropriately worked out
complying with the methodology /51/ and the relevant tool /52/, and the parameters and data for the
calculations are sourced from the proper documents.

6. Additionality of project activity

JCI assessed the additionality of the project activity with the following steps as below, complying
with following Standard, tool and Guidelines;
(1) Clean Development Mechanism validation and verification standard (Version 03.0) /58/
(2) Tool for demonstration and assessment of additionality (Version 06.1.0) /53/

6.1 Assessment of prior consideration of the clean development mechanism

(1) Timeline of the project
The timeline of major key activity relevant to the project implementation and serious consideration of
CDM are tabulated below, according to the guideline of CDM prior consideration /56/.
The Project Participants explained the below timeline and submitted the detailed timeline and the
relevant evidences. JCI has confirmed that the serious consideration of CDM and the secured CDM status
were made appropriately by the project participants. And the relevant evidences were submitted to JCI as
shown in the below Table 5.
The timeline summarizes how the project participant made prior consideration of CDM step by step.
The main events are explained in the following section.

24

JCI CDM Center

Table 5 Timeline of major key activity

Date

10/06/2009
12/08/2009
04/06/2010
02/2011
04/02/2011
07/03/2011
23/04/2011
06/06/2011
06/06/2011
03/09/2011

Key Activity

Evidence

Expression of Interest to construct a 100 Megawatt Wind farm

to the Ministry of Energy by Craftskills Wind Energy
Letter of first rights of Refusal for the site area for 100MW as
per Feed In Tariff
Kipeto Energy registered as a company the Special Purpose
Vehicle
Environmental and social Impact Assessment (ESIA) study
begins by Kurrent Technologies
Joint Development Agreement) signed between General
Electric International (Benelux) B.V. (GE) and Craftskills
Wind Energy International Limited (Craftskills)
First Stakeholders meeting
Installation of metrological masts and start of capturing data
Submission of CDM Prior Consideration to UNFCCC
(published on 14/06/2011)
Submission of CDM Prior Consideration to Kenya DNA

/17/

/13/

/22/

/33/
/32/

/31/

09/12/2011

Completion of Wind Report by Galetech Energy

Board meeting of Kipeto Energy for investment decision and
CDM application
CDM consultant contract with Carbon Africa

06/02/2012

CDM stakeholder meeting at Bounty Hotel Ngong

/40/

03/2012

ESIA report completion

/8/

22/05/2012

Approval letter for ESIA report by NEMA

/12/

01/06/2012

/6/

30/07/2012

Contract with JCI as DOE

Updated wind assessment report by Galetech based on new
turbine layout.
Issuance of EIA license

/16/

03/09/2012

Issuance of host country LoA by NEMA

/11/

02/2013

PPA signing with KPLC (expected)

01/03/2013

Turbine Supply Contract (CDM Project Start date) (expected)

08/2013

Kipeto wind farm construction start (expected)

08/2014

Kipeto start of operation (expected)

08/09/2011

26/07/2012

/5/

/21/

(2) Prior consideration of CDM

In June 2009, the Craftskills Wind Energy International Limited submitted letter to express an interest
of construction 100MW wind farm in Kenya to Ministry of Energy. And the Kipeto Energy Limited was
established in Kenya in June 2010 to develop and operate the project. The Joint Development Agreement
for the wind farm project was signed between General Electric International (Benelux) B.V. (GE) and
Craftskills Wind Energy International Limited (Craftskills) signed on 04/02/2011 /22/.
The Kipeto Energy has understood the project was not financially attractive based on the Wind Report
/5/ prepared by Galetech, the evidenced project costs and revenue assumptions as provided at the
investment decision. Then, Kipeto Energy decided CDM funds to be used for the project in September
2011 together with investment decision of the project /31/.

25

JCI CDM Center

The evidence provided to JCI by Kipeto Energy is the resolution of Board of Directors in which a
consideration of CDM application was clearly reported. The project participant also submitted the
notifications on 06/06/2011 of intention to seek CDM status to both UNFCCC and the Kenya DNA
(published on 14/06/2011) /32//33/, before the project activity start date (expected on 01/03/2013).
From above timeline JCI has concluded that the CDM was seriously considered in the decision for
implementation of the project activity by the project participant. And JCI has concluded that the period of
time between completion of the Wind Report /5/ and the investment decision with CDM application was
sufficiently short, and the decision were made based on the Wind Report and the evidenced project costs.
And also JCI confirmed the notifications for consideration of CDM project to Kenya DNA /32/ and to
UNFCCC /33/ according to the stipulation for prior consideration in para. 107 of CDM VVS.
(3) Project starting date
JCI has assessed that the project starting date with the following issues.
According to the Glossary of CDM terms (version 07.0) /57/ the start date of a CDM project activity
is the earliest date at which either the implementation or construction or real action of a project activity
begins. Furthermore it shall be considered to be the date on which the project participant has committed
to expenditures related to the implementation or related to the construction of the project activity.
In case of the project, there is no date fallen under above category by now but the first such action is
expected in 01/03/2013 which is the main equipment procurement contract. It is considered as the earliest
real action and first commitment on expenditure of the project activity.
JCI has concluded that above project starting date was considered to match with the Glossary of CDM
terms /57/.
(4) Activities/events to achieve CDM
Key activities and events regarding continuing and real actions taken by the project participant to
secure CDM status are tabulated in the Table in B.5 of the PDD.
JCI has confirmed that all milestones listed in the Table were evidenced with the documents which
were provided by the project participants. Then JCI concluded that continuing and real actions were taken
to secure CDM status for the project activity.
In conclusion, JCI confirmed that the above timeline explained the actions/events taken by the project
participants were appropriate in achieving CDM.

6.2 Identification of alternatives

JCI reviewed that as described in the above section of 5.3 Baseline identification in this report, the
PDD /2/ of the proposed project activity identified appropriately the baseline scenario in compliance with
the selected methodology ACM0002 version 13.0.0 /51/.
JCI has assessed through the finding of CL-14 based on the document review and then the on-site visit
to confirm the contents in the related documents such as the Wind report /5/ for the proposed project,
followed by a review of information from similar projects and/or technologies.
JCI reviewed the PDD /2/ and validated that the credible and feasible baseline scenario was to provide
the same amount of electricity by KPLC according to the selected methodology ACM0002 (version
13.0.0) /51/ and relevant Tool /53/.
The PDD /2/ developed the following two (2) possible alternatives:
Alternative 1: The project activity not undertaken as a CDM project activity.
Alternative 2: Electricity delivered to the Kenyan national grid by the project activity would have
otherwise been generated by the operation of grid-connected power plants and by the
addition of new generation sources.
The Additionally Tool (version 06.1.0) stipulated as follows in Para. 4. Therefore above two
alternative identifications were appropriate.

26

JCI CDM Center

4. Project activities that apply this tool in context of approved consolidated methodology
ACM0002, only need to identify that there is at least one credible and feasible alternative that would
be more attractive than the proposed project activity.
Due to the following reasons detailed in section B.5 of the PDD /2/, Alternatives 1 is rejected and the
baseline scenario mentioned in 5.3 was appropriately identified.
Alternative 1: It is a technically credible alternative but is not realistic alternative since it is not
financially attractive as demonstrated in the investment analysis.
As result, Alternative 2 (Continuation of the current situation, i.e. electricity will continue to be
generated by the operation of grid-connected power plants and by the addition of new generation sources)
was identified as the credible and feasible baseline scenario to the project activity.

6.3 Investment analysis

The PDD/2/ selected Investment analysis specified in the Tool for demonstration and assessment of
additionality (Version 06.1.0) /53/.
(1) Benchmark Analysis
The PDD /2/ selected the benchmark analysis method for investment analysis of the project activity
with the following justifications:
1) Tool for the demonstration and assessment of additionality /53/ provides 3 options for the methods
of investment analysis. The baseline scenario for the project activity is the supply of electricity
from a grid. Therefore, the baseline scenario does not necessarily require investment and is outside
the control of the project developer. Option III, benchmark analysis is, therefore, selected as the
appropriate analysis method for the project activity.
2) The PDD /2/ selected the post-tax nominal Return on Equity as an appropriate benchmark for
investment analysis. In Kenya, the average cost of equity for renewable energy investments was
commonly used as the appropriate benchmark for comparison with the Equity IRR, and equity
investors and shareholders are mostly interested in after tax cash flows.
The paragraph 12 of the Guidelines on the assessment of investment analysis (version 05), the
average cost of equity is stipulated as one of appropriate benchmark for comparison with the
Equity IRR. The project has calculated the EIRR based on the CDM default value from the
Guidelines on the assessment of investment analysis (version 05) for equity return of renewable
energy investments in Kenya. The benchmark of 18.25 % is calculated with the default value
13.25% specified in the Guidelines on the Assessment of Investment Analysis version 05 and
Kenya inflation target of 5% which was reported by the Central Bank of Kenya on June 2011.
3) JCI reviewed the calculated average cost of equity input value and then concluded that it was
appropriately calculated and fully complies with the relevant tool /53/ and Guidelines /55/.
4) There are no references of the application of the benchmark analysis to other projects by the project
owner, since the proposed project is the first project for the project owner to invest in.
The Equity IRR was calculated to be 14.41 % without CDM revenue, and 20.75 % with CDM
revenue. It is, therefore, concluded that the project activity is not financially attractive, of which processes
are validated with below steps.
(2) Consistency between PDD and FSR (Conformance with para. 113 a) and b) of VVS /58/)
As stated in 6.1 Prior consideration of CDM, JCI has judged that the period of time between the Wind
Report completion and the investment decision was sufficiently short, and so that the investment decision
was made based on the Wind report.
JCI has reviewed the validity of the input values for the investment decision by comparing the input
values between the Wind Report and the PDD ver02 /2/.

27

JCI CDM Center

The detailed validations for the Project CAPEX, electricity Tariff, Maintenance and OPEX cost and
the Net Energy Production are described in the following item (3). And as for the Equity IRR, it is
discussed in the following item (4).
Table 6 Comparison of parameters of investment analysis

Parameters

Unit

Parameter at
Investment
decision*1

Parameter of

alternative
layout

Base document
for Investment decision

(For reference)

MW
MWh
%

47 GE 1.6-100
16 GE 1.6-82.5
102.06
410,476
45.9122

USD/kWh

0.12

0.12

Corporate Tax
Debt/Equity Ratio
Interest rate

%
%/%
%

30
70/30

30
70/30

10.00

10.00

Project CAPEX
Maintenance parameter
(Year 1)
OPEX parameter*2
(Year 1)

USD

286,579,393

298,021,192

USD

3,874,500

3,874,500

USD

6,350,696*2

6,431,494*2

EUR/CER

24.44
14.41
20.75

24.44
14.38
20.69

Wind Turbines
Gross Capacity
Net Energy Production
Plant Load Factor
Tariff cost

Price per CER

EIRR without CER
EIRR with CER

%
%

63 GE 1.6-100

Wind report /5/

102.06
425,009
47.5377

Wind report /5/

Wind report /5/
Calculated from above
Feed-in-Tariffs Policy
(2010) /85/
Income Tax Act /90/
CfC Stanbic Bank /46/
CfC Stanbic Bank /46/
GE EPC quotes and
others /23/
GE quote and others
Land lease agreement
and others /24/
IETA
Investment analysis /3/
Investment analysis /3/

*1 it is a base data for investment decision at the directors board meeting on 08/09/2011. And those parameters
are reported in the PDD ver. 01 for GSC.
*2 OPEX parameter includes the Maintenance cost of 3,874,500 USD shown in Maintenance parameter

The PDD version 03 shows two kind of financial parameters. One is the parameters which was the
base data for the investment decision (47 GE 1.6-100 and 16 GE 1.6-82.5 wind turbines) and the CDM
decision at the directors board meeting on 08/09/2011. The base documents for decision were the Wind
report for technical matters and GE Energy quotations and so on / 23//24//25 / for financial matters.
After the directors board meeting the project decided minor project modification on some technical
matter to use the GE 1.6-100 for all site locations (alternative layout) in accordance with the revised Wind
report after the Mechanical Loads Analysis conducted by GE Energy on the 23/07/2012. As shown in the
Table 6 the total capacity of project was not changed but the expected net energy production increased.
Therefore the financial situation has been changed slightly by this alternation and then the PDD showed
the two sets of financial parameters and calculation results.
JCI concluded that the project should be validated with the investment decision case (47 GE 1.6-100
and 16 GE 1.6-82.5 wind turbines) in the Table 6 and the financial situation of the alternative layout (63
GE 1.6-100 wind turbines) should be confirmed no change of additionality of the project as reported
below.
(3) Cross check
1) Investment cost
The project is now in the early stage before the project start date (01/03/2013). JCI has reviewed the
expected final actual costs of the project as of the end of November 2012. The actual cost is expected
298,409,318USD which is only 0.4 % higher than the estimated cost at the investment decision in the
PDD. Main cost of the project is the Equipment cost of which contract with EPC contractor has not

28

JCI CDM Center

conducted yet but the cost has agreed with contractor. That cost, which is 86 % of the project CAPEX,
will not be varied any more, and then the project CAPEX is not expected to decrease 10% or more.
Table 7 Comparison of cost by FSR and actual cost
No.

Items

Cost in PDD ver03

(at investment
decision)*1 (USD)

Expected final
actual cost as of
Nov 2012*2 (USD)

Remarks

Project development,
management and legal cost

1,500,000

1,866,391

Expected spend cost /45/

Equipment cost

245,646,608

255,594,716

The contract has not yet.

But agreed value with
EPC contractor.

Contingencies

4,912,932

5,111,894

Expected spend cost

11,033,307

11,488,759

Expected spend cost

5,015,139

5,222,163

Expected spend cost

Interest During
Construction (IDC)
Financing fee

Working capital

6,157,136

6,375,132

Expected spend cost

Debt reserve

12,314,272

12,750,264

Expected spend cost

Total

286,579,393

298,409,318

*1 47 GE 1.6-100 and 16 GE 1.6-82.5 wind turbines

*2 Kipeto Energy has decided already to construct 63 GE 1.6-100 wind turbines, therefore those values are expected for
that plant design case.

There is only one large scale CDM registered projects of wind power plant in Kenya. It has proved its
additionality as first-of-its-kind technology and investment analysis. And its capacity is 310 MW which
is out range of +/- 50 % of the project. The Table 8 shows comparisons of the financial parameters
between the project and the registered project.
The investment cost/Generator capacity of the project is 2,807 USD/kW which is higher than the
reference project of Ref. 4513 of CDM. Main reason of such difference is supposed to be plant scale and
site conditions since the project capacity is only 1/3 of the reference project (310MW).
Table 8 Summary of Cross-check
Item

Investment cost*2 /
Generator capacity

Operating cost*3
/Investment cost*2

Electricity tariff

Plant load
factor

USD / kW

USD / kWh

2,807

2.52

0.120

45.9122

2,319

2.92

0.101

45.9

The Project
Ref. No 4513 in Kenya

*1

Note; *1 Registered large scale CDM project, Lake Turkana 310 MW Wind Power Project, USD/EUR rate = 1.454
*2 Project CAPEX in case of the Project (47 GE 1.6-100 and 16 GE 1.6-82.5 wind turbines)
*3 OPEX parameter in case of the Project

2) Maintenance and Operation cost

The Financial calculation spread sheet /3/ shows about 7,208,000 US$/y as the averaged operating
cost of 20 operation years. The Table 8 shows the operating cost / investment cost of the project and the
referent CDM project in Kenya that both values are almost same. The parameter is usually about 2 - 3 %
so then the values in the Table 8 are reasonable.
3) Electricity tariff
The Electricity tariff of the project activity is 0.120 USD/kWh. The Kenya Ministry of Energy issued
the Feed-in-Tariffs Policy /85/. In the Policy, the Electricity tariff (feed-in-tariffs) of wind farm is

29

JCI CDM Center

prescribed as maximum 0.12 USD/kWh for 0.5 to 100 MW capacity. The PDD is selected highest value
of the Policy. It is a conservative assumption for CDM additionality.
PPA (Power Purchase Agreement) has not contracted yet and will be contracted in February 2013
before financial close of the project. During the on-site assessment, JCI has confirmed by the interview
with KPLC that the electricity tariff of 0.120 USD/kWh was reasonable and appropriate.
4) Net energy production (Electricity generation)
Wind resource assessment
The Kipeto installed 81m Metrological Masts on April 23, 2011 and began capturing wind data at the
site. The Galetech prepared and reported the wind report for Kipeto project area on September 2011 /5/,
which included about four month wind data at the site. After that it goes on capturing wind data.
Power generation
Base on the wind data of both the measurement data by 3 81m Metrological Masts and the numerical
weather predication data the Galetech predicted the wind speed and gross energy yield (before losses) for
63 turbines of which locations were shown in the Wind report /5/.
The wind report reported the expected power generation based on the above wind resource data that
the net annual power production was estimated 410,476 MWh.
Plant load factor;
The figure of the project activity is 45.9122 % which is calculated from net power generation by the
calendar hours of year. The net power generation was estimated by the FSR author as a third party.
Net power generation (Electricity supply to the Grid)
The Galetech calculated the Net power generation from the power generation using the following the
factors and efficiencies /5/;
Topographic factor
101.9 %
Array efficiency
96.0 %
Electrical efficiency
96.0 %
Availability
96.1 %
Substation availability
99.0 %
Icing and blade degradation
99.0 %
Power curve
99.0 %
Hysteresis
99.8 %
Grid curtailment
100.0 %
From the factors and efficiencies, the Galetech calculated 410,476 MWh/year of the net power
generation. JCI validated the net power generation was estimated by Galtech as a third party of expert for
wind power generation.
From above crosscheck, JCI has concluded that the input data for investment analysis are appropriate
with conformance of Guidelines on the Assessment of Investment Analysis /55/.
(4) Evaluation of IRR calculation as the means of the benchmark analysis
JCI has checked the appropriateness of the result of the IRR calculation. JCI issued the finding of
CAR-3 to provide the active IRR calculation spread sheet. The project participant submitted /3/. The
finding of CAR-3 has been resolved and closed.
As stated in the above item 6.1.2), the project owner made decision to apply CDM by the financial
analysis. The input values related IRR calculation can be summarized in the above Table 6.
With the result of Equity IRR calculation, the IRR without CDM revenues calculated 14.41% which is
lower than the benchmark18.25 %, while with CDM revenues 20.75 %. JCI confirmed the Equity IRR
calculation was conducted appropriately as shown in the spread sheet.

30

JCI CDM Center

JCI has confirmed that IRR calculation is in compliance with Guidelines on the Assessment of
Investment Analysis /55/ as stated below:
-

It is an Equity IRR calculation result.

The IRR has been calculated on after-tax and on nominal cash flow basis.
The bank loan is 70 % of the total investment of the project.
The interest rate is 10.00 % which is a commercial lending rate of Kenya. JCI concluded that the
interest rate was payable and prevailing commercial interest.
- The depreciation is calculated using turbine lifetime of 20 years and scrap value of 0.

Then JCI has considered the calculation of EIRR in the PDD /2/ is appropriate because it is calculated
according to Guidelines on the Assessment of Investment Analysis /55/. In conclusion, JCI has validated
that the investment analysis in the PDD /2/ was appropriate.
(5) IRR after modification of plant design
As explained above the plant design has been updated after the investment decision. The PDD version
03 showed the IRRs after design update as follows.
Base design at
investment
decision*1

Updated design*2

Equity IRR without CDM revenues

14.41 %

14.38 %

Equity IRR with CDM revenues

20.75 %

20.69 %

Design

*1 47 GE 1.6-100 and 16 GE 1.6-82.5 wind turbines

*2 63 GE 1.6-100 wind turbines

As a result, the IRR without CDM revenues of the Updated design (63 GE 1.6-100 wind turbines) was
slightly decreased from the base design (47 GE 1.6-100 and 16 GE 1.6-82.5 wind turbines). JCI has
concluded that the project activity was financially unattractive even in case of the updated design.
(6) Sensitivity analysis
Sensitivity analysis has been validated with the following two steps: 1) assessment of (+) / (-) 10%
variation analysis and 2) assessment of likelihood of variations to reach the benchmark IRR complying
with the UNFCCC rules.
1) (+)/(-)10% variation analysis is conducted using the following four parameters.
(a) Electricity generation
(b) Operating costs
(c) Investment costs
(d) Tariff
The PDD /2/ shows the result of the analysis that IRRs do not exceed the benchmark 18.25 % when
any of those three parameters vary within the (+)/(-)10% range.
JCI has considered that the range of the (+)/(-)10% variation is appropriate due to the following
reasons:
- The power generation depends on the variation of plant load factor. Maximum power generation is
limited, and the plant load factor for long term would not be supposed to increase over 10%,
considering the actual data in the wind report.
- JCI has confirmed the investment cost and operation cost increase possibly due to rising of material
cost, labour wage and other commodity prices.
- It, therefore, is not possible that those costs decrease by 10% lower than the cost estimation in the
Table 6 above. If those parameters would increase, it could be considered conservative for CDM
additionality. Accordingly (+)/(-)10% range can be considered appropriate.
- The tariff is regulated by Feed-in-Tariff policy so then it is not supposed to increase over 10 %. For
conservative analysis the impact of 1.7 % inflation rate was included in the sensitivity analysis.

31

JCI CDM Center

2) Assessment of likelihood of variation to reach the benchmark IRR

JCI has conducted to check the likelihood of the four parameters at the time when the IRR is equal to
benchmark, result is shown in Table 9.
Table 9 Parameter changes when project IRR is equal to benchmark
Parameter

Electricity
generation

Operating costs

Investment costs

Tariff

Critical variation to reach

the benchmark 18.25 %

+ 10.90 %

79.30 %

11.13 %

+ 10.90

410,476
455,218 MWh

7,208,768
1,492,215 USD

286,579,393
254,683,106 USD

0.12
0.1331 USD/kWh

Variation from the base

To increase the electricity generation, it needs to increase the average power generation and the
operation hours. Higher average electricity generation and operation hours are possible for short years but
it is hard to consider higher average electricity generation and operation hours continuously for long years
such as 10.9 % as stated in the above.
The operation costs need to lower by 79.3 % and it is impossible.
If the IRR would cross the benchmark IRR, the investment cost (Project CAPEX) needs to lower by
11.13 %. This scenario is actually not possible considering the increase of the actual cost for the
construction because of the increase of the materials, labour wage, etc. which is available by referring to
the official publication on the web-site of the Kenya Government.
The electricity Tariff is regulated by the Government. The electricity Tariff needs to higher by
10.9 % and it is impossible.
JCI has validated that the above arguments clearly demonstrate that it is unlikely that the IRR may
exceed the benchmark within reasonable variations of financial parameters. JCI therefore has concluded
that the result of the above investment analysis with use of the benchmark analysis is robust and then the
project activity is financially unattractive.

6.4 Barrier analysis

With the above 6.3 Investment analyses it was concluded that the project activity was financially
unattractive and additional as CDM project activity, since then the barrier analysis provided in Tool for
demonstration and assessment of additionality was skipped.

6.5 Common practice analysis

Common practice analysis in the PDD was conducted in accordance with the Additionality Tool
version 06.1.0 /53/. JCI interprets that a wind power project is the measure of Switch of technology with
or without change of energy source (including energy efficiency improvement as well as use of renewable
energies) listed in paragraph 6 of the Additionality Tool. So then JCI validates in accordance with step 1
to step 4 stipulated in paragraph 47 of the Additionality Tool.
Step 1: Calculate applicable output range as +/-50% of the design output or capacity of the proposed
project activity.
The PDD defined the applicable output range is between 51.03 MW and 153.09 MW since the output
of the project is 102.06 MW.
Step 2: In the applicable geographical area, identify all plants that deliver the same output or capacity,
within the applicable output range calculated in Step 1, as the proposed project activity and have started
commercial operation before the start date of the project. Note their number Nall. Registered CDM project
activities and projects activities undergoing validation shall not be included in this step 3.
The following criteria are applied to identification of Nall in the common practice analysis of the PDD.

32

JCI CDM Center

1) Applicable geographical area

Kenya is reasonable and appropriate as applicable geographical area.
2) Plants that deliver the same output or capacity as the project
As shown in Step1above, the plants that deliver the same output or capacity are plants between 51.03
MW and 153.09 MW. JCI cross checked power generation plants in Kenya from data of KPLC /81//88/.
The PDD identifies the plants between such ranges appropriately.
3) Plants have started commercial operation before the start date of the project.
The starting start date of the project activity is expected on 01/03/2013. The PDD excluded
appropriately the plants that have started commercial operation after the start date.
4) CDM project activities
The PDD excluded appropriately the registered CDM project activities and also the project activities
undergoing validation located in Kenya.
The Table 21 in Step 2 of Common Practice Analysis of PDD shows totally 37 projects of power
generation in Kenya. From above four criteria, the PDD identified 14 power projects as Nall excluding 23
projects out of output range and CDM projects.
Step 3: Within plants identified in Step 2, identify those that apply technologies different that the
technology applied in the proposed project activity. Note their number Ndiff.
The PDD discussed the technology different from the project as followings in accordance with the
paragraph 9 (Different technologies) of the Additionality Tool.
In the Nall, there are 1 geothermal project, 6 hydropower projects and 7 thermal projects which are
technologies different from wind power project unquestionably. And then Ndiff identified was 14 projects.
Step 4: Calculate factor F = 1 - Ndiff / Nall representing the share of plants using technology similar to the
technology used in the proposed project activity in all plants that deliver the same output or capacity as
the proposed project activity.
F = 1 - Ndiff / Nall = 1- 14 / 14 = 0
Nall - Ndiff = 14 - 14 = 0
And then JCI concluded that the proposed project activity is not a common practice within a sector in
the applicable geographical area since both the following conditions are not fulfilled in accordance with
Additionality Tool (version 06.1.0).
(a) The factor F is greater than 0.2, and
(b) Nall - Ndiff is greater than 3.
JCI issued that finding of CL-21 was regarding selection of similar project which was conducted unit
by unit base. The PDD was revised appropriately to apply project by project base selection. JCI
concluded it is comply with the related Tool. The finding of CL-21 has been resolved and closed.

6.6 Conclusion of assessment of additionality

JCI concluded that the PDD /2/ clearly demonstrated as shown in the above that the project activity is
additional, not financially attractive and therefore, would not occur without CDM revenue provision.
Serious consideration of CDM prior to the project decision by the project participant was clearly and
sufficiently demonstrated. Appropriate actions and events were taken by the project participant to achieve
CDM well after the project decision up to the publication of the PDD /2/. And investment and sensitivity
analyses clearly showed the project activity is not financially viable without CDM revenue. The common
practice analysis revealed that there is no similar activity and the project activity, therefore, is not
common practice.

33

JCI CDM Center

7. Monitoring plan
7.1 Compliance with the requirements of the methodology
JCI has confirmed that the monitoring plan of the project was complied with the requirements of the
methodology /51/.

7.2 The steps for monitoring arrangements

The monitoring implementation plan of the project was described in the PDD /2/, of which monitoring
items were divided to two categories as follows;
1) Quantity of net electricity generation supplied by the project plant/unit to the grid in year y and,
2) The items for determination of emission factor in year y.
(1) Monitoring:
1) Quantity of net electricity generation supplied by the project plant/unit to the grid in year y and hour h
Regarding the quantity of net electricity supplied by the project plant to the grid, there are one
monitored data of EGfacility,y and EGPJ,h in the Monitoring Plan. There are main meter and backup meter
installed at the outlet of the project activity of wind farm to measure the electricity supplied to the grid by
the project. The backup meter will be used in trouble of main meter and cross check of the data monitored.
the data will be cross checked with receipt of sales/invoices from KPLC. The main meter used for the
project will confirm to the requirements including its accuracy of the Kenya Electricity Grid Code and
also of the international standards.
2) The items for determination of emission factor in year y
The project has selected a method of dispatch data analysis for determination of the grid emission
factor EFgrid,OM,y. This method requires annual monitoring so then the Monitoring Plan includes the
monitoring items as follows;
EGn,y and EGn,h ; Net electricity generated by power plant / unit n in year y or hour h.
FCi,n,y ; Amount of fossil fuel type i consumed by power plant n in year y, and
NCVi,y ; Net calorific value (energy content) of fossil fuel type i in year y
EFCO2i,y ; CO2 emission factor of fossil fuel type i in year y
Those are necessary for calculation of emission factor EFgrid,CM,y.
JCI concluded that the monitoring items in the Monitoring Plan were appropriate for the project.
(2) Organization:
The project owner plans to set up the operational and management structure to cover entire process of
the project implementation including monitoring as shown in B.7.3 in the PDD /2/.
The project owner will appoint a carbon manager, who will be responsible for managing the emission
reduction monitoring and verification process, including; data collection, implementation of QA/QC
procedures, preparing of monitoring report, communication with other departments, data managing and
data storage.
The Operation Control Centre will be responsible for the operation and maintenance aspect of the
wind farm and will take care of meter reading and equipment calibration. The administration department
will be responsible for preparing invoices for the sales of electricity.
(3) Manual:
The project owner have not prepared for compiling monitoring and management manual to implement
the monitoring task yet. JCI issued FAR-1 to prepare some manual(s) before operation start.
(4) Training:

34

JCI CDM Center

The staffs related to the CDM project in the t project owner will be trained before operation of the
monitoring by the carbon manager. The training will conducted in order to ensure a common

understanding of the CDM monitoring procedures and requirements before operation start.

7.3 JCIs opinion on monitoring plan

JCI has validated the monitoring plan in the PDD /2/ by step of document review and interviews with
the project owner and the related participants. And JCI concluded that the monitoring plan in the PDD
was compliant with methodology /51/ and that the monitoring arrangement of the project participant was
feasible within the project design and also the project participant was able to implement the monitoring
plan including management organization and operational.

8. Environmental impacts
The Kurrent Technologies Ltd. carried out the Environmental and Social Impact Assessment (ESIA)
and completed it in March 2012 /8/. The ESIA report has submitted to NEMA, Kenya National
Environment Management Authority, in April 2012 and NEMA has issued the License (Approval of
ESIA) /16/ just after JCIs on-site assessment to interview with NEMA.
The ESIA report for the project activities was conducted to ensure that the project complies with
relevant national, regional and local regulations. The ESIA reports referred to anticipated environmental
impacts by the project activities both during the construction period and after the operation start,
recommendation on mitigation measures against visual impacts on natural scenic, local site-specific
impacts, impact on ecology, surface water quality, impact on geology and soil during construction, bird
collision problems, noise problem, and so on. No significant ecological impact on the local area was
anticipated.
The ESIA report showed recommendable mitigation measures of which eight recommendations were
reported in the PDD. And also the PDD reported the summary of ESIA in Appendix 9 which showed the
significance (evaluation result) of each environmental impact in stages at construction, operation and
decommissioning without and with mitigation. All significant impacts were reduced by implementation of
the recommended mitigation measures.
Through the observation of the project site and interview with the stakeholders during the on-site
assessment, JCI confirmed that appropriate mitigation measures would be taken as described in the PDD
/2/ and no serious issues were found. JCI has concluded that, given the project participant would take
necessary mitigation measure with the same level of concern as currently being done; the anticipated
environmental impacts by the project activity would be controlled at a minimum level after the operation
start.

9. Local stakeholder consultation

On 6 February 2012, the project owner had carried the CDM stakeholder consultation in which 46
local stakeholders attended. Approximately 25 participants in those attendees were identified as the
landowners of the project site and residents living around the project area /38//39//40/.
The consultation served to provide a project status update, inform community leaders of the progress
of the Environmental and Social Impact Assessment (ESIA) and discussed carbon credits and the CDM
mechanism. The meeting was conducted mostly in English with translation to local Maasai language.
And also JCI has confirmed the following comments and opinions of residents by interview with
sixteen residents /49/.
They were informed of the wind farm project by the project owner four years ago. After it several
meetings have been held by the project owner and residents (land owners).
They think the project is good news for them since it is a power generation project by renewable
energy.
They have not used electricity. Firewood is used as fuel for cooking and heating and kerosene is
used for lighting at present.
They want to use electricity for alternatives after operation start of the project.

35

JCI CDM Center

They say regarding the land lease fee that it is a little.

The advantage of the project for them is improvement of their life style and they want further new
jobs and new facilities for community.
Based on the above information, JCI has concluded that the project activity was supported by local
stakeholders, gave no significant adverse impacts on local environment, and is expected to contribute to
the development of local economy and the improvement of living conditions of local residents.

36

JCI CDM Center

Appendix A

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

Appendix A Protocol for Large Scale CDM Project (VVS version 1.0)
Abbreviation
CAR
Corrective Action Request
VVS
Validation and Verification Standard
Tbv
To be verified

CL
PDD GL
PA

Clarification Request
PDD Completion Guidelines
Project Activities

FAR
NA
PP

Forward Action Request,

Not Applicable
Project Participants

TABLE-1 REQUIREMENTS CHECKLIST

(OK/No/NA/Tbv)
Check
Comment

General guidelines

PDD GL

--

CAR,
CL, No.
---

PDD
No.

Reference
Para. VVS

Requirement

Title of the PA (project activity):

PDD GL

--

0.1

Confirm that the PDD Form applied the latest version of CDM-PDD.

Para.62

OK

0.2

Confirm that the Tables and their columns in the PDD are stayed without being modified or deleted.

PDD GL

OK

0.3

Confirm that the blanks are left intentionally for the not applicable section of the PDD.
Confirm that the values in the PDD are presented in an internationally recognized format.{For example: digits grouping in
thousands and a decimal point with a dot (.), not with a comma (,)}
( e.g 1,000 representing one thousand and 1.0 representing one.
Confirm that the units used for weights/currency are in S.I. units/norms (thousand/million)

PDD GL

OK

PDD GL

OK

0.4

A.
A.1.
A.1.1
A.1.2
A.1.3

Description of PA

PDD Form

Purpose and general description of PA:

Confirm that the brief description of the PA is provided.
Confirm that the brief description of the baseline scenario or existing scenario is provided in a couple of paragraphs.
(e.g.;Existing scenario prior to the PA (e.g. sugar mill, swine farm, iron smelter, etc.)
Confirm that the full description of the technologies and measures, project boundary and baseline scenario are provided in
sections A.3, B.3 and B.4.

--

--

PDD Form

--

PDD GL

OK

PDD GL

OK

PDD GL

OK

--

A.1.4

Confirm that the estimate of annual average and total GHG emission reductions for the chosen crediting period is provided.

PDD GL

OK

A.1.5

Confirm that the description on how the PA contributes to sustainable development is in one page . not exceed one page

PDD GL

No OK
No OK

CL-1
CL-2

Para.64

No OK

CL-31

Para.65

OK

Para.66

OK

Confirm that the project is the other CDM PA not referred to in paragraphs 65-66.
If yes, confirm that the validation of project description should be undertaken by reviewing available designs and feasibility
studies, and should conduct comparison analysis with equivalent projects, as appropriate.

Para.67

OK

Confirm that the CDM project involves the alteration of an existing installation or process.

Para.68

A.1.6
A.1.7
A.1.8
A.1.9

A.1.10

Confirm that the description of the PA in the PDD is accurate, complete, and provides an understanding of the proposed
CDM PA.
Has the physical site inspection been planned to conduct a physical site inspection for the PA in existing facilities or utilizing
existing equipments.
Confirm that the sampling approach in accordance with the Standard for sampling and surveys for CDM project activities
and programme of activities is applied for the PA.

If yes, confirm that the project description states the differences resulting from the PA compared to the pre-project situation.

Page 1

OK
OK
OK

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

Reference
Para. VVS

Requirement

A.2.

Location of PA

A.2.4

Physical/Geographical location

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

(OK/No/NA/Tbv)
Check
Comment

---

CAR,
CL, No.
---

A.2.1

Confirm that the physical location of the PA is indicated with longitude and latitude correctly.

PDD GL

OK

A.2.2

Confirm that the description of location including a map is in one page. (Do not exceed one page)

PDD GL

OK

PDD Form

--

-CL-3
CL-4
CL-5

A.3.

Technologies and measures

A.3.1

Confirm that the list and the arrangement of the main manufacturing/production technologies, systems and equipment are
identified.

PDD GL

No OK
No OK
No OK

A.3.2

Confirm that the list of facilities, systems and equipment in operation under the existing scenario prior to the implementation
of the PA is identified.

PDD GL

OK

A.3.3

Confirm that the list of facilities, systems and equipment in the baseline scenario, as established in section B.4 is identified.

PDD GL

OK

A.4.

Party(ies) and project participant(s)

A.4.1

Confirm that Party(ies) and project participant(s) are provided in the table.

A.4.2

Confirm that the names of the project participants correctly are stated and consistent with information in Appendix 1.

A.4.3

Confirm that no entities other than those authorized as PPs are included in the sections A.4. of the PDD.

A.5.

Public funding of PA

A.5.1

Confirm that the PA receives no public funding from Parties included in Annex I.

B.

PDD GL

Application of selected approved baseline and monitoring methodology (Para.)

Reference of methodology
Confirm that exact reference (number, title, version) of the selected methodology is indicated.
Confirm that exact reference (number, title, version) of any tools and other methodologies to which the selected
methodology refer is indicated.

B.1.4

--

No OK

CL-30

OK
OK

OK

PDD GL
PDD GL

OK

Confirm that the version of selected methodology is valid at the time of submission of the proposed PA for registration.

Para.70, 73

OK

Confirm that the methodology is correctly quoted and interpreted in the PDD.

Para.71, 74,
76

OK

B.2.

Applicability of methodology

B.2.1

Confirm that the methodology is correctly applied by comparing it with the actual text of the applicable version of the
methodology.

Para.74, 76

B.2.2

Confirm that the conditions of the project are met with the applicability conditions of the selected approved methodology.

Para.74,76

OK

Para.75

OK

Para.76

OK

B.2.3
B.2.4

OK

Confirm that the version of a methodology in PDD is effctive within the grace period at the time of when the PDD will be
submitted for registration.
Confirm that the conditions of the project are met with the applicability conditions of the tool or other methodology
component referred in selected methodology.

Page 2

--

---

B.1.

B.1.3

OK

OK

B.1.1
B.1.2

PDD GL
Para. 46
PDD GL
Para. 46
Para. 47

--

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

B.2.5

B.3.

Reference
Para. VVS

Requirement
Clarification on the applicability of an approved methodology

Para.81

Confirm that the applicability of the selected methodology is applied adquately to the PA.
If not, request for clarification of the methodology to be made with an assessment to ensure that the request is not submitted
with the intention of revising an approved methodology to expand its applicability.

Para.81

Project boundary (PDD GL, Para.82-87)

Para.82
PDD GL
Para.82
PDD GL

B.3.2

Confirm that all emission sources and gases in the project boundary for the purpose of calculating project emissions and
baseline emissions have been described in the table.
Confirm that the flow diagram of the project boundary and physically delineating the PA have been presented in the PDD.

B.3.3

Confirm that the project boundary clearly is defined in accordance with the selected methodology.

B.3.4

Confirm that the project boundary is confirmed on the basis of documented evidence.

B.3.1

B.3.5

Confirm that the project boundary confimed by a site visit.

B.3.6

Confirm that the PP have justified the choice of source or gas within the project boundary, If the methodology allows PP to
choose a source or gas to be included within the project boundary.
project boundary confimed by a site visit.

B.3.7

B.4.
B.4.1
B.4.2

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

Confirm that the justification provided is reasonable, based on an assessment of supporting documented evidence provided
by the PP.
Confirm that the project has not included other emission sources which are not addressed by the selected approved
methodology.
If no (project includes other emission sources), confirm that such other emission sources are expected to contribute more
than 1% of the overall expected average annual emissions reductions.
If yes, request clarification of, revision to, or deviation from the methodology, as appropriate.

OK

PDD GL
PDD GL
Para.82
Para.83
Para.84

OK
No OK
OK

OK
OK
OK

Para.87

OK
OK
OK

-PDD GL

OK

PDD GL

OK

Have the baseline scenario been identified for the proposed PA represented reasonably?.

Para.88

OK

B.4.4

Confirm that any procedure contained in the methodology is correctly applied to identify most reasonable baseline scenario.

Para.89

OK

B.4.5

Confirm that the all alternative scenarios arerealistic and credible in the context of the PA.

Para.90

OK

B.4.6

Confirm that the baseline scenario is determined using conservative assumtions.

Confirm that the PDD provides the description of the identified baseline scenario, including a description of the technology
that would be employed and/or the activities that would take place in the absence of the PA.
Confirm that the relevant national and/or sectoral policies, macro-economic trends and political aspirations are taken into
account sufficiently for the baseline scenario?
Confirm that the following two (2) types of national and/or sectoral policies have been taken into account.
(1) Type E+: Increase GHG emissions for technologies or fuels by National policies or regulations.
Have the E+ policies or regulations been implemented before adoption of the Kyoto Protocol by the COP (decision
1/CP.3, 11 December 1997) .
If yes, baseline scenario is not realistic.

Para.91

OK

Para.92

OK

Para. 93

No OK

Para.93

OK

B.4.8

B.4.9

Page 3

CL-6

OK

B.4.3

B.4.7

CAR,
CL, No.

OK

Establishment and description of baseline scenario (PDD GL, Para.88-93)

Confirm that the explanation is indicated in PDD on how the baseline scenario is established in accordance with the selected
methodology.
Confirm that the full description of the technology of the baseline scenario is indicated in section A.3 of PDD adquetely.

(OK/No/NA/Tbv)
Check
Comment

--

CL-7

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

B.5.
B.5.1
B.5.2

B.5.3

B.5.4

B.5.1
B.5.1.1

B.5.1.2
B.5.1.3

Requirement

Reference
Para. VVS

(2) Type E-: Decrease GHG emissions for technologies or fuels by National policies or regulations.
Have the E- policies or regulations been implemented since the adoption by the COP of the CDM M&P (decision
17/CP.7, 11 November 2001).
If yes, baseline scenario is not realistic.

Para.93

(1)
(2)
(3)
(4)

(5)

(OK/No/NA/Tbv)
Check
Comment

If yes, confimr that it is in line with the methodology.

Confirm that the reliability and credibility of all data, rationales, assumptions, justifications and documentation provided by
the PP to support the demonstration of additionality are assessed using local knowledge and sectoral and financial
expertise.
If required by the applicable methodology, confirm that the tools and guidelines to demonstrate are considered for the
additionality of proposed PA, and also confirm that .the specific complementary or alternative requirements included in the
methodology for demonstrating the additionality.

Para. 101

OK

PDD GL

OK

If yes, have the CDM benefits been considered as necessary in the decision to undertake the project as a proposed CDM
PA?
Confirm that the start date of the PA in the PDD is the earliest date at which either the implementation or construction or real
action of a PA begins.
Confirm whether the construction, retrofit or other modifications are required for the PA.

Confirm that the start date of the PA in the PDD can be selected for a case among the following three cases.
Case-1 : Start date in the period in 2 August 2008 to September 11, 2011
Confirm that the Nofitificationfrom (within 180 days) from Host Patry DNA and/or UNFCCC sectetariart have been
confirmed.
Case-2 : Start date after September 11, 2011
Confirm that the Nofitification (within 180 days) from Host Patry DNA and UNFCCC sectetariart has been confirmed.
Case-1&2 : Start date on/after 2 August 2008
Confirm that the project is appeared in the list of prior consideration notification on UNFCCC website, in case the start date
of the project on or after 2 August 2008.
Case-3 : Start date : Before 2 August 2008
Confirm that the following evidences are provided.
(a) The PP had an awareness of the CDM prior to the PA start date, and that the benefits of the CDM were a decisive
factor in the decision to proceed with the project. Evidence to support this could include, inter alia:
Minutes and/or notes related to the consideration of the decision by the Board of Directors, or equivalent, of the
PP, to undertake the project as a proposed CDM PA.
(b) The PP demonstrated that real and continuing actions were taken to secure CDM status for the project in parallel with
its implementation. Evidence to support this could include one or more of the following:
contracts with consultants for CDM/PDD/methodology services

Page 4

--

OK
Para. 102

OK

Para. 103

OK

--

Assessment of prior consideration of the clean development mechanism (Para. 105-112)

Confirm whether the the start date of PA is prior to the date of publication of the PDD for GSC.

CAR,
CL, No.

OK

--

Demonstration of additionality
Confirm that the additionality for the PA is demonstrated adquately in the PDD in accordance with the selected
methodology.
Confimr whether the PP uses the Tool for the demonstration and assessment of additionality.

Para. 105

--

OK
OK

Para. 106

OK

Para. 106

OK
OK

If yes, has it confimed that the date of commissioning cannot be considered as the PA start date?
B.5.1.4

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

Para. 107

No OK

EB41
Annex 46

OK

EB49
Annex22

No OK

Para. 107

OK

Para. 108

OK
OK
OK
OK

CL-8

CL-10

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

Reference
Para. VVS

Requirement

B.5.1.5
B.5.1.6
(a)

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

draft versions of PDDs

underlying documents such as letters of authorization, if available letter of intent
emission reduction purchase agreements (ERPA) term sheets
ERPAs or other documentation related to the potential sale of the certified emission reductions (CERs) (including
correspondence with multilateral financial institutions or carbon funds)
evidence of agreements or negotiations with a DOE for validation services,
submission of a new methodology or requests for clarification
revision of existing methodologies to the Board
publication in a newspaper
interviews with the DNA
earlier correspondence on the project with the DNA or the secretariat.
Confirm that the reliability and authenticity of above information such as letters, e-mail exchanges and other documented
communications submitted by the PP have been assessed through cross-checking (e.g. interviews).
Confirm that the following gap in timeline is ensured with the evidences?
(a) Gap <2years :There is less than two years of a gap between the documented evidence, the continuing and real actions
were taken to secure CDM status for the PA;

(OK/No/NA/Tbv)
Check
Comment
OK
OK
OK
OK
OK
OK
OK
OK
OK
OK

Para. 109

No OK

Para. 110

OK

(b) Gap >2 years, <3years :The gap between documented evidence is greater than two years and less than three years,
the DOE may determine that continuing and real actions were taken to secure CDM status for the PA and shall justify
any positive or negative validation opinion based on the context of the evidence and information assessed;

OK

(c)

(c) Gap >3years :The gap between documented evidence is greater than three years, the DOE shall conclude that
continuing and real actions were not taken to secure CDM status for the PA.

OK

Confirm that the evidence to support the serious prior consideration of the CDM as indicated above is available.
If not, determine that the CDM was not considered in the decision to implement the PA.

B.5.2

Identification of alternatives (Para. 113-116)

B.5.2.1

Confirm that the baseline scenario is prescribed in the methodology selected by the CDM PA.

B.5.2.2

If no (no prescribed baseline scenarion), confirm that the PDD identified credible alternatives to the PA in order to determine
the most realistic baseline scenario.
Confirm that the list of alternatives given in the PDD have been assessed and determined by considering the following
conditions.

Para. 111

Para. 113

No OK
OK

CL-9

--

--

OK
OK

Para. 114

OK

i. The list of alternatives includes the option that the PA is undertaken without being registered as CDM PA.

OK

ii. The list contains all plausible alternatives that are considered to be viable means of supplying the outputs or services
that are to be supplied by the proposed CDM PA on the basis of local and sectoral knowledge.

OK

iii. The alternatives comply with all applicable and enforced legislation.

OK

--

B.5.3

Investment analysis (Para. 117-123)

B.5.3.1

Confirm whether the investment analysis is used to demonstrate the additionality of the CDM PA.

Para. 117

OK

B.5.3.2

Confirm that the latest version of the Guidelines on the assessment of investment analysis been applied for assessment.

Para. 118

OK

Page 5

CL-11

OK

(b)

B.5.1.7

CAR,
CL, No.

--

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

Requirement

Reference
Para. VVS

B.5.3.3

<Alternatives >
Confirm that the PA is not the most economically or financially attractive alternative, or that it is not economically or
financially feasible without CDM.

Para. 119

(a)

(b)
(c)
B.5.3.4
(a)

(b)

(b) Confirm that the parameters are cross-checked against third-party or publicly available sources, such as invoices or price
indices.

(c)

(c) Confirm that the FSR, public announcements and annual financial reports related to the PA and the PP are as
appropriate.

(d)

(d) Confirm that the correctness of computations carried out and documented by thePP are adequate.

(e)

Para. 120

(a) Confirm that the type of benchmark applied is suitable for the type of financial indicator presented.

(b)

(b) Confim that risk premiums applied in determining the benchmark reflect the risks associated with the project type or
activity.
(c) Confirm that it is reasonable to assume that no investment would be made at a rate of return lower than the benchmark.

(c)
B.5.3.6
B.5.3.7
(a)

(b)
(c)

<FSR >
Confirm that the PP rely on values from FSR that are approved by national authorities for PA.
If yes, confirm the suitability of values from FSR with the following means of validation.
(a.1) Confirm that the FSR is the basis for the decision to proceed with the investment in the project.
(a.1) Confirm that the period of time between the finalization of the FSR and the investment decision is sufficiently short.
(a.1) Confirm that it is unlikely in the context of the underlying PA that the input values would have materially changed..
(b) Confirm that the values used in the PDD and associated annexes are fully consistent with the FSR.
If no, (the inconsistencies occurred), confirm that the appropriateness of the values in PDD is assessed.
(c.1) Confirm that the input values from the FSR are valid and applicable at the time of investment decision.

Page 6

No OK

CAR-4

No OK
No OK
No OK

CL-15
CL-17
CL-18

OK
No OK
No OK
No OK

CL-13
CL-14
CL-20

OK
No OK
OK
No OK
OK

(e.3) Confirm that the likelihood of the conditions for variations in sensitivity analysis are adequate.

(a)

OK

OK
OK

(e.1) Confirm that the suitablity of selected variations in sensitivity analysis is adequate.

<Bench mark>
Confirm that the suitability of benchmark applied in the investment analys is confirmed with the following means.

CAR,
CL, No.

OK

(e.2) Confirm that the suitablity of conditions and ranges for selected variations in sensitivity analysis are adequate.

B.5.3.5

(OK/No/NA/Tbv)
Check
Comment

OK

(a) Confirm that the PA would produce no financial or economic benefits other than CDM-related income.
Confirm that the costs for the PA were documented.
Confim that there is at least one alternative which is less costly than the PA.
(b) Confirm that the PA is less economically or financially attractive than at least one other credible and realistic alternative.
(c) Confrm that the financial returns of the proposed PA would be insufficient to justify the required investment.
<Accuracy >
Confirm that the accuracy of financial calculations for investment analysis was verified with the following means of validation.
(a.1) Confim that the suitability of the financial indicator selected by the PP is assessed.
(a.2) Confirm that thorough assessment of all parameters and assumptions used in calculating such financial indicators was
conducted.
(a.3) Confirm that the accuracy and suitability of these parameters were determined using available evidence and expertise
in relevant accounting practices.

JCI-CDM-VAL-11-183
ver.05

Para. 121

CL-16
CL-19

OK
OK
OK
OK

Para. 122

OK
No OK
OK
OK
OK
OK
OK
No OK

CL-27

CL-12

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

Reference
Para. VVS

Requirement
(c.2) Confirm that this is confirmed on the basis of specific local and sectoral expertise, by cross-checking or other
appropriate means.

Barrier analysis (Para. 124-127)

B.5.4.1

Confirm that barrier analysis is used to demonstrate the additionality of the proposed CDM PA.

(a)

If yes (barrier analysis is used),

Confirm whether the PA faces barriers that:
(a) prevent the implementation of this type of proposed PA.

(b)

(b) do not prevent the implementation of at least one of the alternatives..

B.5.4.3
(a)
(b)
B.5.4.4
(a)

(b)

(OK/No/NA/Tbv)
Check
Comment

Para. 124

OK

Para. 124

OK

--

OK
OK

Confirm whether there are issues that have direct impact on the financial returns of the PA other than:

Para. 125

(a) risk related barriers, for example risk of technical failure, that could have negative effects on financial performance.
(b) barriers related to the unavailability of sources of finance for thePA.
If yes, confime that these issues cannot be considered as barrires and shall be assessed by investment analysis.
Confirm that following two-step process are applied to assessing the barrier analysis .
(a) Confirm that the barriers are real through the following means.
Confirm that the barriers listed in the PDD exist by using the available evidence and/or conducting interviews with
relevant individuals (including members of industry associations, government officials or local experts if necessary).
Confirm that the existence of barriers is substantiated by independent sources of data such as relevant national
legislation, surveys of local conditions and national or international statistics.
Confirm that the existence of a barrier is substantiated only by the opinions of the project participants.
If yes, this barrier can not be considered as adequately substantiated.
- If it is considered, on the basis of its sectoral or local expertise, that a barrier is not real or is not supported by
sufficient evidence, confirm that it shall raise a CAR to have reference to this barrier removed from the project
documentation.
(b) Confirm that the barriers prevent the implementation of the PA but not the implementation of at least one of the possible
alternatives:through the following means.
Confirm, by appling the local and sectoral expertise, that a barrier or set of barriers would prevent the implementation
of the PA.
Confirm that a barrier or set of barriers would not equally prevent implementation of at least one of the possible
alternatives, in particular the identified baseline scenario.

OK
OK
OK

Para. 126

OK
OK
OK
OK
OK
OK

Para. 126

OK
OK
OK

B.5.5

Common practice analysis (Para. 128-130)

B.5.5.1

Confirm that a common practice analysis is used to demonstrate the additionality of the proposed CDM PA.

Para. 128

OK

B.5.5.2

If yes (a common practice analysis is used),

Para. 129

OK
OK
OK

(a)

CAR,
CL, No.

OK

--

B.5.4

B.5.4.2

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

--

Confirm that the PP have conducted a common practice analysis.

(a) Confirm, by using official sources and local and sectoral expertise, that:
the geographical scope (e.g. the defined region) of the common practice analysis is appropriate for the assessment of
common practice related to the PAs technology or industry type.
for certain technologies, the relevant region for assessment will be local and for others it may be transnational/global.
the defined region other than the entire host country was chosen.

OK
OK
OK
OK

If, yes confirm that the explanation of why this region is more appropriate.

Page 7

--

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.
(b)
(c)

B.5.5.3
B.5.5.4

Reference
Para. VVS

Requirement
(b) Confirm that similar and operational projects (e.g. using similar technology or practice), other than project activities, have
been undertaken in the defined region.
(c) Confirm that similar and operational projects, other than project activities, are already widely observed and commonly
carried out in the defined region.
If yes for above (b) or (C), confirm that there are essential distinctions between the proposed PA and the other similar
activities.

B.6.

B.6.1.1
B.6.1.2
B.6.1.3
B.6.1.4
B.6.1.5
B.6.1.6
B.6.1.7

Guideline

OK

Confirm that the stepwise approach for Common Practice in the Guideline is applied as follows.

Common
Practice

OK

Step 1: Calculate applicable output range as +/-50% of the design output or capacity of the PA.

OK

Step 2: In the applicable geographical area, identify all plants that deliver the same output or capacity, within the
applicable output range calculated in Step 1, as the PA and have started commercial operation before the start date
of the project.
Note their number Nall. Registered CDM project activities shall not be included in this step.

OK

OK
OK
OK

---

Emission reductions:
Explanation of methodological choices:

Confirm that data and parameters will not be monitored and will remain fixed throughout the crediting period.
If yes, confirm that;
all data sources and assumptions are appropriate.
calculations are correct as applicable to the PA.
Confirm that data and parameters will be monitored or estimated on implementation and hence become available only after

Page 8

CL-21

OK

Confirm that the common practice analysis is assessed by applling the latest version of Guideline for Common Practice.

Confirm that the explanation was indicated on how the methods or methodological steps in the selected methodology are
applied for calculating baseline emissions, project emissions, leakage and emission reductions.
Confirm that the steps taken and the equations and parameters applied in the PDD to calculate project emissions, baseline
emissions, leakage and emission reductions comply with the requirements of the selected methodology including applicable
tool.
Confirm that it is clearly stated in the PDD that the proper equations are used in calculating emission reductions.
Confirm that the methodology allows for selection between options for equations or parameters.
If yes, confirm that adequate justification has been provided for selection. (based on the choice of the baseline scenario,
context of the PA and other evidence provided) .
Confirm that the correct equations and parameters have been used, in accordance with the methodology selected including
applicable tool.
Confirm that the justification given in the PDD for the choice of data and parameters used in the equations is appropriate.

CAR,
CL, No.

OK

PDD GL

OK

Para. 96

OK

PDD GL

OK

Para. 97

OK

Para. 97

OK

Para. 98

OK
OK

Para. 98

OK

will result in an accurate or otherwise conservative estimate of the emission reductions.

B.6.1.8

(OK/No/NA/Tbv)
Check
Comment
No OK

Step 3: Within plants identified in Step 2, identify those that apply technologies different that the technology applied in
the proposed PA.
Note their number Ndiff.
Step 4: Calculate factor F=1-Ndiff/Nall representing the share of plants using technology similar to the technology used in
the proposed PA in all plants that deliver the same output or capacity as the proposed PA.
The proposed PA is a common practice within a sector in the applicable geographical area, if the factor F is greater
than 0.2 and Nall-Ndiff is greater than 3.

B.6.1.

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

Para. 98

OK
OK
OK

---

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

Reference
Para. VVS

Requirement

(OK/No/NA/Tbv)
Check
Comment

CAR,
CL, No.

validation of the PA.

OK

If yes, confirm that the estimates provided in the PDD for these data and parameters are reasonable.

--

B.6.2.

Data and parameters fixed ex ante

B.6.2.1

Confirm that the compilation of information is indicated in the tables on the data and parameters that are not monitored
during the crediting period?

B.6.3.

Ex ante calculation of emission reductions:

PDD GL

--

PDD GL

No OK

CL-28

PDD GL

OK
No OK
OK

CAR-3

--

--

B.6.3.2
B.6.3.3

Confirm that the relevant electronic spreadsheets for ex ante calculation are provided.

PDD GL

B.6.3.4

Confirm that the additional background information and/or data are described in Appendix 4 adequately.

PDD GL

B.6.4.

Summary of the ex ante estimation of emission reductions:

B.6.4.1
B.6.4.2

B.7.

Confirm that the summary of the results of the ex ante estimation of emission reductions for all years of the crediting period
is provided in the specified Table adequately.
Confirm that the crediting year and periods in the Table are consistent with those indicated in C.2.2. and C.2.3..

PDD GL

OK

PDD GL

OK

--

Monitoring plan

B.7.0.1

Confirm that the detailed description of the monitoring plan of the PA is developed in accordance with the monitoring
requirements of the selected methodology is provided in sections B.7.1, B.7.2 and B.7.3.

B.7.0.2

Confirm that the following two-step process is applied to assess compliance with the requirement of methodology.

(a)

(a) Confirm the compliance of the monitoring plan with the approved methodology and the applicable tool,

PDD GL
Para. 131

OK

Para. 132

OK

(i) Confirm that the list of parameters required by the selected approved methodology including applicable tool by means
of document review are Identified.

No OK

--

CL-29

OK

(ii) Confirm that the description of the monitoring plan contains all necessary parameters.

(b)

OK

--

Confirm that the transparent ex ante calculation of baseline emissions, project emissions (or, where applicable, direct
calculation of emission reductions) and leakage expected during the crediting period is provided.
Confirm that the sample calculation for each equation used, substituting the values used in the equations is provided.

B.6.3.1

--

(iii) Confirm that the means of monitoring described in the plan complies with the requirements of the methodology
including applicable tool.
(b) Confirm the implementation of the plan,

OK
OK
No OK

by means of review of the documented procedures.

by the interviews with relevant personnel.

CL-23

OK

by any physical inspection of the project site.

OK
No OK

(i) Confim that the monitoring arrangements described in the monitoring plan are feasible within the project design.
(ii) Confim that the means of implementation of the monitoring plan, including the data management and quality assurance
and quality control procedures, are sufficient to ensure that the emission reductions achieved by/resulting from the PA
can be reported ex post and verified.

OK

--

B.7.1.

Data and parameters to be monitored

B.7.1.1

Confirm that the specific information on how the data and parameters that need to be monitored would actually be collected
during monitoring is indicated in the tables in Section B.7.1. of PDD adequately.

Page 9

CL-22

PDD GL

OK

--

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

Reference
Para. VVS

Requirement

B.7.1.2

Confirm that any relevant further background documentation is provided in Appendix 5.

B.7.2.

Sampling plan

B.7.2.1

Confirm that the description of the sampling plan is provided in Section B.7.2. of PDD.
(If data and parameters monitored in section B.7.1 are to be determined by a sampling approach)

B.7.3.

Other elements of monitoring plan

B.7.3.1
B.7.3.2
B.7.3.3

C.

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

PDD GL

(OK/No/NA/Tbv)
Check
Comment
OK

-PDD GL

Confirm that the responsibilities and institutional arrangements for data collection and archiving are indicated in Section
B.7.3. of PDD.

--

OK
OK

Confirm that the operational and management structure including project operator in order to monitor emission reductions
are described in Section B.7.3. of PDD.
Confirm that the will implement and any leakage generated by the PA is described.

CAR,
CL, No.

PDD GL

OK

PDD GL

OK

PDD GL

--

--

Duration and crediting period

OK

--

C.1.

Duration of PA

OK

--

--

--

C.1.1.

Start date of PA

C.1.1.1

Confirm that the start date of the project is stated in the format of DD/MM/YYYY in Section C1.1. of PDD.

PDD GL

OK

C.1.1.2

Confirm that the description is provided on how the date has been determined.

PDD GL

OK

C.1.1.3

Confirm that the start date of the project is consistent with that in the Table in B.6.4..

PDD GL

OK

C.1.2.

Expected operational lifetime of PA

OK

C.1.2

Confirm that the expected operational lifetime of the project is stated in years and months in Section C1.2. of PDD.

C.2.

PDD GL

--

OK

Crediting period of PA

OK

--

C.2.1.

Type of crediting period

--

C.2.1.1

Confirm whether the type of crediting period of the project is stated as renewable or fixed in Section C2.1. of PDD.

PDD GL

C.2.1.2

For a renewable crediting period, confirm whether it is indicated the first, second or third.

PDD GL

OK
OK
OK
OK

C.2.2.

Start date of crediting period

OK

--

C.2.2

C.2.3.
C.2.3

D.
D.1.

Confirm that the start date of crediting period of the project is stated in the format of DD/MM/YYYY in Section C2.2. of PDD.

PDD GL

Length of crediting period

OK
OK

Confirm that the length of the crediting period of the project is stated in years and months in Section C.2.3. of PDD.

PDD GL

Environmental impacts

OK

--

Analysis of the environmental impacts

OK

--

D.1.1

Confirm that the PP has conducted an analysis of the environmental impacts of the PA, including trans boundary impacts,

Para. 134

--

D.1.2

Determine that those impacts are considered significant by the project participants or the host Party.
Confirm that the summary of the an analysis of the environmental impacts of the project is provided in Section D.1. of PDD
adequately.

Para. 134

OK

PDD GL

OK

D.1.3

--

--

Page 10

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

D.2.

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

Reference
Para. VVS

Requirement

(OK/No/NA/Tbv)
Check
Comment

--

Environmental impact assessment (EIA)

D.2.1

Confirm that the conclusions of an environmental impact assessment (EIA) are provided in Section D.2. of PDD adequately.

PDD GL

D.2.2

Confirm that the EIA is required by the host Party, in accordance with the host Partys procedures.
Confirm that the requirement for the EIA is confimed by means of a document review and/or using local official sources and
expertise.

Para. 135

No OK
OK

Para. 136

OK

D.2.3

E.
E.1.

Local stakeholder consultation

Solicitation of comments from local stakeholders

CAR,
CL, No.
-CL-24

---

--

CL-25

--

PDD GL

No OK

E.1.2

Confirm that the process, by which comments from local stakeholders have been invited for the project is described in
Section E.1. of PDD.
Confirm that the PP has completed a local stakeholder consultation process.

Para. 138

E.1.3

Confirm that the due steps were taken to engage stakeholders and solicit comments for the PA.

Para. 138

OK
OK

E.1.4

Confirm, by means of document review and interviews with local stakeholders as appropriate, that :
(a) comments have been invited from local stakeholders that are relevant for the PA.

Para. 139

No OK

CL-26

E.2.

Summary of comments received

--

--

E.2.1

Confirm that the stakeholders are identified that have made comments and a summary of these comments provide.

E.1.1

E.2.2

Confirm that the summary of comments from identified stakeholders is provided in Section E.2. of PDD adequately?

PDD GL
PDD GL
Para. 139

OK

Para. 139

OK

Confirm, by means of document review and interviews with local stakeholders as appropriate, that :
E.2.3

E.3.

(b) the summary of the comments received is provided in the PDD is complete.

--

Report on consideration of comments received

Confirm, by means of document review and interviews with local stakeholders as appropriate, that :

E.3.1

F.
F. 1

OK

(c) the PP has taken due account of all comments received and have described this process in the PDD.

Para. 139

Approval and authorization (LoA)

Confirm that the LoA from Party for the PA is available at the time of submitting the PDD to the validating DOE.

PDD GL

OK

--

--

No OK

CAR-1

OK

If yes, confirm that the LoA is provided along with the PDD.
F.2

Confirm that the DNA of each Party indicated in the PDD has provided a written LoA..

Para. 38

OK

F.3

Confirm that the following subjects have been identified in each LoA. :
(a) The Party is a Party to the Kyoto Protocol/
(b) Participation is voluntary/
(c) In the case of the host Party, the proposed PA contributes to the sustainable development of the country.
(d) It refers to the precise proposed PA title in the PDD being submitted for registration.

Para. 39

F.4

Confirm that the LoA of approval is unconditional with respect to paragraph 39 (a) to (d) above..

Para. 40

F.5

Confirm that the LoA is valid for the PA under validation.

Para. 41

F.6

Confirm that the authenticity of the LoA is confirmed through the DNA website or other means.

Para. 42

F.7

Confirm that the each PP has been authorized by at least one Party involved in LoA.

Para. 45

OK
OK
OK
OK
OK
OK
OK
OK
OK

Page 11

--

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

Requirement

Reference
Para. VVS

F.8

Confirm that the approval of participation has been issued from the relevant DNA.
Confirm that the the LoA by the DNA of the host Party has confirmed the contribution of the CDM PA to the sustainable
development of the host Party.

Para. 48

F.9

G.1
G.2

G.3

G.4

G.5

Para. 50, 51

When the identity to be validated by applying paragraph 54 (c) above, confirm that the MoC statement is received from a PP
with whom the DOE has a contractual relationship.
For CDM PoAs, confirm that the MoC statement is received from the CME.
When the identity to be validated by applying paragraph 54 (c) above, confirm that the official who submits the MoC
statement to the DOE and the official who signed the written confirmation (if a different person) is/are duly authorized to do
so on behalf of the respective PP or CME.
If the evidences shown in above paragraph 54 (a), (b) or (c) are unable to apply for validation, confirm that the corporate
and personal details, employment status and specimen signatures included in the MoC statement are valid and accurate
and comply with the requirements of this section.

Para. 53

No OK

CAR-2

OK
OK
OK
OK

Para. 55

OK

Para. 56

OK

Para. 57

OK

OK
OK

Modalities of communications statement Validation requirement (Para. 59-61)

--

G.7
(a)

Confirm that;

Para. 60

H.1
H.2
Appendix
1
AP.1.1

OK

Para. 54

Para. 59

(a) the latest version of the form .Modalities of Communication statement. (F-CDM-MOC) has been used.

OK

(b) the information required as per the F-CDM-MOC, including its annex 1, is correctly completed.
(c) the project participants authorized signatories signing the F-CDM-MOC correspond to the project participants
authorized signatories included in F-CDM-MOC, annex 1.

OK

-Para. 34

OK

Para. 35

OK

Contact information of project participants

--

Confirm that the table is completed, for each organization listed in section A.4, with the following mandatory fields.
Organization
Street/P.O. Box
City, Postcode
Country, Telephone
Fax,
e-mail

Page 12

--

OK

Global stakeholder consultation

Confirm that the receipt of all comments on the PDD of the PA is submitted in accordance with the Project cycle procedure
been acknowledged.
Confirm that all comments on the PDD received during the validation are taken into account.

CAR,
CL, No.

--

Confirm that the MoC statement has been correctly completed and duly authorized..

(c)

(OK/No/NA/Tbv)
Check
Comment
OK

--

Modalities of communications (MoC) (Para. 53-58)

Confirm that the corporate identity of all PPs and focal points are included in the MoC statement, as well as the personal
identities, including specimen signatures and employment status, of their authorized signatories.
Confirm that the MoC statement in the paragraph 53 above have been validated through following evidences.:
(a) Directly checking evidence for corporate, personal identity and other relevant documentation
(b) Notarized documentation; or
(c) Written confirmation from the PP or the CME, for the MoC statement that all corporate and personal details, including
specimen signatures, are valid and accurate.

G.6

(b)

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

PDD GL

OK
OK
OK
OK
OK
OK
OK

--

--

JCI CDM Center

Appendix A

TABLE-1 REQUIREMENTS CHECKLIST

PDD
No.

AP.2.1
Appendix
3
AP.3.1
Appendix
4
AP.4.1
Appendix
5
AP.5.1
Appendix
6
AP.6.1

Reference
Para. VVS

Requirement

Appendix
2

JCI-CDM-VAL-11-183
ver.05

CDM Validation Protocol for Kipeto Wind Energy Project

Name of contact person

Affirmation regarding public funding

(OK/No/NA/Tbv)
Check
Comment
OK
--

Confirm that the project funding is not applied for diversification of Official Development Assistance.

PDD GL

OK

If applicable, has the affirmation obtained from Parties providing public funding to the PA been attached?

PDD GL

OK

Applicability of the selected methodology(ies)

--

Confirm that the further background information on the applicability of the selected methodology is provided.

PDD GL

Further background information on ex ante calculation of emission reductions

Confirm that the further background information on the ex ante calculation of emission reductions is provided. This may
include data, measurement results, data sources, etc.

Further background information on monitoring plan

PDD GL

Summary of post registration changes

PDD GL

Page 13

--

--

OK
--

Confirm that the summary of the post registration changes is provided.

--

OK
--

Confirm that the further background information used in the development of the monitoring plan is provided.. This may
include tables with time series data, additional documentation of measurement equipment, procedures, etc.

--

OK
--

PDD GL

CAR,
CL, No.

OK

--

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

Clarifications and corrective action requests by

validation team

CAR

Corrective Action Requests

CAR
-1

LoA of Kenya (host country) shall be provided to JCI if those

are issued.
It is required to clarify that the project is a unilateral project
or the Annex 1 county will be determined within validation
period.

CAR
-2

CAR
-3

Sec.
No. in
TABLE
-1

F.1

MoC from the Project Participant shall be provided.

Summary of project owner response

Kipeto Energy has requested the issuance of the host countrys

Letter of Approval (LoA) on the 11/05/2012 from Kenyas DNA
(NEMA). The LoA has been issued on the 3rd September 2012 and
has been provided to JCI. The project is a unilateral project. Thus
non ANNEX I party has been included as a project participant.

LoA of Kenya has issued

on 03/09/2012.
It has been confirmed
that the project was
unilateral.

The MoC has been provided to JCI.

CAR-1 was resolved and

closed.
MoC has provided to JCI.

The active spread sheet for ER calculation has been provided to JCI
on 13/06/2011 and has been resend.

CAR-2 was resolved and

closed.
The final version has
provided on 08/12/2012.

The active spread sheet for IRR calculation has been provided to
JCI on 13/06/2011 and has been resend.

CAR-3 was resolved and

closed.
The final version has
provided on 08/12/2012.

G.1.
The active spread sheet for ER calculation shall be provided
to JCI.

Validation team
Conclusion

B.6.3.3

CAR
-4

The active spread sheet for IRR calculation of investment

analysis shall be provided to JCI.
B.5.3.4

CAR-4 was resolved and

closed.

Page 14

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

CL

Clarifications and corrective action requests by

validation team

Sec.
No. in
TABLE
-1

Validation team
Conclusion

Clarification Requests
In A.1 it is described that the project will reduce the
consumer price of electricity. It is difficult for the reader to
understand it since the power generation cost of wind power
is usually higher than that of the thermal power. So some
additional explanation is required such that, e.g., a wind
power is supported by a subsidy from the government.

CL
-1

CL
-2

Summary of project owner response

A.1.5

In A.1 two referential documents are shown in the footnotes

of 3 and 4. Those documents shall be submitted to JCI. In
case that those are big documents, only the related portion
to the project shall be provided.

The electricity price in Kenya has been increased during the recent
years mainly due to the usage of expensive fossil fuel based
emergency power.
The usage of fossil fuels directly affects the end user due to the fact
that the utility company is allowed to charge their customers fuel oil
cost adjustment (FOCA), a foreign exchange rate fluctuations
adjustment (FERFA) and an inflation adjustment in addition to the
fixed retail tariff.
The calculation of the electricity prices are indicated in the Schedule
of Tariffs for Supply of Electricity. As indicated on the report of
Department of Energy, a main objective of the Government of
Kenya is the reduction of dependence on imported oil due to the
implementation of renewable energies like the implementation of
530 MW of wind power. The proposed wind power plant will
therefore contribute to meet the growing electricity demand and to
substitute the temporary emergency power. Thus, the fuel cost
charge will be reduced due to the substitution of fossil fuel based
electricity The costs per kWh of diesel and wind power in Kenya can
be compared in the report of DOE.
Footnotes 3 and 4 are provided to JCI.

It has been clarified.

CL-1 was resolved and
closed.

Those have been

provided.

A.1.5
CL-2 was resolved and
closed.

Page 15

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

Clarifications and corrective action requests by

validation team

Sec.
No. in
TABLE
-1

The gross energy production of 469,690 MWh and net energy

production of 410,476 MWh respectively have been derived from the
Wind Report /5/ taking into consideration a layout consisting of 47
GE 1.6-100 and 16 GE 1.6-82.5 turbines. The net energy production
has been based on the turbine layout at that time. The wind report
however considered 67 possible turbine locations for the 63 turbines
which will be implemented. The 410,476 MWh as net energy output
can be considered conservative since applying a average electricity
generation of 63 of the 67 turbines by dividing 436,254 MWh /5/ by
67 and multiplying by 63 would lead to an electricity generation of
410,209 MWh.

In A.3 the Table 3 reports that the gross energy production is

469,690 MWh and the net energy production is 410,476
MWh. And also the Table show that the net energy
production is calculated from the gross energy production
and 10 kinds of factors and/or efficiencies. The supply of
electricity to the Grid should be 410,476 MWh and then the
actual power generation of electricity just at wind turbine
outlet shall be clarified. And also the in-house power
consumption in the power station and the power loss in the
transmission line shall be clarified.

CL
-3

Summary of project owner response

The in house power consumption in the power station is included in

the losses due to electrical efficiency (4%). Losses due to the
transmission line are not relevant because the Point of Utility
Connection will be just behind the on-site substation (before the
transmission line).
A.3.1
However, during the validation the layout has been changed to 63
GE 1.6-100 wind turbines. Therefore the latest PDD version also
shows a gross energy production of 486,230 MWh and a net energy
production of 425,009 MWh taking into consideration the losses
based on the updated wind report /6/ and shown in the PDD. This
leads to a plant load factor of 47.5377%. The nominal energy
production stays constant, since the total installed capacity (MW)
has not been changed. It can be derived as follows: 102.06
MW*8760h. The gross nominal production has increased due to the
turbine change as described below in accordance with the GE 1.6100 turbine power curve, which achieves higher energy generation
than the GE 1.6-82.5. The values of 425,009 MWh can be derived
from the updated wind report by dividing the energy output of
451,993.5 by 67 and multiplying by 63. This is due to the fact, that
the wind report has been bases on 67 turbines due to the fact that 4
spare turbine locations have been considered in case some of the
locations would not be available.

Page 16

Validation team
Conclusion
It has been clarified.

CL-3 was resolved and

closed.

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

Clarifications and corrective action requests by

validation team

Sec.
No. in
TABLE
-1

In A.3 the Table 4 & 5 report the specifications of two wind

turbines; GE 1.6-82.5 and GE 1.6-100. The GE 1.6-100
machine has larger rotor diameter than the GE 1.6-82.5
machine, but both two machines are same nominal output of
1,620 kW. The reason shall be clarified.

CL
-4

CL
-5

CL
-6

As indicated in the product brochures GE 1.6-82.5 and GE 1.6-100,

the wind turbines are suitable for different wind speeds. Due to
different power curves, the GE 1.6-100 requires slightly lower wind
speeds to reach the nominal output capacity of 1.62 MW.

A.3.1

In A.3 the metering system is described that it will be located

on the 66 kV line on the project activity side of the bus bar
just after the step-up transformers. Those shall be clarified;
1) Do the step-up transformers mean the 33kV to 66kV
transformer?
2) Are the step-up transformers located in the same place
of the new 33kV/HV substation, or does the new
33kV/HV substation mean the new 33kV/66kW
substation?
3) What is the meaning of the Metering CTs and VTs?
4) What is the Meters type; bi-directional or not?

Summary of project owner response

A.3.1

During validation, project layout has been changed to 63 GE 1.6100 wind turbines for all 63-site locations. This is based, on a
mechanical loads analysis (MLA). The analysis considered both
fatigue and extreme loads. The MLA assessment is based on the
following input parameter: Wind rose and wind speed distribution,
turbulence intensity, flow inclination angle, extreme wind condition,
wind shear profile, air density, site information and the latest turbine
positions. The MLA, which has been issued by GE Energy on the
23/07/2012, indicates that the 1.6-100 wind turbine with a hub height
of 80m is suitable for the Kipeto project. Therefore the technical
description of the PDD has been updated accordingly to the new
turbine layout and additional explanation has been added to the
PDD as requested by the validator.
1) Yes, the metering system will be located on the 66 kV line just
behind the 33/66kV transformers (in order to include the losses due
to transforming) and before the transforming to 220 kV since the
Point of Utility Connection is located on a voltage of 66 kV.

Validation team
Conclusion
The original plant design
has clarified.
But the plant design has
been revised as
explained in the PDD
ver.02. It is requested to
add some explanation
regarding design change.
CL-4 was resolved and
closed.

Those have been

clarified.
CL-5 was resolved and
closed.

2) 33kV/HV substation means the new 33kV/66 kV substation.

Therefore the transformers and metering system will be installed
inside of the new on site substation. PDD has been amended to
avoid misunderstandings (PDD version 02).
3) CT and VT stands for current- and voltage transformers that form
part of the metering system.

In B.3 Figure 4 states clearly the extent of Project boundary

but does not state clearly the Project boundary.
B.3.2

4) Installed metering system will be bi-directional.

As indicated in figure 4, the project boundary (including all power
plants connected to the grid) is indicated by the whole figure. In
addition to that information, the project activity (including the wind
power plant and the on-site substation) is shown by the dashed
rectangle.

Page 17

The Figure has been

revised appropriately.
CL-6 was resolved and
closed.

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

CL
-7

CL
-8

CL
-9

CL
-10

CL
-11

Clarifications and corrective action requests by

validation team
In B.4 three referential documents are shown in the Kenyan
Power Sector Policies and Regulation; Electricity Power Act,
National Energy Policy and Feed-in-Tariff Policy. Those
documents shall be submitted to JCI. In case that those are
big documents, only the related portion to the project shall
be provided.
The detailed timeline to show the project progress shall be
provided to JCI in tabulated format specified by JCI.

Sec.
No. in
TABLE
-1

Summary of project owner response

References are provided to JCI as Feed-in-Tariff Policy, Electricity
Power Act and National Energy Policy.

B.4.8

Validation team
Conclusion
Those documents have
been provided.
CL-7 was resolved and
closed.

Template has been filled and provided to JCI.

The detailed timeline has

been provided.

B.5.1.4

In B.5 the Table 10 of Project timetable mentions about the

investment decision of the project owner on 08/09/2011. But
the feasibility study report based on the investment decision
is not mentioned. That information should be included in the
above detailed timeline. (See CL-12)

B.5.1.7

In B.5 the Table 10 reports that the Notification to the

UNFCCC is submitted but the Notification to the Kenya
DNA. It is requested to clarify that the Notification to the
Kenya DNA is submitted within 6 month after the project
activity start.

If the implementation of the project is approved by the

governmental organization, the documents for approval and
its approval letter shall be submitted to JCI.

B.5.1.4

B.5.1.5

The investment decision for the proposed project has been made on
the 08/09/11 at the directors board meeting /31/. This decision is
based on the mentioned wind assessment report /5/, which also
indicates the turbine layout and project cost quotes provided as
references. An overall feasibility study has not been carried out.
Thus the requested milestone has not been included in the table.

Kipeto Energy has notified the Kenyan DNA on the 14th of June
2011 by submitting the Prior Consideration as it can be seen under
the following link:
http://www.nema.go.ke/index.php?option=com_content&view=article
&catid=100&id=267
In addition Kipeto Energy has requested the LoA on the 11/05/2012.
The project start date, as indicated in the PDD version 01 is
01/12/12 and therefore notification of the host country DNA has
been made not more than 6 months after the project start date.
The project has been approved by the Ministry of Energy and has
also been approved by the National Environmental Management
Agency (NEMA).

Page 18

CL-8 was resolved and

closed.
The PDD has revised to
show the investment
decision at the directors
board meeting on
08/09/2011. The based
documents for decision
were reported in the PDD
ver.02.
CL-9 was resolved and
closed.
It has clarified. And the
Table 10 has revised to
add the date of
Notification submission to
Kenya DNA.
CL-10 was resolved and
closed.

It has clarified.
CL-11 was resolved and
closed.

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

CL
-12

CL
-13

CL
-14

CL
-15

Clarifications and corrective action requests by

validation team
In B.5 the Table 12 17 show the main parameters (input
values) used for the investment analysis in the PDD. The
Guideline in the Assessment of Investment Analysis
stipulates in Para. 6 that input value used in all investment
analysis should be valid and applicable at the time of the
investment decision taken by the project participant.
Therefore the timing of the investment decision and the
consistency and appropriateness of the input values with this
timing.
It is required to clarify that the main parameters (input
values) were valid and applicable at the time of the
investment decision. If there was any document showing the
main parameters at that time, the document such as FSR
and/or PDR shall be submitted to JCI.

In B.5 the Table 12 reports that the exchange rate USD/Euro

is 1.42 in accordance with Oanda (03.11.2011). But that
data in Oanda is 1.3741. It is required to clarify the
difference.

In B.5 three referential documents are shown in the footnote

F.N. 15; Monetary Policy Statement,
F.N. 17; Economic Projections of Federal
Reserve Board Members and Federal
Reserve Bank Presidents,
F.N. 19; GHG Market Sentiment Survey.
The documents shall be submitted to JCI. In case that those
are big documents, only the related portion to the project
shall be provided.
In B.5 the Table 16 shows 689,599 USD/y of Lease as
OPEX Item. The value is determined as 1.40 % of Tariff
revenue. It is required to clarify what kind of lease.

Sec.
No. in
TABLE
-1

Summary of project owner response

All input values were valid and applicable at the time of the
investment decision. The investment decision is not based on one
feasibility study taking into consideration all financial input values, it
is based on several project cost quotes provided as references and
the wind assessment report /5/.

B.5.3.7

B.5.3.4

However, during the validation the layout has been changed from a
mix of 47 GE 1.6-100 and 16 GE 1.6-100 turbines to 63 GE 1.6-100
wind turbines. Therefore the technical description has been updated
in accordance with the latest turbine layout. The date of investment
analysis has not been changed since the decision to investment in
the project and the consideration of the CDM has been made in
September 2011. However, in order to show that the additionality of
the project activity will not be negatively affected by the updated
turbine layout, the PDD version 03 shows IRRs and sensitivity
analysis for both layout scenarios.
Assumptions made in the financial model are based on
08.09.2011(date of investment decision as indicated in the PDD)
instead of 03.11.2011. Therefore the exchange rate is
1.4051USD/EUR. Table 12 of the PDD has shown the wrong date
(3/11/2011). Table 12 has therefore been corrected in PDD (version
02).

The documents will be provided to JCI as follows;

1)
2)

B.5.3.4

B.5.3.4

Monetary Policy Statement

Economic Projections of Federal
Reserve Board Members and Federal
Reserve Bank Presidents
3) GHG Market Sentiment Survey

The parameter lease means the land lease for the project area. The
parameter has been renamed to Land Lease in the PDD version
02 and the IRR calculations accordingly.

Page 19

Validation team
Conclusion
The PDD has revised to
show the investment
decision at the directors
board meeting on
08/09/2011, and to show
updated plant design.
The based documents for
investment decision have
been clarified. The
evidence has been
provided.
CL-12 was resolved and
closed.

The date of money

exchange rate has been
revised to the date of
investment decision
08/09/2011.
CL-13 was resolved and
closed.
Those documents have
been provided.
CL-14 was resolved and
closed.

It has been clarified.

CL-15 was resolved and
closed.

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

CL
-16

CL
-17

CL
-18

CL
-19

Clarifications and corrective action requests by

validation team
In B.5 the Table 18 shows that the equity IRR without CDM
revenues is 13.17 % and that with CDM is 19.88 %. But
those IRRs are not consistent with the spreadsheet for CDM
financial Model. It is required to clarify the difference.

Sec.
No. in
TABLE
-1

B.5.3.4

In B.5 the Table 19 and the Figure 8 show the results of

Sensitivity analysis. But those results are not consistent with
the spreadsheet for CDM financial Model. It is required to
clarify the difference. And the Figure 8 does not indicate the
horizontal graduation. And Evidential document of loan
agreement shall be provided to JCI.

It has been clarified.

The IRRs has been
revised finally to 14.41%
without CDM and 20.75%
with CDM revenues.

B.5.3.4

B.5.3.4

CL-17 was resolved and

closed.
It has been clarified.
And the evidence of GE
turbine fact sheets has
been provided.

Letter has been provided to JCI.

B.5.3.4

For cross check of the estimated total investment, the actual

cost of the project shall be provided before completion of
Validation Report.

CL
-20

PDD version 02 shows different values than the investment analysis

because the investment analysis has been corrected after the start
of GSC due to some mistakes in the IDC and principal calculation.
PDD (version 03) therefore shows the IRRs in accordance with the
turbine layout at the time of the investment decision and also a
scenario which takes into account the updated turbine layout.

Validation team
Conclusion

CL-16 was resolved and

closed.
The evidence has been
provided which is the
letter from CfC Stanbic
Bank.

In B.5 the Table 13 shows the interest rate is 10.00% for

project finance. It is required to clarify the validity of rate and
to submit the evidence.

In B.5 The depreciation period and the rate of scrap value

shall be clarified in the PDD. Those procedures to determine
shall be clarified and the evidences related shall be provided
to JCI.

Summary of project owner response

Straight line depreciation method has been applied for wind turbine
equipment a taking into account a depreciation period of 20 years
based on the turbine lifetime of 20 years stated in the GE turbine
fact sheets. Therefore it was assumed that the turbines will not have
a value after 20 years and hence the scrap value is assumed to be
zero.
PDD shows different values than the investment analysis because
the investment analysis has been corrected after the start of GSC.
PDD version 02 has been updated in line with the latest model and
a horizontal graduation has been included to the figure. Evidential
document for loan agreement is provided.
The project has not reached financial close yet. Therefore the
investment analysis is mainly based on several project cost quotes.
Updated actual costs can only be provided for the Project
Development Cost

B.5.3.4
If the project reaches financial close before the end of validation, the
PP will provide actual project cost. However, since the project cost
assumptions are based on quotes provided by external parties, it is
not expected that those cost will differ essentially.

Page 20

CL-18 was resolved and

closed.
It has been clarified. And
the evidence has been
provided.
CL-19 was resolved and
closed.
The required data and
evidences have been
provided to JCI.
CL-20 was resolved and
closed.

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

Clarifications and corrective action requests by

validation team

Sec.
No. in
TABLE
-1

In B.5 the Table 20 shows the similar project candidates for

common practice analysis and the selected similar project is
listed up unit by unit base. It is required to explain about
selection criteria.

CL
-21

CL
-22

CL
-23

CL
-24

Summary of project owner response

Common practice analysis has been adjusted in the PDD (version
02).

B.5.5.2

The sketch diagram for monitoring plan shall be added in

B.7.3 for easy understanding of the readers. The location of
Meters (project side or grid site) and the role of Meter shall
be shown clearly in the sketch. The layout drawing to show
the position of meters is shown in the B.7.3 but it is difficult
to understand the position.

Drawings will be provided to JCI during the validation periodrequired by Kipeto Energy.

B.7.0.2

The Monitoring Manual and Training Manual shall be

provided to JCI during the on-site assessment.

B.7.0.2

In D.1 the ESIA report shall be provided to JCI. And if there

is an approval by governmental organization, it shall be
submitted to JCI.

It is requested that the validators accept CL-23 as a Forward Action

Request as they will only be available in later stages of project
implementation, after registration as CDM project.

The ESIA licence granted by NEMA has been provided to JCI. The
ESIA report is provided to JCI.

D.2.1

Validation team
Conclusion
The Table 20 of PDD has
been revised
appropriately. The
original PDD was
prepared by list-up as
unit by unit base for
similar project. The
revised PDD was project
by project base
(investment decision
base).
CL-21 was resolved and
closed.
The PDD has been
revised to show the
metering equipment in
the single line diagram.
The evidence has been
provided.
CL-22 was resolved and
closed.
It has been clarified.
This item is concerted to
FAR-1.
CL-23 was closed.
The ESIA report and its
license have been
provided.
CL-24 was resolved and
closed.

Page 21

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

CL
-25

Clarifications and corrective action requests by

validation team
In E-1 the local stakeholder consultation is explained. The
evidential documents related to it shall be provided to JCI
during on-site assessment.

Sec.
No. in
TABLE
-1

Validation team
Conclusion

Evidential documents have been provided to JCI during the on-site

assessment as a hard copy. Soft copy is provided to JCI.

The documents have

been provided.

Questionnaire/answers will be provided to JCI during the on-site

assessment.

CL-25 was resolved and

closed.
The stakeholder
evaluation forms to show
the stakeholders
comments on the project
have been provided.

E.1.1

The questionnaire/answers will be reviewed by JCI during

the On-site Assessment.

CL
-26

Summary of project owner response

E.1.4

CL-26 was resolved and

closed.

Page 22

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

Clarifications and corrective action requests by

validation team

Sec.
No. in
TABLE
-1

In Page 5 the PDD mentions about the Mechanical Loads

Analysis. It is required to clarify difference from Wind
Assessment Report, Wind Power Feasibility Study Report
and Turbine Specification. The Mechanical Loads Analysis
might be conducted normally prior turbine selection. It is
required to clarify why it was carried out after turbine
selection in case of the project.

B.5.3.7

In B.6.3 the PDD reports that EFgrid,OM,y is 0.66 tCO2/MWh

and EFgrid,BM,y is 0.49 tCO2/MWh. It is requested to clarify the
reason of two decimals.

B6.3.1

CL
-27

CL
-28

Summary of project owner response

The wind assessment report/wind report has been issued in
September 2011 by Galetech Energy, assuming that the chosen
area/locations will not all be suitable for the GE 1.6-100 turbine.
Therefore for some of the locations the wind report considered the
GE 1.6-82.5 turbine. The MLA has not been carried out earlier since
the PP had a strong indication that the former turbine layout as
described in version 01 of the PDD would be suitable based on wind
speeds, turbulence and air density.
The Mechanical Load Analysis has been finalized by GE Energy on
23/07/2012. The analysis considered both fatigue and extreme
loads. The MLA is based on the following input parameter: Wind
rose and wind speed distribution, turbulence intensity, flow
inclination angle, extreme wind condition, wind shear profile, air
density, site information and the latest turbine positions. The MLA,
which has been issued by GE Energy on the 23/07/2012, indicates
that the 1.6-100 wind turbine with a hub height of 80m is suitable for
the Kipeto project. Therefore the PDD has been updated
accordingly.
The MLA is different from a wind assessment report, since it is not
assessing the wind speeds for the different turbine locations and is
also not presenting the related energy output. It is only assessing
the suitability of a specific turbine type, in our case the GE 1.6-100
for the different locations.
The Kipeto Wind Power Project Feasibility Study for Grid
Connection is assessing different options for the project activity to
connect to the KPLC grid but is however not related to turbine
suitability or wind/energy yield assessment.
The turbine specification provided by GE are additional references
provided which describe the technical specifications of the turbine
e.g. Hub height, blade length etc.
Version 03 of PDD shows four decimals instead of two for all EFCM,
EFOM and EFBM

Validation team
Conclusion
It has clarified
appropriately.
CL-27 was resolved and
closed.

The EF calculation
spread sheet and the
PDD have been revised
appropriately.
CL-28 was resolved and
closed.

Page 23

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

CL
-29

CL
-30

Clarifications and corrective action requests by

validation team
In B.7 Monitoring Plan, two monitoring items are added;
NCVi, y and EFCO2i,y in the revised PDD version 02. The
reason of additions shall be clarified.

The revised PDD dated 24/08/2012 has changed the Project

Participants from one company to three companies and then
the revised PDD dated 28/09/2012 has backed to one
company. The reason of extraordinary changes shall be
clarified.

Sec.
No. in
TABLE
-1

B.7.0.2

A.4.1

Summary of project owner response

The parameter NCVi,y and EFCO2i,y requires annually monitoring
since option (c) Dispatch data analysis OM has been chosen in
accordance with the Tool to calculate the emission factor for an
electricity system (02.2.1) in order to calculate the OM emission
factor. The fact that those parameter were not included in version 01
of the PDD has been a mistake,
The PDD which has been uploaded for GSC only incorporated
Kipeto Energy Limited as a PP. During the validation period, the
shareholders of Kipeto Energy decided to be additional Project
Participants. However, due to a misunderstanding the LoA has only
been issued in the name of Kipeto Energy Limited by the DNA.
Therefore, Kipeto Energy Limited is the sole PP in PDD version 03.

Page 24

Validation team
Conclusion
It has clarified
appropriately.
CL-29 was resolved and
closed.
It has clarified
appropriately.
CL-30 was resolved and
closed.

JCI CDM Center

Appendix A

CDM Validation Protocol for Kipeto Wind Energy Project

JCI-CDM-VAL-11-183
ver.05

TABLE-2 Resolution of Corrective Actions and Clarification Requests

No.
CAR,
CL

Clarifications and corrective action requests by

validation team

Sec.
No. in
TABLE
-1

The editorial matters;

1) Page 21. In the Table 10. What is JDA? And ---- (GE
Energy) and (?) Craftskills -----

CL
-31

2) Page 58 60. The data in Appendix 7 is better to insert

in Appendix 4.
3) Page 61 62. The data in Appendix 8 seems no need
for the PDD since UTM coordinates too detailed and
Figure 10 is not cleared and almost same as Figure 2.
4) Page 63 64.
a) The Table is not clear. It should be improved.
b) It is required to clarify the meaning of (+) and (-) in
the PDD for easy understanding of readers.
c) The kind of code (ACH1 and so on) should be
clarified in the PDD for easy understanding of
readers.
d) It is required to clarify in the PDD whether the
mitigation measures are required for the project and
whether those results will be assessed by the third
party during/after implementation.
5) Figure 1, Figure 8 and figure 9 of PDD ver02 cannot be
print out. Please check and revise the PDD.
6)
7)
8)

1)

2)
3)
4)

Page 9 of PDD ver02. In the second line of B.2 the

version number of ACM0002 should be 13.0.0.
Page 17-18 of PDD ver02. There are several Table
number mistakes in the descriptions.
Page 69 of PDD last page is blank. It should be deleted.

FAR

Forward Action Requests

FAR
-1

The Monitoring Manual and Training Manual shall be

prepared prior the operation start.

JDA stands for Joint Development Agreement. Kipeto Energy

Ltd has been formed due to a JDA by General Electric
International (Benelux) B.V and Craftskills Wind Energy
International Limited, a renewable energy development
company registered in Kenya.
Appendix 7 has been moved to Appendix 4
Changes have been made in PDD version 02 as requested.
a)
b)

A.1.6

B.7.0.2

Validation team
Conclusion

Summary of project owner response

Improved figures have been included in PDD (version 02)

(+) indicates a positive impact whereby (-) indicates a
negative impact. Explanation has been added to PDD
version 02.
c) The codes (ACH1 etc.) only indicate the dependency of the
impact to a specific section e.g. ACH1 = Archaeology and
Cultural Heritage, E1=Impacts on terrestrial vegetation as
also shown in figure 11 in column impact.
d) Mitigation measures are required for the project. Monitoring
will be carried out in line with the applicable NEMA
regulations.
5) Figure 1 has been adjusted to improve readability. Further
increase is not possible, since it is required not to exceed one page
for this particular section. Figure 8 Kenya Grid System has been
deleted. Please clarify issues on figure 9.
6) Has been corrected to ACM0002 version 13.0.0 in version 02 of
the PDD.
7) Corrections have been made in version 02 of the PDD

OK

OK
OK
OK

OK

OK

8) Last page has been deleted in version 02 of the PDD

OK
OK
CL-31 was resolved and
closed.

Those Manuals shall be prepared before the operation start.

It has clarified.

Page 25