Validation Report and Protocol - Rev3b
Validation Report and Protocol - Rev3b
VALIDATION REPORT
Date of first issue: Project No.: DET NORSKE VERITAS
2007-01-11 28624550 CERTIFICATION AS
Approved by: Organisational unit: Veritasveien 1
Michael Lehmann DNV Certification, International N-1322 Hvik
Norway
Climate Change Services http://www.dnv.com
Summary:
Det Norske Veritas Certification AS. (DNV) has performed a validation of the GEEA Biomass 5 MW Power
Plant Project in Brazil on the basis of UNFCCC criteria for the CDM, as well as criteria given to provide for
consistent project operations, monitoring and reporting. UNFCCC criteria refer to Article 12 of the Kyoto
Protocol, the CDM modalities and procedures, the simplified modalities and procedures for small-scale CDM
project activities and the subsequent decisions by the CDM Executive Board. The validation consisted of the
following three phases: i) a desk review of the project design documents, ii) follow-up interviews with project
stakeholders and iii) the resolution of outstanding issues and the issuance of the final validation report and
opinion.
This validation report summarizes the findings of the validation. The only changes made to this version of the
validation report compared to the validation report rev. 03a dated 24 July 2007 referred to in the letter of
approval of the DNA of Brazil are linked to the complementary information about the additionality requested
by the CDM Executive Board Board at EB34 and the version of the letter of approval by the DNA of Brazil
and Japan.
In summary, it is DNVs opinion that the GEEA Biomass 5 MW Power Plant Project as described in the
revised PDD of 24 July 2007 meets all relevant UNFCCC requirements for the CDM and all relevant host
country criteria and correctly applies the baseline and monitoring methodologies AMS-I.D (Version 10 of 23
December 2006) and AMS-III.E (Version 10 of 23 December 2006). Hence, DNV will request the registration
of the GEEA Biomass 5 MW Power Plant Project as a CDM project activity.
1 INTRODUCTION ....................................................................................................... 1
1.1 Validation Objective 1
1.2 Scope 1
1.3 Description of Proposed CDM Project 2
2 METHODOLOGY....................................................................................................... 2
2.1 Review of Documents 4
2.2 Follow-up Interviews 4
2.3 Resolution of Clarification and Corrective Action Requests 4
2.4 Internal Quality Control 4
REFERENCES......................................................................................................................... 13
Appendix A Validation Protocol
Appendix B Certificates of Competence
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Abbreviations
BM Build margin
CAR Corrective Action Request
CDM Clean Development Mechanism
CEF Carbon Emission Factor
CER Certified Emission Reduction
CH4 Methane
CL Clarification request
CO2 Carbon dioxide
CO2e Carbon dioxide equivalent
DNV Det Norske Veritas
DNA Designated National Authority
GEEA Geradora de Energia Eltrica Alegrete Ltda
GHG Greenhouse gas(es)
GWP Global Warming Potential
IPCC Intergovernmental Panel on Climate Change
MP Monitoring Plan
N2O Nitrous oxide
NGO Non-governmental Organisation
ODA Official Development Assistance
PDD Project Design Document
SBS Silica Brasil Sul
UNFCCC United Nations Framework Convention on Climate Change
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1 INTRODUCTION
Mitsubishi UFJ Securities Co. Ltd. has commissioned Det Norske Veritas Certification Ltd.
(DNV) to perform a validation of the GEEA Biomass 5 MW Power Plant Project CDM project,
located in the municipality of Alegrete, Rio Grande do Sul State, Brazil (abbreviated as GEEA
Biomass Power Plant Project). This report summarises the findings of the validation of the
project, performed on the basis of UNFCCC criteria for small-scale CDM projects, as well as
criteria given to provide for consistent project operations, monitoring and reporting. This
validation report summarizes the findings of the validation. The only changes made to this
version of the validation report compared to the validation report rev. 03a dated 24 July 2007
referred to in the letter of approval of the DNA of Brazil are linked to the complementary information
about the additionality requested by the CDM Executive Board at EB34 and the version of the letter of
approval by the DNA of Brazil.
The validation team consists of the following personnel:
Mr. Raphael de Souza Tavares DNV Certification Rio de Janeiro Team leader, CDM
validator
Ms. Andrea Leiroz DNV Certification Rio de Janeiro GHG auditor
Mr. Michael Lehmann DNV Certification Oslo Energy sector expert
Mr Einar Telnes DNV Certification Oslo Technical reviewer
1.2 Scope
The validation scope is defined as an independent and objective review of the project design
document (PDD). The PDD is reviewed against the criteria stated in Article 12 of the Kyoto
Protocol, the CDM modalities and procedures as agreed in the Marrakech Accords, the
simplified modalities and procedures for small-scale CDM project activities and the relevant
decisions by the CDM Executive Board, including the approved baseline and monitoring
methodologies AMS-I.D (Version 10 of 23 December 2006) and AMS-III.E (Version 10 of 23
December 2006 /21/). The validation team has, based on the recommendations in the Validation
and Verification Manual /19/ employed a risk-based approach, focusing on the identification of
significant risks for project implementation and the generation of CERs.
The validation is not meant to provide any consulting towards the project participants. However,
stated requests for clarifications and/or corrective actions may have provided input for
improvement of the project design.
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2 METHODOLOGY
The validation consisted of the following three phases:
I a desk review of the project design documents;
II follow-up interviews with project stakeholders;
III the resolution of outstanding issues and the issuance of the final validation report and
opinion.
In order to ensure transparency, a validation protocol was customised for the project, according
to the Validation and Verification Manual. The protocol shows in transparent manner criteria
(requirements), means of verification and the results from validating the identified criteria. The
validation protocol serves the following purposes:
It organises, details and clarifies the requirements a CDM project is expected to meet;
It ensures a transparent validation process where the validator will document how a
particular requirement has been validated and the result of the validation.
The validation protocol consists of three tables. The different columns in these tables are
described in Figure 1.
The completed validation protocol for the GEEA Biomass 5 MW Power Plant Project is
enclosed in Appendix A to this report.
Findings established during the validation can be seen as a non-fulfilment of validation protocol
criteria or where a risk to the fulfilment of project objectives is identified. Corrective action
requests (CARs) are issued, where:
i) Mistakes have been made with a direct influence on project results;
ii) Validation protocol requirements have not been met; or
iii) There is a risk that the project would not be accepted as a CDM project or that emission
reductions will not be certified.
The term request for clarification (CL) is used where additional information is needed to fully
clarify an issue.
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Validation Protocol Table 3: Resolution of Corrective Action Requests and Requests for Clarification
Draft report corrective Ref. to Table 2 Summary of project Final conclusion
action requests and participants response
requests for clarifications
If the conclusions from the Reference to the The responses given by This section should summarise
draft Validation are either checklist question the project participants the validation teams
a Corrective Action number in Table 2 during the responses and final
Request or a Clarification where the Corrective communications with the conclusions. The conclusions
Request, these should be Action Request or validation team should should also be included in
listed in this section. Clarification Request is be summarised in this Table 2, under Final
explained. section. Conclusion.
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3 VALIDATION FINDINGS
The findings of the validation of the GEEA Biomass 5 MW Power Plant Project 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 validation findings relate to the project design as documented and described in the PDD of
24 July 2007. /3/
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No public funding is involved, and the validation did not reveal any information that indicates
that the project can be seen as a diversion of ODA funding towards.
The project is expected to bring increase in employment opportunities, increase diversity and
quantity of energy supply, decrease environment impacts, use of clean technologies and conserve
natural resources, thus contributing to the sustainable development objectives of the Brazilian
Government. The DNA of Brazil has confirmed that the project assists in achieving sustainable
development /6/.
The project participant has provided information about the main equipments that are being
installed in the project plant and which are related with the CDM project activity.
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Disposal the biomass residue in open air landfills is presented as a common practice of Pilecco
Rice Mill and several other mills in south region of Brazil. There is no regulation that constrains
this practice.
Disposal of rice husk by burning it in the open air is not common practice in Rio Grande do Sul
State. This scenario is unlikely due to the State regulation that does not allow open air burning
without permission. As the project developers are concerned about the environment and about
their image, they have not requested authorization for open-air burning; but even if they did they
would not obtain such authorization.
The project activity will not be implemented without the CDM incentives as there are no
sufficient legal or economic incentives to install of a biomass power plant.
The methodology application firstly involves an identification of possible baseline scenarios, and
eliminates those that would not qualify. As a result the only feasible baseline is a continuation of
the status quo, which meets current regulations, and requires neither additional investments nor
additional running costs. Therefore disposal the biomass in open air and power supply by the
grid can be selected as the baseline scenario.
The baseline for grid connected renewable electricity generation is a combination of operating
margin (OM) and built margin (BM) according to the procedures prescribed in the approved
methodology ACM0002.
The baseline emissions related to the avoidance of methane are the amount of methane from the
decay of the biomass content of the waste treated in the project activity. The yearly methane
generation potential is calculated using the First Order Decay model based on the discrete time
estimate method of the IPCC Guidelines as described in AMS-III.G (Version 4 of 23 December
2006) and the Tool to determine methane emissions avoided from dumping waste at a solid
waste disposal site.
The project boundary is defined as the physical, geographical site of the renewable generation
source and where the treatment of biomass takes place. So, in accordance with AMS-I.D and
AMS-III.E, the project boundary includes the rice husks power plant generation, the landfill site
where the solid waste would have been disposed and the avoided methane emission occurs,
respectively and the itineraries of the transportation.
3.4 Additionality
Evidence that the CDM was seriously considered in the decision to implement the project was
provided through contract signed in 23 February 2006 between the Geradora de Energia Eltrica
Alegrete Ltd - GEEA and Mitsubishi UFJ Securities Co. Ltd., in order to assess potential CDM
revenues. /18. The additionality of the project is demonstrated through an analysis of barriers, by
applying the Attachment A to the Appendix B of the simplified modalities and procedures for
CDM small-scale project activities.
(a) Investment barriers: Since there currently are no direct subsides or promotional support for
the implementation of biomass power plants and there are higher costs required to implement a
renewable energy plant that as would be represented by the baseline scenario, the project faces
financial/economic barriers. In spite of the project receiving funding of 80% of the capital cost
from the National Bank of Social and Economic Development (BNDES), obtaining loans for the
activities represented by the project from the banking institutions in Brazil is difficult and loans
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are only given with high interest rates and with sufficient collateral. Hence, the project would not
be implemented without the revenues from CERs.
The project IRR over a period of 21 years has been verified to be 6.02% which is below the
benchmark IRR selected i.e. the active interest rates in Brazil (17.47% (2004), 18.95% (2005),
14.66% (2006) and 11.43% (2007)) at the time the investment decision was made. The project
involves an investment above 8.9 millions USD (BRL 18.09) as verified on the purchase receipts
of equipment and construction /13//14//15/. The basis for the discount rate is the SELIC rate
(Special System of Clearance and Custody) set by the Central Bank of Brazil*, which represents
the expected return of a low risk investment fund.
The price of electricity on Brazilian market and Brazilian currency in May 2006 (R$ 94.00/MWh
and R$2.19/US$) and up to March 2007 (R$ 120.00/MWh and R$2.11/US$) were considered
according to official information /9//10//11/. In addition, the price of biomass has considered the
transport from the rice industries to GEEA, what is in average 160 km and reaches 240 km /14/
and the O&M costs considered as 10% of income and only 2% of investments which are
considered reasonable compared with similar renewable electricity generation projects.
The input parameters used in the financial analysis have been validated by DNV and are
considered information provided by independent and recognized sources. DNV was able to
confirm that the input parameters used in the financial analysis are reasonable.
A sensitive analysis has been done increasing the maintenance costs, electricity price and
biomass costs by 10% and decreasing the biomass costs by 10%. In the best case the IRR reaches
7.79 %, below the benchmark. Hence, it can be concluded that the project is not financially
attractive and thus is additional.
(b) Technological barriers: Although the technology involved in this scenario is available in the
Brazilian market, the project activity implementation involves risks due to the lower
performance for rice husks based power generation as compared to other residual biomass.
(c) Prevailing business practice barriers: DNV, based on specific data from the National Energy
Balance 2005 from the Ministry of Mines and Energy, is able to confirm that the common
practice for mills is the import of electricity from the grid and the landfilling of industrial
residues, as rice husks.
No other barriers are presented. Given the above, it is deemed sufficiently demonstrated that the
project is not a likely baseline scenario and that emission reductions are thus additional.
*
http://www.bcb.gov.br
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For category I.D, the monitoring shall consist of metering the electricity generated by the
renewable technology and the amount of biomass input.
For category III.E, the main parameters to monitor are the amount of biomass combusted, the
composition of the biomass through representative sampling, the auxiliary fuel used, the non-
biomass carbon in the waste combusted, the total quantity of waste combusted, the average truck
capacity, the power consumption and generation and the distance for transporting the waste in
baseline and the project scenario.
The project participants will demonstrate annually that the amount of waste combusted in the
project activity facilities would have been disposed in a solid waste disposal site without
methane recovery in the absence of the project activity.
The monitoring plan consists of the monitoring the following parameters:
a) Electricity generated.
b) Electricity delivered to the grid
c) Electricity delivered to Pilecco Rice Mill
d) Electricity delivered to SBS
e) Amount of biomass combusted in power plant
f) Composition of biomass combusted in power plant
g) Amount of biomass transported
h) Truck capacity for biomass transportation
i) Surplus of biomass
j) Amount of fuel spent for compacting biomass
k) Documentation on transportation transactions
Concerning leakage, no sources of emission were identified according to AMS-I.D and AMS-
III.E.
Detailed monitoring procedures, including responsibilities for project management, procedures
for QA/QC of monitoring reports, frequency and calibration are described.
The monitoring management system and training are clearly established in the PDD.
The procedures for emergency preparedness for cases where emergencies can cause unintended
emissions have not been identified in monitoring plan. It was observed that there are no
unintended emissions. All the processes are controlled.
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The baseline calculations are according to the simplified methodology for category III.E small-
scale CDM project activities.
The Yearly Methane Generation Potential is calculated using the first order decay model based
on the discrete time estimate method of the IPCC Guidelines, as described in category AMS-I.D.
The methane avoidance was determined using IPCC default MCF for unmanaged, deep (> 5 m
waste) landfills of 0.4, a DOC of 0.43 for wood and wood products and an IPCC default DOCf of
0.5. The value adopted for k is 0.03 and for f is zero. As the site does not receive soil as cover,
the OX is zero. The selection of these factors is deemed reasonable.
Project activity emissions are calculated according to the simplified baseline methodology for
category III.E small-scale CDM project activities. The emissions consist in sum of CO2
emissions through combustion of non-biomass carbon in the year y, CO2 emissions through
incremental transportation in the year y and CO2 emissions through electricity or diesel
consumption in the year y.
Emissions resulting from the transportation of the biomass are accounted for, and correspond to
the transport itself and the compacting process. There are no combustion residues.
The emissions related to power consumption will be null since all power needs will be met by
the in-house power generation.
The PDD estimated amount of GHG emission reductions from the project is 194 859 tCO2e
during the first crediting period (10 years), resulting in estimated average annual emission
reductions of 19 486 tCO2e.
A spreadsheet used for the calculation of the emission reductions was assessed by DNV and is
found to be correct.
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The local stakeholders are listed in the Appendix 3 of the PDD. The letters sent to the local
stakeholders and the received comments were assessed.
Twelve comments were received, however due contend (commendation) the project design did
not require any significant modification. Two comments requesting more information about the
project were sufficiently taken into account by the project participant.
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5 VALIDATION OPINION
Det Norske Veritas Certification Ltd. (DNV) has performed a validation of the GEEA Biomass
5 MW Power Plant Project in Brazil. 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 project participants are Geradora de Energia Eltrica Alegrete Ltd. and Mitsubishi UFJ
Securities Co. Ltd.. The participating Parties Brazil as host Party and Japan as Annex I Party
- meet all relevant participation requirements requirements and have provided written approval
of voluntary participation in the project.
The GEEA Biomass Power Plant Project CDM project activity involves the installation of
100% biomass power plant. This plant will utilize residual biomass, such as rice husks as the
biomass fuel for power generation. The power generated will be used internally in the rice mill
and supplied to the South-Southeast-Midwest Grid. Thus, preventing the generation of GHG by
the decay of rice husk and substituting energy supplied to grid from fossil fuelled power plants.
The project applies the simplified baseline methodologies for selected small-scale CDM project
activity categories, category I.D Grid connected renewable electricity generation and III.E
Avoidance of methane production from biomass decay through controlled combustion. The
baseline methodology has been correctly applied and the assumptions made for the selected
baseline scenario are sound. It is sufficiently demonstrated that the project is not a likely
baseline scenario and that emission reductions attributable to the project are additional to any
that would occur in the absence of the project activity.
The monitoring methodology has been correctly applied. The monitoring plan sufficiently
specifies the monitoring requirements.
By the using of a renewable energy source, the project results in reductions of CO2 emissions
that give long-term benefits to the mitigation of climate change. Emission reductions are directly
monitored and calculated ex-post, through of fuel oil consumption, and using the approach
indicated in AMS-I.D and AMS-III.E.
Local stakeholders, such as the Municipal Government, the state and municipal agencies, the
Brazilian forum of NGOs, neighbouring communities and the office of the attorney general, were
invited to comment on the project, in accordance with the requirements of Resolution 1 of the
Brazilian DNA. Twelve comments were received.
In summary, it is DNVs opinion that the GEEA Biomass 5 MW Power Plant Project, as
described in the revised and resubmitted project design document of 24 July 2007 meets all
relevant UNFCCC requirements for the CDM and all relevant host country criteria and
correctly applies the baseline and monitoring methodologies AMS-I.D (Version 10 of 23
December 2006) and AMS-III.E (Version 10 of 23 December 2006). Hence, DNV will request
the registration of the GEEA Biomass 5 MW Power Plant Project as a CDM project activity.
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REFERENCES
Documents provided by the project proponent that relate directly to the project:
/1/ Project Design Document for the GEEA Biomass 5 MW Power Plant Project
Version 02 of 26 December 2006.
/2/ Project Design Document for the GEEA Biomass 5 MW Power Plant Project
Version 03 of 01 March 2007.
/3/ Project Design Document for the GEEA Biomass 5 MW Power Plant Project
Version 03.1 of 24 July 2007.
/4/ Spreadsheet (Pilecco_PDD_biopower 090207.xls)
/5/ Mitsubishi - Operation License # 86/2006-DL issued on 9 February 2006.
/6/ Mitsubishi - Copy of letters sent to local stakeholders.
/7/ Comisso Interministerial de Mudana Global do Clima (DNA of Brazil): Letter of
Approval. 18 December 2007
/8/ Liaison Committee for the Utilization of the Kyoto Mechanisms (DNA of Japan):
Letter of Approval. 12 April 2007
/9/ Brazil Real Currency http://www5.bcb.gov.br/pec/conversao/conversao.asp?id=txconversao
/10/ Brazilian Electricity Price at 4th.public auction on 10/2005
http://www.valoronline.com.br/valoronline/Geral/empresas/energia/Quarto+leilao+de+energia+vende+1
166+MW+e+negocia+R$+776+bi+MW+medio+ficou+em+R$+9491,,,1,3326281.html
/11/ Brazilian Electricity Price at 5th.public auctionon 10/2007
http://www.furnas.com.br/arqtrab/ddppg/infomercado/dgmt/NT104-Extra_nov2007.pdf
/12/ Picture of start construction ceremony with Rio Grande do Sul Governor
/13/ WEG electrical equipment receipts
128833 issued on 21.05.08
17043 issued on 16.05.08
128832 issued on 21.05.08
17059 issued on 19.05.08
/14/ TGM Turbines receipts
7027 issued on 20.11.07
73549 issued 12.02.08
73869 issued 19.02.08
75339 issued 13.03.08
/15/ Vilery Eng Boiler receipts 1677 / 1678 / 1680 issued 09.10.07
/16/ Rice husk generation
/17/ Spreadsheet GEEA 5 MW
/18/ Contract signed between the Geradora de Energia Eltrica Alegrete Ltd - GEEA and
Mitsubishi UFJ Securities Co. Ltd., in order to assess potential CDM revenues on 23
February 2006.
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Background documents related to the design and/or methodologies employed in the design or
other reference documents:
/19/ International Emission Trading Association (IETA) & the World Banks Prototype
Carbon Fund (PCF): Validation and Verification Manual. http://www.vvmanual.info
/20/ Appendix B of the "Simplified modalities and procedures for small-scale CDM project
activities - Indicative simplified baseline and monitoring methodologies for selected
small-scale CDM project activities: AMS-I.D Grid connected renewable electricity
generation for Type I Renewable Energy Projects. Version 10 of 23 December 2006.
/21/ Appendix B of the "Simplified modalities and procedures for small-scale CDM project
activities - Indicative simplified baseline and monitoring methodologies for selected
small-scale CDM project activities: AMS-III.E Avoidance of methane production
from biomass decay through controlled combustion for Type III Other Project
Activities. Version 10 of 23 December 2006.
/22/ Appendix B of the "Simplified modalities and procedures for small-scale CDM project
activities - Indicative simplified baseline and monitoring methodologies for selected
small-scale CDM project activities: AMS-III.G Landfill methane recovery for Type
III Other Project Activities. Version 4 of 23 December 2006.
/23/ Tool to determine methane emissions avoided from dumping waste at a solid waste
disposal site. Annex 14.
/24/ Attachment A to the Appendix B of the "Simplified modalities and procedures for
small-scale CDM project activities - Indicative simplified baseline and monitoring
methodologies for selected small-scale CDM project activities. Version 06 of
September 2005.
/25/ UNFCCC. ACM0002 - Consolidated baseline methodology for grid-connected
electricity generation from renewable sources. Version 06, 19 May 2006.
Persons interviewed during the validation, or persons who contributed with other information
that are not included in the documents listed above:
/26/ Mara Regina Mendes - Mitsubishi UFJ Securities Co. Ltd.
- o0o -
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APPENDIX A
VALIDATION PROTOCOL
FOR SMALL-SCALE CDM PROJECT ACTIVITIES
DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Table 1 Mandatory Requirements for Small Scale Clean Development Mechanism (CDM) Project Activities
Cross Reference/
Requirement Reference Conclusion Comment
1. The project shall assist Parties included in Annex I in Kyoto Protocol Art. 12.2 OK Table 2, Section E.4.1.
achieving compliance with part of their emission The PDD identifies Mitsubishi UFJ
reduction commitment under Art. 3 Securities Co. Ltd. (Japan) as Annex I
project participants.
2. The project shall assist non-Annex I Parties in Kyoto Protocol Art. 12.2, OK Table 2, Section A.3.
achieving sustainable development and shall have Simplified Modalities and
obtained confirmation by the host country thereof Procedures for Small
Scale CDM Project
Activities 23a
3. The project shall assist non-Annex I Parties in Kyoto Protocol Art. 12.2. OK Table 2, Section E.4.1
contributing to the ultimate objective of the UNFCCC
4. The project shall have the written approval of voluntary Kyoto Protocol Art. OK DNA of Brazil: Letter of Approval. 18
participation from the designated national authority of 12.5a, December 2007
each party involved Simplified Modalities and DNA of Japan: Letter of Approval. 12
Procedures for Small April 2007
Scale CDM Project
Activities 23a
5. The emission reductions should be real, measurable Kyoto Protocol Art. 12.5b OK Table 2, Section E.1 to E.4
and give long-term benefits related to the mitigation of
climate change
6. Reduction in GHG emissions must be additional to any Kyoto Protocol Art. OK Table 2, Section B.2.1
that would occur in absence of the project activity, i.e. 12.5.c,
a CDM project activity is additional if anthropogenic Simplified Modalities and
emissions of greenhouse gases by sources are Procedures for Small
reduced below those that would have occurred in the Scale CDM Project
absence of the registered CDM project activity Activities 26
7. In case public funding from Parties included in Annex I Decision 17/CP.7, OK No public funding is involved, and the
is used for the project activity, these Parties shall CDM Modalities and validation did not reveal any
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SSC CDM Validation Protocol - Report No. 2006-1015, rev. 03b
DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Cross Reference/
Requirement Reference Conclusion Comment
provide an affirmation that such funding does not Procedures Appendix B, information that indicates that the
result in a diversion of official development assistance 2 project can be seen as a diversion of
and is separate from and is not counted towards the ODA funding towards Brazil.
financial obligations of these Parties.
8. Parties participating in the CDM shall designate a CDM Modalities and OK Brazil: Comisso Interministerial de
national authority for the CDM Procedures 29 Mudana Global do Clima.
Japan: Liaisons committee for the
Utilization of the Kyoto Mechanisms.
9. The host Party and the participating Annex I Party CDM Modalities and OK Brazil ratified the protocol on 23
shall be a Party to the Kyoto Protocol Procedures 30, 31b August 2002, and Japan ratified the
protocol on 04 June 2002.
10. The participating Annex I Partys assigned amount CDM Modalities and OK The assigned amount of Japan is 94%
shall have been calculated and recorded Procedures 31b of the emissions in 1990.
11. The participating Annex I Party shall have in place a CDM Modalities and OK Japan has in place a national registry
national system for estimating GHG emissions and a Procedures 31b and reported in May 2005 the latest
national registry in accordance with Kyoto Protocol inventory for the years 1990-2003.
Article 5 and 7
12. The proposed project activity shall meet the eligibility Simplified Modalities and OK Table 2, Section A.1
criteria for small scale CDM project activities set out in Procedures for Small
6 (c) of the Marrakesh Accords and shall not be a Scale CDM Project
debundled component of a larger project activity Activities 12a,c
13. The project design document shall conform with the Simplified Modalities and OK The PDD is in line with the CDM-PDD
Small Scale CDM Project Design Document format Procedures for Small for small-scale CDM project activities
Scale CDM Project (version 02 of 21 March 2006).
Activities, Appendix A
14. The proposed project activity shall confirm to one of Simplified Modalities and OK Table 2, Section A.1.3, B and D.
the project categories defined for small scale CDM Procedures for Small
project activities and uses the simplified baseline and Scale CDM Project
monitoring methodology for that project category Activities 22e
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DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Cross Reference/
Requirement Reference Conclusion Comment
15. Comments by local stakeholders are invited, and a Simplified Modalities and OK Table 2, Section G.
summary of these provided Procedures for Small
Scale CDM Project
Activities 22b
16. If required by the host country, an analysis of the Simplified Modalities and Table 2, Section F.
environmental impacts of the project activity is carried Procedures for Small
out and documented Scale CDM Project
Activities 22c
17. Parties, stakeholders and UNFCCC accredited NGOs Simplified Modalities and OK The PDD of 26 December 2006 was
have been invited to comment on the validation Procedures for Small published on the UNFCCC CDM
requirements and comments have been made publicly Scale CDM Project website,
available Activities 23b,c,d www.dnv.com/certification/ClimateCha
nge, and Parties, stakeholders and
NGOs were invited to provide
comments on the validation
requirement during a period of 30
days, from 28 December 2006 to 26
January 2007.
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DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
debundled component of a larger project large project activity. Although GEEA is planning
activity? another CDM project with Silica Sul Brasil Ltda.,
the project participants, project category and
technology are different.
A.1.3. Does proposed project activity confirm to /1/ DR Yes. The project activity is included in the Type I OK
one of the project categories defined for Renewable Energy Projects, AMS-I.D - Grid
small scale CDM project activities? connected renewable electricity generation and
Type III Other Project Activities, AMS-III.E -
Avoidance of methane production from biomass
decay through controlled combustion.
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
A.2.3. Does the project design engineering /1/ DR Yes. The technology of biomass power generation OK
reflect current good practices? reflects current good practices.
A.2.4. Will the project result in technology /1/ DR The technology will be transferred to other project OK
transfer to the host country? developers that wish to use biomass residues.
A.2.5. Does the project require extensive initial /1/ DR The training program for the works will cover basic OK
training and maintenance efforts in order plant operations, safety and engineering,
to work as presumed during the project environmental management and awareness,
period? Does the project make provisions wastewater and water treatment operations,
for meeting training and maintenance process engineering and control systems and fire
needs? safety and evacuation.
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
project and its facilities.
In order to obtain the license, the project
developers showed evidence that no negative
environmental impact is incurred by this activity.
Environment Licenses are issued after all possible
impacts are analyzed by the State Environmental
Foundation Protection, FEPAM. No adverse
environmental impacts are identified, which seems
reasonable given the nature of the project design.
Transboundary environmental impacts are not
foreseen. The positive environment impacts arising
from the project are the reduction in dumping of
rice husk and of methane.
B. Project Baseline
The validation of the project baseline establishes
whether the selected baseline methodology is
appropriate and whether the selected baseline
represents a likely baseline scenario.
B.1. Baseline Methodology
It is assessed whether the project applies an
appropriate baseline methodology.
B.1.1. Is the selected baseline methodology in /1/ DR The project applies the simplified baseline CL 7 OK
line with the baseline methodologies methodologies for type I.D small-scale CDM project CL 10
provided for the relevant project category? activities (AMS-I.D, Version 10 of 23 December
2006) and type III.E small-scale CDM project
activities (AMS-III.E, Version 10 of 23 December
2006), i.e. the methane emissions from biomass
that would have otherwise been left to decay. Also,
the project applies the methodologies AMS-III.G
* MoV = Means of Verification, DR= Document Review, I= Interview Page A-7
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DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
and ACM0002 and the Tool to determine methane
emissions avoided from dumping waste at a solid
waste disposal site.
The methodology AMS-III.G and the Tool to
determine methane emissions avoided from
dumping waste at a solid waste disposal site were
not addressed in the item B.1. Title and reference
of the approved baseline and monitoring
methodology applied to the small-scale project
activity of the PDD.
The methodology ACM0002 was not addressed in
the item B.1. Title and reference of the approved
baseline and monitoring methodology applied to
the small-scale project activity of the PDD.
B.1.2. Is the baseline methodology applicable to /1/ DR The category I.D and III.E methodologies are CL 4 OK
the project being considered? applicable for the project.
The applicability criteria stated in the PDD not
correspond to the last version of AMS-III.E.
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
no direct subsides or promotional support for the
implementation of biomass power plants and there
are higher costs required to implement a renewable
energy plant that as would be represented by the
baseline scenario, the project faces
financial/economic barriers. In spite of the project
receiving funding of 80% of the capital cost from
the National Bank of Social and Economic
Development (BNDES), obtaining loans for the
activities represented by the project from the
banking institutions in Brazil is difficult and loans
are only given with high interest rates and with
sufficient collateral. Hence, the project would not be
implemented without the revenues from CERs.
(b) Technological barriers: Although the technology
involved in this scenario is available in the Brazilian
market, the project activity implementation involves
risks due to the lower performance for rice husks
based power generation as compared to other
residual biomass.
(c) Prevailing business practice barriers: DNV is
able to confirm that the common practice for mills is
the import of electricity from the grid and the
landfilling of industrial residues, as rice husks.
No other barriers are presented. Given the above, it
is deemed sufficiently demonstrated that the project
is not a likely baseline scenario and that emission
reductions are thus additional.
B.2.2. Is the application of the baseline /1/ DR Yes, the selected baseline is the CH4 emissions OK
methodology and the discussion and from disposing the solid waste on a landfill and
determination of the chosen baseline leaving it to decay and power supply by the grid.
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
transparent and conservative?
B.2.3. Are relevant national and/or sectoral /1/ DR Yes. OK
policies and circumstances taken into
account?
B.2.4. Is the baseline selection compatible with /1/ DR Yes. OK
the available data?
B.2.5. Does the selected baseline represent the /1/ DR Yes. In the absence of the project the rice husk is CL 6 OK
most likely scenario describing what would disposed in landfill sites until it is naturally
have occurred in absence of the project decomposed and the electricity is supply by the
activity? grid.
The project participant should provide information
why they do not request permission to burn the
biomass residues
C. Duration of the Project / Crediting Period
It is assessed whether the temporary boundaries
of the project are clearly defined.
C.1.1. Are the projects starting date and /1/ DR The projects starting date is 05 May 2006 with an CL 1 OK
operational lifetime clearly defined? expected operational lifetime of 25 years.
The length of the crediting period and the expected
operational lifetime of the project activity should be
stated in years and months
C.1.2. Is the assumed crediting time clearly /1/ DR A fixed 10-year crediting period is selected, starting CL 1 OK
defined (renewable crediting period of on 01 July 2008.
seven years with two possible renewals or
The length of the crediting period and the expected
fixed crediting period of 10 years with no
operational lifetime of the project activity should be
renewal)?
stated in years and months.
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
D. Monitoring Plan
The monitoring plan review aims to establish
whether all relevant project aspects deemed
necessary to monitor and report reliable emission
reductions are properly addressed.
D.1. Monitoring Methodology
It is assessed whether the project applies an
appropriate monitoring methodology.
D.1.1. Is the selected monitoring methodology in /1/ DR Yes. The project applies the approved monitoring OK
line with the monitoring methodologies methodologies AMS-I.D (Version 10 of 23
provided for the relevant project category? December 2006) Grid connected renewable
electricity generation for Type I Renewable
Energy Projects and AMS-III.E (Version 10 of 23
December 2006) - Avoidance of methane
production from biomass decay through controlled
combustion for Type III Other Project Activities,
according to the Appendix B of the "Simplified
modalities and procedures for small-scale CDM
project activities - Indicative simplified baseline
and monitoring methodologies for selected small-
scale CDM project activities.
The project also applies the monitoring
methodologies AMS-III.G (Version 4 of 23
December 2006) and ACM0002 (Version 06, 19
May 2006).
D.1.2. Is the monitoring methodology applicable /1/ DR Yes, it complies with the monitoring requirements OK
to the project being considered? for small scale CDM project category I.D and III.E.
D.1.3. Is the application of the monitoring /1/ DR See D.1.2 OK
methodology transparent?
* MoV = Means of Verification, DR= Document Review, I= Interview Page A-11
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DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
D.1.4. Will the monitoring methodology give /1/ DR See D.1.2 OK
opportunity for real measurements of
achieved emission reductions?
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
from another activity or if the existing equipment is
transferred to another activity, AMS-III.E states that
leakage is to be considered. The project will be
implemented with new equipment. Hence, no
leakage is expected.
D.3.2. Are the choices of leakage indicators /1/ DR See D.3.1 OK
reasonable?
D.3.3. Will it be possible to monitor / measure the /1/ DR See D.3.1 OK
specified leakage indicators?
D.3.4. Will the indicators give opportunity for real /1/ DR See D.3.1 OK
measurements of leakage effects?
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
D.5. Project Management Planning
It is checked that project implementation is
properly prepared for and that critical
arrangements are addressed.
D.5.1. Is the authority and responsibility of project /1/ DR Yes. OK
management clearly described?
D.5.2. Is the authority and responsibility for /1/ DR Yes. OK
registration monitoring measurement and
reporting clearly described?
D.5.3. Are procedures identified for training of /1/ DR Yes. OK
monitoring personnel?
D.5.4. Are procedures identified for emergency /1/ DR The procedures for emergency preparedness for CL 9 OK
preparedness for cases where cases where emergencies can cause unintended
emergencies can cause unintended emissions have not been identified in monitoring
emissions? plan. DNV requests further clarifications about the
procedures.
D.5.5. Are procedures identified for calibration of /1/ DR All equipment is calibrated. This mainly comprises OK
monitoring equipment? the electricity meters and the scales, which are
calibrated according to the national standards.
D.5.6. Are procedures identified for maintenance /1/ DR Yes. Maintenance of the equipments will be carried OK
of monitoring equipment and installations? out according to the national standards.
D.5.7. Are procedures identified for monitoring, /1/ DR Yes. OK
measurements and reporting?
D.5.8. Are procedures identified for day-to-day /1/ DR The data will be collected continuously and OK
records handling (including what records archived in electronic form, during the whole
to keep, storage area of records and how crediting period plus 2 years.
to process performance documentation)
D.5.9. Are procedures identified for dealing with /1/ DR No uncertainties are foreseen. OK
possible monitoring data adjustments and
* MoV = Means of Verification, DR= Document Review, I= Interview Page A-14
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DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
uncertainties?
D.5.10. Are procedures identified for internal /1/ DR Yes. OK
audits of GHG project compliance with
operational requirements as applicable?
D.5.11. Are procedures identified for project /1/ DR Yes OK
performance reviews?
D.5.12. Are procedures identified for corrective /1/ DR Yes. OK
actions?
E. Calculation of GHG emission
It is assessed whether all material GHG emission
sources are addressed and how sensitivities and
data uncertainties have been addressed to arrive
at conservative estimates of projected emission
reductions.
E.1. Project GHG Emissions
The validation of ex-ante estimated project
GHG emissions focuses on transparency and
completeness of calculations.
E.1.1. Are all aspects related to direct and /1/ DR Yes. OK
indirect project emissions captured in the
project design?
E.1.2. Have all relevant greenhouse gases and /1/ DR Yes. OK
sources been evaluated?
E.1.3. Do the methodologies for calculating /1/ DR The calculation of the emission reductions is in OK
project emissions comply with existing accordance with AMS-I.D and AMS-III.E and takes
good practice? into account all relevant factors of the project
technology.
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
E.1.4. Are the calculations documented in a /1/ DR Yes, all the sources and calculations are well CL 11 OK
complete and transparent manner? documented. However, the emissions estimated
due to fossil fuel use for compacting biomass are
not correct. There is a unit inconsistency in the
spread sheet received.
E.1.5. Have conservative assumptions been /1/ DR See E.1.4. CL 11 OK
used?
E.2. Leakage
It is assessed whether there leakage effects,
i.e. change of emissions which occurs
outside the project boundary and which are
measurable and attributable to the project,
have been properly assessed and estimated
ex-ante.
E.2.1. Are leakage calculation required for the /1/ DR No leakage calculation is required for this specific OK
selected project category and if yes, are situation. See D.3.1.
the relevant leakage effects assessed?
E.2.2. Are potential leakage effects properly /1/ DR See D.3.1. OK
accounted for in the calculations (if
applicable)?
E.2.3. Do the methodologies for calculating /1/ DR See D.3.1 OK
leakage comply with existing good practice
(if applicable)?
E.2.4. Are the calculations documented in a /1/ DR See D.3.1. OK
complete and transparent manner and (if
applicable)?
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
E.2.5. Have conservative assumptions been /1/ DR See D.3.1 OK
used (if applicable)?
E.2.6. Are uncertainties in the leakage estimates /1/ DR See D.3.1 OK
properly addressed (if applicable)?
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
E.3.7. Are uncertainties in the baseline emissions /1/ DR No uncertainties are foreseen. OK
estimates properly addressed?
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
environmental legislation in the host
country?
F.1.3. Will the project create any adverse /1/ DR See F.1.1 OK
environmental effects?
F.1.4. Have environmental impacts been /1/ DR Yes. The positive environment impacts arising from OK
identified and addressed in the PDD? the project are the reduction in dumping of rice
husk and of methane. No negative effects were
detected.
G. Comments by Local Stakeholder
Validation of the local stakeholder consultation
process.
G.1.1. Have relevant stakeholders been /1/ DR Local stakeholders, such as the Municipal CL 12 OK
consulted? Government, the state and municipal agencies, the
Brazilian forum of NGOs, neighbouring
communities and the office of the attorney general,
were invited to comment on the project, in
accordance with the requirements of Resolution 1
of the Brazilian DNA.
The local stakeholders are listed in the Appendix 3
of the PDD. The letters sent to the local
stakeholders and the received comments were
assessed. However, the project participant did not
send a copy of all the letters sent to the
stakeholders.
Twelve comments were received, however due
contend (commendation) the project design did not
require any significant modification. Two comments
requesting more information about the project were
sufficiently taken into account by the project
Draft Final
Checklist Question Ref. MoV* Comments Concl. Concl.
participant.
G.1.2. Have appropriate media been used to /1/ DR See G.1.1. CL 12 OK
invite comments by local stakeholders?
G.1.5. Has due account been taken of any /1/ DR See G.1.1. CL 12 OK
comments received?
Draft report corrective action requests Ref. to Summary of project participants Final conclusion
and requests for clarification Table 2 response
about their image, they have not
requested authorization for open-air
burning; but even if they did would not
obtain the authorization.
The scenario of open air burning
(scenario 2, section B.3) was edited in
the version 3 of the PDD to inform the
reader that this practice is completely
unacceptable by society and forbidden
by law.
CL 7 B.1.1 Corrected in version 3. The methodology and the tool were
The methodology AMS-III.G and the Tool to included in the last version of the PDD.
determine methane emissions avoided from This CL is closed.
dumping waste at a solid waste disposal site
were not addressed in the item B.1. Title and
reference of the approved baseline and
monitoring methodology applied to the small-
scale project activity of the PDD.
CL 8 A.2.1 Corrected in version 3. The last version of the PDD was
In the project boundary of AMS-III.E (Version E.3.1 assessed and the changes done are
10 of 23 December 2006) there are only enough. This CL is closed.
three points in this item, not four as reported
in the PDD.
CL 9 D.5.4 The project combusts biomass residues It was observed that there is no
The procedures for emergency preparedness (rice husk), whose combustion does not unintended emission. All the processes
for cases where emergencies can cause generate anthropogenic CO2 emissions. are controlled. This CL is closed.
unintended emissions have not been The project emissions are only due to
identified in monitoring plan. DNV requests biomass transport. Therefore, even in
further clarifications about the procedures. case of case of an emergency, the
project will not have extra GHG
emissions or leakage.
Page A-22
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DET NORSKE VERITAS GEEA Biomass 5 MW Power PLANT PROJECT
Draft report corrective action requests Ref. to Summary of project participants Final conclusion
and requests for clarification Table 2 response
CL 10 B.1.1 Corrected in version 3. The methodology was included in the
The methodology ACM0002 was not last version of the PDD. This CL is
addressed in the item B.1. Title and closed.
reference of the approved baseline and
monitoring methodology applied to the small-
scale project activity of the PDD.
CL 11 E.1.4 Corrected in version 3. The last version of the PDD and the
The emissions estimated due to fossil fuel E.1.5 new spreadsheet were assessed. This
use for compacting biomass are not correct. CL is closed.
There is a unit inconsistency in the spread E.1.6
sheet received.
CL 12 G.1.1 G.1.2 Missing letters were sent. A copy of all the letters were sent to
The project participant did not send a copy of G.1.3 G.1.4 DNV. This CL is closed.
all the letters sent to the stakeholders.
G.1.5
- o0o -
Page A-23
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DET NORSKE VERITAS
APPENDIX B
CERTIFICATES OF COMPETENCE
Michael Lehmann
Qualification in accordance with DNVs Qualification scheme for CDM/JI (ICP-9-8-i1-CDMJI-i1
GHG Auditor: Yes
CDM Validator: Yes JI Validator: Yes
CDM Verifier: Yes JI Verifier: Yes
Industry Sector Expert for Sectoral Scope(s): Sectoral scope 1,2,3 & 9
Technical Reviewer for (group of) methodologies:
ACM0001, AM0002, AM0003, AM0010, Yes AM0021 Yes
AM0011, AM0012, AMS-III.G
ACM002, AMS-I.A-D, AM0019, AM0026, Yes AM0023 Yes
AM0029
ACM003, ACM0005, AM0033, AM0040 Yes AM0024 Yes
ACM0004 Yes AM0027 Yes
ACM0006, AM0007, AM0015, AM0036, AM0042 Yes AM0028, AM0034 Yes
ACM0007 Yes AM0030 Yes
ACM0008 Yes AM0031 Yes
ACM0009, AM0008, AMS-III.B Yes AM0032 Yes
AM0006, AM0016, AMS-III.D Yes AM0035 Yes
AM0009, AM0037 Yes AM0038 Yes
AM0013, AM0022, AM0025, AM00379, AMS- Yes AM0041 Yes
III.H, AMS-III.I
AM0014 Yes AM0034 Yes
AM0017 Yes AMS-II.A-F Yes
AM0018 Yes AMS-III.A Yes
AM0020 Yes AMS-III.E, AMS-III.F Yes
CERTIFICATE OF COMPETENCE
Einar Telnes
Qualification in accordance with DNVs Qualification scheme for CDM/JI (ICP-9-8-i1-CDMJI-i1
GHG Auditor: Yes
CDM Validator: Yes JI Validator: Yes
CDM Verifier: Yes JI Verifier: Yes
Industry Sector Expert for Sectoral Scope(s): Sectoral scope 1,2,3 & 9
Technical Reviewer for (group of) methodologies:
ACM0001, AM0002, AM0003, AM0010, Yes AM0021 Yes
AM0011, AM0012, AMS-III.G
ACM002, AMS-I.A-D, AM0019, AM0026, Yes AM0023 Yes
AM0029
ACM003, ACM0005, AM0033, AM0040 Yes AM0024 Yes
ACM0004 Yes AM0027 Yes
ACM0006, AM0007, AM0015, AM0036, AM0042 Yes AM0028, AM0034 Yes
ACM0007 Yes AM0030 Yes
ACM0008 Yes AM0031 Yes
ACM0009, AM0008, AMS-III.B Yes AM0032 Yes
AM0006, AM0016, AMS-III.D Yes AM0035 Yes
AM0009, AM0037 Yes AM0038 Yes
AM0013, AM0022, AM0025, AM00379, AMS- Yes AM0041 Yes
III.H, AMS-III.I
AM0014 Yes AM0034 Yes
AM0017 Yes AMS-II.A-F Yes
AM0018 Yes AMS-III.A Yes
AM0020 Yes AMS-III.E, AMS-III.F Yes
CERTIFICATE OF COMPETENCE
Michael Lehmann
Technical Director, International Climate Change Services