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									  VALIDATION REPORT

 KKSL Lekir Biogas Project, Project BCM07_SLK_14
located at Lekir Palm Oil Mill, Batu 11, Lekir, Setiawan,
                    Perak, Malaysia
              REPORT NR. 01 997 9105043598
                       REVISION NO. 1.5




                CDM Validation Report Template
                 Version 5.0, November 2006
Date of first issue:                       Project No.:
2007-12-01                                 01 997 9105043598
Approved by:                               Organisational unit:               TÜV Rheinland Japan Ltd.
Dr. Manfred Brinkmann                      System Certification Group,
                                                                              Shin Yokohama Daini Center Bldg.,
                                           Industrial Engineering             3-19-5, Shin Yokohama Kohoku-ku,
                                           Services                           Yokohama 222-0033
Client:                                    Client ref.:                       Certificate Number:
BioX Carbon Malaysia                       Mr. Valentine Khoo                 01 997 9105043598
Sdn. Bhd.,
Executive Summary:
Project Name: KKSL Lekir Biogas Project, Project BCM07_SLK_14
Country: Malaysia
Methodology: AMS-III.H.
Version: 06
GHG reducing Measure/Technology: Methane Recovery in Wastewater Treatment: “Introduction of methane
recovery and combustion to an existing anaerobic wastewater treatment system such as anaerobic reactor,
lagoon, septic tank or an on site industrial plant”.
ER estimate: 33,955tCO2e/yr

Size
   Large Scale
   Small Scale

Validation Phases:
    Desk Review
    Follow up interviews
    Resolution of outstanding issues

Validation Status
    Corrective Actions Requested
    Clarifications Requested
    Full Approval and submission for registration
    Rejected

In summary, it is TÜV Rheinland’s opinion that the project “KKSL Lekir Biogas Project, Project
BCM07_SLK_14” located at Lekir Palm Oil Mill, Batu 11, Lekir, Setiawan, Perak, Malaysia as described in the
final PDD Version 3.5 dated 20 June 2008, meet all relevant UNFCCC requirements for the CDM and all
relevant host country criteria and correctly apply the baseline and monitoring methodology AMS-III.H. version
06. TÜV Rheinland thus requests the registration of the project as a CDM project activity.
Report No.:                             Subject Group:
01 997 9105043598                       Environment & Energy          Indexing terms
Report title:
KKSL Lekir Biogas Project, Project BCM07_SLK_14                       Climate Change
                                                                      Kyoto Protocol
                                                                      Small Scale Project Validation
                                                                      Clean Development Mechanism
Work carried out by:
      •    Robert CY Cheong                                                No distribution without permission from the
                                                                           Client or responsible organisational unit
Work verified by:
      •    Dr. Manfred Brinkmann                                           Limited distribution

Date of this revision:      Rev. No.:           Number pages               Unrestricted distribution
2008-06-27                  1.5                 23


Validation Report 01 997 9105043598 Revision No. 1.5
                                                                  2
Abbreviations
Explain any abbreviations that have been used in the report here.
AMS           Approved Methodology Small Scale
BAU           Business as Usual
CAR           Corrective Action Request
CDM           Clean Development Mechanism
CEF           Carbon Emission Factor
CER           Certified Emission Reduction
CH4           Methane
CL            Request for Clarification
CO2           Carbon Dioxide
CO2e          Carbon Dioxide Equivalent
COD           Chemical Oxygen Demand
DNA           Designated National Authority
DoE           Department of Environment
DOE           Designated Operational Entity
DR            Document Review
EB            Executive Board
EFB           Empty Fruit Bunch
ER            Emission Reductions
FFB           Fresh Fruit Bunch
GHG           Greenhouse Gases
GWP           Global Warming Potential
I             Interview
IETA          International Emissions Trading Association
IPCC          Intergovernmental Panel on Climate Change
IRR           Internal Rate of Return
KLK           Kuala Lumpur Kepong
LoA           Letter of Approval
MCF           Methane Correction Factor
MoV           Means of Verification
MP            Monitoring Plan
N2O           Nitrous Oxide
NGO           Non-Governmental Organization
ODA           Official Development Assistance
O&M           Operation and Maintenance
PDD           Project Design Document
POME          Palm Oil Mill Effluent
QA/ QC        Quality Assurance / Quality Control
RM            Ringgit Malaysia
t             Tons
UNFCCC        United Nations Framework Convention on Climate Change




Validation Report 01 997 9105043598 Revision No. 1.5
                                                       3
TABLE OF CONTENTS


1           EXECUTIVE SUMMARY – VALIDATION OPINION ......................................5

2           INTRODUCTION ............................................................................................6
2.1         Objective                                                                                                6
2.2         Scope                                                                                                    6

3           METHODOLOGY............................................................................................7
3.1         Desk Review of the Project Design Documentation                                                        7
3.2         Follow-up Interviews with Project Stakeholders                                                         9
3.3         Resolution of Outstanding Issues                                                                     10
3.4         Internal Quality Control                                                                             13
3.5         Validation Team                                                                                      13

4           VALIDATION FINDINGS ..............................................................................13
4.1         Participation Requirements                                                                        13
4.2         Project Design                                                                                    13
4.3         Baseline Determination                                                                            15
4.4         Additionality                                                                                     17
4.5         Monitoring                                                                                        19
4.6         Estimate of GHG Emissions                                                                         21
4.7         Environmental Impacts                                                                             22
4.8         Comments by Local Stakeholders                                                                  222
4.9         Comments by Parties, Stakeholders and NGOs                                                        23

Appendix A: Validation Protocol




Validation Report 01 997 9105043598 Revision No. 1.5
                                                          4
1 EXECUTIVE SUMMARY – VALIDATION OPINION
TÜV Rheinland has performed a validation of the proposed CDM project “KKSL Lekir
Biogas Project, Project BCM07_SLK_14” located at Lekir Palm Oil Mill, Batu 11,
Lekir, Setiawan, Perak Darul Ridzuan, Malaysia. 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 and on site visit have provided with sufficient evidence to determine the
fulfilment of stated criteria.
The host party is Malaysia and the Annex I party is The Netherlands. Both countries
fulfill the participation criteria. Malaysia ratified the Kyoto Protocol on 04 September
2002 whilst the Netherlands ratified on 31 May 2002. The DNA from Malaysia
confirmed that the project assists in achieving sustainable development. Both the
countries DNAs have approved the project and authorized the project participants to
request the said project to be considered for registration with UNFCCC.
The project correctly applies the approved methodology AMS.III.H “Methane
Recovery in Wastewater Treatment”, version 06.
The project activity involves covering two of the existing anaerobic open ponds to
capture methane-rich biogas from POME generated by the palm oil mill. The
captured biogas will be channeled to the dual fuel diesel-biogas generator for
combustion to generate electricity for use by project activity only and excess biogas
will be flared. The project utilizes technology transferred from the Netherlands in
capturing the biogas for combustion and knowledge transfer to upgrade the technical
skills of local technical personnel.
The mitigation potential of the project activity arises from the capture of methane,
which is currently emitted from the open wastewater ponds. The project activity will
reduce the methane greenhouse gas emissions and improve air quality with
reduction of odour.
The total emission reductions from the project are estimated to average 33,955tCO2e
per year over the selected 10 years crediting period. The emission reduction forecast
has been checked and it is deemed likely that the stated amount is achievable on the
basis that the underlying assumptions do not change.
Adequate training and monitoring procedures have been developed and will be
implemented when the project starts operations.
In summary, it is TÜV Rheinland’s opinion that the proposed CDM project “KKSL
Lekir Biogas Project, Project BCM07_SLK_14” located at Lekir Palm Oil Mill, Batu
11, Lekir, Setiawan, Perak, Malaysia as described in the revised PDD version 3.5
dated 20 June 2008, /2/ meets with the relevant UNFCCC requirements for the CDM
and correctly applies the baseline and monitoring methodology AMS.III.H, version 06.
Therefore, TÜV Rheinland would request the registration of the project as a CDM
project activity.




Validation Report 01 997 9105043598 Revision No. 1.5
                                                       5
2 INTRODUCTION
BioX Carbon Malaysia Sdn. Bhd., has commissioned TÜV Rheinland to perform a
validation of the CDM project “KKSL Lekir Biogas Project, Project BCM07_SLK_14”
located at Lekir Palm Oil Mill, Batu 11, Lekir, Setiawan, Perak Darul Ridzuan,
Malaysia”, (hereafter called “the project”). This report summarises the findings of the
validation of the project, performed on the basis of UNFCCC criteria for the CDM, as
well as criteria given to provide for consistent project operations, monitoring and
reporting. UNFCCC criteria refer to Article 12 of the Kyoto Protocol, the CDM
modalities and procedures, the simplified modalities and procedures for small-scale
CDM project activities and the subsequent decisions by the CDM Executive Board.

2.1 Objective
The purpose of a validation is to have an independent third party assess the project
design. In particular, the project’s baseline, monitoring plan, and the project’s
compliance with relevant UNFCCC and host Party criteria are validated in order to
confirm that the project design, as documented, is sound and reasonable and meets
the identified criteria. Validation is a requirement for all CDM projects 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).

2.2 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 methodology. The validation team has, based
on the recommendations in the Validation and Verification Manual employed a risk-
based approach, focusing on the identification of significant risks for project
implementation and the generation of 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.
The only purpose of a validation is its use during the registration process as part of
the CDM project cycle. Hence, TÜV Rheinland cannot be held liable by any party for
decisions made or not made based on the validation opinion, which will go beyond
that purpose.




Validation Report 01 997 9105043598 Revision No. 1.5
                                                       6
3.0       METHODOLOGY
The validation consists of the following three phases:
I      a desk review of the project design documents
II     follow-up interviews with project stakeholders
III    the resolution of outstanding issues and the issuance of the final validation
       report and opinion.
The following sections outline each step in more detail.

3.1       Desk Review of the Project Design Documentation
The following table outlines the documentation reviewed during the validation:
/1/    Initial PDD Version 2 dated 20 September 2007
/2/    Final PDD Version 3.5 dated 20 June 2008
/3/        Financial Calculations Excel Spreadsheet
/4/        IPCC 2006 Guidelines for National Greenhouse Gas Inventories, Volume 5 –
           Waste
/5/        AMS.III.H “Methane Recovery in Wastewater Treatment”, version 06.
/6/        Attachment A of Appendix B of the simplified modalities and procedures for
           small-scale CDM project activities
/7/        Host country approval dated 14 March 2008 (Attach 1a)
           Host country reissue Approval dated 6 May 2008
/8/        Annex 1 country approval dated 11 February 2008 (Attach 1b)
           Email confirmation from Dutch DNA on project title dated 29 April 2008
/9/        Project Timeline (undated) (Attach 2)
/10/       Monitoring Protocol and Work Instructions dated 12 February 2008 (Attach 3)
/11/       Cost Breakdown for Investment and O & M costs issued by Zebra Special
           Products dated 29 January 2008 (Attach 4)
/12/       Dual Fuel Engine specifications from Dortech dated 30 January 2008 (Attach 5)
/13/       Test Report issued by Union Laboratories dated 11 December 2007 (Attach 6)
/14/       Pilot Project COD measurement October to December 2007 (Attach 6a & 6c)
/15/       Contract FFB for year 2007 (Attach 7)
/16/       Laboratory tests results issued by Union Laboratories date 24 March 2008
           (Attach 8a & b)
/17/       Organisation Chart (Attach 9)
/18/       Oil Palm: The Agricultural Producer of Food, Fibre and Fuel for Global
           Economy by Yusof Basiron and Chan Kook Weng (Attach 10)
/19/       Business Collaboration Agreement between Biox Carbon Axis and Kilang
           Kelapa Sawit Lekir (KKSL) dated 08 August 2007

/20/       Biox Carbon Axis Board Resolution for CDM Joint Development with KKSL
           dated 07 August 2007


Validation Report 01 997 9105043598 Revision No. 1.5
                                                       7
/21/       KKSL BOD resolution for CDM project development with BioX Carbon Axis
           dated 08 August 2007

/22/       Department of Environment (DoE) EIA exemption letter dated 03 October 2007
/23/       Newspaper advertisement dated 27 August 2007 for Local Stakeholder Forum
/24/       Invitation letter dated 24 August 2007 for local stakeholder forum
/25/       MPOB Throughput License dated 29 May 2007
/26/       Department of Environment issued Mill Operating License dated 29 June 2004

           Department of Environment Approved Operating Tonnage and Schedule of
           Discharge Limits dated 30 June 2007
/27/       Bekaert Flare Specifications from Dortech dated 20 January 2008
/28/       Mill throughput process FFB tonnage for last 4 years (2004 to 2007)
/29/       List of Equipment – Power Demand for Project Activity (undated)
/30/       Extract from MetCalf & Eddy, 2004: Wastewater Engineering: Treatment and
           Reuse. 4th Edition, published by Mc Graw Hill (Chapters 10.1 & 10.6)
/31/       Ponds Depth drawing approved by Department of Environment dated 12 July
           2005
/32/       a. Extract from Industrial Process & The Environment (Handbook No. 3) Crude
              Palm Oil Industry issued by Department of Environment – page 40
           b. Extract from Study on Clean Development Mechanism Potential in the Waste
              Sectors in Malaysia conducted by Eco-Ideal Consulting Sdn. Bhd., –
              December 2004 page 49
/33/       CER calculation in a worst case scenario for increase in FFB processing
           tonnage and bioreactor efficiency.
/34/       Biogas Utilisation Flow Diagram dated 14 June 2008
/35/       Mill operating hours for year 2005 to 2007
/36        Application to MPOB for increase in processing capacity dated 28 February
           2008
/37/       Modalities of Communication dated 24 January 2008
/38/       International Emission Trading Association (IETA) & the World Bank’s
           Prototype Carbon Fund (PCF): Validation and Verification Manual.

When TÜV Rheinland received the initial PDD version 02 dated 20 September 2007
/1/, it is made publicly available on the internet at TÜV Rheinland’s webpage as well
as on the UNFCCC CDM-webpage for starting a 30 day global stakeholder
consultation process (GSP). The final PDD version 3.5 dated 20 June 2008 /2/ will
form the basis for the final evaluation as presented by this report. Information on the
first and final PDDs versions are presented at page 3 of the PDDs.
Main changes between the initial version published for the 30 days stakeholder
commenting period and the final version submitted for registration are as follows:
      •   Baseline and project emissions calculations. /3/


Validation Report 01 997 9105043598 Revision No. 1.5
                                                       8
      •   Project and operations costs /3/, /11/
      •   Change of project starting date and crediting period starting date
      •   Data and parameters monitored
      •   Monitoring Protocol and Work Instructions /10/

3.2       Follow-up Interviews with Project Stakeholders
Identify any personnel who have been interviewed and/or provided additional
information to the presented documentation.


          Date                         Name            Organization      Topic
/A/       2007-10-17                   Mr. Valentine   BioX Carbon       •   PDD
                                       Khoo,           Malaysia          •   Technology
                                       Mr. Sim Kean                      •   Baseline
                                       Hong,
                                                                         •   On site assessment
                                       Mr. Iskandar
                                       Majid,                            •   Additionality
                                       Mr.                               •   Monitoring Plan
                                       Asrulnizam                        •   Financial Analysis
                                       Alias,                            •   EIA Compliance
                                       Miss Norzila                      •   Confirmation of
                                                                             project participants
                                                                         •   Confirmation of Annex
                                                                             I party
                                                                         •   National Policy and
                                                                             Criteria
                                                                         •   Quality Assurance
                                                                         •   Project lifespan
/B/       2007-11-21                   Mr.             BioX Carbon      • Mill address
                                       Asrulnizam      Malaysia
                                                                        • Mill operations data,
                                       Alias,
                                       Mr. Mohd                         • Location of project
                                       Syahmi,                            activity,
                                       Mr. Richard                      • Electricity source
                                       Yong,                            • Current wastewater
                                                                          system compliance
                                       Mr. Goh Ah      Owner, Lekir
                                       Peng            Palm Oil Mill    • Interview of local
                                                                          community
                                       Mr. Razywan     Public Community • Local stakeholders
                                       Rahman,                            interviewees
                                       Mr. Yahya
                                       Mahmud,
                                       Mr. Sarkan
                                       Mohmin

Validation Report 01 997 9105043598 Revision No. 1.5
                                                       9
                                       Mr.
                                       Sivalingam
/C/      2007-12-17                    Mr. Sim Kean    BioX Carbon        •   Additionality
                                       Hong,           Malaysia           •   Financial calculations
                                       Mr.                                •   Project Funding
                                       Azrulnizam,
                                                                          •   Board of Directors
                                       Miss Norzila,
                                                                              approvals
                                       Mr. Valentine
                                                                          •   Project agreement
                                       Khoo
                                                                          •   Operating procedures
                                                       BioX BV                /work instructions
                                       Mr. Ruud van    Netherlands
                                       Os                                 •   Calibration and
                                                                              Training
                                                                          •   Archiving of data
                                                                          •   LoAs
                                                                          •   Modalities of
                                                                              Communications
/D/      2008-06-26                    Mr. Chan        JD Energy          • Supplier of Gas
                                       Huan Hin        Systems Sdn..        Engine & Gas Turbine
                                                       Bhd.,
                                       Mr. Low King    Q2 Engineering     • Flares and Flare
                                       Serng           Sdn. Bhd.,           System supplier
                                       Mr. MK Thong    Research           • Data Monitoring
                                                       Instruments Sdn.     System supplier
                                                       Bhd.,

3.3       Resolution of Outstanding Issues
The objective of this phase of the validation is to resolve any outstanding issues
which need be clarified prior to TÜV Rheinland’s positive conclusion on the project
design. The initial validation has in this draft validation report (revision 01) four (4)
corrective action requests (CARs) and fifteen (15) requests for clarification (CLs),
which have been presented to the project proponent. The project participant’s
respond to the initial findings, were included in the submission of the final PDD
version 3.5 dated 20 June 2008 /2/, addressed the raised requests to TÜV
Rheinland’s satisfaction.
In order to ensure transparency, a validation protocol is customised for the project.
The protocol shows in transparent manner criteria (requirements), means of
verification and the results from validating the identified criteria. The validation
protocol serves the following purposes:
•     It organises, details and clarifies the requirements a 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 two tables. The different columns in these tables
are described in the figure below. The completed validation protocol for the project

Validation Report 01 997 9105043598 Revision No. 1.5
                                                       10
“KKSL Lekir Biogas Project, Project BCM07_SLK_14” is enclosed in Appendix A to
this report.
Findings established during the validation can either be seen as a non-fulfilment of
CDM 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)       CDM and/or methodology specific 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.
A request for clarification (CL) may be used where additional information is needed to
fully clarify an issue.




Validation Report 01 997 9105043598 Revision No. 1.5
                                                       11
 Validation Protocol Table 1: Mandatory Requirements for CDM Project Activities
 Requirement                        Reference                 Conclusion
 The requirements the               Gives reference to        This is either acceptable based on evidence provided
 project must meet.                 the legislation or        (OK), a Corrective Action Request (CAR) of risk or
                                    agreement where           non-compliance with stated requirements or a request
                                    the requirement is        for Clarification (CL) where further clarifications are
                                    found.                    needed.

 Validation Protocol Table 2: Requirement checklist
 Checklist Question                 Reference          Means of             Comment               Draft and/or Final
                                                       verification                               Conclusion
                                                       (MoV)
 The various                        Gives              Explains how         The section is        This is either acceptable
 requirements in Table              reference          conformance with     used to               based on evidence
 2 are linked to                    to                 the checklist        elaborate and         provided (OK), or a
 checklist questions the            documents          question is          discuss the           corrective action
 project should meet.               where the          investigated.        checklist             request (CAR) due to
 The checklist is                   answer to          Examples of          question and/or       non-compliance with the
 organised in different             the                means of             the                   checklist question (See
 sections, following the            checklist          verification are     conformance to        below). A request for
 logic of the large-scale           question or        document review      the question. It      clarification (CL) is used
 PDD template, version              item is            (DR) or interview    is further used       when the validation
 03 - in effect as of: 28           found.             (I). N/A means not   to explain the        team has identified a
 July 2006. Each                                       applicable.          conclusions           need for further
 section is then further                                                    reached.              clarification.
 sub-divided.

 Validation Protocol Table 3: Resolution of Corrective Action and Clarification Requests
 Draft report                        Ref. to checklist            Summary of project           Validation conclusion
 clarifications and                  question in table 2          owner response
 corrective action
 requests
 If the conclusions from             Reference to the             The responses given          This section should
 the draft Validation are            checklist question           by the project               summarise the validation
 either a CAR or a CL,               number in Table 2            participants during the      team’s responses and final
 these should be listed in           where the CAR or CL          communications with          conclusions. The
 this section.                       is explained.                the validation team          conclusions should also be
                                                                  should be summarised         included in Table 2, under
                                                                  in this section.             “Final Conclusion”.
Figure 1 Validation protocol tables




Validation Report 01 997 9105043598 Revision No. 1.5
                                                               12
3.4       Internal Quality Control
The draft validation report including the initial validation findings underwent an
internal review before being submitted to the project participants. The final validation
report will undergo another technical review before requesting registration of the
project activity. To guarantee the transparency of the validation process, the
concerns raised and responses given are documented in the validation protocol in
Appendix A.

3.5       Validation Team
 Role/Qualification                      Last Name           First Name    Country
Team Leader                               Cheong            Robert CY     Malaysia
Internal Reviewer                        Brinkmann           Manfred       Japan


4         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.

4.1       Participation Requirements
The project participants are Kilang Sawit Lekir Sdn. Bhd. and BioX Carbon Axis Sdn
Bhd., both companies are from Malaysia and BioX Carbon BV, a company from The
Netherlands. The host party is Malaysia and the Annex I party, the Netherlands meet
with the requirements to participate in the CDM.
The Letter of Approval dated 14 March 2008, /7/ issued by the Malaysia DNA
confirmed that the proposed project assists in Malaysia’s sustainable development.
The Letter of Approval, dated 11 February 2008, /8/ issued by the DNA from the
Netherlands, confirmed that BioX Carbon BV is a project proponent to the proposed
CDM project.
The LoAs issued by both Malaysia and the Netherlands DNAs have been reviewed
and deemed appropriate in confirming that CDM is a voluntary participation and the
date when the countries ratify the Kyoto Protocol. During validation it was found that
the project title on the LoA issued by the Netherlands DNA bears a slightly different
project title. By email dated 26 April 2008 the project participants requested
confirmation that the LoA indeed refers to the published project. The DNA
representative confirmed this in the response on 29 April 2008. It is thus assumed
that the Dutch DNA is aware about the inconsistency in the project title, and that the
LoA is authentic and indeed refers to the project in question. /8/
There is no indication of any public funding for the project from both Parties included
in Annex I of the UNFCCC.




Validation Report 01 997 9105043598 Revision No. 1.5
                                                       13
4.2       Project Design
The proposed project “KKSL Lekir Biogas Project, Project BCM07_SLK_14” is
located at Lekir Palm Oil Mill, Batu 11, Lekir, Setiawan, Perak, Malaysia. The GPS
coordinates are 4.1505º N, 100.7823º E, and have been confirmed during the on-site
visit.
The mill has an approved processing capacity of 100 tons fresh fruit bunch (FFB) per
hour approval, issued by the Department of Environment /26/. The mill current
allowable throughput approved by the Malaysia Palm Oil Board is 360,000 tons per
year /25/. The mill has applied to MPOB /36/ for a capacity increase to 500,000 tons
per year, as the processing amount had exceeded the approved amount allocation
over the last 4 years. /28/
The aim of the project is to reduce GHG emissions from the current open ponding
system where methane is continuously emitted into the atmosphere. Currently the
wastewater from the mill is treated through the conventional open ponding system,
comprising cooling ponds, acidification ponds, anaerobic ponds and aerobic ponds,
before final discharge for land application. With regular desludging of the ponding
system and sufficient retention period, the treated water complies with the host
country environment requirements.
The project employs a technology transfer from the Netherlands in capturing
methane where two of the most active anaerobic ponds will be converted as
bioreactors to generate methane through the anaerobic biologic degradation of the
high organic content in the wastewater. The bioreactors are designed with sufficient
capacity to reduce the high organic content of the POME.
The captured biogas generated will be channeled to the dual fuel diesel-biogas
generator /12/, for combustion and generation of electricity solely for use by the
Project Activity, while excess biogas will be flared. The dual fuel generator is rated at
100kW which is sufficient to support the electricity demand of the equipment /29/
such as pumps, data recorder, gas analyser, flaring system, compressor and control
room having a peak power demand of approximately 90 kW.
There will be no electricity exported to the mill, given the abundance of biomass
waste available as fuel for the mill boilers generating process steam and steam for
captive electricity generation. There are no plans by the project participants to feed
the biogas as fuel for the boilers operation. With the limited capacity of the dual fuel
generators /12/, it is not possible to export electricity to the grid
A 2nd dual fuel generator will be installed as a standby unit to ensure no interruption
of power supply to the equipment, safeguarding the continuous operation and
monitoring of the project activity. The 2nd unit will operation only when the 1st unit
breaks down or taken out of service for maintenance. The biogas utilisation flow
diagram /34/ indicates only one unit of the generator to be in operations at any one
time. The changeover from one generator to another will be carried out manually.
/10/
An enclosed flares system /27/, as described in Annex 5 of the PDD, will be installed
to flare excess gas that is not combusted by the dual fuel generator. The flare system
is designed to operate automatically when the biogas production volume exceeds
what can be combusted by the dual fuel generator.
The treated effluent after the bioreactor will then be channeled to the subsequent
ponds for further treatment before being released for land application.
Validation Report 01 997 9105043598 Revision No. 1.5
                                                       14
The proposed project activity as described in the PDD section A.2 and A.4.2 will
provide sustainable development as follows:
     a) Environmental - reduction of the Methane and odor emissions that will result in
        improved air quality in the surrounding area whereby the methane will be
        captured for combustion and project activity utilisation as green energy as
        compared to the current wastewater treatment system where methane is
        continuously emitted into the atmosphere
     b) Economic and Social – transfer of technology to locals, improve the technical
        skills of local people to operate biogas capturing system and provide
        employment.
The PDD states that prior to the start of the crediting period a monitoring team will be
organised with their tasks and responsibilities to be clearly assigned. For this
purpose, a formal set of monitoring protocol and work instructions /10/ and site
organization chart /17/ have been established that will be implemented when the
project starts operations.
The final PDD version 3.5 dated 20 June 2008 identifies 08 August 2007 as the
project starting date, i.e. the day when the Business Collaboration Agreement /19/
between the project participants was signed, see section 4.4 below for details.
The project participants have chosen a fixed crediting period of 10 years, starting on
01 September 2008 or 3 months after the registration date. According to the PDD,
the expected operational lifetime of the project is 10 years. At the end of the
crediting period of 10 years, the project will be transferred to the mill at no cost for the
continuation operation and maintenance, as stated in the Business Collaboration
Agreement /19/.
At the time of on-site assessment on 21 November 2007 /B/, construction had not
started, and equipment had not been purchased. A project planning schedule has
been established /9/. As stated in the Business Collaboration Agreement /19/ the
project will be implemented upon successful registration with UNFCCC.
The overall emission reductions from the project activity will not exceed 60 ktCO2e
per year. From the baseline calculations, the estimated amount of emission
reductions are 339,550tCO2e over a 10 years fixed crediting period, which equals an
annual average emission reductions of 33,955tCO2e.
The validation did not reveal any information that indicates that the project can be
seen as a diversion of official development assistance (ODA) funding. The project will
be fully financed by BioX Carbon Axis Sdn. Bhd., /19/
The project is not a debundled component of a larger project activity and there is no
similar project activity within the 1km of the project boundary. A search conducted in
the UNFCCC web site and CDM Pipeline before completion of this report did not
show any similar projects registered by the same project participants and within 1km
of the project site.

4.3       Baseline Determination
The proposed CDM project applies the approved baseline methodology AMS-III.H.
“Methane Recovery in Wastewater Treatment” (version 06). Its applicability has been
justified to TÜV Rheinland in accordance with the requirements of the methodology
and the Simplified modalities and procedures for small–scale clean development
Validation Report 01 997 9105043598 Revision No. 1.5
                                                       15
mechanism project activities. As a type III not exceeding 60,000 tons of CO2eq per
year it is found eligible as small-scale project.
In order to determine whether or not the project is indeed eligible as a small-scale
project, the validation team has performed the following analysis:
     1) The total FFB processing amount has continuously increased in the period of
        2004 to 2007 /28/, growth slowing during the past three years (2005 to 2007).
        The average processing amount of FFB and average operating hours during
        the 3-year period were recorded as 550,000 tons of FFB and 6,350 operating
        hours, respectively. /35/
          By calculating the ratio of processing amount for each year and the respective
          mill operating hours /35/, it was found that the mill's actual processing capacity
          in 2005 to 2007 was stable at approximately 86 tons of FFB per hour, which is
          within the capacity approved by the Department of Environment.
     2) The maximum possible processing amount per year can thus be estimated as
          52 week/year x 6days/week x 24h/day x 86t/h = 644,000 t/a.
          (According to local labour requirements, one rest day must be observed in a
          week, therefore the assumption of 6 working days; it was confirmed during the
          site visit /B/ that the mill shuts down on Sunday each week)
          This figure is deemed conservative, as it does not include any shutdown for
          cleaning or maintenance work.
     3) The project participants have submitted a spreadsheet for calculating emission
        reductions, applying an even more optimistic production scenario with an
        annual processing amount of 700,000 tons of FFB per year. The annual
        emission reductions have therein correctly and consistently been calculated at
        54,000 tons of CO2e per year /33/. This is within the limit of 60ktonsCO2e.
        Therefore, the application of the small scale methodology is considered
        justified.
The project activity as described and observed fully corresponds to the scenario in
clause 1.(iv) of the selected methodology, i.e. “Introduction of methane recovery and
combustion to an existing anaerobic wastewater treatment system such as anaerobic
reactor, lagoon, septic tank or an on site industrial plant”.
The baseline scenario is based on the assumption that the mill continues to operate
at the same level as during the last 3 years, with an average throughput of
550,000mt of FFB per year /28/ generating 330,000 m3 of POME (calculation based
on literature data /32b/ that 1 ton of FFB generates 0.6 m3 of POME).
The project boundary has been clearly determined in accordance with the
methodology (see following table). A comprehensive overview about all emissions
included in the project boundary is provided in the PDD section B.6.1 for project
activity emissions and baseline emissions




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                            Source                     Gas   Included     Justification / Explanation
   Baseline

                      Direct emissions from
                                                                        Methane emissions from
                         the waste water               CH4     Yes
                                                                        anaerobic process
                      treatment processes

                                                                        Methane       emissions      from
                        Biogas Bioreactor              CH4     Yes
                                                                        anaerobic process
                                                                        Methane emissions from
                        Anaerobic ponds                CH4     Yes
                                                                        anaerobic process
   Project Activity




                                                                        CO2 emissions from diesel
                       Dual fuel generator             CO2     Yes
                                                                        burning
                                                                        The amount of methane gas
                                                                        combusted in the dual fuel
                                                       CH4     Yes
                                                                        generator would be closely
                         Flaring System                                 monitored.
                                                                        The amount of methane gas
                                                       CH4     Yes      combusted in the flare would be
                                                                        closely monitored.



4.4                   Additionality
Part B.5 of the PDD has demonstrated that the project applies the comprehensive
barrier analysis from the “Attachment A of Appendix B of the simplified modalities
and procedures for small-scale CDM project activities /6/.
The project participant has demonstrated additionality for this project by applying a
financial analysis /6/, showing the investment as the key barrier for the
implementation of the project.
Investment barrier:
             As described in the PDD, the investment barrier is considered to be the most
             significant barrier to the project scenario. The Business Collaboration Agreement
             /19/ states that BioX Carbon Axis is fully accountable for the investment
             (bioreactor conversion, dual fuel engines, flaring and monitoring systems) as well
             as for the corresponding operating and maintenance costs. The project itself does
             not create any revenues other than potential earnings from the generation of
             CER’s. Thus the return on investment is negative in the absence of CDM
             revenues.
             The submitted spreadsheets for investment calculations /3/ correspond to the
             quotation summary of required investments and operating and maintenance costs
             /11/. The validation team has reviewed the documents during on site assessment
             and compared the main investment items (engines, flares, monitoring system)
             with suppliers of similar equipment by telephone interviews /D/ and found the
             indicated cost levels plausible.
             The earnings from the CERs will finance the project as there are no other
             incomes to support the project implementation. The earnings from the CERs will

Validation Report 01 997 9105043598 Revision No. 1.5
                                                              17
     be shared between both project participants at a ratio as stated in the agreement.
     At the end of the crediting period, the project will be transferred to the mill at no
     cost. /19/
     Operational costs are plausible as BioX Carbon Axis (project proponent) will
     employ permanent technical support engineers and plant operation personnel to
     operate and maintain the entire system /10/. The mill operator will provide
     supporting staff to assist in maintaining the project in preparation for takeover of
     the operation and maintenance after the crediting period expires.
     In the PDD table B.5.1 and 5.2 a sensitivity analysis was performed to determine
     with the change in investment or operations and maintenance costs variables.
     The validation team has confirmed the correctness of calculations, which indicate
     that the proposed project cannot be implemented when undertaken without CDM
     consideration.
     Hence, the proposed project activity cannot be considered economically and
     financially viable without revenues generated from the sale of CERs.
     The project is not a baseline scenario as the palm oil mill owners would not
     change their current practice of using ponding system /32/ to treat the POME and
     will not invest in sophisticated system as such investment will not bring any
     financial benefits and returns to them. The palm oil mill owners do not have the
     motivation to change their wastewater management system as there are no laws
     or regulatory directives driving such a change and the upgrading costs will be
     prohibitive.
     Open ponding system /32/ is an accepted wastewater treatment system adopted
     by palm oil mills for the past 50 years to treat POME which is the most plausible
     approach that will meet the local Department of Environment discharge limits
     stipulated in the permit issued. POME is considered as a high strength industrial
     wastewater and using anaerobic lagoons system will be the most economical
     options. One of the main advantages for lagoon system is the ability to handle the
     POME wide range of waste characteristics including solids and oil & grease.
     Besides, it is simple and relatively economical to construct, can provide
     equalization of loads and high effluent quality. /30/
     There is no existing, pending, or planned national, state, or local regulatory
     requirements that govern GHG emissions from wastewater treatment operations.
     However, the existing open ponding wastewater treatment concept used by the
     project activity mill is able to treat the POME to the schedule discharge limit set by
     Department of Environment. /26/ The Department of Environment continues to
     approve open ponding wastewater treatment system whether for a new mill or an
     upgraded mill since this method is the most economical to operate and able to
     meet the discharge limits.


Conclusion:
TÜV Rheinland was able to verify that CDM has been introduced and considered
prior to the project starts:
    • Both the joint project participants BioX Carbon Axis Sdn., Bhd., and Kilang
        Kelapa Sawit Lekir, have signed a Business Collaboration Agreement /19/
        dated 08 August 2007 for developing the project, under the precondition that
        the project would be registered as CDM project.
Validation Report 01 997 9105043598 Revision No. 1.5
                                                       18
     •    Both companies Board of Directors and Management meetings had been held
          authorising the company to enter into a Business Collaboration for the joint
          development of CDM project at the mill. /20/, /21/
Finally, the assessment of the arguments presented above is deemed sufficient to
demonstrate that the project is not likely the baseline scenario and the emission
reductions resulting from the project are additional.

4.5       Monitoring
The project activity applies the approved monitoring methodology AMS-III.H. /5/
“Methane Recovery in Wastewater Treatment” (version 06). The selected monitoring
methodology is applicable to the project in the recovery of methane emissions
through capturing for combustion.
It has been assessed that the project correctly addresses all factors required by the
methodology as provided in the most recent PDD guidelines. Annex 4 contains the
further background information from the monitoring plan (e.g. tables measurement
equipment, procedures, etc.).

4.5.1 The following data are determined ex-ante:
The following data and parameters were available during the validation and will
remain fixed ex-ante throughout the crediting period:
1. Biogas Generation Potential (Bo,)
2. Global Warming Potential (GWP_CH4)
3. Methane correction factor (MCF)
4. Dissolved Methane (CH4)
5. Net Calorific Value for Diesel (NCVdiesel)
6. Emission Factor for Diesel (EFdiesel)
The IPCC default value of 0.21 kg CH4 / kg COD for the biogas generation potential
(Bo) is in accordance to the methodology stated value.
The Global Warming Potential selected is 21 as the current commitment period
default value.
Methane correction factor applied is in accordance to Table III.H.I of AMS-III.H.
version 06. The depth of the anaerobic ponds /31/ are not be less than 2 metres that
is one of the conditions mentioned in the Written Approval Permit /26/ to construct
and commission wastewater treatment plant issued by the Department of
Environment. The approval permit includes the approved drawing /31/ of the ponds
with depth of 6.6meters.
The dissolved methane value applied is the default value of 10-4 tonnes/m3 in
accordance to AMS-III.H. version 06.
The Net Calorific Value and Emission Factor for diesel are IPCC 2006 default values.
The values chosen are appropriate, transparent and conservative.




Validation Report 01 997 9105043598 Revision No. 1.5
                                                       19
4.5.2 Parameters monitored ex-post
The baseline and project emission parameters that are monitored ex-post are
indicated in Section B.7.1 and Annex 3 of the PDD and as follows:
     •    Wastewater flows entering Bioreactor line A
     •    Wastewater flows entering Bioreactor line B
     •    Wastewater flows leaving Bioreactor line A
     •    Wastewater flows leaving Bioreactor line B
     •    Wastewater organic material concentration entering Bioreactor (inlet) Line A
     •    Wastewater organic material concentration entering Bioreactor (inlet) Line B
     •    Wastewater organic material concentration leaving Bioreactor (outlet) Line A
     •    Wastewater organic material concentration leaving Bioreactor (outlet) Line B
     •    Biogas sent to enclosed flares
     •    Biogas sent to dual fuel generator. The amount of gas channeled to the
          generating set to produce electricity for the project activity.
     •    Diesel consumption for dual fuel generator. The amount of diesel consumed
          by the engine when in operation.
     •    End-use of the final sludge. Current practice, the sun dried sludge is returned
          to the plantation as soil conditioner.
     •    Fraction of methane in biogas
     •    Temperature of the Flare
The GHG indicators, parameters, monitoring methods, frequencies and
measurement equipments are acceptable. Data for the lagoon flow rate of POME
from the digester are aggregated according to the requirements of AMS-III.H.
Where applicable, the parameters and assumptions are according to the respective
default and available values of IPCC 2006 /4/ and are current commitment period
values.
Desludging of anaerobic ponds generally in every 24 months is one of the
Department of Environment approval /26/ conditions that palm oil mill need to carry
out. During the on site assessment on 21 November 2007 /B/, the palm oil mill has
demonstrated that there is a sludge holding pond where the sludge is been sun dried
and then disposed to the nearby plantations as soil conditioner as confirmed by the
mill owner.
The monitoring of emission reductions generated by the project activity will be carried
out systematically according to the monitoring plan. All relevant parameters are
monitored as required by methodology and to ensure anaerobic conditions occurs
throughout the project activity implementation
It has been assessed that all parameters required by the methodology have been
included in the PDD Section B.7.1.
All monitoring data will be electronically archived for a period of 2 years after the
crediting period.

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                                                       20
4.5.3 Management system and quality assurance
TÜV Rheinland assessed the proposed management system and how quality will be
assured by the proposed project activity.
A monitoring plan has been provided in the PDD Section B.7.2 and Annex 4
describes, that a formal set of monitoring standard operating procedures (SOPs) /10/
has be established including the organisation chart /17/, control and steps required
for the key monitoring system features.
A management and operational system will be implemented that covers operation
and management of the monitoring and record keeping such as:
     a) Data handling
     b) Quality Assurance
     c) Training
     d) Project Management
     e) Maintenance
All measurements will use calibrated measurement equipment that will be maintained
regularly and checked for its functioning.
Hence, all indicators of importance for controlling and reporting of projects
performance have been incorporated in the monitoring plan as well as indicated in
the planned formal set of monitoring protocol and work instructions.

4.6          Estimate of GHG Emissions
The emission reductions are generated by introducing a recovery and combustion
system to the existing anaerobic wastewater treatment facility, enabling the
destruction of methane that is formed as a result of the Palm Oil Mill effluent’s
(POME) biodegradation in the bioreactor.
The formula below as stated in PDD is applied correctly and in accordance to the
methodology AMS-III.H. Version 06.
MEP y, ww treatment = Q y, ww x COD y, ww, untreated x B o, ww x MCF ww, final
Where:
     (i)        Methane emission potential of the wastewater in the year, y (tCH4/y)
                MEPy, ww
     (ii)       Volume of wastewater treated in the year, y (m3/y) Q y, ww
     (iii)      Chemical oxygen demand of the treated wastewater in the year, y
                (tonnes/m3) COD y, ww, untreated
     (iv)       Methane producing capacity for the wastewater (The default value of 0.21
                kg CH4/ kg COD) B o, ww
     (v)        Methane correction factor based on type of treatment and discharge
                pathway of the wastewater (fraction) MCF higher value in table III.H.I for
                sea, river and lake discharge i.e. 1.0 ) MCF ww, final
     (vi)       Global Warming Potential for methane (value of 21 is used) GWP_CH4
Project emissions considered in the monitoring plan as follows:

Validation Report 01 997 9105043598 Revision No. 1.5
                                                       21
     1. Emissions from power consumption by Project Activity
     2. Volume of diesel required by Dual Fuel generator
     3. Methane emission of inefficiency of the wastewater treatment & presence of
        degradable organic carbon in treated wastewater
     4. Emission from flaring/combustion inefficiency
     5. Emission from dissolved methane in treated wastewater
The total emission reductions are subtracting the project emissions from the baseline
emissions.
The emissions reduction formula applied below is correct:

ERy = BEy – (PEy + Leakagey)
The calculation of emission reductions (ERy) is based on the amount of methane
(BEy) recovered, deducting project emissions (PEy) and any leakages. These data
will be monitored ex-post.
All equipments are new and not transferred from another activity. According to
methodology leakages need not to be considered.
Hence, the expected emissions reductions were calculated to be 339,550tCO2e over
a 10 (ten) years crediting period.

4.7       Environmental Impacts
The project activity will not have any adverse environmental impacts but will provide
following environment benefits:
             •       Reduction of methane emission.
             •       Generation of green energy.
             •       Significant reduction of odour.
This project does not require an EIA study and exemption has been obtained from
the Department of Environment. An exemption letter /22/ was issued by the
Department of Environment dated 03 October 2007.

4.8       Comments by Local Stakeholders
There is no local requirement to carry out local stakeholder consultation in the host
country. The local stakeholder forum was held on 06 September 2006 is to fulfil the
requirements of CDM Modalities and Procedures §37b
Local stakeholders have been invited to the forum held at Kilang Kelapa Sawit Lekir
Sdn. Bhd, located at Lekir, Setiawan, Perak, Malaysia on 06 September 2007. The
relevant stakeholders have been invited by letter /24/ and via public invitations in the
newspapers, “New Straits Times” and “Berita Harian” dated 27 August 2007. /23/
Comments received at the forum were regarding Kyoto Protocol, cost of project and
amount of methane capture. Participants at this consultation did not raise any
objections or concerns with regards to the implementation of the project. A summary
of the comments has been provided in the PDD Section E.1.



Validation Report 01 997 9105043598 Revision No. 1.5
                                                       22
During the on site validation on 21 November 2007, local communities have been
interviewed to obtain feedback on the project and they support the project with
positive comments.

4.9       Comments by Parties, Stakeholders and NGOs
The PDD of 20 September 2007 was made publicly available on UNFCCC server
climate change website link as below
http://cdm.unfccc.int/Projects/Validation/DB/ART3B7X4AMF641C3QZG72HBJTCOL
DJ/view.html
 and Parties, stakeholders and NGOs were invited to provide comments during a 30
days period from 02 October 2007 – 31 October 2007.
There were no comments received during the period.




Validation Report 01 997 9105043598 Revision No. 1.5
                                                       23
                                                         APPENDIX A

                                                  CDM VALIDATION PROTOCOL
                                       KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                  REPORT NR. 01 997 9105043598




CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                               1
Table 1           Mandatory Requirements for Clean Development Mechanism (CDM) Project Activities
                     Requirement                             Reference          Conclusion     Cross Reference / Comment
About Parties
1. The project shall assist Parties included in Kyoto Protocol Art.12.2            OK        Table 2, Section A.2.1 Annex I
    Annex I in achieving compliance with                                                     Party is from the Netherlands.
    part of their emission reduction
    commitment under Art. 3.
2. The project shall assist non-Annex I Kyoto Protocol Art.12.2.                   OK        Table 2, Section A.2.1
   Parties in contributing to the ultimate
   objective of the UNFCCC.
3. The project shall have the written Kyoto Protocol Art. 12.5a, CDM              CAR 1      Approvals        of    voluntary
   approval of voluntary participation from Modalities and Procedures §40a         OK        participation from the DNAs in
   the designated national authority of each                                                 Malaysia and the Netherlands
   Party involved.                                                                           have been received.
4. The project shall assist non-Annex I Kyoto Protocol Art. 12.2, CDM             CAR 2      Table    2,  Section    A.2.2
   Parties    in    achieving    sustainable Modalities and Procedures §40a        OK        Confirmation from Malaysia
   development and shall have obtained                                                       DNA has been received (LoA).
   confirmation by the host country thereof.
5. In case public funding from Parties Decision 17/CP.7, CDM Modalities             OK       The review of documents and
   included in Annex I is used for the project and Procedures Appendix B, § 2                the interviews during the on-
                                                                                (No public
   activity, these Parties shall provide an                                                  site assessment showed that
                                                                                  funding
   affirmation that such funding does not                                                    no ODA is used for the project
                                                                                 involved)
   result in a diversion of official                                                         financing.
   development assistance and is separate
   from and is not counted towards the
   financial obligations of these Parties.


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                  2
                     Requirement                     Reference                Conclusion     Cross Reference / Comment
6. Parties participating in the CDM shall CDM Modalities and Procedures §29      OK        Malaysia DNA is Conservation
   designate a national authority for the                                                  and              Environmental
   CDM.                                                                                    Management Division, Ministry
                                                                                           of Natural Resources and
                                                                                           Environment;
                                                                                           The DNA from Netherlands is
                                                                                           the Ministry of Housing, Spatial
                                                                                           Planning and the Environment.
7. The host Party and the participating CDM Modalities §30/31a                   OK        Malaysia ratified the Kyoto
   Annex I Party shall be a Party to the                                                   Protocol on 04 September
   Kyoto Protocol.                                                                         2002;
                                                                                           Netherlands ratified the Kyoto
                                                                                           Protocol on 31 May 2002.
8. The participating Annex I Party’s assigned CDM Modalities and Procedures      OK
    amount shall have been calculated and §31b
    recorded.
9. The participating Annex I Party shall have CDM Modalities and Procedures      OK
    in place a national system for estimating §31b
    GHG emissions and a national registry in
    accordance with Kyoto Protocol Article 5
    and 7.
About additionality
10. Reduction in GHG emissions shall be Kyoto Protocol Art. 12.5c, CDM           OK        Table 2, Section B.3
   additional to any that would occur in the Modalities and Procedures §43
   absence of the project activity, i.e. a
   CDM project activity is additional if
   anthropogenic emissions of greenhouse


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                          3
                     Requirement                         Reference                 Conclusion     Cross Reference / Comment
    gases by sources are reduced below
    those that would have occurred in the
    absence of the registered CDM project
    activity.
About forecast emission reductions and
environmental impacts
11. The emission reductions shall be real, Kyoto Protocol Art. 12.5b                  OK        Table 2, Section B.4
   measurable and give long-term benefits                                                       to B.7
   related to the mitigation of climate
   change.
For large-scale projects only
12. Documentation on the analysis of the CDM Modalities and Procedures                Not       Not Applicable
   environmental impacts of the project §37c                                       Applicable
   activity, including transboundary impacts,
   shall be submitted, and, if those impacts
   are considered significant by the project
   participants or the Host Party, an
   environmental impact assessment in
   accordance with procedures as required
   by the Host Party shall be carried out.
About small-scale project activities (if
applicable)
13. The proposed project activity shall meet Simplified           Modalities and      OK        Table 2, Section A.5.2
   the eligibility criteria for small scale CDM Procedures for Small Scale CDM                  There is no other similar project
   project activities set out in § 6 (c) of the Project Activities §12a,c                       within 1 km of the project
   Marrakech Accords and shall not be a                                                         registered under the name of


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                              4
                     Requirement                     Reference                Conclusion     Cross Reference / Comment
    debundled component of a larger project                                                the project participants.
    activity.
14. The proposed project activity shall Simplified        Modalities    and      OK        Table 2, Section B.1.1
   confirm to one of the project categories Procedures for Small Scale CDM                 The project is applying the
   defined for small scale CDM project Project Activities §22e                             approved               baseline
   activities and use the simplified baseline                                              methodology     AMS-III.H.     –
   and monitoring methodology for that                                                     Methane        Recovery       in
   project category.                                                                       Wastewater Treatment Version
                                                                                           06
15. If required by the host country, an Simplified           Modalities and      OK        Table 2, Section D.1.2
   analysis of the environmental impacts of Procedures for Small Scale CDM                 The project does not require an
   the project activity is carried out and Project Activities §22c                         EIA study as confirmed by the
   documented.                                                                             Department of Environment of
                                                                                           by the host country.
About stakeholder involvement
16. Comments by local stakeholders shall CDM Modalities and Procedures           OK        Table 2, Section E.1.1 & E.1.2
   be invited, a summary of these provided §37b                                            The       public     stakeholder
   and how due account was taken of any                                                    consultation      forum     was
   comments received.                                                                      announced in local newspapers
                                                                                           New Straits Times and Berita
                                                                                           Harian on 27 August 2007. The
                                                                                           public stakeholder consultation
                                                                                           forum was conducted on 06
                                                                                           September       2007    at   the
                                                                                           premises of Kilang Kelapa
                                                                                           Sawit Lekir at Sitiawan, Perak.
17. Parties, stakeholders and UNFCCC CDM Modalities and Procedures §40           OK        PDD       was    published    for
   accredited NGOs shall have been invited                                                 invitation of comments for a 30

CDM Validation Report, No. 9105043598
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                                                          5
                     Requirement                      Reference                Conclusion    Cross Reference / Comment
      to    comment     on   the  validation                                                days period from 02 October
      requirements for minimum 30 days, and                                                 2007 to 31 October 2007 and
      the project design document and                                                       no comments were received.
      comments have been made publicly
      available.
Other
18.      The    baseline    and   monitoring CDM Modalities and Procedures        OK        The baseline and monitoring
      methodology     shall  be   previously §37e                                           methodology was approved at
      approved by the CDM Executive Board.                                                  EB 33 on 27 July 2007
19. A baseline shall be established on a CDM Modalities and Procedures            OK        The     baseline   has  been
   project-specific basis, in a transparent §45c,d                                          established in a transparent
   manner and taking into account relevant                                                  manner as stated in PDD
   national and/or sectoral policies and
   circumstances.
20. The baseline methodology shall exclude CDM Modalities and Procedures §47      OK        This has been considered in
   to earn CERs for decreases in activity                                                   the project emissions.
   levels outside the project activity or due
   to force majeure.
21. The project design document shall be in CDM Modalities and Procedures         OK        The PDD is in conformance
   conformance with the UNFCCC CDM- Appendix B, EB Decision                                 with UNFCCC format CDM-
   PDD format.                                                                              SSC-PDD Version 03
22. Provisions for monitoring, verification CDM Modalities and Procedures         OK        This has been considered in
   and reporting shall be in accordance with §37f                                           the monitoring plan.
   the modalities described in the
   Marrakech      Accords     and   relevant
   decisions of the COP/MOP.


CDM Validation Report, No. 9105043598
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Table 2           Requirements Checklist
                        CHECKLIST QUESTION
                                                                                                                                     Draft   Final
  * MoV = Means of Verification, DR= Document Review,                  Ref.   MoV*                  COMMENTS
                                                                                                                                    Concl.   Concl.
                      I= Interview
    A. General Description of Project Activity
     The project design is assessed.
A.1. Project Boundaries
          Project Boundaries are the limits and borders defining
          the GHG emission reduction project.
A.1.1. Are the project’s spatial boundaries (geographical)                    DR,    The project is located at Lekir Palm Oil       CL.1      OK
       clearly defined?                                                              Mill at Batu 11, Lekir, 32030, Setiawan,
                                                                                     Perak Darul Ridzuan.
                                                                                     CL.1      Kindly    advice     the   correct
                                                                                     coordinates for the location of the project
                                                                                     activity.
A. 1.2. Are the project’s system boundaries (components                       DR,    Yes. The project boundary includes the         CL 2      OK
       and facilities used to mitigate GHGs) clearly                           I     covering up of the two (2) most active
       defined?                                                                      anaerobic      ponds      converting    into
                                                                                     bioreactors to capture methane-rich
                                                                                     biogas to generate electricity with a dual
                                                                                     fuel generator for the project activity
                                                                                     consumption only. Excess gas will be
                                                                                     flared.
                                                                                     CL.2: Kindly indicate in the PDD a
                                                                                     diagram of the baseline boundary in
                                                                                     addition to project activity boundary of
                                                                                     Figure B.1 and schematic diagram of the
                                                                                     project activity of Figure A.3
A.2. Participation Requirements


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                        CHECKLIST QUESTION
                                                                                                                                Draft   Final
  * MoV = Means of Verification, DR= Document Review,              Ref.   MoV*                  COMMENTS
                                                                                                                               Concl.   Concl.
                        I= Interview
       Referring to Part A, Annex 1 and 2 of the PDD as
       well as the CDM glossary with respect to the terms
       Party, Letter of Approval, Authorization and Project
       Participant.
A.2.1. Which Parties and project participants are                         DR,    The project participants are Kilang Sawit      OK       OK
       participating in the project?                                       I     Lekir Sdn. Bhd. and BioX Carbon Axis
                                                                                 Sdn Bhd., both are private companies in
                                                                                 Malaysia. BioX Carbon BV the project
                                                                                 participant from the Netherlands.
A.2.2. Have all involved Parties provided a valid and                     DR,    CAR 1: The confirmation of the host           CAR 1     OK
       complete letter of approval and have all                            I     country and the Annex 1 country has not
       private/public project participants been authorized                       been received yet. The Malaysia and the
       by an involved Party?                                                     Netherlands       Designated       National
                                                                                 Authorities requires a draft validation
                                                                                 report to issue the Letter of Approval.
A.2.3. Do all participating Parties fulfil the participation              DR     Yes. Malaysia ratified the Kyoto Protocol      OK       OK
       requirements as follows:                                                  on 04 September 2002 for voluntary
       - Ratification of the Kyoto Protocol                                      participation   in    GHG      emissions
                                                                                 reductions. The DNA is Conservation
       - Voluntary participation
                                                                                 and Environmental Management Division
       - Designated a National Authority                                         of the Ministry of Natural Resource and
                                                                                 Environment.
                                                                                 The Netherlands is the Annex 1 country,
                                                                                 ratified the Kyoto Protocol on 31 May
                                                                                 2002. The DNA is the Ministry of
                                                                                 Housing, Spatial Planning and the

CDM Validation Report, No. 9105043598
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                        CHECKLIST QUESTION
                                                                                                                                Draft   Final
  * MoV = Means of Verification, DR= Document Review,               Ref.   MoV*                  COMMENTS
                                                                                                                               Concl.   Concl.
                      I= Interview
                                                                                  Environment.
A.2.4. Potential public funding for the project from Parties               DR,    The review of documents did not reveal        OK       OK
       in Annex I shall not be a diversion of official                      I     any information indicating, that ODA is
       development assistance.                                                    used for financing the project. No
                                                                                  diversion of ODA occurs.
A.3. Technology to be employed
          Validation of project technology focuses on the project
          engineering, choice of technology and competence/
          maintenance needs. The validator should ensure that
          environmentally safe and sound technology and know-
          how is used.
A.3.1. Does the project design engineering reflect current                 DR,    The project design engineering reflects       OK       OK
       good practices?                                                      I     good practise where the methane is
                                                                                  captured and combusted to generate
                                                                                  electricity instead of current practice
                                                                                  allowing the methane to escape into the
                                                                                  atmosphere.
A.3.2. Does the project use state of the art technology or                 DR,    Yes. The project activity employs the         OK       OK
       would the technology result in a significantly better                I     technology transfer from the Netherlands
       performance than any commonly used technologies                            which is above local standard.
       in the host country?
A.3.3. Does the project make provisions for meeting                        DR,    CL.3: At the time of validation, there are   CL.3      OK
       training and maintenance needs?                                      I     no documented procedures made
                                                                                  available to the validation team for the
                                                                                  monitoring activities as describe in Annex
                                                                                  4 for training and maintenance needs.


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                        CHECKLIST QUESTION
                                                                                                                             Draft   Final
 * MoV = Means of Verification, DR= Document Review,               Ref.   MoV*                 COMMENTS
                                                                                                                            Concl.   Concl.
                      I= Interview
A.4. Contribution to Sustainable Development
          The project’s contribution to sustainable development
          is assessed.
A.4.1. Has the host country confirmed that the project                    DR,    CAR 2: The letter of approval from host    CAR 1     OK
       assists it in achieving sustainable development?                    I     country which confirms the project’s
                                                                                 assistance in achieving sustainable
                                                                                 development has not been received.
A.4.2. Will the project create other environmental or social              DR,                                                OK       OK
                                                                                 The proposed project activity as
       benefits than GHG emission reductions?                              I     described in the PDD section A.2 and
                                                                                 A.4.2    will    provide   sustainable
                                                                                 development as follows:
                                                                                 a) Environmental - reduction of the
                                                                                    Methane and odor emissions that will
                                                                                    result in improved air quality in the
                                                                                    surrounding area whereby the
                                                                                    methane will be captured for
                                                                                    combustion and project activity
                                                                                    utilisation as green energy as
                                                                                    compared to the current wastewater
                                                                                    treatment     system    will     have
                                                                                    continuous methane emitted to the
                                                                                    atmosphere
                                                                                 b) Economic and Social – transfer of
                                                                                    technology to locals, improve the
                                                                                    technical skills of local people to
                                                                                    operate biogas capturing system and

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                        CHECKLIST QUESTION
                                                                                                                                 Draft   Final
  * MoV = Means of Verification, DR= Document Review,                Ref.   MoV*                 COMMENTS
                                                                                                                                Concl.   Concl.
                      I= Interview
                                                                                      provide employment.
A.5. Small scale project activity
          Tit is assessed whether the project qualifies as small-
          scale CDM project activity
A.5.1 Does the project qualify as a small scale CDM                         DR,    Yes, The project activity is a small scale    OK       OK
       project activity as defined in paragraph 6 (c) of                     I     CDM category as the emission
       decision 17/CP.7 on the modalities and procedures                           reductions does not exceed 60ktCO2 per
       for the CDM?                                                                year.
A.5.2 Is the small scale project activity not a debundled                   DR     The project activity is not a debundled       OK       OK
       component of a larger project activity?                                     component of a larger project activity as
                                                                                   there are no similar projects implemented
                                                                                   by the same project participants and
                                                                                   same technology within 1km from this
                                                                                   project location.
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. Does the project apply an approved methodology                       DR     The project applies the approved              OK       OK
       and the correct version thereof?                                            baseline methodology AMS-III.H. –
                                                                                   Methane Recovery in Wastewater
                                                                                   Treatment Version 06 from Appendix B

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                        CHECKLIST QUESTION
                                                                                                                                 Draft   Final
  * MoV = Means of Verification, DR= Document Review,                Ref.   MoV*                 COMMENTS
                                                                                                                                Concl.   Concl.
                      I= Interview
                                                                                   Simplified Modalities and Procedures for
                                                                                   small scale CDM projects.
B.1.2. Are the applicability criteria in the baseline                       DR     Yes, the project fulfils the applicability    OK       OK
       methodology all fulfilled?                                                  criteria and comply the requirements of
                                                                                   AMS-III.H. for Methane recovery in
                                                                                   Wastewater Treatment by means of the
                                                                                   following technology:
                                                                                   (i) Introduction of methane recovery
                                                                                         and combustion to an existing
                                                                                         anaerobic wastewater treatment
                                                                                         system such as anaerobic reactor,
                                                                                         lagoon, septic tank or an on site
                                                                                         industrial plant.
B.2. Baseline Scenario Determination
             The choice of the baseline scenario will be validated
             with focus on whether the baseline is a likely
             scenario, and whether the methodology to define the
             baseline scenario has been followed in a complete
             and transparent manner.
B.2.1. What is the baseline scenario?                                       DR     The chosen baseline is clause 6 (iv) of       OK       OK
                                                                                   the    methodology    “Introduction  of
                                                                                   methane recovery and combustion to an
                                                                                   existing anaerobic wastewater treatment
                                                                                   system such as anaerobic reactor,
                                                                                   lagoon, septic tank or an on site
                                                                                   industrial plant”.


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                        CHECKLIST QUESTION
                                                                                                                                 Draft   Final
  * MoV = Means of Verification, DR= Document Review,             Ref.   MoV*                  COMMENTS
                                                                                                                                Concl.   Concl.
                      I= Interview
                                                                                In the absence of the proposed project
                                                                                activity, the alternative been identified for
                                                                                the treatment of the organic wastewater
                                                                                is:
                                                                                • There would be continuation of
                                                                                     current practice (existing lagoon
                                                                                     based waste water treatment system)
                                                                                     without methane recovery
B.2.2. What other alternative scenarios have been                        DR     There are no alternative scenarios have          OK       OK
       considered and why is the selected scenario the                          not been considered, as this is not
       most likely one?                                                         required by the methodology.
B.2.3. Has the baseline scenario been determined                         DR     Yes. The baseline of this project activity       OK       OK
       according to the methodology?                                            has been determined according to AMS-
                                                                                III.H. Version 06 baseline applicability
                                                                                “Introduction of methane recovery and
                                                                                combustion to an existing anaerobic
                                                                                wastewater treatment system such as
                                                                                anaerobic reactor, lagoon, septic tank or
                                                                                an on site industrial plant”.
B.2.4. Has the baseline scenario been determined using                   DR,    The baseline scenario has applied                OK       OK
       conservative assumptions where possible?                           I     conservative assumptions for calculating
                                                                                the baseline emissions the project.
B.2.5. Does the baseline scenario sufficiently take into                 DR     Yes. There are presently no Government           OK       OK
       account relevant national and/or sectoral policies,                      regulations or policies in place to recover
       macro-economic trends and political aspirations?                         methane from anaerobic lagoons in the
                                                                                palm oil industry.


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                        CHECKLIST QUESTION
                                                                                                                                   Draft   Final
 * MoV = Means of Verification, DR= Document Review,                  Ref.   MoV*                  COMMENTS
                                                                                                                                  Concl.   Concl.
                         I= Interview
B.2.6. Is the baseline scenario determination compatible                     DR     The baseline scenario is deemed               CL 4      OK
       with the available data and are all literature and                           appropriate
       sources clearly referenced?                                                  CL.4: Annex 6 is the list of reference. But
                                                                                    the reference as to which data stated in
                                                                                    the PDD refer to which of these
                                                                                    documents is not clear. Please create
                                                                                    footnote or linkage. IPCC values used
                                                                                    should be 2006 version.
B.2.7. Have the major risks to the baseline been                             DR     Major risks to the baseline have been          OK       OK
       identified?                                                                  considered and described in the PDD
B.3. Additionality Determination
             The assessment of additionality will be validated with
             focus on whether the project itself is not a likely
             baseline scenario.
B.3.1. Is the project additionality assessed according to the                DR,    Yes. The additionality tool of Attachment     CL 5      OK
       methodology?                                                                 A to Appendix B has been applied to
                                                                                    address additionality as indicated in
                                                                                    Section B.5 of the PDD. The most
                                                                                    significant barrier is investment.
                                                                                    1. Investment barrier: The PDD mention
                                                                                        existing system is already installed
                                                                                        that required no further investment
                                                                                        and financially attractive. In the
                                                                                        Financial analysis, it indicates the
                                                                                        incentive from CERs makes the
                                                                                        project activity viable.


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                        CHECKLIST QUESTION
                                                                                                                                   Draft   Final
  * MoV = Means of Verification, DR= Document Review,               Ref.   MoV*                  COMMENTS
                                                                                                                                  Concl.   Concl.
                      I= Interview
                                                                                  CL.5: Please explain on why the CERs
                                                                                  sales are still required since the project is
                                                                                  financially viable. Please provide an IRR
                                                                                  calculation for further review.
B.3.2. Are all assumptions stated in a transparent and                     DR,    Yes, all assumptions stated              are     OK       OK
       conservative manner?                                                       transparent and conservative
B.3.3. Is sufficient evidence provided to support the                      DR,    CL.6: Please provide explanation and            CL 6      OK
       relevance of the arguments made?                                     I     evidence for:                                   CL 7      OK
                                                                                  • Bioreactor breakdown costs
                                                                                  • Gas engine, flare and associated
                                                                                      costs
                                                                                  • Operational Maintenance costs
                                                                                  CL.7: Refer excel spreadsheet, please
                                                                                  explain following:
                                                                                  1. Kindly provide what is the NPV 5%
                                                                                      discount rate?
                                                                                  2. Mill data is incomplete
                                                                                  3. Why was baseline referred to
                                                                                      AM0022?
                                                                                  4. Current exchange rate between Euro
                                                                                      and       Malaysia      ringgit    is
                                                                                      Euro1:RM5.05?        Please     make
                                                                                      correction
B.3.4. If the starting date of the project activity is before the          DR,    At the time of validation, the project has      CAR 3     OK
       date of validation, has sufficient evidence been

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                        CHECKLIST QUESTION
                                                                                                                              Draft   Final
  * MoV = Means of Verification, DR= Document Review,              Ref.   MoV*                 COMMENTS
                                                                                                                             Concl.   Concl.
                         I= Interview
      provided that the incentive from the CDM was                         I     not started.
      seriously considered in the decision to proceed with                       CAR 3: The project starting date stated
      the project activity?                                                      in PDD is 01 December 2007. Kindly
                                                                                 make amendments to project starting
                                                                                 date and crediting period of C.1.1 and
                                                                                 C.2.2.1 of PDD.
                                                                                 Please provide a time chart for the
                                                                                 project activity.
B.4. Calculation of GHG Emission Reductions –
     Project emissions
             It is assessed whether the project emissions are
             stated according to the methodology and whether the
             argumentation for the choice of default factors and
             values – where applicable – is justified.
B.4.1. Are the calculations documented according to the                   DR,    Yes. The project emissions calculations      OK       OK
       approved methodology and in a complete and                                have been provided in a transparent
       transparent manner?                                                       manner.
B.4.2. Have conservative assumptions been used when                       DR,    CL.8: Refer pages 21, 22 and 23 of          CL 8      OK
       calculating the project emissions?                                        PDD, kindly provide evidence to support
                                                                                 the data stated.
                                                                                 • Volume of biogas required by dual
                                                                                     fuel generator
                                                                                 • Volume of diesel required by dual fuel
                                                                                     generator
                                                                                 • Net calorific value of diesel reference


CDM Validation Report, No. 9105043598
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                        CHECKLIST QUESTION
                                                                                                                              Draft   Final
  * MoV = Means of Verification, DR= Document Review,              Ref.   MoV*                 COMMENTS
                                                                                                                             Concl.   Concl.
                      I= Interview
                                                                                 • Final sludge will be sun dried and
                                                                                   disposed
                                                                                 • Dissolved   methane    in    treated
                                                                                   wastewater
B.4.3. Are uncertainties in the project emission estimates                DR     Yes. All uncertainties are addressed         OK       OK
       properly addressed?
B.5. Calculation of GHG Emission Reductions –
     Baseline emissions
             It is assessed whether the baseline emissions are
             stated according to the methodology and whether the
             argumentation for the choice of default factors and
             values – where applicable – is justified.
B.5.1. Are the calculations documented according to the                   DR,    Yes. The calculations provided are           OK       OK
       approved methodology and in a complete and                                complete and in accordance with the
       transparent manner?                                                       approved methodology
B.5.2. Have conservative assumptions been used when                       DR,    CL.9: Please provide evidence for the       CL 9      OK
       calculating the baseline emissions?                                       applied assumptions for calculating the
                                                                                 baseline emissions.
                                                                                 1. Efficiency of the biodigestor
                                                                                 2. Please provide a copy of the annual
                                                                                    throughput amount of the Fresh Fruit
                                                                                    Bunch (FFB) processed by the mill.
                                                                                    At the time of validation, the mill is
                                                                                    operating above the approved MPOB
                                                                                    capacity of 360,000 tons per annum.


CDM Validation Report, No. 9105043598
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                        CHECKLIST QUESTION
                                                                                                                            Draft   Final
  * MoV = Means of Verification, DR= Document Review,              Ref.   MoV*                COMMENTS
                                                                                                                           Concl.   Concl.
                      I= Interview
                                                                                 3. Amount of raw POME generated for
                                                                                    each ton of FFB.
                                                                                 4. Raw POME concentration (COD)
                                                                                    from the mill.
                                                                                 5. POME COD value after biodigestor.
B.5.3. Are uncertainties in the baseline emission estimates               DR,    Yes. Baseline emission estimates           OK       OK
       properly addressed?                                                       uncertainties have been addressed
                                                                                 appropriately.
B.6. Calculation of GHG Emission Reductions –
     Leakage
             It is assessed whether leakage emissions are stated
             according to the methodology and whether the
             argumentation for the choice of default factors and
             values – where applicable – is justified.
B.6.1. Are the leakage calculations documented according                  DR     No leakage effects need to be accounted    OK       OK
       to the approved methodology and in a complete and                         as no equipment being transferred from
       transparent manner?                                                       another activity.
B.6.2. Have conservative assumptions been used when                       DR     No leakage effects need to be accounted    OK       OK
       calculating the leakage emissions?                                        as no equipment being transferred from
                                                                                 another activity.
6.3. Are uncertainties in the leakage emission estimates                  DR     No leakage effects need to be accounted    OK       OK
       properly addressed?                                                       as no equipment being transferred from
                                                                                 another activity.
B.7. Emission Reductions
         The emission reductions shall be real,


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                                                              18
                        CHECKLIST QUESTION
                                                                                                                               Draft   Final
 * MoV = Means of Verification, DR= Document Review,              Ref.   MoV*                  COMMENTS
                                                                                                                              Concl.   Concl.
                          I= Interview
           measurable and give long-term benefits related
           to the mitigation of climate change.
B.7.1. Are the emission reductions real, measurable and                  DR,    Yes. The project will result in less GHG       OK       OK
       give long-term benefits related to the mitigation of               I     emissions than the baseline scenario.
       climate change.                                                          The estimated emission reduction for the
                                                                                10 years crediting period is 339,550t CO2
                                                                                that are real, measurable and give long-
                                                                                term benefits related to the mitigation of
                                                                                climate change.
    B.8. Monitoring Methodology
             It is assessed whether the project applies an
             appropriate baseline methodology.
B.8.1. Is the monitoring plan documented according to the                DR,    Yes, the project activity applies the         CAR 4     OK
       approved methodology and in a complete and                         I     approved monitoring methodology in a
       transparent manner?                                                      complete and transparent manner.
                                                                                CAR 4. Table B.7.1 – Data and
                                                                                parameter monitored that state value of
                                                                                data applied for the purposed of
                                                                                calculating expected emission reductions
                                                                                in section B.5 is incorrect for
                                                                                data/parameter (5), (6), (7), (8), (9)
                                                                                and(10) need to be amended to the
                                                                                correct section
B.8.2. Will all monitored data required for verification and             DR,    Yes. The monitoring data will be kept for      OK       OK
       issuance be kept for two years after the end of the                I     two (2) years after expiry of the crediting
       crediting period or the last issuance of CERs, for                       period.


CDM Validation Report, No. 9105043598
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                        CHECKLIST QUESTION
                                                                                                                                    Draft   Final
  * MoV = Means of Verification, DR= Document Review,                 Ref.   MoV*                  COMMENTS
                                                                                                                                   Concl.   Concl.
                          I= Interview
       this project activity, whichever occurs later?
    B.9. Monitoring of Project Emissions
             It is established whether the monitoring plan provides
             for reliable and complete project emission data over
             time.
B.9.1. Does the monitoring plan provide for the collection                   DR,    Yes, the data collection system for             OK       OK
       and archiving of all relevant data necessary for                       I     monitoring data those are required for
       estimation or measuring the greenhouse gas                                   baseline      and     project      emissions
       emissions within the project boundary during the                             determination reflect good monitoring
       crediting period?                                                            practise will be kept for at least 2 years
B.9.2 Are the choices of project GHG indicators                              DR,    Yes, data needed to calculate project           OK       OK
       reasonable and conservative?                                           I     emissions will be directly monitored at
                                                                                    regular intervals.
B.9.3. Is the measurement method clearly stated for each                     DR,    Yes. Measurement equipment will be              OK       OK
       GHG value to be monitored and deemed                                   I     installed to monitor these indicators.
       appropriate?
B.9.4. Is the measurement equipment described and                            DR,    Yes. The measurement equipment are              OK       OK
       deemed appropriate?                                                    I     identified and described.
B.9.5. Is the measurement accuracy addressed and                             DR,    Yes. The PDD describes measurement             CL 10     OK
       deemed appropriate? Are procedures in place on                         I     procedures in table form.
       how to deal with erroneous measurements?                                     CL.10: At the time of validation
                                                                                    procedures are not available to validation
                                                                                    team. Please clarify such procedures will
                                                                                    be established and implemented.
B.9.6. Is the measurement interval identified and deemed                     DR,    The     measurements       frequency      is    OK       OK


CDM Validation Report, No. 9105043598
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                                                                20
                        CHECKLIST QUESTION
                                                                                                                                 Draft   Final
 * MoV = Means of Verification, DR= Document Review,                  Ref.   MoV*                 COMMENTS
                                                                                                                                Concl.   Concl.
                          I= Interview
       appropriate?                                                           I     determined in the tables in Section B.7.1
B.9.7. Is the registration, monitoring, measurement and                      DR,    Yes. Annex 4 of PDD describes rough on      CL 10     OK
       reporting procedure defined?                                           I     operational and responsibilities for
                                                                                    monitoring and quality assurance of
                                                                                    emission reductions.
                                                                                    Refer to CL 10 above
B.9.8. Are procedures identified for maintenance of                          DR,    Yes, Calibration intervals will be          CL 10     OK
       monitoring equipment and installations? Are the                        I     observed     according     to    industry
       calibration intervals being observed?                                        standards.
                                                                                    Refer to CL 10 above
B.9.9. Are procedures identified for day-to-day records                      DR,    Yes, The PDD provides information           CL 10     OK
       handling (including what records to keep, storage                      I     identifying day-to-day records handling
       area of records and how to process performance                               including what records to keep storage of
       documentation)                                                               records and how to process information
                                                                                    documentation.
                                                                                    Refer to CL 10 above
    B.10. Monitoring of Baseline Emissions
             It is established whether the monitoring plan provides
             for reliable and complete baseline emission data
             over time.
B.10.1. Does the monitoring plan provide for the collection                  DR,    The monitored data and parameter of          OK       OK
        and archiving of all relevant data necessary for                      I     B.7.1 Annex 4 consider objectives,
        determining baseline emissions during the                                   organisation, equipment, data collection
        crediting period?                                                           and data management to determine
                                                                                    baseline emissions during the crediting


CDM Validation Report, No. 9105043598
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                                                                21
                        CHECKLIST QUESTION
                                                                                                                            Draft   Final
  * MoV = Means of Verification, DR= Document Review,           Ref.   MoV*                 COMMENTS
                                                                                                                           Concl.   Concl.
                      I= Interview
                                                                              period.
B.10.2. Are the choices of baseline GHG indicators                     DR,    Yes, the choices of baseline indicators       OK       OK
        reasonable and conservative?                                          are in accordance to AMS-III.H. and are
                                                                              reasonable.
B.10.3. Is the measurement method clearly stated for each              DR,    Yes, the choices of baseline indicators       OK       OK
         baseline indicator to be monitored and also                          are in accordance to AMS-III.H. and are
         deemed appropriate?                                                  reasonable.
B.10.4. Is the measurement equipment described and                     DR,    Yes. Measurement method for each              OK       OK
         deemed appropriate?                                                  baseline indicator are monitored and
                                                                              deemed appropriate as described in the
                                                                              PDD.
B.10.5. Is the measurement accuracy addressed and                      DR,    Yes. The PDD describes measurement           CL 10     OK
         deemed appropriate? Are procedures in place on                       procedures in table form.
         how to deal with erroneous measurements?                             Refer to CL 10 above
B.10.6. Is the measurement interval for baseline data                  DR,    The    measurements        frequency    is    OK       OK
         identified and deemed appropriate?                                   determined in the tables in Section B.7.1
B.10.7. Is the registration, monitoring, measurement and               DR,    Refer to CL.10 above                         CL 10     OK
         reporting procedure defined?
B.10.8. Are procedures identified for maintenance of                   DR,    Refer to CL.10 above                         CL 10     OK
        monitoring equipment and installations? Are the
        calibration intervals being observed?
B.10.9. Are procedures identified for day-to-day records               DR,    Refer to CL.10 above                         CL 10     OK
        handling (including what records to keep, storage
        area of records and how to process performance


CDM Validation Report, No. 9105043598
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                                                           22
                        CHECKLIST QUESTION
                                                                                                                             Draft   Final
  * MoV = Means of Verification, DR= Document Review,                Ref.   MoV*                 COMMENTS
                                                                                                                            Concl.   Concl.
                       I= Interview
         documentation)
    B.11. Monitoring of Leakage
             It is assessed whether the monitoring plan provides
             for reliable and complete leakage data over time.
B.11.1. Does the monitoring plan provide for the collection                 DR     There is no leakage effects need to be    OK       OK
         and archiving of all relevant data necessary for                          accounted in this project.
         determining leakage?
B.11.2. Are the choices of project leakage indicators                       DR     Refer to B.11.1 above                     OK       OK
         reasonable and conservative?
B.11.3. Is the measurement method clearly stated for each                   DR     Refer to B.11.1 above                     OK       OK
         leakage value to be monitored and deemed
         appropriate?
   B.12. Monitoring of Sustainable Development
      Indicators/ Environmental Impacts
             It is assessed whether choices of indicators are
             reasonable and complete to monitor sustainable
             performance over time.
B.12.1. Is the monitoring of sustainable development                        DR     Monitoring    of   data   concerning      OK       OK
         indicators/ environmental impacts warranted by                            environmental, social and economic
         legislation in the host country?                                          impacts is not requested by the host
                                                                                   country.
B.12.2. Does the monitoring plan provide for the collection                 DR     Not applicable. See above.                OK       OK
        and archiving of relevant data concerning
        environmental, social and economic impacts?
B.12.3. Are the sustainable development indicators in line                  DR     Not applicable. See above.                OK       OK
        with stated national priorities in the Host Country?


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                23
                        CHECKLIST QUESTION
                                                                                                                                Draft   Final
  * MoV = Means of Verification, DR= Document Review,                 Ref.   MoV*                 COMMENTS
                                                                                                                               Concl.   Concl.
                      I= Interview
    B.13. Project Management Planning
             It is checked that project implementation is properly
             prepared for and that critical arrangements are
             addressed.
B.13.1. Is the authority and responsibility of overall project               DR,    The PDD describe on the overall project    CL 11     OK
         management clearly described?                                        I     management and appointed of key
                                                                                    personnel to manage and operate the
                                                                                    project.
                                                                                    CL.11: Kindly provide an organisation
                                                                                    chart indicating the reporting structure
                                                                                    and overall project management.
B.13.2. Are procedures identified for training of monitoring                 DR,    CL.12: Although Annex 4 describes          CL 12     OK
        personnel?                                                            I     training will be provided to operational
                                                                                    staff. The procedures for training and
                                                                                    monitoring of personnel have not been
                                                                                    made available during validation. Please
                                                                                    provide information that such procedures
                                                                                    will be established and implemented and
                                                                                    submit to validation team for review.
B.13.3. Are procedures identified for emergency                              DR,    No such emergencies were identified in     CL 13     OK
        preparedness for cases where emergencies can                          I     the monitoring plan
        cause unintended emissions?                                                 Currently no procedures for emergency
                                                                                    cases where they can cause unintended
                                                                                    emissions are foreseen in the PDD.
                                                                                    CL.13: Please clarify if such procedures
                                                                                    will be established and implemented.

CDM Validation Report, No. 9105043598
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                                                                 24
                        CHECKLIST QUESTION
                                                                                                                               Draft   Final
 * MoV = Means of Verification, DR= Document Review,               Ref.   MoV*                 COMMENTS
                                                                                                                              Concl.   Concl.
                       I= Interview
B.13.4. Are procedures identified for review of reported                  DR     Annex 4 of PDD describe on the report of     CL 13     OK
        results/data?                                                            results and data. No procedures are
                                                                                 made available for review during
                                                                                 validation
                                                                                 Refer to CL 13 above
B.13.5. Are procedures identified for corrective actions in               DR     No procedures have been established for      CL 13     OK
        order to provide for more accurate future                                corrective actions.
        monitoring and reporting?                                                Refer to CL 13 above
    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 project’s starting date and operational                     DR,    Yes. The PDD states the starting date        CL 14     OK
      lifetime clearly defined and evidenced?                              I     and operational lifetime.
                                                                                 CL.14: At the time of on site validation,
                                                                                 the project activity has not started
                                                                                 construction and the starting date needs
                                                                                 to be reconfirmed
C.1.2. Is the start of the crediting period clearly defined               DR,    The crediting period is 10 years.            CL 15     OK
       and reasonable?                                                     I     CL.15: At the time of validation, the
                                                                                 project    activity   has    not   started
                                                                                 construction. The starting date of the
                                                                                 crediting period needs to be reconfirmed.
    D. Environmental Impacts
     Documentation on the analysis of the environmental
     impacts will be assessed, and if deemed significant, an EIA


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                              25
                        CHECKLIST QUESTION
                                                                                                                             Draft   Final
  * MoV = Means of Verification, DR= Document Review,           Ref.   MoV*                  COMMENTS
                                                                                                                            Concl.   Concl.
                      I= Interview
     should be provided to the validator.
D.1.1. Has an analysis of the environmental impacts of the             DR,    The environmental impacts have been            OK       OK
       project activity been sufficiently described?                    I     sufficiently assessed in the PDD, Section
                                                                              D.
D.1.2. Are there any Host Party requirements for an                    DR,    This project does require an EIA and           OK       OK
       Environmental Impact Assessment (EIA), and if yes,               I     obtained exemption from the host
       is an EIA approved?                                                    country Department of Environment
D.1.3. Will the project create any adverse environmental               DR,    No significant negative impacts are            OK       OK
       effects?                                                         I     anticipated from the project.
                                                                              The project activity will provide benefits
                                                                              to the environment such reduction of
                                                                              methane emissions and odour
D.1.4. Are transboundary environmental impacts                         DR     No transboundary environmental impacts         OK       OK
       considered in the analysis?                                            to other regions or countries have been
                                                                              identified.
D.1.5. Have identified environmental impacts been                      DR     No negative environmental impacts have         OK       OK
       addressed in the project design?                                       been identified in the project. The project
                                                                              will reduce methane emissions from
                                                                              treatment of POME in anaerobic lagoon
D.1.6. Does the project comply with environmental                      DR     Yes. The project complies with host            OK       OK
       legislation in the host country?                                       country environmental legislation in
                                                                              relation to establishment and operations
                                                                              of the project activity.
    D.2. For Small-scale projects


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                           26
                        CHECKLIST QUESTION
                                                                                                                                 Draft   Final
 * MoV = Means of Verification, DR= Document Review,              Ref.   MoV*                  COMMENTS
                                                                                                                                Concl.   Concl.
                       I= Interview
D.2.1. Does host country legislation require an analysis of              DR     There are no requirements by the host            OK       OK
       the environmental impacts of the project activity?                       country for an EIA for this project activity.
                                                                                However,     the    DNA       requires     a
                                                                                confirmation from the Department of
                                                                                Environment that an EIA is not required.
                                                                                A letter has been issued by Department
                                                                                of Environment that no EIA is required.
D.2.2. Does the project comply with environmental                        DR     Refer to above                                   OK       OK
       legislation in the host country?
D.2.3. Will the project create any adverse environmental                 DR     The project activity will not create any         OK       OK
       effects?                                                                 adverse environmental effects
D.2.4. Have environmental impacts been identified and                    DR     No environmental impacts are identified          OK       OK
       addressed in the PDD?                                                    since the project activity will not create
                                                                                any adverse effects.
    E.1. Stakeholder Comments
     The validator should ensure that stakeholder comments
     have been invited with appropriate media and that due
     account has been taken of any comments received.
E.1.1. Have relevant stakeholders been consulted?                        DR,    Yes. The public stakeholder consultation         OK       OK
                                                                          I     forum was conducted on 06 September
                                                                                2007 at the premise of Kilang Kelapa
                                                                                Sawit Lekir Sdn. Bhd.,
E.1.2. Have appropriate media been used to invite                        DR,    The local stakeholder consultation was           OK       OK
       comments by local stakeholders?                                    I     advertised in the New Straits Times and
                                                                                Berita Harian on 27 August 2007



CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                             27
                        CHECKLIST QUESTION
                                                                                                                       Draft   Final
 * MoV = Means of Verification, DR= Document Review,          Ref.   MoV*                COMMENTS
                                                                                                                      Concl.   Concl.
                         I= Interview
E.1.3. If a stakeholder consultation process is required by          DR     Stakeholder consultation process is not    OK       OK
       regulations/laws in the host country, has the                        required by law of the host country.
       stakeholder consultation process been carried out
       in accordance with such regulations/laws?
E.1.4. Is a summary of the stakeholder comments received             DR,    Yes. A detailed summary of comments        OK       OK
       provided?                                                      I     received is provided in the PDD Section
                                                                            E.
E.1.5. Has due account been taken of any stakeholder                 DR,    Yes. There was a question and answer       OK       OK
       comments received?                                             I     session during the consultation with
                                                                            questions about the project and were
                                                                            dealt with during the meeting.




CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                        28
Table 2          Resolution of Corrective Action and Clarification Requests
Draft report clarifications and corrective        Ref. to checklist     Summary of project owner           Validation team conclusion
action requests by validation team                question in table 2   response
CAR 1: The confirmation of the host                     A.2.2           Malaysia host country approval LoAs from host country and Annex
country and the Annex 1 country has                                     was obtained on 14 March 08 1 country have been received.
not been received yet. The Malaysian                                    issued by DNA. Reference is
Designated National Authority as well                                   made to      Attachment 1A -
as the responsible authority of the                                     Malaysia LoA
Netherlands require a draft validation
report and protocol to issue the Letter                                 Obtained Annex 1 (Netherland)
of Approval                                                             host country approval on 12
                                                                        February 2008. Reference is
                                                                        made to attachment 1B –
                                                                        Netherland LoA
CAR 2: The letter of approval from host                 A.4.1           Malaysia host country approval The LoA from host country states
country which confirms the project’s                                    was obtained on 14 March 08 the project will assist in achieving
assistance in achieving sustainable                                     issued    by    DNA.      Refer sustainable development.
development has not been received.                                      Attachment 1A - Malaysia LoA

                                                                        Obtained Annex 1 (Netherland)
                                                                        host country approval on 12
                                                                        February 2008. Reference is
                                                                        made to attachment 1B –
                                                                        Netherland LoA
CAR 3: The project starting date stated                 B.3.4           Amended accordingly     with   a Amendments have been made in
in PDD is 01 December 2007. Kindly                                      Projected Timeline.              revised PDD version 3.5.
make amendments to project starting
date and crediting period of C.1.1 and                                  Reference is made to the Project


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                 29
Draft report clarifications and corrective             Ref. to checklist     Summary of project owner     Validation team conclusion
action requests by validation team                     question in table 2   response
C.2.2.1 of PDD.                                                              Timeline (Attachment 2)
Please provide a time chart for the
project activity.
CAR 4. Table B.7.1 – Data and                                B.8.1           Amended. Reference is made to Amendments have been made in
parameter monitored that state value of                                      the PDD version 3.5, section revised PDD version 3.5
data applied for the purposed of                                             B.7.1.
calculating      expected       emission
reductions in section B.5 is incorrect for
data/parameter (5), (6), (7), (8), (9),
(10), (11) and (12) need to be amended
to the correct section
CL.1 Kindly advice the correct                               A.1.1           Amended. Reference is made to Amendments have been made in
coordinates for the location of the                                          the PDD version 3.5, section revised PDD version 3.5
project activity location.                                                   A.4.1.4

                                                                             4.1505o N, 100.7823º E
CL.2: Kindly indicate in the PDD                   a         A.1.2           Amended, Reference is made to Amendments have been made in
diagram of the baseline boundary                  in                         the PDD version 3.5, section B.3. revised PDD version 3.5
addition to project activity boundary             of
Figure B.1 and schematic diagram                  of
the project activity of Figure A.3
CL.3: At the time of validation, there                       A.3.3           This has been described in the Amendments have been made in
are no documented procedures made                                            monitoring    protocol.    See revised PDD version 3.5
available to the validation team for the                                     Attachment 3 for the Monitoring
monitoring activities as describe in                                         Protocol.
Annex 4 for training and maintenance


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                      30
Draft report clarifications and corrective        Ref. to checklist     Summary of project owner             Validation team conclusion
action requests by validation team                question in table 2   response
needs.
CL.4: Annex 6 is the list of reference.                 B.2.6           Amended. Reference is made to Amendments have been made in
But the reference as to which data                                      the PDD version 3.5, Annex 6. All revised PDD version 3.5
stated in the PDD refer to which of                                     default values applied are based
these documents is not clear. Please                                    on IPCC 2006.
create footnote or linkage. IPCC values
used should be 2006 version.
CL.5: Please explain on why the CERs                    B.3.1           The statement in PDD is meant        Amendments have been made in
sales are still required since the project                              for the existing open lagoons        revised PDD version 3.5 for this
is financially viable. Please provide an                                anaerobic system.                    statement.
IRR calculation.                                                        This   statement      has     been   The revised PDD describes the
                                                                        rephrased for clarification and an   justification on why CERs is
                                                                        IRR calculation has been added       required to support the project as
                                                                        in the PDD version 3.5, section      there is no other income source to
                                                                        B.5.                                 operate the project.
CL.6: Please provide explanation and                    B.3.3           CL.6.                         Cost breakdown analysis for
evidence for:                                                           The cost break down has been engine and system has been
   • Bioreactor breakdown costs                                         added as attachment 4 – “Cost received.
   • Gas engine, flare and associated                                   Breakdown for the proposed
       costs                                                            project” to this response.
   • Operational Maintenance costs
CL.7: Refer excel spreadsheet, please                                   CL.7.
explain following:                                                      1. The NPV is not used 1. Financial calculation has been
1. Kindly provide what is the NPV 5%                                       anymore in the financial         changed to IRR method.
    discount rate?                                                         calculation.     The      IRR 2. Mill data have been updated in
                                                                           calculation is used instead.     financial spreadsheet.
2. Mill data is incomplete


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                 31
Draft report clarifications and corrective        Ref. to checklist     Summary of project owner             Validation team conclusion
action requests by validation team                question in table 2   response
3. Why was baseline referred to                                         2. Updated,      refer   to  the 3. Amendment has been made in
   AM0022?                                                                 financial spreadsheet.           financial spreadsheet.
4. Current exchange rate between                                        3. Typing error. It should be 4. The currency indicator in
   Euro and Malaysia ringgit is                                            AMS.III.H. Refer to the          financial    spreadsheet has
   Eur1:RM5.05?    Please   make                                           financial spreadsheet.           been amended to EURO
   correction.                                                          4. Amended using EURO, refer        currency.
                                                                           to the financial spreadsheet.
CL.8: Refer pages 21, 22 and 23 of                      B.4.2           a. Reference is made to              a. Dual fuel generator specification
PDD, kindly provide evidence to                                            attachment 5 - Dual Fuel             has been received that indicate
support the data stated.                                                   specification                        the respective volume of fuel
a. Volume of biogas required by dual                                    b. Reference is made to                 used.
     fuel generator                                                        attachment 5 - Dual Fuel          b. As per above stated in the
b. Volume of diesel required by dual                                       specification                        specification sheet provided.
     fuel generator                                                     c. IPCC 2006 default value (43       c. Amendment has been made in
c. Net calorific value of diesel                                           TJ/kg) or 43.33 MJ/liter             accordance with IPCC values.
     reference                                                          d. Sludge from desludging will       d. Revised PDD version 3.5 shows
d. Final sludge will be sun dried and                                      be sun dried and disposed in         that this data will be monitored.
     disposed                                                              the estate as soil application.   e. Updated in revised PDD version
e. Dissolved methane in treated                                            Will be monitored according          3.5
     wastewater                                                            the procedure mentioned in
                                                                           section B7.1 of the PDD,
                                                                           version 3.5.
                                                                        e. AMS IIIH version 6 default
                                                                           value




CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                 32
Draft report clarifications and corrective        Ref. to checklist     Summary of project owner           Validation team conclusion
action requests by validation team                question in table 2   response
CL.9: The applied assumptions for                       B.5.2           1. Amended.        Using   78%     1. Pilot project document has been
calculating the baseline emissions,                                        efficiency        as      the      received for the efficiency of
please justified on the following:                                         conservative figure (Refer         biodigestor.
1. Efficiency of the biodigestor                                           attachment 6a, 6b & 6c -
                                                                           Pilot       project    COD
2. Please provide a copy of the annual
                                                                           measurement).
    throughput amount of the Fresh                                                                         2. Mill processed FFB throughput
    Fruit Bunch (FFB) processed by the                                  2. Using conservative figure of
                                                                           500,000t/yr based on the last      for the past 5 years had been
    mill. At the time of validation, the                                                                      submitted showing the average
    mill is operating above the                                            3 year mill processed
                                                                           tonnage of FFB. Kindly refer       processed     throughput    is
    approved MPOB capacity of                                                                                 500,000t/year. The mill has
    360,000 tons per annum.                                                Attachment 7 (Contracted
                                                                           FFB year 2007) for ton of          applied for an increase in
3. Amount of raw POME generated for                                                                           throughput      capacity    to
                                                                           FFB bought from oil palm
    each ton of FFB.                                                                                          500,000t.year
                                                                           estates in year 2007.
4. Raw POME concentration (COD)                                         3. An         average        0.6
    from the mill.                                                                                         3. Data had been amended in
                                                                           m3POME/tFFB published by
                                                                                                              revised PDD version 3.5 and
                                                                           MPOB
                                                                                                              financial spreadsheet.
                                                                        4. Raw COD concentration           4. Laboratory tests results have
                                                                           from     the     mill, Refer       been received.
                                                                           Attachment 8a & 8b – Lab
                                                                           results
CL.10: At the time of validation                        B.9.5           Reference is made to Attachment The Monitoring Protocol has been
procedures are not available to                                         3 -Monitoring Protocol.         received    that   include    the
validation team. Please clarify such                                                                    necessary.
procedures will be established and
implemented.
Refer to CL 10 Above                                    B.9.7           Reference is made to Attachment The Monitoring Protocol has been

CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                 33
Draft report clarifications and corrective        Ref. to checklist     Summary of project owner          Validation team conclusion
action requests by validation team                question in table 2   response
                                                                        3 -Monitoring Protocol.           received    that    include   the
                                                                                                          necessary.
Refer to CL 10 Above                                    B.9.8           Reference is made to Attachment   The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.           received    that    include   the
                                                                                                          necessary.
Refer to CL 10 Above                                    B.9.9           Reference is made to Attachment   The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.           received    that    include   the
                                                                                                          necessary.
Refer to CL 10 Above                                    B.10.5          Reference is made to Attachment   The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.           received    that    include   the
                                                                                                          necessary.
Refer to CL 10 Above                                    B.10.7          Reference is made to Attachment   The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.           received    that    include   the
                                                                                                          necessary.
Refer to CL 10 Above                                    B.10.8          Reference is made to Attachment   The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.           received    that    include   the
                                                                                                          necessary.
Refer to CL 10 Above                                    B.10.9          Reference is made to Attachment   The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.           received    that    include   the
                                                                                                          necessary.
CL.11: Kindly provide an organisation                   B.13.1          Reference is made to Attachment   Organisation chart has been
chart indicating the reporting structure                                9 – Organization Chart            received indicating the reporting
and overall project management.                                                                           and management structure
CL.12: Although Annex 4 describes                       B.13.2          Reference is made to Attachment Monitoring Protocol has been
training will be provided to operational                                3 -Monitoring Protocol.         received indicating training and
staff. The procedures for training and                                                                  monitoring of personnel.
monitoring of personnel have not been


CDM Validation Report, No. 9105043598
KKSL Lekir Biogas Project, Project BCM07_SLK_14
                                                                 34
Draft report clarifications and corrective        Ref. to checklist     Summary of project owner        Validation team conclusion
action requests by validation team                question in table 2   response
made available during validation.
Please provide information that such
procedures will be established and
implemented and submit to validation
team for review.
CL.13:   Please   clarify  if such                      B.13.3          Reference is made to Attachment The Monitoring Protocol has been
procedures will be established and                                      3 -Monitoring Protocol.         received    that   include    the
implemented.                                                                                            necessary.
Refer to CL 13 above                                    B.13.4          Reference is made to Attachment The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.         received    that   include    the
                                                                                                        necessary.
Refer to CL 13 above                                    B.13.5          Reference is made to Attachment The Monitoring Protocol has been
                                                                        3 -Monitoring Protocol.         received    that   include    the
                                                                                                        necessary.
CL.14: At the time of on site validation,               C.1.1           This has been amended in Amendments has been made in
the project activity has not started                                    section C.1.1. of the PDD version revised PDD version 3.5 Section
construction and the starting date                                      3.5.                              C.1.1
needs to be reconfirmed.
CL.15: At the time of validation, the                   C.1.2           This has been amended in Amendments has been made in
project activity has not started                                        section C.2.2.1 of the PDD revised PDD version 3.5 Section
construction. The starting date of the                                  version 3.5.               C.2.2.1
crediting   period   needs     to   be
reconfirmed.




CDM Validation Report, No. 9105043598
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                                                                 35

								
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