Yalnızardıç Dam and Berat HEPP - VCS Project Database

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Yalnızardıç Dam and Berat HEPP - VCS Project Database
PROJECT DESCRIPTION: VCS Version 3

                Yalnızardıç Dam and Berat HEPP
                                      Document prepared by:
        Armada Eğitim ve Belgelendirme Danışmanlık Müh. Enerji Denizcilik San. ve Tic. Ltd. Şti.
                                         by Muge Karaca

        Project Title   Yalnızardıç Dam and Berat HEPP

            Version     01

       Date of Issue    04-02-2015

       Prepared By      Armada Eğitim ve Belgelendirme Danışmanlık Müh. Enerji Denizcilik San. ve Tic. Ltd. Şti

            Contact     Physical Address: Mustafa Kemal Mah. Barış Sit. 2139. Sok. No:2/16 Çankaya – ANKARA -
                        TURKEY,
                        Telephone: +90 312 284 03 58
                        Email: mugekaraca@armadadanismanlik.com
                        Website: www.armadadanismanlik.com

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Table of Contents

1      Project Details ...................................................................................................................................... 3
    1.1     Summary Description of the Project ............................................................................................. 3
    1.2     Sectoral Scope and Project Type.................................................................................................. 3
    1.3     Project Proponent ......................................................................................................................... 3
    1.4     Other Entities Involved in the Project ............................................................................................ 3
    1.5     Project Start Date .......................................................................................................................... 4
    1.6     Project Crediting Period ................................................................................................................ 4
    1.7     Project Scale and Estimated GHG Emission Reductions or Removals ....................................... 4
    1.8     Description of the Project Activity.................................................................................................. 4
       1.8.1      Technology to be employed by the project activity ............................................................... 6
       1.8.2      Civil Construction Details ...................................................................................................... 7
    1.9     Project Location .......................................................................................................................... 10
    1.10 Conditions Prior to Project Initiation ............................................................................................ 11
    1.11 Compliance with Laws, Statutes and Other Regulatory Frameworks ........................................ 11
    1.12 Ownership and Other Programs ................................................................................................. 12
       1.12.1 Right of Use......................................................................................................................... 12
       1.12.2 Emissions Trading Programs and Other Binding Limits ..................................................... 12
       1.12.3 Participation under Other GHG Programs .......................................................................... 12
       1.12.4 Other Forms of Environmental Credit ................................................................................. 12
       1.12.5 Projects Rejected by Other GHG Programs ....................................................................... 12
    1.13 Additional Information Relevant to the Project ............................................................................ 12
2      Application of Methodology ................................................................................................................ 13
    2.1     Title and Reference of Methodology ........................................................................................... 13
    2.2     Applicability of Methodology ........................................................................................................ 13
    2.3     Project Boundary ......................................................................................................................... 15
    2.4     Baseline Scenario ....................................................................................................................... 17
    2.5     Additionality ................................................................................................................................. 18
    2.6     Methodology Deviations .............................................................................................................. 25
3      Quantification of GHG Emission Reductions and Removals ............................................................. 25
    3.1     Baseline Emissions ..................................................................................................................... 25
    3.2     Project Emissions ........................................................................................................................ 26
    3.3     Leakage....................................................................................................................................... 26
    3.4     Net GHG Emission Reductions and Removals ........................................................................... 26
       Ex-ante calculation of emission reduction .......................................................................................... 30
       Summary of the ex-ante estimation of emission reductions: ............................................................. 36
4      Monitoring ........................................................................................................................................... 36
    4.1     Data and Parameters Available at Validation ............................................................................. 36
    4.2     Data and Parameters Monitored ................................................................................................. 40
    4.3     Description of the Monitoring Plan .............................................................................................. 42
5      Environmental Impact ......................................................................................................................... 44
6      Stakeholder Comments ...................................................................................................................... 44

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1       PROJECT DETAILS

1.1    Summary Description of the Project

        Title                    : Yalnızardıç Dam and Berat HEPP
        Document Version         : 01
        Date of Completion       : January 31h, 2015

        Yalnızardıç Dam and and Berat HEPP is a grid-connected power project in Turkey. Project activity
        is installed by Albe Enerji Elektrik Elektronik Danışmanlık Müşavirlik Petrol Madencilik Tarım
        Hayvancılık Sanayi ve Ticaret A.Ş. (Albe Enerji in short). The project uses renewable source of the
        Gevye stream of the Göksu River in Konya/Turkey. The total installed capacity of Yalnızardıç Dam
        and and Berat HEPP is 33.00 MW. There are two turbines. Two of them have 16.25 MW’s and one
        of them has 0.50 MW capacity. Yalnızardıç Dam and Berat HEPP will be connected with a
        transmission line of 22 km of 34.5 kV to the transformer station which is connected to the
        transmission grid of 154 kV. The project activity will generate 73.101 GWh per year. Based on the
        Turkey’s Combined Margin Emission Factor of 0.4175 tCO2e/MWh, the project is expected to
        produce 30,520 tonnes of CO2eq GHG reductions each year. In the absence of the project activity,
        the same amount of energy will be produced by grid-connected fossil fuel based power plants which
        are common in Turkey.

1.2    Sectoral Scope and Project Type

        Using the list of categories of project activities and of registered CDM project activities by category
        available on the UNFCCC CDM web site, Yalnızardıç Dam and Berat HEPP falls in:

        Scope number             :   1
        Sectoral scope           :   Energy industries (renewable - / non-renewable sources)

        The project is not a grouped project.

1.3    Project Proponent

        Organization name      Albe Enerji Elektrik Elektronik Danışmanlık Müşavirlik Petrol Madencilik
                               Tarım Hayvancılık Sanayi ve Ticaret A.Ş.

        Contact person         Atilla Ataç

        Title                  Energy Coordinator

        Address                Horasan Sok. No:24 G.O.P. Çankaya / ANKARA

        Telephone              +90 312 447 17 00

        Email                  aatac@kolin.com.tr

1.4    Other Entities Involved in the Project

        Organization name      Armada Eğitim ve Belgelendirme Dan. Müh. Enerji Denizcilik. San. ve Tic.
                               Ltd. Şti
        Role in the project    Consultant
        Contact person         Müge Karaca

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        Title                  Project Coordinator
        Address                Mustafa Kemal Mah. Barış Sit. 2139. Sok. No:2/16 Çankaya, Ankara -
                               Turkey
        Telephone              +90 312 284 03 58
        Email                  mugekaraca@armadadanismanlik.com

1.5    Project Start Date

        March 1st, 2015 is the expected start date of the project activity which is the start date of operation,
        and is also the project’s start of GHG reduction.

1.6    Project Crediting Period

        The crediting period starts with the commissioning of the plant, exactly with the first day of
        documented electricity supply to the grid. A renewable crediting period (10 years) which can be
        renewed 3 times is chosen.

        Crediting Period Start Date         : 01.03.2015
        Crediting Period End Date           : 28.02.2025

1.7    Project Scale and Estimated GHG Emission Reductions or Removals

                                  Project Scale
                                  Project
                                  Large project                          X

                  Years                                    Estimated GHG emission
                                                           reductions or removals (tCO2e)
                  01-03-2015 till 28-02-2016                           30,520
                  01-03-2016 till 28-02-2017                           30,520
                  01-03-2017 till 28-02-2018                           30,520
                  01-03-2018 till 28-02-2019                           30,520
                  01-03-2019 till 28-02-2020                           30,520
                  01-03-2020 till 28-02-2021                           30,520
                  01-03-2021 till 28-02-2022                           30,520
                  01-03-2022 till 28-02-2023                           30,520
                  01-03-2023 till 28-02-2024                           30,520
                  01-03-2024 till 28-02-2025                           30,520
                  Total estimated ERs                                  305,200
                  Total number of crediting years                         10
                  Average annual ERs                                   30,520

1.8    Description of the Project Activity

        The grid-connected electricity generation from renewable sources project Yalnızardıç Dam and
        Berat HEPP in Turkey will be installed by Albe Enerji Elektrik Elektronik Danışmanlık Müşavirlik

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       Petrol Madencilik Tarım Hayvancılık Sanayi ve Ticaret A.Ş. (Albe Enerji in short) Yalnızardıç Dam
       and Berat HEPP involves the installation and operation of a plinth tailwater power plant and a
       downstream power plant to best suit the local conditions of the project area. Yalnızardıç Dam and
       Berat HEPP will be connected with a transmission line of 22 km of 34.5 kV to the transformer station
       which is connected to the transmission grid of 154 kV.

       Yalnızardıç Dam and Berat HEPP is located on the river Gevne which is passing through the
       Province of Konya. Project area can be located on scaled (1/1000) maps which are presented as
       supplementary documents (please see 16-Maps). According to the finding done in 09-10-2014, the
       ratio of civil construction completed is 88%. After the completion of civil construction works, the
       plant will be commissioned in March 2015. The agreement for construction works will be signed
       with a contractor company after necessary assessments for choosing the best option.

       Yalnızardıç Dam and Berat HEPP project includes the combination of two facilities (“Yalnızardıç
       Dam” and “Berat HEPP”) which are both planned and developed by the same project owner. After
       considering financial and operational implementation criteria for both facilities, the company has
       decided to implement a unified project under the name of “Yalnızardıç Dam and Berat HEPP”. The
       owner company has taken a generation license for previously planned Yalnızardıç Dam’s (obtained
       from the Energy Market Regulatory Authority, EMRA) power plant which has been issued on 04-
       08-2011 where the capacity of the facility has been mentioned as 17.52 MWm. However the
       combined project (Yalnızardıç Dam and Berat HEPP) is designed to be operational with an installed
       capacity of 33.00 MWm. License application for Yalnızardıç Dam and Berat HEPP has been
       finalized and the license has been given for the purpose of conducting productive activity for 49
       years dating from 11.03.2009.

       According to the planned generation data, an average generation of 73,101,000 kWh (73.101 GWh)
       per year is expected by the efficient utilization of the hydraulic energy, where the project activity
       will replace grid electricity, which consists of different fuel sources, mainly fossil fuels. By the end
       of 2013, about 71.0% of the electricity is generated by fossil fuel based power plants. Forecasts of
       TEIAS (National Grid Operator) show that the dependency of the Turkish electricity generation
       system on fossil fuels will continue with 74% share in total generation by 2018 (see also Table 5).
       Utilizing renewable energy, the electricity produced by project activity will, therefore, result in an
       annual emission reduction of 30,520 tonnes of CO2e, from business as usual scenario. Moreover,
       the project activity will contribute to the further dissemination of hydraulic energy and an extension
       of the national power generation. It is expected that the generation of electricity will start as of
       March 2015 and the operational life is assumed as 49 years (as “Generation Licenses in the host
       country Turkey are given for 49 years). However, it is recommended to renew the equipment in
       every 20 years.

       The project will help Turkey to stimulate and commercialise the use of grid connected renewable
       energy technologies and markets. Furthermore, the project will demonstrate the viability of grid
       connected hydropower which can support improved energy security, improved air quality,
       alternative sustainable energy futures, improved local livelihoods and sustainable renewable
       energy industry development. The specific goals of the project are to:

          reduce greenhouse gas emissions in Turkey compared to the business-as-usual scenario;
          help to stimulate the growth of the hydropower industry in Turkey;
          create local employment during the construction and the operation phase of the proposed
           facility.
          reduce other pollutants resulting from the power generation industry in Turkey, compared to a
           business-as-usual scenario;
          help to reduce Turkey’s increasing energy deficit;
          and to differentiate the electricity generation mix and to reduce import dependency.

       As the project developer, Albe Enerji believes that efficient utilization of all kinds of natural
       resources coupled with responsible environmental considerations is vital for sustainable

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       development of Turkey and the World. This has been a guiding factor for the shareholders towards
       designing and installation of a HEPP project. Other than the objective of climate change mitigation
       through significant reduction in greenhouse gas (GHG) emissions, the project has been carried out
       to provide social and economic contribution to the region in a sustainable way. The benefits that
       will be gained by the realization of the project compared to the business-as-usual scenario can be
       summarized under four main indicators:

       Environmental

       The project activities will replace the grid electricity which constitutes different fuel sources causing
       greenhouse gas emissions. By replacing the consumption of these fuels, it contributes to the
       conservation of water, soil, flora and faunas and transfers these natural resources and also the
       additional supply of these primary energy sources to the future generations. In the absence of the
       project activity, an equivalent amount of electricity would have been generated from the power
       plants connected to the grid, majority of which are based on fossil fuels. Thus, the project is
       replacing greenhouse gas emissions (CO2, CH4) and other pollutants (SO X, NOX, particulate
       matters) occurring from the extraction, processing, transportation and burning of fossil-fuels for
       power generation connected to the national grid.

       Economic

       Firstly, the project will help to accelerate the growth of the hydro power industry and stimulate the
       designation and production of renewable energy technologies in Turkey. Then, other entrepreneurs
       irrespective of sector will be encouraged to invest in hydro power generation capacity as well. It will
       also help to reduce Turkey’s increasing energy deficit and diversify the electricity generation mix
       while reducing import dependency, especially natural gas.

       Social

       Local employment will be enhanced by all project activities during construction and operation of the
       HEPP. As a result, local poverty and unemployment will be partially eliminated by increased job
       opportunities and project business activities. Construction materials for the foundations, cables and
       other auxiliary equipment will preferably be sourced locally.

       Technological

       Implementation of the proposed project will contribute to a wider deployment of the technology for
       developing HEPPs at the local and national level. It will demonstrate the viability of larger grid
       connected HEPPs which will support improved energy security, alternative sustainable energy, and
       also renewable energy industry development. This will also strengthen pillars of Turkish electricity
       supply based on ecologically sound technologies.

             1.8.1    Technology to be employed by the project activity

       The proposed project activity generates electricity from hydro power with an installed capacity of
       33.00 MWm.

       According to the feasibility study as under consideration by the State Hydraulic Works, the average
       net electricity production and delivery to the grid is expected to be 73.101 GWh per year. This
       implies an average capacity factor of 25.6%, when the installed capacity of 33.00 MWm is taken
       into account.

       Yalnızardıç Dam and Berat HEPP project entails the construction and operation of a 0.50 MWm
       MWm plinth hydroelectric power plant after the dam structure and 32.50 MWm downstream power
       plant which will regulate the water flow and work to produce electricity. The water will be transferred

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           to constructed connection tunnel, and then to penstock to reach the downstream power plant. On
           the other hand, plinth power plant will have no connection tunnel in design. The project consists of
           hydro power plant with three turbines; one of 0.50 MWm and two of 16.25 MWm capacity. The
           turbines will be first hand Francis type with vertical axis. The electromechanical contracts were
           signed on 17.05.2013. The net electricity production (delivered to the grid after losses and
           consumption in the plant) from the plant is estimated to be 73.101 GWh per annum, as specified
           on the generation license.

           The technology which is planned to be used in the plant includes first hand hydro turbines and its
           auxiliary equipment with extensive automatization. There is no new technology which is expected
           to replace the plant’s selected technology in the short run. The project does not need extensive
           initial training and maintenance efforts in order to work during the project period. Necessary
           trainings to the plant staff will be delivered by the supplier in line with the agreement between the
           project owner and the supplier. Electromechanical equipment providing companies also provide a
           guarantee and maintenance for 2 years and related trainings of the plant’s personnel will be
           delivered by these companies through related agreements.

           The economic life of an HEPP in Turkey is assumed as 49 years as specified on the generation
           license. “Generation licenses” are given by EMRA usually for this time range. However, it is
           recommended to renew the equipment every 20 years.1

                   1.8.2    Civil Construction Details

           As mentioned in above sections, proposed facility is designed to include a combination of two
           previously planned facilities which both belong to the same project owner. Owner company has
           made this decision after technical assessments which lead to a more financially attractive option.

           Final project “Yalnızardıç Dam and Berat HEPP” consists of an upstream dam (Yalnızardıç Dam),
           a plinth power plant and a downstream power plant which was previously named as Berat HEPP.
           Dam structure will be constructed on Gevne River’s 1272.25 thalweg level, 112.75 meters higher
           than the thalweg elevation. By the help of water intake structure which is planned to be constructed
           on the right beach at a level of1350.00 m, water will be transferred to pressurized connection tunnel
           and then to penstock which ends at Berat HEPP’s turbine structure. Within the power plant structure
           of Berat HEPP, there exists 2 francis turbines having an installed capacity of 32.50 MW

           On the other hand downstream tailwater at dam axis is planned to be used for electricity generation
           purposes. For that reason 0.586 m3/s flow rate of tailwater is planned to be regulated by a plinth
           power plant which will have an installed capacity of 0.50 MWm. When both electricity generation
           units of the proposed facility is considered project’s total installed capacity becomes 33.00 MWm
           which will help the facility to produce an electrical energy of 73.101 GWh annually. Other
           characteristic information related to the proposed facility is described briefly in the following table:

             Rainfall area                        254 km2
             Annual average water amount          192.07 hm3 (6.10 m3/s) (natural situation)
                                                  Berat HEPP     Tailwater HEPP            Total
             Turbined water amount                170.29 hm3     18.38 hm3                 188.67 hm3
                                                  5.40 m3/s      0.586 m3/s                5.98 m3/s
             Regulation ratio                     98%
             Downstream tailwater left            0.586 m3/s

             Yalnızardıç Dam Reservoir
             Maximum water level                                 1381.50 m

1   http://ekutup.dpt.gov.tr/enerji/oik585.pdf (page 4.26)

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       Normal water level                          1381.50 m
       Minimum water level                         1350.00 m
       Total storage volume                        129.906 hm3
       Active storage volume                       83.375 hm3
       Dead volume                                 46.531 hm3
       Sedimentation volume                        25.000 hm3

       Yalnızardıç Dam Structure
       Body type                                   Clay core rockfill
       Thalweg level                               1272.25. m
       Crest elevation                             1385.00 m
       Elevation above thalweg                     112.75 m
       Elevation above the base                    120 m
       Slope of downstream bevel                   2.0 (y) / 1.0 (D)
       Slope of upstream bevel                     2.0 (y) / 1.0 (D)
       Crest length                                475 m
       Crest width                                 10 m
       Body volume                                 4 972 123 m3

       Yalnızardıç Dam Cofferdam and Derivation Tunnel
       Type                                       Clay core rockfill
       Crest elevation                            1307.00 m / 1290.00 m
       Crest length                               155.50 m / 155.50 m
       Crest width                                4.00 m / 4.00 m
       Fill volume                                136 600 m3 / 44 080 m3
       Derivation Tunnel Type                     Modified horseshoe (ɸ = 4.50 m)
       Derivation Tunnel Lenght                   706.20 m
       Slope of Derivation Tunnel Base            0.007 m/m

       Structure of the spillway
       Type                                        Radial cap, reverse intake
       Crest level                                 1379.30 m
       Cap number                                  Radial 6 caps
       Cap dimensions                              7.5 x 2.7 m (B x H)

       Water Intake Structure
       Type                                        Reverse intake with bellmouth
       Location                                    Right beach
       Dimensions                                  6.00 x 8.00 m (BxH)
       Grate dimensions                            5.00 x 6.50 m (BXH)

       Energy Tunnel
       Type                                        Modified Horseshoe
       Location                                    Right beach
       Diameter and Height                         3.20 m / 4 850 m

       Surge Chamber
       Type                                        Vertical shaft connecte with a throttle
       Diameter and Height                         15.00 m / 56 m
       Environment Elevation                       1385.90 m
       Min. Water Level                            1335.68 m
       Max. Water Level                            1384.56 m

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       Penstock
       Berat HEPP
       Diameter                                 2.35 m
       Length                                   379.50 m (bended)
       Tailwater HEPP
       Diameter                                 0.40 m
       Length                                   280.40 m (bended)

       Hydroelectrical Power Plant
       Berat HEPP
       Berat HEPP operational level of water    1381.50 m
       Tailwater level                          1205.00 m
       Project flow rate                        22.46 m3/s
       Gross Water Drop Level                   176.50 m
       Net Design Drop Level                    167.80 m (average)
       Power plant location thalweg level       1203.70 m
       Power plant type                         Cycle plant
       Tailwater HEPP
       Operational level of water               1381.50 – 1350.00 m (average 1373.66 m)
       Tailwater level                          1273.50 m
       Project flow rate                        0.586 m3/s
       Gross Water Drop Level                   108.00 m
       Net Design Drop Level                    104.76 m (average)
       Power plant location thalweg level       1272.12 m
       Power plant type                         Plinth plant

       Berat HEPP Turbines
       Amount                                   2
       Type                                     Vertical axis Francis
       Nominal power                            16 250 kW + 16 250 kW
       Design flow rate                         11.23 m3/s + 11.23 m3/s
       Design net water drop level              167.80 m (average net drop)
       Synchroneity speed                       700 rpm
       Specific speed                           140.0 m-kW

       Berat HEPP Generators
       Amount                                   2
       Type                                     Vertical axis generator
       Working style                            Continuous
       Nominal Power                            18 500 kVA + 18 500 kVA
       Terminal voltage                         6.3 kV
       Power factor                             0.9 (back)
       Frequency                                50 Hz
       Rotation speed                           Variable
       Impulse type                             Francis type turbine coupled with axis
       Warning type                             Static warning
       Shorcut ratio                            Higher than 1
       Isolation class                          F

       Tailwater HEPP Turbines
       Amount                                   1
       Type                                     Horizontal axis Francis
       Nominal power                            540 kW

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         Design flow rate                                     0.586 m3/s
         Design net water drop level                          167.80 m (average net drop)
         Synchroneity speed                                   600 rpm
         Specific speed                                       160.0 m-kW

         Tailwater HEPP Generators
         Amount                                               1
         Type                                                 Horizontal axis generator
         Working style                                        Continuous
         Nominal Power                                        650 kVA
         Terminal voltage                                     6.3 kV
         Power factor                                         0.9 (back)
         Frequency                                            50 Hz
         Rotation speed                                       Variable
         Impulse type                                         Francis type coupled with the axis
         Warning type                                         Static warning
         Shorcut ratio                                        Higher than 1
         Isolation class                                      F
        Ref: Feasibility Study Report (See “18- FSR/” directory in supplementary documents)

1.9    Project Location

        The Yalnızardıç Dam and Berat HEPP is located in the Central Anatolian (Dam structure) and South
        Anatolian region (Berat HEPP) of Turkey. It is located on the Gevne/Göksu river. The geographical
        coordinates of Yalnızardıç Dam and Berat HEPP, and the location of the project on Turkey map
        are as follows:

        Table 1 Location of the dam and the power plant of Yalnızardıç Dam and Berat HEPP

                      Dam and Plinth HEPP                                       Berat HEPP
                     Latitude (N)    Longitude (E)                       Latitude (N)      Longitude (E)
          1          36.762544°      32.458166°               2          36.711888°        32.451826°

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          Figure 1 Project area and the power plant siting in the water catchment

1.10 Conditions Prior to Project Initiation

           There was no other hydroelectric power plant installation at the project location. The project activity
           does not generate greenhouse gas emissions, so it can be concluded that the implementation has
           been made only in order to generate GHG emissions with their subsequent reduction.

1.11 Compliance with Laws, Statutes and Other Regulatory Frameworks

          Undertaking the project activity is in compliance with the following identified applicable mandatory
          laws and regulations:

       (1) Electricity Market Law2
       (2) Law on Utilization of Renewable Energy Resources for the Purpose of Generating Electricity
           Energy3
       (3) Environment Law4
       (4) Energy Efficiency Law5
       (5) Forest Law6

2 See: http://www.epdk.gov.tr/documents/elektrik/mevzuat/kanun/Elk_Kanun_Epk_Son.doc (Enactment Date:2001)
3 See: http://www.epdk.gov.tr/documents/elektrik/mevzuat/kanun/Elk_Kanun_Yek_Kanun.doc (Enactment Date: 2005)
4 See:

http://www.mevzuat.gov.tr/Metin.Aspx?MevzuatKod=1.5.2872&MevzuatIliski=0&sourceXmlSearch=%C3%A7evre%2
0kanunu (Enactment Date: 1983)
5 See: http://www.eie.gov.tr/duyurular/EV/EV_kanunu/EnVerKanunu_Temmuz2008.pdf (Enactment Date: 2007)
6

http://www.mevzuat.gov.tr/Metin.Aspx?MevzuatKod=1.3.6831&MevzuatIliski=0&sourceXmlSearch=orman%20kanun
u

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       (6) Regulation on Environmental Impact Assessment7

          According to the rules indicated in the Electricity Market Law, permission is granted to a legal entity
          by the board of EMRA (Electricity Market Regulatory Authority) in order to enable it to engage in
          market activities.

1.12 Ownership and Other Programs

          1.12.1 Right of Use

          Necessary documents that support the proof of company title were provided to the DOE as
          separate files. The documents include “Turkish Trade Registry Gazette” where company title was
          listed accordingly and signature circulars of authorized company directors.

          1.12.2 Emissions Trading Programs and Other Binding Limits

          Host country Turkey recently ratified the Kyoto Protocol. But currently neither CDM nor JI Projects
          can be developed in Turkey. To generate ERUs within a JI Project country, that country must have
          a cap, which is not the case in Turkey. Thus generating ERUs within a JI Project is not possible for
          Turkey. Turkey is classified as Annex-I party. This is the reason why CDM is also not an option.
          Therefore the site is not subject to binding limits on greenhouse gas emissions and there is no
          regulatory greenhouse gas emission trading program in Turkey.

          1.12.3 Participation under Other GHG Programs

          The project has not registered, and is not seeking registration under any other greenhouse gas
          program.

          1.12.4 Other Forms of Environmental Credit

          The project has not registered, and is not seeking registration under any other greenhouse gas
          program.

          1.12.5 Projects Rejected by Other GHG Programs

          The project has not been rejected by any other greenhouse gas program.

1.13 Additional Information Relevant to the Project

          As an additional information related to the project activity, it must be clarified whether the project
          activity has any fossil fuel consumption onsite. The facility will use its self-produced electricity
          during the operational stage, but in emergency situations, electricity will be taken from TEIAS by
          paying its price (which will be cut from the generation income). The use of a diesel generator is the
          last resort to be used in these kind of situations and carbon emissions from the diesel generator is
          taken as 0 (zero) in the ER calculations by considering unplanned and momentary usage during
          operational stage.

7

http://www.mevzuat.gov.tr/Metin.Aspx?MevzuatKod=7.5.12256&MevzuatIliski=0&sourceXmlSearch=%C3%A7evrese
l%20etki%20de%C4%9Ferlendirmesi%20y%C3%B6netmeli

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2       APPLICATION OF METHODOLOGY

2.1    Title and Reference of Methodology

        For determination of the baseline, the approved small scale methodology; AMS-I.D., Version 17.0,
        “Grid Connected Renewable Electricity Generation”8, has been applied.
        The Approved Methodology refers to the following tools:
        “Tool to calculate the emission factor for an electricity system” (Version 4.0.0).
        “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion” (Version 02)

2.2    Applicability of Methodology

        The methodology AMS-I.D, Version 17.0, is applicable to grid-connected renewable power
        generation project activities that are:

         Reference page in       Applicability Criteria                   Justification
         AMS-I.D    Version
         17.0
         1                       Supplying electricity to a national or   Proposed project will supply
                                 a regional grid; or                      electricity to Turkey’s national
                                                                          grid operated by TEIAS.
         1                       Supplying electricity to an identified   There       is    no     contractual
                                 consumer           facility        via   arrangement between the project
                                 national/regional grid through a         owner company and an identified
                                 contractual arrangement such as          consumer facility. Yalnızardıç
                                 wheeling;                                Dam and Berat HEPP project will
                                                                          only supply electricity to the
                                                                          national grid.
         1                       Install a new power plant at a site      No power plant was operated on
                                 where there was no renewable             the proposed site of project
                                 energy power plant operating prior       activity.      Technical     project
                                 to the implementation of the project     preparation of the proposed
                                 activity (Greenfield plant)              activity and related feasibility
                                                                          studies are completed for a
                                                                          greenfield activity.
         1                       Involve a capacity addition;             Project does not involve a
                                                                          capacity       addition.     On-site
                                                                          assessments          and    satellite
                                                                          imagery          are      adequate
                                                                          justifications     regarding    this
                                                                          consideration.
         1                       Involve a retrofit of (an) existing      Project activities does not involve
                                 plant(s); or                             a retrofit of (an) existing plant.
                                                                          FSR, project licence and on-site
                                                                          assessments         are   adequate
                                                                          justifications     regarding    this
                                                                          consideration.
                                 Involve a replacement of (an)            The project does not involve a
                                 existing plant(s)                        replacement of (an) existing plant
                                                                          or plants. Above mentioned
                                                                          clarifications are also acceptable
                                                                          for this item.

8  http://cdm.unfccc.int/filestorage/V/9/L/V9LRSXKP24Q7YT6HZDUBO3C0ING8AJ.1/EB61_repan17_Revision_AMS-
I.D_ver17.pdf?t=RjV8bTg0czJ2fDAUXvAZG9PAKaZt54JtLAyd (accessed on 11 August 2012)

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       Reference page in    Applicability Criteria                      Justification
       AMS-I.D    Version
       17.0
       2                    Hydro power plants with reservoirs          The project activity is not
                            (A reservoir is defined as a water          implemented in an existing
                            body created in valleys to store            reservoir, where the volume of
                            water generally made by the                 reservoir is increased and the
                            construction of a dam) that satisfy         power density of the project
                            at least one of the following               activity is identified as far greater
                            conditions are eligible to apply this       than 4 W/m2 by considering that
                            methodology:                                Yalnızardıç Dam and Berat
                            o The           project    activity    is   HEPP project is an accumulation
                                  implemented in an existing            reservoir type HEPP and
                                  single or multiple reservoirs,        installed capacity per areal
                                  with no change in the volume          storage capacity is far greater
                                  of any of reservoirs;                 than the mentioned reference; 4
                            o The           project    activity    is   W/m2. The situation is clearly
                                  implemented in an existing            identified within the “Revised
                                  reservoir, where the volume of        Feasibility Study Report” (pdf
                                  reservoir is increased and the        page 147) and below:
                                  power density of the project
                                  activity, as per definitions given    Yalnızardıç         Accumulation
                                  in the project emissions              Reservoir
                                  section in the approved
                                  methodology, is greater than 4        Normal Water Level: 1381.50 m
                                  W/m2;                                 Total Storage Volume: 129.91
                            o The project activity results in           hm3
                                  new reservoirs and the power          Installed Capacity: 33 MW
                                  density of the power plant, as        Power Density (PD): 33*106W /
                                  per definitions given in the          (129.91*106 m3 / 1381.50 m) =
                                  project emissions section in          351 W/m2
                                  the approved methodology, is
                                  greater than 4 W/m2.
       2                    If the new unit has both renewable          The project does not involve an
                            and non-renewable components                installation which has both
                            (e.g. a wind/diesel unit), the              renewable and non-renewable
                            eligilibility limit of 15 MW for a          components.
                            small-scale CDM project activitiy
                            applies only to the renewable
                            component. If the unit co-fires fossil
                            fuel, the capacity of the entire unit
                            shall not exceed the limit of 15 MW.
       2                    According            to        approved     The project does not include any
                            methodology, combined heat and              combined heat and power (co-
                            power (co-generation) systems are           generation) system.
                            not eligible under the category
                            mentioned within the applicability
                            criteria part of the document.
       2                    It is stated in the approved                Proposed project activity does
                            methodology that in the case of             not involve the addition of
                            project activities that involve the         renewable energy generation
                            addition of renewable energy                units at an existing renewable
                            generation units at an existing             power generation facility.
                            renewable         power      generation
                            facility, the added capacity of the
                            units added by the project should

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         Reference page in         Applicability Criteria                   Justification
         AMS-I.D    Version
         17.0
                                   be lower than 15 MW and should
                                   be physically distinct from the
                                   existing units.
         2                         The approved methodology states          Proposed project activity does
                                   that in the case of retrofit or          not involve any cases such as
                                   replacement, to qualify as a small-      retrofit or replacement.
                                   scele project, the total output of the
                                   retrofitted or replacement unit shall
                                   not exceed the limit of 15 MW.

        All related files which justify the situation of being a grid connected greenfield plant are provided as
        supplementary documents (Check directory “19-EIA_positive” for the coordinates of the facility and
        for the confirmation that the EIA is accepted by the Ministry of Environment and Urbanization on
        12-12-2012). This acceptance was before the start of the construction of the project. In the host
        country (Turkey), projects are obligated to get EIA approval letter before the implementation of a
        project to a Greenfield, except for small hydro projects, which receive an EIA exemption letter.

2.3    Project Boundary

        The Yalnızardıç Dam and Berat HEPP Project entails the installation and operation of a plinth
        tailwater power plant (0.50 MW) and a downstream power plant (32.50 MW) which have a total
        installed capacity of 33 MW to best suit the local conditions of the project area. The project consists
        of a hydro power plant with three turbines; one with a nominal power of 500 kW, and two of each
        having 16,250 kW.

        The project boundary includes net electricity generated and supplied to the Turkish national grid.
        There is a diesel generator only for the emergency situations. The electricity produced in the
        generator is not for selling purposes, it is only used for internal consumption of the plant.

        A general operator diagram is given in the next figure, which is presented in more detail in “11-
        Single_Line_Diagram”:

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                                All the other plants are
                                connected to the grid.

        Figure 2 Operator diagram for the Yalnızardıç Dam and Berat HEPP

       Based on the above operation diagram, the baseline and project activity related greenhouse gases
       which are considered in baseline calculation is given below:

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        Table 2 Justification of the project boundary

          Source                     Gas       Included?      Justification/Explanation
                      Generation     CO2       Yes            CO2 emissions from fossil fuel fired power plants
                                                              that are displaced due to the project activity are
           Baseline
                      mix of
                                                              taken into account
                      electricity
                                     CH4       No             Minor emission source
                      grid in
                      Turkey         N2O       No             Minor emission source

                                     CO2       No             As net electricity approach is applied, emissions
                                                              that occur during construction and during the
                      Construction                            operation are negligible and non-existent
                      and                                     respectively
           Project

                                     CH4       Yes            The emissions during construction are at a
                      operation of                            negligible level and also, as the power density of
                      the HEPP                                the project is far more than 10 W/m 2 (by
                      Project                                 considering runoff structure of the plant with no
                                                              reservoir), no CH4 emissions are expected.
                                     N2O       No             Minor emission source

2.4    Baseline Scenario

        Since the proposed project activity is the installation of a new grid-connected hydroelectric, that is
        a renewable power plant and therefore, the baseline scenario is defined as the following based on
        AMS I.D (Version 17.0):

                       “The baseline scenario is that the electricity delivered to the grid by the project activity
                       would have otherwise been generated by the operation of grid-connected power plants
                       and by the addition of new generation sources into the grid.”

        Since the proposed project activity is going to be connected to the Turkish national grid, the
        baseline scenario of the proposed project is the supply of the equivalent amount of annual power
        output by the existing Turkish national grid which is the continued operation of existing power plants
        and the addition of new sources to meet electricity demand.

        Since the proposed project activity is an installation of a new grid-connected renewable power
        plant, the baseline scenario is formulated in AMS I.D./Version 17 “Electricity delivered to the grid
        by the project would have otherwise been generated by the operation of grid-connected power
        plants and by the addition of new generation sources, as reflected in the Combined Margin (CM)
        calculations described below”.

        According to the “Baseline Methodology Procedure” in the “Tool to Calculate the Emission Factor
        for an Electricity System Version 04.0.0.”, the following steps should be followed.

        All the information pertaining to the grid and estimating baseline emissions are publicly available,
        and was available at the website of TEIAS (Turkish Electricity Transmission Company Inc.).

        To describe the baseline and its development for the project activity, long term electricity demand
        and supply projections for Turkey are assessed.

        Demand for electricity in Turkey has been growing rapidly with an average growth of 5.8% over the
        previous ten years. TEIAS, who is responsible from the grid reliability has prepared an electricity

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          demand projection for next ten years period (2014-2023) for Turkey and published in December
          2014, given in the next Table, reflecting the continuation of current demand growth. 9

          Table 3 Low and High Demand Projection Scenarios for Ten Years Period (TWh)

                             2014     2015     2016    2017     2018    2019     2020     2021    2022     2023
           Base demand      256.7    271.5    287.3   302.8    320.0   338.3    357.4    376.2   395.5    415.7
           High demand      274.0    291.5    309.9   329.1    349.2   370.1    391.9    414.7   438.3    462.9
          Source: Table 4 and 5 of the TEIAS capacity projection,
          http://www.teias.gov.tr/YayinRapor/APK/projeksiyon/KAPASITEPROJEKSIYONU2014.pdf

          In this projection, electricity supplies are also forecasted taking into account all power plants which
          are operational, under construction and newly licensed. Generation projection based on project
          generation is given in the next Table:

          Table 4 Projection of Total Generation Capacity by Fuel Types (GWh)
                               2013    2014    2015    2016    2017     2018 Share in 2018
           Lignite            52880 54094 55325 56825 58746 59071                    13.1%
           Hard Coal           3967    4939    5911    5911    5911     5911          1.3%
           Imported Coal      26287 33957 41876 42567 42132 42179                     9.4%
           Natural Gas       177543 185308 193493 199278 205683 208381               46.3%
           Geothermal          2206    2508    2962    3279    4040     4635          1.0%
           Fuel Oil            9429    9834 10239 10239 10239 10239                   2.3%
           Diesel               148     148      148     148     148      148         0.0%
           Nuclear                0       0        0       0       0        0         0.0%
           Other               1332    1332    1332    1332    1332     1332          0.3%
           Total thermal     273790 292118 311284 319577 328230 331895               73.7%
           Biogas + waste      1508    1619    1736    1768    1792     1792          0.4%
           Hydro              77094 83195 89777 96208 100123 101778                  22.6%
           Wind                9646 10537 11611 13089 14568 14752                     3.3%
           Total             362038 387468 414409 430643 444713 450217
           Fossil fuel share   76%     75%      75%     74%     74%      74%
          Source: Table 21 of the TEIAS capacity projection,
          http://www.teias.gov.tr/YayinRapor/APK/projeksiyon/KAPASITEPROJEKSIYONU2014.pdf

          As a result, fossil fuels will hold the dominance in generation mix for at least midterm period (until
          the end of 2018) with 73.7% share. Hydro share will stay at a 22.6% share and non-hydro
          renewable energy contribution will constitute a mere 3.7% of the total share by the end of 2018.

2.5     Additionality

          For the explanation of how and why the project activity leads to emission reductions that are
          additional to what would have occurred in the absence of the project activity, the Baseline
          Methodology refers to the consolidated “Guidelines on the demonstration of additionallity of small
          scale project activities (version 9)”, which defines a step-wise approach to be applied to the
          proposed project.

          Within the scope of additionality to justify the early consideration of VER, the timeline of the project
          activity is presented below.

9   http://www.teias.gov.tr/YayinRapor/APK/projeksiyon/KAPASITEPROJEKSIYONU2014.pdf

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       Table 5 Planned Project Implementation Schedule and Early Consideration of VER

         Date (DD/MM/YYYY)         Activity
         11-03-2009                First license application for Yalnızardiç.
         01-01-2011                Revised FSR
                                   “Environmental Impact Assessment Exemption Certificate” from
         12-12-2012
                                   Ministry of Environment and Urbanization
         22-10-2012                Water Usage Agreement with DSI
                                   Final Revision of Licence (After the combination of Yalnizardıç
         04-08-2011
                                   Dam and Berat HEPP); Licence No EÜ/3344-28/2032
                                   Investment decision by considering the income from carbon
         12-12-2011
                                   offsets.
                                   Agreement for getting consulting services for emission reduction
         22-05-2012
                                   activities.
         07-05-2013                Registration of the Company on Turkey Trade Registry Gazette
         17-05-2013                Electromechanical Agreement
         13-11-2013                Local Stakeholder Meeting Regarding VER Activities

       STEP 1. Identification of alternatives to the project activity consistent with current laws and
       regulations.

       SUB-STEP 1a. Alternatives to the project activity

       The project alternatives can be defined as follows:

       a) The proposed project activity undertaken without being registered as a VER project activity

       This alternative is not credible since the investment analysis shows that the project is not
       economically feasible without VER credit income. Detailed information is given in Step 2.

       b) Other realistic and credible alternative scenario(s) to the proposed VER project activity scenario
       that deliver electricity with comparable quality, properties and application areas, taking into account,
       where relevant, examples of scenarios identified in the underlying methodology;

       The project activity is a power generation activity without any greenhouse gas emission employing
       hydro electricity generation. Being a private entity, Albe Enerji does not have to undertake power
       investments in the proposed project activity. Also, since Albe Enerji only has a licence for a hydro
       power investment and since in the proposed project area there is no hydro or other sources for
       electricity generation, other project activities delivering the same electricity in the same project area
       is not a realistic alternative for the project participant.

       c) Continuation of the current situation, i.e. Yalnızardıç Dam and Berat HEPP is not built

       The decision in favour or against a project investment depends on the expected revenues and risks,
       like for every other private investment. Investment decisions other than Yalnızardıç Dam and Berat
       HEPP are independent from the question whether Yalnızardıç Dam and Berat HEPP is built or not.
       This alternative is also realistic and credible.

       According to the baseline scenario which is described in Section B.4, there is a need for energy
       investment to satisfy increasing demand and if the Yalnızardıç Dam and Berat HEPP is not built,
       the same amount of energy will be supplied by other private investors to the grid. Forecasts shows
       that electricity supplied in the absence of the Yalnızardıç Dam and Berat HEPP will be based for
       the great majority on fossil fuels as shown by official TEIAS projections until the year 2018, where
       a share of 73.7% fossil fuels in the energy mix is foreseen.

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           Therefore, one realistic and credible alternative scenario is identified for the project activity:

       a) Continuation of the current situation, i.e. Yalnızardıç Dam and Berat HEPP is not built.

           The only real alternative to the project is not building the project. This means that no action is
           undertaken by the project developer and in fact the decision of not investing does not contradict
           with any legal and regulatory requirements.

           SUB-STEP 1b. Consistency with mandatory laws and regulations

           The project alternative, the baseline scenario which is the continuation of the existing situation is
           in compliance with all mandatory applicable and legal and regulatory requirements. Also the
           alternative scenario of addition of new power generation capacity to the grid is regulated by the
           Energy Market Regulatory Authority (EMRA) who issued the licenses for electricity generation and
           is responsible for ensuring that new capacity applies with its rules and regulations.

           Outcome of Step 1b: The alternative scenario to the project activity is the supply of electricity by
           the existing grid with additional capacity is in compliance with the mandatory legislation and
           regulations.

           STEP 2. Investment analysis

           SUB-STEP 2a: Appropriate analysis method

           With the help of the investment analysis it shall be demonstrated that the proposed project activity
           is not economically or financially feasible without the revenue from the sale of VERs. Therefore,
           the benchmark analysis shall be applied, as there is no alternative project activity for a comparison
           of the attractiveness of an investment.

           SUB-STEP 2b: Option III: Benchmark analysis

           In order to evaluate the attractiveness of investment projects and compare them with possible
           alternatives, the project IRR (Internal Rate of Return) shall be used. Here the project IRR is applied
           as it is transparent in calculations and it leads to the following conclusion: the project needs carbon
           credits, due to its low profitability.

           According to the Tool, a benchmark can be derived from “Estimates of the cost of financing and
           required return on capital (e.g. commercial lending rates and guarantees required for the country
           and the type of project activity concerned), based on bankers views and private equity
           investors/funds” (see Section 4.3.4, 38(b)).

           There are no benchmarks specified by national authorities for hydropower projects in Turkey. Local
           lending rates can be taken as the benchmark for the investment analysis.

           State Planning Organisation publishes “Main Economic Indicators” on a monthly basis. As the
           project is a mid-term investment (exceeding a year), lending rate for medium term investment has
           been selected as the benchmark. The monthly lending rates for 2011 are given in the table below.

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PROJECT DESCRIPTION: VCS Version 3
           Table 6 Loan Interest Rates for Medium Term Investment Loans

                 Turkish Development Bank (TSKB) – interest rates for credits
                Date        Month        Medium Term Investment Rate (%)
                               1                        12.3
                               2                        12.3
                               3                        12.5
                               4                        12.5
                               5                        12.5
                               6                        13.0
                2011
                               7                        13.0
                               8                        13.0
                               9                        13.0
                              10                        16.0
                              11                        16.0
                              12                        16.0
           Ref: http://ekutup.dpt.gov.tr/tg/index.asp?yayin=teg&yil=0&ay=0
           Temel Ekonomik Göstergeler, 2014, 3rd quarter
           7. Bolum, 13th Excel Sheet. (Please also see 28- IRR\13-faiz_orani.xls in order to reach to the same document

           The investment decision was taken on 12-12-2011. Therefore, the published interest rate for
           December 2011 is taken as the benchmark, which is 16.0%.

           SUB-STEP 2c: Calculation and comparison of the IRR

           In the 9th paragraph of the “Guidance on the Assessment of Investment Analysis”, 10 it is stated that:
           “The cost of financing expenditures (i.e. loan repayments and interest) should not be included in
           the calculation of project IRR.” Since the benchmark as identified in the Sub-step 2b is the
           required/expected return on the project, the project IRR (before tax) of the project activity shall be
           calculated for comparison.

           The feasibility study prepared by Hidromak Mühendislik Müşavirlik A.Ş. in January 2011 and the
           below IRR calculations both reveal the fact that the project is not financially attractive. Therefore,
           carbon revenues are crucial for the project. The assumptions used for this analysis are outlined as
           follows:

                   The financial analysis is performed with a 3 years construction period and a 20 year
                    operation period. Therefore includes the investments to be made by the project owner three
                    years, whereas the operational costs are applied along the lifetime of the project.
                   The project Internal Rate of Return (IRR) of the project cash flow has been calculated.
                   The depreciation period of machinery and equipment was assumed as 20 years, which is
                    in line with the real life conditions and a common assumption for machinery. Moreover, the
                    other fixed assets’ (buildings etc.) depreciation life is assumed as 50 years, which is in line
                    with the real life conditions and a common assumption for buildings.
                   The annual power generation figure is 71.101 GWh, as specified in the FSR as approved
                    by the State Hydraulic Works
                   A power price for the project is assumed to be 85 $/MWh (Please refer to the Revised
                    FSR pdf page 182) as it reflects a more realistic scenario than using the price under the
                    state guarantee which is 73 $/MWh.11

           The project IRR (before tax) of Yalnızardıç Dam and Berat HEPP is calculated on the basis of
           expected cash flows (investment, operating costs and revenues from electricity sale), as used in

10   Annex to http://cdm.unfccc.int/methodologies/PAmethodologies/tools/am-tool-01-v6.0.0.pdf
11   Please refer to Turkish Renewable Energy Law No: 5346 amendment of December 2010.

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       the financial analysis for the feasibility assessment of the project. The parameters and values used
       for the IRR calculation are available to DOE during validation. The resulting IRR for 20 years is
       stated in the following table.

       Table 7 Project IRR for project activity (before tax)

         Period                        IRR
         20 years                      2.46%
       Source: for calculation see the attached spreadsheet “/8-IRR/IRR_Ver02.xls”

       Without adding any risk premium to the benchmark, which is 16.0%, the benchmark clearly exceeds
       the calculated project IRR, rendering the project activity economically unattractive without VER
       carbon credits.

       SUB-STEP 2d: Sensitivity analysis

       According Section 4.3.6 of the tool, a sensitivity analysis needs to be undertaken to demonstrate
       the robustness of the conclusion that the project is economically unattractive.

       While the main parameter determining the income of the project is the electricity sales price, a
       variation of the main parameters of the financial model shall demonstrate the reliability of the IRR
       calculation. Electricity price (EP) is varied following a conservative approach the range 70-100
       $/MWh is taken into consideration. It is common practice in Turkey to sell renewable electricity on
       the spot market, which used to have a price above the feed-in tariff of the RES law. It is, however,
       not guaranteed and even prices below this feed-in tariff have been observed recently after
       December 2009, when Turkey moved to an hourly pricing regime. Therefore, the sensitivity analysis
       will show the possible impact of spot prices above and below the average expected price of 85
       $/MWh.

       In addition, to show the sensitivity of other key parameters, the investment cost and operating costs
       are varied with +/- 20%. This shows what would happen if the investment costs or operating costs
       would differ from the values as presented in the FSR.

       The worst, base and best case results for each parameter variation is given in the next Table.

       Table 8 Project IRR results for varied parameters (for other parameters 85 $/MWh Energy
       Price is applied)

          Parameter    Electricity Price    Investment Cost   Operational cost
          Variance    70      85      100 -20%     0    20% -20%    0%     20%
          IRRs      0.37% 2.46% 4.31% 4.77% 2.46% 0.72% 2.70% 2.46% 2.22%

       Source: for calculation see the attached spreadsheet “22-IRR/IRR_Ver03.xls

       The sensitivity analysis confirms that the proposed project activity is unlikely to be economically
       attractive without the revenues from VERs as even the maximum project IRR result for the best
       case scenario (4.77%) is substantially below the benchmark, which is 16.0%.

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       Step 3 Barrier analysis

       As the investment analysis concludes that the proposed project activity is unlikely to be the most
       financially attractive option, the sub step 3 (Barrier Analysis) is optional and this is not considered
       for the Yalnızardıç Dam and Berat HEPP project activity.

       Step 4 Common Practice Analysis

       As per “Tool for the Demonstration and Assessment of Additionality”, projects are considered
       similar if they are in the same region and rely on the same technology, are of a similar scale, and
       take place in a comparable environment with respect to regulatory framework, investment climate,
       access to technology, access to finance, etc. According to the Guidelines on Common Practice
       (version 02), common practice analysis is presented through the following 5 steps.

       Common Practice tool step 1: Calculate applicable output range as +/- 50% of the capacity of the
       proposed project activity:

       As a hydropower project, the installed capacity is chosen as an appropriate proxy for “similar scale”.
       The power generation capacity of 33.00 MW of the proposed project is selected as the design
       capacity. Therefore, the range from 16.50 MW to 49.50 MW is considered as applicable capacity.

       Common Practice tool step 2: Identify similar project (both CDM and non-CDM) which fulfil all of
       the following conditions:
           1. The projects are located in the applicable geographical area
           2. The projects apply the same measure as the proposed project activity
           3. The projects use the same energy source/fuel and feedstock as the proposed project
                activity, if a technology switch measure is implemented by the proposed project activity
           4. The plants in which the projects are implemented produce goods or services with
                comparable quality, properties and application areas as the proposed project plants
           5. The capacity or output of the projects is within the applicable capacity range as calculated
                in step 1
           6. The projects started commercial operation before the PDD is published for global
                stakeholder consultation or before the start date of the proposed project activity, whichever
                is earlier for the proposed project activity.

       The applicable geographical area for the project activity is considered the Antalya water catchment
       area in Turkey. This catchment largely falls in the Antalya province as illustrated in the below graph.

       Figure Water catchments in Turkey

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