Under Review - Adani Power
Under Review - Adani Power
Under Review - Adani Power
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CONTENTS
D. Environmental impacts
E. Stakeholders’ comments
Annexes
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Adani Group, a diversified conglomerate has interests in various activities including interests in
commodity trading, edible oil refining and infrastructure projects and services. Adani Enterprises Ltd
(AEL), the flagship company of the group, is an international trading house dealing in nearly 70
commodities in more than 60 countries around the world. Adani Power Maharashtra Limited (APML)
is a subsidiary company of Adani Power Limited. The power division of AEL is a well known name in
power trading in India.
APML will implement the high efficiency power generation project using coal-fired super-critical
technology at Tirora, District Gondia - Maharashtra which would result in reduced consumption of
fossil fuel and associated greenhouse gas (GHG) emissions for thermal power generation.
Purpose of the project activity
Super-critical coal fired power generation plant is being proposed as project activity which will have
an installed capacity of 1320 MW (2 x 660 MW). The efficiency of the super-critical coal fired power
plant is around 41.75%1 which is quite higher than the sub-critical coal fired power plants that are
presently operating in India having average efficiency ~31.80%2 (also refer Table A1 in Annex 3). A
subcritical power plant of 500 x2 MW capacity and constructed in recent years would have a higher
efficiency of about 35.1% (corresponding to a station heat rate of 2450 kCal/kWh)3. The electricity
generated will be exported to the local/regional/national grid. The project activity will be implemented
at Tirora, the installed capacity will be 1320 MW (2 x 660 MW).
Many regions of the world are experiencing fast growing electricity demand. Thermal power plants
are a major source of carbon dioxide, which is one of the GHGs listed under the Kyoto Protocol. Coal
1
Calculated from Station Heat Rate of 2060 kCal/kWh for the proposed project activity
2
Sources: http://www.cea.nic.in/god/opm/Thermal_Performance_Review/0607/SECTION-13.pdf
http://www.cea.nic.in/god/opm/Thermal_Performance_Review/0708/highlights.pdf
3
http://www.cercind.gov.in/03022007/Pet_106-2006%20RihandSTPS-II.pdf
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is an abundant fuel resource in many of the world’s developing regions and forecasts show that it is
likely to remain a dominant fuel for electricity generation in many countries for years to come.
Capital scarcity and competition which are maintaining downward pressure on prices of new power
plants. It is against this backdrop that power plant suppliers have invested heavily in generation
technologies that produce power more efficiently. Enhanced plant efficiency reduces emissions of CO2
and all other pollutants by using less fuel per unit of electricity generated. Improvement in efficiency
can be achieved by using supercritical steam conditions. One percent increase in efficiency reduces by
two percent, specific emissions such as CO2, NOx, SOx and particulates4.
The steam generation in the project activity will be occurring at super-critical conditions (at boiler
outlet, steam temperature of 5710C and pressure of 25.40 MPa (g)) and this steam is further utilised in
power generation through condensing type steam turbine. The super-critical cycle has a higher
efficiency of steam generation as compared to that of conventional sub-critical technology. Higher
steam generation efficiency and hence higher overall cycle efficiency will lead to lower specific coal
(i.e. fossil fuel) consumption.
4
http://power4georgians.com/supercritical.aspx
5
The Steam after passing through the HP turbine is reheated in the reheater before passing through the IP/LP
turbine. This is referred to as the reheat steam. Refer to Figure 2 (part marked 3).
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Thus the implementation of the proposed project activity will reduce fossil fuel combustion for the
generation of same amount of electricity and thus will lead to lessening of global warming.
Sustainable
Development
Social sustainability
Due to its location, the project activity will contribute towards poverty alleviation by generating both
direct and indirect employment for the local community. During the construction activity of the
project, local people will be employed. Due to better technology usage, the project activity would help
adding to the knowledge and skill base of the power plant operators. It will also contribute to
improvement of the power deficit situation, which will improve quality of life and facilitate accelerated
implementation of rural electrification initiatives in India.
Environmental sustainability
The higher efficiency of power generation would reduce fossil fuel consumption. Less coal
consumption will improve the local environmental condition by reducing emissions of carbon dioxide
and other air pollutants like SPM, SO2 etc.
Economic sustainability
The project activity will contribute towards sustainable development of the region, not only through
reduced emissions contributions, but also through various initiatives to be undertaken by the project
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proponent. These include the local employment during project implementation and operational phases
and extending the medical care facility to the employees. It will also lead to the local employment for
the resources with low and medium skilled services often required in the project activity. The proposed
project activity will lead to huge investment being made in the State of Maharashtra. The proposed
project activity will reduce the supply deficit of electricity in India and contribute to the infrastructural
and economic growth of India. The technical consultants, equipment suppliers all would be benefited
economically because of the proposed project activity.
Technological sustainability
The technology employed being the first-of-its-kind in the thermal power generation sector of
Maharashtra and the project activity will initiate capacity building, development of new skills and the
knowledge base which could be used as a reference for the next coming entrants. The usage and
development of such technologies in developing countries like India will help in greater extent in
fulfilling its energy generation need in a very environment friendly way.
Name of Party involved Private and/or public entity Kindly indicate if the Party
(ies) project participants involved wishes to be
considered as project
participant (Yes/ No)
Government of India (Host Adani Power Maharashtra Ltd – No
Country) Private Entity
India
Maharashtra
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The site is located about 2.5 km east of Tirora town in Gondia District, Maharashtra. The site is about
122 km from Nagpur airport, and 45 km from Gondia railway station. The latitude and longitude of
plant site are 21O 24’ 42.9” North and 79O 58’ 14.9” East respectively. The site is encompassed by
villages Chikhali, Churdi, Bhiwapur, Tamsar and Mendipur Bhandara Road – Gondia Section of
South Eastern Railway is passing within 500 m of the site. The state highway connecting Khairanji
and Bhandara Road grazes past the plant site and connects Tirora Town.
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The project activity is a large scale potential CDM project, which fits into the Category 1: Energy
industries (renewable / non renewable sources) as per ‘List of Sectoral Scopes’6.
Thermodynamic Cycle:
The thermodynamic cycle for 660 MW unit will consider super-critical steam parameters. The unit
comprises the boiler, the steam turbine generator, the condenser, the condensate extraction and boiler
feed systems along with all other necessary equipment for single/double reheat-regenerative cycle. The
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steam parameters at the outlet of the boiler have been considered to be 259.01 kg/cm2 (a), 571°C with
steaming capacity of about 2111 TPH. Corresponding steam parameters at the turbine inlet would be
246.77 kg/cm2 (a) at 566°C and reheated steam parameters would be about 46.091 kg/cm2 (a) and
569°C. The HP/IP cylinders may be single/double casing design as per manufacturers’ standard. The
exhaust from HP-IP turbine will further expand in the double flow LP Turbines.
The exhaust steam from the LP turbine will be cooled in the main steam condenser by circulation of
required quantity of cooling water and its vacuum will be maintained by two of the four 50% capacity
vacuum pumps maintaining a backpressure of 76 mm Hg (abs). The condenser would be twin flow,
double pass, horizontal, shell and tube type, cooled by circulation of cooling water (inlet water
temperature 33°C max) in a re-circulating cooling water circuit using wet cooling tower.
The regenerative feed heating system will consist of three/four stages of low pressure heaters, one
gland steam condenser, one separate condenser, one separate drain cooler, one spray-cum-tray type
deaerator, two parallel chains of three high pressure heaters having 50% capacity. The condensate
drawn from condenser hot well by 3 x 50% capacity steam turbine driven condensate extraction
pumps will be pumped to the de aerator through condensate polishing unit, gland steam condenser,
drain cooler and the LP heaters. The feed water would be drawn by the boiler feed pumps and pumped
to the respective boilers to the three higher pressure heaters. Three nos. boiler feed pumps [two nos.
turbine driven of 50% capacity each and one no. motor driven of 30% capacity] have been envisaged
for each unit.
6
Reference: http://cdm.unfccc.int/DOE/scopes.html
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pressure and temperature, cycle efficiency improves which results in reduction of fuel consumption per
unit electricity generated which in terms reduces CO2, NOx & SOx emissions. To limit the dust load
at the inlet to the chimney to a value of 75 mg/Nm3, adequately sized electrostatic precipitators would
be provided.
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Two super-critical coal fired power generation units will be set up in proposed project activity, each of
which has 660 MW (Nominal) capacity, providing a total installed capacity of 1320 MW (Nominal).
The steam generator (SG) would be once through type of boiler and would be designed for firing on
100% domestic coal. The characteristics of the SG would be radiant, single reheat, balanced draft and
outdoor type. The parameters for the SG are as below.
7
Turbine Maximum Continuous Rating
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A.4.4 Estimated amount of emission reductions over the chosen crediting period:
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B.1. Title and reference of the approved baseline and monitoring methodology applied to the
project activity:
Title: Consolidated baseline and monitoring methodology for new grid connected fossil fuel fired
power plants using a less GHG intensive technology
Reference: ACM0013, Version 02.1, www.unfccc.int
B.2 Justification of the choice of the methodology and why it is applicable to the project
activity:
The methodology ACM0013, Version 02.1 is applicable to “new electricity generation plants” and
thus can be considered for the proposed project activity under consideration since the proposed project
activity of APML involves development of Greenfield coal based power generation capacity using
super-critical technology and supplying power to the Western Regional Grid of India.
Further, the project activity meets the applicability criteria of ACM0013, Version 02.1 as under.
“The project activity is the construction and operation of a new fossil fuel fired grid-connected
electricity generation plant that uses a more efficient power generation technology than what would
otherwise be used with the given fossil fuel”- The proposed project activity of APML involves
construction of the new super-critical coal fired power plant at Village Tirora, District Gondia. As
already depicted in section A.2., the project activity uses super-critical technology which is more
efficient than the conventional coal fired sub-critical power generation technology, an established and
conventional practice in the Indian scenario.
“The project activity is not a co-generation power plant”- The proposed project activity generates
only power and is not a cogeneration power plant. A fully condensing turbine will be used in the
proposed project activity. The turbine will operate at a pressure of about 24.2 MPa (a), main steam
temperature and reheat steam temperature both are of about 566 0C.
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“Data on fuel consumption and electricity generation of recently constructed power plants is
available.”- The relevant data/ information on electricity generation and fuel consumption are
available with Central Electricity Authority (CEA), Govt. of India and the same have been used by
CEA for calculation of baseline emission factor which has been published by CEA8. The same factor
is used by the project proponent to arrive at the baseline emissions for the project activity9.
“The identified baseline fuel is used in more than 50% of total generation by utilities in the
geographical area, as defined later in the methodology, within a country or country10. To
demonstrate this applicability condition data for latest three year shall be used. Maximum value of
same fossil fuel generation estimated for three years should be greater than 50%”-The identified
baseline fuel is coal which is used in more than 50% of total generation by utilities within India which
is clearly shown in the below given data. Data for latest three years have been given below.
Table 3: All India Electricity Generation Data in GWh
Type of Generation Generation (GWh)
2007-081 2006-071 2005-062
Coal 476726.57 461339.98 435096.64
Gas + Diesel 72227.9 66207.38 62117.66
Total Thermal 558990.05 527547.36 497214.30
Hydro 123424.12 113358.77 101293.1
Nuclear 16776.91 18606.75 17238.89
Total 699191.08 662522.96 617510.44
% Coal in total 68.18 69.63 70.45
Generation
% of gas + diesel in 10.33 9.99 10.05
Total Generation
1
http://www.cea.nic.in/god/opm/Monthly_Generation_Report/18col_A_08_03/FILE-04.pdf
2
http://www.cea.nic.in/cea-archive/body/Reports/Monthly%20Generation%20Report/2006/18col_06_03.pdf
8
As per CEA website (http://www.cea.nic.in/planning/cdm.pdf), “The CO2 Baseline Emission factor for coal
based power units as applicable to new coal fired power generating units with supercritical steam parameters
has been worked out as 0.941 tCO2/MWh ( based on net generation ) for the year 2007-08. The calculations
are based on CDM Executive Board approved methodology ACM0013 Ver 01 “ New Grid connected fossil
fuel fired power plants using a less GHG intensive technology”. Since the calculation procedure for emission
factor is the same for ACM0013 version 01 and ACM0013 version 02, hence the value of 0.941 tCO2/MWh
has been used for the project activity as well.
9
http://www.cea.nic.in/
10
For the purpose of demonstrating compliance with the applicability condition the geographical area has to
be limited by the physical borders of the host country and cannot be extended to neighboring non-Annex I
countries, even if such an extended geographical area is used for the calculation of a benchmark emission
factor.
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Using tables 3 and 4, it can be concluded that the identified baseline fuel, coal is used as a fuel in more
than 50% of the generation utilities in India.
B.3. Description of the sources and gases included in the project boundary
The circumference of the project boundary includes the power plant at the project site and all power
plants considered for the calculation of the baseline CO2 emission factor (EFBL,CO2,y). In calculating the
project emissions and Baseline emissions, only CO2 emissions from fossil fuel combustion in power
plant(s) are taken.
Table 5: Overview on emissions sources included in or excluded from the project boundary
This is conservative.
N2O No Excluded for simplification.
This is conservative.
On-site fuel CO2 Yes Main emission source.
Activity
combustion in the
Project
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The project boundary includes the top 15% coal fired power plants constructed in the last 5 years,
operating in India with a capacity of 500 MW at base load. Besides these power plants, the proposed
project activity at Tirora is also included in the project boundary.
B.4. Description of how the baseline scenario is identified and description of the identified
baseline scenario:
11
For supercritical power plant, unit sizes are available in 660 MW and 800 MW. The project activity uses the 660 MW
configuration. For subcritical power plants, unit sizes are available in 250 MW and 500 MW (these two units “form the
backbone of the Indian Power Sector” as per page 5 of the report made available by CEA, “REPORT OF THE
COMMITTEE TO RECOMMEND NEXT HIGHER SIZE OF COAL FIRED THERMAL POWER STATIONS” at
http://www.cea.nic.in/thermal/Special_reports/Report%20of%20the%20committee%20to%20recommend%20next%20hi
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Alternative 3. Power generation using energy sources (natural gas) other than coal
Natural gas can be used for power generation and this alternative is in compliance with all laws and
regulations of the country. In this case, the power plants will emit GHGs associated with combustion
of natural gas. However, given the deficit situation of natural gas supply and the projection of long-
term natural gas price, it is unlikely that any new thermal power generation capacity of 1320 MW will
come with natural gas as fuel. Hence this alternative is not considered further for arriving at the
baseline scenario.
As per CEA data of 2006-07, in the Indian Grid, coal based generation capacity is about 69.63% of
the total generation capacity while gas and diesel together account for only 9.99%. Nuclear and
renewable energy sources contribute a small amount to the energy requirement of India. Considering
these facts, it can be concluded that electricity generation comparable to the proposed project activity
in India can only be achieved by coal fired generation technology.
Alternative 4: Power generation using energy sources (diesel/ fuel oil/naphtha) other than coal
Diesel/ fuel oil/naphtha based power generation as an alternative to the project activity can be taken by
the project proponent. This alternative would be in order with all applicable laws and regulations of
the country. However, in this alternative the project proponent would face high operational cost barrier
on account of spiraling diesel/ fuel oil/naphtha prices for consumers. Under merit order purchasing or
compared to low cost of generation through other fuel alternatives, selling of power would be
extremely difficult from such power stations. In fact, the highest capacity power plant running on
diesel in India is of 128 MW (Kozhikode DG)12 only. Hence this alternative is not considered further
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for arriving at the baseline scenario since this alternative is associated with the barriers mentioned
above.
Alternative 5: Power generation using energy sources (renewable energy sources) other than
coal
In this alternative scenario, the project proponent could have considered generation of power using
renewable energy sources which includes hydro power, wind power, biomass energy etc. In this option
there would be no GHG emissions and this alternative is in compliance with all applicable laws and
regulations of the country. However, generation of power to the tune of 1320MW (which would be
running on a base load) using renewable resources like small hydro, wind, biomass etc is not a
technically and economically feasible proposition on account of inconsistent availability of renewable
sources and high risk associated with renewable technologies. The project proponent would face high
investment, technological and other barriers in order to implement this alternative. Furthermore,
renewable resource based power generating stations typically used for peak load services. Wind
energy generation is seasonal and intermittent during the seasons. Highest plant load factor achieved
by the wind based generation projects in a coastal Indian state like Maharashtra, is at a maximum of
33%, which is not comparable to the proposed project activity13. Biomass based generation projects
are planned to encourage utilization of waste land and active utilization of biomass available.
According to Ministry of New and Renewable Energy, Govt. of India, maximum load factor
achievable is 75%, which is less than that of the proposed project activity14. Typically biomass based
power stations are to the tune of 10 MW and hence is not a feasible alternative to the proposed project
activity.
Gas the power and fertilizer sector and some other specific units will receive NG supply against their existing allocation.
Also, in case of reduction in availability of this gas in future, the supplies to APM consumer would be reduced on a pro-
rate basis. The project proponent – APML does not have any existing allocation of NG. Furthermore, considering the
declining volume of APM gas supply in future (Ref: CRISIL Research Natural Gas Update – November 2007) it is highly
unlikely that the 1320 MW or nearing power generation capacity would come up based on APM gas supply.
http://72.14.235.132/search?q=cache:jtfvfuTUOp0J:powermin.nic.in/whats_new/PFR/Kearla/Perijankutty.pdf
+powermin+Brahmapuram&hl=en&ct=clnk&cd=1&gl=in
13
Page 30 of Maharashtra Electricity Regulatory Commission Order, Case No. 17 (3), 3, 4 & 5 of 2002 found
at http://mercindia.org.in/pdf/Detail_Wind_Energy_Order.pdf
14
http://mnes.nic.in/annualreport/2006_2007_English/HTML/ch2_pg5.htm
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Large hydro projects face huge risks of geological and hydrological uncertainties and could cause
dislocation of significant population15.
Therefore, the nature of the project activity and this baseline option on delivering similar services vary
significantly17.
Hence this alternative is not considered further for arriving at the baseline scenario.
Alternative 6. Power generation using energy sources (nuclear) other than coal
As an alternative to the project activity, the project proponent could have opted for nuclear power
generation. In this option there would be very less GHG emissions and this alternative will be in
compliance with all applicable laws and regulations of the country. However, as per the present
Atomic Energy Act of India nuclear power generation is restricted to Government or Government
owned companies only and not so far open to any private sector participation18. The project proponent
has to face stiff regulatory barriers in order to implement this option. Hence this alternative is not
considered further for arriving at the baseline scenario.
15
Policy on Hydro Power Development, Govt of India, Page 2-3 found at
http://www.powermin.nic.in/whats_new/pdf/hydro_power_policy_developmemt.pdf
16
http://www.cea.nic.in/power_sec_reports/general_review/0405/ch2.pdf,
http://www.cea.nic.in/power_sec_reports/executive_summary/2006_03/6.pdf,
http://www.cea.nic.in/power_sec_reports/Executive_Summary/2007_03/6.pdf,
http://www.cea.nic.in/god/opm/Monthly_Generation_Report/18col_07_03.pdf,
http://www.cea.nic.in/power_sec_reports/general_review/0405/ch3.pdf
17
As per Ministry of Power Guidelines for development of Hydro Electric projects sites by private developers,
GoI, several potential risks of natural calamities such as inter-state water sharing disputes, ecological
imbalance, displacement and land submergence. For e.g. seven tribunals were set-up by Ministry of Water
Resources for resolving various disputes including the inter-state. As a result of these disputes, large hydro
generation projects are withheld for execution among various Indian states.
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Alternative 7: Import of electricity from connected grids, including the possibility of new
interconnections.
This alternative involves import of electricity from connected grid to meet the power demand of India.
Table 6: Import of Electricity in India
All India Energy Generation data
Type of Generation Generation (GWh)
2007-08 2006-07 2005-06
Thermal 558990.05 527547.36 497214.30
Nuclear 16776.91 18606.75 17238.89
Hydro 123424.12 113358.77 101293.13
Bhutan Import 5290.1 3010.08 1764.12
Total 704481.18 662522.96 617510.44
% of import in Total Generation 0.75 0.45 0.29
http://www.cea.nic.in/god/opm/Monthly_Generation_Report/18col_A_08_03/FILE-04.pdf
http://www.cea.nic.in/cea-archive/body/Reports/Monthly%20Generation%20Report/2006/18col_06_03.pdf
http://www.cea.nic.in/power_sec_reports/executive_summary/2008_03/6.pdf
This alternative is in coherence with all applicable laws and regulations of the country. However, the
import of power by India has been 0.75% in 2007-08 and 0.45% in 2006-07. Considering this
historical trend of import of power and also considering the fact that large scale power import in India
is constrained by inadequate power transmission infrastructure and lack of grid integration among
neighboring countries, it can be concluded that the import of electricity from connected grids is not a
realistic and credible alternative and the imported amount of electricity will not be sufficient to meet
the power deficit situation in India. Hence this alternative is not considered any further.
The major assumptions to arrive at the levelized cost of power generation have been tabulated below.
18
National Report to the Convention on Nuclear Safety, Fourth Review Meeting of the Contracting Parties,
April 2008, Govt. of India
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The values for the subcritical power plant have been taken from a CERC approved order of a power
plant of similar capacity (500 x 2 MW) and approved at the same time when the project activity was
being conceptualized. The cost has been extrapolated for a plant of 1320 MW capacity.
The 70:30 debt/equity for the subcritical power plant is as per standard CERC guidelines and the
same has been used for the supercritical power plant.
The fuel (coal) price has been considered at INR 1077.8 per ton. This figure is arrived at by
considering a coal price of INR 750 per ton, a transportation and handling charge of INR 220 per ton
and a transportation loss of 0.1%19. The coal price of INR 750 per ton20 has been calculated
considering:
a) a royalty for the coal block allocated to the project proponent (including cess etc) (about INR
120/ton)
b) operational costs including manpower cost, power, stores etc
Table 7: Economic analysis of all the realistic and credible alternatives available with APML in
absence of the proposed project activity
Description of Alternative Levelized Cost of electricity
production (INR/kWh)
Alternative 1 The project activity not implemented as a 2.01
CDM project
Alternative 2 Power generation using sub-critical coal- 1.64
fired power generation technologies
Note: The calculation sheet is attached as Appendix 2.
As the data shows in above Table 7, the occurrence of Alternative -1 is prohibited by the higher
levelized cost of electricity generation. Hence, this alternative can not be considered as baseline option.
Alternative 2 “Power generation using sub-critical coal-fired power generation technologies” is
therefore the baseline for the proposed project activity.
19
Project Information Memorandum by SBI Capital Markets Limited for Adani Power Maharashtra Limited
20
Advance Coal Management & Marketing Pvt Ltd: Assessment of estimated project cost and operational
cost at Lohara West & Lohara Extension Opencast Project
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B.5. Description of how the anthropogenic emissions of GHG by sources are reduced below
those that would have occurred in the absence of the registered CDM project activity
(assessment and demonstration of additionality): >>
As per the approved methodology (ACM0013, Version 02.1) followed in this PDD,
“A power plant is a facility for the generation of electric power from thermal energy from
combustion of a fuel. In case where several power generation units have been installed at one site in
a single location, each unit should be considered as a power plant.”
Therefore, each of the 660 MW super-critical technology based unit (in project activity scenario) or
500 MW sub-critical units (in baseline scenario) have been considered as separate power plant for
subsequent discussion on emission reduction computation.
Even though this super-critical technology is already in practice in other nations like UK and Japan, no
super-critical power plant is yet operational in India21. In India, out of total installed power generation
capacity of 143061.01 MW the installed capacity of coal based thermal power constitutes 76048.88
MW as on 31.03.2008 (Refer to Table 4). However, till date not a single thermal power plant in India
has come up with super-critical technology. This demonstrates the real uniqueness of the project. The
technology has achieved very limited penetration in India due to the investment, technology and other
barriers as elaborated below.
The “Tool for the demonstration and assessment of additionality” version 05.2 has been followed to
demonstrate the additionality of this proposed project activity.
21
Page 141 of UMPP Risk Analysis Report by Mott MacDonald, British High Commission found at the link
http://www.defra.gov.uk/environment/climatechange/internat/devcountry/pdf/umpp-risk-analysis.pdf
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Step 1: Identification of alternatives to the project activity consistent with current laws and
regulations
Realistic and credible alternatives to the proposed project activity which are consistent with mandatory
laws and regulations and can be part of the baseline scenario have been identified in Section B.4. Thus
Option 2, which involves power generation using sub-critical coal fired technology, has been selected
as the most representative baseline for this proposed project activity.
Step 2: Investment Analysis
The project proponent has performed investment analysis to establish project additionality.
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As per the additionality tool, levelized cost of electricity production may be selected as a financial
indicator of the project. For the project activity under consideration, levelized cost of electricity
production has been identified as the most suitable financial indicator for the project type.
Sub-step 2c: Calculation and comparison of financial indicators
Levelized cost of electricity production
Options (INR/kWh)
Baseline: Power generation using sub-critical 1.64
coal-fired power generation technologies
Project activity not implemented as a CDM 2.01
project
Since, the levelized cost of electricity production of the proposed project activity is substantially
higher than the levelized cost of electricity production for the baseline case, it can be concluded that
the proposed project activity is additional from the financial point of view. The above comparison
between levelized costs of electricity production signifies that it is not a financially attractive
proposition for the project proponent to invest in the proposed project activity. However, the revenue
flow to the project activity through CDM would make the project financially viable.
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(Phase 3), Mundra were being conceptualized. However the UMPPs are of a higher capacity (4000
MW) and use a different unit size (800 MW). The NTPC plant is also of a higher capacity (1980
MW). Only the Adani Power Plant in Mundra satisfies the criteria to similar activities. (All the five
projects i.e. the Mundra UMPP, Sasan UMPP, Krishnapatnam UMPP, NTPC North Karanpura
projects and Adani –Phase 3 have been conceptualized considering CDM revenues)22.
Sub-step 4b. Discuss any similar options that are occurring
As there are no similar activities observed, this authenticate similar activities are not commonly
carried-out. Hence the need to any similar options that are occurring would not arise.
Since similar activities are not observed, hence Step 4 is satisfied.
Thus, it may be concluded that the proposed project activity is additional as it satisfies all the criteria
of the “Tool for the demonstration and assessment of additionality”, Version 05.2.
The objective of the proposed project activity is to generate and supply power to consumers in India
through electricity distribution agencies on a long term basis. The objective holds true irrespective of
the technology and investment chosen for the power plant. Under the proposed project activity, the
project proponent will be supplying 1320 MW of power to Maharashtra State Electricity Distribution
Co. Ltd as per the competitive tariff based mutually signed contractual agreement. In absence of the
said Power Purchase Agreement with the Maharashtra State Electricity Distribution Co. Ltd for the
proposed project activity, the project proponent would have generated power and sold it to other
authorities/ third party etc. The agreement with any other distribution authority would have also been
based on a similar competitive tariff based bidding process.
Even though there are other cost effective options (coal based subcritical power plant), yet the project
proponent decided to go for implementation of a supercritical coal based power plant. The tariff of
22
The Mundra UMPP was the first supercritical power plant based on 800 MW units
(http://www.ifc.org/ifcext/spiwebsite1.nsf/1ca07340e47a35cd85256efb00700cee/1584EA74DA3979AB85257
3A0006847BB), which was awarded in April 2007 (http://news.oneindia.in/2007/04/23/tata-power-takes-
over-mundra-umpp.html). The Sasan and Krishnapatnam UMPPs were awarded between May-October 2007
(http://www.business-standard.com/india/news/reliance-power-bags-krishnapatnam-umpp/29907/on. The
fourth UMPP at Tilaiya was to be awarded at a much later date in December 2008
(http://www.projectsmonitor.com/detailnews.asp?newsid=16355). All these projects are of a higher capacity
(4000 MW) as compared to the proposed project activity. All the UMPPs have been conceptualized with
CDM consideration (Page 7 of http://www.pfcindia.com/Tariff_Policy.pdf). The supercritical plant at North
Karanpura which is also of a higher capacity as compared to the proposed project activity, was also
conceptualized with CDM consideration.
(http://cdm.unfccc.int/methodologies/PAmethodologies/publicview.html?meth_ref=NM0217)
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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power generation from this power plant is also independent of the technology or investment chosen for
the power plant. The project proponent decided to go for the implementation of a coal based
supercritical power plant due to the reason that the flow of CDM revenue to the supercritical coal
based power plant would improve the cost effectiveness of the project activity and the energy efficient
supercritical power plant would contribute to the cause of mitigation of climate change.
The major milestones in the CDM chronology of the proposed project activity have been tabulated
below. The table demonstrates that the project proponent was well aware of the CDM modalities and
procedures before they decided to go ahead with the project activity and that CDM was the major
decisive factor for them to go ahead with the proposed project activity.
Sr. Subject / Activity Date Remark
No.
1 Email communications with CDM consultants 29.9.2007 Awareness of
CDM
05.10.2007
2 Information Memorandum by SBI Caps Nov-07
3 Proposal placed by Vineet Jain, for implementation of 07.02.2008 CDM
the project activity consideration
4 Approval for implementation of project activity by group 08.02.2008
Chairman
5 Email communications with CDM consultants for 20.2.2008
appointment
22.2.2008
6 EPC Contract with M/s. SCMEC for 2 x 660 MW coal 28.02.2008 Start date of
based Thermal Power Project on Super Critical project
Technology activity
7 Preparation of PDD Mar-Jun 2008
8 PPA Signed with MSEDCL 08.09.2008
9 Communications with validator for appointment 16.09.2008
10 Presentation to DNA (Ministry of Environment & 17.11.2008
Forests, Govt of India)
11 Validator appointment 28.11.2008
12 Webhosting 01 Jan-30 Jan 2009
13 Receipt of Host Country Approval 17.04.2009
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Baseline Emissions
Baseline emissions are calculated by multiplying the electricity generated in the project plant (EGPJ,y)
with a baseline CO2 emission factor (EFBL,CO2,y), as follows:
BE y = EG PJ , y xEFBL ,CO 2 , y
Where:
EFBL,CO2 is determined using the lower value between the emission factor of the technology and fuel
type that has been identified as the most likely baseline scenario and a benchmark emission factor
determined based on the performance of the top 15% power plants that use the same fuel as the project
plant and any technology available in the geographical area as defined in Step 2 below.
To calculate EFBL,CO2,y the lowest value among the following two options will be used.
Option 1: The emission factor of the technology and fuel identified as the most likely baseline scenario
under “Identification of the baseline scenario” section above, and calculated as follows:
Where:
EFBL,CO2,y Baseline emission factor in year y (tCO2/MWh)
EFFF,BL,CO2,y CO2 baseline emission factor of the baseline fossil fuel type that has been
identified as the most likely baseline scenario (tCO2 / Mass or volume unit)
EFFF,PJ,CO2,y Average CO2 emission factor of the fossil fuel type used in the project plant in
year y (tCO2 / Mass or volume unit)
ηBL Energy efficiency of the power generation technology that has been identified as
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Option 2: The average emissions intensity of all power plants j, corresponding to the power plants
whose performance is among the top 15 % of their category, as follows:
å FC
j
j,x * NCV j , x * EFCO 2, j , x
EFBL ,CO 2, y =
å EG
j
j,x
Where:
EFBL,CO2,y Baseline emission factor in year y (tCO2/MWh)
FCj,x Amount of fuel consumed by power plant j in year x (Mass or volume unit)
NCVj,x Net calorific value of the fossil fuel type consumed by power plant j in year x (GJ / Mass
or volume unit)
EFCO2,j,x CO2 emission factor of the fossil fuel type consumed by power plant j in year x (tCO2 /
Mass or volume unit)
EGj,x Net electricity generated and delivered to the grid by power plant j in year x
X Most recent year prior to the start of the project activity for which data is available
J Top 15% performing power plants (excluding cogeneration plants and including power
plants registered as CDM project activities), as identified below, among all power plants
in a defined geographical area (India) that have a similar size, are operated at similar
load (i.e. at base load) and use the same fuel type (coal) as the project activity
For determination of the top 15% performer power plants j, the following step-wise approach is used:
Step 1: Definition of similar plants to the project activity
The sample group of similar power plants should consist of all power plants (except for cogeneration
power plants):
• Those use the same fossil fuel type as the project activity, where fuel types are defined in the
following categories:
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-Coal
-Oils (e.g. diesel, kerosene, residual oil)
-Natural gas
• Those have been constructed in the previous five years;
• Those have a comparable size to the project activity, defined as the range from 50% to 150% of the
rated capacity of the project plant;
• Those are operated in the same load category, i.e. at peak load (defined as a load factor of less than
3,000 hours per year) or base load (defined as a load factor of more than 3,000 hours per year) as the
project activity; and
• Those have operated (supplied electricity to the grid) in the year prior to the start of the project
activity.
The sample group of plants identified consists of coal based sub-critical power plants that have a
capacity between 330MW to 990MW, have been constructed in last 5 years, operate at base load and
have supplied electricity to the grid before start of the proposed project activity.
Step 2: Definition of the geographical area
As per the methodology ACM0013, Version 02.1, the geographical area to identify similar power
plants is chosen in a manner that the total number of power plants “N” in the sample group comprises
at least 10 plants. As a default, the grid to which the project plant will be connected should be used.
As the number of similar plants, as defined in Step 1, within the Western regional grid boundary is
less than 10, the geographical area is extended to India. The number of similar plants is now greater
than 10.
Step 3: Identification of the sample group
Identify all power plants n that are to be included in the sample group. Determine the total number
“N” of all identified power plants that use the same fuel as the project plant and any technology
available within the geographical area, as defined in Step 2 above.
The sample group should also include all power plants within the geographical area registered as
CDM project activities, which meet the criteria defined in Step 1 above.
Step 4: Determination of the plant efficiencies
Calculate the operational efficiency of each power plant n identified in the previous step. The most
recent one-year data available is used. The operational efficiency of each power plant n in the sample
group is calculated as follows:
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EGn , x
h n ,x =
FC n , x * NCV n , x * 277.8
Where:
EGn,x Net electricity generated and delivered to the grid by the power plant n in the year x
(MWh)
FCn,x Quantity of fuel consumed in the power plant n in year x (Mass or volume unit)
NCVn,x Net calorific value of the fuel type fired in power plant n in year y (GJ / mass or volume
unit)n are all power plants in the defined geographical area that have a similar size, are
operated at similar load and use the same fuel types as the project activity
277.8 Conversion factor from TJ to MWh
x Most recent year prior to the start of the project activity for which data are available
Project emissions
The CO2 emissions from electricity generation in the proposed project activity (PEy) is calculated
using the latest approved version of the “Tool to calculate project or leakage CO2 emissions from
fossil fuel combustion” (Version 02, EB 41), where the process j in the tool corresponds to the
combustion of fossil fuels in the project plant. Here the process j corresponds to combustion of coal
for power generation using super-critical technology in the proposed project activity. As per this tool,
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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CO2 emissions from fossil fuel combustion in process j are calculated based on the quantity of fuels
combusted and the CO2 emission coefficient of those fuels, as follows:
PE FC , j , y = å FC i , j , y xCOEFi , y
i
Where:
PEFC,j,y CO2 emissions from fossil fuel combustion in process j during the year y (tCO2 / yr)
FCi,j,y Quantity of fuel type i combusted in process j during the year y (mass or volume unit /
yr);
COEFi,y CO2 emission coefficient of fuel type i in year y (tCO2 / mass or volume unit);
I Fuel types combusted in process j during the year y
The CO2 emission coefficient COEFi,y can be calculated following two procedures, depending on the
available data on the fossil fuel type i, as follows:
Option A: The CO2 emission coefficient COEFi,y is calculated based on the chemical composition of
the fossil fuel type i, or
Option B: The CO2 emission coefficient COEFi,y is calculated based on net calorific value and CO2
emission factor of the fuel type i.
Option A is followed here.
COEFi , y = wc,i , y x 44 / 12
Where:
COEFi,y CO2 emission coefficient of fuel type i in year y (tCO2 / mass or volume unit);
wc,i,y Weighted average mass fraction of carbon in fuel type i in year y (tC / mass unit of the
fuel)
i Fuel types combusted in process j during the year y
Note: For ex-ante calculation of emission reduction, the value of wc,i,y is estimated to be 0.416 or
41.6%. As this is a future project, hence the data sources (fuel supplier invoices or measurement by
project proponent) as mentioned in the “Tool to calculate project or leakage CO2 emissions from fossil
fuel combustion” (Version 02) are not applicable here. The value of 41.6% is an estimated value taken
from the technical specifications of the supply contract between the project proponent and SCMEC
(signed on 28th February 2008). The same will be monitored ex-poste as mentioned in section B.7.2 in
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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line with the “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion”
(Version 02).
Leakage
The methodology does not require the consideration of any leakage emissions.
LEy=0
LEy are the leakage emissions during the year y (tCO2e).
Emission reductions
Emission reductions (ERy) by the project activity during year y are the difference between the baseline
emissions (BEy), project emissions (PEy) and emissions due to leakage (LEy), and are expressed as
follows:
ERy = BEy − PEy − LEy……………………………………….. (15)
where:
ERy Emission reductions due to the project activity during the year y (tCO2e)
BEy Baseline emissions during the year y (tCO2e)
PEy Project emissions during the year y (tCO2e)
LEy Leakage emissions during the year y (tCO2e)
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page 35
Note: The parameters FCj,x, FCn,x, NCVj,x, NCVn,x, EGj,x and EGn,x are required to calculate the
baseline emission factor (as per Option 2). Since the baseline emission factor EFBL,CO2,y is calculated
and published by CEA, Govt of India, hence the parameters FCj,x, FCn,x, NCVj,x, NCVn,x, EGj,x and
EGn,x have not been included in this section of data and parameters available at validation.
CEA has publicly made available a document which says that the factor of 0.941 tCO2/MWh has been
calculated as per the methodology ACM0013, considering data upto 2007-08 and is applicable to new
coal fired power generating units with supercritical steam parameters. The same is available at:
http://www.cea.nic.in/planning/cdm.pdf
The detailed step wise procedure and calculation based on the methodology ACM0013 to calculate the
emission factor (of 0.941 tCO2/MWh) as per Option 2 can also be found in pages 20-26 of “CO2
Baseline Database for the Indian Power Sector, User Guide”, Version 4.0, October 2008 published by
Government of India, Ministry of Power, Central Electricity Authority (CEA) and publicly available
at: http://www.cea.nic.in/planning/c%20and%20e/user_guide_ver4.pdf
The list of power plants that are coal based sub-critical power plants with a capacity between 330MW
to 990MW, constructed in last 5 years, operating at base load and supplying electricity to the grid
before start of the proposed project activity have been included in the sample group.
Table 11: Power Plants included in the sample group
S. No. Name Unit No. Capacity Location Date of
Commissioning
1. TALCHER STPS 3 500 Orissa 4-Jan-03
2. TALCHER STPS 4 500 Orissa 25-Oct-03
3. TALCHER STPS 5 500 Orissa 13-May-04
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Baseline Emissions
Option 1 Option
2
Year PLF Auxiliary EGPJ,y EFFF,BL,CO2, EFFF,PJ,CO2,y ηBL EFBL,CO2,y EFBL,CO2 BEy
Consump y ,y
tion
% % MWh tCO2/GJ tCO2/GJ tCO2/M tCO2/M tCO2
Wh Wh
Sub- Coal used
bituminous in project
coal
Aug 85 7.50% 7197490 0.0961 0.0961 0.351 0.986 0.941 6772838
2011-Jul
2012
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2012-Jul
2013
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2013-Jul
2014
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2014-Jul
2015
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2015-Jul
2016
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2016-Jul
2017
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2017-Jul
2018
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2018-Jul
2019
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2019-Jul
2020
Aug 85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2020-Jul
2021
Total 83769310
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Project Emissions
Year Sub-Bituminous Coal FCi,i,y Wc,i,y PEy
required ton per MWh
ton/MWh ton %C tCO2
Aug 2011-Jul 2012 0.529 3807870 41.6 5808271
Aug 2012-Jul 2013 0.529 4809941 41.6 7336763
Aug 2013-Jul 2014 0.529 4809941 41.6 7336763
Aug 2014-Jul 2015 0.529 4809941 41.6 7336763
Aug 2015-Jul 2016 0.529 4809941 41.6 7336763
Aug 2016-Jul 2017 0.529 4809941 41.6 7336763
Aug 2017-Jul 2018 0.529 4809941 41.6 7336763
Aug 2018-Jul 2019 0.529 4809941 41.6 7336763
Aug 2019-Jul 2020 0.529 4809941 41.6 7336763
Aug 2020-Jul 2021 0.529 4809941 41.6 7336763
Total 47097337 71839138
page 39
B.7 Application of the monitoring methodology and description of the monitoring plan:
page 40
page 41
specifically for the CDM project, the metered fuel consumption quantities
would also be cross-checked with available purchase invoices from the
financial records.
Any comment: Total coal consumption will be monitored at project end and cross verified
with audited balance sheet.
page 42
B.8 Date of completion of the application of the baseline study and monitoring methodology
and the name of the responsible person(s)/entity(ies)
page 43
25 years 0 months
Not applicable.
Not applicable.
C.2.2.2. Length:
10 years 0 months
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A comprehensive study on the project’s positive and negative impacts on the local environment and on
society is thus a key element for each CDM project. Article 12 of the Kyoto Protocol requires that a
CDM project activity lead to the sustainable development of the host country. APML proposes to
implement the proposed project activity because of its commitment to ensure maximum global and
local benefits in relation to certain environmental and social issues and is a major step towards
sustainable development.
Assessment of Environmental Impact
The impact of the project on the environment can be seen broadly in two stages:
1. Construction phase
2. Operational phase
Impacts during construction phase
As the construction period is around three years whereas the lifetime of the power plant is around 25
years, so the impacts due to the construction activities are negligible. Associated activities would
cause air pollution which would be short-term and would cease to exist beyond the construction phase.
Impacts during operational phase
Since the operating technology is occurring at super-critical conditions, most of the GHGs emissions
are occurring due to the consumption of coal but if a sub-critical power plant of the same capacity had
been set up, then the coal consumption would have been higher resulting in more GHG emissions.
The nature of the impacts that are evident during the operational and maintenance phases are
discussed in the tables given below. All possible environmental aspects for the proposed project
activity have been identified and discussed for their impacts on the baseline environment (that prevails
before the proposed project activity is executed). The following table summarizes the environmental
scenario before the proposed project activity is executed, proposed project activity’s local and
environmental, social and other impacts, benefits and the mitigation measures taken by APML to
reduce/ minimize negative impacts if any and enhance the positive impacts.
Environment Impacts and Mitigation Measures
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D.2. If environmental impacts are considered significant by the project participants or the
host Party, please provide conclusions and all references to support documentation of an
environmental impact assessment undertaken in accordance with the procedures as required by
the host Party:
For the proposed project activity under consideration, the total investment is about INR 6560 crore.
As per Ministry of Environment and Forests Notification, New Delhi, 14th September, 2006, an
Environment Impact Assessment (EIA) study need not be done for a project activity if the investment
is less than INR 100 crore for new project and less than INR 50 crore for expansion / modernization
project23. Therefore, EIA is required for this proposed project activity. Accordingly, a separate
Environment Impact Assessment or EIA study had been developed for the proposed project activity.
The assessment of Environmental Impact for the proposed project activity has also been carried out as
required under Environmental (Protection) Act 1986, Government of India, mandatory for expansion
or modernization of any activity or for setting up new projects listed in Schedule I of the notification.
For the project activity under consideration, Environmental Clearance (EC) received from the Ministry
of Environment & Forest (MoEF), New Delhi for 2x660 MW Tirora Project vide their letter No.: J-
13011/4/2008-IA.II (T) dated 29.5.2008.
23
Source: EIA Notification Amendment dated June 13, 2002
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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E.1. Brief description how comments by local stakeholders have been invited and compiled:
Identification of Stakeholders
The proposed 660 x 2 MW super critical project will be implemented by APML. The project activity
will use more efficient technology for power generation in comparison to conventional sub critical
technology. The GHG emissions will be substantially less as compared to conventional technology
based power plant.
· Technical Consultants
· Employees of APML
Stakeholders list includes the government and non-government parties, which are involved in the
project activity at various stages. APML applied / communicated to the relevant stakeholders to get
the necessary clearances. APML had invited all the identified stakeholders for the meeting by sending
invitation letters well in advance. The invitation letter copy as well as the list to whom it had been sent
will be submitted to the DOE. The purpose of convening a local stakeholder meeting was to appraise
the stakeholders about the project activity and get their feedback on the same. The detailed report of
stakeholder consultation will be submitted to the DOE.
Stakeholders Involvement
APML has communicated to the relevant stakeholders about the project. As project activity is
environmental friendly which will lead to sustainable development of the local area. Since proposed
project activity does not involves any displacement of the local population which in turn has not
disturbed the local social structure but rather has helped in improving their quality of life.
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Several industries are stakeholders to the project. Project consultants were involved in the project to
take care of various pre-contract and post contract project activities like preparation of reports,
preparation of engineering documents, selection of vendors / suppliers and supervision of project
implementation.
Equipment suppliers will supply the equipments as per the specifications finalized for the project
activity and equipment supplier/APML are responsible for successful erection and commissioning of
the same at the site.
Stakeholders’ Comments
The comments from the local stakeholders have been taken in a very transparent way by the APML
and no adverse comments are being received from any stakeholders. Comments received from the
stakeholders are presented in tabulated format below.
page 49
E.3. Report on how due account was taken of any comments received:
APML has so far received only positive feedbacks on the project activity from all the stakeholders.
However stakeholder consultation is an on-going process and the project proponent will continue the
process. All the comments received, so far, have been considered and given due consideration while
preparing the CDM Project Design Document.
Furthermore, as per the requirement of UNFCCC, the CDM Project Design Document has been web-
hosted on the DOE’s (Designated Operational Entity) website for a period of one month for global
stakeholder consultation. The comments received by the Validator during the period of global
stakeholder consultation will be properly addressed as a part of CDM process.
PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03
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Annex 1
page 51
Annex 2
page 52
Annex 3
BASELINE INFORMATION
Table A1: Average station heat rate in Indian power plant as published by Central Electricity
Authority, Government of India
Baseline Emissions
Option 1 Option 2
Year PLF Auxiliary EGPJ,y EFFF,BL,CO2,y EFFF,PJ,CO2,y ηBL EFBL,CO2,y EFBL,CO2,y BEy
% Consumption MWh tCO2/GJ tCO2/GJ tCO2/MWh tCO2/MWh tCO2
IPCC value -
sub- IPCC value-
bituminous coal used in
% coal project
Aug 2011-Jul
85 7.50% 7197490 0.0961 0.0961 0.351 0.986 0.941 6772838
2012
Aug 2012-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2013
Aug 2013-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2014
Aug 2014-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2015
Aug 2015-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2016
Aug 2016-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2017
Aug 2017-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2018
Aug 2018-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2019
Aug 2019-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2020
Aug 2020-Jul
85 7.50% 9091566 0.0961 0.0961 0.351 0.986 0.941 8555164
2021
Total 83769310
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Annex 4
MONITORING INFORMATION
The operational and management structure that will monitor the project activity is described below.
Manager (Operations)
Shift Engineers
Operators
page 54