Voluntary Carbon Standard 2007 Validation Report Template

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VCS 2007 Validation Report Template Voluntary Carbon Standard 2007 Validation Report Template 19 November 2007 Validation Report: Name of Verification company: TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstrasse 199-80686 Munich - GERMANY Report Title: Validation Report for Sebenoba 30 MW Wind Farm in Turkey Date of the issue: 07/09/2010 Approved by: Certification Body Climate and Energy Client: Deniz Elektrik Üretim Ltd. Şti Project Title: Sebenoba 30 MW Wind Farm in Turkey Summary: The certification body Climate and Energy of TÜV SÜD Industrie Service GmbH has been ordered by Deniz Elektrik Üretim Ltd. Şti., 34212 Istanbul, Turkey, to perform the Upgrade Validation from the VER+ to VCS standard of the project Sebenoba 30 MW Wind Farm in Turkey in Turkey. The project Sebenoba 30MW Wind Farm in Turkey has been once 1

VCS 2007 Validation Report Template validated against the VER+ Standard and complies with the requirements of the Voluntary Carbon Standard (VCS) VCS 2007.1. The validation process of the above mentioned project was performed against the criteria set by Voluntary Carbon Standard 2007.1 and the approved consolidated UNFCCC CDM methodology ACM0002 version 06. The project also applies the UNFCCC CDM methodological tool Tool to calculate the emission factor for an electricity system version 01.1 and the Tool Tool for the demonstration and assessment of additionality version 05.2. During the validation process, TÜV SÜD issued several corrective action and clarification requests, which were addressed by the project owner Deniz Elektrik and the consultant FutureCamp. Additionally the assessment team reviewed the estimation of the projected emission reductions. In the validation report it is confirmed that the indicated amount of annual verified emission reductions of 60,669 tonnes CO 2,e represents a conservative estimation using the assumptions given by the project documents. For a 10-year crediting period, the emission reductions correspond to 606,690 tonnes CO 2, e. Work carried out by: Thomas Kleiser (Assessment Team Leader) - Dr. Nuri Mol (GHG-Auditor) -Georgios Agrafiotis (GHG-Trainee, Project Manager) * Team composition and appointments valid at the time of taking over the order to upgrade VER+ validation to VCS Number of pages: 10 Annex 1: Validation VCS protocol Annex 2: Information Reference List Annex 3: Validation report according to VER+ standard 2

VCS 2007 Validation Report Template Abbreviations ACM Approved Consolidated Methodology BM Build Margin CAR Corrective Action Request CDM Clean Development Mechanism CM Combined Margin CMP Conference of the Parties serving as the Meeting of the Parties to the Kyoto Protocol CO 2,e Carbon dioxide equivalent CR / CL Clarification Request DNA Designated National Authority DOE Designated Operational Entity DP Determination Protocol EF Emission Factor EIA / EA Environmental Impact Assessment / Environmental Assessment EPDK Energy Market Regulatory Authority (EMRA) ER Emission Reduction FAR Forward Action Request FSR Feasibility Study Report GHG Greenhouse Gas (es) GSP Global Stakeholder Process GWP Global Warming Potential IFPV Initial and First Periodic Verification IPCC Intergovernmental Panel on Climate Change IRL Information Reference List KP Kyoto Protocol MP Monitoring Plan MR Monitoring Report MoEF Ministry of Environment and Forestry NGO Non-Governmental Organisation OM Operational Margin PDD Project Design Document PMUM Energy Market Financial Settlement Department (linked with Grid operator TEIAS) PP Project Participant SCADA Supervisory Control and Data Acquisition TEIAS Turkish Electricity Transmission Company (Grid Operator) TÜV SÜD TÜV SÜD Industrie Service GmbH UNFCCC United Nations Framework Convention on Climate Change VER Voluntary Emission Reductions VCS Voluntary Carbon Standard VVM Validation and Verification Manual 3

VCS 2007 Validation Report Template [Table of Contents] 1. Introduction 5 1.1 Objective 5 1.2. Scope and Criteria 5 1.3. VCS Project Description 5 1.4. Level of Assurance 6 2. Methodology 6 2.1. Review of Document 7 2.2. Follow-up Interviews 7 2.3. Resolution of any material Disrcepancy 8 3. Validation Findings 8 3.1. Project Design 8 3.2. Baseline 8 3.3. Monitoring Plan 9 3.4. Calculation of GHG Emissions 9 3.5. Environmental Impact 9 3.6. Comments by Stakeholders 9 4. Validation Conclusion 9 5. Validation Signature 10 6. Independent Reviewer Signature 10 4

VCS 2007 Validation Report Template 1 Introduction 1.1 Objective Deniz Elektrik Üretim Ltd. Şti, ( Deniz Elektrik ) Istanbul, Turkey, has commissioned TÜV SÜD Industrie Service GmbH to validate the Sebenoba Wind Farm project located in Sebenoba, province Hatay, Turkey. The validation serves as design verification and is recommended for all VER projects. The validation objective is to have an independent Third Party assessment of the proposed project activity against all criteria of Voluntary Carbon Standard 2007.1 (VCS) and against the approved Clean Development (CDM) methodologies and tools set by UNFCCC. This validation report summarizes the findings of the validation. The VCS project activity was assessed against the CDM methodology ACM0002, version 06, Consolidated methodology for grid connected electricity generation from renewable sources The audit team was provided with the PDD in February 2010. The project activity discussed by this validation report has been submitted under the project title: Sebenoba 30 MW Wind Farm in Turkey 1.2 Scope and Criteria The validation is not meant to provide any consulting towards the client. However, stated requests for clarifications and/or corrective actions may provide input for improvement for the project design. Once TÜV SÜD receives a first PDD version, it is made publicly available on the internet at TÜV SÜD s web page for starting 30 day global stakeholder consultation process (GSP). In case of any request the PDD might be revised (under certain conditions the GSP will be repeated) and the final PDD will form the basis for the final evaluation as presented by this report. 1.3 VCS project Description The project site is situated near the village of Sebenoba on Yayladağı Mountains, District of Samandag, Province Hatay, Turkey. It consists of 15 class 1 VESTAS wind turbine units V80 OptiSpeed, each with 2.0 MW rated capacity, 80m rotor diameter and 67m hub height. The wind turbines/generators are connected to the wind farm substation through 20 kv underground cables. 5

VCS 2007 Validation Report Template Further, the voltage is raised to 154 kv and is transmitted to the Turkish public Grid via 154 kv Antakya III TM Station. The purpose of the project is to generate electricity from wind power and replace the fossil fuel power plants. By replacing fossil fuel power generation, the greenhouse gas emission in Turkey is reduced 1.4 Level of assurance Deniz Elektrik and TÜV SÜD have agreed on a reasonable level of assurance for the validation. TÜV SÜD has focused on means of appropriate methodologies for assessment of additionality, calculation of grid emission factors and the estimation of emission reductions. Based on the submitted documents, TÜV SÜD can provide a reasonable level of assurance. 2 Methodology The project activity has been assessed on a risk based approach. TÜV SÜD has developed a methodology specific validation protocol based on the templates in CDM Validation and Verification Manual ( VVM ). The protocol shows criteria (requirements), the discussion of each criterion by the assessment team and the results from validating the identified criteria. The protocol refers to: - Conformity of project activity and the PDD - Resolution of corrective action and clarification requests - Unresolved corrective action and clarification requests Appointment of the Assessment Team According to the technical scopes and experiences, TÜV SÜD has composed a project team in accordance with the appointment rules of TÜV SÜD certification body climate and energy. It is required that the sectoral scope linked with the methodology has to be covered by the assessment team. The validation team for this project activity was consisting of the following experts: Name Thomas Kleiser Qualificatio n Assessment Team Coverage of sectoral scope Coverage of technical area Host country experience 6

VCS 2007 Validation Report Template Dr. Nuri Mol Georgios Agrafiotis Leader GHG- Auditor GHG- Trainee Internal Quality Control As final step of validation, the validation report and the protocol have to follow an internal quality control procedure by the certification body climate and energy and each report has to be approved. 2.1 Review of Document A preliminary VCS PDD version submitted by the project participant and additional background documents related to the VCS PDD and the baseline were reviewed as initial step of the validation process. A complete list of all documents and proofs reviewed is attached as annex 3. 2.2 Follow-up Interviews TÜV SÜD has performed onsite interviews with project stakeholders to confirm selected information and to resolve issues identified in the first document review. The table below provides a list of all persons interviewed in the context of this onsite visit. Name Ahmet Hatipoğlu Sancar Saraçoğlu Ali Asaf Oğuz İsmail Yıldız Felix Nickel Organisation Project engineer, AKSA Enerji Üretim A.Ş., Istanbul Project engineer, AKSA Enerji Üretim A.Ş., Istanbul Project engineer, AKSA Enerji Üretim A.Ş., Istanbul Plant Operator, AKSA Enerji Üretim A.Ş., Istanbul Consultant, FutureCamp GmbH, Munich, Germany 7

VCS 2007 Validation Report Template 2.3 Resolution of any material discrepancy The objective of this phase of the validation is to resolve the requests for corrective actions and clarifications and any other outstanding issues which needed to be clarified for TÜV SÜD s positive conclusion on the project design. The comments and requests raised by TÜV SÜD during the onsite meeting were taken into account in the new VCS PDD version 01, dated January 11, 2007. To guarantee the transparency of the validation process, the remaining concerns raised and responses that have been given are summarised in chapter 3 below and documented in more detail in the validation protocol in Annex 3. 3 Validation Findings 3.1 Project Design The Sebenoba 30 MW Wind Farm in Turkey was assessed against the VCS 2007.1 criteria and relevant UNFCCC CDM methodologies and tools. The chosen 15 VESTAS V.80 2.0 MW turbine-generator units represent state of art technology. The project owner Deniz Elektrik has not registered the project in any other emission trading programme. The crediting period is set to 10 years, the start of the crediting period was March 26, 2008 and the end March 25, 2017. The project was designed based on the approved CDM methodology ACM0002, version 06. The project meets all eligibility criteria set by VCS 2007.1. 3.2 Baseline The baseline has been determined based on the approved baseline methodology ACM0002, version 06. The tool for the demonstration and assessment of additionality, version 5.2 and the Tool to calculate the emission factor for an electricity system, version 01.1. have been applied correctly. The relevant data was provided on the web pages of the Grid operator and the State Statistics Institute. 8

VCS 2007 Validation Report Template 3.3 Monitoring Plan The monitoring plan was set according to the approved Monitoring Methodology ACM0002, version 06, which is applicable for the renewable energy projects. Responsibilities regarding the implementation of the Monitoring Plan were described, the monitoring frequency, recording and back-up system were described transparently. Estimations of emission reduction data were calculated in a conservative manner. 3.4 Calculation of GHG Emissions The emissions reduction calculations were estimated by considering the correct balance equations. No project emissions and leakage were expected. The uncertainty was considered by choosing 1-σ approach. The emission reduction are conservative and in line with the approved methodology/tool. 3.5 Environmental Impact The environmental impact of the project has been evaluated in a prefeasibility assessment by the Ministry of Environment and Forestry. Based upon the conclusion, no EIA report was requested. The project meets all environmental requirements. 3.6 Comments by stakeholders TÜV SÜD has published the project documents on its own web page http://www.netinform.de/ke/wegweiser and invited comments by Parties, stakeholders and non-governmental organisations during a period of 30 days, starting by 28-11-2006. No comments were received. 9

VCS 2007 Validation Report Template 4 Validation conclusion TÜV SÜD has performed a validation of the following proposed VER project activity: Sebenoba 30 MW Wind Farm in Turkey. The review of the project design documentation and the subsequent follow-up interviews have provided TÜV SÜD with sufficient evidence to determine the fulfilment of the stated criteria. In our opinion, the project meets all relevant VCS 2007.1 criteria and UNFCCC requirements regarding the CDM methodologies / tools. It can be confirmed that the submitted project documentation is in line with all requirements of the Voluntary Carbon Standard VCS 2007.1. Therefore the certification body climate and energy within TÜV SÜD Industrie Service GmbH agrees registering the project as VCS project according to VCS 2007.1 and issuance of a certificate confirming this registration. An analysis as provided by the applied methodology demonstrates that the proposed project activity is not a likely baseline scenario. Emission reductions attributable to the project activity are hence additional to any that would occur in the absence of the VCS project activity. Given that the project is implemented as designed, the project is likely to achieve the estimated amount of emission reductions as specified within the final VCS PDD version. The validation is based on the information made available to TÜV SÜD and the engagement conditions detailed in this report. The validation has been performed using a risk based approach as described above. Munich, 07/09/2010 Munich, 07/09/2010 Certification body Climate and energy Rachel Zhang (Deputy Head) Assessment Team Leader Thomas Kleiser 10

VCS 2007 Validation Report Template Annex 1: Upgrade Validation Protocol according to VCS standard 11

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 1. Compliance Checklist VER+ / VCS CHECKLIST QUESTION Ref. MoV* COMMENTS A. Description of the Project A.1 Title of the project activity Does the used project title clearly enable to identify the unique VCS activity? A.2 Type or category of the project Which project category as part of a GHG program that has been approved by the VCS Board was chosen? Is it specified if the project is a grouped project? A.3 Estimated amount of emission reductions over the crediting period including project size Is it a: a) micro project (less than 5,000 tonnes CO2 equivalent emission reductions per year) or is it a b) mega project (more than 1,000,000 tonnes CO2 equivalent emission reductions per year)? A.4 Brief description of the project Is a brief project description included in the VCS PD A.5 Project location including geographic and physical information allowing the unique identification and delineation of the specific extent of the project. Are the project boundaries included in the document in form of GPS data? A.6. Duration of the project activity and crediting period a) Is the project starting date included in the document, which is defined as the date the Draft Concl Final Concl Included to regular VER+ checklist Included to regular VER+ checklist VCS specific The average annual emission reduction is estimated to 60,699 t CO 2, e. Therefore the category is a standard project. Included to regular VER+ checklist Included to regular VER+ checklist VCS specific Earliest starting date 1 st January 2002 1

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS project activity began reducing or re-moving GHG emissions? [VCS Policy Announcement 10.09.08] b) Is the crediting period starting date included means the date the first monitoring period commenced? (VCS project crediting period: A maximum of ten years which may be renewed at most two times.) Earliest crediting start 28 March 2006 (2 years max time for validations, see above) NOTE for early crediting: VCS 2007 validations shall be completed within two years of the project start date, or shall be completed or contracted before 19 November 2008. In relation to contracts entered into before 19 November 2008, validation shall be completed by 19 November 2009 and proof of contracting prior to 19 November 2008 shall be provided. Draft Concl Final Concl A.7 Conditions prior to project initiation Are the conditions before project start adequately described? A.8 A description of how the project will achieve GHG emission reductions and/or removal enhancements. Is it described adequately how the project will achieve GHG emission reductions and/or removal enhancements? A.9 Project technologies, products, services and the expected level of activity. Is a description of the used technologies and services as well as the expected products and the level of activity included to the document? A.10 Compliance with relevant local laws and regulations related to the project. The project is validated and registered as VER+ project on 24 April 2007. The start of crediting period is 26 March 2008, it will end in 25 th of March 2017. VCS specific / pot. included to regular VER+ checklist Clarification Request 1 Please provide a statement on conditions prior to project initiation. See IRL No. 41 and No.42 in Annex 2. CR1 IRL 41 IRL 42 Included to regular VER+ checklist Included to regular VER+ checklist 2

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS Does the VCS PD include identification of relevant local laws and regulations related to the project and demonstration of compliance with them? A.11 Identification of risks that may substantially affect the project s GHG emission reductions or removal enhancements. Are risks that may affect the project activity identified and explained in an adequate manner? A.12 Demonstration to confirm that the project was not implemented to create GHG emission reductions primarily for the purpose of its subsequent removal or destruction. Is it confirmed in the document that the project was not implemented to create GHG emission reductions primarily for the purpose of its subsequent removal or destruction? A.13 Demonstration that the project has not created another form of environmental credit (for example renewable energy certificates). If the project has created another form of environmental credit: Is a letter provided from the program operator that the credit has not VCS specific Clarification Request 2 Please provide the project introduction file PIF. VCS specific No plant-specific risks are defined, that may lead to a breakdown of the project activity. Circumstances like deteriorating weather conditions or wind capacity changes can be regarded as temporarily. Emissions Reductions calculations are done on the actually measured electricity data. The conservativeness of the ER calculations is assured. VCS specific The project is not implemented with this scope, the issue is not relevant for a wind power plant. VCS specific According to project owner s declaration, no other Draft Concl CR2 Final Concl IRL 41 IRL 42 3

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS been used and has been cancelled from the relevant program? A.14 Project rejected under other GHG programs (if applicable) Projects rejected by other GHG programs can be considered. If this is the case it shall be: a) clearly stated in the VCS PD: all GHG programs for which the project has applied for credits and why the project was rejected (no commercially sensitive information, see A.17). b) provision of the VCS verifier and registry with the actual rejection document(s) including explanation. c) If the project was validated against VCS program requirements. A.15 Project proponents roles and responsibilities including contact information of the project proponent, other project participants. Are project proponents roles and responsibilities (contact information and other participants) included in the document? A.16 Further Information Have information that are relevant for the eligibility of the project and quantification of emission reductions or removal enhancements, including legislative, technical, economic, sectoral, social, environmental, geographic, sitespecific and temporal information been included in the document. certificates are created for this project. For individual producers transfer to interconnected system not possible / no synchronised VCS specific The project is not rejected by other GHG programs. A switch from VER+ to VSC is voluntarily applied. No credits have been issued under VER+. VCS specific The project and project participants are identified, as confirmed in the PDD and the Validation Report. VCS specific The corresponding information has been included in the PDD and approved in the Validation Report. Draft Concl Final Concl 4

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS A.17 Commercially sensitive Information (if applicable) Is commercially sensitive information that has been excluded from the public version of the VCS PD (that will be displayed on the VCS Project Database) listed? B. VCS Methodology B.1 Title and references of the VCS methodology Is the right VCS program methodology named and an explanation given why this methodology was used? Are information given about methodology deviations or methodology revisions? B.2 Methodology justification Is a justification regarding the choice of the methodology and why it is applicable to the project activity included in the VCS PD? B.3 Identification of GHG sources Is sufficient information provided about GHG sources, sinks and reservoirs for the baseline scenario and for the project given? B.4 Description of how the baseline scenario is identified baseline scenario. Is a description of the most reasonable baseline scenario for the project given, that reflects what most likely would have occurred in the absence of the project? B.5 Description of how the emission of GHG by source in baseline scenario are reduced below those that would have occurred in the absence of the project activity (assessment VCS specific All necessary information has been included in the PDD, there is no separate PDD version for the public. VCS specific CDM methodologies have been used, e.g. ACM 0002, version 6, and corresponding Tools. There are no deviations from the methodology. Draft Concl Final Concl Included to regular VER+ checklist Included to regular /VER+ checklist Included to regular VER+ checklist 5

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS and demonstration of additionality) Is demonstrated that the project activity is additional based of one of the tests: a) the project test, b) the performance test c) technology test C. Monitoring C.1 Title and references of the VCS methodology (which includes the Monitoring requirements) applied to the project activity and explanation of the methodology choices. Are the title and the reference of the chosen VCS methodology listed? And is the choice of the methodology explained? C.2 Monitoring, including estimation, modeling, measurement or calculation approaches. Does the VCS PD include: a) the purpose of monitoring b) the types of data and information to be reported, including units of measurements c) origin of the data d) monitoring, including estimation, modeling, measurement or calculation approaches e) monitoring times and periods, considering the needs of intended users f) monitoring roles and responsibilities g) managing data quality C.3 Data and parameters monitored / selecting relevant GHG sources, sinks and reservoirs for monitoring or estimating GHG Included to regular VER+ checklist CDM additionality tool have been used. Draft Concl Final Concl Included to regular VER+ checklist Included to regular VER+ checklist 6

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS emissions and removals. Is the complete list of parameter based on the following table included into the VCS PD? Data / Parameter: Data unit: Description: Source of data to be used: Value of data applied for the purpose of calculating expected emission reductions Description of measurement methods and procedures to be applied: QA/QC procedures to be applied: Any comment: Draft Concl Final Concl Included to regular VER+ checklist C.4 Description of the monitoring plan Is the monitoring plan adequately described? Included to regular VER+ checklist D. GHG Emission Reductions D.1 Explanation of methodology choice Is the choice of the methodology adequately described? D.2 Quantifying GHG emissions and/or removals for the baseline scenario Are the data of expected GHG emissions and/or removals for the baseline scenario included? Are they correct? D.3 Quantifying GHG emissions and/or Included to regular VER+ checklist Included to regular VER+ checklist 7

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS removals for the project scenario Are the data of expected GHG emissions and/or removals for the project scenario included? Are they correct? Draft Concl Final Concl Included to regular VER+ checklist D.4 Quantifying GHG emission reductions and removal enhancements for the GHG project. Are the data of expected GHG emission reductions or removal enhancements included? Are they correct? Included to regular VER+ checklist Has ISO 14064-2 been used for quantifying GHG emission reductions or removal enhancements? 5.7 Quantifying GHG emissions and/or removals The project proponent shall select or establish criteria, procedures and/or methodologies for quantifying GHG emissions for selected GHG sources, sins and/or reservoirs (see 5.6). Based on selected or established criteria and procedures, the project proponent shall quantify GHG emissions and/or removals separately for a) Each relevant GHG for each GHG source, sink and/or reservoir relevant for the project, and b) Each GHG source, sink and/or reservoir relevant for the baseline scenario. When highly uncertain data and information are relied upon, the project proponent shall select assumptions and values that ensure that the quantification does not lead to over-estimation of GHG emissions reductions or removal 8

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS enhancements. The project proponent shall estimate GHG emissions and/or removals by GHG sources, sinks and reservoirs relevant for the project and relevant for the baseline scenario, but not selected for regular monitoring. The project proponent shall establish and apply criteria, procedures and methodologies to assess the risk of a reversal of a GHG emission reduction or removal enhancement (i.e. permanence of GHG emission reduction or removal enhancement). If applicable, the project proponent shall select or develop GHG emissions or removal factors that - are derived from a recognized origin - Are appropriate for the GHG source or sink concerned - Are current at the time of the quantification - Take account of the quantification uncertainty and are calculated in a manner intended to yield accurate and reproducible results, and - Are consistent with the intended use of the GHG report. Draft Concl Final Concl E. Environmental impact Is a summary of the environmental impact Included to regular VER+ checklist assessment included in the document? If such an assessment is required by applicable legislation or regulation. F. Stakeholders comments Is a detailed summary of the relevant outcomes Included to regular VER+ checklist 9

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS from stakeholder consultations and mechanisms for ongoing communication included in the document? G. Schedule Is a chronological plan for the date of initiating project activities, date of terminating the project, frequency of monitoring and reporting and the project period, including relevant project activities in each step of the GHG project cycle included in the document? H. Ownership H.1 Proof of land title Is the proof of title been provided by one of the following: a) a legislative right b) a right under local common law c) ownership of plant, equipment and/or process generating the reductions/removals d) a contractual arrangement with the owner of the plant, equipment or process that grants all reductions/removals to be proponent H.2 Projects that reduce GHG emissions from activities that participate in an emission trading program (if applicable) Is, if applicable, a list included to the document that shows all project proponents of projects that reduce GHG emissions from activities that: a) are included in an emission trading program, or b) take place in a jurisdiction or sector in which binding limits are established on GHG emissions. VCS specific The project chronology has been described in the Electricity Generation License and the PDD, Section B and section C. See IRL No.3 and IRL No.8 VCS specific Following permits have been submitted : - Electricity Generation License (by EPDK) - Trade Registry Certificate of the Project Owner - Grid connection and usage agreement - Supply contract with VESTAS (IRL No.4, IRL No. 29 ) VCS specific The project owner has given a statement, that he is not involved in other programs. There is no cap&trade program in Turkey. Draft Concl Final Concl IRL 3 IRL 8 10

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 CHECKLIST QUESTION Ref. MoV* COMMENTS Is, if applicable, evidence that reductions or removals generated by the project have or will not be used in the program or jurisdiction for the purpose of demonstrating compliance included? If yes, does evidence include: a) a letter from the program operator or designated national authority that emissions allowances (or other GHG credits used in the program) equivalent to the reductions/removals generated by the project have been cancelled from the program, or national cap as applicable or; b) purchase and cancellation of the GHG allowances equivalent to the reductions/removals generated by the project related to the program or national cap. VCS specific Not relevant VCS specific Not relevant Draft Concl Final Concl 2. Compilation and Resolutions of CARs, CRs and FARs Corrective Action Requests by audit team Comments and Results Ref Concl usion and IRL 11

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 Corrective Action Requests by audit team Issue Corrective Action Request No.1. Response n.a. Assessment n.a. Clarification Requests by audit team Comments and Results Ref Concl usion and IRL Issue Clarification Request 1 A.7. Response Please provide a statement on conditions prior to project initiation (A.7) The project description is structure in accordance with the official CDM methodology ACM0002. This methodology assumes that the baseline of renewable electricity projects connected to the grid, i.e. the situation without such a project, is the generation of an accordant amount of electricity by the power plants connected to the grid. The PDD thus contains the following relevant issues with respect to the situation prior to or without project initiation: Section B4: Prevailing Practice The PDD describes the fact that existing wind licenses remain unused and that only five projects with an overall installed capacity of 50.1 MW, one of them also a VER project, have been implemented. Section B4: Development of electricity demand and supply: The PDD describes the situation in Turkey with respect to expected electricity shortage in the coming years. This shall show that the project is an important contribution to the urgently needed installation of new capacities. Section B6.1: Electricity Generation Mix in Turkey The PDD provides a detailed derivation of the carbon intensity of the grid electricity mix in Turkey without the project IRL 41 IRL42 IRL 41 IRL 42 12

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 Corrective Action Requests by audit team With the above named issues, the situation and conditions before project initiation seem to be adequately described. Assessment The approved UNFCCC methodology ACM0002 considers also the baseline scenario without the implementation of the project. These issues have been described in the validated PDD v1 (dated : 11.01.2007), section B. Furthermore a summary on project history (PIF) gives an overview on the projects development. Further details can be found in the IRL No. 41 and IRL No. 42.The issue can be closed. Issue Clarification Request 2 Please provide the project introduction file PIF (A.10) Response The PDD does not contain a separate analysis of relevant laws and accordant compliance, as this is covered by the following documents, which the PDD refers to and which are available for validation and verification: Sebenoba Environmental Impact Study: The Study (IRL No. 8 from original validation) for the Sebenoba project, concluded in February 2005, contains a comprehensive project description, including relevant laws and regulations with respect to environment, land-use and labour. It serves as basis for applying for relevant licenses and permits. The main outcomes are the EIA not required certificate issued by the local environmental authority and the electricity generation license. The main underlying laws are the Environmental Law (Law No. 2872) and the Regulation on Environmental Impact Assessment (Gazette No. 25318) Electricity Generation License: A.10. IRL 41 IRL42 IRL 41 IRL 42 Assessment The fact that the project received the Electricity Generation License confirms that it complies with all relevant laws and regulations related to electricity generation and grid connection. The main relevant laws are the Electricity Market Law (Law No. 4628), the Law on Utilisation of Renewable Energy Resources for the Purpose of Generating Electricity (Law No. 5346) as well as several decrees issued by the Energy Market Regulation Authority (EMRA). The project is regarded like any other industrial project and has to follow the relevant legislation. Besides permission on civic works, various directives in regard with an energy plant have to be implemented before the issuance of the Electricity Generation License. These steps have been taken 13

Checklist of the Voluntary Carbon Standard Date of Completion: 07 September 2010 Number of Pages:14 Corrective Action Requests by audit team by the project participant. The issue can be closed. Forward Action Requests by audit team Comments and Results Ref Concl usion and IRL Issue Forward Action Request No. 1 Response Assessment n.a. n.a. VCS 2007 validations shall be completed within two years of the project start date, or shall be completed or contracted before 19 November 2008. In relation to contracts entered into before 19 November 2008, validation shall be completed by 19 November 2009 and proof of contracting prior to 19 November 2008 shall be provided. 14

VCS 2007 Validation Report Template Annex 2: Information Reference List 12

Final Report 2010-09-07 Verification of the Sebenoba 30 MW Wind Farm Project Turkey Information Reference List Page 1 of 4 Ref. No. 1. 2. 3. 4. 5. Issuance and/or submission date(dd/mm/yyyy) 19.05.2006 Title/Type of Document Approved Consolidated Baseline Methodology for grid connected electricity generation from renewable sources ACM0002, version 06 Author/Editor/ Issuer UNFCCC homepage http://cdm.unfccc.int 18.11.2008 Voluntary Carbon Standard 2007.1 VCS Organisation 09.01.2007 PDD Sebenoba 30 MW Wind Farm Project, version 1 FutureCamp 24.04.2007 Validation Report Sebenoba 30 MW Wind Farm Project final versiop TÜV SÜD 22.03.2010 Monitoring Report, v1.2, First Verification : 26/03/2008-31/12/2009 FutureCamp Additional Information (Relevance in CDM Context) 6. 01.02.2010 Excel Workbook on ER calculations FutureCamp 7. June 2005 Micrositing Report 8. 9. 04.06.2004 03.05.2007 Electricity Generation License issued for Deniz Elektrik Üretim Ltd. Şti. for a total capacity of 30 MW : 20 a 1.5 MW WTG units Electricity Generation License, revised at constant total capacity of 30 MW : 15 a 2.0 MW WTG units Dr. Ferdi Türksoy et al. EPDK (EMRA) EPDK (EMRA) 10. 26.04.2007 Geographic Map with position of the WTG units and GPS coordinates Deniz Elektrik 11. 12. 17.03.2009 Trade Registry of the project owner Deniz Elektrik Ltd. Şti. 14.03.2008 Preliminary Operation Permission for the 30MW Sebenoba Wind Farm : WTG units 2 to 15 13. 27.05.2009 Connection and Operation Permission for WTG unit 1 TEIAS 14. 20.07.2007 Grid connection Agreement TEIAS Istanbul Chamber of Trade Ministry of Energy Natural Resources www.epdk.gov.tr www.epdk.gov.tr last revision on 09.09.2009 15. 26.03.2008 Grid usage Agreement TEIAS TÜV SÜD INDUSTRIE SERVICE GMBH

Final Report 2010-09-07 Verification of the Sebenoba 30 MW Wind Farm Project Turkey Information Reference List Page 2 of 4 Ref. No. Issuance and/or submission date(dd/mm/yyyy) Title/Type of Document Author/Editor/ Issuer Additional Information (Relevance in CDM Context) 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 04.09.2007 15.01.2004 SINGLE LINE Diagram indicating the meters and connections to 154 kv Antakya III 154 kv TM station VESTAS V80-2.0 OptiSpeed Wind Turbine : Technical Description Manual Deniz Elektrik VESTAS 22.03.2003 Directive on Meter Usage in Electricity Generation Facilities EPDK (EMRA) 19.11.2007 Test Certificate for Main meter No. 360 83 054, Calibration Report TEIAS 19.11.2007 Test Certificate for Backup meter No. 360 83 055, Calibration Report TEIAS 27.02.2008 First Index Reading Protocol of Meters at Startup Test phase TEIAS 26.03.2008 12.06.2009 12.06.2009 15.04.2008 to 15.05.2009 15.04.2008 to 15.05.2009 First Index Reading Protocol of Meters with invoiced electricity supply to the Grid Begin of the Crediting Period Manual meter data reading and recording Excel spreadsheets (Logbook with daily manual meter readings and other relevant data, e.g. hourly plant load data) Monthly TEIAS meter data protocol on electricity supplied to the Grid and purchased from the Grid Final monthly PMUM meter data issued by PMUM considering net electricity supply to the Grid and Grid losses Final data for invoice Monthly invoices issued to TEIAS for the electricity amount supplied to the grid (as fixed in the PMUM data) TEIAS Deniz TEIAS, Deniz PMUM, TEIAS Deniz 2008 and 2009 Monthly SCADA data records on energy generation for each WTG unit VESTAS www.epdk.gov.tr TÜV SÜD INDUSTRIE SERVICE GMBH

Final Report 2010-09-07 Verification of the Sebenoba 30 MW Wind Farm Project Turkey Information Reference List Page 3 of 4 Ref. No. Issuance and/or submission date(dd/mm/yyyy) 28. 2008 and2009 29. 30. Title/Type of Document SCADA Wind Farm Performance Report Samples (Availability, Error logbook) Author/Editor/ Issuer VESTAS April 2008 Service and Maintenance Agreement regarding WTG units VESTAS 2010 Organisation Chart Plant Management Deniz Additional Information (Relevance in CDM Context) 31. 32. 33. 34. 35. 36. various dates 2008 and 2009 Training and Qualification Certificates for Sebenoba Wind Farm staff HighVoltage Operator, Security Staff Official payroll and labour documents for Sebenoba 30MW Wind Farm staff Various entities 04.02.2010 List of VESTAS Technical Staff reserved for Maintenance Works onsite VESTAS 16.06.2009 Invoice on transport of the sewage out of the wastewater septic tank 17/03/2008 Installation and Warranty for 44 kva Diesel Gen-Set AKSA SGK Fatmaoğulları Nakliye 07.04.2007 Technical Document on Transformator unit onsite BEST Cross check / NM 37. 18.07.2009 General Plant Operation and Management Procedure (OP) Including short remarks on data management 38. 19.02.2010 Pictures shot onsite Utility, metering devices TÜV SÜD CMS 39. 12/06/2009 On-site interviews conducted by TÜV SÜD. Verification Team: Dr. Nuri MOL TÜV SÜD CMS, GHG Auditor Interviewed People onsite : Asaf Oğuz Deniz Elektrik, Operation Manager Ismail Yıldız Deniz Elektrik, Plant Operator Deniz TÜV SÜD TÜV SÜD INDUSTRIE SERVICE GMBH

Final Report 2010-09-07 Verification of the Sebenoba 30 MW Wind Farm Project Turkey Information Reference List Page 4 of 4 Ref. No. Issuance and/or submission date(dd/mm/yyyy) Title/Type of Document Levent Benli Deniz Elektrik, Plant Manager Feliz Nickel FutureCamp Ramazan Aslan FutureCamp Author/Editor/ Issuer Additional Information (Relevance in CDM Context) Abbreviations: TEIAS Public Grid operator, Turkey PMUM Energy Market Finance Settlement Department EPDK Energy Market Regulatory Authority Deniz Deniz Elektrik Üretim Ltd. Şti. VCS Voluntary Carbon Standard Ltd Şti Ltd TÜV SÜD TÜV SÜD Industrie Service GmbH SGK State Social Insurance Entity 40. 12.06.2009 Participants list of the Onsite Assessment TÜV SÜD 41. 19.02.2010 Baseline consideration prior to the project and legislative issues FutureCamp 42. 19.02.2010 Project history description FutureCamp TÜV SÜD INDUSTRIE SERVICE GMBH

VCS 2007 Validation Report Template Annex 3: Validation report according to VER+ standard 13

Validation Report Deniz Elektrik Üretim Ltd. VALIDATION OF THE VER-PROJECT: TSEBENOBA 30 MW WIND FARM IN TURKEY REPORT NO. 909 971 2007, April 24 TÜV SÜD Industrie Service GmbH Carbon Management Service Westendstr. 199-80686 Munich GERMANY

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 1 of 11 Report No. Date of first issue Revision No. Date of this revision Certificate No. 909 971 2007-02-21 01 2007-04-23 - Subject: Validation of a CDM Project Accredited TÜV SÜD Unit: TÜV SÜD Industrie Service GmbH Certification Body climate and energy Westendstr. 199-80686 Munich Federal Republic of Germany Client: Deniz Elektrik Üretim Ltd. Gülbahar Caddesi 1. Sokak, 34212 Istanbul Turkey Project Title: Sebenoba 30 MW Wind Farm in Turkey TÜV SÜD Contract Partner: TÜV SÜD / Türkiye Istanbul, Turkey Project Site(s): Sebenoba Wind Farm, Sebenoba Gözene -Yayladağ, District of Samandağ, Province of Hatay, Turkey Applied Methodology / Version: ACM0002 version 6 Scope(s): 1 (Energy industries) First PDD Version: Date of issuance: 2006-10-27 Version No.: 00 Starting Date of GSP 2006-11-28 Estimated Annual Emission Reduction: Assessment Team Leader: Klaus Nürnberger Summary of the Validation Opinion: Final PDD version: Date of issuance: 2007-01-11 Version No.: 01 60,669 tons COB2eB Further Assessment Team Members: Dr. Thyge Weller Dr. Nuri Mol The review of the project design documentation and the subsequent follow-up interviews have provided TÜV SÜD with sufficient evidence to determine the fulfilment of all stated criteria. In our opinion, the project meets all relevant UNFCCC requirements for the CDM. It can be confirmed that the submitted project documentation is in line with all requirements of TÜV SÜD Standard GHG 027. Therefore the Certification Body Climate and Energy within TÜV SÜD Industrie Service GmbH registers this project as VER project according to TÜV SÜD Standard GHG 027 and issues a certificate confirming this registration. The review of the project design documentation and the subsequent follow-up interviews have not provided TÜV SÜD with sufficient evidence to determine the fulfilment of all stated criteria. Hence the requirements of TÜV SÜD Standard GHG 027 are not fulfilled and no certificate according to TÜV SÜD Standard GHG 027 will be issued by the Certification Body Climate and Energy within TÜV SÜD Industrie Service GmbH.

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 2 of 11 Abbreviations ACM AM BM CAR CDM CER CR DNA DOE EB EIA / EA ER GHG GSP KP MOEF MP NGO PDD PP SCADA TEIAŞ TÜV SÜD UNFCCC VER VVM Approved Consolidated Methodology Approved Methodology Build Margin Corrective Action Request Clean Development Mechanism Certified Emission Reduction Clarification Request Designated National Authority Designated Operational Entity Executive Board Environmental Impact Assessment / Environmental Assessment Emission reduction Greenhouse gas(es) Global Stakeholder consultation Process Kyoto Protocol (Turkish) Ministry of Environment and Forestry Monitoring Plan Non Governmental Organisation Project Design Document Project Participant Supervisory Control And Data Acquisition Türkiye Elektrik İletim A.Ş. TÜV SÜD Industrie Service GmbH United Nations Framework Convention on Climate Change Verified Emission Reduction Validation and Verification Manual

TU1UT TUINTRODUCTIONUT...4 TU2UT TUMETHODOLOGYUT TU3UT TUSUMMARY TU4UT TUCOMMENTS TU5UT TUVALIDATION Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 3 of 11 Table of Contents Page TU1.1UT TUObjectiveUT 4 TU1.2UT TUScopeUT 4...5 TU2.1UT TUAppointment of the Assessment TeamUT 6 TU2.2UT TUReview of DocumentsUT 7 TU2.3UT TUFollow-up InterviewsUT 7 TU2.4UT TUResolution of Clarification and Corrective Action RequestsUT 8 TU2.5UT TUInternal Quality ControlUT 8 OF FINDINGSUT...9 BY PARTIES, STAKEHOLDERS AND NGOSUT...10 OPINIONUT...11 Annex 1: Validation Protocol Annex 2: Information Reference List

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 4 of 11 1 INTRODUCTION 1.1 Objective Deniz Elektrik Üretim Ltd., Istanbul, Turkey, has commissioned TÜV SÜD Industrie Service GmbH to validate the Sebenoba Wind Power Plant Project. The validation serves as design verification and is recommended for all VER-projects. Beyond the requirements for VER-projects Deniz Elektrik Üretim Ltd. requested the project to be validated against the full requirements of CDM projects. The validation objective is to have an independent Third Party assess the proposed project activity against all defined criteria of TÜV SÜD Standard GHG 027 based on the criteria set for the registration under the Clean Development Mechanism (CDM). This validation is seen as necessary to provide assurance to stakeholders of the quality of the project and its intended generation of verified emission reductions (VERs). If the general framework changes accordingly in the future a validation of the project as a JI or CDM project activity is planned. This validation is seen as the basis for the full JI / CDM validation which will then be required. The project activity discussed by this validation report has been submitted under the project title: Sebenoba 30 MW Wind Farm in Turkey 1.2 Scope The scope of any assessment is defined by the underlying legislation, regulation and guidance given by relevant entities or authorities. In the case of the project activity the scope is set by: TÜV SÜD Standard GHG 027 Decision 2/CMP1 and Decision 3/CMP.1 (Marrakech Accords) Further COP/MOP decisions with reference to the CDM (e.g. decisions 4 8/CMP.1) Decisions by the EB published under http://cdm.unfccc.int Specific guidance by the EB published under http://cdm.unfccc.int Guidelines for Completing the Project Design Document (CDM-PDD) The applied approved methodology (ACM 0002) The technical environment of the project (technical scope) Internal and national standards on monitoring and QA/QC Technical guideline and information on best practice The validation is not meant to provide any consulting towards the client. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the project design. Once TÜV SÜD receives a first PDD version, it is made publicly available on the internet at TÜV SÜD s webpage for starting a 30 day global stakeholder consultation process (GSP). In case of any request a PDD might be revised (under certain conditions the GSP will be repeated) and the final PDD will form the basis for the final evaluation as presented by this report. Information on the first and on the final PDD version is presented at page 1.

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 5 of 11 2 METHODOLOGY The project assessment aims at being a risk based approach and is based on the methodology developed in the Validation and Verification Manual (for further information see HTUwww.vvmanual.infoUTH), an initiative of Designated and Applicant Entities, which aims to harmonize the approach and quality of all such assessments. TIn order to ensure transparency, a validation protocol was customised for the project. TÜV SÜD developed a cook-book for methodology-specific checklists and protocol based on the templates presented by the Validation and Verification Manual. The protocol shows, in a transparent manner, criteria (requirements), the discussion of each criterion by the assessment team and the results from validating the identified criteria. The validation protocol serves the following purposes: It organises, details and clarifies the requirements a CDM project is expected to meet; It ensures a transparent validation process where the validator will document how a particular requirement has been validated and the result of the validation. The validation protocol consists of three tables. The different columns in these tables are described in the figure below. The completed validation protocol is enclosed in Annex 1 to this report. Validation Protocol Table 1: Conformity of Project Activity and PDD Checklist Topic / Question Reference Comments PDD in GSP Final PDD The checklist is organised in sections following the arrangement of the applied PDD version. Each section is then further subdivided. The lowest level constitutes a checklist question / criterion. Gives reference to documents where the answer to the checklist question or item is found in case the comment refers to documents other than the PDD. The section is used to elaborate and discuss the checklist question and/or the conformance to the question. It is further used to explain the conclusions reached. In some cases sub-checklist are applied indicating yes/no decisions on the compliance with the stated criterion. Any Request has to be substantiated within this column Conclusions are presented based on the assessment of the first PDD version. This is either acceptable based on evidence provided (), or a Corrective Action Request (CAR) due to noncompliance with the checklist question (See below). Clarification Request (CR) is used when the validation team has identified a need for further clarification. Conclusions are presented in the same manner based on the assessment of the final PDD version.

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 6 of 11 Validation Protocol Table 2: Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests Ref. to table 1 Summary of project owner response Validation team conclusion If the conclusions from table 1 are either a Corrective Action Request or a Clarification Request, these should be listed in this section. Reference to the checklist question number in Table 1 where the Corrective Action Request or Clarification Request is explained. The responses given by the client or other project participants during the communications with the validation team should be summarised in this section. This section should summarise the validation team s responses and final conclusions. The conclusions should also be included in Table 1, under Final PDD. In case of a denial of the project activity more detailed information on this decision will be presented in table 3. Validation Protocol Table 3: Unresolved Corrective Action and Clarification Requests Clarifications and corrective action requests If the final conclusions from table 2 results in a denial the referenced request should be listed in this section. Id. of CAR/CR 1 Identifier of the Request. Explanation of the Conclusion for Denial This section should present a detail explanation, why the project is finally considered not to be in compliance with a criterion. 2.1 Appointment of the Assessment Team According to the technical scopes and experiences in the sectoral or national business environment TÜV SÜD has composed a project team in accordance with the appointment rules of the TÜV SÜD certification body climate and energy. The composition of an assessment team has to be approved by the Certification Body ensuring that the required skills are covered by the team. The Certification Body TÜV SÜD operates four qualification levels for team members that are assigned by formal appointment rules: Assessment Team Leader (ATL) Greenhouse Gas Auditor (GHG-A) Greenhouse Gas Auditor Trainee (T) Experts (E) It is required that the sectoral scope linked to the methodology has to be covered by the assessment team. The validation team was consisting of the following experts (the responsible Assessment Team Leader in written in bold letters):

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 7 of 11 Name Qualification Coverage of technical scope Coverage of sectoral expertise Klaus Nürnberger ATL Host country experience Dr. Thyge Weller GHG-A Dr. Nuri Mol E Klaus Nürnberger is head of the division energy certification at TÜV SÜD Industrie Service GmbH. In his position he is responsible for the implementation of verification and certifications processes for electricity production based on renewable sources. The division has assessed more than 600 plants and sites all over Europe. He has received extensive training in the CDM and JI validation processes and participated in many CDM and JI project assessments. Dr. Thyge Weller is lead auditor of the division energy certification at TÜV Industrie Service GmbH TÜV SÜD Group. In his position he implements verification and certifications processes for electricity production based on renewable sources. Further on, he is responsible to develop new business opportunities related to renewable energies. His technical specialization is in wind energy, solar energy and hydropower. He has received extensive training in the CDM and JI validation processes and participated in several CDM and JI project assessments. Dr. Nuri Mol is a consultant in environmental and renewable energy issues. He is lead auditor for Quality and Environmental Management Systems and advices industry and municipalities in environmental protection technologies due to IPPC. He is associated with TÜV SÜD TGK Turkey and participated in various local projects. 2.2 Review of Documents TA preliminary PDD version (V.0, October 27,2006) submitted by the client and additional background documents related to the project design and baseline were reviewed as initial step of the validation process. A complete list of all documents and proofs reviewed is attached as annex 2 to this report. 2.3 Follow-up Interviews In the period of November 6 to 7, 2006 TÜV SÜD performed interviews on-site with project stakeholders to confirm selected information and to resolve issues identified in the first document review. The table below provides a list of all persons interviewed in the context of this on-site visit. Name Ahmet Hatipoglu Sancar Saraçoğlu Felix Nickel Organisation Project engineer, AKSA ENERJI URETIM A.S., Istanbul, Turkey Project engineer, AKSA ENERJI URETIM A.S., Istanbul, Turkey Consultant, Future Camp GmbH, Munich, Germany

T Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 8 of 11 Magda Kmiecik Consultant, Future Camp GmbH, Munich, Germany 2.4 Resolution of Clarification and Corrective Action Requests The objective of this phase of the validation is to resolve the requests for corrective actions and clarifications and any other outstanding issues which needed to be clarified for TÜV SÜD`s positive conclusion on the project design. The comments and requests raised by TÜV SÜD during the onsite meeting were immediately taken into account in a new PDD version (version 01) which was made available November 9, 2006 and which was the basis for the GSP. Some minor layout aspects of this PDD version were changed January 11, 2007; but as no content was changed the version number remained the same. To guarantee the transparency of the validation process, the remaining concerns raised and responses that have been given are summarised in chapter 3 below and documented in more detail in the validation protocol in annex 1. 2.5 Internal Quality Control As final step of a validation the validation report and the protocol have to undergo and internal quality control procedure by the Certification Body climate and energy, i.e. each report has to be approved either by the head of the certification body or his deputy. In case one of these two persons is part of the assessment team approval can only be given by the other one. It rests at the decision of TÜV SÜD s Certification Body whether a project has fulfilled all requirements or not.

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 9 of 11 3 SUMMARY OF FINDINGS As informed above all findings are summarized in table 2 of the attached validation protocol. In total the assessment team expressed only 1 Corrective Action Request. This fact is based on the aspect that many findings of the on-site visit were already considered in a the PDD version 01 which was the basis of the validation protocol. The finding in PDD version 01 was related to the scope and depth of the intended monitoring approach. A detailed monitoring plan should be set up and provided to the audit team latest at the time when the operation of the wind farm starts. Within the original documents and spreadsheets there have been some inconsistencies on figures and calculations delivering the result on the emission reduction estimation. Beyond that the estimate of the yearly wind power generation could not be considered conservative. These assumptions have been resolved in the GSP-version of the submitted documents. The given estimation is reproducible and substantiated by verified data and assumptions. Baseline determination and additionality are correctly discussed by the PDD. There is no concern on this discussion as the continuation of the current situation is obviously the most likely scenario as long as there are no legal constraints.

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey Page 10 of 11 4 COMMENTS BY PARTIES, STAKEHOLDERS AND NGOS TÜV SÜD published the project documents on its own TÜV SÜD website and invited comments by Parties, stakeholders and non-governmental organisations during a period of 30 days. No comments were received. The following table presents all key information on this process: webpage: HTUhttp://www.netinform.de/KE/Wegweiser/Guide2.aspx?ID=2343&Ebene1_ID=26&Ebene2_ID=698&mode=0UTH Starting date of the global stakeholder consultation process: 2006-11-28 Comment submitted by: Issues raised: - - Response by TÜV SÜD: -

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey TAnnex 1: Validation Protocol

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 Table 1 Conformity of Project Activity and PDD CHECKLIST TOPIC / QUESTION Ref. COMMENTS A. General description of project activity A.1. Title of the project activity A.1.1. A.1.2. A.1.3. Does the used project title clearly enable to identify the unique project activity? Is there any indication concerning the revision number and the date of the revision? Is this consistent with the time line of the project s history? A.2. Description of the project activity A.2.1. A.2.2. Is the description delivering a transparent overview of the project activities? What proofs are available demonstrating that the project description is in compliance with the actual situation or planning? 1,2, 20 1,2, 20 1,2, 20 The project title clearly enables the identification of the project activity. In the future there will be more wind farms in the area but they have / will have different names. It has to be noted that also in official documents instead of Sebenoba also the spelling Sabenoba or Sabenova is being used. The revision number and the date of the issuance of this revision is correctly indicated (version 1, Nov. 9, 2006). The given dates are in consistency with the time line of the project development. 2, 20 The description of the project activity delivers a transparent overview of the project activities. 2,3,4,5,8, 9,10, 14, 16, 17, 20 Relevant documents were presented and checked. They include: the production licence from EMRA statements of land ownership the EIA wind turbine purchase and delivery agreement the micrositing report of the wind farm the single line diagram of the electrical system of the wind farm PDD in GSP Final PDD Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-1

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 A.2.3. A.2.4. CHECKLIST TOPIC / QUESTION Is the information provided by these proofs consistent with the information provided by the PDD? Is all information presented consistent with details provided by further chapters of the PDD? A.3. Project participants A.3.1. A.3.2. A.3.3. Is the form required for the indication of project participants correctly applied? Is the participation of the listed entities or Parties confirmed by each one of them? Is all information on participants / Parties provided in consistency with details provided by further chapters of the PDD (in particular annex 1)? Ref. 1,2, 20 1,2, 20 COMMENTS The information provided by the PDD corresponds exactly with the information surveyed by the assessment team. Detail information as well as summaries are consistent throughout the PDD. PDD in GSP 2, 20 The project participant is clearly indicated. 1 The project is uni-lateral and therefore there is just one participant. He has been contacted directly. Participation has been confirmed. 1,2, 20 Instead of the project participant name (DENIZ ELEKTRIK ÜRE- TIM LTD) in some documents the name of the parent company AKSA Energy is mentioned. AKSA Energy owns 95% of the shares of DENIZ ELEKTRIK ÜRETIM. As there are no misunderstandings possible, this name use is accepted by the assessment team. Final PDD A.4. Technical description of the project activity A.4.1. A.4.1.1. A.4.1.2. Location of the project activity Does the information provided on the location of the project activity allow for a clear identification of the site(s)? How is it ensured and/or demonstrated, that the project proponents can implement the project at this site (ownership, licenses, contracts etc.)? 1,2, 20 In the PDD there is one overview map and one detail map which indicate clearly the position of the wind farm. The location of the individual turbines is indicated in the micrositing report. 9,10 The production licence by EMRA, the Turkish Energy Market Regulatory Authority, indicates clearly the site. The ground needed for the 15 turbines was private property for 12 turbines and public property for 3 turbines. The private land has been Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-2

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS bought from the owners (2.000 m2 per turbine) and according to Turkish laws it is now being transferred into the ownership of EMRA. The statements of land ownership were presented. PDD in GSP Final PDD A.4.2. A.4.2.1. Category(ies) of project activity To which category(ies) does the project activity belonging to? Is the category correctly identified and indicated? 1,2, 20 The project belongs to the category grid-connected renewable power generation project activities, sub-type wind sources. This is correctly identified and indicated. A.4.3. A.4.3.1. A.4.3.2. A.4.3.3. A.4.3.4. A.4.3.5. A.4.3.6. Technology to be employed by the project activity Does the technical design of the project activity reflect current good practices? Does the description of the technology to be applied provide sufficient and transparent input/ information to evaluate its impact on the greenhouse gas balance? Does the implementation of the project activity require any technology transfer from annex-i-countries to the host country(ies)? Is the technology implemented by the project activity environmentally safe? Is the information provided in compliance with actual situation or planning? Does the project use state of the art technology and / or does the technology result 2,4, 11, 20 2,3,4,11, 14, 20 1,2, 14, 20 1,2,8, 20 1,2, 20 1,2, 11, The project reflects a professional standard medium scale wind park as it can be found in many European countries (where in contrast to Turkey - appropriate support mechanisms guarantee the profitability of such projects). In Turkey, those wind farms are still very rare. The detailed data of the wind turbine, combined with the wind generation estimate, allow a reasonably solid estimation of the electricity production and thus the GHG reduction. The turbines are built in Denmark. There is some limited technology transfer effect by the maintenance activities which will be carried out after the warranty period by local specialists. Wind energy is a technology which is inherently safe from an environmental view. Also the EIA states that there are no environmental issues with the Sebenoba wind farm. The PDD reflects the actual situation correctly. The planned wind turbines are modern state-of-the-art turbines. In Turkey there are up to now very few wind turbines erected which Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-3

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 A.4.3.7. A.4.3.8. A.4.3.9. CHECKLIST TOPIC / QUESTION in a significantly better performance than any commonly used technologies in the host country? Is the project technology likely to be substituted by other or more efficient technologies within the project period? Does the project require extensive initial training and maintenance efforts in order to be carried out as scheduled during the project period? Is information available on the demand and requirements for training and maintenance? A.4.3.10. Is a schedule available for the implementation of the project and are there any risks for delays? A.4.4. A.4.4.1. A.4.4.2. A.4.5. A.4.5.1. Ref. COMMENTS 20 are all quite new and therefore comparable to the planned turbines. 1,2, 11, 20 1,2,5,14, 20 1,2,5,14, 20 Estimated amount of emission reductions over the chosen crediting period Is the form required for the indication of projected emission reductions correctly applied? Are the figures provided consistent with other data presented in the PDD? Public funding of the project activity Is the information provided on public funding provided in compliance with the actual PDD in GSP Final PDD It is not expected that today s highly efficient wind turbines will be substituted by better technologies within the project period. In the first two years the turbine manufacturer will be responsible for support and maintenance. Thereafter there will be a gradual phase-over between the turbine manufacturer and the wind farm operator. This includes training on-site and at the manufacturer s plant. Training for support and maintenance is already now being planned, even if it will be needed only after the 2 year s warranty period. 5 A detailed implementation schedule exists. At present, the project is on track. Unforeseen delays, however, cannot be excluded. For example, due to the high demand for wind turbines there is an increasing tendency of wind turbine producers to delay even confirmed shipments. 2, 20 The form has been correctly filled out. 2,4,6,20 The figures are consistent with the data in the PDD and in the supporting documents. 1 According to the information provided to the assessment team to public funding is involved in the financing of the project. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-4

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 A.4.5.2. CHECKLIST TOPIC / QUESTION situation or planning as available by the project participants? Is all information provided consistent with the details given in remaining chapters of the PDD (in particular annex 2)? Ref. 1,2, 20 B. Application of a baseline and monitoring methodology B.1. Title and reference of the approved baseline and monitoring methodology B.1.1. Are reference number, version number, and title of the baseline and monitoring methodology clearly indicated? B.1.2. Is the applied version the most recent one and / or is this version still applicable? COMMENTS PDD in GSP Final PDD Not applicable. 2, 20 Both methodologies (ACM 0002, version 06) are clearly indicated in section B.1 of the PDD. 2, 20 ACM 0002, version 06, is the most recent version. B.2. Justification of the choice of the methodology and why it is applicable to the project activity B.2.1. Is the applied methodology considered the most appropriate one? 1,2, 20 Even if the project will generate VERs, a CDM-methodology has been applied to be prepared for a time where a registration of Turkish projects as JI or CDM activity is possible. ACM0002 is the most appropriate CDM-methodology for gridconnected wind farms with a capacity of more than 15 MW. Fill in the required amount of sub checklists for applicability criteria as given by the methodology applied and comment at least every line answered with No B.2.2. Criterion 1: Type of capacity addition by renewable energy 2,7, 20 Applicability checklist / No Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-5

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS PDD in GSP Final PDD B.2.3. Criterion 2: Exclusion of fuel switching activities 2, 20 Applicability checklist / No Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? B.2.4. Criterion 3: Defined electricity grid boundaries 2, 20 Applicability checklist / No Criterion discussed in the PDD? Compliance provable? Evidences provided in the PDD? Compliance verified? B.2.5. Criterion 4: Approved inclusion in other methodologies (if applied only) - Not applicable n.a. n.a. B.3. Description of the sources and gases included in the project boundary Integrate the required amount of sub-checklists for sources and gases as given by the methodology applied and comment on at least every line answered with No B.3.1. Source: Fugitive Emissions from non-condensable gases (geothermal activities only) Gas(es): CO 2, CH 4 Type: Project Emissions - Not applicable. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-6

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 B.3.2. B.3.3. B.3.4. B.3.5. B.3.6. B.3.7. CHECKLIST TOPIC / QUESTION Source: Emissions from combustion of fossil fuels (geothermal activities only) Gas(es): CO 2 Type: Project Emissions Source: Emissions from the reservoir (new hydroelectric activities only) Gas(es): CO 2, CH 4 Type: Project Emissions Source: Emissions from electricity generation in fossil fuel fired power plants of the project electricity system Gas(es): CO 2 Type: Baseline Emissions Source: Emissions from electricity generation in fossil fuel fired power plants of any connected electricity system Gas(es): CO 2 Type: Baseline Emissions Source: Emissions from electricity generation in fossil fuel fired power plants of imported electricity Gas(es): CO 2 Type: Baseline Emissions Do the spatial and technological boundaries as verified on-site comply with the Ref. - Not applicable. - Not applicable. 1,2, 20 COMMENTS PDD in GSP Final PDD There are no fossil fuel fired power plants within the project electricity system. 1,2,7, 20 Boundary checklist / No Source and gas(es) discussed by the PDD? Inclusion / exclusion justified? Explanation / Justification sufficient? Consistency with monitoring plan? 2, 20 Imports are from connected electricity systems located in another country and their emission factor is set to 0 tons CO2 per MWh. 2,20 Spatial and technological boundaries comply with the statements in the PDD. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-7

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION discussion provided by the PDD? Ref. COMMENTS PDD in GSP Final PDD B.4. Description of how the baseline scenario is identified and description of the identified baseline scenario B.4.1. B.4.2. B.4.3. Is it clearly described that the baseline is represented by the combined margin of the grid the activity will be connected to? In case of any modification or retrofit of existing facilities: Is data available to determine the historic production level? In case of any modification or retrofit of existing facilities: Have conservative assumptions been applied in order to estimate the point in time when the existing equipment needs to be replaced? 2,20 It is made clear that the baseline is computed as a combined margin on the basis of the Turkish power grid. - Not applicable. - Not applicable. 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): B.5.1. B.5.2. B.5.3. In case of applying step 0 of the additionality tool: Is evidence provided, that the project s starting date is after Jan 01, 2000 and before Nov 18, 2004? In case of applying step 0 of the additionality tool: Is evidence provided, that CDM has been considered seriously in the decision to proceed with the project activity? Have realistic and credible alternatives been identified providing comparable out- - Not applicable. - Not applicable. 1,2, 20 The identified alternatives (proposed project not undertaken as a VER project activity; power supply provided by the grid) are realis- Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-8

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 B.5.4. B.5.5. B.5.6. B.5.7. B.5.8. B.5.9. B.5.10. B.5.11. CHECKLIST TOPIC / QUESTION puts or services? (step 1a) Is the project activity without CDM included in these alternatives? (step 1a) Is a discussion provided for all identified alternatives concerning the compliance with applicable laws and regulations? (step 1b) In case the PDD argues that specific laws are not enforced in the country or region: Is evidence available concerning that statement? (step 1b) In case of applying step 2 / investment analysis of the additionality tool: Is the analysis method identified appropriately (step 2a)? In case of Option I (simple cost analysis): Is it demonstrated that the activity produces no economic benefits other than CDM income? In case of Option II (investment comparison analysis): Is the most suitable financial indicator clearly identified (IRR, NPV, cost benefit ratio, or (levelized) unit cost)? In case of Option III (benchmark analysis): Is the most suitable financial indicator clearly identified (IRR, NPV, cost benefit ratio, or (levelized) unit cost)? In case of Option II or Option III: Is the calculation of financial figures for this indi- Ref. tic and credible. COMMENTS PDD in GSP Final PDD 2,20, see B.5.3. 2,20 It is stated that both scenarios comply with applicable laws and regulations. 2,20 This argument is not used. 2,20 Investment analysis (step 2) is not used. - Not applicable. - Not applicable. - Not applicable. - Not applicable. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-9

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 B.5.12. B.5.13. B.5.14. CHECKLIST TOPIC / QUESTION cator correctly done for all alternatives and the project activity? In case of Option II or Option III: Is the analysis presented in a transparent manner including publicly available proofs for the utilized data? In case of applying step 3 (barrier analysis) of the additionality tool: Is a complete list of barriers developed that prevent the different alternatives to occur? In case of applying step 3 (barrier analysis): Is transparent and documented evidence provided on the existence and significance of these barriers? Ref. - Not applicable. COMMENTS 2,20 Barriers due to prevailing practice as well as Investment barriers have been described. This list can be considered to be complete. 1,2, 20 The prevailing-practice-barrier was clearly demonstrated: Sebenoba is as large as today s largest wind farm in Turkey, Bares II, which is also a VER-project. There are no wind farms without VER-support. PDD in GSP Final PDD B.5.15. In case of applying step 3 (barrier analysis): Is it transparently shown that the execution of at least one of the alternatives is not prevented by the identified barriers? B.5.16. Have other activities in the host country / region similar to the project activity been identified and are these activities appropriately analyzed by the PDD (step 4a)? B.5.17. If similar activities are occurring: Is it demonstrated that in spite of these similarities the project activity would not be implemented without the CDM component (step 4b)? Also investment barriers are clearly demonstrated in detail. 2,20, power supply provided by the grid is not prevented by those barriers. 2,20, the financing of other wind farms has been analysed; see point B.5.14. 2,20, this is proven by the fact that the other wind farms have applied / will apply also for VER-support. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-10

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 B.5.18. CHECKLIST TOPIC / QUESTION Is it appropriately explained how the approval of the project activity will help to overcome the economic and financial hurdles or other identified barriers (step 5)? Ref. 2,6, 20 COMMENTS The impact of VER registration is presented in detail. It is demonstrated that the IRR without VER-income is very low (with conservative assumptions on a 10-years basis even below zero) and that the VER income is a decisive instrument to achieve at least very modest profits. PDD in GSP Final PDD B.6. Emissions reductions B.6.1. Explanation of methodological choices B.6.1.1. B.6.1.2. B.6.1.3. B.6.1.4. B.6.1.5. Is it explained how the procedures provided in the methodology are applied by the proposed project activity? Is every selection of options offered by the methodology correctly justified and is this justification in line with the situation verified on-site? Are the formulae required for the determination of project emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? Are the formulae required for the determination of baseline emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? Is the choice of options to determine the emissions factor (OM, BM) justified in a 2,20 The emission reduction is explained step by step in the PDD, following the ACM0002 methodology. 2,20 Every option is justified. During the on site visit it could be checked that the best available data have been used. As no plantspecific data are available, calculations for the combined margin were based on aggregated generation and fuel consumption data (corresponding to option 4 in footnote 4 in the baseline-section of ACM0002). Those data were taken from an official source (Statistical Yearbook of Turkey). 2,20 There are no project emissions. 2,20 The formulae to calculate the baseline emissions have been correctly and completely presented. They are based on the use of aggregated generation and fuel consumption data. 2,6, 20 To determine the OM the ex-ante approach of option a (Simple Operating Margin) has been chosen. This is justified in detail. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-11

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION suitable and transparent manner? Ref. COMMENTS To determine the BM option 1 (ex-ante approach) has been applied, using the capacity additions of those 129 power plants which comprise 20% of the system generation in 2005 and have been built most recently. All choices of options have been justified in detail. PDD in GSP Final PDD B.6.1.6. B.6.1.7. B.6.1.8. B.6.1.9. In case of alternative weighing factors for the Combined Margin: Is the quantification of the alternative weighing factor justified in a suitable and transparent manner? In case of alternative weighing factors for the Combined Margin: Is the guidance for the PDD concerning the acceptability of alternative weights considered in the discussion? Are the formulae required for the determination of leakage emissions correctly presented, enabling a complete identification of parameter to be used and / or monitored? Are formulae required for the determination of emission reductions correctly presented? B.6.2. Data and parameters that are available at validation B.6.2.1. Is the list of parameters presented in chapter B.6.2 considered to be complete 2,20 No alternative weighing factor has been used. According to ACM0002 the default weights for wind parks w OM = 0.75 and w BM = 0.25 are used. 2,20 No alternative weighing factor has been used 2,20 As there is no leakage no formulae are used. 2,20 The project proponents decided to use the net energy production (energy which is fed into the grid minus energy which is taken from the grid in times where the wind farm does not produce enough energy to cover its auxiliary demand). Therefore no project emissions have to be taken into account for the externally provided auxiliary energy. 2,20 The list of parameters is complete under the chosen options (in particular calculation of the combined margin based on aggre- Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-12

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS with regard to the requirements of the applied methodology? gated generation and fuel consumption data) B.6.2.2. Is the choice of ex-ante or ex-post vintage of OM and BM factors clearly specified in the PDD? Fill in the required amount of sub checklists for monitoring parameter and comment any line answered with No B.6.2.3. B.6.2.4. Parameter Title: Annual electricity supplied to the grid prior to retrofit (applicable only for retrofit and modification activities) Parameter Title: Emission factor of the grid (CM) PDD in GSP Final PDD 2,20 The choice of the ex-ante-option is clearly specified. - Not applicable. 2,7, 20 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? B.6.2.5. Parameter Title: Operating margin (OM) emission factor of the grid 2,7, 20 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description? Source clearly referenced? Correct value provided? Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-13

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Has this value been verified? Choice of data correctly justified? Measurement method correctly described? PDD in GSP Final PDD B.6.2.6. Parameter Title: Build margin (BM) emission factor of the grid 2,7, 20 Data Checklist / No Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? B.6.2.7. Parameter Title: gross electricity production by fossil fuels 2,7, 20 Data Checklist / No Title in line with methodology? No Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? The parameter is not explicitly mentioned in the methodology; need for this parameter is a consequence of using aggregated production data. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-14

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS PDD in GSP Final PDD B.6.2.8. Parameter Title: relation gross / net electricity production 2,7, 20 Data Checklist / No Title in line with methodology? No Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? B.6.2.9. Parameter Title: CO2 emissions of net electricity production The parameter is not explicitly mentioned in the methodology; need for this parameter is a consequence of using aggregated production data. 2,7, 20 Data Checklist / No Title in line with methodology? No Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? B.6.2.10. Parameter Title: electricity imports The parameter is not explicitly mentioned in the methodology; need for this parameter is a consequence of using aggregated emission data. 2,7, 20 Data Checklist / No Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-15

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Title in line with methodology? Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? PDD in GSP Final PDD B.6.2.11. Parameter Title: capacity of each power source 2,7, 20 Data Checklist / No Title in line with methodology? No Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? B.6.2.12. Parameter Title: full-load-hours by energy source The parameter is not explicitly mentioned in the methodology; need for this parameter is a consequence of using aggregated production data. 2,7, 20 Data Checklist / No Title in line with methodology? No Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-16

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Has this value been verified? Choice of data correctly justified? Measurement method correctly described? PDD in GSP Final PDD B.6.2.13. Parameter Title: technology specific emission coefficient of plants The parameter is not explicitly mentioned in the methodology; need for this parameter is a consequence of using aggregated production data 2,7, 20 Data Checklist / No Title in line with methodology? No Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided? Has this value been verified? Choice of data correctly justified? Measurement method correctly described? B.6.2.14. Parameter Title: surface area of full reservoir level (for new hydroelectric activities only The parameter is not explicitly mentioned in the methodology; need for this parameter is a consequence of using aggregated production data - Not applicable. B.6.3. Ex-ante calculation of emission reductions B.6.3.1. B.6.3.2. Is the projection based on the same procedures as used for future monitoring? Are the GHG calculations documented in a complete and transparent manner? 2, 20 The projection is done by the same algorithms as used for later monitoring. 2,20 The detailed calculation of operating margin and build margin up to the combined margin can be checked transparently in the Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-17

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 B.6.3.3. CHECKLIST TOPIC / QUESTION Is the data provided in this section consistent with data as presented in other chapters of the PDD? Ref. B.6.4. Summary of the ex-ante estimation of emission reductions B.6.4.1. B.6.4.2. B.6.4.3. B.6.4.4. Will the project result in fewer GHG emissions than the baseline scenario? Is the form/table required for the indication of projected emission reductions correctly applied? Is the projection in line with the envisioned time schedule for the project s implementation and the indicated crediting period? Is the data provided in this section in consistency with data as presented in other chapters of the PDD? COMMENTS PDD, section B.6., and in Annex 3. 2,20 The estimated value of the wind farm production is consistently used throughout the PDD and attached documents. PDD in GSP 2,20 The project activity will result in emission reductions. 2,20 The form is correctly applied. 1,2,5, 20 The projection of emission reductions corresponds with the envisioned time schedule and the indicated crediting period. 2,20 The data are consistent with other data in the PDD and associated documents. B.7. Application of the monitoring methodology and description of the monitoring plan Final PDD B.7.1. Data and parameters monitored B.7.1.1. Is the list of parameters presented by chapter B.7.1 considered to be complete with regard to the requirements of the applied methodology? 1,2, 20 The list is complete.net electricity supplied to the grid is the only parameter required. Integrate the required amount of sub-checklists for monitoring parameter and comment on any line answered with No B.7.1.2. Parameter Title: Electricity supplied to the grid 2,20 Monitoring Checklist Title in line with methodology? / No See remark CAR #1 Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-18

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Ref. COMMENTS Data unit correctly expressed? Appropriate description of parameter? Source clearly referenced? Correct value provided for estimation? Has this value been verified? Measurement method correctly described? Correct reference to standards? Indication of accuracy provided? QA/QC procedures described? QA/QC procedures appropriate? No No Partial PDD in GSP Final PDD The PDD uses the term net electricity production instead of the methodology term electricity production. The approach of adding the term net clarifies the parameter better and is supported by the auditing team. According to the existing plans there will be one main electricity line and one line for auxiliary back up purposes. The net electricity therefore will be [(main line feed-in) (main line consumption from grid) (auxiliary line consumption from grid)]. This has to be explicitly outlined in a more detailed monitoring plan. The estimated value is base on a wind expert s report by Enercon. Conservative reduction factors have been considered for method uncertainties, availability and electrical losses. Comparison with the results of near-by wind farm Virtsu I confirm the conservative approach. QA/QC procedures are described in reasonable detail in the PDD. As the substation and meters have not yet been built detailed QA/QC procedures will be established at a later point in time. Realization of those procedures has to be checked during the initial Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-19

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION B.7.1.3. Parameter Title: Quantity of steam produced (for geothermal projects only) B.7.1.4. Parameter Title: Fraction of CO 2 in steam produced (for geothermal projects only) B.7.1.5. Parameter Title: Fraction of CH 4 in steam produced (for geothermal projects only) B.7.1.6. Parameter Title: Quantity of steam generated during well testing (for geothermal projects only) B.7.1.7. Parameter Title: Fraction of CO 2 in steam during well testing (for geothermal projects only) B.7.1.8. Parameter Title: Fraction of CH 4 in steam during well testing (for geothermal projects only) B.7.1.9. Parameter Title: CO 2 emission coefficient of fuel used by the geothermal plant (for geothermal projects only) B.7.2. Description of the monitoring plan B.7.2.1. Is the operational and management structure clearly described and in compliance Ref. COMMENTS verification (see CAR #1, B.7.2.1.). - Not applicable. - Not applicable. - Not applicable. - Not applicable. - Not applicable. - Not applicable. - Not applicable. 1,2, 20 Section B.7.2. and Annex 4 of the PDD describe in a generic form the operational and management structure. Details are still miss- PDD in GSP CAR #1 Final PDD Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-20

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION with the envisioned situation? Ref. COMMENTS ing. With the start of the wind farm operation at the latest a more elaborate monitoring plan is needed. PDD in GSP Final PDD B.7.2.2. B.7.2.3. B.7.2.4. Are responsibilities and institutional arrangements for data collection and archiving clearly provided? Does the monitoring plan provide current good monitoring practice? If applicable: Does annex 4 provide useful information enabling a better understanding of the envisioned monitoring provisions? 1,2, 20 1,2, 20 1,2, 20 CAR #1: A formal statement by the project proponent is needed indicating the intention to develop a detailed monitoring plan until August 2007. See B.7.2.1. See B.7.2.1. See B.7.2.1. B.8. Date of completion of the application of the baseline study and monitoring methodology an the name of the responsible person(s)/entity(ies) B.8.1. B.8.2. B.8.3. Is there any indication of a date when the baseline was determined? Is this consistent with the time line of the PDD history? Is the information on the person(s) / entity(ies) responsible for the application of the baseline and monitoring methodology provided consistent with the actual situation? CAR #1 CAR #1 CAR #1 2,20, the date is given (09/11/2006) 2,20 The date of the baseline study corresponds with the PDD date. 2,20 FutureCamp GmbH, Germany, is named as responsible for the baseline study. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-21

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 B.8.4. CHECKLIST TOPIC / QUESTION Is information provided whether this person / entity is also considered a project participant? Ref. C. Duration of the project activity / crediting period COMMENTS PDD in GSP Final PDD 2,20 This information is given; FutureCamp is no project participant. C.1. Duration of the project activity C.1.1. Are the project s starting date and operational lifetime clearly defined and reasonable? 2,20 The project s starting date and the operational lifetime are correctly indicated and reflect the envisioned schedule for the implementation. C.2. Choice of the crediting period and related information C.2.1. Is the assumed crediting time clearly defined and reasonable (renewable crediting period of max 7 years with potential for 2 renewals or fixed crediting period of max. 10 years)? D. Environmental impacts 2,20 The crediting period is clearly defined (from Sept. 1, 2007 to August 31, 2014). Also its type is defined (renewable crediting period). D.1. Documentation on the analysis of the environmental impacts, including transboundary impacts D.1.1. D.1.2. Has the analysis of the environmental impacts of the project activity been sufficiently described? Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, has an EIA been approved? 2,8, 20 15, 17 A short summary of the EIA is given; there are no relevant environmental impacts. Projects with a capacity of less than 50 MW require a small EIA. Such an EIA has been produced and approved by the Ministry of Environment and Forestry. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-22

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 D.1.3. D.1.4. CHECKLIST TOPIC / QUESTION Will the project create any adverse environmental effects? Were transboundary environmental impacts identified in the analysis? Ref. COMMENTS 8,15 According to the EIA there will be no adverse environmental effects. 2,20 There are no transboundary environmental impacts by the wind farm project. PDD in GSP Final PDD 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 D.2.1. D.2.2. Have the identified environmental impacts been addressed in the project design sufficiently? Does the project comply with environmental legislation in the host country? E. Stakeholders comments 8 No environmental impacts have been identified. 8,15, 17 There is full compliance with the Turkish environmental legislation. This has been confirmed by the EIA. E.1. Brief description how comments by local stakeholders have been invited and compiled E.1.1. E.1.2. E.1.3. Have relevant stakeholders been consulted? Have appropriate media been used to invite comments by local stakeholders? If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws? The communities close to the wind farm site have been contacted and informed early in November 2005. 35 people attended the meeting. Other meetings followed regarding land renting / purchasing. Invitation was by public announcement by the local community, which is appropriate for such small settlements. The applied process follows the regulations valid for wind farms with a capacity of less than 50 MW. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-23

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 E.1.4. CHECKLIST TOPIC / QUESTION Is the undertaken stakeholder process that was carried out described in a complete and transparent manner? Ref. COMMENTS The process is rather simple and is sufficiently described in the PDD and documented by the meeting protocol issued by the local community. PDD in GSP Final PDD E.2. Summary of the comments received E.2.1. Is a summary of the stakeholder comments received provided? A meeting protocol exists. It states that there were no negative comments. E.3. Report on how due account was taken of any comments received E.3.1. F. Annexes 1 4 Has due account been taken of any stakeholder comments received? No negative comments were received. Annex 1: Contact Information F.1.1. F.1.2. Is the information provided consistent with the one given under section A.3? Is the information on all private participants and directly involved Parties presented? Annex 2: Information regarding public funding F.1.3. Is the information provided on the inclusion of public funding (if any) in consistency with the actual situation presented by the project participants? F.1.4. If necessary: Is an affirmation available that any such funding from Annex-I-countries does not result in a diversion of ODA? 2,20, the information is consistent. 2,20 There is just one participant; the respective information is presented. 2,20 There is no public funding. 2,20 Not applicable. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-24

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 CHECKLIST TOPIC / QUESTION Annex 3: Baseline information F.1.5. F.1.6. F.1.7. If additional background information on baseline data is provided: Is this information consistent with data presented by other sections of the PDD? Is the data provided verifiable? Has sufficient evidence been provided to the validation team? Does the additional information substantiate / support statements given in other sections of the PDD? Ref. 2,7, 20 2,7, 20 COMMENTS Besides the Statistical Yearbook of Turkey no additional background information on baseline data was provided. The data provided have been checked against the data in the Statistical Yearbook of Turkey. More disaggregated data were not available, according to the statements of the project proponent and the entity determining the baseline. Additionally plausibility checks have been applied. No discrepancies were found. PDD in GSP 2,20 See F.1.5. Final PDD Annex 5: Monitoring information F.1.8. F.1.9. F.1.10. If additional background information on monitoring is provided: Is this information consistent with data presented in other sections of the PDD? Is the information provided verifiable? Has sufficient evidence been provided to the validation team? Do the additional information and / or documented procedures substantiate / support statements given in other sections of the PDD? 2,20 No additional background information on monitoring was provided. - Not applicable. - Not applicable. Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-25

VER Validation Protocol Date of Completion: 21.02.07 Number of Pages: 26 Table 2 Resolution of Corrective Action and Clarification Requests Clarifications and corrective action requests by validation team CAR #1: A formal statement by the project proponent is needed indicating the intention to develop a detailed monitoring plan until August 2007. Ref. to table 1 B.7.1.2. B.7.2.1. B.7.2.4. Summary of project owner response A written statement was signed by the project proponent indicating that before final commissioning of the wind farm a detailed monitoring plan will be made available to the validator, covering all aspects which have been requested in the CAR. Validation team conclusion This approach is deemed to be reasonable by the auditing team. It allows the project proponent to include all those technical and organizational details into the monitoring plan which at the time of the audit could not yet be defined sufficiently. The audit team assured itself that the monitoring plan is being written and that it will be ready before commissioning of the wind park which is expected in September 2007. The open issue was resolved by these findings. Table 3 Unresolved Corrective Action and Clarification Requests (in case of denials) Clarifications and / or corrective action requests by validation team Id. of CAR/CR - - - Explanation of Conclusion for Denial Table 1 is applicable to ACM0002, version 06 with ex-ante determination of CM Page A-26

Validation of the VER Project: Sebenoba 30 MW Wind Farm in Turkey TAnnex 2: Information Reference List

Information Reference List Date of Completion: February 21, 2007 Number of Pages: 1 Reference No. Document or Type of Information 1. On-site interview in Turkey with the project developer and the CDM-consultant at the office of DENIZ in Istanbul at November 6 / 7, 2006, by auditing team of TÜV SÜD Industrie Service GmbH Validation team on-site: Dr. Thyge Weller TÜV SÜD Industrie Service GmbH, Munich, Germany Dr. Nuri Mol TÜV SÜD / Türkiye, Istanbul, Turkey Interviewed persons: Ahmet Hatipoglu Project engineer, AKSA ENERJI URETIM A.S., Istanbul, Turkey Sancar Saraçoğlu Project manager, AKSA ENERJI URETIM A.S., Istanbul, Turkey Felix Nickel Consultant, Future Camp GmbH, Munich, Germany Magda Kmiecik Consultant, Future Camp GmbH, Munich, Germany 2. Project Design Document for VER Project Sebenoba 30 MW wind farm project in Turkey, November 9, 2006 3. Sebenoba Wind Farm Feasibility Study, AKSA ENERJİ ÜRETİM A.Ş., July 2005 4. Sebenoba Wind Power Plant Micrositing Report,,Deniz Elektrik,, June 2005 5. Sebenoba Planning Schedule, November 2006 6. Sebenoba Financial Analysis, 07.11.2006 (Excel-file) 7. Statistical Yearbook of Turkey, 2005 [TÜRKIYE ISTATISTIK YILLIGI], www. 8. Sebenoba Wind Farm Environmental Impact Study, Bozat J.S.Company, February 2005 9. Production Licence, Turkish Energy Market Regulatory Authority (EMRA / EPDK), June 4, 2004 10. Statement of Land Ownership, Sebenoba Wind Farm (samples), June 2006 11. Statement of Class 1 Compliance V80 2 MW, Vestas Wind Systems AS, Randers, Denmark, March 16, 2005 12. Letter of Support by Commerzbank AG, Frankfurt, November 2, 2006 13. Single line diagram of Sebenoba wind farm, Deniz Elektrik Üretim Ltd., October 17, 2005 14. Wind Turbine Purchase and Delivery Agreement, Vestas Italia SrL / AKSA Ennerji Üretim A.S., April 5, 2006 15. Turkish regulation on environmental conformance, December 2003 16. Approval of heavy load traffic for Sebenoba, September 2006 17. Approval of Sebenoba wind farm EIA, March 10, 2005 18. Protocol of Sebenoba windpark stakeholder meeting, November 14, 2005 19. Statement of Deniz regarding the monitoring plan for Sebenoba, January 2007 20. Preliminary Project Design Document for VER Project Sebenoba 30 MW wind farm project in Turkey, V.0, October 27, 2006 21. Project Design Document for VER Project Sebenoba 30 MW wind farm project in Turkey, V.1 (layout change), January 11, 2007 TÜV SÜD