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PROJECT DESIGN DOCUMENT FORM (CDM PDD) - Version 03

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CLEAN DEVELOPMENT MECHANISM
PROJECT DESIGN DOCUMENT FORM (CDM-PDD)
Version 03 - in effect as of: 28 July 2006

CONTENTS

A. General description of project activity

B. Application of a baseline and monitoring methodology

C. Duration of the project activity / crediting period

D. Environmental impacts

E. Stakeholders comments

Annexes

Annex 1: Contact information on participants in the project activity

Annex 2: Information regarding public funding

Annex 3: Baseline information

Annex 4: Monitoring plan





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SECTION A. General description of project activity

A.1. Title of the project activity:
Substitution of coal with alternate fuels at Lucky Cement Limited, Karachi Plant
Version 1
10/01/2012

A.2. Description of the project activity:

Lucky Cement Limited has been sponsored by Yunus Brothers Group which is one of the largest business
groups of Pakistan. The company has grown rapidly to become the leader among Pakistani cement
manufacturers with the largest production capacity, highest sales and greatest market share. Lucky
Cement Limited operates two plants and manufactures Ordinary Portland Cement, Sulphate Resistant
Cement and Slag Cement. One plant of Lucky Cement Limited is at Karachi and other is at Pezu district
Lakki Marwat.

Scenario Existing Prior to the Start of Implementation of the Project Activity

Lucky Cement Limited, Karachi Plant has three kilns, Kiln E, Kiln F and Kiln G. Each kiln has a
designed clinker production capacity of 3,300 Tons per Day (TPD) and uses coal as fuel source for
clinker production and heavy fuel oil (HFO) for pre-heating of kilns. Kiln E and F have been in operation
since October 2006 while Kiln G started operation in January 2009.

Project Scenario

The project activity comprises installation of tyre derived fuel (TDF) and refuse derived fuel (RDF)
systems (plants) at the three existing kilns at Lucky Cement, Karach plant. The project activity would
result in 50% substitution of coal with alternative fuels (TDF from tyre waste, RDF from Municipal Solid
Waste (MSW) and biomass residues such as, Rice Husk). The project activity will result in transfer of
modern technology to the host country as RDF and TDF plants are manufactured by Vecoplan Germany
and Eldan Recycling A/S Denmark, respectively.

Baseline Scenario

The baseline scenario is the scenario existing prior to the start of implementation of the project activity
and is same as identified in Section B.4 of the PDD.

Reduction in Greenhouse Gas Emission

The major source of emissions in the baseline situation is the burning of coal for clinker production. The
project activity will substitute coal (the major CO
2
emission source) with the alternative fuels (see section
A.4.3 for details). The amount of HFO used for preheating of kilns in the project activity will be the same
as that in the baseline situation. The minor carbon dioxide emissions that will occur due to the project
activity are associated with the burning of the alternative fuels such as TDF and RDF and transportation
of these fuels (sources of emissions and type of emissions are described in detail is section B.3). As there
is surplus availability of rice husk in the region, leakage emissions associated with its incineration are
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considered to be zero in the project activity. Likewise, since the project activity does not use less carbon
intensive fuels, there are no upstream leakage emissions involved.

The project activity will result in reduction of Greenhouse Gas (GHG) emissions (on average) equivalent
to 208,484 tCO
2
per year.

Contribution towards Sustainable Development

The project activity will the following contributions towards sustainable development:

Environmental Development

Improvement of the local environment by significant reduction of CO
2
emission to the
atmosphere
Conservation of fossil fuel resources by displacing coal based clinker production
Use of municipal solid waste as RDF will help reduce the uncontrolled burning and decaying of
municipal solid waste
Use of scrap tyres as TDF will result in abatement of environmental hazards associated with their
uncontrolled burning

Social Development

Alleviation of poverty by providing labour employment opportunities to the local community
during construction phase
Creation of new permanent jobs during operational phase of the project activity
Reduced health impacts for the local population through less emission of CO
2


Economic Development

Cost reduction for heat production due to lower price of alternative fuels such as rice husk and
RDF
Employment opportunities for the local people
Less dependency on imported coal

Technology Development

Introduction of modern technology to the host country (technology transfer)
Setting up an example of sustainable development to be followed by other cement factories


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A.3. Project participants:

The table below illustrates the participants involved in the project activity. Contact information is
provided in Annex 1.

Table A.3.1: Project Participants
Name of Party involved
((host) indicates a host
Party)
Private and/or public entity(ies)
project participants
(as applicable)
Kindly indicate if
the Party involved
wishes to be
considered as
project participant
(Yes/No)
Islamic Republic of Pakistan
(host)
Lucky Cement Limited.
(private entity)
No
Islamic Republic of Pakistan
(host)
Carbon Services Private Limited.
(private entity)
No
Switzerland
First Climate (Switzerland) AG
(private entity)
No

A.4. Technical description of the project activity:

A.4.1. Location of the project activity:

A.4.1.1. Host Party(ies):

Islamic Republic of Pakistan

A.4.1.2. Region/State/Province etc.:

Sindh

A.4.1.3. City/Town/Community etc.:

Nooriabad, Karachi

A.4.1.4. Details of physical location, including information allowing the
unique identification of this project activity (maximum one page):

The project is located at:

Lucky Cement Factory,
58 km Milestone, Super Highway,
Nooriabad, Karachi, Sindh, Pakistan.

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The company is headquartered at:

6 A, M Ali Housing Society,
A. Aziz Hashim Tabba Road,
Karachi 75350, Sindh, Pakistan.

Lucky Cement Karachi Plant is located at following geographical coordinates:
Latitude: 25 3 14
Longitude: 67 25 53


Fig A.4.1.4.1: Location of Lucky Cement Plants in Pakistan
1





1
maps.google.com
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Fig A.4.1.4.2: Location of Lucky Cement Plants in Pakistan



Fig A.4.1.4.3: Photograph of Lucky Cement Karachi Plant


A.4.2. Category(ies) of project activity:

As per the sectoral scope of the project activities mentioned in the list of sectoral scopes or accreditation
of DOEs, the project activity falls under Sectoral Scope 4 Manufacturing industries

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A.4.3. Technology to be employed by the project activity:

Lucky Cement Limited, Karachi Plant has three kilns, Kiln E, Kiln F and Kiln G. Each kiln has a
designed clinker production capacity of 3,300 Tons per Day (TPD) and uses coal as fuel source for
clinker production and heavy fuel oil (HFO) for pre-heating of kilns. Kiln E and F have been in operation
since October 2006 while Kiln G started operation in January 2009. Two types of coal, local and
imported, are used for clinker production. However, use of imported coal is almost 100%. No alternative
fuels have been used in the existing plant for the last three years before the implementation of the project
activity. Specifications of the kilns are shown in table A.4.3.1 below

Table A.4.3.1: Technical Specifications of Kilns
Parameter Kiln-E Kiln-F Kiln-G
Designed Production Capacity (TPD) 3,300 3,300 3,300
Minimum Guaranteed Production (TPD) 3,000 3,000 3,000
Guaranteed Heat Rate (kcal/kg) 741.60 741.60 741.60
Achieved Heat Rate (kcal/kg) 784.069 801.3 760


Table A.4.3.2: Historical Operational Days of Kilns
Year Kiln-E Kiln-F Kiln-G
July 2007 June 2008 333 333 -
July 2008 June 2009 342 339 114
July 2009 June 2010 329 321 320


The project activity involves 50% substitution of coal at the existing kilns with the alternative fuels (RDF
from Municipal Solid Waste (MSW), TDF and Rice Husk).

In order to implement the proposed project activity a complete system for receiving, storing, and feeding
of alternative fuels will be built. The project activity will result in transfer of modern technology to the
host country as it involves installation of RDF plant and TDF plant manufactured by Vecoplan Germany
and Eldan Recycling A/S Denmark, respectively.

The project activity will result in substitution of coal with RDF and TDF and biomass residues (Rice
Husk). The amount of HFO used for preheating of kilns in the project activity will be the same as that in
the baseline situation.

The project activity involves implementation of complete waste treatment plant for the municipal solid
waste. This plant will treat the municipal solid waste and convert it to reuse derived fuel (RDF) which
will be used in the kiln. Specifications of the RDF plant is shown in table A.4.3.3 below,

Table A.4.3.3: RDF Plant Technical Specifications
Name of manufacturer Vecoplan (Germany)
Input capacity of Municipal Solid Waste 50-60 TPH
Density of Input material 350 400 kg/m
3

Output capacity of RDF 15-20 TPH
Weight of the shredder 25,000 kg
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Intake Length 2500 mm
Intake Width 1700 mm
Two rotors, Diameter 720 mm
Length per rotor 500 mm
Motor Power x 2 155 KW

TDF plant has been imported from Denmark for processing of scrap tyres. Scrap tyres will consist of car
tyres, light truck tyres and truck tyres. The scrap tyres (raw material input to the TDF plant) will be free
of flammable fluids and foreign bodies such as stones. This plant will recycle scrap tyres by converting
them into tyre derived fuel (TDF) which will be used in the kilns E, F and G in place of coal. The TDF
plant comprises three parts: Super Chopper (SC), Multi-Purpose Rasper (MPR) and Magnetic Separators
(MS). Technical details of each part are provided below:
A.
Table A.4.3.4: General Specifications of TDF Plant
Input capacity of the TDF Plant 18 tons scrap tyres/hour
Output capacity of the TDF plant 18 tons TDF chips/hour
Maximum diameter of scrap tyre 1900 mm
Output size of the TDF chips 25 mm

Scrap tyres will be fed into the super choppers (SC) where it is chopped down into small pieces of about
100 mm diameter. The technical features of the super choppers (SC) are mentioned below in table
A.4.3.5:

Table A.4.3.5: Super Chopper SC2118T/3 Technical Specifications
Power 250 KW
Rotor length 2,100 mm
Rotor Diameter 450 mm
Rotor Speed 22 rpm
Knives 18 flying / 8 static
Weight of the Machine 26,000 kg
Weight of the Inlet Hopper 1,200 kg
Weight of the Hydraulic Station 4,000 kg
Dimensions Length : 3,900 mm
Height : 1,800 mm
Width : 4,000 mm

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The output of the super chopper is fed into the multi purpose rasper (MPR). The MPR further reduces the
size of tyres from 100 mm to 25 mm diameter. The technical features of the multi purpose rasper
(MPR)are mentioned below in table A.4.3.6:

Table A.4.3.6: Multi Purpose Rasper MPR200T Technical Specifications
Motor 2 x 132 kW / 734 rpm / 50Hz
Rotor Length 2,000 mm
Rotor Diameter 400 mm
Cutting Diameter 506 mm
R.P.M of Rotor 144 rpm
Opening at cutting chamber 700 x 2,000 mm
Knives 25 flying / 26 static
Total Weight Approx 24,000 kg

The output of the MPR is then fed into the magnetic separator (MS). This magnetic separator separates
the rubber and the wires from the TDF. The output of MS is then fed into the kiln for clinker production.
The technical details of the magnetic separator are provided below
B.

Fig A.4.3.1: Eldan Magnetic Seperator

The Overband Magnets are used to separate magnetic materials from nonmagnetic materials. The
Overband Magnets are constructed on a frame. The frame is mounted with a drum motor at one end and a
carrier roll at the other end. A permanent magnet is placed in the frame. The Overband Magnets are
placed so far above the outlet conveyors that the magnetic material cannot pass by them.


Overband Magnets
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Energy Mass Flows in the baseline and project situation are provided in Table A.4.3.7 below,

Table A.4.3.7: Energy Mass Flows
Description Baseline Project
Pre Heating of Kilns
HFO Consumption for Pre Heating Purposes
(tons/yr)
489.43 489.43
Energy Generated from HFO (GJ/yr) 19,704 19,704
Clinker Production and Fuel/Energy Consumption
Clinker Production (tons/yr) 3,385,800 3,385,800
Coal Consumption (tons/yr) 443,426 221,713
Energy Generated from Coal (GJ/yr) 11,085,372 5,542,686
Rice Husk (tons/yr) - 43,836
Energy Generated from Rice Husk (GJ/yr) - 554,269
TDF (tons/yr) - 153,214
Energy Generated from TDF (GJ/yr) - 4,101,588
RDF (tons/yr) - 63,608
Energy Generated from RDF (GJ/yr) - 886,830
Total Energy Consumed for Clinker
Production (GJ/yr)
11,085,372 11,085,372


The major source of emissions in the baseline situation is the burning of coal for clinker production. The
project activity will substitute coal (the major CO
2
emission source) with the alternative fuels (see section
A.4.3 for details). Project emissions from additional electricity are considered zero as the project activity
doesnt result in consumption of additional electricity. However, as per the methodology requirement, the
project emissions due to additional electricity consumption shall be monitored during the entire crediting
period of the project activity. The amount of HFO used for preheating of kilns in the project activity will
be the same as that in the baseline situation. The minor carbon dioxide emissions that will occur due to
the project activity are associated with the burning of the alternative fuels such as TDF and RDF and
transportation of these fuels (sources of emissions and type of emissions are described in detail is section
B.3). As there is surplus availability of rice husk in the region, leakage emissions associated with its
incineration are considered to be zero in the project activity. Likewise, since the project activity does not
use less carbon intensive fuels, there are no upstream leakage emissions involved.

All the equipment installed in the project activity is brand new and supplier has guaranteed that the
technical lifetime of the equipment is 20 years. The project technology is not likely to be substituted by
other or more efficient technologies within the crediting period of the project activity.

The baseline scenario is the scenario existing prior to the start of implementation of the project activity,
and is same as identified in Section B.4 of the PDD.
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The project equipment is brand new and uses state of the art technology. The technology is
environmentally safe as high carbon intensive fuels are displaced with less carbon intensive fuels. Hence
the implemented technology in the project activity is safe. The project involves transfer of modern
technology to Pakistan.

The import of new equipment not merely means technology transfer but skill transfer as well. Lucky
Cement Limited is contributing significantly to the education and training of technicians with the
necessary skills to properly maintain and operate such equipment..

A.4.4. Estimated amount of emission reductions over the chosen crediting period:

A fixed crediting period of 10 years starting from July 01, 2012 has been chosen with average annual
estimated emission reductions of 208,484 tCO
2
/year.

Table A.4.4.1: Emission reductions over the crediting period
Years
Annual estimation of emission
reductions in tonnes of CO
2
e
Year 1
208,484
Year 2
208,484
Year 3
208,484
Year 4
208,484
Year 5
208,484
Year 6
208,484
Year 7
208,484
Year 8
208,484
Year 9
208,484
Year 10
208,484
Total estimated reductions (tonnes of CO
2
e)
2,084,840
Total number of crediting years 10
Annual average over the crediting period of
estimated reductions (tonnes of CO
2
e)
208,484

A.4.5. Public funding of the project activity:

No public funding is involved in this project activity.

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SECTION B. Application of a baseline and monitoring methodology

B.1. Title and reference of the approved baseline and monitoring methodology applied to the
project activity:

For the project activity, the approved consolidated baseline and monitoring methodology ACM0003
Version 07.4, Emissions reduction through partial substitution of fossil fuels with alternative fuels
or less carbon intensive fuels in cement or quicklime manufacture is used.

The project design document also refers to the latest approved versions of the following tools:

Combined tool to identify the baseline scenario and demonstrate additionality (version 03.0.1);
Tool to calculate baseline, project and/or leakage emissions from electricity consumption (version
01).

B.2. Justification of the choice of the methodology and why it is applicable to the project
activity:

The project activity fulfils all the applicability conditions of the chosen methodology, ACM0003 (version
07.4); this is shown inTableB.2.1 below.

Table B.2.1: Applicability of ACM0003 (version 07.4) for the Project Activity
Condition
Project Activity/Baseline
Scenario
Source Applicability
The methodology is applicable to
project activities in the cement or
quicklime industry where fossil
fuel(s) used in an existing clinker or
quicklime production facility are
partially replaced by less carbon
intensive fuel(s) and/or alternative
fuel(s)
The coal consumed in the
clinker kiln is partially
replaced by TDF, RDF and
biomass residues(e.g. rice
husk)
Project
Feasibility
study
Applicable.
A significant investment is required
to enable the use of the alternative
fuel(s) and/or the less carbon
intensive fossil fuel(s)
A significant investment of
approximately PKR 1.04
billion is required for the
implementation of the project
activity.
Project
Feasibility
study Applicable.
During the last three years prior to
the start of the project activity, no
alternative fuels have been used in
the project plant
No alternative fuels have been
used in the project plant
during the last three years
prior to the start of the Project
Activity.
Daily
production
reports
(2007 2010)
Applicable
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Condition
Project Activity/Baseline
Scenario
Source Applicability
The CO
2
emissions reduction
relates to CO
2
emissions generated
from fuel combustion only and is
unrelated to the CO
2
emissions
from decarbonisation of raw
materials (i.e. CaCO
3
and MgCO
3

bearing minerals)
There is no change in
chemical composition of the
raw material for kiln feed in
the project situation, therefore
CO
2
emissions from
decarbonisation are not
affected by the project. The
CO
2
emissions reduction is
related only to reduce coal
combustion due to the project
activity and is unrelated to the
CO
2
emissions from
decarbonisation of raw
materials.
- Applicable
The methodology is applicable only
for installed capacity (expressed in
tons clinker/year or tons
quicklime/year) that exists by the
time of validation of the project
activity
The project activity is
restricted to the existing 3
kilns (E ,F and G) each having
total installed capacity of
3,300 TPD (3,385,800
tons/year clinker production)
Project
Feasibility
study
Applicable
The biomass is not chemically
processed (e.g. esterification to
produce biodiesel, production of
alcohols from biomass, etc.) prior
to combustion in the project plant
but it may be processed
mechanically or be dried at the
project site. Moreover, any
preparation of the biomass,
occurring before use in the project
activity, does not cause other
significant GHG emissions (such
as, for example, methane emissions
from anaerobic treatment of waste
water or from char coal production)
Biomass used in the project
activity is not chemically
processed and will be
combusted directly in the
kilns. Only physical operations
like drying in open sun,
classification, size reduction,
storage, dosing, etc. shall take
place. No chemical reactions
are involved.
- Applicable
The biomass used by the project
facility is stored under aerobic
conditions
The biomass to be used by the
project facility will be stored
under aerobic conditions.
- Applicable
In cases where renewable biomass
from dedicated plantation is
used,natural regeneration
The project activity will not
use any renewable biomass
from dedicated plantation -
This condition
is not
applicable to
the project
activity.
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Condition
Project Activity/Baseline
Scenario
Source Applicability
The applicability conditions
outlined in the latest available
versions of the following tools have
to be fulfilled as well:

Combined tool to identify the
baseline scenario and
demonstrate additionality
(version 03.0.1);
Emissions from solid waste
disposal sites (version 06.00);
Tool to calculate project or
leakage CO
2
emissions from
fossil fuel combustion (version
02.00);
Tool to calculate baseline,
project and/or leakage
emissions from electricity
consumption (version 01.00).

The following tools have been
used in the PDD

Combined tool to identify
the baseline scenario and
demonstrate additionality
(version 03.0.1);
Tool to calculate baseline,
project and/or leakage
emissions from electricity
consumption (version
01.00).

The project activity fulfils all
the applicability conditions as
outlined in the tools used
for/applicable to the project
activity
- Applicable
The methodology is not applicable
to project activities that implement
efficiency measures in production
of clinker, such as changing the
configuration/number of pre-
heaters
The project activity does not
implement efficiency
measures or modifications in
the existing clinker production
process.
I.E.E Report Applicable
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Condition
Project Activity/Baseline
Scenario
Source Applicability
Finally, this methodology is only
applicable if F2 (the continuation of
the current fuel mix) or F3 (a
different fossil fuel mix portfolio)
results to be the most plausible
baseline scenario for the use of
fuels in the cement plant and if one
or several of the following
scenarios, as explained in the
Procedure for the selection of the
most plausible baseline scenario
and demonstration of additionality
result to be the most plausible
baseline scenario for the use of
alternative fuels:
For the fate of any wastes
originating from fossil sources:
scenarios W1 and/or W3
For the fate of any biomass
residues: scenarios B1, B2
and/or B3;
For the fate of any renewable
biomass: scenario R1.
For the project activity, F2 is
the most plausible baseline
scenario for the use of fossil
fuels at the project plant, W3
and B1 and B3 result to be the
most plausible baseline
scenarios for use of alternative
fuels. Since the project activity
does not use any renewable
biomass, hence condition R 1
is not applicable
(identification of baseline
scenario is discussed in detail
in section B.4).
- Applicable

B.3. Description of the sources and gases included in the project boundary:

The physical project boundary covers all production processes related to clinker production, including:
The pre-heaters, where the heat of exhaust gas is used to heat the inputs for clinker production;
The pre-calciner, where fuels are fired for the pre-calcination of the inputs for clinker production;
The kiln tube, where fuels are also fired and where the calcinations process takes place;
On-site storage and on-site transportation and drying of alternative fuels (if alternative fuels are
used in the project activity);
The vehicles used for transportation of alternative fuels to the project site;
Where biomass residues are used, the project boundary includes the sites where the biomass
residues would be dumped, left to decay or burnt in the absence of the project activity;
The project boundary is shown in figures below. Figure B 3.1.1 shows the baseline situation with
emission sources and gases

Figure B.3.1.1: Baseline Situation

Imported and
local coal
Consumption of
coal in the Kiln
Clinker
CO
2
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Figure B 3.1.2 shows the project situation with emission sources, project boundary and gases.


Figure B.3.1.2: Project Activity

Project Boundary
Imported and
local coal
Consumption of
coal in the Kiln
Tire Waste
Transportation
of Tire from
port to the
project plant
Recycling of
tires to TDF
using Tire
recycling plant
CO2
Consumption
of TDF in the
Kiln
CO2 CO2
MSW
Transportation
of MSW from
landfills to the
project plant
CO2
Recycling of
MSW to RDF
using RDF
recycling plant
Consumption
of RDF in the
Kiln
CO2
Biomass
residues (Rice
Husk)
Clinker Production
Recycling of
Biomass
residues to RDF
using RDF
recycling plant
Consumption
of Biomass
residues in
Kiln
Electricity consumption by
the RDF and TDF recycling
CO2
Cement Production
Transportation
of MSW from
landfills to the
project plant
CO2
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Emission sources and gases included in or excluded from the project boundary are described in Table 3.

Table B.3.1:Emissions sources included in or excluded from the project boundary
Source Gas Included? Justification/Explanation
B
a
s
e
l
i
n
e

Emissions from fossil
fuels displaced in the
project plant (BE
FF,y
)
CO
2
Yes Main emission source
CH
4
No Minor source. Neglected for simplicity
N
2
O No Minor source. Neglected for simplicity
Methane emissions
avoided from
preventing disposal or
uncontrolled burning of
biomass residues
CO
2
No It is assumed that CO
2
emissions from surplus
biomass residues do not lead to changes of
carbon pools in the LULUCF sector
CH
4
Yes Included if leakage can be ruled out
N
2
O No Minor source
P
r
o
j
e
c
t

A
c
t
i
v
i
t
y

Emissions from the use
of alternative fuels
(PE
k,y
)
CO
2
Yes Main emission source
CH
4
No Minor source. Neglected for simplicity
N
2
O No Minor source. Neglected for simplicity
Emissions from the use
less carbon intensive
fossil fuels (PE
k,y
)
CO
2
No Not applicable
CH
4
No Not applicable
N
2
O No Not applicable
Emissions from
additional electricity as
a result of the project
activity (PE
EC,y
)
CO
2
Yes Can be a significant emission source
CH
4
No Minor source. Neglected for simplicity
N
2
O No Minor source. Neglected for simplicity
Emissions from
additional fossil fuel
consumption as a result
of the project activity
(PE
FC,y
)
CO
2
No Not applicable
CH
4
No Not applicable
N
2
O No Not applicable
Emissions from
combustion of fossil
fuels for transportation
of alternative fuels to
the project plant (PE
T,y
)
CO
2
Yes Can be a significant emission source
CH
4
No Minor source. Neglected for simplicity
N
2
O No Minor source. Neglected for simplicity
Emissions from the
cultivation of
renewable biomass at
the dedicated
plantation (PE
BC,y
)
CO
2
No Not applicable
CH
4
No Not applicable
N
2
O No Not applicable

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B.4. Description of how the baseline scenario is identified and description of the identified
baseline scenario:

The identification of baseline scenario is done as per the procedure for the selection of the most plausible
baseline scenario and demonstration of additionality provided in ACM0003 (version 07.4) which states
that the baseline scenario should be identified and additionality be assessed using the most recent
approved version of the Combined tool to identify the baseline scenario and demonstrate additionality
(version 3.0.1).

Step 1: Identification of alternative scenarios

Step 1a: Define alternative scenarios to the proposed CDM project activity

According to ACM0003, in applying step 1a of the Combined tool to identify the baseline scenario and
demonstrate additionality, the following scenarios are considered, as outcome of step 1a of the tool, as
alternatives to the proposed CDM project activity:

Possible alternatives to the fuel mix for cement manufacturing

F1: The proposed project activity not undertaken as a CDM project activity (i.e. use of alternative
fuels and/or less carbon intensive fuels)
F2: Continuation of current practice, i.e., a scenario in which the company continues cement
production using the existing technology, materials and fuel mix
F3: The continuation of using only fossil fuels and no alternative fuels, however, with a different fuel
mix portfolio, taking into account relative prices of the fuels available. The scenarios may be
used on one fuel or a different mixes of fuel.
F4: The currently used fuels are partially substituted with alternative fuels and/or less carbon
intensive fossil fuels other than those used in the CDM project activity and/or any other fuel
types, without using the CDM. If relevant develop different scenarios with different mixes of
alternative fuels or less carbon intensive fuels and varying degrees of fuel switch from traditional
to alternative fuels or less carbon intensive fuels
F5: The construction and operation of a new cement plant

Since the project activity uses alternative fuels, the following alternatives are considered:

Possible alternatives to waste originating from fossil sources used as alternative fuel
W1: Incineration of the waste in a waste incinerator without utilizing the energy from the incineration
W2: Incineration of the waste in a waste incinerator with use of the energy (e.g. for heat and/or
electricity generation)
W3: Disposal of the waste at a managed or unmanaged landfill
W4: The use of the waste at other facilities, e.g. other cement plants or power plants, as a feedstock or
for the generation of energy
W5: The recycling or reutilization of the waste
W6: The proposed project activity, not undertaken as a CDM project activity, i.e. the use of the waste
in the project plant

Since the project activity uses biomass residues (rice husk), the following alternatives are considered:
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Possible alternatives to biomass residues used as alternative fuel

B1: The biomass residues are dumped or left to decay under mainly aerobic conditions. This applies,
for example, to dumping and decay of biomass residues on fields
B2: The biomass residues are dumped or left to decay under clearly anaerobic conditions. This
applies, for example, to deep landfills with more than 5 meters. This does not apply to biomass
residues that are stock-piled or left to decay on fields
B3: The biomass residues are burnt in an uncontrolled manner without utilizing them for energy
purposes
B4: The biomass residues are sold to other consumers in the market and used by these consumers,
such as for heat and/or electricity generation, for the generation of biofuels, as feedstock in
processes (e.g. the pulp and paper industry), as fertilizer, etc.
B5: The biomass residues are used for other purposes at the project site, such as for heat and/or
electricity generation, for the generation of biofuels, as feedstock in processes (e.g. the pulp and
paper industry), as fertilizer, etc.
B6: The proposed project activity, not undertaken as a CDM project activity, i.e. the use of the
biomass residue in the project plant

Since the project activity does not use any renewable biomass; No alternative scenarios to use of
renewable biomass are considered.

Outcome of Step 1a: List of plausible alternative scenarios to the project activity.

All the alternatives F1 to F5, W1 to W6 and B1 to B6 mentioned in Step 1a are plausible alternatives to
the project activity.
Sub-Step 1b: Consistency with mandatory applicable laws and regulations

All of the alternatives identified above are in compliance with the mandatory laws and regulations
governing the cement manufacturing process in Pakistan. There are no legal, national, or sectoral policies
in place which prohibit the project proponent from opting out any of the alternatives, F1 to F5, W1 to W6
and B1 to B6 which are outcome of step 1a of the tool, in the project years.

Outcome of Step 1b:

All the alternatives F1 to F5, W1 to W6 and B1 to B6 mentioned in Step 1a are in compliance with the
mandatory applicable laws and regulations governing the cement manufacturing process in Pakistan.


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Step 2: Barrier analysis
Sub-step 2a: Identify barriers that would prevent the implementation of alternative scenarios

A list of barriers that would prevent implementation of alternative scenarios is presented below:
Investment barriers: High initial investment without any additional benefit.
Technological barrier: Instability in clinker production process, unavailability of skilled labor to
operate the technology.
Barriers due to Prevailing Practice: Prevailing industry practice in the country.
Other barriers: alternative use (other than that in the project activity) of biomass

Sub-step 2b: Eliminate alternative scenarios which are prevented by the identified barriers

In this step barrier analysis has been conducted with respect to each alternative so as to select the most
plausible baseline scenario for the project activity. The results are provided in Tables 4.1, 4.2, and 4.3
below followed by details given in case of each alternative.


Table B.4.1: Barrier analysis for F1 to F5


Alternative
Sub-step 2a:Identify Barriers that would prevent
the implementation of alternative scenarios



Comments
Investment Barrier Technological Barrier
F1

This alternative turns
out to be a plausible
baseline scenario to the
project activity only in
conjunction with B6 and
W6
F2

This alternative turns
out to be the most
plausible baseline
scenario to the project
activity
F3
X
This alternative could
be excluded from the
further consideration.
See explanation below
F4
X X
This alternative could
be excluded from the
further consideration.
See explanation below
F5
X X
This alternative could
be excluded from the
further consideration.
See explanation below

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Alternative F1: This alternative is not prevented by any of the identified barriers.

Alternative F2: This alternative is not prevented by any of the identified barriers because the
continuation of the current practice bears no additional costs; the technology is well-known and is widely
used in the country. There are no legal, national, or sectoral policies in place which either prohibit the
project proponent from the continuation of current practice in the project years or force the project
proponent to undertake the project activity. Hence, it is the most plausible baseline scenario.

Alternatives F3: This alternative is not in consonance with common practice at cement industry in
Pakistan. Most of the cement plants in Pakistan primarily use imported coal (because of its purity and low
sulphur content) for clinker production. Local coal and pet coke are also used but only in minor fractions.
Heavy Fuel Oil (HFO) is primarily used for pre-heating of the kilns and thus cannot be associated with
clinker production. At lucky Cement Karachi Plant imported coal has been a preferred choice because its
high purity and local coal has only been sparingly used because of its high sulphur content. Thus using
local coal in larger quantities could not only create environmental issues but also translate into a serious
technological barrier resulting in damage of the clinker production equipment or compromise the clinker
quality. Therefore, this alternative is excluded from further consideration as baseline scenario.

Alternative F4: This alternative faces high capital costs and technological barriers. Use of less carbon
intensive fuels such as Natural Gas (NG) is not possible due to two reasons (i) Lucky Cement does not
have NG connection. Secondly, due to severe gas shortages in the country, there is no possibility of using
it even in the remote future. Since there is no way to use fossil fuels other than coal, and use of alternative
fuels other than those used in the project activity would require high capital investment, this alternative is
excluded from the further consideration as baseline scenario.

Alternative F5: Of all the alternatives discussed so far, this is the most unlikely scenario to happen
because of its very high costs which could be many times greater than the project activity cost. Even if a
new cement plant is constructed, it shall consume same type of fuels which are currently being utilized in
Lucky Cement Karachi Plant, so it shall not make any changes in the CO
2
emissions during its operation.
Therefore, it is excluded from the further consideration as baseline scenario.
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Table B.4.2: Barrier analysis for W1 to W6



Alternative
Sub-step 2a:Identify Barriers that would prevent
the implementation of alternative scenarios



Comments
Investment Barrier Prevailing Practice
Barrier
W1
X
This alternative could
be excluded from the
further consideration.
See explanation below
W2
X
This alternative could
be excluded from the
further consideration.
See explanation below
W3

This alternative turns
out to be the most
plausible baseline
scenario to the project
activity
W4
X X
This alternative could
be excluded from the
further consideration.
See explanation below
W5
X X
This alternative could
be excluded from the
further consideration.
See explanation below
W6

This alternative turns
out to be a plausible
baseline scenario to the
project activity only in
conjunction with F1 and
B6

Alternative W1:

Prevailing Practice Barrier:
This alternative is prevented by prevailing practice barrier as incineration of waste in a waste incinerator
without utilizing the energy from the waste incineration is not a common practice in the Pakistan. There
are no facilities in the country for the waste incineration.
Alternative W2:

Prevailing Practice Barrier:
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This alternative is prevented by prevailing practice barrier as incineration of waste in a waste incinerator
with utilization of the energy from the waste incineration is not a common practice in the Pakistan. There
are no facilities in the country for the waste incineration.
Alternative W3:
This alternative is not prevented by any of the presented barriers. As disposal of waste in the managed or
unmanaged landfills is the common practice in the Pakistan.
Alternative W4:

This alternative is prevented by the two barriers prevailing practice barrier and investment barrier.

Prevailing Practice Barrier:
Use of waste in the other cement plants is not a common practice
2
in Pakistan. Most of the cement plants
use fossil fuels for their clinker production.

Investment barrier:
This alternative is prevented by the investment barrier as use of waste for the clinker production requires
state of the art waste recycling plants. These recycling plant are very costly and requires high upfront cost
and operational and maintenance cost. That is why this alternative is not a common practice in the
country.
Alternative W5:
This alternative is prevented by the two barriers prevailing practice barrier and investment barrier.

Prevailing Practice Barrier:
The recycling and utilization of the waste in the country is not the common practice.

Investment barrier:
The use of waste requires a recycling plant which is very costly. It requires high upfront and operational
and maintenance cost. That is why this alternative is not the suitable baseline scenario.
Alternative W6:
This alternative is not prevented by any of the identified barriers.



2
As demonstrated in section b.5 common practice analysis
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Table B.4.3: Barrier analysis for B1 to B6


Alternative
Sub-step 2a:Identify Barriers that would prevent
the implementation of alternative scenarios



Comments
Prevailing Practice
Barrier
Other Barriers
B1

This alternative turns
out to be the most
plausible baseline
scenario to the project
activity
B2
X
This alternative could
be excluded from the
further consideration.
See explanation below
B3

This alternative turns
out to be the most
plausible baseline
scenario to the project
activity
B4
X
This alternative could
be excluded from the
further consideration.
See explanation below
B5
X
This alternative could
be excluded from the
further consideration.
See explanation below
B6

This alternative turns
out to be a plausible
baseline scenario to the
project activity only in
conjunction with F1 and
W6

Alternative B1:

The surplus biomass residue would be dumped or left to decay under mainly aerobic conditions in the
absence of the proposed project activity. Therefore, Alternative B1 is a realistic baseline alternative for
unused biomass. Hence this alternative is a likely baseline scenario.
Alternative B2:

Prevailing Practice Barrier:
Dumping of biomass residue under clearly anaerobic condition is not a common practice in the country.
Normally the biomass residue are dumped or left for decay on field or burnt in an uncontrolled manner
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for storage efficiency. Hence this alternative is not a likely baseline scenario as it faces prevailing practice
barrier.
Alternative B3:
Burning of surplus biomass residues in an uncontrolled manner without utilizing them for energy
purposes is the most prevalent practice in Pakistan. Hence this is a likely scenario as this alternative faces
no barrier.
Alternative B4:

Prevailing Practice Barrier:
As discussed earlier it is not a common practice in Pakistan to utilize biomass residue in industry.
Biomass is usually dumped or burnt at site of production as a means of disposal. Hence this alternative is
not a likely baseline scenario as it faces prevailing practice barrier.
Alternative B5:

Other Barrier
This is not a likely scenario as there is no other possible use (other than incineration in the kiln) of
alternative fuel at the Lucky Cement Karachi Plant.
Alternative B6:
This alternative is not prevented by any of the identified barriers.

Outcome of Step 2b: List of alternative scenarios to the project activity that are not prevented by
any barrier.

Alternative 1
F1, W6, B6: The proposed project activity not undertaken as a CDM project activity (i.e. use of
alternative fuels in the project plant such as TDF from tyre waste, RDF from municipal solid waste and
rice husk).

Alternative 2
F2, W3, B1 and B3: Continuation of current practice (i.e., a scenario in which the company continues
cement production using the existing technology, materials and fuel mix, municipal solid waste is
disposed at a managed or unmanaged landfill and the continuation of dumping of biomass residue (rice
husk) under aerobic condition and burning biomass residues in an uncontrolled manner).

As further discussed in section B.5 alternative 1 is economically less attractive than alternative 2. Hence
alternative 2 has been identified as the baseline scenario.

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B.5. Description of how the anthropogenic emissions of GHG by sources are reduced below
those that would have occurred in the absence of the registered CDM project activity (assessment
and demonstration of additionality):

CDM consideration before starting date of the project and continued effort to secure CDM status

The starting date of the project activity is November 23
rd
2010 corresponding to the date of signing of
contract between Lucky Cement Limited and the project equipment supplier, Eldan Denmark. Lucky
Cement was aware of CDM since February 2007 and it played an instrumental role in the investment
decision taken on October 21
st
, 2010 to implement the project. Discussions with CDM consultants started
in February 2007 and during the whole implementation phase before validation, Lucky Cement was
accompanied by CDM consultants. The signing of contract between Lucky Cement and civil work
consultant was finalized in May 2011. The key dates of the project timeline are provided in table B.5.1

Table B.5.1: Project Timeline
Milestone Date Source
CDM awareness February 3, 2007 Letter from Director of
Carbon Services (Private)
Limited to Technical Director
of Lucky Cement Limited
Investment decision 21

October, 2010 Extract from the minutes of
the Boards Meeting
Starting date of the project activity 23 November, 2010 Contract with Eldan
Recycling A/S for TDF plant
Contract with Vecoplan for RDF plant 26 January, 2011 Contract with Vecoplan for
RDF plant
Letter of credit for TDF plant 30 November, 2010 LC for the TDF plant
Letter of credit for RDF plant 7 December, 2010 LC for the RDF plant
Intimation to UNFCCC and DNA
(Designated National Authority)
Pakistan
06 April, 2011 Prior Consideration letter to
UNFCCC and DNA.
Contract for Civil works and
Mechanical works
May, 2011

As per the recommendations of the methodology ACM0003 (version 7.4) Combined tool to identify the
baseline scenario and demonstrate additionality (version 03.0.1) is used for setting the baseline and the
assessment and demonstration of additionality. As per the tool following steps needed to the applied:

Step 1: Identification of alternative and baseline scenarios
Step 2: Barrier analysis
Step 3: Investment analysis
Step 4: Common practice analysis

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Step 1: Identification of alternative and baseline scenarios

Step 1a: Define alternative scenarios to the proposed CDM project activity
This step has been described in detail above (section B.4 in the PDD).

Sub-step 1b: Consistency with mandatory laws and regulation
This step has been described in detail above (section B.4 in the PDD).

Step 2: Barrier analysis

Sub-step 2a: Identify barriers that would prevent the implementation of alternative scenarios
This step has been described in detail above (section B.4 in the PDD).

Sub-step 2b: Eliminate alternative scenarios which are prevented by the identified barriers
This step has been described in detail above (section B.4 in the PDD).

Outcome of Step 2b: List of alternative scenarios to the project activity that are not prevented by
any barrier.

Alternative 1
F1, W6, B6: The proposed project activity not undertaken as a CDM project activity (i.e. use of
alternative fuels in the project plant such as TDF from tyre waste, RDF from municipal solid waste and
rice husk).

Alternative 2
F2, W3, B1 and B3: Continuation of current practice (i.e., a scenario in which the company continues
cement production using the existing technology, materials and fuel mix, municipal solid waste is
disposed at a managed or unmanaged landfill and the continuation of dumping of biomass residue (rice
husk) under aerobic condition and burning biomass residues in an uncontrolled manner).

Step 3: Investment Analysis:

As discussed in the section above, it is required to substantiate the additionality by conducting a
benchmark analysis comparing the alternatives as identified in step 2. The investment analysis is done in
line with the Guidelines on the Assessment of Investment Analysis (Version 5.0.0)
3


The reasoning provided in the following paragraphs clearly reveals that the criteria employed for the
selection of type of IRR and the corresponding benchmark are as per the guidance provided in
paragraphs 12-14 of Annex 5 to EB 62.

It is stated in Paragraph 12 of Annex 5 to EB 62 that In cases where a benchmark approach is used the
applied benchmark shall be appropriate to the type of IRR calculated. Local commercial lending rates or
weighted average costs of capital (WACC) are appropriate benchmarks for a project IRR.
Required/expected returns on equity are appropriate benchmarks for an equity IRR. Benchmarks supplied
by relevant national authorities are also appropriate if the DOE can validate that they are applicable to
the project activity and the type of IRR calculation presented

3
Annex 5 to EB 62
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Furthermore, Paragraph 13 of Annex 5 to EB 62 states that In the cases of projects which could be
developed by an entity other than the project participant the benchmark should be based on parameters
that are standard in the market.

With regard to the proposed CDM project activity:

The investment analysis is in compliance with the requirements of Paragraph 12 of Annex 5 to
EB 62 as it is based on the calculation of project IRR and its comparison with the commercial
lending rate (15.21%) evaluated at the time of investment decision.

The chosen benchmark is in compliance with the requirements of Paragraph 13 of Annex 5 to EB
62 as the project activity could have been implemented by an entity other than Lucky Cement.

As per guidance provided in Paragraph 14 of Annex 5 to EB 62, Internal company
benchmarks/expected returns (including those used as the expected return on equity in the
calculation of weighted average cost of capital-WACC) should only be applied in cases where
there is only one possible project developer... The reasoning provided in the preceding
paragraph clearly shows that this is not the case; therefore, use of equity IRR or internal
benchmark is not appropriate the context of the current project activity.

The discussion provided above clearly shows that the selection of project IRR and the corresponding
benchmark are appropriate for the purpose of conducting investment analysis of the project activity.

Below it is demonstrated that the Internal Rate of Return for the project activity, i.e. (project IRR) is lower
than the benchmark and the project IRR surpasses the benchmark return only with an additional revenue
stream from sale of Certified Emission Reductions (CER) generated under the project activity.

Benchmark (Commercial Lending Rate): The local lending and borrowing rates in Pakistan are based
on Karachi Inter-bank Offered Rate (KIBOR) plus the credit spread over the KIBOR charged by the local
bank. In February 2004, KIBOR was officially introduced by State Bank of Pakistan as a reference rate
for all corporate in Pakistan
4
. Thus the KIBOR portion of the commercial lending rate is always
determined by SBP. The credit spread calculation is performed by local banks which determine it based
on various project specific risks or characteristics of a project type.

For the determination of the benchmark (commercial lending rate) for the project activity, Lucky Cement
considered a 6 month tenor average KIBOR of 13.21% for October 2010
5
and assumed a credit spread of
200 basis points which was based on a loan offer extended to Lucky Cement by a local bank in Pakistan
6
.
The benchmark thus evaluated was (13.21% + 2.0%) 15.21%.

4
Press release by State Bank of Pakistan: http://www.sbp.org.pk/press/2004/jan-21-04.pdf
Third Quarterly report of State Bank of Pakistan FY04:
http://sbp.org.pk/reports/quarterly/fy04/thirdQtr/Money%20Market.pdf
5
This is based on average KIBOR rate as available on October 20
th
for the month of October 2010. KIBOR rates
for October 2010 are available at the website of State Bank of Pakistan:
http://www.sbp.org.pk/ecodata/kibor/2010/Oct/index.asp
6
Habib Metropolitan Bank Limited loan offer letter to Lucky Cement
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Calculation and comparison of the project IRR with the selected benchmark

The following general assumptions have been made to calculate the project IRR of the project activity:

Table B.5.2: General assumptions for project IRR calculation
General Information Value Unit Source of data
Exchange rate to PKR 120.1 PKR
Feasibility Study: Exchange rate EURO
to PKR on October 20, 2010
www.xe.com as on
Exchange rate $ to PKR 86.00 PKR
Feasibility Study (Exchange rate USD
to PKR on October 20, 2010
http://www.forex.pk/currency-
converter.php?send=Y)
Depreciation period 20 years
Operational technical lifetime of the
project plant(letter from the equipment
supplier)
Technical lifetime of the plant 20 years
Operational technical lifetime of the
project plant(letter from the equipment
supplier)
Tax on net income 35 % Income Tax Ordinance
Total project investment 1,037,140,283 PKR Feasibility study
Operational & maintenance cost 10,371,403 PKR
O&M Cost guarantee letter from the
supplier
Percentage of project loan 100 % Bank Loan Offer Letter
Loan period 7 Years Bank Loan Offer Letter
Grace period 2 Years Bank Loan Offer Letter
Clinker Production 3,385,800 Tons/yr Feasibility Study
Coal consumption at the baseline
scenario
443,426 Tons/yr
Feasibility Study
Coal consumption at the project
scenario
221,713 Tons/yr
Feasibility Study
Coal Cost 10,798 PKR/ton London Commodity News Letter
Rice Husk Cost 5,650 PKR/ton Quotation from the Rice Husk supplier
TDF Cost 11,724 PKR/ton Quotation from the TDF supplier
RDF Cost 6,240 PKR/ton Quotation from the RDF supplier

The total investment amount to implement the project is 1,037,140,283 PKR. This includes cost of TDF
plant, RDF plant and purchasing of local components for the project activity. As the analysis period
corresponds to the depreciation period of 20 years, the fair value of the project investments will be 0 at
the end of the analysis period
7
. Depreciation and financial expenses are only used for tax calculation and
added back to net profits for the calculation of the project IRR.
The Operation and Maintenance (O&M) Costs considered for the project activity is 10,371,403 PKR per
annum which represent 1% of the total investment costs
8
.

7
Operational guarantee letter from the equipment supplier
8
Operation and Maintenance Cost letter from the equipment supplier
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The resulting project IRR of the project saving potential by introducing the project activity is very low
and it is in negative. As the benchmark is determined at 15.21%, the project activity would not be
implemented. Considering the CER revenues, the project IRR would come up to 15.60% and so gets an
economically attractive investment option for project proponent.

Sensitivity analysis

To show the robustness of the results, a sensitivity analysis is carried out for the variation (+/- 10%) of the
decisive variables of the project activity. These are the initial project investment, coal cost and alternate
fuel cost. The results of the sensitivity analysis are shown in Table B.5.3.

Table B.5.3: Sensitivity analysis
Project Investment -10% Base Case 10%
Net Saving Cash Flow w/o CER - - -
Benchmark 15.21% 15.21% 15.21%
Break Even Point -89.55%

Coal Cost -10% Base Case 10%
Net Saving Cash Flow w/o CER - - 14.57%
Benchmark 15.21% 15.21% 15.21%
Break Even Point 10.29%

Alternate Fuel Cost -10% Base Case 10%
Net Saving Cash Flow w/o CER 15.00% - -
Benchmark 15.21% 15.21% 15.21%
Break Even Point -10.09%

The sensitivity analysis shows that the results are robust; even a variation of +/- 10% in the project
investment, coal cost and alternate fuel cost do not make the project economically additional without the
CDM benefits. For the project investment, the limit of additionality is situated at a total investment cost
decrease of 89.55%. This in the present project highly unlikely. For the coal cost, the limit of additionality
is situated at a coal cost increase of 10.29%, which is highly unlikely in the current scenario. Likewise a
decrease of 10.09% in alternate fuel cost will turn the project financially attractive without the CER
revenue. This in the present scenario is highly unlikely.

Outcome of step 3:

Hence as explained in the investment analysis, the project activity would not be economically attractive
without the consideration of the CER revenue and would not be realised.

Hence Alternative 1 (F1, W6, B6): The proposed project activity not undertaken as a CDM project
activity is not a financially viable option.

Therefore, Alterative 2 (F2, W3, B1 and B3): Continuation of current practice (i.e., a scenario in which
the company continues cement production using the existing technology, materials and fuel mix,
municipal solid waste is disposed at a managed or unmanaged landfill and the continuation of dumping of
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biomass residue (rice husk) under aerobic condition and burning biomass residues in an uncontrolled
manner) is the only plausible baseline scenario.


Step 4: Common practice analysis

Geographical area for the assessment of common practice in Pakistan is the cement industry of Pakistan.
The common practice in Pakistan at the other 28 cement plants is the use of fossil fuels for clinker
production. Use of alternative fuels on such large scale has never been attempted by any cement factory
in Pakistan (except by DG Cement, which is also a CDM based project) which shows that the project
activity is not a common practice in the region. This has been confirmed by All Pakistan Cement
Manufacturers Association (APCMA) that the proposed CDM project activity at Lucky Cement Karachi
Plant is among the first of its kind in the cement industry of Pakistan in terms of size, installation of fully
automatic equipment, and environment friendly technological features.

As per the latest Guidelines on the common practice (version 01.0)
9
common practice can be
demonstrated as below:

Step 1: Lucky Cement Karachi Plant produced 3,428,571 tons of clinker in June 2009
10
. If we take +50%
and -50% of the clinker production then the applicable range will become 1,714,286 - 5,142,857 tons per
year clinker production.

Step 2: In the project activity applicable geographical area is taken as the host country. There are total 28
cement plants in the host country. Out of these, there are 9 cement plants in the geographical area that
come in the applicable range of 1,714,286 - 5,142,857 tons per year.

N
all
= 9

Step 3: Within the plants identified in step 2 those plants that apply different technology other than the
project activity.

N
diff
= 8

Step 4:
F = 1 - (N
diff
/ N
all
)
F = 0.11

N
diff
- N
all =
1

Outcome of step 4:

F is less than 0.2
N
diff
- N
all
is less than 3


9
Annex 12 of EB 65
10
Source: Ministry of Industries
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Since both factors F and difference of N
diff
N
all
are less than 0.2 and 3, respectively, this project activity
is not a common practice
11
.

In view of the investment, sensitivity and common practice analyses provided above, it can be concluded
that project activity is additional i.e. CDM income is necessary for the implementation of the project and
without CDM income the project would not have been implemented.

B.6. Emission reductions:

B.6.1. Explanation of methodological choices:

The emission reductions of the project activity were calculated according to the methodology ACM0003
(version 7.4)

Project emissions

Project emissions include project emissions from the use of alternative fuels (PE
k,y
), project emissions
from additional electricity and/or fossil fuel consumption as a result of the project activity (PE
EC,y
andPE
FC,y
), project emissions from combustion of fossil fuels for transportation of alternative fuels to the
project plant (PE
T,y
), and, if applicable, project emissions from the cultivation of renewable biomass at the
dedicated plantation (PE
BC,y
):

y , BC y , T y , EC y , FC y , k y
PE PE PE PE PE PE (1)

Where:

PE
y
= Project emissions during the year y (tCO
2
e)
PE
k,y
= Project emissions from combustion of alternative fuels in the project plant in year y
(tCO
2
)
PE
FC,y
= Project emissions from additional fossil fuel combustion as a result of the project
activity in year y (tCO
2
)
PE
EC,y
= Project emissions from additional electricity consumption as a result of the project
activity in year y (tCO
2
)
PE
T,y
= CO
2
emissions during the year y due to transport of alternative fuels to the project plant
(tCO
2
)
PE
BC,y
= Project emissions from the cultivation of renewable biomass at the dedicated plantation
in year y (tCO
2
e)



11
Detailed common practice analysis as per the guidelines on common practice (version 01.0) will be provided to
DOE during validation
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Project emissions are calculated in the following steps:

Step 1. Calculate project emissions from the use of alternative fuels.
Step 2. Calculate project emissions from additional electricity and/or fossil fuel consumption as a result
of the project activity.
Step 3. Calculate project emissions from combustion of fossil fuels for transportation of alternative fuels
to the project plant.
Step 4. Calculate project emissions from the cultivation of renewable biomass at the dedicated plantation.

Step 1: Calculate project emissions from the use of alternative fuels and/or less carbon intensive fossil
fuels

In case of project activity:

Project emissions from the use of alternative fuels in the project plant are calculated as follows:

k
y k, CO2, y k, y k, PJ, y k,
EF NCV FC PE (2)

Where:
PE
k,y
= Project emissions from combustion of alternative fuels in the project plant in year y
(tCO
2
)
FC
PJ,k,y
= Quantity of alternative fuel type k used in the project plant in year y (tons)
EF
CO2,k,y
= Carbon dioxide emissions factor for alternative fuel type k in year y (tCO
2
/GJ)
NCV
k,y
= Net calorific value of the alternative fuel type k in year y (GJ/tonne)
k = Alternative fuel types used in the project plant in year y

Step 2: Calculate project emissions from additional electricity and/or fossil fuel consumption as a
result of the project activity

The use of alternative fuels or less carbon intensive fossil fuels may result in additional fossil fuel and/or
electricity consumption at the project site or off-site. This may include, inter alia, the following emission
sources:

Drying or mechanical treatment of the fuels;
On-site transportation of the fuels;
Flue gas treatment required as a result of the project activity.

CO
2
emissions from on-site combustion of fossil fuels (PE
FC,y
) should be calculated using the latest
approved version of the Tool to calculate project or leakage CO
2
emissions from fossil fuel combustion.
For each fossil emission source j, the fuel consumption of each fuel type i (FC
i,j,y
) should be monitored,
consistent with the guidance in the tool.

In case of Project Activity:

There is no fossil fuel consumption at the project plant, so no emissions can be associated with the
combustion of fossil fuels.
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CO
2
emissions from on-site electricity consumption (PE
EC,y
) have been calculated using the latest
approved version of the Tool to calculate baseline, project and/or leakage emissions from electricity
consumption.

In case of Project Activity:

The following equation is used according to the tool for the calculation of Project Emissions due to
electricity consumption

Where:

PE
EC,y
= Project emissions from electricity consumption in year y (tCO
2
/yr)
EC
PJ,j,y
= Quantity of electricity consumed by the project electricity consumption source j in year y
(MWh/yr)
EF
EL,j,y
= Emission factor for electricity generation for source j in year y (tCO
2
/MWh)
TDL
j,y
= Average technical transmission and distribution losses for providing electricity to source j in
year y
12


The Emission Factor for electricity generation source has to be chosen using one of the 3 scenarios
mentioned in the tool.

Since there is a fossil fuel fired captive power plant installed at the site of electricity consumption and the
plant is not connected to the grid, Scenario B is identified as the most plausible scenario for the
determination of the emission factor for electricity generation.

Step 3: Project emissions from combustion of fossil fuels for transportation of alternative fuels to the
project plant

CO
2
emissions resulting from transportation of alternative fuels to the project plant are determined in this
step. In the case of project activity transportation is undertaken by vehicles (trucks). Project participant
has chosen an approach based on distance and vehicle type (Option 1).

Option 1:

y km,CO2, y
y
k
y k, T,
y T,
EF AVD
TL
AF
PE (4)

Where:
PE
T,y
= CO
2
emissions during the year y due to transport of alternative fuels to the project plant
(tCO
2
/yr)

12
Taken as 0% as mentioned in the Tool to calculate baseline, project and/or leakage emissions from electricity
consumption (Version 01). This is the default value for scenario B.
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N
y
= Number of truck trips during the year y
AVD
y
= Average round trip distance (from and to) between the alternative fuel supply sites and
the site of the project plant during the year y (km)
EF
km,CO2,y
= Average CO
2
emission factor for the trucks measured during the year y (tCO
2
/km)
AF
T,k,y
= Quantity of alternative fuel type k that has been transported to the project site during the
year y (mass or volume units)
TL
y
= Average truck load of the trucks used (tons or liter) during the year y
k = Types of alternative fuels used in the project plant and that have been transported to the
project plant in year y

Step 4: Calculate project emissions from the cultivation of renewable biomass at the dedicated
plantation


This step is not applicable in our case as renewable biomass is not used in our Project activity.

Baseline emissions

The project reduces CO
2
emissions by using alternative fuels in the pre-calciner and the kiln for the
production of clinker in cement manufacture. The project also reduces CH
4
emissions from preventing
disposal of biomass residues. Baseline emissions are calculated as follows:

y biomass, CH4, y FF, y
BE BE BE (7)

Where:
BE
y
= Baseline emissions in year y (tCO
2
)
BE
FF,y
= Baseline emission from fossil fuels displaced by alternative fuels in year y (tCO
2
)
BE
CH4,biomass,y
= Baseline methane emissions avoided during the year y from preventing disposal or
uncontrolled burning of biomass residues (tCO
2
e)

Baseline emissions are determined in the following steps:

Step 1. Estimate the project specific fuel penalty.
Step 2. Calculate baseline emissions from the fossil fuels displaced by the alternative fuel(s).
Step 3. Calculate baseline emissions from decay, dumping or burning of biomass residues.

Step 1: Estimate the project specific fuel penalty

This project specific fuel penalty (FP
y
) has been determined as follows:

) SEC (SEC P FP
BL clinker, y PJ, clinker, y clinker, y
(8)
Where:
FP
y
= Fuel penalty in year y (GJ)
P
clinker,y
= Production of clinker in year y (tons)
SEC
clinker,PJ,y
= Specific energy consumption of the project plant in year y (GJ/t clinker)
SEC
clinker,BL
= Specific energy consumption of the project plant in the absence of the project
activity (GJ/t clinker)
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The specific energy consumption in the project is calculated based on the quantity of all fuels used in the
project plant and the quantity of clinker produced in year y, as follows:
y clinker,
k
y , k y , k , PJ
i
y i, y PJ,i,
y PJ, clinker,
P
NCV FC NCV FC
SEC
(9)

Where:
SEC
clinker,PJ,y
= Specific energy consumption of the project plant in year y (GJ/t clinker)
FC
PJ,i,y
= Quantity of fossil fuel type i fired in the project plant in year y (tons)
NCV
i,y
= Net calorific value of the fossil fuel type i in year y (GJ/ton)
FC
PJ,k,y
= Quantity of alternative fuel type k used in the project plant in year y (tons)
NCV
k,y
= Net calorific value of the alternative fuel type k in year y (GJ/tonne)
P
clinker,y
= Production of clinker in year y (tons)
k = Alternative fuel types used in the project plant in year y
i = Fossil fuel types used in the project plant in year y that are not less carbon intensive
fossil fuel types

As a conservative approach, the specific energy consumption in the absence of the project activity has
been calculated as the lowest annual ratio of fuel input per clinker production among the most recent three
years (July 2007 June 2010) prior to the start of the project activity, as follows:

2 x clinker,
2 x
1 - x clinker,
1 - x
x clinker,
x
BL clinker,
P
HG
;
P
HG
;
P
HG
MIN SEC (10)

With
i
i
x i, x
NCV FC HG (11)

Where:
SEC
clinker,BL
= Specific energy consumption of the project plant in the absence of the project activity
(GJ/t clinker)
HG
x
= Heat generated from fuel combustion in the project plant in the historical year x (GJ)
FC
i,x
= Quantity of fossil fuel type i used in the project plant in year x (tons)
NCV
i
= Net calorific value of the fossil fuel type i (GJ/ton)
P
clinker,x
= Production of clinker in year x (tons)
x = Year prior to the start of the project activity
i = Fossil fuel types used in the project plant in the last three years prior to the start of the
project activity


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Step 2: Calculate baseline emissions from the fossil fuels displaced by the alternative or less carbon
intensive fuel(s)

Baseline emissions from displacement of fossil fuels are calculated as follows:

y BL, CO2, , , , y FF,
EF BE
y
k
y k y k PJ
FP NCV FC (12)

Where:
BE
FF,y
= Baseline emission from fossil fuels displaced by alternative fuels in year y (tCO
2
)
FC
PJ,k,y
= Quantity of alternative fuel type k used in the project plant in year y (tons)
NCV
k,y
= Net calorific value of the alternative fuel type k in year y (GJ/tonne)
FP
y
= Fuel penalty in year y (GJ)
EF
CO2,BL,y
= Carbon dioxide emissions factor for the fossil fuels displaced by the use of alternative
fuels in the project plant in year y (tCO
2
/GJ)
k = Alternative fuel types used in the project plant in year y

The baseline emission factor (EF
CO2,BL,y
) is estimated as the lowest of the following CO
2
emission factors
for Case A and B (Case C is not applicable to the project activity as F3 is not a plausible baseline
scenario):

A. The weighted average CO
2
emission factor for the fossil fuel(s) consumed during the most recent
three years before the start of the project activity, calculated as follows:

i
i x i, 1 x i, 2 x i,
i
i FF, CO2, i x i, 1 x i, 2 x i,
y BL, CO2,
NCV FC FC FC
EF NCV FC FC FC
EF (13)

Where:
EF
CO2,BL,y
= Carbon dioxide emissions factor for the fossil fuels displaced by the use of
alternative fuels in the project plant in year y (tCO
2
/GJ)
FC
i,x
= Quantity of fossil fuel type i used in the project plant in year x (tons)
NCV
i
= Net calorific value of the fossil fuel type i (GJ/ton)
EF
CO2,FF,i
= CO
2
emission factor for fossil fuel type i (tCO
2
/GJ)
x = Year prior to the start of the project activity
i = Fossil fuel types used in the project plant in the last three years prior to the start
of the project activity

B. The weighted average annual CO
2
emission factor of the fossil fuel(s) that are not less carbon
intensive fossil fuels and that are used in the project plant in year y, calculated as follows:

i
i, , ,
i
y i, FF, CO2, y i, , ,
y BL, CO2,
NCV
EF NCV
EF
y y i PJ
y i PJ
FC
FC
(14)

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Where:
EF
CO2,BL,y
= Carbon dioxide emissions factor for the fossil fuels displaced by the use of
alternative fuels in the project plant in year y (tCO
2
/GJ)
FC
PJ,i,y
= Quantity of fossil fuel type i fired in the project plant in year y (tons)
NCV
i,y
= Net calorific value of the fossil fuel type i in year y (GJ/ton)
EF
CO2,FF,i,y
= Carbon dioxide emission factor for fossil fuel type i in year y (tCO
2
/GJ)
i = Fossil fuel types used in the project plant in year y that are not less carbon
intensive fossil fuel types


Step 3: Calculate baseline emissions from decay, dumping or burning of biomass residues

Baseline emissions from decay, dumping or burning of biomass residues are calculated as follows:

y , 2 B , 4 CH y , 3 B / 1 B , 4 CH y , biomass , 4 CH
BE BE BE (16)

Where:


BE
CH4,biomass,y
= Baseline methane emissions avoided during the year y from preventing disposal
or uncontrolled burning of biomass residues (tCO
2
e)
BE
CH4,B1/B3,y
= Baseline methane emissions avoided during the year y from aerobic decay
and/or uncontrolled burning of biomass residues (tCO
2
e)
BE
CH4,B2,y
= Baseline methane emissions avoided during the year y from anaerobic decay of
biomass residues at a solid waste disposal site (tCO
2
e)


In case of Project Activity:

The baseline methane emissions are avoided from aerobic decaying of the biomass residues. So, only
BE
CH4,B1/B3,y
has to be calculated.
Whereas baseline methane emissions are not avoided from anaerobic decay of biomass so BE
CH4,B2,y
= 0.

Baseline emissions avoided from aerobic decay and/or uncontrolled burning of biomass residues are
calculated as follows:

y k, 4, burning,CH y k,
k
y k, PJ, CH4 y B1/B3, CH4,
EF NCV FC GWP BE
(17)
Where:
BE
CH4,B1/B3,y
= Baseline methane emissions avoided during the year y from aerobic decay and/or
uncontrolled burning of biomass residues (tCO
2
e)
GWP
CH4
= Global Warming Potential of methane valid for the commitment period (tCO
2
e/tCH
4
)
FC
PJ,k,y
= Quantity of alternative fuel type k used in the project plant in year y (tons)
NCV
k,y
= Net calorific value of the alternative fuel type k in year y (GJ/tonne)
EF
burning,CH4,k,y
= CH
4
emission factor for uncontrolled burning of the biomass residue type k during
the year y (tCH
4
/GJ)
k = Types of biomass residues used as alternative fuel in the project plant in year y for
which the identified baseline scenario is B1 or B3 and for which leakage effects
could be ruled out with one of the approaches L
1
, L
2
or L
3
described in the leakage
section
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To determine the CH
4
emission factor, referenced default values have been used. In our scenario the
default value of 0.0027 tCH
4
/ton biomass is used for the product of NCV
k
and EF
burning,CH4,k,y
and the
uncertainty is deemed to be greater than 100%, thus resulting in a conservativeness factor of 0.73 (See
table B.6.1.1). Thus, in this case, an emission factor of 0.001971 t CH
4
/t biomass is used.

Table B.6.1.1: Conservativeness factors
Estimated uncertainty range (%)
Assigned
uncertainty band
(%)
Conservativeness factor where
lower values are more
conservative
Less than or equal to 10 7 0.98
Greater than 10 and less than or equal to 30 20 0.94
Greater than 30 and less than or equal to 50 40 0.89
Greater than 50 and less than or equal to 100 75 0.82
Greater than 100 150 0.73

Leakage emissions

Leakage emissions are calculated as follows:

y , upstream , FF y , BR y
LE LE LE (18)

Where:
LE
y
= Leakage emissions during the year y (tCO
2
e/yr)
LE
BR,y
= Leakage emissions related to the use of biomass residues during the year y (tCO
2
)
LE
FF,upstream,y
= Upstream leakage emissions from fossil fuel use in year y (tCO
2
e)

Leakage emissions are calculated in two steps:

Step 1. Calculation of leakage emissions related to the use of biomass residues.
Step 2. Calculation of upstream leakage emissions from fossil fuel use.

Step 1: Calculation of leakage emissions related to the use of biomass residues

In case of Project Activity:
As the quantity of available biomass residue is at least 25% larger than the quantity of biomass residue
utilized in the region, approach L
2
is used to demonstrate that there are no leakages associated with the
project activity.


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Step 2: Calculation of upstream leakage emissions from fossil fuel use

Upstream leakage emissions from fossil fuel use are calculated as follows:

y CO2, LNG, y CH4, y upstream, FF,
LE LE LE (20)

Where:
LE
FF,upstream,y
= Upstream leakage emissions from fossil fuel use in year y (tCO
2
e)
LE
CH4,y
= Leakage emissions due to fugitive upstream CH
4
emissions in the year y (t CO
2
e)
LE
LNG,CO2,y
= Leakage emissions due to fossil fuel combustion / electricity consumption associated
with the liquefaction, transportation, re-gasification and compression of LNG into a
natural gas transmission or distribution system during the year y (t CO
2
e)

Fugitive methane emissions

For the purpose of determining fugitive methane emissions associated with the production and in case
of natural gas, the transportation and distribution of the fuels the following equation is used:
CH4 CH4 upst ream, i, y i,
i
y i, BL,
k
CH4 upst ream, k, y k, y k, PJ, y CH4,
GWP EF NCV FC EF NCV FC LE (21)

Where:
LE
CH4,y
= Leakage emissions due to fugitive upstream CH
4
emissions in the year y (t CO
2
e)
FC
PJ,k,y
= Quantity of less carbon intensive fossil fuel type k used in the project plant in year y
(mass or volume unit)
FC
BL,i,y
= Quantity of fossil fuel type i displaced in the project plant as a result of the project
activity in year y (mass or volume unit)
NCV
k,y
= Net calorific value of less carbon intensive fossil fuel type k in year y (GJ/mass or
volume unit)
NCV
i,y
= Net calorific value of fossil fuel type i in year y (GJ/mass or volume unit)
EF
k,upstream,CH4
= Emission factor for upstream fugitive methane emissions from production,
transportation and distribution of less carbon intensive fuel type k (t CH
4
/ GJ)
EF
i,upstream,CH4
= Emission factor for upstream fugitive methane emissions from production,
transportation and distribution of fossil fuel type i (t CH
4
/ GJ)
GWP
CH4
= Global warming potential of methane valid for the relevant commitment period
k = Less carbon intensive fossil fuel types used in the project plant in year y
i = Fossil fuel types displaced in the project plant as a result of the use of alternative fuels
or less carbon intensive fossil fuels under the project activity

Where reliable and accurate national data on fugitive CH
4
emissions associated with the production, and
in case of natural gas, the transportation and distribution of the fuels is available, project participants
should use this data to determine average emission factors by dividing the total quantity of CH
4
emissions
by the quantity of fuel produced or supplied respectively.
13



13
GHG inventory data reported to the UNFCCC as part of national communications can be used where country-
specific approaches (and not IPCC Tier 1 default values) have been used to estimate emissions.
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As reliable and accurate national data on fugitive CH
4
emissions associated with the production, and in
case of natural gas, the transportation and distribution of the fuels is not available; the default values
provided in Table B.6.1.2 below are used.

Table B.6.1.2: Default emission factors for fugitive CH
4
upstream emissions

CO
2
emissions from LNG

As LNG is not used in the project activity, therefore LE
FF,upstream,y
= 0.


Activity Unit
Default
emission
factor
Reference for the underlying emission
factor range in Volume 3 of the 1996
Revised IPCC Guidelines
Coal
Underground mining t CH4 / kt coal 13.4 Equations 1 and 4, p. 1.105 and 1.110
Surface mining t CH4 / kt coal 0.8 Equations 2 and 4, p.1.108 and 1.110
Oil
Production t CH4 / PJ 2.5 Tables 1-60 to 1-64, p. 1.129 - 1.131
Transport, refining and storage t CH4 / PJ 1.6 Tables 1-60 to 1-64, p. 1.129 - 1.131
Total t CH4 / PJ 4.1
Natural gas
USA and Canada
Production t CH4 / PJ 72 Table 1-60, p. 1.129
Processing, transport and distribution t CH4 / PJ 88 Table 1-60, p. 1.129
Total t CH4 / PJ 160
Eastern Europe and former USSR
Production t CH4 / PJ 393 Table 1-61, p. 1.129
Processing, transport and distribution t CH4 / PJ 528 Table 1-61, p. 1.129
Total t CH4 / PJ 921
Western Europe
Production t CH4 / PJ 21 Table 1-62, p. 1.130
Processing, transport and distribution t CH4 / PJ 85 Table 1-62, p. 1.130
Total t CH4 / PJ 105
Other oil exporting countries / Rest of world
Production t CH4 / PJ 68 Table 1-63 and 1-64, p. 1.130 and 1.131
Processing, transport and distribution t CH4 / PJ 228 Table 1-63 and 1-64, p. 1.130 and 1.131
Total t CH4 / PJ 296
Note: The emission factors in this table have been derived from IPCC default Tier 1 emission factors provided in Volume 3 of the 1996 Revised
IPCC Guidelines, by calculating the average of the provided default emission factor range.
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Emission Reductions
Emission reductions are calculated as follows:

y y y y
LE PE BE ER (24)

Where:
ER
y
= Emission reductions during the year y (tCO
2
/yr)
BE
y
= Baseline emissions during the year y (tCO
2
e/yr)
PE
y
= Project emissions during the year y (tCO
2
e/yr)
LE
y
= Leakage emissions during the year y (tCO
2
e/yr)

B.6.2. Data and parameters that are available at validation:

Data / Parameter: FC
impcoal,2009

Data unit: tons
Description: Quantity of imported coal used in the kilns in financial year 2009-2010
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 440,286
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :
Coal is measured at coal feeding end, using weigh feeder. It is recorded daily.
Any comment:

Data / Parameter: FC
impcoal,2008

Data unit: tons
Description: Quantity of imported coal used in the kilns in financial year 2008-2009
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 360,679
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :
Coal is measured at coal feeding end, using weigh feeder. It is recorded daily.
Any comment:

Data / Parameter: FC
impcoal,2007

Data unit: tons
Description: Quantity of imported coal used in the kilns in financial year 2007-2008
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 291,097
Justification of the
choice of data or
description of
Coal is measured at coal feeding end, using weigh feeder. It is recorded daily.
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measurement methods
and procedures
actually applied :
Any comment:

Data / Parameter: FC
Local coal,2009

Data unit: tons
Description: Quantity of local coal used in the kilns in financial year 2009-2010
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 0
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :
Coal is measured at coal feeding end, using weigh feeder. It is recorded daily.
Any comment:

Data / Parameter: FC
local coal,2008

Data unit: tons
Description: Quantity of local coal used in the kilns in financial year 2008-2009
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 4,945
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :
Coal is measured at coal feeding end, using weigh feeder. It is recorded daily.
Any comment:

Data / Parameter: FC
local coal,2007

Data unit: tons
Description: Quantity of local coal used in the kilns in financial year 2007-2008
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 1,303
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :
Coal is measured at coal feeding end, using weigh feeder. It is recorded daily.
Any comment:

Data / Parameter: FC
HFO,2009

Data unit: tons
Description: Quantity of HFO used in the kilns in financial year 2009-2010
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Source of data used: Data from fuel consumption data logs at the project site
Value applied: 440
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :
Coal is measured at coal feeding end, using weigh feeder. It is recorded daily.
Any comment:

Data / Parameter: FC
HFO,2008

Data unit: tons
Description: Quantity of HFO used in the kilns in financial year 2008-2009
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 644
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
HFO,2007

Data unit: tons
Description: Quantity of HFO used in the kilns in financial year 2007-2008
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 385
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: P
clinker,2009

Data unit: tons
Description: Production of clinker in financial year 2009-2010
Source of data used: Data from production data logs at the project site
Value applied: 3,149,163
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

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Any comment:

Data / Parameter: P
clinker,2008

Data unit: tons
Description: Production of clinker in financial year 2008-2009
Source of data used: Data from production data logs at the project site
Value applied: 2,643,195
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: P
clinker,2007

Data unit: tons
Description: Production of clinker in financial year 2007-2008
Source of data used: Data from production data logs at the project site
Value applied: 2,107,290
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Parameter: NCV
Imported Coal

Data unit: GJ/ton
Description: Net calorific value of coal used in the kilns in the last three years prior to the
start of the project activity
Source of data: Coal test reports
Value applied: 25.00
Measurement
procedures (if any):
-
Any comment:

Parameter: NCV
Local Coal

Data unit: GJ/ton
Description: Net calorific value of coal used in the kilns in the last three years prior to the
start of the project activity
Source of data:
Value applied: 24.54
Measurement
procedures (if any):
-
Any comment:
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Parameter: EF
CO2,FF,Imported Coal

Data unit: tCO
2
/GJ
Description: Weighted average CO
2
emission factor for imported and local coal used in the
kilns in the last three years prior to the start of the project activity
Source of data: IPCC default values
Value applied: 0.0895
Measurement
procedures (if any):

Any comment: Lower value has been taken to be on the conservative side.

Parameter: EF
CO2,FF,Local Coal

Data unit: tCO
2
/GJ
Description: Weighted average CO
2
emission factor for imported and local coal used in the
kilns in the last three years prior to the start of the project activity
Source of data: IPCC default values
Value applied: 0.0895
Measurement
procedures (if any):

Any comment: Lower value has been taken to be on the conservative side.


Parameter: EF
CO2,FF,HFO

Data unit: tCO
2
/GJ
Description: Weighted average CO
2
emission factor for HFO used in the kilns in the last
three years prior to the start of the project activity
Source of data: IPCC default values
Value applied: 0.0788
Measurement
procedures (if any):

Any comment: Higher value has been taken to be on the conservative side.

Parameter: EG
captive power plant, 2007

Data unit: MWh
Description: Quantity of electricity generation from the captive power plant in financial year
2007-2008
Source of data: Data from power generation report
Value applied: 228,161
Measurement
procedures (if any):

Any comment:

Parameter: EG
captive power plant, 2008

Data unit: MWh
Description: Quantity of electricity generation from the captive power plant in financial year
2008-2009
Source of data: Data from power generation report
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Value applied: 281,454
Measurement
procedures (if any):

Any comment:

Parameter: EG
captive power plant, 2009

Data unit: MWh
Description: Quantity of electricity generation from the captive power plant in financial year
2009-2010
Source of data: Data from power generation report
Value applied: 303,137
Measurement
procedures (if any):

Any comment:

Parameter: EG
WHR power plant, 2009

Data unit: MWh
Description: Quantity of electricity generation from the waste heat recovery power plant in
financial year 2009-2010
Source of data: Data from power generation report
Value applied: 28,194
Measurement
procedures (if any):

Any comment:

Data / Parameter: FC
HFO,2007

Data unit: tons
Description: Quantity of HFO used in the captive power plant in financial year 2007-2008
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 14,625
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
HFO,2008

Data unit: tons
Description: Quantity of HFO used in the captive power plant in financial year 2008-2009
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 6,343
Justification of the
choice of data or
description of
measurement methods

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and procedures
actually applied :
Any comment:

Data / Parameter: FC
HFO,2009

Data unit: tons
Description: Quantity of HFO used in the captive power plant in financial year 2009-2010
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 4,586
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
NG,2007

Data unit: Nm
3

Description: Quantity of NG used in the captive power plant in financial year 20072008
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 51,564,262
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
NG,2008

Data unit: Nm
3

Description: Quantity of NG used in the captive power plant in financial year 2008-2009
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 78,490,821
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
NG,2009

Data unit: Nm
3

Description: Quantity of NG used in the captive power plant in financial year 2009-2010
Source of data used: Data from fuel consumption data logs at the project site
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Value applied: 86,893,165
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
DI,2007

Data unit: Ltr
Description: Quantity of Diesel used in the captive power plant in financial year 2007-2008
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 80,189
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
DI,2008

Data unit: Ltr
Description: Quantity of Diesel used in the captive power plant in financial year 2008-2009
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 59,667
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:

Data / Parameter: FC
DI,2009

Data unit: tons
Description: Quantity of Diesel used in the captive power plant in financial year 2009-2010
Source of data used: Data from fuel consumption data logs at the project site
Value applied: 44,955
Justification of the
choice of data or
description of
measurement methods
and procedures
actually applied :

Any comment:
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B.6.3. Ex-ante calculation of emission reductions:

The methodological approach applied, justifications of the choices and the methodological equations
applicable to the project activity are explained in detail in the Section B.6.1. A brief step-wise calculation
of emission reductions is provide below:

Baseline emissions
Baseline emissions are calculated as follows:

y biomass, CH4, y FF, y
BE BE BE

Specific fuel penalty is calculated as zero.

FP
y
= 0 tCO
2
/year

Baseline emissions from the fossil fuels displaced by the alternative

BE
FF,y
= 495,005 tCO
2
/year

Baseline emissions from the decay, dumping of biomass residues

BE
CH4,biomass,y
= 1,814 tCO
2
/year

BE
y
= 495,005 + 1,814 tCO
2
/year
BE
y
= 496,819 tCO
2
/year

Project emissions

Project emissions are calculated as follows.

y , BC y , T y , EC y , FC y , k y
PE PE PE PE PE PE

Project emissions due to use of alternative fuels (PE
k,y
),

PE
k,y
= 287,821 tCO
2
/year

As no fossil fuels are used in the project activity hence PE
FC,y
is taken as zero.

As no additional electricity is consumed in the project activity hence it is calculated as zero.

PE
EC,y
= 0

Project emissions from combustion of fossil fuels for transportation of alternative fuels to the project
plant (PE
T,y
):

PE
T,y
= 515

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As the project activity does not use any biomass from dedicated plantation so PE
BC,y
is

not applicable.

Total project emissions,

PE
y
= 287,821+ 0 + 0 + 515 tCO
2
/year

PE
y
= 288,335 tCO
2
/year

Leakage

As there is surplus availability of biomass in the region and the project activity does not use LNG,
leakage emissions are taken as zero

LE
y
= 0 tCO
2
/yr

Emission Reductions

Emission reductions are calculated as follows:

2 y y y y
484 , 208 0 288,335 819 , 496 LE PE BE ER tCO

Estimated annual average emission reduction for the project activity is 208,484 tCO
2
/ year.

B.6.4 Summary of the ex-ante estimation of emission reductions:

The annual & total estimation of emission reductions for the fixed crediting period of 10 years starting
from July 01, 2012 is provided below:

Table B.6.4.1: Ex-ante Estimation of Emission Reductions
Year
Estimation of
project activity
emissions
(tonnes of CO
2
e)
Estimation of
baseline
emissions
(tonnes of CO
2
e)
Estimation of
leakage
(tonnes of CO
2
e)
Estimation of
overall emission
reductions
(tonnes of CO
2
e)
Year 1 288,335 496,819 0 208,484
Year 2 288,335 496,819 0 208,484
Year 3 288,335 496,819 0 208,484
Year 4 288,335 496,819 0 208,484
Year 5 288,335 496,819 0 208,484
Year 6 288,335 496,819 0 208,484
Year 7 288,335 496,819 0 208,484
Year 8 288,335 496,819 0 208,484
Year 9 288,335 496,819 0 208,484
Year 10 288,335 496,819 0 208,484
Total
(tonnes of CO
2
e)
2,883,350 4,968,190 0 2,084,840

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B.7. Application of the monitoring methodology and description of the monitoring plan:

B.7.1 Data and parameters monitored:

Data / Parameter: FC
PJ,k,y

Data unit: tons
Description: Quantity of alternate fuel used in the project plant in year y
Source of data to be
used:
Internal records of Lucky Cement Limited
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Fuel Name Amount
RDF 63,608
TDF 153,214
Rice Husk 43,836
Description of
measurement methods
and procedures to be
applied:
Data type: Difference of cumulated values
Monitoring Instrument:Screw Weigh Feeder
Manufacturer: Schenck
Model: Multiflex-A20-25
Range:3-15 TPH
Accuracy of the Instrument: 99.90% (error 0.10%)
Internal Calibration By: Instrument Department
External Calibration By: None
Calibration Frequency: Twice per year
Calibration Standard: Schenck Standard Calibration and Procedure
Recording Frequency: Daily
Recording Type: Paper and Electronic
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: FC
PJ,coal,y

Data unit: Tons
Description: Quantity of coal used in the project plant in year y
Source of data to be
used:
Internal records of Lucky Cement Limited
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Fuel Name Amount
Coal 221,713
Description of
measurement methods
and procedures to be
applied:
Data type: Difference of cumulated values
Monitoring Instrument:Coal Dosing System
Manufacturer: Schenck
Model: Multicore K-50
Range:0-15 TPH
Accuracy of the Instrument: 99.90% (error 0.10%)
Internal Calibration By: Instrument Department
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External Calibration By: None
Calibration Frequency: Twice per year
Calibration Standard: Schenck Standard Calibration and Procedure
Recording Frequency: Daily
Recording Type: Paper and Electronic
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: FC
PJ,HFO,y

Data unit: Tons
Description: Quantity of HFO used in the project plant in year y
Source of data to be
used:
Internal records of Lucky Cement Limited
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Fuel Name Amount
HFO 0
Description of
measurement methods
and procedures to be
applied:
Data type: Difference of cumulated values on energy meter
Monitoring Instrument:Unithrem oil firing system
Manufacturer: Endress& Hauser
Model: Promass - 80
Range: 0 180000 Kg/ H
Accuracy of the Instrument: 99.85% (error 0.15%)
Internal Calibration By: Instrument Department
External Calibration By: None
Calibration Frequency: Yearly
Calibration Standard: Endress and Hauser Calibration and Procedure
Recording Frequency: As per firing of HFO
Recording Type: Paper and Electronic
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment: HFO is used only for pre-heating purposes in both the project and baseline
scenario. The quantity of HFO consumed will remain the same in the project
activity. If HFO consumption during the project years is greater than the
historical average of 489 tons/year it will be considered as project emissions.

Data / Parameter: EF
CO2,FF,imported coal,y

Data unit: tCO
2
/GJ
Description: Weighted average CO
2
emission factor imported coal in year y
Source of data to be
used:
IPCC default values at the lower limit
14
of the uncertainty at a 95% confidence
interval as provided in table 1.4 of Chapter1 of Vol. 2 (Energy) of the 2006
IPCC Guidelines on National GHG Inventories

14
To be conservative, choose the upper limit where project emissions are calculated and the lower limit where
baseline emissions are calculated.
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Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
0.0895
Description of
measurement methods
and procedures to be
applied:
Local value is not available as Pakistan doesnt have any GHG inventory data.
Therefore, IPCC default value is used which is permissible by the applied
methodology.

QA/QC procedures to
be applied:

Any comment:

Data / Parameter: EF
CO2,k,y

Data unit: tCO
2
/GJ
Description: Weighted average CO
2
emission factor for alternate fuels in year y
Source of data to be
used:
EF
CO2,k,y
is zero for the following alternative fuels:
- Biomass residues;
For following alternate fuels, supplier values shall be used.
- Tyre waste/TDF
- RDF
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Fuel Type Emission Factor
Biomass Residues
(Rice Husk)
0
TDF 60.4
RDF 45.2
Description of
measurement methods
and procedures to be
applied:
Emission factors for RDF and TDF will be provided by the supplier.

Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Each Delivery
QA/QC procedures to
be applied:
.QMS procedures will be followed in recording and reporting of the parameter.
Any comment: Values reported by the supplier will kept in record for the entire crediting period

Data / Parameter: NCV
k,y

Data unit: GJ/ton
Description: Weighted average net calorific value of alternate fuels in year y
Source of data to be
used:
Supplier Value
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Fuel Type NCV
TDF 26.77
RDF 13.94
Rice Husk 12.64
Description of Net Calorific Value for alternate fuels will be provided by the supplier.
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measurement methods
and procedures to be
applied:

Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Each Delivery
QA/QC procedures to
be applied:
QMS procedures will be followed in recording and reporting of the parameter.
Any comment: Values reported by the supplier will kept in record for the entire crediting period

Data / Parameter: NCV
i,y

Data unit: GJ/ton
Description: Weighted average net calorific value of imported coal in year y
Source of data to be
used:
Supplier value
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

25.00
Description of
measurement methods
and procedures to be
applied:
Net Calorific Value (NCV) of the imported coal will be provided by the coal
supplier.

Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Each Delivery
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment: Values reported by the supplier will kept in record for the entire crediting period

Data / Parameter: EG
captive power plant, year

Data unit: MWh
Description: Quantity of electricity generated in the captive power plant
Source of data to be
used:
Internal records of Lucky Cement
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
For ex ante calculation, the value for this parameter has been taken as the sum
of the following years:


Year Electricity Generation
2007 2008 228,161
2008 2009 281,454
2009 2010 303,137


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Description of
measurement methods
and procedures to be
applied:
Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Monthly
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: EG
WHR Plant, year

Data unit: MWh
Description: Quantity of electricity generated by the waste heat recovery power plant
Source of data to be
used:
Internal records of Lucky Cement
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Year Electricity Generation
2009 2010 28,194
Description of
measurement methods
and procedures to be
applied:
Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Monthly
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment: The WHR plant commenced operation in February 2010


Data / Parameter: FC
captive power plant,NG,year

Data unit: Nm
3

Description: Natural Gas consumption in the captive power plant for the electricity used in
the project activity
Source of data to be
used:
Internal records of Lucky Cement
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Year NG Consumption
2007 2008 51,564,262
2008 2009 78,490,821
2009 2010 86,893,165
Description of
measurement methods
and procedures to be
applied:
Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Monthly
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

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Data / Parameter: FC
captive power plant,DI,year

Data unit: tons
Description: Diesel consumption in the captive power plant for the electricity used in the
project activity
Source of data to be
used:
Internal records of Lucky Cement
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Year Disel Consumption
(Litres)
Disel
Consumption
(kg)
2007 2008 80,189 69,764
2008 2009 59,667 51,910
2009 2010 44,955 39,111
Description of
measurement methods
and procedures to be
applied:
Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Monthly
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment: Density of diesel has been taken as 0.87 kg/l

Data / Parameter: FC
captive power plant,HFO,year

Data unit: tons
Description: HFO consumption in the captive power plant for the electricity used in the
project activity
Source of data to be
used:
Internal records of Lucky Cement
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

Year HFO Consumption
2007 2008 14,625
2008 2009 6,343
2009 2010 4,586
Description of
measurement methods
and procedures to be
applied:
Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Monthly
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: NCV
HFO,year

Data unit: GJ/ton
Description: Weighted average net calorific value of HFO used in the captive power plant in
year y
Source of data to be
used:
Supplier value
Value of data applied 40.26
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for the purpose of
calculating expected
emission reductions in
section B.5
Description of
measurement methods
and procedures to be
applied:
Net Calorific Value (NCV) of HFO will be provided by the supplier.

Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Each Delivery
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: NCV
NG,year

Data unit: MJ/Nm
3

Description: Weighted average net calorific value of NG used in the captive power plant in
year y
Source of data to be
used:
Net Calorific Value (NCV) of the NG will be provided by the SNGPL in the
monthly bill.

Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
30.85
Description of
measurement methods
and procedures to be
applied:
Data type: measured
Archiving procedure: Paper and Electronic
Recording Frequency: Monthly
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: NCV
DI,year

Data unit: MJ/l
Description: Weighted average net calorific value of Diesel used in the captive power plant
in year y
Source of data to be
used:
Supplier value
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
36.95
Description of
measurement methods
and procedures to be
Net Calorific Value (NCV) of Diesel will be provided by the supplier.

Data type: measured
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applied: Archiving procedure: Paper and Electronic
Recording Frequency: Each Delivery
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: AVD
y

Data unit: km
Description: Average round trip distance (from and to) between the alternative fuel supply
sites and the site of the project plant during the year y
Source of data to be
used:
Internal records of Lucky Cement Limited
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5

95
Description of
measurement methods
and procedures to be
applied:
Data type: Recorded
Archiving procedure: Paper and Electronic

QA/QC procedures to
be applied:
QMS procedures will be followed in recording & reporting of the parameter.
Any comment:

Data / Parameter: EF
km,CO2,y

Data unit: tCO
2
/km
Description: Average CO
2
emission factor for the trucks measured during the year y
Source of data to be
used:
This value is based on experience and knowledge of the project proponent.
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
0.000394851
Description of
measurement methods
and procedures to be
applied:
Data type: Recorded
Archiving procedure: Paper and Electronic
Monitoring Frequency: Annually
QA/QC procedures to
be applied:
The value of parameter shall be cross-checked with the information in the
literature. QMS procedures will be followed in recording & reporting of the
parameter.
Any comment:

Data / Parameter: AF
T,k,y

Data unit: tons
Description: Quantity of alternative fuel type k that has been transported to the project site
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during the year y.
Source of data to be
used:
Internal records of Lucky Cement Limited
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5


Fuel Type Amount
Tyre waste 153,214
RDF 63,608
Biomass Residues 43,836
Total 260,658
Description of
measurement methods
and procedures to be
applied:
Data type: Measured
Recording Frequency: Upon each delivery
QA/QC procedures to
be applied:
QMS procedures will be followed in recording & reporting of the parameter.
Any comment:

Data / Parameter: TL
y

Data unit: Tons
Description: Average truck load of the trucks used during the year y
Source of data to be
used:
Internal records of Lucky Cement Limited
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
19
Description of
measurement methods
and procedures to be
applied:
Data type: Measured
Recording Frequency: Upon each delivery
QA/QC procedures to
be applied:
QMS procedures will be followed in recording & reporting of the parameter.
Any comment:

Data / Parameter: P
clinker,y

Data unit: tons
Description: Production of clinker in year y
Source of data to be
used:
Internal records of Lucky Cement Limited
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
3,385,800
Description of Data type: Difference of cumulated values on energy meter
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measurement methods
and procedures to be
applied:
Monitoring Instrument: Kiln feed system
Manufacturer: Schenck
Model: Multicore S - 450
Range:0 300 TPH
Accuracy of the Instrument: 99.90% (error 0.10%)
Internal Calibration By: Instrument Department
External Calibration By: None
Calibration Frequency: Twice per year
Calibration Standard: Schenck Standard Calibration and Procedure
Recording Frequency: Daily
Recording Type: Paper and Electronic
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:

Data / Parameter: EF
CO2,BL,y

Data unit: tCO
2
/GJ
Description: Carbon dioxide emissions factor for the fossil fuels displaced by the use of
alternative fuels in the project plant
Source of data to be
used:
Calculated as follows as the lowest of the following CO
2
emission factors:

- The weighted average annual CO
2
emission factor for the fossil fuel(s)
consumed and monitored ex ante during the most recent three years before
the start of the project activity
- The weighted average annual CO
2
emission factor of the fossil fuel(s)
consumed in the project plant in year y that are not less carbon intensive
fossil fuels
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
0.0893
Description of
measurement methods
and procedures to be
applied:
Calculated as per step 2 of Baseline emissions calculation in the applied
methodology.
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment:


Data / Parameter: FC
BL,i,y

Data unit: Tons
Description: Quantity of coal displaced in the project plant as a result of the project activity
in year y
Source of data to be
used:
Internal records of Lucky Cement Limited
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Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
221,713
Description of
measurement methods
and procedures to be
applied:
Quantity of displaced coal shall be calculated based on heat input from the
alternate fuels and NCV of coal.
QA/QC procedures to
be applied:
QMS procedures will be followed in measuring, recording, and reporting of the
parameter.
Any comment: -


Data / Parameter: Biomass residue type k
Data unit: Tons
Description: Quantity of biomass residues of type k that are utilized (e.g. for energy
generation or as feedstock) in the defined geographical region
Source of data to be
used:
Surveys or statistics
Value of data applied
for the purpose of
calculating expected
emission reductions in
section B.5
0
Description of
measurement methods
and procedures to be
applied:

QA/QC procedures to
be applied:

Any comment: Monitoring of this parameter is applicable if approach L
2
is used to rule out
leakage


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B.7.2. Description of the monitoring plan:

All parameters such as, fossil fuel consumption, alternative fuel consumption, leakage emissions, fuel
characteristics etc., will be monitored as per the requirements of the monitoring methodology defined in
the ACM0003 / Version 07.4.

Lucky Cement has planned proper monitoring system for the project activity. This monitoring system has
been explained in detail in this section.

At the production section, Plant Operators hourly collect data for clinker production, fossil fuel
consumption and alternate fuel consumption at kilns E, F and G. Daily log sheet for production (Daily
production report) is prepared by Senior Assistant Manager based on the data collected by the Plant
Operators. The Production Report is initially verified by Deputy Managers of production section, and
finally verified by Production Managers.

Data for electricity generation by power plant is collected by Engine Room Operator. Daily log sheet for
electricity generation by the power plant is prepared by the Shift Engineer. Deputy Manager Operation
does the initial verification of the data for electricity generation. This data is finally verified by the
Manager Operations monthly.

The monitored data shall be audited internally by ISO representative after every six months.

Following Table B.7.2.1.shows designation of personnel involved in monitoring plan.


Table B.7.2.1: Designation of personnel involved in monitoring plan
Parameter Item
First Data
Collection
Daily Data Log
Preparation
Initial Data
Verification
Final Data
Verification
Clinker production Kiln
Plant Operator
(Hourly)
Senior Assistant
Manager
Deputy Manager Production
Manager
Coal consumption Kiln
Plant Operator
(Hourly)
Senior Assistant
Manager
Deputy Manager Production
Manager
Alternate Fuels
consumption
Kiln
Plant Operator
(Hourly)
Senior Assistant
Manager
Deputy Manager Production
Manager
HFO consumption
Kiln
Plant Operator
(Hourly)
Senior Assistant
Manager
Deputy Manager Production
Manager
Power
House
Engine Room
Operator
Shift Engineer Deputy Manager
Operation
Manager
Operation
Natural gas
consumption
Power
House
Engine Room
Operator
Shift Engineer Deputy Manager
Operation
Manager
Operation
Electricity
generation
Power
House
Engine Room
Operator
Shift Engineer Deputy Manager
Operation
Manager
Operation
Electricity
Consumption
Power
House
Engine Room
Operator
Shift Engineer Deputy Manager
Operation
Manager
Operation
Cement
Plant
Shift Staff Office Assistant Deputy Manger
Operation
Senior Manager
E/I

Reading is taken once a day in the morning
shift

AF System
Service Operator Shift Engineer Shift Manager Production
Manager
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Fuel Characteristics
(NCV, and density)
Coal
Chemist Chemist Deputy Manager
QC
Plant Manager
Alternate Fuels
Transportation
Quantity
of AF
Store Assistant Store In charge Store Assistant Store Manager
Truck
Load
Store Assistant Store In charge Store Assistant Store Manager
Distance
Daily basis n/a Fleet Tracking
Assistant
Fleet Manager

B.8. Date of completion of the application of the baseline study and monitoring methodology and
the name of the responsible person(s)/entity(ies):

Date of Completion (DD/MM/YYYY): 10/01/2012

Table 11 - Name of Responsible Entities
First Climate (Switzerland) AG
Stauffacherstrasse 45
CH-8004 Zurich
Switzerland
URL: www.firstclimate.com
Contact person: Mr.NikolausWohlgemuth
Email: nikolaus.wolhlgemuth@firstclimate.com
Carbon Services (Private) Limited
19 Davis Road,2nd Floor, Al Maalik,
Lahore
Pakistan
URL: www.carbon.com.pk
Contact person: Mr. Omar M. Malik
Email: omar.malik@carbon.com.pk

Both First Climate (Switzerland) AG and Carbon Services (Private) Limited are project participants.

SECTION C. Duration of the project activity / crediting period

C.1. Duration of the project activity:

C.1.1. Starting date of the project activity:

November 23, 2010
15


C.1.2. Expected operational lifetime of the project activity:

20 years

C.2. Choice of the crediting period and related information:

C.2.1. Renewable crediting period:

C.2.1.1. Starting date of the first crediting period:
N/A
C.2.1.2. Length of the first crediting period:
N/A

15
Date of signing of contract with equipment supplier for TDF (Eldan Recycling A/S)
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C.2.2. Fixed crediting period:

C.2.2.1. Starting date:

Starting date of the crediting period is (01/07/2012) or date of submission to UNFCCC whichever occurs
later.

C.2.2.2. Length:
10 years 0 months

SECTION D. Environmental impacts
>>

D.1. Documentation on the analysis of the environmental impacts, including transboundary
impacts:

No negative environmental impacts are to be considered, as the technology to be adopted is mature and
safe, once appropriate operation and maintenance procedure are in place.

The environmental analyses conducted by Lucky Cement Limited for the project are consistent in
demonstrating that the project activity is expected to remain fully compliant with NEQS (National
Environmental Quality Standards). In fact, it is expected that pollutant emissions (both of local concern
and global concern, such as CO
2
) will reduce from the current levels.

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:

Neither the project participants nor the host Party have any concern about negative environmental impacts
associated with the project activity, given that project activity aims at reducing the local and global
environmental impacts of the industrial site where the project activity is to be implemented.

SECTION E. Stakeholders comments

E.1. Brief description how comments by local stakeholders have been invited and compiled:

The local stakeholders consultation meeting is a requirement by Designated National Authority (DNA)
of CDM Pakistan, as well as it is required for the CDM PDD. The DNA issues Host Country Approval to
the project participants after the stakeholders consultation meeting is conducted and all the evidences are
provided to it.

Stakeholders were informed about the project activity through specific advertising published by the
project owner in the local media (newspaper, public notice boards within and surrounding Lucky Cement
Karachi Plant).

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The Stakeholder consultation meeting was held on May18, 2011 at Lucky Cement Limited Karachi Plant
and was open to anybody willing to participate (private citizens, representatives of associations, interest
groups, unions, public authorities, NGOs etc.).

The meeting was conducted by the representative of the project owner who explained in detail the project
activity and stimulated the debate and the expression of comments.

E.2. Summary of the comments received:

Comments from the stakeholders were collected in written form during and after the meeting. These are
summarized below in Table E.2.1: Summary of the Comments

Table E.2.1:Summary of the comments

Sr.
No
.
Stakeholders
Name
Designation
Qualificatio
n
Address
Comments/Views
about the Project
1.

Rasheed Ahmad
Jokhio
Land Lord Intermediate
Village Saleh
Muhammad Jokhio
Goth KathoreGaddap
Town.
This Project is
in the best
interest of the
region.
Environment
will become
pleasant. It
will create
employment
opportunities,
will save fuel.
People will be
inclined
towards
getting
education, also
it will improve
the lifestyle of
the people
2.

Mujahid Ahmad
Jokhio
Land Lord/ Ex-
Nazim UC2
M.A Political
Science
Village Raza
Muhammad
DarsanoChanoGadda
p Town.
The project
will reduce
environmental
pollution and
will increase
employment
opportunity to
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the people.
3.


Niaz Ahmad
Jokhio
Land Lord B.A
RaisWalidad
Muhammad Goth,
District Jamshoro,
Hyderabad.
The project
will cause new
employment
opportunities
for the people,
which will
eradicate
unemployment
. Environment
will improve
and the region
will progress
4.

JiandSalarJokhi
o
Agriculture Primary
Goth dodo Salar Bin
Qasim Town.
This project
will enhance
the business of
local people.
Region will
progress
economically
and will help
in wiping out
unemployment
.
5.
A.
GafoorBalouch
Land Lord Intermediate
SirajAhmed Village
UC3 Gaddap Karachi
This project
will reduce
environmental
pollution in
the region and
will give
better
employment
opportunities
to the people.
Economic
progress will
cause
betterment for
the area.
6. Qaisar
Farmer/
Shopkeeper
Matriculation
Muhammad Ali
Jokhio Goth Link
Road, Koteroro.
This project
will not only
provide
employment
to the local
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people but
also will be a
source of
environmental
changes,
which in turn
will cause a
positive
change in the
life style of
the people.
7. ShabanJokhio Land Lord


Matriculation
Goth WalidadLakhar,
District Jamshoro
This project
will reduce
environmental
pollution in
the region and
will give
better
employment
opportunities
to the people.
Economic
progress will
cause
betterment for
the area.
8. Salam Din Farmer



Matriculation
RaisWalidadJokhio
Goth, District
Jamshoro, Hyderabad
This project
will reduce
environmental
pollution in
the region and
will give
better
employment
opportunities
to the people.
Economic
progress will
cause
betterment for
the area.
9.
Basheer Ahmed
Khaskhaili
Farmer/ Gardner
Dumba Goth Super
Highway, Malir
Karachi
This project
will reduce
environmental
pollution in
the region and
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will give
better
employment
opportunities
to the people.
Economic
progress will
cause
betterment for
the area.
10.

Badar-Ud-Deen
Jokhio
Farmer



Matriculation
Kareem
BukhshJokhio
Village
Bin Qasim Town
Karachi.
This project
will reduce the
amount of fuel
used and
people will be
more inclined
towards
getting
education.
Prosperity in
the region will
improve the
standard of
living of the
people.
11.
Abdul Sattar
Bukhshani
Farmer Middle
Damloti- No.8,
Bukhshani, Goth
Malir Karachi
This project
will reduce
environmental
pollution in
the region and
will give
better
employment
opportunities
to the people.
Economic
progress will
cause
betterment for
the area.
12.
Haji Abdul
Majeed Lakhro
Land Lord Matriculation
P.O Jhunipur District,
Thatha Sindh
This project
will enhance
the business of
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local people.
Region will
progress
economically
and will help
in wiping out
unemployment
.
13.
Ali Nawaz
Bukhshani
Farmer Intermediate
Bukhsha Goth
Damloti No.8, Malir
Karachi
This project
will reduce
environmental
pollution in
the region and
will give
better
employment
opportunities
to the people.
Economic
progress will
cause
betterment for
the area.
14.
Muhammad
Azeem Jokhio
Farmer/Shopkeepe
r
Matriculation
Ikhtyar Khan Jokhio
Goth
DarsanaChainoGadar
This project
will reduce
environmental
pollution in
the region and
will give
better
employment
opportunities
to the people.
Economic
progress will
cause
betterment for
the area.

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E.3. Report on how due account was taken of any comments received:

All the comments received at the stakeholders meeting were expressing a positive opinion of the project.
The personnel at Lucky Cement explained in detail the technical, environmental, and social consequences
of substitution of alternate fuels for clinker production process. The stakeholders were informed that the
project is fully in compliance with NEQS. It was also explained that in Lucky Cement Karachi Plant
regular environmental audits are conducted by third parties. The stakeholders were satisfied, and were
supportive to the project. In conclusion, no negative concerns were expressed by the stakeholders, which
eventually expressed appreciation for initiative of Lucky Cement Limited.

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Annex 1

CONTACT INFORMATION ON PARTICIPANTS IN THE PROJECT ACTIVITY

Organization: Lucky Cement Limited
Street/P.O.Box: A. Aziz Hashim Tabba Street
Building: 6-A M. Ali Housing Society
City: Karachi
State/Region: Sindh
Postcode/ZIP:
Country: Pakistan
Telephone: +92-21-111 786 555
FAX: +92-21-34534302
E-Mail: info@lucky-cement.com
URL: www.lucky-cement.com
Represented by:
Title: CEO
Salutation: Mr.
Last name: Tabba
Middle name:
First name: Muhammad Ali
Department:
Mobile:
Direct FAX:
Direct tel:
Personal e-mail: malitabba@lucky-cement.com

Organization: First Climate (Switzerland) AG
Street/P.O.Box: Stauffacherstr 45
Building:
City: Zurich
State/Region: Zurich
Postcode/ZIP: 8004
Country: Switzerland
Telephone: +41-44-298 2800
FAX: +41 44-298 2899
E-Mail: info@firstclimate.com
URL: www.firstclimate.com
Represented by:
Title: Managing Director
Salutation: Mr.
Last name: Lchinger
Middle name:
First name: Alexander
Department:
Mobile:
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Direct FAX: +41-44-298 2899
Direct tel: +44-44-298 2807
Personal e-mail: alexander.luchinger@firstclimate.com

Organization: Carbon ServicesPrivateLimited
Street/P.O.Box: 19 Davis Road
Building: 2nd Floor, Al Maalik,
City: Lahore
State/Region: Punjab
Postfix/ZIP:
Country: Pakistan
Telephone: +92-42-36313235 / 36313236
FAX: +92-42-36312959
E-Mail:
URL: www.carbon.com.pk
Represented by: Mr. Omar M. Malik
Title: Director
Salutation: Mr
Last Name: Malik
Middle Name: M
First Name: Omar
Department:
Mobile: +92-300-8463743
Direct FAX: +92-42-36312959
Direct tel: +92-42-36313235 / 36313236
Personal E-Mail: omar.malik@carbon.com.pk



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Annex 2

INFORMATION REGARDING PUBLIC FUNDING

No Public Funding is involved in this project activity.
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Annex 3

BASELINE INFORMATION


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Annex 4

MONITORING INFORMATION

- - - - -

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