Registration Request for Review Form


CDM project activity/programme of activities
registration request review form (CDM-REGR-FORM)
(Version 03.0)

Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration9761
Title of the proposed CDM project activity/PoA submitted for registrationFes New Landfill Gas Recovery Reuse and Flaring Project
Please indicate, in accordance with paragraphs 37 and 40 of the CDM modalities and procedures, which validation requirement(s) may require review. A list of requirements is provided below. Please provide reasons in support of the request for review. Including any supporting documentation.
The following are requirements derived from paragraph 37 of the CDM modalities and procedures:
The participation requirements as set out in paragraph 28 to 30 of the CDM modalities and procedures are satisfied;

Comments by local stakeholders have been invited, a summary of the comments received has been provided, and a report to the designated operational entity (DOE) on how due account was taken of any comments has been received;

Project Participants have submitted to the DOE documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts and, if those impacts are considered significant by the project participants or the host Party, have undertaken an environmental impact assessment in accordance with procedures as required by the host Party;

The project activity is expected to result in a reduction in anthropogenic emissions by sources of greenhouse gases that are additional to any that would occur in the absence of the proposed project activity, in accordance with paragraphs 43 to 52 of the CDM modalities and procedures;

The baseline and monitoring methodologies comply with requirements pertaining to methodologies previously approved by the Executive Board;

Provisions for monitoring, verification and reporting are in accordance with decision 17/CP.7, the CDM modalities and procedures and relevant decisions of the COP/MOP;

The project activity conforms to all other requirements for CDM project activities in decision 17/CP.7, the CDM modalities and procedures and relevant decisions by the COP/MOP and the Executive Board.
The following are requirements derived from paragraph 40 of the CDM modalities and procedures:
The DOE shall, prior to the submission of the validation report to the Executive Board, have received from the project participants written approval of voluntary participation from the designated national authority of each Party involved, including confirmation by the host Party that the project activity assists it in achieving sustainable development;

In accordance with provisions on confidentiality contained in paragraph 27(h) of the CDM modalities and procedures, the DOE shall make publicly available the project design document;

The DOE shall receive, within 30 days, comments on the validation requirements from Parties, stakeholders and UNFCCC accredited non-governmental organizations and make them publicly available;

After the deadline for receipt of comments, the DOE shall make a determination as to whether, on the basis of the information provided and taking into account the comments received, the project activity should be validated;

The DOE shall inform project participants of its determination on the validation of the project activity. Notification to the project participants will include confirmation of validation and the date of submission of the validation report to the Executive Board;

The DOE shall submit to the Executive Board, if it determines the proposed project activity to be valid, a request for registration in the form of a validation report including of the project design document, the written approval of the host Party and an explanation of how it has taken due account of comments received.
There are only minor issues which should be addressed by the DOE/project participants prior to the registration of the project.
Additional information
1) A) The DOE is required to further substantiate the description of the technology employed by the project, since section B.2 from the PDD states that one of the uses of the LFG will be to generate steam to evaporate the leachate collected whereas section A.3 from the PDD states that the evaporation is made through direct heat exchange with the combustion chamber and direct contact of the combustion gases with the leachate
B) The DOE is required to clarify how it has validated that the use of the leachate evaporation technology is in line with the applicability criteria (c) (ii) on page 3 from the methodology (i.e. the methodology is applicable to project activities which flare the LFG and/or use the captured LFG to generate heat in a boiler, air heater or kiln (brick firing only) or glass melting furnace).
C) The DOE is required to further substantiate how it has validated that the project complies with the applicability criteria "d) Do not reduce the amount of organic waste that would be recycled in the absence of the project activity" as it was justified only based on the waste received by the landfill, without assessing the prevailing waste management practices in the region affected by the landfill as well as relevant national and/or sectoral circumstances and whether the amount of waste recycled is maintained after the project implementation. Please refer to paragraph 76 from VVS v04.0.

2) During the consideration of baseline alternatives, scenarios LFG3, LFG4 and LFG5 were excluded based on interviews with the landfill's representatives and based on the feasibility study for the waste management.. However, it is unclear how the exclusions are in line with the prevailing waste management practices in the region affected by the landfill as well as relevant national and/or sectoral circumstances. The DOE is requested to further substantiate how it has validated that the LFG would not be partially generated because the organic fraction of the waste received by the landfill would be either (i) recycled, (ii) treated aerobically, (iii) incinerated in the absence of the project, for example based on interviews with local authorities, information from official sources or expert opinions. Please refer to paragraphs 93 and 94 from VVS v04.0.

3) A) The DOE is required to clarify how it has validated the default value of flare efficiency applied by the project based on the height of the flare installed (as per the tool’s definition of low height flare).
B) The DOE is required to further substantiate how it has validated the steps used to determine the flare efficiency since section B.6.1 from the PDD (page 33) states that a default value approach was selected but it contains the description of steps 2.1 to 2.4 from the "Project Emissions from Flaring" tool, which are applicable in case of measured flare efficiency. Please refer to paragraphs 97 and 98 from VVS v04.0.

4) The methodology, on page 8, requires the application of the gaseous stream tool to the to the LFG delivery pipeline and to each item of electricity generation or heat generation equipment and the monitoring plan, on section B.7.1, contains only the monitoring system and procedures of a generic parameter related to the gas flow named “Vt,db = Vt,wb = FVRG,h” without indicating which gas streams will be monitored and how the monitoring will be undertaken for each of the streams. The DOE is required to clarify how it has validated the compliance of the monitoring plan with the requirements from the methodology and from the gaseous stream tool. Please refer to paragraph 132 from VVS v04.0.
Date 01 Feb 14