Info Report Check
Submission incomplete:
Scope: The verification report does not contain reference to the approved request for notification/request for approval of changes from the project activity as described in the registered PDD. (VVM v.1.2 para 198 (d))

It is noted in the monitoring report and the verification report that a notification of post-registration changes for the parameter "Flare Efficiency" (FE), including the hourly flare efficiency calculation, will be made as part of the request for issuance. However, the proposed changes have been applied in the Monitoring Report submitted with the request for issuance. According to the Project Cycle Procedure (PCP) para. 132, the DOE is required to submit, prior to the submission of the request for issuance, a request for approval by the Board of changes referred to in para. 130 of the PCP, which includes permanent changes to the monitoring plan. It should be noted that under the old process ("VVM track") any changes to the monitoring plan or project design should be approved by the Board before the submission of the request for issuance, per VVM para. 203. However, as the procedure for revision of monitoring plan no longer exists, and the DOE is submitting a request for post-registration changes under the new procedure ("VVS track"), the DOE should provide a validation opinion on how the relevant guidelines are complied with, including the appropriate procedures to submit the request for post-registration changes (PRC) as per the relevant requirements of the PCP.