Info Report Check
Submission incomplete:
1: Scope: The validation opinion does not describe the nature and extent of the actual changes, determine whether this description accurately reflects the implementation, operation and monitoring of the modified project activity (VVS ver 09 para 318)
Issue: The electric efficiency of reference plant (11.971%) is calculated as a function of the NCV and consumption of the black liquor and biomass from forest operations. The revised PDD (pg. 110) indicates that the NCVs were sourced from average historic measurements (2009 to 2013) monitored directly from the pulp mill; and the consumption for the black liquor and biomass from forest operations were based on the weighted average amounts of black liquor and forest residues that would be burnt in the recovery boiler. However, no information is provided on why historical measurements on the consumption of the black liquor and forest residues have not been applied. The PP/DOE are requested to address this inconsistent approach in data application.

2: Scope: The verification report does not state that the monitoring has been carried out in accordance with registered or the accepted revised monitoring plan. (VVS ver 09 para 389)
Issues: (i) The registered revised PDD (pg.83) has considered the default value for the CH4 emission factor for uncontrolled burning of the biomass residue type k, EFburning, CH4,k,y, (0.0027 tCH4/BDt). However, the submitted monitoring report (pg. 50) and the ER calculation excel sheet have considered a measured value (930 kg CH4/TJ or 0.0172 tCH4/BDt). The PP/DOE are requested to provide information on why this change was not considered as part of the requested PRC which was submitted together with this request for issuance,
(ii) The revised PDD (pg.91) has considered a default value of 100% for εboiler (average net energy efficiency of heat generation in the boiler that would generate heat in the absence of the project activity). However, the submitted monitoring report (pg. 51) and the ER calculation excel sheet have considered a value of 85%. The PP/DOE are requested to provide information on why this change was not considered as part of the requested PRC which was submitted together with this request for issuance


3: Scope: The verification report does not list each parameter required by the monitoring plan and does not provide an statement on how the DOE verified the information flow (from data generation, aggregation, to recording, calculation and reporting) for these parameters including the values in the monitoring reports (VVS ver 09, para 393).
Issue: In reporting the measured EFburning,CH4,k,y value (0.00093 tCH4/GJ), the MR (pg. 50) states that “the measured value is considerably higher than the IPCC default value”. The DOE (VR pg. 149) states that “the IPCC default values have been reviewed and no significant differences have been identified”. The DOE is requested to address this inconsistency and provide information on how it verified the appropriateness of the measured EFburning,CH4,k,y value (0.00093 tCH4/GJ) putting into account that the measured value is considerably higher than the IPCC default value (0.0003 tCH4/GJ).