17:48 26 Aug 24
Info Report Check
Submission incomplete:
1: The updated project flowcharts (i.e. figure 2, 3 and 4 in the revised PDD) in the proposed corrections does not illustrate how the project activity is physically connected to the other CDM project activity (i.e. PA 2285), since biogas is transferred from PA 2341 to PA 2285 (page 2 of submitted document “Final response to request CDM 2341 v1”). In addition, the DOE is also requested to provide information on how it has concluded the debundling check, in particular the compliance with paragraph 10 of the methodological tool “Assessment of debundling for small-scale project activities” version 04.0.
2: Project emissions from electricity consumption are added as part of the post-registration changes and two corresponding monitoring parameters (i.e. Grid electricity consumption in year “y” and grid emission factor) are added. However, this change has been considered as corrections. The DOE shall provide information on how it has concluded the type of the proposed change. Please refer to section 8.3.4 of CDM VVS for project activities version 2. In addition, parameter flare efficiency (%) is also added as one monitoring parameter and considered as a correction.
3: Paragraph 35 of the applied methodology (i.e. AMS III.H version 9) requires monitoring electricity consumption of the project activity facilities. However, instead of direct measurement by energy meters, the grid electricity consumption is to be determined by the measurement of the operation hours multiplied by the name plate of the facilities (i.e. flaring equipment and water heater). The DOE is requested to provide information on how it has concluded the type of this change. Please refer to paragraph 296 and 298 of CDM VVS for project activities version 2.
4: Paragraph 35 (b) and (c) of AMS III.H version 9 require monitoring the degradable carbon content of sludge before and after treatment, and the flow of sludge treated (Sy,untreated). However, those parameters are not included in the monitoring plan. The DOE is requested to provide information on how it has verified the compliance of the monitoring plan with the applied methodology.
5: Paragraph 41 of AMS III.H version 9 require monitoring the end-use of the final sludge if the methane emissions from anaerobic decay of the final sludge are to be neglected. The project activity does not consider methane emissions from final sludge, and does not include monitoring of the end-use of the final sludge. The DOE is requested to provide information on whether there is final sludge produced and how it has verified the compliance of the monitoring plan with the paragraph 41 of AMS III.H version 9.
6: As part of the proposed changes, the grid emission factor is monitored ex-post, and determined as 0.00011 tCO2/MWh for year 2011 and 0.00013 tCO2/MWh for year 2012. Paragraph 9 (b) of AMS I.D version 13 (i.e. weighted average emissions of the current generation mix) has been opted in the revised PDD to determine the grid emission factor. However, it is observed that a grid emission factor of 0.269090 tCO2/MWh for year 2012 is applied in PA 2285 (i.e. the other CDM project activity which sources biogas from this project activity PA 2314). The DOE is requested to clarity the variance between those two grid emission factors for the same grid, and explain how it has validated the correctness and appropriateness of the approach in determining grid emission factor of the project activity.
7: The formulas applied in the ER sheet (i.e. column AA of tab “ER_Calculation”) in calculating project emissions from methane release in capture and utilization/combustion/flare systems (i.e. parameter PEy,fugitive) is not consistent with the formula stated in page 23 of the revised PDD, as the calculated project emissions exclusively consider the methane release from flare systems whereas does not consider release from the biogas sent to the gas engine generators and the water heater. Please refer to equation (7) and paragraph 34 of AMS III.H version 9.
1: The updated project flowcharts (i.e. figure 2, 3 and 4 in the revised PDD) in the proposed corrections does not illustrate how the project activity is physically connected to the other CDM project activity (i.e. PA 2285), since biogas is transferred from PA 2341 to PA 2285 (page 2 of submitted document “Final response to request CDM 2341 v1”). In addition, the DOE is also requested to provide information on how it has concluded the debundling check, in particular the compliance with paragraph 10 of the methodological tool “Assessment of debundling for small-scale project activities” version 04.0.
2: Project emissions from electricity consumption are added as part of the post-registration changes and two corresponding monitoring parameters (i.e. Grid electricity consumption in year “y” and grid emission factor) are added. However, this change has been considered as corrections. The DOE shall provide information on how it has concluded the type of the proposed change. Please refer to section 8.3.4 of CDM VVS for project activities version 2. In addition, parameter flare efficiency (%) is also added as one monitoring parameter and considered as a correction.
3: Paragraph 35 of the applied methodology (i.e. AMS III.H version 9) requires monitoring electricity consumption of the project activity facilities. However, instead of direct measurement by energy meters, the grid electricity consumption is to be determined by the measurement of the operation hours multiplied by the name plate of the facilities (i.e. flaring equipment and water heater). The DOE is requested to provide information on how it has concluded the type of this change. Please refer to paragraph 296 and 298 of CDM VVS for project activities version 2.
4: Paragraph 35 (b) and (c) of AMS III.H version 9 require monitoring the degradable carbon content of sludge before and after treatment, and the flow of sludge treated (Sy,untreated). However, those parameters are not included in the monitoring plan. The DOE is requested to provide information on how it has verified the compliance of the monitoring plan with the applied methodology.
5: Paragraph 41 of AMS III.H version 9 require monitoring the end-use of the final sludge if the methane emissions from anaerobic decay of the final sludge are to be neglected. The project activity does not consider methane emissions from final sludge, and does not include monitoring of the end-use of the final sludge. The DOE is requested to provide information on whether there is final sludge produced and how it has verified the compliance of the monitoring plan with the paragraph 41 of AMS III.H version 9.
6: As part of the proposed changes, the grid emission factor is monitored ex-post, and determined as 0.00011 tCO2/MWh for year 2011 and 0.00013 tCO2/MWh for year 2012. Paragraph 9 (b) of AMS I.D version 13 (i.e. weighted average emissions of the current generation mix) has been opted in the revised PDD to determine the grid emission factor. However, it is observed that a grid emission factor of 0.269090 tCO2/MWh for year 2012 is applied in PA 2285 (i.e. the other CDM project activity which sources biogas from this project activity PA 2314). The DOE is requested to clarity the variance between those two grid emission factors for the same grid, and explain how it has validated the correctness and appropriateness of the approach in determining grid emission factor of the project activity.
7: The formulas applied in the ER sheet (i.e. column AA of tab “ER_Calculation”) in calculating project emissions from methane release in capture and utilization/combustion/flare systems (i.e. parameter PEy,fugitive) is not consistent with the formula stated in page 23 of the revised PDD, as the calculated project emissions exclusively consider the methane release from flare systems whereas does not consider release from the biogas sent to the gas engine generators and the water heater. Please refer to equation (7) and paragraph 34 of AMS III.H version 9.
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