Info Report Check
Submission incomplete:
1: The revised PDD (section B.7.3) proposes to monitor the parameter “gross generation” from energy meter M1 (installed at the output of the generator) instead of the energy meter M2 (located at the substation). However, the DOE has not provided a validation opinion on this part of the PRC. In doing so, the DOE is requested to clarify how this approach is conservative considering that the revised PDD (Appendix 7) mentions that there are line losses of around 0.1% between measurements taken by M1 and by M2 and this parameter is applied to calculate the baseline emissions.


2: The PRC proposes to exclude paper fiber as the boiler biomass fuel and instead use only forestry and agriculture residues. The revised PDD (Appendix 7) indicates that (i) paper fibers represented 0.2% of the total biomass considered in the registered PDD, (ii) project emissions attributable to the biomass transport have reduced from 8,768 tCO2 to 8,574 tCO2 and (iii) there is no impact in emissions from the combustion of biomass residues (PEBR,y) since CH4 from the combustion of paper fiber residues will no longer occur. The DOE is requested to:
i. Provide a validation opinion on this part of the PRC as the same has not been provided.
ii. Clarify if additional amount of other biomass (forestry and agriculture residues) would be combusted to maintain the boiler operational hours as in the registered PDD considering that 0.2% paper fiber has been excluded and it is not clear how the same boiler operation hours, as in the registered PDD, would be maintained after this exclusion.
iii. Submit the ex-ante emission reduction excel sheet which shows how the project emissions attributable to the biomass transport have been calculated.


3:
Regarding the permanent changes to the project design (i.e., exclusion of the paper fiber and correction of the plant load factor), the DOE shall provide an assessment on when the changes occurred, reasons for these changes taking place and whether the changes would have been known prior to the registration of the CDM project activity (please refer to the VVS-PA ver. 03 paragraph 309 (b)).


4: The verification report (section E.6.2) indicates that the data related to the biomass delivery and consumption was cross verified with an annual energy balance that is based on purchased quantities and stock changes. However, the energy balance excel sheet has not been submitted.