13:01 27 Apr 26
Info Report Check
Submission incomplete:
1: Temporary deviation #2: LFG delivered to the consumers not monitored, 5% discount applied
a) The DOE is requested to further elaborate on where the 5% discount comes from, how it is assumed as conservative, and justify why it is applied to leakage for transport, in relation to the lack of monitoring devices for the biogas delivery.
b) In doing so, please explain the steps of the operation for the biogas production and delivery, namely how the gas is loaded into cylinders and ultimately into trucks, how it is transported and where and how exactly the leakage is generated.
2: Temporary deviation #3: Unavailable invoices from the electricity company.
The DOE shall elaborate on the reason why there is no evidence of the electricity used during the period 13/04/2016 to 30/11/2016.
3: Project’s monitoring diagram
a) The DOE is requested to produce a detailed monitoring diagram, which shows the meters of all the different processes of the project activity, including but not limited to the three (3) key lines: flaring, electricity and biogas. In doing so, please indicate the exact location of the meters in the process.
b) Please also add the monitoring parameters to the project’s monitoring diagram, clearly indicating at which point they are being monitored (before / after the technology).
c) Additionally, please explain what the difference is between supplying gas through trucks and through the pipeline. Please elaborate on the difference in operations.
4: The maximum permissible error of the equipment of 0.1 % conservatively applied to the amount of LFG sent to trucks from April 2016 to June 2019.
In relation to the monitoring parameter Vt,db (MR page 19), it is indicated in the MR page 20 that “The most recent calibration showed an error of 0.06 compared to the error of 0.1 presented in the manual. Thus, the error of maximum permissible error of the equipment of 0.1 was conservatively applied to the amount of LFG which is sent to trucks from April 2016 to June 2019”. The value 0.1 should be corrected to 0.1 % (percentage symbol added). The DOE is requested to correct all the instances of the latter across all the documents (VR-PRC, MR and VCR) and ensure the corrections are replicated in all the occurrences in the ER sheet, where applicable.
5: No calibration during the whole monitoring period
In reference to the following monitoring parameters, it is stated that “During the monitoring period there were no calibration of the equipment”.
a) FCH4,NG TR,y (MR page 18)
b) Vt,db (MR page 20)
c) Vi,t,db (MR page 21)
The DOE is requested to justify why no calibration was performed during the whole monitoring period.
6: ER calculations: Value 0.716
In reference to the ER sheet, tab “pipe”, cell J12, the DOE is requested to clarify where the value 0.716 comes from and what concept it represents.
7: Registration date and start of monitoring period vs. start of operations
The DOE is requested to clarify the discrepancy between the registration date and the start date of monitoring period (13 April 2016) vs. the start of operations, considering the latter appears to be 18 January 2016, as shown in the VCR page 9: “The start of operations is 18/01/2016, when it happened the first sale of compressed purified biogas”.
8: Electricity generator at the project site owned by Bio Gera Energia Locações e Equipamentos Industriais Ltda.
Considering the following statements:
- MR page 2: “During the monitoring period from 13/04/2016 to 31/12/2020, the project reduced 71,826 tCO2e by delivering LFG through gas pipeline and by trucks. Up to October 2020, electricity used in the project activity was consumed from the grid; from November 2020 onwards, renewable electricity generated with LFG was purchased by the project participant. Therefore, there is an electricity generator at the project site, however, it is not owned and operated by the project developer but by Bio Gera Energia Locações e Equipamentos Industriais Ltda. For this reason, operation, maintenance, and use are not the project developer responsibility”.
- MR page 14: “Possibly, electricity may be generated from a captive plant installed at the project site considering the high variation of electricity supply which the project has been facing at the time of commissioning”.
- MR page 26: “The installation of a fossil fuel generator is possible considering intermittences of electricity supply at the project site. If this type of generator is installed at the project site, fossil fuel shall be monitored in order to calculation project emissions.”
a) The DOE is requested to explain which captive plant is referred to in the MR page 14. Please provide more details and clarify if this is related to the GERA generator.
b) Additionally, please elaborate on where the biogas that GERA uses comes from and if the gas that GERA uses is the same gas that is sold to end consumers.
9: Electricity consumption from the grid vs. from the biogas produced
a) In relation to the following phrase found on the ER sheet, tab “ECPJ,y”, cell A3: “Up to 10/2020, electricity was consumed from the grid. After this date, electricity was produced with biogas”, the DOE is requested to further elaborate on the source of electricity consumed in November and December 2020, given the fact that in cells F19 and F20 of the above mentioned tab, there are still values of electricity consumed from the grid.
b) In so doing, kindly provide the definition of 'biogas' under this project activity, clarifying whether such biogas is the actual LFG, the natural gas going to the final consumers or something else.
1: Temporary deviation #2: LFG delivered to the consumers not monitored, 5% discount applied
a) The DOE is requested to further elaborate on where the 5% discount comes from, how it is assumed as conservative, and justify why it is applied to leakage for transport, in relation to the lack of monitoring devices for the biogas delivery.
b) In doing so, please explain the steps of the operation for the biogas production and delivery, namely how the gas is loaded into cylinders and ultimately into trucks, how it is transported and where and how exactly the leakage is generated.
2: Temporary deviation #3: Unavailable invoices from the electricity company.
The DOE shall elaborate on the reason why there is no evidence of the electricity used during the period 13/04/2016 to 30/11/2016.
3: Project’s monitoring diagram
a) The DOE is requested to produce a detailed monitoring diagram, which shows the meters of all the different processes of the project activity, including but not limited to the three (3) key lines: flaring, electricity and biogas. In doing so, please indicate the exact location of the meters in the process.
b) Please also add the monitoring parameters to the project’s monitoring diagram, clearly indicating at which point they are being monitored (before / after the technology).
c) Additionally, please explain what the difference is between supplying gas through trucks and through the pipeline. Please elaborate on the difference in operations.
4: The maximum permissible error of the equipment of 0.1 % conservatively applied to the amount of LFG sent to trucks from April 2016 to June 2019.
In relation to the monitoring parameter Vt,db (MR page 19), it is indicated in the MR page 20 that “The most recent calibration showed an error of 0.06 compared to the error of 0.1 presented in the manual. Thus, the error of maximum permissible error of the equipment of 0.1 was conservatively applied to the amount of LFG which is sent to trucks from April 2016 to June 2019”. The value 0.1 should be corrected to 0.1 % (percentage symbol added). The DOE is requested to correct all the instances of the latter across all the documents (VR-PRC, MR and VCR) and ensure the corrections are replicated in all the occurrences in the ER sheet, where applicable.
5: No calibration during the whole monitoring period
In reference to the following monitoring parameters, it is stated that “During the monitoring period there were no calibration of the equipment”.
a) FCH4,NG TR,y (MR page 18)
b) Vt,db (MR page 20)
c) Vi,t,db (MR page 21)
The DOE is requested to justify why no calibration was performed during the whole monitoring period.
6: ER calculations: Value 0.716
In reference to the ER sheet, tab “pipe”, cell J12, the DOE is requested to clarify where the value 0.716 comes from and what concept it represents.
7: Registration date and start of monitoring period vs. start of operations
The DOE is requested to clarify the discrepancy between the registration date and the start date of monitoring period (13 April 2016) vs. the start of operations, considering the latter appears to be 18 January 2016, as shown in the VCR page 9: “The start of operations is 18/01/2016, when it happened the first sale of compressed purified biogas”.
8: Electricity generator at the project site owned by Bio Gera Energia Locações e Equipamentos Industriais Ltda.
Considering the following statements:
- MR page 2: “During the monitoring period from 13/04/2016 to 31/12/2020, the project reduced 71,826 tCO2e by delivering LFG through gas pipeline and by trucks. Up to October 2020, electricity used in the project activity was consumed from the grid; from November 2020 onwards, renewable electricity generated with LFG was purchased by the project participant. Therefore, there is an electricity generator at the project site, however, it is not owned and operated by the project developer but by Bio Gera Energia Locações e Equipamentos Industriais Ltda. For this reason, operation, maintenance, and use are not the project developer responsibility”.
- MR page 14: “Possibly, electricity may be generated from a captive plant installed at the project site considering the high variation of electricity supply which the project has been facing at the time of commissioning”.
- MR page 26: “The installation of a fossil fuel generator is possible considering intermittences of electricity supply at the project site. If this type of generator is installed at the project site, fossil fuel shall be monitored in order to calculation project emissions.”
a) The DOE is requested to explain which captive plant is referred to in the MR page 14. Please provide more details and clarify if this is related to the GERA generator.
b) Additionally, please elaborate on where the biogas that GERA uses comes from and if the gas that GERA uses is the same gas that is sold to end consumers.
9: Electricity consumption from the grid vs. from the biogas produced
a) In relation to the following phrase found on the ER sheet, tab “ECPJ,y”, cell A3: “Up to 10/2020, electricity was consumed from the grid. After this date, electricity was produced with biogas”, the DOE is requested to further elaborate on the source of electricity consumed in November and December 2020, given the fact that in cells F19 and F20 of the above mentioned tab, there are still values of electricity consumed from the grid.
b) In so doing, kindly provide the definition of 'biogas' under this project activity, clarifying whether such biogas is the actual LFG, the natural gas going to the final consumers or something else.
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