Info Report Check
Submission incomplete:
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 v.9 para 318)

The revised PDD (tracked; pg. 119) indicates that the electric efficiency of reference plant, which has been revised from 12.09% to 11.971%, is calculated as a function of ex-post-monitored NCVs and calculated (weighted average) biomass consumption. The DOE is requested to address the following:
i. The DOE (assessment opinion page 42) has explained that it is not possible to apply real values to the quantity of biomass used in the reference plant for the ex-ante calculations because the “current capacity of the project activity is being restricted as per environmental permission, which caps the productivity to 550,000 ADt/y while the reference plant has its capacity defined as per plant design (728,640 ADt/y)”. The DOE is requested to clarify why a request for post-registration change due to the project design (i.e. change of the production capacity between the reference plant and project plant) is not required considering that the registered PDD (pg. 7) states that “it must be noted that the alternative business-as-usual (BAU) pulp mill (or reference mill) would have had the same capacity as the real mill (with the implementation of the CDM project activity)”;

ii. The estimated amount of annual average GHG emission reductions have increased by 28% (i.e. from 107,015 tCO2e (registered PDD ver. 04.0) to 137,170 tCO2e (revised PDD ver. 09.0) due to the requested PRC. The DOE is requested to provide information on (a) how it verified the conservativeness of the calculated annual average GHG emission reductions (137,170 tCO2e), (b) why it considers that the requested PRC does not require prior approval from EB considering that it has been validated (assessment opinion pgs 22 and 28) that the new equipment (dryer) installed as part of the requested PRC will change some operational parameters; and

iii. The applied monitoring methodology (ACM0006 ver. 05 page 47) has listed the “electric efficiency of reference plant, εel,reference plant” as parameter which is fixed ex-ante (not monitored). However, the PP has applied the monitored values for the biomass NCVs to update this parameter. The DOE is requested to clarify why a deviation from the applied monitoring methodology is not requested considering that the efficiency of reference plant, εel,reference plant” is fixed ex-ante whereas the PP proposes to update it ex-post.