Info Report Check
Submission incomplete:
1: Three ER spreadsheets (i.e. “CTL 4th v3 2017 08 25 JAS_part 2_DEVIATION”, “CTL 4th v3 2017 08 25 JAS_part 3_NORMAL”, and “CTL 4th v3 2017 08 25 JAS_part 4_NORMAL”) are not accessible.


2: Page 48 of the monitoring report states that the increase of food waste in the waste composition (i.e. from 35.78% in the PDD to 55.43% in real operation) and the higher LFG collection efficiency (i.e. from 70% in the PDD to 85% in real operation) have resulted in the increased collection of methane. Further, it is observed that most part of this monitoring period (i.e. 15/09/2014 – 27/04/2017) is prior to the approval date of the PDD (i.e. 24/04/2017). The DOE shall clarify on why such information on real operation was not reported and reflected in the PDD during the process of requesting for post-registration-changes.


3: (1) The formula applied to calculate BECH4 in page 37 of the monitoring report (i.e. “BECH4 = (1-OXtop_layer) * (FCH4,PJ,y – FCH,BL,y) * GWPCH4” ) is not in line with the applied methodology (i.e. “BECH4 = ( (1-OXtop_layer) * FCH4,PJ,y – FCH,BL,y) * GWPCH4” ). Please refer to equation (2) of ACM0001 version 17. The DOE shall specify how it has validated the correctness of formula in the ER sheets in accordance with ACM0001 version 17.

(2) Paragraph 30 of ACM0001 version 17 requires deduction of parameter OXtop_layer (i.e. fraction of methane in the LFG that would be oxidized in the top layer of the SWDS in the baseline) in determining BECH4 (i.e. baseline emissions of methane from the SWDS in year y). However, such required deduction is not observed in ER spreadsheets (e.g. cell D16, tabl “Consolidado 4a VER” of the sheet “Consolidated and tendency 4th VER v5”).

(3) Paragraph 34 of ACM0001 version 17 requires determining parameter FCH4,flare,y (i.e. amount of methane in the LFG which is destroyed by flaring in year y) as (FCH4,sent_flare,y – PEflare,y/GWPCH4). However, the deductive component related to PEflare,y (i.e. project emissions from flaring of the residual gas stream in year y) is not reflected in the ER sheet (e.g. D44, table “CERs Estimative” of the sheet “CTL 4th v3 2017 08 25 JAS_part 1_DEVIATION”).

(4) Page 42 of the monitoring report requires formula of BENG,y as a product of 0.0504, FCH4,NG,y (i.e. amount of methane in the LFG which is sent to the natural gas distribution network) and EFCO2,NG,y (i.e. average CO2 emission factor of natural gas in the natural gas network). However, the values of BENG,y are based on FCH4,NG,y and GWPCH4 (e.g. cell D31, tabl “Consolidado 4a VER” of the sheet “Consolidated and tendency 4th VER v5”), which is not in line with formula in the monitoring report or the applied methodology. Please refer to paragraph 61 of ACM0001 version 17.