Info Report Check
Submission incomplete:
1: The DOE is requested to address and to clarify the issues below in accordance with the VVS-PA (ver. 01) paragraph 284.
The Verification Report section E4.1 has the temporary deviation provision that it was considered an addition of 10% to account for transmission and distribution losses for the calculation of parameter ECPJ2,y. However, it is not clear whether the 10% addition has been taken into account while calculating the ECPJ2,y given that the spreadsheets “CERs Estimative, cell C65” for part 1 to part 3 have considered the defaulted value 0.16 for TDLy without considering the addition of 10%.

2: The DOE is requested to address and to clarify the issues below in accordance with the VVS-PA (ver. 01) paragraph 300.
The PRC applied via the corrections results in increasing estimated emission reductions and it is not clear whether those changes should be part of the “changes to project design (PDD-PA section 8.3.5)” instead of “corrections (PDD-PA section 8.3.1)”. For example, the proposed revised PDD (v16) page 2 describes that a new operational license has been issued on 26/02/2016 and valid until 26/02/2021 due to the environmental license from the landfill area are expansion, from which it is not clear whether, due to the change of amount of waste which results in increment of amount of LFG collected, there is any impact to the additionality resulting from the increment of LFG provided through a dedicated pipeline to the customer. It is noted that as per PDD (v16) page 3 approximately 20% of collected LFG will be injected to the dedicated customer, which would involve generating of sales revenue. Similarly, as per revised PDD (v16) page 53, it is not clear whether the change of the composition of waste will result in the same concern of having impact to the additionality and therefore it should be treated as part of changes to the project design. To address this issue, the DOE is requested to provide detail information and clarification to justify whether the proposed PRC should be handled under the “changes to project design (PDD-PA section 8.3.5 and PDD VVS section 8.3.5)” and to verify the project activity based on the applied requirements.

3: The DOE is requested to address and to clarify the issues below in accordance with the VVS-PA (ver. 01) paragraph 376.
As per the PDD pages 63 and 64, dispatch data analysis OM and option 2 of BM have been selected to calculate CM emission factor ex post. Further the verification report page 33 states that the grid emission factor value 0.3904 T CO2/MWh is in accordance with data latest available by the Brazilian DNA in the year 2016. It is not clear how the DOE verified this grid emission factor value given that based on the Tool to calculate the emission factor for an electricity system, the dispatch data analysis OM is to use the year in which the project activity displaces grid electricity and update the emission factor annually during monitoring. In the case of this 5th monitoring period which spans from 28/04/2017 to 28/02/2018, the years are to be 2017 and 2018.

4: The DOE is requested to address and to clarify two issues below in accordance with the VVS-PA (ver. 01) paragraph 377.
(1) As per the spreadsheets “CERs Estimative, cell C45” for part 1 to part 3, the factor (1- Methane destroyed in the baseline (0.2)) has been applied to the calculation of parameter “PEflare”. Similarly, it is observed that the spreadsheet “Consolidato 5a VER, columns T and V” have applied the same application as above. It is not clear how the DOE verified the calculation of “PEflare” as per the calculation step 3 required in the PDD (v16) page 43 and the applied Tool and to ensure conservative and correct approach applied.

(2) The PDD page 42 has the provision that the “flare efficiency (ηflare,m)” is to be determined by Option B.1 of the methodological tool “Project emissions from flaring”, where the flare efficiency is measured in a biannual basis or, if the biannual measurements are not available, Option A of the methodological tool “Project emissions from flaring” will be used. The issues below are found:
(A) The Tool project emission from flaring (v.2) page 68, for the parameter “FCH4,EG,t”, requires “The average flow rate to the flare during the time period t must be greater than the average flow rate observed for the previous six months”; however, the MR does not provide such information and the VR does not provide the corresponding verification opinion.
(B) The Tool above page 4, for the option B.1, has the provision “The two time periods in year y during which the flare efficiency is measured, each a minimum of one hour and separated by at least six months”. It is not clear how the DOE verified the compliance whether (a) the two time periods in year y is separated by at least six months and (b) each time period is measured a minimum of one hour. For example, the MR page 35 reports the Date of Test of the test result 99.854% used for the monitoring period 28/04/2017 – 07/06/2017 for the Flare 107 is on 08/12/2016; however, as per the Tool, the flare efficiency that is used in the calculation shall be based on two measurements with gap of at least 6 months. The same issue above is also for other test results (99.9996%, 99.9996%, 99.860%, 99.844, 92.8860% and 99.9998%). To address this issue, the detail information of all tests are requested to be provided so as to demonstrate how this requirement is fulfilled.
(C) The Tool above page 68, requires that measurements of the parameter “FCH4,EG,t” is undertaken by a “third party accredited entity”; however, the VR page 20 confirms only that the analysis is provided by a third party company and it is not clear whether it is an accredited entity.