Info Report Check
Submission incomplete:
1: The DOE is requested to explain how the operation and monitoring of the project activity has been conducted as per the PDD, in line with paragraph 357 of VVS-PA, version 01.0. As per the page 23 of the PDD, default values for the flare efficiency can be used in case of the continuous system is unavailable for maintenance, or failure. However, during this monitoring period, default value for the flare efficiency is used because the continuous monitoring of the flare efficiency has not been implemented. Responding to this issue in the initial submission, the DOE/PP explained that application of default value is more conservative and that footnote 17 of the PDD allows the use of default value. However, it is understood that the PDD has set a provision on page 23 that default values for the flare efficiency can be used only in case of the continuous system is unavailable for maintenance, or failure. Therefore, this is considered a deviation to the registered monitoring plan, for which post registration change may be needed.


2: The DOE is requested to explain how the provision in paragraph 369 of VVS-PA, version 01.0 for the delayed calibrations of meter for parameter LFGflare,y, has been correctly applied as the deduction is done to parameter MDflare,y, as shown in the ER spreadsheet, instead of the parameter LFGflare,y itself.
Responding to this issue in the initial submission, the DOE/PP explained that the application of adjustment of -1% to parameter MDflare,y would give the same result as applying adjustment of -1% to parameter LFGflare. However, it is to be noted that
that parameter LFGflare,y is used twice in the formula to calculate MDflare,y, i.e.: MDflare = (LFGflare,y * wCH4,y * DCH4) – (PEflare,y/ GWPCH4), where PEflare = LFGflare * (1-ηflare) * GWPCH4. One is as subtraction. Therefore, applying adjustment of -1% to the second formula (i.e. PEflare = LFGflare * (1-ηflare) * GWPCH4) would not be as conservative as applying adjustment of +1%.