Info Report Check
Submission incomplete:
1: For the proposed temporary deviation, the alternative monitoring arrangement is that the external biomass is not accounted in the CERs in December 2017:
(a) Even though the monitoring report states that this external source of biomass (317.86 tons) was measured by scale 2, the ER spreadsheet does not show that there was any measurement by scale 2 in December 2017 (the value was zero) and it is not evident from the ER spreadsheet that the amount of 317.86 tons has been excluded in the ER calculation;
(b) Since the use of this external biomass from other source is not as per the description of the project activity, the DOE is requested to explain how the proposed arrangement has been conservative as portion of electricity in December 2017 was also generated by this source of biomass.
Please refer to paragraph 283 of VVS for project activities (version 02.0)


2: For permanent changes to the registered monitoring plan, the PDD has not described the nature and extent of the non-conforming monitoring as required by paragraph 238 of PS for project activities (version 02.0).


3: The DOE has not provided information how it validated the proposed permanent changes to the registered monitoring plan particularly:
(a) How the proposed changes are in accordance with paragraph 239 of PS for project activities (version 02.0);
(b) Even though the parameters MCy and NCVbiomass dry are only used for crosschecking, how the proposed changes ensure that the result of the crosscheck will not overestimate the emission reductions.
Please refer to paragraphs 296 and 298 of VVS for project activities (version 02.0).


4: Considering the ER spreadsheet shows the measured values from scale 2 are zero during the monitoring period, the DOE is requested to clarify whether there are no other biomass waste except the one from MIL and other source considered under the temporary deviation.
Please refer to paragraph 355 of VVS for project activities (version 02.0).


5: The DOE is requested to explain how it verified parameter EFgrid,y in line with the PDD. As per the PDD, the parameter is calculated as per option A1 of "Tool to calculate the emission factor for an electricity system" (version 5). As per this tool, if IPCC values are used, NCVi,y and EFCO2,y are based on the lower limit. However, the the calculation sheets of the EFgrid,y shows that upper limit values are used.
Please refer to paragraph 360 of VVS for project activities (version 02.0).


6: The DOE is requested to explain how the frequency of calibration of power meters and scales 1 and 2 measuring is in line with the monitoring plan. The monitoring plan states that the PP shall ensure the equipments are calibrated either in accordance with the local/national standards, or as per the manufacturer’s specifications, and if local/national standards or the manufacturer’s specifications are not available, international standards may be used. However, the verification report only concludes that calibration frequency is at least once in three years. Furthermore, instructions in annex 14 of EB54 mentions that measuring equipment should still be recalibrated at appropriate intervals according to manufacturer specifications, but at least once in 3 years.
Please refer to paragraphs 365 and 370 of VVS for project activities (version 02.0).


7: The DOE is request to explain how it verified the calculation of PETR,m. The ER spreadsheet shows that only measured value of FRf,m and CTy,ash in 2017 are considered for PETR,m calculation.
Please refer to paragraph 372 of VVS for project activities (version 02.0).