Info Report Check
Submission incomplete:
Paragraph 231 of the CDM Project Standard for Project Activities (PS-PA) (version 2) allows the PP to seek deviation and it requires that the PP shall describe the nature, extent and duration of the non-conforming monitoring period in the monitoring report, and (a) propose alternative monitoring arrangements for the non-conforming monitoring period by applying conservative assumptions or discount factors to the calculations to the extent required to ensure that GHG emission reductions or net anthropogenic GHG removals will not be over-estimated as a result of the deviation; or (b) apply the following most conservative values approach when alternative monitoring arrangements are not proposed.
In the first submission, the PP/DOE applied a conservative approach without filing the deviation with a justification. In this submission, the PP/DOE has requested a deviation but directly applied the above (b) option which causes an interference impact on the emission reductions when applying the concept of annual capacity cap instead of daily cap to the calculation of baseline emissions, because part of the actual production of nitric acid has taken place during the deviation period. Based on the submitted monitoring results, it is observed that the N2O abatement system kept operating during the deviation period i.e. emission reductions have been achieved, although no reliable inlet monitoring results were available. Kindly please follow the CDM PS-PA (version 2) paragraph 231 in filing the deviation request by:
(1) Identifying an appropriate alternative such as the lowest observed inlet N2O emissions or another alternative such as the value referred to by the methodology, and providing a justification regarding this alternative on why it would not result in over-estimation of emission reductions; only when an alternative is not available, the PP may voluntarily opt for zero emission reductions during the concerned period of deviation.
(2) Correctly applying the concept of cap based on “Pproduct, max” by following the methodology equation correctly: BEy = sum [FTI,i * CIN2O,i * Mi] / Pproduct,y * GWPN2O * Minimum(Pproduct,max ,Pproduct,y), after the first step (1). It has been observed that the methodological equation requires the application of the lower value between “Pproduct, max” and “Pproduct,y” whereas the PP has applied the higher value Pproduct in the daily calculations, as demonstrated in the example highlighted on page 33 of 37 of the revised Monitoring Report.