Info Report Check
Submission incomplete:
1: The DOE shall provide further information on how it has verified the implementation of CPAs during this monitoring period, in particular:
(a) the technical specification and operation status of four CPAs (i.e. CPA 05, 06, 20 and 29), considering that this request for issuance includes 13 CPAs whereas section E.3.1 of the verification report does not include the verification opinion on these four CPAs;
(b) for CPA 01, information on when the two 300 kW gas engines stopped operation and how the DOE verified the cease of operation, considering that pages 16 and 21 of the verification report mention that the two 300kW gas engines are no longer in working condition;
(c) for CPA 02, page 21 of the verification report mentions "Recommissioning of microturbine and commissioning of microturbine 2 (C1000) on 14/12/2017". However, (i) it is not clear which specific microturbine is indicated in this statement and (ii) whether any of the microturbines is still in working condition during this monitoring period.


2: The DOE shall clarify and address the inconsistency in describing the monitoring practice of parameter BGburnt,y in CPAs 01 and 02. E.g. (a) For CPA 01, page 29 of the verification report mentions “the data logger was working until 01/12/2015 and from there on the measurements were done manually” whereas page 37 of the monitoring report indicates that the flare flow meter was used until 01/12/2015; and (b) page 29 of the verification report indicates that no biogas sent to flare is claimed for CPA 01 or CPA 02 whereas page 38 of the monitoring report states that the emission reductions from the flare are claimed for the months of April, June and July 2016 for CPA 02. In doing that, the DOE shall provide clarity on the availability of monitoring equipment, the availability of monitored values and the claim for emission reductions, regarding each stream of the biogas sent to flare or combustion of each CPA relevant.


3: The emission reduction calculation sheets are not traceable, e.g. in the spreadsheet “POA 5979 CPA-02 ERclean_14Dec2022_resubmitted (1).xlsx”, the calculation of MDy,flare in cell O13 or MDy-energy in cell N14 in the table “MDy-PEpower,y,ex-post” are not traceable. The DOE shall clarify how it has verified that these emission reductions have been correctly calculated in accordance with the approved methodology.


4: The DOE shall clarify whether a site visit was carried out for CPA 51, considering that page 22 of the verification report indicates a site visit was conducted to CPA 51 whereas section D.2 of the verification report states onsite visit was not performed.