12:08 27 Nov 24
Info Report Check
Submission incomplete:
1: The PoA-DD page 13 mentions that a template LUC has been prepared and provided as an appendix of the PoA-DD. However, the PoA-DD does not include any appendix containing template for LUC.
2: The length of fixed crediting period mentioned in generic CPA-DD for scenario 2 is 10 years. The PoA-DD on page 95 mentions that if the remaining lifetime of the affected systems increases due to the Project activity, the crediting period is limited to the estimated remaining lifetime, i.e., the time when the affected systems would have been replaced in the absence of the Project activity. It is not clear how establishing the length of crediting period as 10 years is in line with the provision on page 95 of the PoA-DD. Please refer to paragraph 122 of PS-PoA.
3: The DOE is requested to explain how it validated the description of the proposed PoA in line with paragraph 42 of VVS-PoA, in particular the type of biomass to be utilized by CPAs under the PoA. In different places, the PoA-DD mentions "biomass" (which implies not limited to biomass residue), "biomass residue", "rice husk", and "saw dust'.
4: The DOE is requested to explain how it validated how the CPAs will meet all the applicability conditions of the methodology as per paragraph 102 of VVS-PoA. All generic CPA-DDs concludes that the applicability conditions relating to the use of solid biomass fuel such as briquette and relating to charcoal (paragraphs 11, 12 and 16 of methodology) are not applicable. However, in the absence of clarity on the type of biomass to be utilized by CPAs, it is not clear how such conclusion can be made. Furthermore, pages 14 and 15 of the PoA-DD indicate the use of briquette.
5: The DOE is requested to explain how it has validated the correct application of equations and parameters in line with paragraphs 122 and 123 of VVS-PoA, in particular:
(a) Project emissions from fossil fuel consumption: Generic CPA-DD of scenario 1 and scenario 3 opted option B to calculate the project emissions from fossil fuel consumption. However, it is not clear why parameter WC,i,y (Weighted average mass fraction of carbon in fuel type i in year y) and Weighted average density of fuel type i in year y in the calculation, which are used under option A and not used under option B, will also be monitored;
(b) Leakage emissions from transport of biomass: The equations to calculate the emissions from transport of biomass described in all generic CPA-DDs are not in line with any of the options described in the tool “Project or leakage emissions from road transportation of freight” (version 1.1.0);
(c) The equations in the relevant section for baseline emissions for retrofit project (section 5.2.10 of the methodology) are not used by the generic CPA-DD for scenario 2;
(d) In the absence of clarity of the type of biomass to be utilized by CPAs under the PoA, it is not clear why project emissions from cultivation of biomass are not considered by all generic CPA-DDs;
(e) In the absence of clarity of the type of biomass to be utilized by CPAs under the PoA, it is not clear why all generic CPA-DDs consider only leakage source from diversion of biomass residue from tool “Project and leakage emissions from biomass” (version 04.0);
(f) All generic CPA-DDs have not considered requirements in paragraph 42 e (ii) and (iii) from the tool “Project and leakage emissions from biomass” (version 04.0);
(g) With regard to the project emissions from electricity consumption, all generic CPA-DDs describe that the CPA will use grid electricity. However, the monitoring plan includes monitoring of parameter Auxiliary Electricity Consumption of the Project activity from the off grid Captive Power Plant (Diesel Generator set or Fossil fuel based power source) in a year y, which indicates the use of electricity from captive power plant. This contradicts the statement that the CPA will use grid electricity;
(h) Generic CPA-DD for scenario 3 includes a fixed ex ante parameter nBL,thermal (The Efficiency of the plant using fossil fuel that would have been used in the absence of the Project activity). However, none of the formulas in the generic CPA-DD for scenario 3 includes this parameter;
(i) Generic CPA-DD for scenario 3 includes the following parameters to be monitored: Qsteam,old,y; Tsteam,old,y; Psteam,old,y; TFWB,old,y; Qflow,old,y; Tin,old,y;Tout,old,y and hold,y. However, it is not clear what these parameters are used for as none of the formulas in the generic CPA-DD for scenario 3 includes these parameters;
(j) With regard to leakage emissions from biomass, all generic CPA-DDs: (i) Have not included the provision to determine the alternative scenarios of the biomass residues in absence of the project activity, which alternative scenarios for the use of biomass residue are described in paragraph 40 of the tool “Project and leakage emissions from biomass” (version 04.0); (ii) Considered the area within 50 km radial distance for the determination of surplus of biomass, whereas as per the tool, the project region is defined as area within a radius of 250km around the project activity;
(k) The generic CPA-DD of scenario 2 in page 95 makes reference to clarification SSC_374, which was requested under version 16 of AMS-I.C. The DOE is requested to explain how this the clarification occurred in 2009 is still relevant as in the clarification the SSC-WG concluded that it agreed to include more detailed procedures for retrofit of fossil fuel thermal generating equipment to use biomass residues including guidelines to ensure comparable level of service during the baseline and the project at the time of proposing the next revision to AMS-I.C;
(l) The generic CPA-DDs of scenario 1 (for greendfield project) and scenario 3 have not included provision for determining baseline scenario as per the “General guidelines for SSC CDM methodologies”, which is required by paragraph 6 of the methodology.
(m) As per paragraph 175 of PS-PoA, in case of replacement of existing equipment, the CME shall estimate the point in time when the existing equipment would be replaced in the absence of the proposed CPA in accordance with the “Tool to determine the remaining lifetime of equipment”. However, this provision is not included in generic CPA-DD for scenario 1.
6: The DOE is requested to explain how it has validated the monitoring plan in the generic CPA-DDs in line with paragraphs 129 and 130(a) of VVS-PoA, in particular:
(a) With regard to the project emissions from electricity consumption, all generic CPA-DDs do not include parameter TDLj,y as parameter to be monitored as per the tool “Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation” (version 03.0). This parameter is instead considered as fixed ex ante parameter;
(b) With regard to the leakage emissions due to processing of biomass by utilizing electricity, all generic CPA-DDs do not include parameters ECLEi,y and TDLi,y as parameters to be monitored as per the tool “Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation” (version 03.0). These parameters are instead considered as fixed ex ante parameters;
(c) With regard to the leakage emissions due to processing of biomass by utilizing electricity, all generic CPA-DDs assume that EFEL,i,y (Emission Factor for fossil fuel-based electricity generation for source i in year y) equals EFEL,j,y (Emission Factor for fossil fuel-based electricity generation for source j). The DOE is requested to explain how it validated that the source of electricity generation for process of biomass in a particular CPA will always be the same as the source of electricity generation for electricity consumption at the project site at the stage of PoA registration;
(d) With regard to leakage emissions from biomass, all generic CPA-DDs do not include parameter “Biomass residues categories and quantities used in the project activity" which is listed as parameter to be monitored (Data / Parameter table 2) in the tool “Project and leakage emissions from biomass” (version 04.0).
7: The DOE is requested to explain how it has validated the eligibility criteria in the generic CPA-DDs in line with paragraph 137 of VVS-PoA, in particular:
(a) For generic CPA-DD for scenario 2, the PoA-DD on page 95 mentions that if the remaining lifetime of the affected systems increases due to the Project activity, the crediting period is limited to the estimated remaining lifetime, i.e., the time when the affected systems would have been replaced in the absence of the Project activity. However, this provision is not considered in the eligibility criterion 13 about the crediting period of CPA;
(b) The eligibility criterion 17 for all generic CPA-DDs mentions that biomass residues which are not in line with the “Definition of Renewable Biomass” as per Annex 18 of EB 23 and “Glossary of CDM terms (Version 05)” shall not be utilised. However, the criterion has not explained how the renewability of the biomass will be checked or validated, and how the declaration from CPA Operator and Biomass purchase contract can confirm the fulfillment of conditions described in the “Definition of Renewable Biomass”;
(c) Pertaining to additionality: (i) How it is adequate that the approach for comparison analysis for all generic CPA-DDs is the same, considering different baseline scenario approach for each generic CPA-DD. For example, the baseline scenario for greenfield project under generic CPA-DD for scenario 1 would be a greenfield fossil fuel heat generating unit for which investment cost can be included in the analysis. However, the baseline scenario for CPA under generic CPA-DD for scenario 2 would be the continuation of the operation of the existing fossil fuel heat generating unit for which investment cost is not applicable in the analysis; (ii) The information about the approach to conduct comparison analysis does not describe what the discount factor will be.
1: The PoA-DD page 13 mentions that a template LUC has been prepared and provided as an appendix of the PoA-DD. However, the PoA-DD does not include any appendix containing template for LUC.
2: The length of fixed crediting period mentioned in generic CPA-DD for scenario 2 is 10 years. The PoA-DD on page 95 mentions that if the remaining lifetime of the affected systems increases due to the Project activity, the crediting period is limited to the estimated remaining lifetime, i.e., the time when the affected systems would have been replaced in the absence of the Project activity. It is not clear how establishing the length of crediting period as 10 years is in line with the provision on page 95 of the PoA-DD. Please refer to paragraph 122 of PS-PoA.
3: The DOE is requested to explain how it validated the description of the proposed PoA in line with paragraph 42 of VVS-PoA, in particular the type of biomass to be utilized by CPAs under the PoA. In different places, the PoA-DD mentions "biomass" (which implies not limited to biomass residue), "biomass residue", "rice husk", and "saw dust'.
4: The DOE is requested to explain how it validated how the CPAs will meet all the applicability conditions of the methodology as per paragraph 102 of VVS-PoA. All generic CPA-DDs concludes that the applicability conditions relating to the use of solid biomass fuel such as briquette and relating to charcoal (paragraphs 11, 12 and 16 of methodology) are not applicable. However, in the absence of clarity on the type of biomass to be utilized by CPAs, it is not clear how such conclusion can be made. Furthermore, pages 14 and 15 of the PoA-DD indicate the use of briquette.
5: The DOE is requested to explain how it has validated the correct application of equations and parameters in line with paragraphs 122 and 123 of VVS-PoA, in particular:
(a) Project emissions from fossil fuel consumption: Generic CPA-DD of scenario 1 and scenario 3 opted option B to calculate the project emissions from fossil fuel consumption. However, it is not clear why parameter WC,i,y (Weighted average mass fraction of carbon in fuel type i in year y) and Weighted average density of fuel type i in year y in the calculation, which are used under option A and not used under option B, will also be monitored;
(b) Leakage emissions from transport of biomass: The equations to calculate the emissions from transport of biomass described in all generic CPA-DDs are not in line with any of the options described in the tool “Project or leakage emissions from road transportation of freight” (version 1.1.0);
(c) The equations in the relevant section for baseline emissions for retrofit project (section 5.2.10 of the methodology) are not used by the generic CPA-DD for scenario 2;
(d) In the absence of clarity of the type of biomass to be utilized by CPAs under the PoA, it is not clear why project emissions from cultivation of biomass are not considered by all generic CPA-DDs;
(e) In the absence of clarity of the type of biomass to be utilized by CPAs under the PoA, it is not clear why all generic CPA-DDs consider only leakage source from diversion of biomass residue from tool “Project and leakage emissions from biomass” (version 04.0);
(f) All generic CPA-DDs have not considered requirements in paragraph 42 e (ii) and (iii) from the tool “Project and leakage emissions from biomass” (version 04.0);
(g) With regard to the project emissions from electricity consumption, all generic CPA-DDs describe that the CPA will use grid electricity. However, the monitoring plan includes monitoring of parameter Auxiliary Electricity Consumption of the Project activity from the off grid Captive Power Plant (Diesel Generator set or Fossil fuel based power source) in a year y, which indicates the use of electricity from captive power plant. This contradicts the statement that the CPA will use grid electricity;
(h) Generic CPA-DD for scenario 3 includes a fixed ex ante parameter nBL,thermal (The Efficiency of the plant using fossil fuel that would have been used in the absence of the Project activity). However, none of the formulas in the generic CPA-DD for scenario 3 includes this parameter;
(i) Generic CPA-DD for scenario 3 includes the following parameters to be monitored: Qsteam,old,y; Tsteam,old,y; Psteam,old,y; TFWB,old,y; Qflow,old,y; Tin,old,y;Tout,old,y and hold,y. However, it is not clear what these parameters are used for as none of the formulas in the generic CPA-DD for scenario 3 includes these parameters;
(j) With regard to leakage emissions from biomass, all generic CPA-DDs: (i) Have not included the provision to determine the alternative scenarios of the biomass residues in absence of the project activity, which alternative scenarios for the use of biomass residue are described in paragraph 40 of the tool “Project and leakage emissions from biomass” (version 04.0); (ii) Considered the area within 50 km radial distance for the determination of surplus of biomass, whereas as per the tool, the project region is defined as area within a radius of 250km around the project activity;
(k) The generic CPA-DD of scenario 2 in page 95 makes reference to clarification SSC_374, which was requested under version 16 of AMS-I.C. The DOE is requested to explain how this the clarification occurred in 2009 is still relevant as in the clarification the SSC-WG concluded that it agreed to include more detailed procedures for retrofit of fossil fuel thermal generating equipment to use biomass residues including guidelines to ensure comparable level of service during the baseline and the project at the time of proposing the next revision to AMS-I.C;
(l) The generic CPA-DDs of scenario 1 (for greendfield project) and scenario 3 have not included provision for determining baseline scenario as per the “General guidelines for SSC CDM methodologies”, which is required by paragraph 6 of the methodology.
(m) As per paragraph 175 of PS-PoA, in case of replacement of existing equipment, the CME shall estimate the point in time when the existing equipment would be replaced in the absence of the proposed CPA in accordance with the “Tool to determine the remaining lifetime of equipment”. However, this provision is not included in generic CPA-DD for scenario 1.
6: The DOE is requested to explain how it has validated the monitoring plan in the generic CPA-DDs in line with paragraphs 129 and 130(a) of VVS-PoA, in particular:
(a) With regard to the project emissions from electricity consumption, all generic CPA-DDs do not include parameter TDLj,y as parameter to be monitored as per the tool “Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation” (version 03.0). This parameter is instead considered as fixed ex ante parameter;
(b) With regard to the leakage emissions due to processing of biomass by utilizing electricity, all generic CPA-DDs do not include parameters ECLEi,y and TDLi,y as parameters to be monitored as per the tool “Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation” (version 03.0). These parameters are instead considered as fixed ex ante parameters;
(c) With regard to the leakage emissions due to processing of biomass by utilizing electricity, all generic CPA-DDs assume that EFEL,i,y (Emission Factor for fossil fuel-based electricity generation for source i in year y) equals EFEL,j,y (Emission Factor for fossil fuel-based electricity generation for source j). The DOE is requested to explain how it validated that the source of electricity generation for process of biomass in a particular CPA will always be the same as the source of electricity generation for electricity consumption at the project site at the stage of PoA registration;
(d) With regard to leakage emissions from biomass, all generic CPA-DDs do not include parameter “Biomass residues categories and quantities used in the project activity" which is listed as parameter to be monitored (Data / Parameter table 2) in the tool “Project and leakage emissions from biomass” (version 04.0).
7: The DOE is requested to explain how it has validated the eligibility criteria in the generic CPA-DDs in line with paragraph 137 of VVS-PoA, in particular:
(a) For generic CPA-DD for scenario 2, the PoA-DD on page 95 mentions that if the remaining lifetime of the affected systems increases due to the Project activity, the crediting period is limited to the estimated remaining lifetime, i.e., the time when the affected systems would have been replaced in the absence of the Project activity. However, this provision is not considered in the eligibility criterion 13 about the crediting period of CPA;
(b) The eligibility criterion 17 for all generic CPA-DDs mentions that biomass residues which are not in line with the “Definition of Renewable Biomass” as per Annex 18 of EB 23 and “Glossary of CDM terms (Version 05)” shall not be utilised. However, the criterion has not explained how the renewability of the biomass will be checked or validated, and how the declaration from CPA Operator and Biomass purchase contract can confirm the fulfillment of conditions described in the “Definition of Renewable Biomass”;
(c) Pertaining to additionality: (i) How it is adequate that the approach for comparison analysis for all generic CPA-DDs is the same, considering different baseline scenario approach for each generic CPA-DD. For example, the baseline scenario for greenfield project under generic CPA-DD for scenario 1 would be a greenfield fossil fuel heat generating unit for which investment cost can be included in the analysis. However, the baseline scenario for CPA under generic CPA-DD for scenario 2 would be the continuation of the operation of the existing fossil fuel heat generating unit for which investment cost is not applicable in the analysis; (ii) The information about the approach to conduct comparison analysis does not describe what the discount factor will be.
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