12:40 27 Nov 24
Info Report Check
Submission incomplete:
1: The project/pre-project scenarios stated in single generic CPA-DD are contradicting. For example, in the generic CPA-DD #1, page 22 states that the generic CPA may involve existing LFG capture system whereas the scenario of existing LFG capture has been eliminated in determining parameter FCH4,BL in page 34 which further states “this generic CPA comprehends a total release of LFG from the SWDS under the baseline scenario”.
2: In determining the baseline parameter FCH4,BL, paragraph 39 of ACM0001 version 19 requires consideration of regulatory or contractual requirements in addressing safety and odour concerns or for other reasons. Page 34 of the PoA-DD (i.e. generic CPA-DD #1) has concluded "No requirement to destroy methane exists". However, the DOE did not provide information on how it has validated the correctness of the conclusion in the generic CPA-DD and did not specify the requirements validated by the DOE.
3: The eligibility criteria related to technology specification (e.g. criteria in page 67 for generic CPA-DD #1) are not in line with paragraph 78 of ACM0001 version 19, e.g. lack of specifying the ranges design specifications (ranges of sizes of landfill and amounts of waste disposed) etc. Therefore, the DOE shall further provide information on how it has validated the eligibility criteria in the generic CPAs related to the technology specification in accordance with paragraph 124(d) of PS for PoA version 2 and paragraph 78 of ACM0001 version 19.
4: For generic CPAs applying the Combined tool (TOOL02) to demonstrate additionality, the relevant eligibility criteria refers to section I.5 of the generic CPA-DD in which several input values (i.e. CapEx, OpEx, Total revenues, Taxes, Depreciation and Asset´s lifetime) for investment analysis are defined. However, the eligibility criteria for CPAs applying TOOL02 does not include ranges of costs or ranges of revenues, as required by paragraph 78 of ACM0001 version 19. The DOE shall further provide information on how it has validated the eligibility criteria related to additionality demonstration in accordance with paragraph 78 of ACM0001 version 19.
1: The project/pre-project scenarios stated in single generic CPA-DD are contradicting. For example, in the generic CPA-DD #1, page 22 states that the generic CPA may involve existing LFG capture system whereas the scenario of existing LFG capture has been eliminated in determining parameter FCH4,BL in page 34 which further states “this generic CPA comprehends a total release of LFG from the SWDS under the baseline scenario”.
2: In determining the baseline parameter FCH4,BL, paragraph 39 of ACM0001 version 19 requires consideration of regulatory or contractual requirements in addressing safety and odour concerns or for other reasons. Page 34 of the PoA-DD (i.e. generic CPA-DD #1) has concluded "No requirement to destroy methane exists". However, the DOE did not provide information on how it has validated the correctness of the conclusion in the generic CPA-DD and did not specify the requirements validated by the DOE.
3: The eligibility criteria related to technology specification (e.g. criteria in page 67 for generic CPA-DD #1) are not in line with paragraph 78 of ACM0001 version 19, e.g. lack of specifying the ranges design specifications (ranges of sizes of landfill and amounts of waste disposed) etc. Therefore, the DOE shall further provide information on how it has validated the eligibility criteria in the generic CPAs related to the technology specification in accordance with paragraph 124(d) of PS for PoA version 2 and paragraph 78 of ACM0001 version 19.
4: For generic CPAs applying the Combined tool (TOOL02) to demonstrate additionality, the relevant eligibility criteria refers to section I.5 of the generic CPA-DD in which several input values (i.e. CapEx, OpEx, Total revenues, Taxes, Depreciation and Asset´s lifetime) for investment analysis are defined. However, the eligibility criteria for CPAs applying TOOL02 does not include ranges of costs or ranges of revenues, as required by paragraph 78 of ACM0001 version 19. The DOE shall further provide information on how it has validated the eligibility criteria related to additionality demonstration in accordance with paragraph 78 of ACM0001 version 19.
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