20:00 23 Nov 24
Info Report Check
Submission incomplete:
1: VVS-PoA, paragraph 122:
The DOE is requested to further explain how it has validated the methods to calculate baseline emissions, projects emissions and leakage in accordance with the applied methodologies and applicable tools as:
(a) Generic CPA type II does not include PEFC,RDF_SB,y (Project emissions from fossil fuel consumption associated with RDF/SB (production and on-site combustion) in year y) and PEww,RDF_SB,y (Project emissions from the wastewater treatment associated with RDF/SB (production and on-site combustion) in year y) which are required by ACM0022 (version 02.0), and there is no explanation why they are not included;
(b) Generic CPA type I on page 37 states that the CPAs will be connected to grid, however, for exigency the DG set may be installed to meet requirement during no grid supply, and that in line with applied approved methodology the project emission on account of fossil fuel consumption can be calculated using “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion”. However, as per paragraph 17 of Methodological tool: Project and leakage emissions from composting (version 02.0), where the composting activity involves electricity consumption from the grid or from a fossil fuel fired on-site power plant, project emissions from electricity consumption shall be calculated using the latest approved version of the methodological tool “Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation”;
(c) The PoA-DD on page 2 states that partial-biodegradable/combustible component will be further processed to make refuse derived fuel (RDF) to be used in boiler along with methane and other waste to generate electricity. The DOE clarifies that the project emissions due to combustion of other materials have been now considered in the revised PoA-DD. However, the PoA-DD only has project emissions due to combustion of fossil fuels. It does not have provisions to calculate project emissions due to combustion of other materials than RDF;
(d) For project emissions from electricity consumption, generic CPA type III on page 136 concludes that the applicable scenario is Scenario C, case C.III. Where case C.III has been identified, as a conservative simple approach, the emission factor for electricity generation should be the more conservative value between the emission factor determined as per guidance for scenario A and B respectively. The generic CPA type III has defined the applicable emission factor for scenario A (option A1), however it has not defined the applicable emission factor for scenario B;
(e) Generic CPA type III does not specify any particular type of fossil fuel in order to calculate project emission from fossil fuel consumption using option A and option B (page 137 of PoA-DD). However, as shown in the section I.6.8 of the PoA-DD (Data and parameters fixed ex ante) under parameters NCVdiesel,y, EFCO2,diesel,y and density of diesel, the PP considered the fuel as diesel.
2: VVS-PoA, paragraph 124(a):
The DOE is requested to explain how it validated the fixed ex-ante parameters, in particular:
(a) The source of data and choice of data or Measurement methods and procedures of parameters NCVdiesel,y and EFCO2,diesel,y under Generic CPA type II are not as per the Methodological tool “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion” (Version 3.0).
(b) For Generic CPA type II, the DOE is requested to explain how it validated that: (i) for parameters NCVdiesel,y and EFCO2,diesel,y, fuel supplier does not provide the value in their invoices and also this parameter value is not available top through measurement; (ii) Regional or national default values are not available; considering that the DOE is not validating CPA inclusion and the value may be available during CPA inclusion;
(c) Generic CPA type I and type II state that parameter Combined Margin CO2 emission factor for the India Grid in year y (EFgrid,CM,y) is to be determined at CPA level. However, they refer to Central Electricity Authority (CEA) of India Database Version 12.0.
3: VVS-PoA, paragraphs 129 and 130(a):
The DOE is requested to explain how it confirmed that the monitoring plan has been found to be in compliance with the requirements of the applied methodology and applicable tools as:
(a) Parameters that are required to calculate leakage emissions associated with the end-use of RDF/SB exported outside the project boundary (LEENDUSE, RDF_SB,y) for Generic CPA type II are not included in the monitoring plan;
(b) Parameters that are required to calculate project emissions from fossil fuel consumption associated with RDF/SB (production and on-site combustion) in year y (PEFC,RDF_SB,y) for Generic CPA type I are not included in the monitoring plan.
(c) Parameters that are required to calculate project emission from fossil fuel consumption using option A and option B (pages 93 and 94 of PoA-DD) for calculation of Project emissions associated with RDF/SB in year y (PERDF_SB,y) under Generic CPA type II are not all included in the monitoring plan. It is also observed that parameters NCVdiesel,y and EFCO2,diesel,y are considered as parameters fixed ex ante, whereas these parameters are parameters to be monitored as per the “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion” (version 03.0).
(d) Generic CPA type I and type II describe a sampling plan. However, it does not state for which parameter(s) and does not describe a complete sampling plan as required by Standard for Sampling and surveys for CDM project activities and programmes of activities (version 08.0), paragraph 8, and sections 4 and 5 in general.
(e) Parameters that are required to calculate project emission from fossil fuel consumption using option A and option B (page 137 of PoA-DD) under Generic CPA type III are not all included in the monitoring plan. It is also observed that parameters NCVdiesel,y, EFCO2,diesel,y and density of diesel are considered as parameters fixed ex ante, whereas these parameters are parameters to be monitored as per the “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion” (version 03.0).
4: VVS-PoA, paragraphs 136-137:
The DOE is requested to explain how it has validated the eligibility criteria for the inclusion of CPAs, in particular how eligibility criterion no. 15 of Generic CPA type I and type II is in line with paragraphs 114(a), (b) and (c) of ACM0022 (version 02.0) as this criterion has not defined: (i) Type of solid waste disposal site of CPAs to be included under the PoA; (ii) Ranges of capacity of the treatment plant or unit of CPAs to be included under the PoA; (iii) Composition of the waste in the CPAs to be included under the PoA.
1: VVS-PoA, paragraph 122:
The DOE is requested to further explain how it has validated the methods to calculate baseline emissions, projects emissions and leakage in accordance with the applied methodologies and applicable tools as:
(a) Generic CPA type II does not include PEFC,RDF_SB,y (Project emissions from fossil fuel consumption associated with RDF/SB (production and on-site combustion) in year y) and PEww,RDF_SB,y (Project emissions from the wastewater treatment associated with RDF/SB (production and on-site combustion) in year y) which are required by ACM0022 (version 02.0), and there is no explanation why they are not included;
(b) Generic CPA type I on page 37 states that the CPAs will be connected to grid, however, for exigency the DG set may be installed to meet requirement during no grid supply, and that in line with applied approved methodology the project emission on account of fossil fuel consumption can be calculated using “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion”. However, as per paragraph 17 of Methodological tool: Project and leakage emissions from composting (version 02.0), where the composting activity involves electricity consumption from the grid or from a fossil fuel fired on-site power plant, project emissions from electricity consumption shall be calculated using the latest approved version of the methodological tool “Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation”;
(c) The PoA-DD on page 2 states that partial-biodegradable/combustible component will be further processed to make refuse derived fuel (RDF) to be used in boiler along with methane and other waste to generate electricity. The DOE clarifies that the project emissions due to combustion of other materials have been now considered in the revised PoA-DD. However, the PoA-DD only has project emissions due to combustion of fossil fuels. It does not have provisions to calculate project emissions due to combustion of other materials than RDF;
(d) For project emissions from electricity consumption, generic CPA type III on page 136 concludes that the applicable scenario is Scenario C, case C.III. Where case C.III has been identified, as a conservative simple approach, the emission factor for electricity generation should be the more conservative value between the emission factor determined as per guidance for scenario A and B respectively. The generic CPA type III has defined the applicable emission factor for scenario A (option A1), however it has not defined the applicable emission factor for scenario B;
(e) Generic CPA type III does not specify any particular type of fossil fuel in order to calculate project emission from fossil fuel consumption using option A and option B (page 137 of PoA-DD). However, as shown in the section I.6.8 of the PoA-DD (Data and parameters fixed ex ante) under parameters NCVdiesel,y, EFCO2,diesel,y and density of diesel, the PP considered the fuel as diesel.
2: VVS-PoA, paragraph 124(a):
The DOE is requested to explain how it validated the fixed ex-ante parameters, in particular:
(a) The source of data and choice of data or Measurement methods and procedures of parameters NCVdiesel,y and EFCO2,diesel,y under Generic CPA type II are not as per the Methodological tool “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion” (Version 3.0).
(b) For Generic CPA type II, the DOE is requested to explain how it validated that: (i) for parameters NCVdiesel,y and EFCO2,diesel,y, fuel supplier does not provide the value in their invoices and also this parameter value is not available top through measurement; (ii) Regional or national default values are not available; considering that the DOE is not validating CPA inclusion and the value may be available during CPA inclusion;
(c) Generic CPA type I and type II state that parameter Combined Margin CO2 emission factor for the India Grid in year y (EFgrid,CM,y) is to be determined at CPA level. However, they refer to Central Electricity Authority (CEA) of India Database Version 12.0.
3: VVS-PoA, paragraphs 129 and 130(a):
The DOE is requested to explain how it confirmed that the monitoring plan has been found to be in compliance with the requirements of the applied methodology and applicable tools as:
(a) Parameters that are required to calculate leakage emissions associated with the end-use of RDF/SB exported outside the project boundary (LEENDUSE, RDF_SB,y) for Generic CPA type II are not included in the monitoring plan;
(b) Parameters that are required to calculate project emissions from fossil fuel consumption associated with RDF/SB (production and on-site combustion) in year y (PEFC,RDF_SB,y) for Generic CPA type I are not included in the monitoring plan.
(c) Parameters that are required to calculate project emission from fossil fuel consumption using option A and option B (pages 93 and 94 of PoA-DD) for calculation of Project emissions associated with RDF/SB in year y (PERDF_SB,y) under Generic CPA type II are not all included in the monitoring plan. It is also observed that parameters NCVdiesel,y and EFCO2,diesel,y are considered as parameters fixed ex ante, whereas these parameters are parameters to be monitored as per the “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion” (version 03.0).
(d) Generic CPA type I and type II describe a sampling plan. However, it does not state for which parameter(s) and does not describe a complete sampling plan as required by Standard for Sampling and surveys for CDM project activities and programmes of activities (version 08.0), paragraph 8, and sections 4 and 5 in general.
(e) Parameters that are required to calculate project emission from fossil fuel consumption using option A and option B (page 137 of PoA-DD) under Generic CPA type III are not all included in the monitoring plan. It is also observed that parameters NCVdiesel,y, EFCO2,diesel,y and density of diesel are considered as parameters fixed ex ante, whereas these parameters are parameters to be monitored as per the “Tool to calculate project or leakage CO2 emissions from fossil fuel combustion” (version 03.0).
4: VVS-PoA, paragraphs 136-137:
The DOE is requested to explain how it has validated the eligibility criteria for the inclusion of CPAs, in particular how eligibility criterion no. 15 of Generic CPA type I and type II is in line with paragraphs 114(a), (b) and (c) of ACM0022 (version 02.0) as this criterion has not defined: (i) Type of solid waste disposal site of CPAs to be included under the PoA; (ii) Ranges of capacity of the treatment plant or unit of CPAs to be included under the PoA; (iii) Composition of the waste in the CPAs to be included under the PoA.
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