12:37 27 Nov 24
Info Report Check
Submission incomplete:
1: The PoA descriptions in the PoA-DD are not consistent, for example page 20 of the PoA-DD indicate pre-project usage of LFG (i.e. the PoA makes investment into new or existing LFG capture system to increase the LFG collection efficiency and change the use of the captured LFG) whereas it also states “the captured LFG was partially flared and not used prior to the implementation of the project activity”. In addition, it also did not describe whether the project is to be implemented in new or existing SWDS. The PoA-DD is requested to address inconsistency and provide clarity in its generic CPA-DDs on the pre-project scenarios involved: (a) new or existing SWDS; (b) new or existing LFG capture system; (c) partial flaring of LFG; and (d) pre-project usage of LFG. The DOE is requested to validate the accuracy and completeness of the PoA description. Please refer to paragraph 77 and 78 of ACM0001.
2: In ACM0001, paragraph 77 requires PoA-DD describes each type of CPAs separately, and paragraph 78 requires justification on the classification of CPA types based on a series of factors including baseline scenario. However, it is not clear whether baseline scenario would varies considering the various pre-project scenarios covered by the PoA as mentioned in the issue above. The DOE is requested to provide information on how it has validated and provide clarity on the baseline scenarios considering various pre-project scenario, including but not limited to (a) new LFG capture system; (b) existing LFG capture system; (c) pre-project usage of captured LFG; (d) pre-project flaring scenario; and (e) new or existing SWDS etc. In addition, taking into those various scenario, the PoA-DD shall also describe transparently and justify the classification of types of CPA and reflect the same in corresponding generic CPA-DDs.
3: In generic CPAs involving LFG supply through natural gas distribution network, the description of alternative scenario of LFG supply through natural gas distribution network (e.g. page 75 of the PoA-DD) is missing thus not described as per paragraph 28(c) of ACM0001 version 18.
4: The PoA-DD/generic CPA-DDs did not provide clarity on how the parameter FCH,BL,y (i.e. Amount of methane in the LFG that would be flared in the baseline in year y) would be determined considering the various pre-project scenario mentioned above.
5: Page 22 of the PoA-DD mentions on-site fuel (i.e. LPG) consumption whereas no relevant project emissions are considered in the generic CPA-DD.
6: The eligibility criteria included in the generic CPAs are not complete. For example, paragraph 124 (i) (j) requires criteria related to stakeholder consultation, environment impact analysis and funding from Annex I Parties whereas those criteria are missing.
7: Regarding the alternatives for the destruction of LFG in the absence of the project activity, alternatives LFG4, LFG5 and LFG6 are excluded in the PoA-DD by simply stating “The EIA (Environmental Impact Assessment) does not cover recycling, treatment or incineration of organic waste”. However, the validation report did not provide information on how the DOE has validated the exclusion of those baseline alternatives at the PoA level, in particular for CPAs involving new SWDS if applicable.
8: The value of Ru in page 31 of the PoA-DD (i.e. 8,314 Pa.m3/kmol.K) is not consistent the value (i.e. 0.008314472 Pa.m3/kmol.K) stated in paragraph 39 of the methodological tool “Project emissions from flaring” version 03.
9: To determine the flare efficiency, the generic CPAs have opted option B.1 (i.e. Biannual measurement of the flare efficiency) of the methodological tool “Project emissions from flaring”. However, (a) the requirement of footnote 2 (i.e. If the monitoring period is shorter than one year, the measurement should be at least twice in a monitoring period and in a maximum timeframe of six months between each measurement) under option B.1 is not included in the PoA design; (b) the monitoring plan does not require monitoring the flow rate of the residual gas at minute interval as required by the methodology. Please refer to paragraph 25(a) and 21(a) of the methodological tool “Project emissions from flaring” version 03.
10: (1) Regarding the eligibility criteria of technology specification, no specific technology information is described in the criteria (e.g. page 64 of the PoA-DD). The generic CPAs shall specify the technology specification in the relevant criteria as per paragraph 124(d) of PS for PoA version 2 and paragraph 79 of ACM0001 version 18; the DOE shall provide information on how it has validated the compliance.
(2) Paragraph 124(f) of PS for PoA version 2 requires eligibility criteria including conditions to ensure compliance with the applicability of the applied methodologies and the other applied methodological regulatory documents. However, the eligibility criteria of the generic CPAs have only mentioned the applicability of the applied methodology and did not ensure compliance with the applied methodological tools (e.g. page 19 of the PoA-DD).
11: Regarding the eligibility criteria related to demonstrating additionality, only general description is provided in the generic CPA-DD (e.g. page 119 of the PoA-DD, for Generic CPA-DD #2). The criteria shall specify specific methodology provision applied and the option selected in the methodological tool applied; if investment analysis is to be applied, relevant input values and the corresponding technical/economic criteria shall be defined as per para 124(g)(iv) of PS for PoA version 2. In addition, simplified procedure for demonstration of additionality in section 5.3.1 of ACM0001 version 18 is applied to generic CPAs involving LFG supply to consumer whereas the simplified procedure is only applicable to electricity/heat generation and flaring as per paragraph 22 of ACM0001 version 18. The DOE is requested to provide information on how it has validated the compliance of the eligibility criteria with paragraph 124(g) of PS for PoA version 2, and the applicability of simplified procedure for each generic CPA.
1: The PoA descriptions in the PoA-DD are not consistent, for example page 20 of the PoA-DD indicate pre-project usage of LFG (i.e. the PoA makes investment into new or existing LFG capture system to increase the LFG collection efficiency and change the use of the captured LFG) whereas it also states “the captured LFG was partially flared and not used prior to the implementation of the project activity”. In addition, it also did not describe whether the project is to be implemented in new or existing SWDS. The PoA-DD is requested to address inconsistency and provide clarity in its generic CPA-DDs on the pre-project scenarios involved: (a) new or existing SWDS; (b) new or existing LFG capture system; (c) partial flaring of LFG; and (d) pre-project usage of LFG. The DOE is requested to validate the accuracy and completeness of the PoA description. Please refer to paragraph 77 and 78 of ACM0001.
2: In ACM0001, paragraph 77 requires PoA-DD describes each type of CPAs separately, and paragraph 78 requires justification on the classification of CPA types based on a series of factors including baseline scenario. However, it is not clear whether baseline scenario would varies considering the various pre-project scenarios covered by the PoA as mentioned in the issue above. The DOE is requested to provide information on how it has validated and provide clarity on the baseline scenarios considering various pre-project scenario, including but not limited to (a) new LFG capture system; (b) existing LFG capture system; (c) pre-project usage of captured LFG; (d) pre-project flaring scenario; and (e) new or existing SWDS etc. In addition, taking into those various scenario, the PoA-DD shall also describe transparently and justify the classification of types of CPA and reflect the same in corresponding generic CPA-DDs.
3: In generic CPAs involving LFG supply through natural gas distribution network, the description of alternative scenario of LFG supply through natural gas distribution network (e.g. page 75 of the PoA-DD) is missing thus not described as per paragraph 28(c) of ACM0001 version 18.
4: The PoA-DD/generic CPA-DDs did not provide clarity on how the parameter FCH,BL,y (i.e. Amount of methane in the LFG that would be flared in the baseline in year y) would be determined considering the various pre-project scenario mentioned above.
5: Page 22 of the PoA-DD mentions on-site fuel (i.e. LPG) consumption whereas no relevant project emissions are considered in the generic CPA-DD.
6: The eligibility criteria included in the generic CPAs are not complete. For example, paragraph 124 (i) (j) requires criteria related to stakeholder consultation, environment impact analysis and funding from Annex I Parties whereas those criteria are missing.
7: Regarding the alternatives for the destruction of LFG in the absence of the project activity, alternatives LFG4, LFG5 and LFG6 are excluded in the PoA-DD by simply stating “The EIA (Environmental Impact Assessment) does not cover recycling, treatment or incineration of organic waste”. However, the validation report did not provide information on how the DOE has validated the exclusion of those baseline alternatives at the PoA level, in particular for CPAs involving new SWDS if applicable.
8: The value of Ru in page 31 of the PoA-DD (i.e. 8,314 Pa.m3/kmol.K) is not consistent the value (i.e. 0.008314472 Pa.m3/kmol.K) stated in paragraph 39 of the methodological tool “Project emissions from flaring” version 03.
9: To determine the flare efficiency, the generic CPAs have opted option B.1 (i.e. Biannual measurement of the flare efficiency) of the methodological tool “Project emissions from flaring”. However, (a) the requirement of footnote 2 (i.e. If the monitoring period is shorter than one year, the measurement should be at least twice in a monitoring period and in a maximum timeframe of six months between each measurement) under option B.1 is not included in the PoA design; (b) the monitoring plan does not require monitoring the flow rate of the residual gas at minute interval as required by the methodology. Please refer to paragraph 25(a) and 21(a) of the methodological tool “Project emissions from flaring” version 03.
10: (1) Regarding the eligibility criteria of technology specification, no specific technology information is described in the criteria (e.g. page 64 of the PoA-DD). The generic CPAs shall specify the technology specification in the relevant criteria as per paragraph 124(d) of PS for PoA version 2 and paragraph 79 of ACM0001 version 18; the DOE shall provide information on how it has validated the compliance.
(2) Paragraph 124(f) of PS for PoA version 2 requires eligibility criteria including conditions to ensure compliance with the applicability of the applied methodologies and the other applied methodological regulatory documents. However, the eligibility criteria of the generic CPAs have only mentioned the applicability of the applied methodology and did not ensure compliance with the applied methodological tools (e.g. page 19 of the PoA-DD).
11: Regarding the eligibility criteria related to demonstrating additionality, only general description is provided in the generic CPA-DD (e.g. page 119 of the PoA-DD, for Generic CPA-DD #2). The criteria shall specify specific methodology provision applied and the option selected in the methodological tool applied; if investment analysis is to be applied, relevant input values and the corresponding technical/economic criteria shall be defined as per para 124(g)(iv) of PS for PoA version 2. In addition, simplified procedure for demonstration of additionality in section 5.3.1 of ACM0001 version 18 is applied to generic CPAs involving LFG supply to consumer whereas the simplified procedure is only applicable to electricity/heat generation and flaring as per paragraph 22 of ACM0001 version 18. The DOE is requested to provide information on how it has validated the compliance of the eligibility criteria with paragraph 124(g) of PS for PoA version 2, and the applicability of simplified procedure for each generic CPA.
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