Info Report Check
Submission incomplete:
1: VVS-PoA, paragraph 45:
The DOE is requested to explain how it has validated the additionality demonstration for the CPAs under the PoA, in particular:
(a) Section C of PoA-DD allows the use of barrier analysis, whereas in pages 25-26 and 73, the PoA-DD states that There are no realistic and credible barriers that may prevent alternative scenarios to occur for Generic CPA 1 and generic CPA 2;
(b) The generic 1 and 2 has not described what would be the applicable benchmark and its sources, and the applicable sources of input values for the investment analysis;
(c) Generic CPA 2 has not included sale price of RDF as one of the input values for investment analysis.
(d) The generic CPA 3 does not describe how the CPA will demonstrate that it would not be the most economically or financially attractive alternative, or economically or financially feasible, without the revenue from the sale of certified emission reductions (CERs). And if barrier analysis is used, what barriers apply and what conditions in the eligibility criteria to be fulfilled to demonstrate such barriers.

2: VVS-PoA, paragraph 54:
The PoA-DD states that the environmental impacts will be carried out at CPA level. However, in section D.1.6 of the validation report, the DOE confirms that the PoA does not require environment impact assessment in accordance with the procedures of the host Party.

3: VVS-PoA, paragraph 90:
The DOE is requested to explain how it validated the description of the generic CPAs as:
(a) The figure in page 6 of PoA-DD indicates CPA type I and CPA type II, however the figure does not reflect the description of the CPA type I and CPA type II. For example, turbine is part of CPA type II as per this figure, whereas CPA type II does not include electricity generation from RDF;
(b) The PoA-DD on page 2 states that the rejects after segregation and generation of electricity shall be used for reject management facility including brick manufacturing. However, it is not clear in generic CPA type I and generic CPA type II how to ensure that the all rejects are used for reject management facility including brick manufacturing.
(c) For generic CPA type III, It is not clear:
(i) If it will be for Greenfield activities only considering the PoA-DD on page 106, under technology/measure, states replacement of existing and upcoming old inefficient brick kilns by new energy efficient brick production process technology;
(ii) If it will also use fly ash and rejects coming not from CPAs of this PoA.

4: VVS-PoA, paragraph 115:
The DOE is requested to further explain how it has validated the elimination of the following alternative scenarios for generic CPA type I and generic CPA type II:
(a) M4, how this alternative scenario is not considered plausible only due to no mandatory requirements;
(b) M5, M7, M8 and M9, how these alternative scenarios are not considered plausible only because prior to the project activity entire waste was being dumped into SWDS. It is to be noted that the identified baseline scenario may not be the practice prior to the implementation of the CPA.

5: 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) For project emissions from electricity consumption associated with composting, generic CPA type I and generic CPA type II mention that the project plant will be connected to the grid and may also install a backup diesel generator. While, the emission factor from the grid is included in the monitoring plan, it is not clear how the emission factor from operation of the diesel generator will be determined;
(b) Project emissions from electricity consumption associated with RDF/SB (production and on-site combustion) (PEEC,RDF_SB,y) are to be calculated as per the “Tool to calculate baseline, project and/or leakage emissions from electricity consumption”. However, the formulas in generic CPA type I and generic CPA type II (pages 37 and 84 of PoA-DD) are not as per this tool;
(c) For project emissions from electricity consumption associated with RDF/SB (production and on-site combustion) (PEEC,RDF_SB,y), the generic CPA type I and generic CPA type II state that the project activity will consume electricity from the generation facility at site connected to grid, therefore this can be neglected as per applied methodology. However, it is not clear how to ensure that the CPA will consume electricity from the generation facility at site for this parameter. And for generic CPA type II, it needs to be clarified whether there will be electricity generation facility at site as part of the CPA;
(d) The generic CPA type I and generic CPA type II do 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;
(e) The generic CPA type II includes project emissions from RDF combustion within the project boundary (PECOM_CO2,c,y). However, it is not clear in what equipment the RDF is combusted within the project boundary. As per the description, generic CPA type II will sell the RDF to identified users;
(f) As per the methodology ACM0022 (version 02.0), leakage emissions associated with composting (LECOMP,y) are calculated according to the methodological tool “Project and leakage emissions from composting”. As per this tool, leakage shall be accounted for if compost is subjected to anaerobic storage or disposed of in a SWDS. As per the generic CPA type I and generic CPA type II, final product from CPAs will be bagged and sold as organic soil conditioner and not stored under anaerobic conditions or disposed of in a SWDS. Therefore the leakage is not considered. However, it is not clear how to ensure that there are no composts that are stored under anaerobic condition or disposed in a SWDS;
(g) As per the methodology ACM0022 (version 02.0), leakage emissions associated with disposing of waste by-products associated with RDF/SB production in a SWDS (LESWDS,WBP, RDF_SB,y) are to be considered. The generic CPA type I and generic CPA type II do not include this source of leakage and there is no explanation why they are not included;
(h) As per the methodology ACM0022 (version 02.0), leakage emissions associated with the end-use of RDF/SB exported outside the project boundary (LEENDUSE, RDF_SB,y) are to be considered. This source of leakage is not considered by generic CPA type II which will sell the RDF to identified users;
(i) The generic CPA type III does not describe how Project emissions due to fossil fuel consumption (PEfossilfuel,y) will be calculated;
(j) The generic CPA type III mentions that the project activity will consume RDF based steam for its high-pressure steam-curing operations (page 118 of PoA-DD). However, it is not clear whether the operation of steam generation facility using RDF is included in the CPA boundary, and if it is, how the emissions from the operation of the facility will be considered;
(k) The PoA-DD on page 2 states that a landfill may also be developed for final disposal of rejects and the operation and maintenance if the same shall be undertaken. However, it is not clear how the emissions from the operation of this landfill and the emissions from the rejects dumped in this landfill are to be considered;
(l) 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. However, it is not clear how the emissions from the combustion of other materials than RDF are to be considered;
(m) To determine PECOM_CO2,c,y, the option 3 is chosen by generic CPA type I and generic CPA type II. However, it is not clear how parameter FFCstack,c,y (Concentration of fossil-based carbon in the stack gas of the combustor c in year y) will be obtained;
(n) The generic CPA type III includes parameters EFCO2,diesel, NCVdiesel and Density of diesel as parameter not monitored to calculate project emissions. However, it is not clear which project emissions will be calculated from these parameters.

6: VVS-PoA, paragraph 124(a):
The DOE is requested to explain how the determination of the grid emission factors under the PoA is in line with “Tool to calculate the emission factor for an electricity system” (version 07.0), in particular:
(a) With paragraph 99, which requires that steps to determine the CO2 emission factor for an electricity system shall be applied to each CPA, while the grid emission factors (EFgrid,OM,y, EFgrid,BM,y and EFgrid,CM) are set fixed ex-ante at PoA level for generic CPA type I and generic CPA type II;
(b) With paragraphs 100 and 101, as the generic CPAs do not describe, inter alia, the equations and options used to calculate the emission factor, and the choice of which option to use.

7: VVS-PoA, paragraph 124(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 as the monitoring plan in the generic CPAs do not include parameter Average technical transmission and distribution losses for providing electricity to source j in year y (TDL j,y) which is required by methodological tool “Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation”, version 03.0.

8: 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:
(a) It is not clear how the PoA/generic CPAs consider para 114 (a) to 114 (e) of ACM0022 when establishing the eligibility criteria;
(b) Eligibility criterion 3 of generic CPA type I also includes green waste based brick manufacturing activities, whereas as per the section A.3 of the PoA-DD, generic CPA type I is composting and RDF based electricity generation;
(c) Eligibility criterion 3 of generic CPA type II also includes RDF based power generation activities, whereas as per the section A.3 of the PoA-DD, generic CPA type II is composting and RDF manufacturing, without electricity generation;
(d) Eligibility criterion 6 of generic CPA type I and generic CPA type II includes green waste based brick manufacturing, whereas as per the section A.3 of the PoA-DD, these two generic CPAs do not include brick manufacturing;
(e) Eligibility criterion 6 of each generic CPA, as shown in the column “Supporting evidence for inclusion”, only allows the demonstration for each CPA that it is not the most economical or at least costlier than one other alternative. However, section C of the PoA-DD also allows the demonstration of barriers;
(f) Eligibility criterion 7 of each generic CPA has not include the requirement to conduct environmental impact assessment by each CPA;
(g) Eligibility criterion 10 of generic CPA type I and generic CPA type II states that the sampling method for monitoring the parameters if applied in the CPA (e.g. in the Monitoring plan) shall follow the requirement outlined in the methodology and referred tools. However, the monitoring plan in these two generic CPAs has not described any sampling method which can be applied by CPAs;
(h) Eligibility criterion 3 of generic CPA type III does not describe the level of service (i.e. the capacity) of the brick manufacturing facility of the CPAs to be included in the PoA;
(i) Eligibility criterion 6 of generic CPA type III says that The additionality of the project activity will be demonstrated at CPA level using " Combined tool to identify the baseline scenario and demonstrate additionality" as specified in applied approved methodology. However, the applied methodology for generic CPA type III (AMS-III.Z) does not specify the use of this tool.