Info Report Check
Submission incomplete:
1: The generic CPA-DD (AMS-I.E.) will distribute clean energy cookstove and introduce renewable biomass (carbonized/non-carbonized pellets/briquettes/woodchips/agricultural residues) to replace non-renewable biomass across the three Host countries. However, no information is provided to demonstrate how the proposed fuels can be considered as renewable biomass (please refer to the CDM Glossary of Terms ver. 10, page 16, regarding the applicable conditions for fuels to be considered as renewable biomass).


2: The PoA-DD proposes to add a new methodology (AMS-I.E.: fuel switch) to the registered methodology (AMS-II.G.: Technology switch but no change of energy source). The DOE shall report how it assessed and confirmed that the change introduces complementary technology/measure involving mass and/or energy transfer to/from the original technology/measure (please refer to PS-PoA ver.02 paragraph 238 (h) and VVS-PoA ver. 02 paragraph 275).


3: The monitoring plan (Section I.7.1-AMS-I.E. generic CPA-DD) indicates that the monitoring of the parameter “average annual consumption of non-renewable woody biomass per household in the pre-project devices during the project activity, BCPJ,HH,y” would also include any potential consumption of non-renewable biomass on the project activity devices (i.e. the clean energy cookstoves). However, the sampling plan (revised PoA-DD, page 95) has listed sampling of the “average annual consumption of non-renewable woody biomass per household in the pre-project devices during the project activity; and no information is provided on monitoring and sampling of the “potential consumption of non-renewable biomass on the project activity devices”.


4: The revised PoA-DD (page 12) and eligibility criteria No. 03 mention that CPAs implemented in Kenya are additional due to investment barrier (i.e. purchasing an ICS requires up-front capital, which is a barrier to end-users due to difficulties in accessing capital). The CME/DOE shall provide transparent and documented third party evidence such as national/international statistics, national/provincial policy and legislation, studies/surveys by independent agencies etc. to substantiate the mentioned investment barrier in Kenya (please refer to paragraph 8 of the applied Tool 21 and EB 35 Annex 34: Non-binding best practice examples to demonstrate additionality for SSC project activities).


5: The updated PoA-DD (Section A.1) indicates that the goal of the PoA is the distribution of efficient stoves/clean energy cookstoves and the eligibility criteria No. 1 (in case of AMS-II.G.) will ensure that the distributed ICS have an efficiency of atleast 20%. The CME/DOE shall provide information on how the revised PoA complies with paragraph 124 (d) and footnote 23 of PS-PoA ver. 02 which require to define the specification of the technology, as well as the performance specifications of the proposed Technology based on, inter alia, testing/certification (please note that indicating that all cook stoves will have an efficiency X% would not be sufficient).


6: The DOE (validation report page 27) and the updated PoA-DD (page 43) indicate that the lifespan of the distributed devices should be reported in cases where the efficiency loss is accounted as per paragraph 37 (a) of AMS-II.G. However, the applied methodology (parameter Table 19) requires lifespan is reported in cases where efficiency loss is accounted as per paragraph 37.