10:29 29 Nov 24
Info Report Check
Submission incomplete:
1: Criterion 1 of eligibility criteria in each generic CPA-DD mentions that all projects must comply with one of the additionality tests explained in the PoA-DD. Under point (b) it says "Solar technologies, off-shore wind technologies, or marine technologies (wave and tidal) thermosolar of any from the tool 32, Positive list of technologies.". The DOE is requested to explain how it concluded that the CME has outlined clear and unambiguous eligibility criteria for the inclusion of a CPA under the PoA as the criterion 1 above does not describe how paragraph 14 of tool will be complied with. It is also observed that page 19 of PoA-DD refers to regulatory documents that are not valid anymore, i.e. "Standard demonstration of additionality, development of eligibility criteria and application of multiple methodologies for programme of activities" (version 03.0), and "Guidelines for demonstrating additionality of microscale project activities".
Refer to paragraph 382(b) of VVS-PoA and paragraph 124(g) of PS-PoA.
2: 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; (b) How the wOM and wBM set at 0.25 and 0.75 for hydro, wave/tidal power generation are appropriate for CPAs that will be included during the second PoA renewal period. It is to be noted that the wOM and wBM are linked to crediting period, not to PoA renewal period; (c) With paragraphs 100 and 101, as the PoA-DD does not describe, inter alia, the equations and options used to calculate the emission factor, and the choice of which option to use. Refer to paragraph 382(b) of VVS-PoA.
3: The DOE is requested to explain how it validated the monitoring plan in accordance with the applicable tools, as: (i) Parameter EFCO2,i,y, required by "Methodological Tool: Tool to calculate project or leakage CO2 emissions from fossil fuel combustion" (version 3.0) for option B, is not included in the monitoring plan; (ii) For CPAs with a total installed capacity up to 15 MW, the calibration of electricity meter is every three years according to the General Guidelines to SSC CDM methodologies, version 17. However, this version of the Guidelines is not valid anymore, and the latest version of the Guidelines does not have such provision.
Refer to paragraph 382(b) of VVS-PoA.
1: Criterion 1 of eligibility criteria in each generic CPA-DD mentions that all projects must comply with one of the additionality tests explained in the PoA-DD. Under point (b) it says "Solar technologies, off-shore wind technologies, or marine technologies (wave and tidal) thermosolar of any from the tool 32, Positive list of technologies.". The DOE is requested to explain how it concluded that the CME has outlined clear and unambiguous eligibility criteria for the inclusion of a CPA under the PoA as the criterion 1 above does not describe how paragraph 14 of tool will be complied with. It is also observed that page 19 of PoA-DD refers to regulatory documents that are not valid anymore, i.e. "Standard demonstration of additionality, development of eligibility criteria and application of multiple methodologies for programme of activities" (version 03.0), and "Guidelines for demonstrating additionality of microscale project activities".
Refer to paragraph 382(b) of VVS-PoA and paragraph 124(g) of PS-PoA.
2: 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; (b) How the wOM and wBM set at 0.25 and 0.75 for hydro, wave/tidal power generation are appropriate for CPAs that will be included during the second PoA renewal period. It is to be noted that the wOM and wBM are linked to crediting period, not to PoA renewal period; (c) With paragraphs 100 and 101, as the PoA-DD does not describe, inter alia, the equations and options used to calculate the emission factor, and the choice of which option to use. Refer to paragraph 382(b) of VVS-PoA.
3: The DOE is requested to explain how it validated the monitoring plan in accordance with the applicable tools, as: (i) Parameter EFCO2,i,y, required by "Methodological Tool: Tool to calculate project or leakage CO2 emissions from fossil fuel combustion" (version 3.0) for option B, is not included in the monitoring plan; (ii) For CPAs with a total installed capacity up to 15 MW, the calibration of electricity meter is every three years according to the General Guidelines to SSC CDM methodologies, version 17. However, this version of the Guidelines is not valid anymore, and the latest version of the Guidelines does not have such provision.
Refer to paragraph 382(b) of VVS-PoA.
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