14:49 25 Nov 24
Info Report Check
Submission incomplete:
1: VVS-PoA, paragraph 378:
The DOE is requested to explain how it validated the updated eligibility criteria for CPA inclusion in particular:
(a) Eligibility criterion on additionality (no. 11) which applies provision of automatic additionality when the project activities solely consist of households or communities or small and medium enterprises (SMEs) and where the size of each unit is no larger than 5% of the small-scale CDM threshold. It is not clear how this provision is in accordance with provisions under section 5.2 of AMS-I.E (version 10.1) and with the valid version of Methodological TOOL 01 "Tool for the demonstration and assessment of additionality" or Methodological TOOL 21: "Demonstration of additionality of small-scale project activities" or the Methodological TOOL 19: "Demonstration of additionality of microscale project activities", which are referred in paragraph 12 of AMS-III.AV (version 08.0).
(b) Eligibility criterion on additionality (no. 12). The criterion has not described the water purification technologies to be applied under the PoA, including specification of technology/measure such as the capacity as required by paragraph 124(d) PS-PoA.
2: VVS-PoA, paragraph 378:
The DOE is requested to explain how it validated the description of the generic CPA-DD in accordance with paragraph 81(b) of PS-PoA as the generic CPA-DD has not described the technologies/measures for water purification to be employed and/or implemented by the corresponding CPAs. Furthermore, the DOE is also requested to explain how footnote 5 of the PoA-DD is in line with the requirement of paragraph 81(b) of PS-PoA.
3: VVS-PoA, paragraph 382(b):
The PoA also includes boreholes as part of the community based water purification systems. The DOE is requested to explain how paragraph 3 of AMS-III.AV is complied with as the PoA-DD and generic CPA-DD do not make it clear that: (i) the boreholes (Soil filtration schemes) has to include container disinfection; and (ii) the PP shall demonstrate ex ante that rehabilitation and/or construction of the wells complies with relevant national and/or international standards and that measures are taken to ensure that water and well are not contaminated.
4: VVS-PoA, paragraph 382(b):
The DOE is requested to explain how the calculation methods of baseline emissions, project emissions or leakage have been in accordance with the applied methodologies or relevant tools, in particular:
(a) Page 23 of the PoA-DD states that if the operation of the project water purification system involves consumption of fossil fuels and/or electricity, CO2 emissions from on-site consumption of fossil fuels and electricity due to the project activity shall be accounted for as project emissions, in line with equation 6 of AMS-III.AV version 8.0. However, the same page also states that the operation of the CPA water purification systems does not involve consumption of fossil fuels and/or electricity. It is not clear whether or not the project water purification system involves consumption of fossil fuels and/or electricity. If it does, the CPA-DD has not described how emissions from on-site consumption of fossil fuels and electricity will be determined as per the "TOOL03: Tool to calculate project or leakage CO2 emissions from fossil fuel combustion"nd "TOOL05: Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation". If it does not, it is not clear how to ensure that only systems which do not involve consumption of fossil fuels and/or electricity will be part of the PoA.
(b) For parameter fNRB, the generic CPA-DD has not described which option of paragraph 42 of AMS-I.E (version 10.1) will be used by CPAs.
(c) For parameter EFprojected_fossil fuel, the generic CPA-DD has not described how the CPAs will obtain this parameter.
(d) The generic CPA-DD has not described how efficiency project stove will be determined according to the requirements of AMS-II.G, including the loss of efficiency of the project stove, as required by data / parameter table 14 of AMS-I.E (version 10.1):
(e) The PoA-DD states that potential cross over effect is avoided by only claiming emission reduction from one solution from each households selected for monitoring, even if a households selected for monitoring is found to have been provided with both an ethanol stove and purified drinking water solutions. However, it is not clear from which solution the ER will be claimed.
(f) Parameter Charcoal conversion factor will be determined at CPA level. However, the generic CPA-DD has not provided the provision to determine the conversion factor as per paragraph 28 of AMS-I.E (version 10.1);
(g) Parameters NCV charcoal and NCV biomass will be determined at CPA level. However, the generic CPA-DD has not described how the parameters NCV will be sourced. For NCV biomass, AMS-I.E (version 10.1) has provision under data / parameter table 9;
(h) The generic CPA-DD has not described: (i) how CPAs that will renew the crediting period will assess the validity of their baseline as per the methodological tool "Assessment of the validity of the original/current baseline and update of the baseline at the renewal of the crediting period"; and (ii) how to determine or what would be the baseline scenario for CPAs that will be included in the second PoA renewal period.
5: VVS-PoA, paragraph 382(b):
The DOE is requested to explain how it validated the monitoring plan in accordance with the applied methodologies or relevant tools, in particular:
(a) The monitoring frequency of parameter ETusage,y, used to calculate parameter HGp,y as at least every two years, considering the AMS-I.E (version 10.1) requires annual monitoring of HGp,y;
(b) Page 41 of PoA-DD has provision for biennial inspection when defining the confidence/precision level. However, on the same page, under "Summary", the PoA-DD states that monitoring will be done at least every year.
(c) On page 41 under "Summary", the CME will conduct monitoring over 7 days period. It is not clear how this 7-day period of monitoring will represent the consumption for the whole year.
(d) On page 42, the PoA-DD says that households will be provide with 20 liter or 12 liter of denatured alcohol during the 7-day period of monitoring. The DOE is requested to clarify whether or not the denatured alcohol during the 7-day monitoring period will be provided for free. If it will be provided for free to sampled households, the DOE is requested to explain whether this represents the actual arrangement, i.e. all households under the PoA will be provided denatured alcohol for free;
(e) For parameter m (Fraction of functional appliances that are providing the SDW), the generic CPA-DD (page 38) states that the parameter shall be determined through checking all appliances or a statistically representative sample of the appliances to ensure the that, among others, they are still operating or are replaced by an equivalent in service appliance. It is not clear how the CME will ensure that the community based water purification systems are still operating, considering the sampling plan only targets households;
(f) Appendix 7 of the updated PoA-DD contains provision "Any additional requirements in the Monitoring plan specified in the PoA DD after PRC, shall apply to all CPAs even if such additional requirements is not specified in CPAs that has been included in the program prior to the PRC". The DOE is requested to explain how it has validated this statement considering: (i) this statement is available only in appendix 7 which is a section to summarize all PRCs; (ii) it is not clear how this statement/provision which does not require revision of CPA-DDs is in accordance with paragraph 226 of PS-PoA which requires revision of CPA-DD.
1: VVS-PoA, paragraph 378:
The DOE is requested to explain how it validated the updated eligibility criteria for CPA inclusion in particular:
(a) Eligibility criterion on additionality (no. 11) which applies provision of automatic additionality when the project activities solely consist of households or communities or small and medium enterprises (SMEs) and where the size of each unit is no larger than 5% of the small-scale CDM threshold. It is not clear how this provision is in accordance with provisions under section 5.2 of AMS-I.E (version 10.1) and with the valid version of Methodological TOOL 01 "Tool for the demonstration and assessment of additionality" or Methodological TOOL 21: "Demonstration of additionality of small-scale project activities" or the Methodological TOOL 19: "Demonstration of additionality of microscale project activities", which are referred in paragraph 12 of AMS-III.AV (version 08.0).
(b) Eligibility criterion on additionality (no. 12). The criterion has not described the water purification technologies to be applied under the PoA, including specification of technology/measure such as the capacity as required by paragraph 124(d) PS-PoA.
2: VVS-PoA, paragraph 378:
The DOE is requested to explain how it validated the description of the generic CPA-DD in accordance with paragraph 81(b) of PS-PoA as the generic CPA-DD has not described the technologies/measures for water purification to be employed and/or implemented by the corresponding CPAs. Furthermore, the DOE is also requested to explain how footnote 5 of the PoA-DD is in line with the requirement of paragraph 81(b) of PS-PoA.
3: VVS-PoA, paragraph 382(b):
The PoA also includes boreholes as part of the community based water purification systems. The DOE is requested to explain how paragraph 3 of AMS-III.AV is complied with as the PoA-DD and generic CPA-DD do not make it clear that: (i) the boreholes (Soil filtration schemes) has to include container disinfection; and (ii) the PP shall demonstrate ex ante that rehabilitation and/or construction of the wells complies with relevant national and/or international standards and that measures are taken to ensure that water and well are not contaminated.
4: VVS-PoA, paragraph 382(b):
The DOE is requested to explain how the calculation methods of baseline emissions, project emissions or leakage have been in accordance with the applied methodologies or relevant tools, in particular:
(a) Page 23 of the PoA-DD states that if the operation of the project water purification system involves consumption of fossil fuels and/or electricity, CO2 emissions from on-site consumption of fossil fuels and electricity due to the project activity shall be accounted for as project emissions, in line with equation 6 of AMS-III.AV version 8.0. However, the same page also states that the operation of the CPA water purification systems does not involve consumption of fossil fuels and/or electricity. It is not clear whether or not the project water purification system involves consumption of fossil fuels and/or electricity. If it does, the CPA-DD has not described how emissions from on-site consumption of fossil fuels and electricity will be determined as per the "TOOL03: Tool to calculate project or leakage CO2 emissions from fossil fuel combustion"nd "TOOL05: Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation". If it does not, it is not clear how to ensure that only systems which do not involve consumption of fossil fuels and/or electricity will be part of the PoA.
(b) For parameter fNRB, the generic CPA-DD has not described which option of paragraph 42 of AMS-I.E (version 10.1) will be used by CPAs.
(c) For parameter EFprojected_fossil fuel, the generic CPA-DD has not described how the CPAs will obtain this parameter.
(d) The generic CPA-DD has not described how efficiency project stove will be determined according to the requirements of AMS-II.G, including the loss of efficiency of the project stove, as required by data / parameter table 14 of AMS-I.E (version 10.1):
(e) The PoA-DD states that potential cross over effect is avoided by only claiming emission reduction from one solution from each households selected for monitoring, even if a households selected for monitoring is found to have been provided with both an ethanol stove and purified drinking water solutions. However, it is not clear from which solution the ER will be claimed.
(f) Parameter Charcoal conversion factor will be determined at CPA level. However, the generic CPA-DD has not provided the provision to determine the conversion factor as per paragraph 28 of AMS-I.E (version 10.1);
(g) Parameters NCV charcoal and NCV biomass will be determined at CPA level. However, the generic CPA-DD has not described how the parameters NCV will be sourced. For NCV biomass, AMS-I.E (version 10.1) has provision under data / parameter table 9;
(h) The generic CPA-DD has not described: (i) how CPAs that will renew the crediting period will assess the validity of their baseline as per the methodological tool "Assessment of the validity of the original/current baseline and update of the baseline at the renewal of the crediting period"; and (ii) how to determine or what would be the baseline scenario for CPAs that will be included in the second PoA renewal period.
5: VVS-PoA, paragraph 382(b):
The DOE is requested to explain how it validated the monitoring plan in accordance with the applied methodologies or relevant tools, in particular:
(a) The monitoring frequency of parameter ETusage,y, used to calculate parameter HGp,y as at least every two years, considering the AMS-I.E (version 10.1) requires annual monitoring of HGp,y;
(b) Page 41 of PoA-DD has provision for biennial inspection when defining the confidence/precision level. However, on the same page, under "Summary", the PoA-DD states that monitoring will be done at least every year.
(c) On page 41 under "Summary", the CME will conduct monitoring over 7 days period. It is not clear how this 7-day period of monitoring will represent the consumption for the whole year.
(d) On page 42, the PoA-DD says that households will be provide with 20 liter or 12 liter of denatured alcohol during the 7-day period of monitoring. The DOE is requested to clarify whether or not the denatured alcohol during the 7-day monitoring period will be provided for free. If it will be provided for free to sampled households, the DOE is requested to explain whether this represents the actual arrangement, i.e. all households under the PoA will be provided denatured alcohol for free;
(e) For parameter m (Fraction of functional appliances that are providing the SDW), the generic CPA-DD (page 38) states that the parameter shall be determined through checking all appliances or a statistically representative sample of the appliances to ensure the that, among others, they are still operating or are replaced by an equivalent in service appliance. It is not clear how the CME will ensure that the community based water purification systems are still operating, considering the sampling plan only targets households;
(f) Appendix 7 of the updated PoA-DD contains provision "Any additional requirements in the Monitoring plan specified in the PoA DD after PRC, shall apply to all CPAs even if such additional requirements is not specified in CPAs that has been included in the program prior to the PRC". The DOE is requested to explain how it has validated this statement considering: (i) this statement is available only in appendix 7 which is a section to summarize all PRCs; (ii) it is not clear how this statement/provision which does not require revision of CPA-DDs is in accordance with paragraph 226 of PS-PoA which requires revision of CPA-DD.
Offset now: visit the United Nations Carbon Offset Platform
Connect with us: