Info Report Check
Submission incomplete:
1: The applied methodology (ACM0006 ver. 14, paragraphs 21 (e) and 22 (e)) require assessment of installation of new plants for power generation (Scenario P5) and heat generation (Scenario H5). The PDD (page 22) has identified Scenario P5 as the credible alternative scenario for power generation as a new generator of 12 MW can be installed but excluded Scenario H5. However, the PDD (under Scenario H3) indicates a possibility to install a new plant (i.e. boiler No. 3 (140 TPH)). The PP shall provide information to clarify exclusion of Scenario H5 from the list of credible alternative scenarios (PS-PA ver. 02 para 59)


2: In calculating the emission reductions:
i. For step 1.3 in the spreadsheet of “ER Spread Sheet _San Pedro”, the “Baseline load factor of heat engine i” (LFCEG,CG,i) has applied three different ratio values (i.e. 0.48, 0.57 and 0.59) which are calculated as ratio of hourly power consumption and total installed power. However, the applied methodology (parameter Table 14) requires the ratio between the ‘actual electricity generation’ of the heat engine and its ‘design maximum electricity generation’ along one year of operation. Further, the PDD should contain the information on how the parameter is determined;
ii. For step 1.4 in the spreadsheet of “ER Spread Sheet _San Pedro”, the calculation has provided for “Quantity of biomass residues of category n used in the project activity in year y (BRPJ,n,y) whereas the requirement in the applied methodology is to calculate the parameter “baseline availability of biomass residues (BRB5,n,y). Please take note that BRB5,n,y is determined as per equation 5 of ACM0006 ver. 14 which requires application of the “quantity of the main product of the production process (Py/Px)” and “Quantity of biomass residues of category n used for power or heat generation at the project site in year x prior the date of submission of the PDD for validation (BRHIST,n,x)”; and
iii. For Step 3.1 and the PDD (page 36), the “Baseline load factor of heat generator h (LFGHG,h)” has applied a ratio of “1” which is based on hours of operation per year. However, the applied methodology (parameter Table 12) requires the ratio between the ‘actual heat generation’ of the heat generator and its ‘design maximum heat generation’ along one year of operation. Further, the PDD should contain the information on how the parameter is determined.



3: For the data and parameters fixed ex-ante:

i. The PDD (section B.6.2) does not provide information on the ex-ante parameters “Quantity of biomass residues of category n used for power or heat generation at the project site in year x prior the date of submission of the PDD for validation (BRHIST,n,x), Quantity of the main product of the production process (Px) and the Net calorific value of biomass residues (NCVBR,n,x)”. Please take note that BRHIST,n,x and Px are required to determine the baseline availability of biomass residues (Step 1.4, equation 5). (ACM0006 ver. 14, paragraph 115); and
ii. An ex-ante value of 12 MW has been provided for the parameter “Baseline electricity generation capacity of heat engine i (CAPEG,CG,i)”. However, no information is provided to justify how the applied value was determined (please refer to ACM0006 ver. 14, parameter Table 11).




4: For Data and parameters to be monitored:
i. The PDD (page 22) identified the baseline scenario for the biomass residues as B5. However, the monitoring plan has not listed monitoring of the parameter “Quantity of biomass residues of category n used in the CDM project activity in year y for which the baseline scenario is B5 (BRB5,n,y)” (ACM0006 ver. 14, parameter table 25); and
ii. The monitoring plan does not list the monitoring of the parameters “specific enthalpy of the heat carrier at the process heat demand side (hLOW,y)” and “specific enthalpy of the heat carrier at the heat generator side (hHIGH,y)” (ACM0006 ver. 14, parameter table 35). These parameters will be applied to determine the baseline biomass-based cogeneration of process heat and electricity and heat extraction (Step 3.2).




5: The DOE’s validation opinion for the alternative scenarios (VR, page 18 Scenarios P2, P4, P6, H3, H6 and H7) does not provide information on how it validated and cross-checked, with other verifiable and credible sources, the assumptions and the rationales used in the PDD to determine that the most plausible baseline scenario has been identified (i.e. for scenario P4: the PDD indicates that retrofitting of the current turbo is not a realistic scenario since its power capacity and efficiency cannot be modified. However, DOE’s opinion repeats the same PDD information without providing any rationale/or cross-check; Scenario P6: the PDD indicates that there are no off-site power generation plants, either existing or planned to be built, near the project site, however, the DOE has not provided a validation opinion related to generation of power in specific off-site plants; and for scenario H6: the DOE has validated fuel switch and has not provided a validation opinion related to the PDD information) (VVS-PA ver. 02 paragraph 79).


6: The alternative scenario for the biomass residues has been identified as B5 (PDD, page 20), reported as B4 (PDD page 35) and validated as B4 (validation report, pages 25/30).


7: The validation report indicates three different dates when the on-site inspection was conducted i.e. between 21/08/13-23/08/17 (VR, Page 5), 21/08/13-23/08/13 (VR, page 5); and 21/08/12-23/08/12 (VR, pages 12 and 58). The PP/DOE to address this inconsistency.