03:39 30 Jun 25
Info Report Check
Submission incomplete:
1: The DOE is requested to describe how it has assessed the application of the equations and parameters for the calculation of emission reductions as per VVS version 2 paragraphs 97 and 99 (d) (e).
(a) The EB68 Annex 15 requires that the “Tool to determine the mass flow of a greenhouse gas in a gaseous stream” shall be used to determine the FCH4,m (Mass flow of methane in the residual gaseous stream in the minute m) in Step 1 (Determination of the methane mass flow of the residual gas). The “Tool to determine the mass flow of a greenhouse gas in a gaseous stream” provides 6 options to determine the parameter, however the PDD has not defined and the DOE has not validated which option to be used and the relevant parameters to be determined/monitored;
(b) The DOE is requested to further explain how it validated that the ex-ante PEflare,y being zero is appropriate, in light of annual biogas generation of 4,582,528 m3 shown in NPV calculation spreadsheet, and the required energy input of 2091 kW of gas engine shown in page 8 of the PDD;
(c) In light of clarification 0173, the DOE is requested to further explain how the monitoring of project emissions from flaring, transport and diesel consumption is adequate. Furthermore, why leakage from the competing uses of the biomass is not accounted for, considering that some wastes are not from in-house.
2: The DOE is requested to verify the justification of the data used for the ex-ante emission reduction calculations as per VVS version 2 paragraphs 98, 99 (a) (b) (c) and 100.
The DOE is requested to further explain how it has validated the parameters that are fixed throughout the crediting periods, in particular: (i) the density of the residual gas at reference conditions in minute m being 0.87450 kg/m3, argued to be the default value provided in Table 1 of the “Project emissions from flaring”, whereby the Table of the “Project emissions from flaring” does not provide such parameter. Furthermore, as this parameter is calculated, how fixing the methane content at 70% throughout the crediting period is appropriate; (ii) the parameter SPECflare required by the “Project emissions from flaring” in case of Option A of the enclosed flare.
3: The DOE is requested to describe how it has validated the evidence provided for prior consideration of CDM as per VVS version 2 paragraph 112 (b).
The VR page 51 states that the PP only informed the UNFCCC about the intention to seek CDM status for the project activity. However, the PDD page 27 states that the notification was sent to UNFCCC and DNA. Please kindly clarify this inconsistency.
4: The DOE is requested to describe how it has validated the suitability of the input values used in the financial calculations as per VVS version 2 paragraphs 120 and 123 (a).
The DOE is requested to further explain how it has validated the following input values in accordance with the VVS version 5 paragraph 120b,c: (a) the transportation cost, as the Validation Report has not provided information why the transportation cost is higher than the cost in the the public domain as stated in the Validation Report pages 141-142; (b) the escalation of O&M cost, as there is no information how the DOE validated this input value in line with the paragraph 120b,c of the VVS version 5.
5: The DOE is requested to describe how it has validated the compliance of the monitoring plan with the applied methodology(ies) as per VVS version 2 paragraph 132 (a).
(a) The DOE is requested to further explain how the monitoring plan has complied with the “Project emissions from flaring”, version 2.0.0, as the tool requires parameter SPECflare and the demonstration the temperature of the flare (TEG.m) and the flow rate of the residual gas to the flare (FRG,m) being within the manufacturer’s specification for the flare (SPECflare) in minute m, and the flame being detected in minute m (Flamem), for Option A of the enclosed flare, however the monitoring plan does not include the aforementioned parameters. Please clarify;
(b) The PDD page 29 states "Mass flow of methane in the residual gaseous stream in the minute m (FCH4,m), which is measured as the mass flow during minute m, shall then be used to determine the mass of methane in kilograms fed to the flare in minute m (FCH4,RG,m).". However the monitoring plan does not include the measurement of the mass flow of methane in residual gaseous stream. Please clarify;
(c) The PDD page 41 states "The value of biogas consumption shall be monitored by gas flow meters that will be calibrated by the
equipment supplier once in a year". As the biogas is also consumed in gas engine, the monitoring plan section B.7.1 has not provided information on how this parameter is monitored.
6: The DOE is requested to report details of all CARs, CLs and FARs as per VVS version 2 paragraph 29.
The DOE is requested to further explain how it has properly closed CAR B3 point 12, in particular as the PP's response did not respond to the DOE's concern about the transport distance not being realistic.
1: The DOE is requested to describe how it has assessed the application of the equations and parameters for the calculation of emission reductions as per VVS version 2 paragraphs 97 and 99 (d) (e).
(a) The EB68 Annex 15 requires that the “Tool to determine the mass flow of a greenhouse gas in a gaseous stream” shall be used to determine the FCH4,m (Mass flow of methane in the residual gaseous stream in the minute m) in Step 1 (Determination of the methane mass flow of the residual gas). The “Tool to determine the mass flow of a greenhouse gas in a gaseous stream” provides 6 options to determine the parameter, however the PDD has not defined and the DOE has not validated which option to be used and the relevant parameters to be determined/monitored;
(b) The DOE is requested to further explain how it validated that the ex-ante PEflare,y being zero is appropriate, in light of annual biogas generation of 4,582,528 m3 shown in NPV calculation spreadsheet, and the required energy input of 2091 kW of gas engine shown in page 8 of the PDD;
(c) In light of clarification 0173, the DOE is requested to further explain how the monitoring of project emissions from flaring, transport and diesel consumption is adequate. Furthermore, why leakage from the competing uses of the biomass is not accounted for, considering that some wastes are not from in-house.
2: The DOE is requested to verify the justification of the data used for the ex-ante emission reduction calculations as per VVS version 2 paragraphs 98, 99 (a) (b) (c) and 100.
The DOE is requested to further explain how it has validated the parameters that are fixed throughout the crediting periods, in particular: (i) the density of the residual gas at reference conditions in minute m being 0.87450 kg/m3, argued to be the default value provided in Table 1 of the “Project emissions from flaring”, whereby the Table of the “Project emissions from flaring” does not provide such parameter. Furthermore, as this parameter is calculated, how fixing the methane content at 70% throughout the crediting period is appropriate; (ii) the parameter SPECflare required by the “Project emissions from flaring” in case of Option A of the enclosed flare.
3: The DOE is requested to describe how it has validated the evidence provided for prior consideration of CDM as per VVS version 2 paragraph 112 (b).
The VR page 51 states that the PP only informed the UNFCCC about the intention to seek CDM status for the project activity. However, the PDD page 27 states that the notification was sent to UNFCCC and DNA. Please kindly clarify this inconsistency.
4: The DOE is requested to describe how it has validated the suitability of the input values used in the financial calculations as per VVS version 2 paragraphs 120 and 123 (a).
The DOE is requested to further explain how it has validated the following input values in accordance with the VVS version 5 paragraph 120b,c: (a) the transportation cost, as the Validation Report has not provided information why the transportation cost is higher than the cost in the the public domain as stated in the Validation Report pages 141-142; (b) the escalation of O&M cost, as there is no information how the DOE validated this input value in line with the paragraph 120b,c of the VVS version 5.
5: The DOE is requested to describe how it has validated the compliance of the monitoring plan with the applied methodology(ies) as per VVS version 2 paragraph 132 (a).
(a) The DOE is requested to further explain how the monitoring plan has complied with the “Project emissions from flaring”, version 2.0.0, as the tool requires parameter SPECflare and the demonstration the temperature of the flare (TEG.m) and the flow rate of the residual gas to the flare (FRG,m) being within the manufacturer’s specification for the flare (SPECflare) in minute m, and the flame being detected in minute m (Flamem), for Option A of the enclosed flare, however the monitoring plan does not include the aforementioned parameters. Please clarify;
(b) The PDD page 29 states "Mass flow of methane in the residual gaseous stream in the minute m (FCH4,m), which is measured as the mass flow during minute m, shall then be used to determine the mass of methane in kilograms fed to the flare in minute m (FCH4,RG,m).". However the monitoring plan does not include the measurement of the mass flow of methane in residual gaseous stream. Please clarify;
(c) The PDD page 41 states "The value of biogas consumption shall be monitored by gas flow meters that will be calibrated by the
equipment supplier once in a year". As the biogas is also consumed in gas engine, the monitoring plan section B.7.1 has not provided information on how this parameter is monitored.
6: The DOE is requested to report details of all CARs, CLs and FARs as per VVS version 2 paragraph 29.
The DOE is requested to further explain how it has properly closed CAR B3 point 12, in particular as the PP's response did not respond to the DOE's concern about the transport distance not being realistic.
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