18:31 26 Apr 25
Info Report Check
Submission incomplete:
1: The DOE is requested to describe how each applicability condition of the methodology/ies is fulfilled by the project activity as per VVS version 2 paragraphs 76 and 77.
The methodology ACM 0001, Version 13, is applicable, among other requirements, to project activities which "do not reduce the amount of organic waste that would be recycled in the absence of the project activity". In validating the compliance with this applicability condition, the DOE (VR, p. 13) has noted, "Visit on site. Project does not change the amount of waste to recycle, also interviews with landfill operators." The PDD (p.13) has also stated, "the amount of organic waste will be the same in the project activity as well as in the absence of the project activity." The DOE is requested to provide further information to support its validation, including documentation or references for the statement in the PDD, and whether information is available from credible sources other than that used in the PDD, to substantiate that in the absence of the project activity, there is no recycling of organic waste in the project region, either by formal and/or informal means.
2: The DOE is requested to describe how it has validated the steps taken to assess the identification of the baseline scenario of the project activity as per VVS version 2 paragraphs 91-95.
(a) The DOE has validated the elimination of LFG3, LFG4 and LFG5 as baseline alternatives for the LFG destruction since the EIA (Environmental Impact Assessment) of the project does not cover recycling, treatment or incineration of waste. However, the baseline alternatives LFG 3, LFG 4 and LFG 5 do not pertain only to project proponent (or at the project activity level) and therefore the elimination of these baseline alternatives requires a demonstration of what would have happened to the wastes in the baseline i.e., "solid waste recycling, aerobic treatment, incineration, etc., without being disposed of in the landfill". This becomes particularly more relevant in case of active landfills which are still receiving wastes. Accordingly, the DOE is requested to provide further validation opinion on how it has validated the elimination of the baseline alternatives LFG 3, LFG 4 and LFG 5.
(b) In validating the consistency of the identified alternatives with mandatory applicable laws and regulations, the DOE (VR, p. 17) has noted "According to PDD, all alternative scenarios identified in Step 1a comply with all applicable laws and regulations like the National Solid Waste Policy (NSWP) (new Brazilian legislation). Legislation does not request the LFG capture and/or flare and there is not forecast to approve any regulation or policy in the next years with this requirement." The DOE is requested to provide further information to support its validation that LFG capture and/or flaring is not required by legislation and/or evidence that it is not enforced in the area where the project is specifically located.
1: The DOE is requested to describe how each applicability condition of the methodology/ies is fulfilled by the project activity as per VVS version 2 paragraphs 76 and 77.
The methodology ACM 0001, Version 13, is applicable, among other requirements, to project activities which "do not reduce the amount of organic waste that would be recycled in the absence of the project activity". In validating the compliance with this applicability condition, the DOE (VR, p. 13) has noted, "Visit on site. Project does not change the amount of waste to recycle, also interviews with landfill operators." The PDD (p.13) has also stated, "the amount of organic waste will be the same in the project activity as well as in the absence of the project activity." The DOE is requested to provide further information to support its validation, including documentation or references for the statement in the PDD, and whether information is available from credible sources other than that used in the PDD, to substantiate that in the absence of the project activity, there is no recycling of organic waste in the project region, either by formal and/or informal means.
2: The DOE is requested to describe how it has validated the steps taken to assess the identification of the baseline scenario of the project activity as per VVS version 2 paragraphs 91-95.
(a) The DOE has validated the elimination of LFG3, LFG4 and LFG5 as baseline alternatives for the LFG destruction since the EIA (Environmental Impact Assessment) of the project does not cover recycling, treatment or incineration of waste. However, the baseline alternatives LFG 3, LFG 4 and LFG 5 do not pertain only to project proponent (or at the project activity level) and therefore the elimination of these baseline alternatives requires a demonstration of what would have happened to the wastes in the baseline i.e., "solid waste recycling, aerobic treatment, incineration, etc., without being disposed of in the landfill". This becomes particularly more relevant in case of active landfills which are still receiving wastes. Accordingly, the DOE is requested to provide further validation opinion on how it has validated the elimination of the baseline alternatives LFG 3, LFG 4 and LFG 5.
(b) In validating the consistency of the identified alternatives with mandatory applicable laws and regulations, the DOE (VR, p. 17) has noted "According to PDD, all alternative scenarios identified in Step 1a comply with all applicable laws and regulations like the National Solid Waste Policy (NSWP) (new Brazilian legislation). Legislation does not request the LFG capture and/or flare and there is not forecast to approve any regulation or policy in the next years with this requirement." The DOE is requested to provide further information to support its validation that LFG capture and/or flaring is not required by legislation and/or evidence that it is not enforced in the area where the project is specifically located.
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