13:09 20 Jan 25
Info Report Check
Submission incomplete:
1: The validation report on page 15 states that the PJRCES Validation Team further confirms that the proposed CDM project activity is neither registered as a CDM project activity nor included as a component project activity (CPA) in a registered CDM programme of activities (PoA) nor a CPA excluded from a registered PoA nor a project activity that has been deregistered. However, the DOE, i.e. RINA, has not provided any confirmation on this aspect.
2: The validation report on page 32 states that PJRCES has assessed and validated the starting date of the project, as well as concluded that CDM was seriously considered in the decision to proceed with the project activity, that proposed project activity complies with requirements on the demonstration and assessment of prior consideration of CDM, and that barriers associated with the project activity is found to be credible, complete and sufficiently demonstrated that the project is not a likely baseline scenario. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion on aspects above. Furthermore, it is observed that there is no barriers demonstrated in the PDD. Refer to paragraphs 46, 83 and 106 of the VVS-PA.
3: Responding to the issue for incompleteness, the DOE explained that parameter BRB5,n,y has been estimated as per equation 5 of the methodology. However, as per paragraph 51 (c) of the methodology, the quantity of biomass residue of category n allocated to scenario B5 is the maximum between sub paragraph (i) and sub paragraph (ii). This provision has not been considered in the PDD and in the calculation.
Furthermore, it is observed that the emission reductions are calculated from year 2015-16, whereas the PDD mentions the crediting period is expected to start on 03/06/2017 or date of submission of complete request for registration by the DOE whichever is later.
Refer to paragraph 110 of VVS-PA.
4: Responding to the issue for incompleteness, the DOE explained that:
(a) Parameter LFCEG,CG,i is now estimated based on values sourced from Project Technical Description. The DOE is requested to explain what ‘lost time’ is and how the inclusion of ‘lost time’ when calculating the actual electricity generation (‘Yearly power generation’, as shown in the spreadsheet) is in accordance with the provision in the methodology, i.e. the actual electricity generation of the heat engine should be determined taking into account downtime due to maintenance, seasonal operational patterns, and any other technical constraints;
(b) The PDD has included parameter BRHIST,n,x, Px and NCVBR,x, with x refer to year 2017-18. The DOE is requested to explain:
(i) How the choice of year x as year 2017-18 is in line with the methodology, as: the methodology describes that x is year prior the date of submission of the PDD for validation of the CDM project activity; and the chosen year is after the commissioning of the project activity (May 2017);
(ii) How the inclusion of bagasse stored when calculating BRHIST,n,x is in line with the methodology. As per the methodology, BRHIST,n,x is the quantity of biomass residues of category n used for power or heat generation at the project site, whereas stored bagasse is not used for power or heat generation yet.
Refer to paragraph 112(a) of VVS-PA.
5: The validation report on page 48 states that PJRCES confirms that the description of the monitoring plan contains all necessary parameters, that they are described and that the means of monitoring described in the PDD complies with the requirements of the methodology. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion on this aspect. Refer to paragraph 119 of the VVS-PA.
6: The validation report on page 49 states that PJRCES through documental review and interviews, determined that the project participants conducted an analysis of the environmental impacts of the proposed project activity. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion on this aspect. Refer to paragraph 129 of the VVS-PA.
7: The validation report on page 50 describes the confirmation regarding MoC by PJRCES. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion regarding the MoC. Refer to paragraph 157 of the VVS-PA.
1: The validation report on page 15 states that the PJRCES Validation Team further confirms that the proposed CDM project activity is neither registered as a CDM project activity nor included as a component project activity (CPA) in a registered CDM programme of activities (PoA) nor a CPA excluded from a registered PoA nor a project activity that has been deregistered. However, the DOE, i.e. RINA, has not provided any confirmation on this aspect.
2: The validation report on page 32 states that PJRCES has assessed and validated the starting date of the project, as well as concluded that CDM was seriously considered in the decision to proceed with the project activity, that proposed project activity complies with requirements on the demonstration and assessment of prior consideration of CDM, and that barriers associated with the project activity is found to be credible, complete and sufficiently demonstrated that the project is not a likely baseline scenario. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion on aspects above. Furthermore, it is observed that there is no barriers demonstrated in the PDD. Refer to paragraphs 46, 83 and 106 of the VVS-PA.
3: Responding to the issue for incompleteness, the DOE explained that parameter BRB5,n,y has been estimated as per equation 5 of the methodology. However, as per paragraph 51 (c) of the methodology, the quantity of biomass residue of category n allocated to scenario B5 is the maximum between sub paragraph (i) and sub paragraph (ii). This provision has not been considered in the PDD and in the calculation.
Furthermore, it is observed that the emission reductions are calculated from year 2015-16, whereas the PDD mentions the crediting period is expected to start on 03/06/2017 or date of submission of complete request for registration by the DOE whichever is later.
Refer to paragraph 110 of VVS-PA.
4: Responding to the issue for incompleteness, the DOE explained that:
(a) Parameter LFCEG,CG,i is now estimated based on values sourced from Project Technical Description. The DOE is requested to explain what ‘lost time’ is and how the inclusion of ‘lost time’ when calculating the actual electricity generation (‘Yearly power generation’, as shown in the spreadsheet) is in accordance with the provision in the methodology, i.e. the actual electricity generation of the heat engine should be determined taking into account downtime due to maintenance, seasonal operational patterns, and any other technical constraints;
(b) The PDD has included parameter BRHIST,n,x, Px and NCVBR,x, with x refer to year 2017-18. The DOE is requested to explain:
(i) How the choice of year x as year 2017-18 is in line with the methodology, as: the methodology describes that x is year prior the date of submission of the PDD for validation of the CDM project activity; and the chosen year is after the commissioning of the project activity (May 2017);
(ii) How the inclusion of bagasse stored when calculating BRHIST,n,x is in line with the methodology. As per the methodology, BRHIST,n,x is the quantity of biomass residues of category n used for power or heat generation at the project site, whereas stored bagasse is not used for power or heat generation yet.
Refer to paragraph 112(a) of VVS-PA.
5: The validation report on page 48 states that PJRCES confirms that the description of the monitoring plan contains all necessary parameters, that they are described and that the means of monitoring described in the PDD complies with the requirements of the methodology. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion on this aspect. Refer to paragraph 119 of the VVS-PA.
6: The validation report on page 49 states that PJRCES through documental review and interviews, determined that the project participants conducted an analysis of the environmental impacts of the proposed project activity. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion on this aspect. Refer to paragraph 129 of the VVS-PA.
7: The validation report on page 50 describes the confirmation regarding MoC by PJRCES. However, the DOE, i.e. RINA, has not provided any confirmation or conclusion regarding the MoC. Refer to paragraph 157 of the VVS-PA.
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