Info Report Check
Submission incomplete:
1: The DOE is requested to describe the process taken to validate the accuracy and completeness of the project description as per VVS version 2 paragraphs 64-68 and 69 (a) (b).
It is not clear whether the process heat supplied by the project activity (i.e steam extracted from reducing station and from turbine) remains the same as the process heat supplied by the configurations existing in the pre-project scenario (i.e. one set of 9.5 MW turbo-generator and three boilers).

2: 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.
It is not clear how the DOE has validated the compliance of the project activity with applicability criteria (3) in page 4 of ACM0006 version 12, since the captive electricity demand of the paper plant increases from 11.36 MW in pre-project scenario to 15.87 MW in project scenario (CER spreadsheet, tab "Consolidated BL scenario" and tab "Consolidated PA scenario"), which indicates the processing capacity of the plant has increased. The DOE shall clarfy in details how it has validated the compliance of this applicability condition. In addition, please also provide the information on the processing capacity and production of the paper plants prior to and after the commission of the project activity.

3: It is not clear how black liquor is considered as fossil fuel. The DOE shall explain the details on how it has validated that the black liquor used in the existing boiler (ID # 13) is a type of fossil fuel.


4: 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).
The DOE shall explain how it has validated the emission reductions has been correctly calculated in according with ACM0006 version 12, considering that several issues are identified. For examples:
(a) To determine the total baseline process heat generation in step 1.1 (page 25 of ACM0006), it is not clear how the enthalpy of the condensate return to the heat generators is considered as per the requirement CER spreadsheet, Tab "Calculation", cell F177).
(b) For the baseline availability of biomass residues (BRB4,n,y) in step 1.4. the value reported in page 31 of the validation report (179,612 tonnes) in not consistent with the value calculated (CER spreadsheet, Tab "Calculation", cell F191).
(C) To determine the efficiencies of heat generators in step 1.5, it is not clear whether the applied NCVs of biomass are conservative since net calorific value or lower calorific value (CER spreadsheet, Tab "INPUT", table A) is applied in calculating the efficiencies.
(d) To determine the efficiencies of heat generators in step 1.5, the efficiency for biomass-based heat generators is not calculated in line with equation 6 of ACM0006 (page 29), since the energy content of fuel oil has been added into the denominator of equation 6 (e.g. CER spreadsheet, Tab "Calculation", cell F196 & F198).
(e) In calculating the heat-to-power ratio of cogeneration-type heat engines in step 1.5, the quantity of process heat supplied to the heat engine is applied (CER spreadsheet, Tab "Calculation", cell F242), which in not in line with equation 11 of ACM0006 (quantity of process heat extracted from the heat engine shall be used).
(f) The value of the emission factor of fuel oil (77.4 tonne CO2/GJ) is not correct. (CER spreadsheet, Tab "Calculation", cell F255)
(g) The baseline biomass-based heat generation efficiency (ηBL,HG,BR,h) applied in step 3.1 (CER spreadsheet, Tab "Calculation", cell F267) is not consistent with the value resulted in step 1.5.
Please note, the issues listed are only examples. The DOE shall explain validated the compliance of each calculation step with the applied methodology (ACM0006 version 12).