03:34 20 Jun 25
Info Report Check
Submission incomplete:
1: The PP/DOE are requested to describe the GHG sources with in the project boundary in the PDD as per EB 48 Annex 60 paragraph 10 (a).
i) The PP/DOE are requested to correct the inconsistencies in the tables of page 22 from the PDD and of item 4.4 from the Validation Report, in particular emissions of CH4 and N2O from sludge composting and emissions of CH4 from storage tanks; ii) the PP/DOE shall assess why emissions gases and sources are being included/excluded from the project boundary based on the baseline and project situations, in particular providing its assessment on why the project emissions of CO2 from thermal energy generation are being excluded if the Validation Report states that "May be an important emission source". In addition when assessing the inclusion of CO2 emissions from manure transportation, it shall be clear whether it is an important emission source.
2: The PP/DOE are requested to describe on identification of baseline scenario(s) in PDD and VR as per EB 48 Annex 60 paragraph 10 (a) and VVM v1.2 paragraph 87.
The PDD and the Validation Report shall include: i) How the alternative "Aerobic Treatment" was excluded from the list of alternatives to the baseline scenario; ii) include the assessment on how it was concluded that the alternative "Cattle deep bedding" has lower emissions compared to the alternative "uncovered anaerobic lagoon"; iii) indicate which farms have baseline emissions equals or above 900 tCO2 as per the methodology guidance for the assessment of the baseline scenario for the livestock farms.
3: The PP/DOE are requested to explain the methodological choices for the calculation of the baseline, project emissions and emission reductions as per EB 48 Annex 60 paragraph 10 (a).
i) The PP/DOE should include in the assessment which approach from the "Tool to determine project emissions from flaring gases containing methane" will be followed (default value or continuous monitoring) to monitor the flaring of the gas; ii) The PDD states (page 20) that the "residues collected from the farms, in the project activity, are not stored in between collection activities" and, therefore, no emissions from storage tanks are taken into account. However, the PDD states (on page 14) that the manure will be collected every 1-2 days according to a routine and frequent timetable and the transport is made through tank trucks. The PDD shall include a justifications on how the manure is managed and/or stored between the collection days and the reasons for not including the methane emissions from manure storage; iii) In the determination of the MCF, it is not clear which is the AWMS baseline technology for each farm included in the project boundary, which is the average temperature in each farm included in the project boundary and whether the monthly average temperature in a certain month during an year for a certain farm is below 5ºC and whether this month was included in the estimations; iv) The determination approach of the parameter NEX (annual average nitrogen excretion per head of a defined livestock population in kgN/animal/year), as per Annex 6 from the methodology, was not justified in the PDD.
4: The PP/DOE are requested to list the data and parameters used to calculate the emission reductions as per EB 48 Annex 60 paragraph 10 (a).
i) the PDD shall correct the source and value for the parameter EF1 as the PDD indicates that the value of the parameter EF1 is 0.0075 as per Table 11.3, chapter 11, volume 4 of IPCC 2006 guidelines, however according to the referred source, the value for this parameter is differentl; ii) The PDD shall include the parameters used to determine the grid emission factor in Section B.6.2.
5: The PP/DOE are requested to list all the data and parameters to be monitored in line with applied methodology as per EB 48 Annex 60 paragraph 10 (a).
The monitoring of the following parameters were not described in section B.7.1: i) "Monthly quantity of produced compost in the project scenario"; ii) "Monthly total nitrogen concentration of the residues leaving the composting plant".
6: The PP/DOE are requested to include the details of each monitoring parameter listed as per EB 48 Annex 60 paragraph 10 (a).
a) The monitoring frequency of all the parameters should be described in section B.7.1 of the PDD; b) QA/QC procedures applied for the monitoring of the parameter "Monthly total nitrogen concentration in the effluent mix entering the central treatment plant" makes reference to Annex 3 and Annex 4. The PDD shall be corrected as the annexes show information other than the procedures for the monitoring of this parameter. In doing so, the PDD shall indicate how the Total Nitrogen in animal waste will be determined and how samples will be undertaken, as per Annex 3 and Annex 4 of the methodology AM0073; c) The PDD states that the grid emission factor will be determined using the ex-ante approach and will remain fixed for the entire crediting period, however the parameter "CEFgrid" is listed in Section B.7.1; d) Section B.7.1 lists the parameters to be monitored as per the “Tool to determine project emissions from flaring gases containing methane”, however the frequency and QA/QC procedures are not in compliance with the requirements from the tool.
7: The DOE is requested to justify why the site visit was not conducted as per VVM v1.2 paragraph 60-62.
The validation report mentions that 158 diary cow farms were visited. However the DOE did not validate how it has complied with the methodology requirements (page 6 of Meth AM0073) which mentions that "DOEs shall perform site inspections on the sites that are individually responsible for an amount of baseline emissions equal to, or higher than, 900 tCO2e
(“upper rank”).
8: The DOE is requested to provide a statement whether the identified boundary, sources and gases are justified for the project activity as per VVM v1.2 paragraph 80.
i) The PDD indicates, in Section B.3, that emissions of CH4 and N2O from sludge composting and emissions of CH4 from storage tanks are to be included in the project boundary, however these 2 sources were not included in the table from item 4.4 in the Validation Report; ii) the D shall assess why emissions gases and sources are being included/excluded from the project boundary based on the baseline and project situations, in particular providing its assessment on why the project emissions of CO2 from thermal energy generation are being excluded if the Validation Report states that "May be an important emission source". In addition when assessing the inclusion of CO2 emissions from manure transportation, the Validation Report shall enforce whether it is an important emission source rather than indicating that it may be an important emission source.
1: The PP/DOE are requested to describe the GHG sources with in the project boundary in the PDD as per EB 48 Annex 60 paragraph 10 (a).
i) The PP/DOE are requested to correct the inconsistencies in the tables of page 22 from the PDD and of item 4.4 from the Validation Report, in particular emissions of CH4 and N2O from sludge composting and emissions of CH4 from storage tanks; ii) the PP/DOE shall assess why emissions gases and sources are being included/excluded from the project boundary based on the baseline and project situations, in particular providing its assessment on why the project emissions of CO2 from thermal energy generation are being excluded if the Validation Report states that "May be an important emission source". In addition when assessing the inclusion of CO2 emissions from manure transportation, it shall be clear whether it is an important emission source.
2: The PP/DOE are requested to describe on identification of baseline scenario(s) in PDD and VR as per EB 48 Annex 60 paragraph 10 (a) and VVM v1.2 paragraph 87.
The PDD and the Validation Report shall include: i) How the alternative "Aerobic Treatment" was excluded from the list of alternatives to the baseline scenario; ii) include the assessment on how it was concluded that the alternative "Cattle deep bedding" has lower emissions compared to the alternative "uncovered anaerobic lagoon"; iii) indicate which farms have baseline emissions equals or above 900 tCO2 as per the methodology guidance for the assessment of the baseline scenario for the livestock farms.
3: The PP/DOE are requested to explain the methodological choices for the calculation of the baseline, project emissions and emission reductions as per EB 48 Annex 60 paragraph 10 (a).
i) The PP/DOE should include in the assessment which approach from the "Tool to determine project emissions from flaring gases containing methane" will be followed (default value or continuous monitoring) to monitor the flaring of the gas; ii) The PDD states (page 20) that the "residues collected from the farms, in the project activity, are not stored in between collection activities" and, therefore, no emissions from storage tanks are taken into account. However, the PDD states (on page 14) that the manure will be collected every 1-2 days according to a routine and frequent timetable and the transport is made through tank trucks. The PDD shall include a justifications on how the manure is managed and/or stored between the collection days and the reasons for not including the methane emissions from manure storage; iii) In the determination of the MCF, it is not clear which is the AWMS baseline technology for each farm included in the project boundary, which is the average temperature in each farm included in the project boundary and whether the monthly average temperature in a certain month during an year for a certain farm is below 5ºC and whether this month was included in the estimations; iv) The determination approach of the parameter NEX (annual average nitrogen excretion per head of a defined livestock population in kgN/animal/year), as per Annex 6 from the methodology, was not justified in the PDD.
4: The PP/DOE are requested to list the data and parameters used to calculate the emission reductions as per EB 48 Annex 60 paragraph 10 (a).
i) the PDD shall correct the source and value for the parameter EF1 as the PDD indicates that the value of the parameter EF1 is 0.0075 as per Table 11.3, chapter 11, volume 4 of IPCC 2006 guidelines, however according to the referred source, the value for this parameter is differentl; ii) The PDD shall include the parameters used to determine the grid emission factor in Section B.6.2.
5: The PP/DOE are requested to list all the data and parameters to be monitored in line with applied methodology as per EB 48 Annex 60 paragraph 10 (a).
The monitoring of the following parameters were not described in section B.7.1: i) "Monthly quantity of produced compost in the project scenario"; ii) "Monthly total nitrogen concentration of the residues leaving the composting plant".
6: The PP/DOE are requested to include the details of each monitoring parameter listed as per EB 48 Annex 60 paragraph 10 (a).
a) The monitoring frequency of all the parameters should be described in section B.7.1 of the PDD; b) QA/QC procedures applied for the monitoring of the parameter "Monthly total nitrogen concentration in the effluent mix entering the central treatment plant" makes reference to Annex 3 and Annex 4. The PDD shall be corrected as the annexes show information other than the procedures for the monitoring of this parameter. In doing so, the PDD shall indicate how the Total Nitrogen in animal waste will be determined and how samples will be undertaken, as per Annex 3 and Annex 4 of the methodology AM0073; c) The PDD states that the grid emission factor will be determined using the ex-ante approach and will remain fixed for the entire crediting period, however the parameter "CEFgrid" is listed in Section B.7.1; d) Section B.7.1 lists the parameters to be monitored as per the “Tool to determine project emissions from flaring gases containing methane”, however the frequency and QA/QC procedures are not in compliance with the requirements from the tool.
7: The DOE is requested to justify why the site visit was not conducted as per VVM v1.2 paragraph 60-62.
The validation report mentions that 158 diary cow farms were visited. However the DOE did not validate how it has complied with the methodology requirements (page 6 of Meth AM0073) which mentions that "DOEs shall perform site inspections on the sites that are individually responsible for an amount of baseline emissions equal to, or higher than, 900 tCO2e
(“upper rank”).
8: The DOE is requested to provide a statement whether the identified boundary, sources and gases are justified for the project activity as per VVM v1.2 paragraph 80.
i) The PDD indicates, in Section B.3, that emissions of CH4 and N2O from sludge composting and emissions of CH4 from storage tanks are to be included in the project boundary, however these 2 sources were not included in the table from item 4.4 in the Validation Report; ii) the D shall assess why emissions gases and sources are being included/excluded from the project boundary based on the baseline and project situations, in particular providing its assessment on why the project emissions of CO2 from thermal energy generation are being excluded if the Validation Report states that "May be an important emission source". In addition when assessing the inclusion of CO2 emissions from manure transportation, the Validation Report shall enforce whether it is an important emission source rather than indicating that it may be an important emission source.
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