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 DOE is requested to further explain how it validated the applicability conditions of the methodology. In particular that the electricity and heat requirement of the consuming facility is generated in separate systems (i.e. electricity and heat in the baseline cannot be generated in another cogeneration facility) in the absence of the project activity. The diagram in the PDD page 6 shows that there is steam extracted from TG-901/2/3/4 and TG-951/2. Furthermore, on page 5 of the PDD, it is mentioned that turbines TG-901/2/3/4 and TG-951/2 are partial condensation turbines with steam extraction.

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 explain how it validated the ex-ante parameters in Section B.6.2 of the PDD in line with the VVS version 07.0 paragraph 103, in particular for the following parameters:
(a) The efficiency of Efficiency of conventional electricity generator units (boilers and steam generators). It is not clear whether the figures are historical figures (as shown in the spreadsheet) or only from specification (as mentioned in the PDD: "Process engineering information based on technical specifications of equipment and operating conditions"). Furthermore, it is not clear why different periods were chosen for different units as shown in the spreadsheet (901/2 based on year 2007-2009, U-902 based on year 2002, U-951/2 based on year 2002-2004, and U2401/2/3 based on year 2011-2013), and how the use of those periods is suitable in the context of the project activity starting in Year 2011;
(b) BEFelec fossil fuel (Baseline CO2 emissions factor for electricity from the dedicated fossil fuel power plant(s)). In particular the calculation of PGi,n (Power generated by sources i (in MWh), by relevant power sources n, sources delivering electricity to the consuming facility), as the Validation Report has not provided information on how this fixed ex-ante parameter is calculated. Furthermore, as PGi,n is not determined based on actual historical figure (as shown in the spreadsheet), the DOE is requested to explain how the values are conservative.

3: The DOE is requested to describe how it has assessed the barrier analysis as per VVS version 2 paragraphs 125-127.
The DOE is requested to further explain: (a) how it has validated the four issues that are considered as indirect penalties provided in the Validation Report page 27 (under institutional barrier Test 2a), in line with paragraph 23(a)(ii) of the VVS version 07.0; (b) how the institutional barrier in Step 2a is real, in line with the VVS version 07.0 paragraph 133(a), as the PP is a self-generating facility and it is already connected to the grid; (c) how the institutional barrier, in particular the economic penalty(ies), does not prevent the implementation of the baseline scenario. Please see paragraph 133(b) of the VVS version 07.0.

4: 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).
The DOE is requested to explain it confirms that the monitoring plan is in compliance with the applicable methodology, in particular for parameter MCHO (Cogeneration heat supplied to industrial plant). As per the methodology, the parameter is to be measured. In the monitoring plan the parameter is determined based on “total steam cogeneration output” and "steam cogeneration output from refinery gas burning". While the “total steam cogeneration output” is measured, the "steam cogeneration output from refinery gas burning" involves the calculation based on factor of 1.182 GJ steam from refinery gas / GJ consumption of refinery gas. Furthermore, the DOE is requested to explain how it validated the factor, in particular how the factor being set fixed ex-ante is conservative throughout the crediting period. Kindly provide the monitoring system diagram showing the measurement point of “total steam cogeneration output” and "steam cogeneration output from refinery gas burning".