12:57 20 Jan 25
Info Report Check
Submission incomplete:
1: The PP/DOE are requested to describe in the PDD the procedure taken to demonstrate additionality of the project activity as per PS version 09.0 paragraphs 49-52 and 111.
The PDD states that ''At the time of the project’s CDM-PDD publication for global stakeholder consultation, no other high-pressure biomass bagasse cogeneration technology in operation in Dominican Republic. Indeed, as confirmed by the DNA and the National Energy Commission (CNE), the project of San Pedro Bio-Energy is a FOIK in the country." The PP is required to describe the how the project activity meets “Methodological tool: Additionality of first-of-its-kind project activities” version 3 as 1) the output of the project is considered as electricity while the project activity produces both electricity and steam and 2) the PDD does not describe how the project is the first in Dominican Republic that applies a technology that is different from technologies that are implemented by any other project, which are able to deliver the same output and have started commercial operation in the applicable geographical area before the project design document (CDM-PDD) is published for global stakeholder consultation or before the start date of the proposed project activity, whichever is earlier as per the paragraph 12 of the tool.
2: The DOE is requested to describe how each applicability condition of the methodology/ies and/or the standardized baseline(s) is fulfilled by the project activity as per VVS version 09.0 paragraphs 85 and 86.
The applied methodology (p 4-5) provides applicability conditions for the case of biomass from dedicated plantations. The DOE (p 11) states that "The project plant will use bagasse (by-product of sugar production), which is a biomass residue." However, its food note 3 also states that "At the time of PDD elaboration the use of dedicated plantations has not been clearly defined however it be considered in a further project stage." Further, it (p 13) states that "This condition was confirmed by PJRCES through visit on site, the sugarcane plantation is for sugar production, for this reason this condition does not apply to CDM project activity." while in the same page, the DOE states that at the time of PDD elaboration the use of dedicated plantations has not been clearly defined however in case to be considered in a further stage, the same criteria from the applied methodology will be adopted. The DOE is required to provide further information on how it has validated this applicability condition as the calculation of the emission reduction and the monitoring plan do not contain the relevant emission and monitoring parameters.
3: The DOE is requested to describe the steps taken to crosscheck the information given in the PDD as per VVS version 09.0 paragraphs 112 and 198.
The DOE (p 22) states that "San Pedro Bioenergy Technology differs from the common used technology of the existent plants in the country due to the capacity of equipment as the proposed project activity will constitute the biggest installed capacity in Dominican Republic. The information presented by the PP was crosschecked by investigating the Dominican Energy Secretariat website which publishes information related to the energy production." The DOE is required to provide further information on 1) how it validated that the technology applied to the project activity is different from technologies in other plants which are able to deliver the same output and have started commercial operation in the applicable geographical area before the project design document (CDM-PDD) is published for global stakeholder consultation or before the start date of the proposed project activity as per “Methodological tool: Additionality of first-of-its-kind project activities” version 3 and 2) why electricity is only considered as the output while the DOE (p6) states that "The new power plant shall produce 140 tonnes of steam at 82 and 520ºC per hour. The steam will supply the sugar mill process and generate from 27.25MW to 29.15MW given to the crops seasoning."
4: The DOE is requested to describe how it has validated the monitoring plan as per VVS version 09.0 paragraphs 149 (b) and 150 (b) (c).
The DOE (p 40) states that "Details of the data to be collected, the frequency of data recording and its format, responsibilities and authorities for project management, procedures for monitoring and reporting, QA/QC procedures, procedures for calibration of metering equipment and procedures for training and maintenance have been elaborated in the monitoring plan described in the Section B.7 and Appendix 5 of the PDD." However, it raised 1 FAR regarding the non-availability of the QA/QC manual of the project and there was no response by the PP and the assessment of DOE on this. The DOE is required to provide further information.
1: The PP/DOE are requested to describe in the PDD the procedure taken to demonstrate additionality of the project activity as per PS version 09.0 paragraphs 49-52 and 111.
The PDD states that ''At the time of the project’s CDM-PDD publication for global stakeholder consultation, no other high-pressure biomass bagasse cogeneration technology in operation in Dominican Republic. Indeed, as confirmed by the DNA and the National Energy Commission (CNE), the project of San Pedro Bio-Energy is a FOIK in the country." The PP is required to describe the how the project activity meets “Methodological tool: Additionality of first-of-its-kind project activities” version 3 as 1) the output of the project is considered as electricity while the project activity produces both electricity and steam and 2) the PDD does not describe how the project is the first in Dominican Republic that applies a technology that is different from technologies that are implemented by any other project, which are able to deliver the same output and have started commercial operation in the applicable geographical area before the project design document (CDM-PDD) is published for global stakeholder consultation or before the start date of the proposed project activity, whichever is earlier as per the paragraph 12 of the tool.
2: The DOE is requested to describe how each applicability condition of the methodology/ies and/or the standardized baseline(s) is fulfilled by the project activity as per VVS version 09.0 paragraphs 85 and 86.
The applied methodology (p 4-5) provides applicability conditions for the case of biomass from dedicated plantations. The DOE (p 11) states that "The project plant will use bagasse (by-product of sugar production), which is a biomass residue." However, its food note 3 also states that "At the time of PDD elaboration the use of dedicated plantations has not been clearly defined however it be considered in a further project stage." Further, it (p 13) states that "This condition was confirmed by PJRCES through visit on site, the sugarcane plantation is for sugar production, for this reason this condition does not apply to CDM project activity." while in the same page, the DOE states that at the time of PDD elaboration the use of dedicated plantations has not been clearly defined however in case to be considered in a further stage, the same criteria from the applied methodology will be adopted. The DOE is required to provide further information on how it has validated this applicability condition as the calculation of the emission reduction and the monitoring plan do not contain the relevant emission and monitoring parameters.
3: The DOE is requested to describe the steps taken to crosscheck the information given in the PDD as per VVS version 09.0 paragraphs 112 and 198.
The DOE (p 22) states that "San Pedro Bioenergy Technology differs from the common used technology of the existent plants in the country due to the capacity of equipment as the proposed project activity will constitute the biggest installed capacity in Dominican Republic. The information presented by the PP was crosschecked by investigating the Dominican Energy Secretariat website which publishes information related to the energy production." The DOE is required to provide further information on 1) how it validated that the technology applied to the project activity is different from technologies in other plants which are able to deliver the same output and have started commercial operation in the applicable geographical area before the project design document (CDM-PDD) is published for global stakeholder consultation or before the start date of the proposed project activity as per “Methodological tool: Additionality of first-of-its-kind project activities” version 3 and 2) why electricity is only considered as the output while the DOE (p6) states that "The new power plant shall produce 140 tonnes of steam at 82 and 520ºC per hour. The steam will supply the sugar mill process and generate from 27.25MW to 29.15MW given to the crops seasoning."
4: The DOE is requested to describe how it has validated the monitoring plan as per VVS version 09.0 paragraphs 149 (b) and 150 (b) (c).
The DOE (p 40) states that "Details of the data to be collected, the frequency of data recording and its format, responsibilities and authorities for project management, procedures for monitoring and reporting, QA/QC procedures, procedures for calibration of metering equipment and procedures for training and maintenance have been elaborated in the monitoring plan described in the Section B.7 and Appendix 5 of the PDD." However, it raised 1 FAR regarding the non-availability of the QA/QC manual of the project and there was no response by the PP and the assessment of DOE on this. The DOE is required to provide further information.
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