CDM project activity/programme of activities issuance request review form (CDM-ISSR-FORM) (Version 03.0)

Project title of the project activity or programme of activities (PoA) for which issuance is requested	Azito Energie, Phase 3 Expansion from Single Cycle to Combined Cycle (8456)
DOE that requested for issuance and date of request	AENOR (28 Mar 18)
Please indicate, in accordance with paragraphs 65 of the CDM modalities and procedures, for which reason(s) you request review
Incompetence
Please indicate reasons for the request for review
1) According to applied version of the monitoring methodology, it shall be verified whether the NCV of natural gas used by the project power unit(s) are within the uncertainty range of the IPCC default values as provided in Table 1.2, Vol. 2 of the 2006 IPCC Guidelines, when the NCV is provided by the fuel supplier. The methodology further states that if the monitored values fall below this range, additional information from the testing laboratory shall be collected to justify the outcome or additional measurements shall be conducted. The registered monitoring plan states that “If CIE data is not available, local fuel test sheets will be applied. Eventually if none of the mentioned sources are available, IPCC default values at the upper limit of the uncertainty at a 95% confidence interval as provided in Chapter 1 of Vol. 2 (Energy) of the 2006 IPCC Guidelines on National GHG Inventories shall be applied. The CIE data will be cross-checked against fuel test sheets and IPCC values to assure consistency”. However, the ER excel sheet submitted along with the issuance request indicates that the NCV used for calculating project emissions is chosen as the maximum between (i) IPCC default values at the lower limit (as indicated in Cell row D27: R29 and cell O9 of the ER Calculation Tab Sheet) and (ii) information provided by fuel supplier.  Therefore, the DOE is further requested to clarify how it has verified that the monitoring plan, in particular NCV used for calculating project emissions is in accordance with the monitoring methodology, specifically how it has verified that the NCV of natural gas used by the project power unit(s) is within the uncertainty range of the IPCC default values. Please refer to paragraphs 386  of the VVS version 9.0. Please refer to Paragraphs 386 of the VVS version 9.0.. 2) Upstream leakage emissions (fugitive methane emissions from production, transportation, distribution of natural gas) is calculated using the default emission factor (EFi, upstream, CH4) value provided in the applied methodology. However, it is observed that there is a mismatch between the value used in the ER excel sheet submitted along with the issuance request (0.296 tCO2/GJ) versus the one indicated in the methodology (296 tCH4/PJ or 0.000296 tCH4/GJ (“Data Parameter EFi, upstream, CH4, Page 19, ACM007, Version 06.1.0). In addition, for LEy calculation in the ER excel sheet, it is not clear why the parts of the equations are divided by 10^6, for example, the equation in cell [cell row D36: R36 of the ER Calculation Tab Sheet] since the units used for fuel consumed by the project is reported in m3 and historical fuel consumptions is reported in 10^6 m3. The DOE is further requested to clarify how it has verified that the default emission factor “EFi,upstream,CH4”, the equations and units were correctly applied for the calculation of upstream leakage emissions.   Please refer to Paragraphs 402(c), (d) and (e) of the VVS version 9.0.
Date	07 Jun 18