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	Cerro Pabellon Geothermal Project (Apacheta) (8767)
DOE that requested for issuance and date of request	KBS (23 Dec 24)
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) The DOE verified that the temporary deviations from the registered monitoring plan for the monitoring parameters “Average mass fraction of carbon dioxide and methane in the produced steam in year y” (ωsteam,CO2,y and ωsteam,CH4,y respectively) and “Quantity of steam produced in year y (Msteam,y), without submitting a request for approval of changes as per paragraph 137 of CDM PCP version 3 and para 276 of the CDM VVS version 3. Further, the DOE has verified that i) the most conservative available values have been applied for the parameters ωsteam,CO2,y and ωsteam,CH4 and ii) the most conservative available value as well as alternative monitoring arrangements have been applied for the parameter Msteam,y , as per paragraph 373(a)(i) of VVS version 3.   The DOE is requested to further substantiate on why it did not submit a request for approval of changes as per paragraph 137 of CDM PCP version 3 and para 276 of the CDM VVS version 3 and “CDM project standard for project activities” and in particular an independent validation opinion on consideration of the most conservative values approach and propose alternative monitoring arrangements approach for the monitoring of ωsteam,CO2,y, ωsteam,CH4,y and Msteam,y since:   i)                 the values considered for defining the most conservative values for ωsteam,CO2,y and ωsteam,CH4,y were based on the monitored values at Q4 in 2017 and 2018 and Q3 and Q4  in 2019 and 2020, while the monitoring plan requires quarterly monitoring; ii)                there were no information on when the monitoring of ωsteam,CO2,y and ωsteam,CH4 would be implemented as per the monitoring plan; iii)               there were no validation opinion on the proposed alternative monitoring arrangements of using a totalized flowmeter for the Msteam,y, I which were different from the monitoring plan (which requires the use of a Venturi flow meter located at the upstream of the flash steam turbine) for the period of 08/05/2017 to 31/12/2019 . Please refer to paras 276, 282-284 of the CDM validation and verification standard for project activities Version 03.0.
Date	04 Apr 25