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	N2O Emission Reduction in nitric acid plant Paulínia, SP, Brazil (1011)
DOE that requested for issuance and date of request	ERM CVS (03 Aug 15)
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 verification report (p. 72 and 23) states that the project campaign 11 was on going after the end of this monitoring period (which is the same date as the end of the first crediting period) and the DOE (p 23) confirmed “EFBL was recalculated in line with the requirements of the methodology” as the length of project campaign 11 was shorter than the average historic campaign length (CLnormal). The DOE shall further clarify how it verified that the recalculated baseline emission factor (EFBL11) is in line with the applied methodology, considering that the applied methodology states that “The period of time beginning from the installation of a new gauze pack until the subsequent plant shut down is defined as a campaign” and methodology clarification AM_CLA_0204 states that “For comparison with the normal campaign length CLnormal, the project campaign length CLn will be determined by the duration of the corresponding production run, with the respective set of gauze pack, including the time that may be outside the crediting periods.” The DOE is also requested to explain why the “adjusted” baseline emission factor for the 9th campaign (0.0058252 tN2O/tHNO3) is larger than the value from the baseline campaign (0.0057603 tN2O/tHNO3), noting that a shorter campaign length should usually lead to lower emission factors. Please refer to VVS v. 7 para. 289.
Date	19 Oct 15