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	Biomass thermal energy plant – Hartalega Sdn.Bhd, Malaysia (1186)
DOE that requested for issuance and date of request	SQS (25 Nov 11)
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 registered PDD in several sections has stated that the EFB at disposal sites is stockpiled and stored above the ground level. Also in the monitoring report in section E.3 states that "EFB are likely to continue to be stockpiled at the landfill site throughout the crediting period.  It was clarified by the Meth Panel through AM_CLA_0046, 5 June'07, that this tool is not applicable to stockpiles because anaerobic conditions are not ensured because they are exposed to higher aeration due to a larger surface area to volume ratio. The PP/DOE shall clarify how did they deem appropriate to apply “Tool to determine the methane emissions avoided from dumping of waste at a solid waste disposal site” to calculate baseline emissions due to decay of EFB.  Please refer to VVM paragraph 208 (e). 2) Leakage assessment has been carried out as per approach L2 for palm kernel shells (PKS). The proportion of total available PKS in the market that is used as boiler fuel (3.66%) and that used for other industrial applications (20%) is still based on the report 'Renewable Energy Resources by Anders Evald and Others, Integrated Resource Planning, February 2005'. The DOE / PP shall clarify how did they deem appropriate to still use the values as referred in report from 2005 while estimating leakage due to competing use of biomass in year 2010.  Please refer to VVM paragraph 208 (d).
Date	06 Feb 12