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	Fuel switchover from higher carbon intensive fuels to Natural Gas (NG) at Indian Farmers Fertiliser Cooperative Ltd (IFFCO) in Phulpur Village, Allahabad, Uttar Pradesh by M/s Indian Farmers Fertiliser Cooperative Ltd (IFFCO) (1289)
DOE that requested for issuance and date of request	SGS (16 Mar 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 methodology requires natural gas utilized by the project activity be crosschecked with fuel purchasing invoice, while the DOE confirmed that the natural gas amount in the purchasing invoice includes not only gas consumption of the project activity, but also gas consumption of other processes in the fertilizer plant. The DOE shall further clarify how the monitoring of natural gas consumption (FFproject,i.y) complies with the methodology which requires the metered fuel consumption quantities be cross-checked by annual energy balance and also cross-checked with available purchase invoices from the financial records. 2.The DOE verified that the natural gas was not only sourced from abroad (supplied by GAIL) as it was during the past two monitoring periods, but also from domestic gas supplier (supplied by Reliance NG). However, the default emission factor for upstream fugitive methane emissions (EFNG,upstream,CH4) was only based on USA/Canada data (160 tCH4/PJ) published by IPCC guidelines 1996. The DOE shall further clarify how the calculation of leakage complies with the applied methodology.
Date	10 Oct 11