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

Reference number of the proposed CDM project activity/programme of activities (PoA) submitted for registration	7740
Title of the proposed CDM project activity/PoA submitted for registration	Methane Recovery from Advanced Wastewater Treatment System in an Ethanol Plant
Please indicate, in accordance with paragraphs 37 and 40 of the CDM modalities and procedures, which validation requirement(s) may require review. A list of requirements is provided below. Please provide reasons in support of the request for review. Including any supporting documentation.
The following are requirements derived from paragraph 37 of the CDM modalities and procedures:
The participation requirements as set out in paragraph 28 to 30 of the CDM modalities and procedures are satisfied; Comments by local stakeholders have been invited, a summary of the comments received has been provided, and a report to the designated operational entity (DOE) on how due account was taken of any comments has been received; Project Participants have submitted to the DOE documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts and, if those impacts are considered significant by the project participants or the host Party, have undertaken an environmental impact assessment in accordance with procedures as required by the host Party; The project activity is expected to result in a reduction in anthropogenic emissions by sources of greenhouse gases that are additional to any that would occur in the absence of the proposed project activity, in accordance with paragraphs 43 to 52 of the CDM modalities and procedures; The baseline and monitoring methodologies comply with requirements pertaining to methodologies previously approved by the Executive Board; Provisions for monitoring, verification and reporting are in accordance with decision 17/CP.7, the CDM modalities and procedures and relevant decisions of the COP/MOP; The project activity conforms to all other requirements for CDM project activities in decision 17/CP.7, the CDM modalities and procedures and relevant decisions by the COP/MOP and the Executive Board.
The following are requirements derived from paragraph 40 of the CDM modalities and procedures:
The DOE shall, prior to the submission of the validation report to the Executive Board, have received from the project participants written approval of voluntary participation from the designated national authority of each Party involved, including confirmation by the host Party that the project activity assists it in achieving sustainable development; In accordance with provisions on confidentiality contained in paragraph 27(h) of the CDM modalities and procedures, the DOE shall make publicly available the project design document; The DOE shall receive, within 30 days, comments on the validation requirements from Parties, stakeholders and UNFCCC accredited non-governmental organizations and make them publicly available; After the deadline for receipt of comments, the DOE shall make a determination as to whether, on the basis of the information provided and taking into account the comments received, the project activity should be validated; The DOE shall inform project participants of its determination on the validation of the project activity. Notification to the project participants will include confirmation of validation and the date of submission of the validation report to the Executive Board; The DOE shall submit to the Executive Board, if it determines the proposed project activity to be valid, a request for registration in the form of a validation report including of the project design document, the written approval of the host Party and an explanation of how it has taken due account of comments received.
There are only minor issues which should be addressed by the DOE/project participants prior to the registration of the project.
Additional information
1) The DOE is requested to further substantiate the baseline selection and validate whether the list of alternatives considered in the PDD includes all possible baseline alternatives. In particular the DOE shall clarify: (a) why baseline alternatives, such as a combination of fuel types including renewable sources (i.e. bagasse) were not considered as a possible scenario for heat and power generation; and (b) the elimination of alternative scenarios H1 and H3 is appropriate considering that  the validation report mentions that the ethanol plant would use bunker fuel oil and bagasse as source of fuel for the boiler (page 19) and bagasse would also be used in the absence of the project activity (page 29). Please refer to VVM v1.2 paragraph 83, 84 and 87, ACM0014 Version 04.1.0. 2) The DOE validated in page 19 of the VR that the production of bagasse is not continuous and not sufficient to meet the plant energy demand and that the ethanol plant would use bunker fuel oil and bagasse as source of fuel for the boiler. Therefore it is not clear how the DOE validated the requirements of the applied methodology for the determination of: a) EFBL,EL,y, where the lower emission factor between the grid emission factor and a captive plant should be applied; and b) EFCO2,FF,boiler, if co-generation of heat using fossil fuels in a captive cogeneration power plant and/ or heat generation using renewable sources apply, then BEHG,y = 0. Please refer to VVM v1.2 paragraph 67(b, c), ACM0014 Version 04.1.0.. 3) The DOE is requested to further clarify why emissions from the sludge treatment are not considered as applicable emission sources in the context of the project activity, as it was observed, that in some sections of the validation report (page 98) it is mentioned that “sludge disposal in the baseline, derived from the anaerobic lagoons, would result in the same disposal method i.e. composting to land” while CL 7 of the VR (page 145) mentions that “In the project scenario, residual sludge will be burnt in the boiler alongside Vinasse”. Please refer to VVM v1.2 paragraph 89, 92(c, d), ACM0014 Version 04.1.0..
Date	14 Jul 13