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	BRASCARBON Methane Recovery Project BCA-BRA-15. (6411)
DOE that requested for issuance and date of request	ICONTEC (10 May 21)
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 monitoring report and the verification report describe that parameter “time the flare is operating in a minute (Flamem)” was measured using minute-by-minute thermocouples, whereas the applied methodological tool “Project emissions from flaring”, version 03.0 (Data / Parameter table 10) and the monitoring plan require that the parameter be determined using a flame detector (Ultra Violet detector or Infra-Red or both). The DOE raised a FAR which requires an analysis in the upcoming verification for alternatives such as a revision of the monitoring plan or a possible deviation of the methodology. The DOE is requested to substantiate (i) how it verified the monitoring of Flamem in compliance with the approved monitoring plan and the applied Tool for this monitoring period and (ii) why it did not consider a permanent change to the monitoring plan or a temporary deviation from the Tool and the monitoring plan, prior to submitting the request for issuance. Please refer to Paragraph 360 of the VVS-PA ver. 02. 2) The DOE is requested to substantiate how it verified the monthly aggregate values of the amount of Biogas burned below 500ºC since there is discrepancy observed between the information in file "CER Calculation MR08 - BCA-BRA-15_v2” and the individual Bracarbon Form 08.001 spreadsheets (i.e. Formulario 08:001). As an example, for Site ID “BCA-227SP1-15”, the file “CER Calculation MR08 - BCA-BRA-15_v2”, workbook “MDy-PEpower,y,expost, cell T102” indicates 250.41 m3 of biogas burned below 500ºC for month August 2020, whereas file “BCA-227SP1-15 - Formulario 08.001 - 08-2020” does not show any biogas burned below 500ºC for month August 2020. In doing so, the DOE shall address this observation for the entire months of this monitoring period. Please refer to Paragraph 364 of VVS-PA ver. 02.
Date	11 Oct 21