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	Dona Juana landfill gas-to-energy project (2554)
DOE that requested for issuance and date of request	ICONTEC (10 Apr 18)
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 DOE is requested to explain how the temporary deviation from the registered monitoring plan, has been properly applied, in particular: (a) The application of the proposed temporary deviation from the monitoring plan, i.e. “for LFG total, m, the lower limit of the confidentiality tolerance is applied, while for LFG flare 1, m, LFG flare 2, m, LFG flare 3, m and LFG engine 1, m the upper limit of the confidentiality tolerance is applied”, as the submitted spreadsheets do not show the application of this approach. (b) The temporary deviation is not submitted as PRC with the relevant documents, in line with paragraph 134 of the CDM project cycle procedure for project activities (version 01.0). Please refer to section 8.2 of VVS-PA (version 01.0).. 2) The DOE is requested to explain how it verified the parameter Vtdb,m (Volumetric flow of the LFG stream in time interval t on a dry basis in the hour h for each power generator) as the verification and certification report does not include such information. Please refer to paragraph 367 of VVS-PA (version 01.0).. 3) The DOE is requested to explain how it has verified the appropriate application of the weighting of operating margin emissions factor and weighting of build margin emissions factor in line with paragraph 376(e) of the VVS-PA (version 01.0) as: (i) The project activity applies the weighting of 0.75 and 0.25 for operating margin and build margin, respectively, whereas as per paragraph 84 of the “Tool to calculate the emission factor for an electricity system” (Version 05.0), default value of 0.25 and 0.75 should be used for operating margin and build margin; (ii) According to this tool, if the weightage does not reflect their situation with an explanation for the alternative weights. the PP can submit alternative proposal, for revision of tool or the methodology or deviation from its use. The PP, however, did not submit any proposal for revision of the tool. Please refer to paragraph 376(e) of VVS-PA (version 01.0) and paragraphs 84 and 85 of “Tool to calculate the emission factor for an electricity system” (Version 05.0).. 4) The DOE is requested to explain how it verified the emission reductions calculation, in particular:   (a) The correct application of the flare efficiency, both measured efficiency and default value of efficiency, in line with the tool “Project emissions from flaring” (Version 02.0.0). As per this tool, efficiency can be measured/calculated or default value of 90% can be applied when during the minute m, the temperature of the flare (TEG.m) and the flow rate of the residual gas to the flare (FRG,m) is within the manufacturer’s specification for the flare (SPECflare) and flame is detected. Otherwise, the efficiency is zero. The PDD has documented the parameter SPECflare, i.e. temperature between 900 °C and 1,200 °C, and the flow rate between 1,000 - 5,000 Nm³/h. It is observed that in some minutes, the temperature and/or the flow rate are outside the range of the SPECflare, but the efficiency during those minutes are not zero, for examples: (i) Flare 2: 09/04/2017 15:53. Flare efficiency is 100% (calculated), while temperature of the flare is 832.15 and flow is 113.518 (outside the SPECflare); (ii) Flare 2: 06/05/2017 18:38. Flare efficiency is 90% (default value), while temperature of the flare is 863.9468 (outside the SPECflare); (iii) Flare 3: 12/09/2017 11:27. Flare efficiency is 100% (calculated), while temperature of the flare is 761.5586 and flow is 529.9262 (outside the SPECflare); It is also observed that the default efficiency of 50% is applied (for example in spreadsheets "BDJ - CDM Raw Data - 2017 05" and "BDJ - CDM Raw Data - 2017 09"), while the tool does not have provision for default value 50%;   (b) the completeness of the data, as it is observed that the file "BDJ - CDM Raw Data - 2017 04" only contains data from 03/04/2017 15:36, while the monitoring period starts on 01/04/2017; Please refer to paragraph 376(a) and (c) of VVS-PA (version 01.0)..
Date	26 Jun 18