I-DEV0400: Deviation related to the monitoring of the energy consumed for the Cuidad Juarez landfill gas to energy project activity

According to section B.6.1 of the registered PDD that refers to the explanation of methodological choices, as well as the methodology ACM0001 version 05 “Consolidate baseline methodology for landfill gas project activities”, the total amount of electricity imported to meet project requirements shall be measured continuously during the crediting period. Due to the low quantity of landfill gas produced in the Ciudad Juarez landfill, as well due the interconnection and transmission contracts between the project participant
and the Mexican Federal Electricity Commission being delayed until 15 June 2010, the installation of the official meter device that measures the electricity delivered to the grid for the Electricity Commission has
not been implemented yet. The project participant installed an electricity meter (Schlumberger Sentinel, serial number 30247067506-2003*0334006) only on 9 June 2010 (calibrated by CFE (Federal Electricity Commission of Mexico) on 25 May 2010) in order to comply with the requirement to continuously measure
the electricity consumption of the project as required by the monitoring plan and monitoring methodology.
With the installation of the meter device Schlumberger Sentinel, serial number 30247067506-2003*0334006 and the continuous monitoring of the electricity consumed by the project activity, the project participant now comply with the requirements of the monitoring plan contained in the registered PDD dated 23 October 2007.
In the monitoring period of 01 August 2008 to 31 July 2010, however, the electricity consumption for the project activity was not measured. Information of the recent monthly electricity consumptions was verified through the review of measurement reports elaborated by an engineering firm that acts as third party.
Based on an analysis of the information on the historical monthly electricity consumption measured during June 2010 to January 2011 and the landfill gas production from 01 December 2007 to 30 September 2010, the project participant suggests to apply an electricity consumption of 42 695 kWh per month to calculate the project emissions for the monitoring period of 01 August 2008 to 31 July 2010. The electricity consumption of 42 695 kWh per month was calculated as follows:
a) The highest electricity consumption measured during June 2010 to January 2011 was 30 800 kWh (measured in July, August, September, December 2010 and January 2011; please note that the electricity consumption was similar in these months and due to the high multiplier of the meter the resultign electricity consumption in kWh is the same for these months).
b) An statistical analysis based in standard deviation with 95% confidence level was applied to the monthly electricity consumption measurements, the upper limit value calculated was 31 440 kWh, which is higher than the highest electricity consumption measured of 30 800 kWh.
c) The lowest amount of landfill gas production measured during June to September 2010 was 855 267.2 Nm3 (measured in August 2010).
d) The highest amount of landfill gas production measured during the period of 01 December 2007 to 30 September 2010 was 1 161 437.97 Nm3 (measured in February 2009).
e) Based on the above data, the highest electricity consumption during the monitoring period of 01 August 2008 to 31 July 2010 was calculated by extrapolating the upper limit value of the statistical analysis with 95% confidence interval at the lowest amount of landfill gas production measured
during June to September 2010 with the highest amount of landfill gas production measured during the period of 01 December 2007 to 30 September 2010. The resulting electricity consumption is 42 695 kWh per month (d = a / b * c).

As the project participant did not comply with the requirements of the monitoring plan contained in the registered PDD with respect to the measurement of electricity consumption, a deviation has occurred regarding to the measurement of the electricity consumption by the project activity. However, this deviation does not require a revision of the monitoring plan as the project participant installed a calibrated meter device on 9 June 2010 to comply with the monitoring plan.

The electricity consumption selected is a conservative value identified during the analysis of recent measurements of the project activity electricity consumption after the installation of the meter equipment from June 2010 to January 2011 and the landfill gas production during 01 December 2007 to 30 September 2010. The electricity consumption measurements are representative for the monitoring period as the biogas production observed during June 2010 to September 2010 is comparable with the biogas quantity during the monitoring period (refer to Spreadsheet B with value of 95% confidence1stMP.xls). This indicates that the landfill operated with similar characteristics at the time of the recement measurements of the project’s electricity consumption compared to the monitoring period. For this reason similar electricity consumption
would be expected and applying the highest recent measurement to the monitoring period is thus considered appropriate.
The application of an statistical analysis with a 95% of confidence interval, based on the “Guideline to calculate the fraction of methane in the landfill gas from periodical measurement” EB 48 Annex 13, that resulted in a higher value than the highest available electricity consumption measurement (31 440 kWh Vs 30 800 kWh). In addition, the calculated electricity consumption was extrapolated to the highest amount of landfill gas production measured during the period of 01 December 2007 to 30 September 2010, and the resulting electricity consumption is 42 695 kWh. This results in higher project emissions than actual project emissions as is applied in the direct cross multiplication, which will yield a more conservative estimation of the emission reductions.

Response to questions raised during completeness check by Secretariat:

1. The DOE explained that the installation of the official meter device that measures the electricity delivered to the grid for the Electricity Commission has not been implemented yet. And that the project participant installed an electricity meter on 9 June 2010 to continuously measure the electricity consumption of the project. The DOE is requested to clarify if the project has generated electricity during the second monitoring period, as this information has not been provided in the deviation request and there is no meter to measure the electricity generated and exported to the grid.
DNV answer: The project participant did not generate electricity in the monitoring period of 01 August 2008 to 31 July 2010.

2. The DOE is requested to indicate the source of the electricity consumed by the project activity during the second monitoring period.
DNV answer: the electricity consumed in the second monitoring period is electrcticity directly imported from the Mexican Grid.

3. The DOE is requested to clarify whether in the baseline scenario there is energy and/or electricity consumption, as this is not clear in the registered PDD.
DNV answer: according to the registered PDD (page 23), the baseline is: …” is the atmospheric release of the gas although the baseline methodology considers that some of the methane generated by the landfill may be captured and destroyed to comply with regulations or contractual requirements, or to address
safety and odor concerns. The Ciudad Juarez landfill currently does not have any LFG collection or flaring system. No fossil fuel consumption exists for the Project under the baseline scenario.” No electricity consumption is included in the baseline scenario. However, to determine any project emissions, the parameter ELy is included and stipulates the calculation of net quantity of electricity exported during year y. As per definition, the net electricity is the energy electricity generated less the electricity consumed by the project activity, and the methodology asks for the measurement of electricity consumed,
the project participant suggests to use the electricity imported value as this is more conservative that the theoretician electricity of the equipment installed (refer to incise 5 and annexes “Methodology to calculate energy consumption at Cd Juarez landfill” and “Spreadsheet A.xls”).

4. The DOE is requested to clarify how it has validated that a 4-month period (Jun - Oct 2010) of expost measured data (electricity consumed) is sufficient to determine the highest value of electricity consumed by the project, in order to be applied for estimation of electricity consumed during the second monitoring period.
DNV answer: Additional information from November 2010 to January 2011 of electricity consumption of the landfill has been included in the deviation analysis, therefore a 8-month period is considered for the analysis; Furthermore, the project participant has applied an statistical analysis with 95% confidence interval of the electricity measurement sample (based in the “Guidelines to calculate the fraction of methane in the landfill gas from periodical measurements”, EB 60 Annex 13) in order to give more accuracy and conservativeness to the deviation presented. To establish a correlation between the electricity consumption in a period of time and the landfill gas
produced, the weather conditions were observed to calculate and cross check the correlation presented in the deviation. According to the Mexican Meteorological Institute (http://smn.cna.gob.mx1), the average temperature conditions from June to January in the municipality of Ciudad Juarez are historically the
highest and the lowest registered in an average year as per use the use of air condition systems and landfill gas production conditions, for these reasons the use of electricity consumption values from June 2010 to January 2011 are conservative and representative for the monitoring period.

5. The DOE is requested to explain how the highest value of electricity consumed by the project measured during the period Jun - Oct 2010 is conservative, since no comparison with the total nominal value of the equipments of the project activity consuming electricity has been
provided/considered.
DNV answer: The total nominal value of the equipments of the project activity consuming electricity can be found in the Spreadsheet A.xls attached to this deviation. The calculation of this nominal values were done through the maximum theoretical consumption of the equipments installed at the CDM project activity at the working hours from 01 August 2008 to 31 July 2010 (see files Methodology to calculate energy consumption at Cd Juarez landfill and Spreadsheet A.xls), according to this information, the maximum calculation of electricity consumption is 287 896 kWh compared with 1 024 679 kWh that is the result of the energy consumption value calculated as suggested in this deviation request (42 695 kWh) per the 24 months in the period from 01 August 2008 to 31 July 2010. (Spreadsheet B with value of 95% confidence2ndMP.xls).

6. There is contradicting information submitted regarding the period of measured landfill gas production used for the deviation analysis. The DOE has initially stated that the information analyzed related to landfill gas production was from December 2007 to October 2010, but later the
DOE has stated "c) The highest amount of landfill gas production measured during the monitoring period of 30 November 2007 to 31 July 2008 was 1 161 437.97 Nm3 (measured in February 2009)”. In addition, the spreadsheet provided only shows the landfill gas production values from December 2007 to September 2010. Please clearly indicate the period of measured landfill gas production used for the deviation analysis.
DNV answer: The period of measured landfill gas production used for the deviation analysis is from 01 December 2007 to 30 September 2010. In order to obtain a more accurate analysis for the deviation, the project participant included historical information of landfill gas production instead of the data of the 24-month period that corresponds to the second monitoring period (from 01 August 2008 to 31 July 2010). For this reason, the data analysis was based in a sample of 32-month information from 01 December 2007 to 30 September 2010.
In conclusion it is DNV’s opinion that the use of the directly energy measurement approach is more conservative than the use of the theoretical energy consumption approach. Moreover, it is in DNV’s opinion that the measurement campaign of energy for 8 months is representative for determining the highest electricity consumption value in the monitoring period.