Review Request Form
Submitted Request for Review Form (Version 03.0)
SECTION 1: GENERAL INFORMATION
Title and UNFCCC reference number
of the project activity or
programme of activities (PoA) 		0008: "Brazil NovaGerar Landfill Gas to Energy Project"
SECTION 2: BASIS FOR REVIEW REQUEST
Please indicate the relevant requirement(s) for which you have reasonable concern about whether the project activity or PoA complies,
by checking the appropriate box and specifying the relevant requirement(s) in the list below.

SECTION 3: COMMENTS SUPPORTING REVIEW REQUEST
Please elaborate the reason for requesting a review on the issues you indicated in section 2 above

1) Refer to paragraph: Para 291, CDM project cycle procedure for project activities, version 02.0

The DOE verifies the energy plant Operational license dated 30/04/2019 to confirm the increase in the installed capacity from 4.245 MW in the registered PDD to 16.93 MW.  The change in the installed capacity has become effective ten months after the expiry of the second crediting period on 30/06/2018. Para 291 of the PCP specifies that "If a post-registration change becomes effective during the crediting period prior to or after its renewal, a request for approval of such post-registration change shall not be combined with a request for renewal of crediting period". The DOE shall substantiate how it confirms that the combined request complies with the requirement of para 291 of the PCP for project activities version 02.0.

 

2) Refer to paragraph: Para 243 (a), CDM project standard for project activities, version 02.0

The PP has argued that the proposed increase in the installed capacity from 4.245 MW in the registered PDD to 16.93 MW is not within the control of the PP, the PP mentions that the company Nova Iguaçu Energia e GasRenovavel LTDA which is responsible for exploration, electricity generation and commercialization made investments related to power generation operations. It is however noted that the revised calculations to demonstrate that the project activity remains financially unattractive without CDM include inputs such as CAPEX on engines and operating costs related to operating the power plants in deriving net cash flows. The PP/DOE shall further justify how they have considered it appropriate to account for revenues and expenses not attributable by the project participant in demonstrating financial unattractiveness of the project activity.