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) 		2183: "Curva de Rodas and La Pradera landfill gas management 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: paragraphs 30 (a) and 402 of VVS-PA (version 02.0)

Paragraphs 30 (a) and 402 of VVS-PA (version 02.0) require that it is mandatory for the DOE to conduct an on-site inspection at validation for the project activity if the estimated annual average of greenhouse gas (GHG) emission reductions is more than 100,000 tCO2eq. It is observed that both updated PDD and VR indicate value of the estimated annual average GHG emission reductions as 230,918 tCO2eq, which is more than 100,000 tCO2e. However, the validation report (Section C.2, page 3) has confirmed that the on-site inspection was not conducted. The DOE shall clarify how it complies with requirement of paragraphs 30 (a) and 402 of VVS-PA (version 02.0).

 

2) Refer to paragraph: paragraph 404(b) of the VVS-PA (version 02.0), “Tool to determine the mass flow of a greenhouse gas in a gaseous stream” (version 3.0), Project emissions from flaring” (version 3.0), Tool to calculate the emission factor for an electricity system (Version 07.0)

The DOE is requested to explain how the project activity has correctly applied the methodology and applicable tools in line with paragraph 404(b) of the VVS-PA (version 02.0), as:

(a)  The QA/QC for parameters Tt and Pt described in the monitoring plan in the PDD is not in line with QA/QC procedures described in the applied tool “Tool to determine the mass flow of a greenhouse gas in a gaseous stream”, version 3.0. In the monitoring plan, the QA/QC procedures are that the meters are subject to regular maintenance and testing regime to ensure accuracy, whereas as per the tool, the QA/QC procedures are “Periodic calibration against a primary device by an independent accredited laboratory. Calibration and frequency of calibration is according to manufacturer’s specifications” for parameter Tt, and “Periodic calibration against a primary device and monthly calibration” for parameter Pt;

(b)  The measurement methods and procedures for parameter Flamem described in the monitoring plan in the PDD is not in line with the measurement methods and procedures described in the applied tool “Project emissions from flaring”, version 3.0. In the monitoring plan, it is stated that the parameter will be measured by thermocouple, whereas as per the per tool the parameter is to be measured using fixed installation optical flame detector: Ultra Violet detector or Infra-Red or both;

(c)  Inconsistency is observed between the PDD and the validation report on option selected to determine the flare efficiency. On page 21, the PDD states that the PP has chosen Option B (Measure the flare efficiency, i.e. Option B.2) with provision that in case of flare failure, Option A (Apply a default value for flare efficiency) will be used, as well as that Option A is selected for the project. Whereas, the validation report on page 16 mentions that the PP has chosen Option A and the use of option B.2 only when it is needed;

(d)  The operating margin (OM) mentioned in the document “Documento_calculo_del_FE_SIN_2017_Rev_Dic_2018.docx” in the UPME/SIAME website (0.623 tCO2/MWh) was calculated based on one-year data (i.e. 2017). This implies that the OM is calculated based on ex-post option of simple adjusted OM method, whereas the PDD states that ex-ante option of simple adjusted OM is chosen. As per paragraph 42(a) of the Tool to calculate the emission factor for an electricity system (Version 07.0), ex-ante option of simple adjusted OM requires the use of a 3-year generation-weighted average data. The DOE is also requested to explain how the OM from the publication is applicable for the project activity.