1) Refer to paragraph: VVS paras 404(b), 412(a)(iii)(iv)

The updated PDD (v24) concludes that case 4 (i.e. there is requirement to destroy methane, and there is existing LFG capture system) is applicable when determining the parameter FCH4,BL,y (i.e. the amount of methane that would have been destroyed in the baseline). It defines the value of FCH4,BL,R,y as zero as the requirement does not specify the amount or percentage of LFG that should be destroyed but requires the installation of a capture system, without requiring the captured LFG to be flared. It also defines the value of parameter methane destruction efficiency in the baseline (MDBL) as 1.76% to obtain parameter FCH4,hist,y, which is based on the study  “Reducing the uncertainty of methane recovered (R) in GHG inventories from waste sector and of adjustment factor (AF) in landfill gas projects under CDM” which analyzed 154 Brazilian municipal solid waste landfills. The DOE is requested to explain how it validated the determination of parameter FCH4,BL,y in line with the applied methodology, in particular:

(a)  How the case 4 is applicable as the updated PDD (v24) on page 22 confirms that no new regulations requiring capture and combustion or use of LFG are in place and therefore the baseline scenario does not have to be updated for the second crediting period. It is observed that the project activity falls under case 3 in the first crediting period. While addressing this issue, the DOE shall also explain the nature and deliverable of applicable requirements introduced (i.e. information of the host country’s regulatory requirements relating to LFG, contractual requirements, or requirements to address safety and odour concerns), and further justify the choice of zero for parameter FCH4,BL,R,y based on these applicable requirements introduced, in line with paragraph 43(b) and table 9 of the applied methodology;

(b) How the determination of the value of 1.76% for MDBL to obtain parameter FCH4,hist,y from the study above is in accordance with paragraphs 47 to 49 of the applied methodology ACM0001 (v19) which require the use of historical data related to the respective project activity. It is also observed that on page 10 of the validation report, the DOE states that the MDBL value 1.76% is in line with the methodology but no justification is provided. It is noted that a default value (20%) shall be applied as per the paragraphs 50 – 51 of the ACM0001 (v19), if monitored/historic data of the respective project activity is not available.

2) Refer to paragraph: VVS paras 118(a), 119(a) and 412(a)(iv)

The updated PDD (v24) specifies the value for TDLy for ex-ante calculation as 16%, which is based on World Bank database from 2014. The DOE is requested to explain how the chosen source of data is in accordance with provisions in table 3 of the section 7.2 of Tool 05: Baseline, project and/or leakage emissions from electricity consumption and monitoring of electricity generation (v3), in particular:

(a)   How the DOE validated that the 2014 data from World Bank is the most recent data available for Brazil;

(b)   How the use of data year 2014 is in accordance with the requirement that in the absence of data from the relevant year, most recent figures should be used, but not older than 5 years;

(c)   How the data from World Bank reflects the annual average value within the host country, as required by the tool.