dortmund derne chp plant - klean industries · 2010-08-18 · validate the project: “utilization...

VALIDATION REPORT-VER-

GREEN GAS GERMANY GMBH

DORTMUND DERNE CHP PLANT

Report No: 8000349801-07/91-VAL

Date: 2007-November-27

TÜV NORD CERT GmbHJI/CDM Certification Program

Langemarckstrasse 2045141 Essen, Germany

Phone: +49-201-825-3335Fax: +49-201-825-3290

www.tuev-nord.dewww.global-warming.de

Validation Report: Dortmund Derne CHP Plant

TÜV NORD CERT GmbH JI/CDM Certification Program

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Date of first issue: Project No.:

2007-11-27 8000349801-07/91-VAL Approved by: Organisational unit:

Mr. R. WinterTÜV NORD JI/CDM Certification Program

Client: Client ref.:

Green Gas Germany GmbH Dr. Christina Rüffer

Summary/Opinion:

Green Gas Germany GmbH has commissioned the TÜV NORD JI/CDM Certification Program (CP) to validate the project: “Utilization Dortmund Derne CHP Plant”.

This project is intended to reduce CH4 emissions by capturing CMM and converting it in CHP plants into less harmful CO2. Furthermore the project aims to claim emission reductions from heat displacement.

A risk based approach has been followed to perform this validation. In the course of the draft validation 11 Corrective Action Requests (CAR) and 3 Clarification Requests (CR) were raised and successfully closed.

The review of the project design documentation and additional documents related to baseline and monitoring methodology; the subsequent background investigation and follow-up interviews have provided TÜV Nord JI/CDM CP with sufficient evidence to come to a final validation opinion.

In detail the conclusions can be summarised as follows:

- The chosen baseline is a likely scenario to describe what would occur without the project implementation.

- The monitoring plan and the monitoring practices displayed in the project documentation are transparent and adequate.

- The project additionality is sufficiently justified in the PDD.

The conclusions of this report show, that the project, as it was described in the project documentation, is in line with all criteria applicable for the validation.

Report No.: Subject Group:

8000349801-07/91-VAL Environment Indexing terms

Report title:

Dortmund Derne CHP Plant Climate change

Voluntary Emission Reduction

Validation

Work carried out by:

Eric KruppManoj Kumar Borekar

No distribution without permission from the client or responsible organisational unit

Work verified by:

Rainer WinterLimited distribution

Date of this revision: Rev. No.: Number of pages:

2007-11-27 0 69Unrestricted distribution



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Abbreviations

BAU Business as usual

BImSchG Bundes-Immissionsschutzgesetz

(Federal Immission Control Act)

CAR Corrective Action Request

CCX Chicago Climate Exchange

CH4 Methane

CHP Combined Heat & Power

CMM Coal Mine Methane

CO2 Carbon dioxide

CO2e Carbon dioxide equivalent

CR Clarification Request

E Emissions of CO2eq

EIA Environmental Impact Assessment

EU-ETS European Union Emissions Trading Scheme

GHG Greenhouse gas

GWP Global Warming Potential

h Pa Hecto Pascal

IPCC Intergovernmental Panel on Climate Change

K Kelvin

kW Kilowatt

kWh Kilowatt hour

MP Monitoring Plan

MW Megawatt

MWh Megawatt hours

N/A not applicable

NG Natural Gas

P Project

PDD Project Design Document

ProMechG Projekt Mechanismen Gesetz

(German Project Based Mechanisms Act)

PP Project Proponent

UNFCCC United Nations Framework Convention on Climate Change

UVPG Umweltverträglichkeitsprüfungsgesetz (German EIA law)

VER Voluntary Emission Reductions



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Table of Contents Page

1 INTRODUCTION ............................................................................................51.1 Objective 51.2 Scope 51.3 GHG Project Description 6

1.3.1 Project Entities 61.3.2 Project location 61.3.3 Technical project description 7

2 VALIDATION TEAM........................................................................................8

3 METHODOLOGY............................................................................................83.1 Validation Protocol 93.2 Review of Documents 93.3 Follow-up Interviews 103.4 Resolution of Clarification and Corrective Action Requests 103.5 Finalising the report 11

4 VALIDATION FINDINGS ..............................................................................124.1 Project design 134.2 Baseline 134.3 Additionality 154.4 Monitoring Plan 194.5 Calculation of GHG Emissions 204.6 Environmental Impacts 20

5 VALIDATION OPINION ................................................................................22

6 REFERENCES .............................................................................................23

ANNEX: VALIDATION PROTOCOL..........................................................................27



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1 INTRODUCTION

Green Gas Germany GmbH (GGG) has commissioned the TÜV NORD JI/CDM Certification Program (CP) to validate the project:

“Dortmund Derne CHP Plant”

with regard to the relevant requirements for voluntary GHG project activities.

1.1 Objective

The purpose of this validation is to have an independent third party assess the project design. In particular the project's baseline and the monitoring plan (MP) are validated in order to confirm that the project design as documented is sound and reasonable and meets the stated requirements and identified criteria. Validation is seen as necessary to provide assurance to stakeholders on the quality of the project and its intended generation of voluntary emission reductions (VERs).

1.2 Scope

The validation scope is given as an independent and objective review of the project design, the project’s baseline study and monitoring plan which are included in the PDD and other relevant supporting documents.

The items covered in the validation are described below:

• Project Description

- Project design - Project boundaries- Predicted project GHG emissions

• Project Baseline

- Baseline methodology- Baseline GHG emissions

• Monitoring Plan

- Monitoring Plan methodologies and intervals - Indicators/data to be monitored and reported - Responsibilities- External verification and certification



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• Background investigation and follow up interviews

• Draft validation reporting with CARs & CRs, if any

• Validation reporting.

The information included in the PDD and the supporting documents were reviewed against the requirements and criteria mentioned above. The TÜV NORD JI/CDM CP has, based on the recommendations in the Validation and Verification Manual/VVM/, employed a risk-based approach in the validation, focusing on the identification of significant risks for project implementation and the generation of VERs. The validation is based on the information made available to TÜV NORD JI/CDM CP and on the contract conditions.

The validation is not meant to provide any consulting to Green Gas Germany GmbH. However, stated requests for clarifications and/or corrective actions may provide input for improvement of the project design.

1.3 GHG Project Description

1.3.1 Project Entities

The following entity is involved in the developing of the project:

Entity: Green Gas Germany GmbHHessenstr. 57D-47809 KrefeldGermany

Contact person: Mr. Ralf Michels+49 (0) 2151 / 5255 [email protected]

1.3.2 Project location

The project is located at:

Postal Address Glücksstraße 1044329 Dortmund



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1.3.3 Technical project description

The project involves the installation of three co-generation gas-engines and the recovery of coal mine methane (CMM) from a closed coal mine gallery to use it as fuel for the gas-engines. The technology used in the project is of combined heat & power (CHP) type. The key data are given in the table 1-1 mentioned below.

Table 1-1: Technical and operational dataCHP gas engineManufacturer DeutzNumber / formation of cylinders 16 / VCylinder capacity 70.8 dm3

Rotational frequency 1,500 1/minCapacity (electrical power) 3 x 1.358 MWel total 4.074 MWel

Capacity (useful heat) 3 x 1.623 MWth total 4.869 MWth

The emission reductions are a result of the recovery of CMM out of the coal minewhich otherwise would be emitted to the atmosphere. Furthermore the project activity replaces conventionally produced power and heat. Regarding the application of VER out of this replacement CAR A2 and CAR A3 were raised and addressed in table 1and 3 of this report.

As a result, the replacement of conventionally produced power cannot be claimed as emission reductions as: a) the majority of the GHG emissions due to the power production in Germany are subject to the EU-ETS from 1st Jan. 2005 on and thus claiming emission reductions would lead to double counting of emissions in the time after 2005, and b) power from certain sources, e.g. CMM is financially supported by the German Renewable Energy Sources Act (EEG). Though Green Gas Germany GmbH could sufficiently show, that the benefits from the EEG are not sufficient to overcome the investment barrier, the German regulation with respect to the project based mechanisms (ProMechG) states clearly that benefits like EEG support, would lead to the situation in which this part of a project activity is automatically part of the baseline scenario.

Furthermore, the replacement of conventionally produced heat can only be claimed for the time before 2005, as the heating plant from which the heat is displaced by the project activity, also falls under the scope of EU-ETS. To avoid double counting, corresponding credits can only be claimed for the time before 2005.



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2 VALIDATION TEAM

- The Validation Team was led by Mr. Eric Krupp. He is an expert in the field of environmental approval procedures as well as national and international Emission Trading. He worked in different projects in the framework of the German allocation procedure, the verification of the annual CO2 emission reports and the validation/verification of several JI and CDM projects. Mr. Krupp is an appointed JI/CDM Assessor. For this Validation he was assisted by:

- Manojkumar Borekar, TÜV Nord -Pune, India. Mr. Borekar, M.Tech. (Energy Management), B.E. (Mechanical Engineering) and Certified Energy Auditor by Bureau of Energy Efficiency of India (Ministry of Power). Currently he is GHG and Energy Auditor-CDM Services for TÜV NORD India operation. He is an appointed CDM/JI Assessor for TÜV NORD JI/CDM CP and performed validation and verification of several CDM projects.

The validation report is verified by:

- Mr. Rainer Winter. Mr. Winter works at TÜV NORD as ISO 9001/ 14001 Auditor and environmental verifier for EMAS. He is also an approved emission verifier within the European Emission Trading Scheme. Mr. Winter is an authorized JI/CDM assessor and is in charge of the TÜV NORD JI/CDM CP.

3 METHODOLOGY

The Validation of the project was carried out from October to November ‘07. It wasdivided into 2 phases: The pre-validation and the final validation.

The pre-validation process consisted of the following three sub-phases:

• A desk review of the PDD (incl. annexes) and supporting documents with the use of a customised validation protocol/CPM/ according to the Validation and Verification Manual/VVM/;

• Back ground investigation and follow-up interviews with personnel of the project proponent, the consultant, legal authorities and other stakeholders;

• Reporting of validation findings taking into account the public comments received on TÜV NORD website.

The draft validation report includes Corrective Action and Clarification Requests (CAR and CR) identified in the course of this validation.

A Corrective Action Request is established if

• mistakes have been made in assumptions or the project documentation which directly will influence the project results,

• the requirements deemed relevant for validation of the project with certain characteristics have not been met or



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• there is a risk that the project would not be registered by the UNFCCC or that emission reductions cannot be verified and certified.

A Clarification Request is issued where information is insufficient, unclear or not transparent enough to establish whether a requirement is met.

The final validation started after issuance of proposed corrective action (CA) of these CAR and CR by the project proponent. The validation team has assessed the proposed CA with a positive result and after the closure of these CAR and CR the project proponent has issued the final version of the PDD /PDD/. On the basis of this the final validation report and opinion were issued.

3.1 Validation Protocol

In order to ensure consideration of all relevant assessment criteria, a validation protocol was used. The protocol shows, in a transparent manner, criteria and requirements, means of verification and the results from pre-validating the identified criteria. The validation protocol serves the following purposes:

- It organises, details and clarifies the requirements that a JI project is expected to meet;

- It ensures a transparent validation process where the independent entity will document how a particular requirement has been validated and the result of the determination.

The completed validation protocol is enclosed in Annex to this report identifying 11Corrective Action Requests and 3 Clarification Requests.

3.2 Review of Documents

The draft PDD /PDD/ submitted by Green Gas Germany GmbH in October 2007 and supporting background documents related to the project design and baseline were reviewed.

Furthermore, the validation team used additional documentation by third parties like host party legislation, technical reports referring to the project design or to the basic conditions and technical data.

The documents that were considered during the validation process are given in chapter 6 of this report. They are listed as follows:

• Documents provided by the project proponent (Table 6-1)

• Background investigation and assessment documents (Table 6-2)

• Websites used (Table 6-3).

In order to ensure the transparency of the decision making process, the reference codes listed in tables 6-1 to 6-3 are used in the validation protocol and – as far applicable – in the report itself.



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3.3 Follow-up Interviews

In November 2007 TÜV NORD JI/CDM CP performed interviews with the project proponent to confirm selected information and to resolve issues identified in the document review. In the past several interviews with local geological scientists were carried out to prove the basic baseline assumption.

The main topics of the interviews are summarised in Table 3-1.

Table 3-1 Interviewed persons and interview topics

Interviewed Persons /

Entities

Interview topics

Project proponent representatives (head office and site)

- General aspects of the project- Technical details of the project realisation- Involved personnel and responsibilities - Monitoring and measurement equipment- Financial aspects- Management decision- Baseline study assumptions- Environmental impacts - Fuel characteristics- Details of emission reduction calculation- Operational data- Editorial aspects of PDD- Procedural aspects- Details of emission reduction calculation

Scientists - Baseline justification - Performance characteristics

A detailed list including the functions or designations of the interviewed persons is given in chapter 6 (cp. Table 6-4). This table also includes reference codes to be used in the validation protocol.

3.4 Resolution of Clarification and Corrective Action Requests

In order to remedy any mistakes, problems or any other outstanding issues which needed to be clarified for positive conclusion on the project design, CARs and CRs were raised.

In this validation 11 CAR and 3 CR were raised.

The CARs / CRs are documented in the annex.



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3.5 Finalising the report

The draft validation report was submitted to the project participant. After reviewing the revised and resubmitted project documentation/PDD/; resolving the CRs & CARs raised and outstanding concerns TÜV NORD JI/CDM CP issues the final validation report and opinion.



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4 VALIDATION FINDINGS

In the following paragraphs the findings from the desk review of the draft PDD /PDD/, interviews and supporting documents are summarised. This also includes the corresponding corrective action taken by the client and its final assessment.

This chapter also includes a brief discussion of important issues where considered necessary for the project assessment. For a more detailed assessment of single aspects within these categories please also refer to the validation checklist as presented in the annex.

The results are shown in table 4-1:

Table 4-1: Summary of CAR and CR issued

Validation topic 1)

No. of CAR No. of CR

Project design (A) 3 0

Baseline (B and C) 2 0

Additionality (C) 0 0

Crediting Period (D) 1 0

Monitoring Plan (E) 2 1

GHG Calculation (F) 3 2

Environmental Impacts (G) 0 0

SUM 11 3

1) The letters in brackets refer to the validation protocol



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4.1 Project design

The project involves the installation of three co-generation gas-engines and the recovery of coal mine methane (CMM) from a closed coal mine gallery to use it as fuel for the gas engines.

Without recovery the CMM would migrate from the former mine area to the surface and this will result in diffuse emissions of GHG Methane into the atmosphere. In several submitted appraisals of the DMT (Deutsche Montan Technologie) /DMT1/ /DMT2/

it is clearly explained that the whole CMM would be emitted without recovery within comparable timeframes.

Additional to the methane destruction, the replacement of conventionally produced heat will be claimed for emission reductions. Though the heating plant from which the heat is displaced falls under the scope of the EU-ETS, and claiming of carbon credits would lead to double counting, the emission reductions related to displacement of heat can be claimed in the time from start of the project activity and 2004-12-31.

The displacement of power was also applied for in the draft PDD. But with respect to the requirements from the German regulator (given in the Project Mechanisms Act in connection with the German Renewable Sources Act) the emission reductions related to displacement of electrical power cannot be claimed in the whole crediting period. These restrictions are subject to CAR A2 and CAR A3 and addressed in the annex of this report. Green Gas Germany GmbH has taken corresponding measures which satisfies the validation team; hence the corresponding CARs are closed.

Furthermore the project boundary originally includes the gas pumps as part of the CMM extraction system. But the PDD gives contradictory information about the inclusion of these devices into the project boundary. In order to clarify the situation and to ensure consistency within the information included in the PDD, CAR A1 has been raised. In the course of the validation the PP has submitted sufficient information to ensure that the gas pumps only operate with the power produced by the CHP plants. Thus, considering the applied output approach for determination of emission reductions, this power falls under auxiliary consumption of the CHP units and is already considered, as the decisive parameter is the power supplied to the grid. Hence CAR A1 is closed.

4.2 Baseline

The baseline is the scenario that reasonably represents the anthropogenic emissions by sources of GHG emissions that would occur in the absence of the project activity.

The basic assumption for calculating the baseline emissions of abandoned mines is that all recovered methane would migrate to the surface in comparable timeframes and that the mitigated methane amounts are equal to the pumped and combusted quantities. During validation the justification of this basic assumption could be verified by means of document review/DMT1//DMT2/ and by means of interviews with scientists (see chapter 6).



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The monitoring of the baseline and project emissions can be carried out via the input approach by measurement of the CMM amount and the methane concentration or via the output approach by measurement of the power output and a conservative estimation of the electrical efficiency of the plant. In the draft PDD/PDD/ the monitoring via the output approach were chosen. Based on first experiences, especially with respect to the difficulties in measuring CMM quantity and quality, the applied output approach can be assessed as more reliable and more conservative than the input approach.

The coal mine gas contains CO2 as a further greenhouse gas in addition to CH4. Provided that the basic assumption (see above) applies, the emissions of the CO2

part of the coal mine gas are the same in the baseline and in the project situation. Considering the output approach the same logic applies for leakage CH4 that also would be emitted in the baseline and the project situation.

The baseline scenario justification follows a stepwise approach based on definition and elimination of possible alternatives (including continuation of status quo and the proposed project without revenues from carbon credits) due to local or national regulation or barriers. The approach cares for the selection of the baseline scenario either as the only remaining alternative or in case more than one alternative remains, as the most conservative alternative. For this project activity only one alternative remains, i.e. the continuation of status quo. Nevertheless, as the information about the elimination of heat production (e.g. in boilers) was weak in the draft PDD, CAR C1 was raised. In order to close this CAR the PP has provided additional information to the validation team, which underlines the statement that the revenues from selling heat are not sufficient to finance a project consisting of a heating boiler. Furthermore, the contractual relations with the local operator of the district heating grid are short termed, that the certainty to achieve long term benefits to refinance the investment, cannot be ensured. The alternative can be eliminated due to this information and CAR is closed.

Furthermore, the PP would like to claim emission reductions resulting from displacement of electricity and heat (cp. 4.1). The general application is subject to CAR A2 and A3. As a result, the displacement of electricity cannot be claimed and the displacement of heat can only be applied for the time before EU-ETS (i.e. before 01/01/2005). Considering the heat displacement the draft PDD aims to calculate emission reductions for the entire heat supply of the location the CHP units are located. During interview the validation team has obtained the information that the heat is produced not only by the CMM fired CHP units but also from a natural gas fired CHP and from a boiler fired with natural gas and heating oil. Thus an additional CAR C2 was raised after completion of pre-validation. As a result of this CAR the PP calculates the heat supply which is related to the CMM fired CHP plants as the minimum of either the invoiced amount or an amount calculated by the load of the three CMM fired engines and the thermal capacity. This approach can be assessed as appropriate, because the PP provides sufficient information on the priority in operation of the plants (i.e. CMM fired CHP first, NG fired CHP second, boiler third).

All together the baseline scenario is assessed to be constructed in a complete as well as transparent manner. It is in line with the goal for a baseline, to be a scenario that reasonably represents the GHG emissions that would occur in the absence of the project.



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4.3 Additionality

The additionality was demonstrated basing on the “Tool for demonstration and assessment of additionality”/AT/.

The arguments to justify the additionality were summarised in table 4-2. This table also includes the assessment of the validation team.

Table 4-2: Additionality assessment

Step1) Argument PP Assessment of the validation team

1a

The alternatives to the project activity are already defined within the baseline selection.

All the given alternatives can be assessed as possible alternatives for the project activity.

1b

At the time there is no applicable law or regulation to capture and utilize the CMM in Germany. But the CMM was included in the scope of the German Renewable Energy Sources Act (EEG) which promotes “renewables” in the power production by guarantee a fixed prize for the produced electricity. Furthermore all CMM capturing facilities fall under the Federal Immission Control Act (BImSchG) and the German mining law (BBergG) and need corresponding licenses.

All alternatives are in line with the national regulations.

step passed

step not passed

not applicable

Investment barriers

Commercial banks are not financing exploration on a project base. Even if a well is successfully tested most commercial banks are reluctant to finance the project development for the exploitation and the needed co-generation units, because there is no method to determine exactly proven reserves.

Argument not justified

Argument not convincing

Argument justified but not decisive

Argument justified / significant

2

German Renewable Sources Act (EEG) guarantees fixed compensatory payments per kWh, the act aims at providing an incentive for investment. Nevertheless, the project faced investment barriers for several reasons with a key reason being that with a compared to other energy sources in the EEG low electricity sales tariff and with the





step passed

step not passed

not applicable



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uncertainty over CMM flows and variable purity and other technology operation risks, the CMM to power project cannot reach the threshold risk adjusted hurdle rate. Another core reason to be mentioned is that electricity prices increased in the past and EEG tariffs were not adjusted accordingly. Thus, the incentive meant to be set by the EEG is currently undermined whenever actual electricity prices exceeded the fixed tariff such at particular so-called peak times.

The companies dealing with mine gas constantly highlighted the environmental benefit of CMM utilization and calculated with secondary income from selling credits for the reduction of emissions as described in the Kyoto Protocol. The project Her-Teuto is one example of CMM projects that received credits of certified emission reductions. The project is of a similar type compared to the proposed project activity: abandoned mine, CMM utilization for power and heat generation.





Another distinctive feature of the project activity posing an investment barrier is the short predetermined payback time period made available. It was restricted to four years due to the contract regarding the purchase of CMM which expired at the end of 2005.





Technological barriers

The Technology installed in a CHP has to be adjusted to unforeseen events such as high concentrations of contaminants, or a too low concentration of methane for power generation motors. Hence, oftentimes costly high technology equipment has to be installed subsequently in order to cope with upcoming new situations while the project activity is carried out.







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One distinctive feature of the CHP plant in Derne is a 600m long pipeline to transport the CMM from the colliery to the plant.





Within the project activity it had to be dealt with unexpected high contents of sulfur in the project activity. Sulfur amounts metered were about 10-times higher than at other gas fields. Therefore, a gas cooling system, O2-Treatment and an active carbon filter had to be installed. While the gas cooling is used to dehumidify, the O2-Treatment and the active carbon filter are used to further clean the gas and filter the sulfur which otherwise leads to problems with the motor. Before these additional desulfurization installations were carried out, the high concentration of sulfur led to a breakdown of certain parts of the compressor, the motor and auxiliaries. The module 1 had to be replaced in April 2004 and June 2004, module 3 in September 2003 and September 2004. The plant inDortmund-Derne was the first one in which the aforementioned cleaning technologies were installed.





Barriers specific to CMM

Gas quality and quantity cannot be adequately estimated. The CMM amount and the CH4 concentration can vary so that the engines cannot operate or can only be operate with reduced capacity.CMM can contain several impurities which have an impact for the regular operation of the engines







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Other Barriers

So far, with the exception of CCX no approved methodology exists for accrediting emission reductions produced at an abandoned mine. Thus, there is an accreditation barrier for the proposed project activity.





2b

All alternatives face the same barriers. But because of the simpler technology of the alternatives flaring and heat production compared with the project activity, the barrier will not prevent these alternatives

It can be expected that the alternatives, even though they face the same barriers, would rather be implemented than the project activity, because the impact of the technological barriers on this alternatives will not be so important.

3

In Germany many CMM utilization projects are installed. About 50 of these projects have applied for the host government approval to get the status of a JI project and / or claim emission reductions in terms of VERs. With respect to the specific problems described in the technology and the CMM specific barrier analysis, the installed projects cannot be considered as BAU. Considering several technical expertise from hard coal mining research institutes and CMM utilisation working group, which underline the problems which can occur on individual project sites, the installation of a CMM utilisation plant is a high risk investment and not BAU.

Argument not justifiedArgument not convincingArgument justified but not decisive Argument justified / significant

step passed

step not passed

not applicable

Assessment of the validation team

project is additional

project is not additional

The additionality was justified by the barrier route. The technological barriers and the Barriers specific to CMM were assessed to be significant barriers, which are able to prevent the proposed project activity. These barriers lead to several uncertainties in the investment decision and during operation of the plant. Furthermore there are some technological problems within this individual project activity, which are significant barriers, like the sulphur problem, which caused several retrofit measures during operation of the plant. Thus the project can be assessed as additional and is not a BAU case.



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4.4 Monitoring Plan

The monitoring plan defines the collection of data, the measuring instruments and the practices of the monitoring.

The monitoring of the baseline and project emissions can be carried out via the input approach by measurement of the CMM amount and the methane concentration or via the output approach by measurement of the power output and a conservative estimation of the electrical efficiency of the plant. In the draft PDD/PDD/ the monitoring via the output approach was chosen. Based on first experiences, the output approach can be assessed as more reliable and more conservative than the input approach. As the monitoring plan allows for both approaches, the final decision which calculation approach is decisive (i.e. the most conservative approach) should be taken during verification.

All relevant data will be collected continuously and stored during the whole crediting period. The instruments are well known and state of the art. The practices of the monitoring and the training of the personnel represent a high standard.

The approach for the monitoring of the mitigated methane is described in detail in the PDD. Basically the amount of methane used can be derived by the measurement of the generated electricity and calculation of the input fuel energy by applying the thermal efficiency of the CHP. The calculation will be carried out with a fixed conservative value either (in case the PP can provide sufficient

38.5% (in case the information cannot be provided or the efficiency had exceeded 37%). In connection with application of this value, please refer also CAR F3 addressed in the section 4.5 and the annex of this report.

The baseline emissions monitoring regarding CH4-recovery is virtually identical with the monitoring of the project emissions. No further variables have to be measured.

Furthermore the produced heat has to be measured by appropriate measurement devices. The draft PDD does not provide for the measurement of this parameter. A corresponding CAR was raised and closed by the PP.

Furthermore during interview after the pre-validation the validation team became aware that the measurement devices provide only heat measurement for the whole location (which includes also a NG fired CHP unit and a NG / heating oil fired boiler, the monitoring must be extended to separate the heat which is attributable to the combustion of CMM. Thus a CAR C2 was raised together with the assessment of the baseline. The PP assures that the heat will be calculated based on the measurements, the electrical load of the plant and the thermal capacity. For subsequent verification the minimum of the either calculated value or the measured and invoiced value has to be taken. This can be assessed as appropriate, as the PP has provided sufficient information on the operating priority of the plants (i.e. CMM CHP comes first, due to the pricing of the fuel, NG CHP comes second due to possibility of cogeneration and boiler comes at the last position only in order to meet high heat demands exceeding the capacities of all other devices).

Nevertheless during pre-validation of the monitoring plan 1 additional CAR and one CR were raised regarding the lack of organisational structure in the draft PDD and



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the unclear approach which is applied. The PP provides additional information and corrected the PDD accordingly. Thus CAR is closed and CR is resolved.

4.5 Calculation of GHG Emissions

The emission reductions are calculated by subtracting the project emissions from the baseline emissions. The determination of the baseline emissions can be assessed as complete and transparent. The estimation of the project emissions is also transparent and follows conservative assumptions.

The GHG calculation is consistent with the monitored parameters. The formulae are sufficiently given in the PDD showing all necessary parameters necessary. The calculation approach of the methane destruction related part of the baseline, the heat displacement related part of the baseline as well as of the project emissions are assessed to be appropriate.

Nevertheless during pre-validation of the GHG calculation 3 CARs and 2 CRs were raised. CAR F1 was raised as a traceable document (e.g. Spreadsheet) is required to assess the sheet programming. An Excel calculation sheet was provided by the PP providing all necessary calculations. The formulae given in the PDD were applied correctly in the spreadsheet, thus CAR is closed.

CAR F2 was raised as the GWP of methane was incorrectly applied in the draft PDD. PP has revised the project documentation using the UNFCCC approved GWP of 21 for methane. CAR is closed.

CAR F3 dealt with the conservative application of the electrical efficiency value. The draft PDD applies an electrical efficiency value of 35.7 %, taken the measurement report of TÜV NORD Systems for another CMM fired CHP unit into account. As an individual measurement of the proposed project is not possible, the PP must apply a conservative value estimated either as 37% in case PP can provide information about average load, gross production of electricity, quality and quantity for CMM and technical specification of the gas engines, or has to apply 38.5% as a fallback value. The value of 38.5% can be assessed as conservative in any case as the technical data sheet and the average load leads to the assumption that the electrical efficiency has not exceeded this value.

The CRs were raised in order to receive additional information about the applied standard conditions of the gas and the application of the combustion efficiency, which is already considered when the output approach is considered. PP provided sufficient information regarding this CRs, thus CRs are resolved.

4.6 Environmental Impacts

In Germany the environmental impact assessment act /UVPG/ requires a site-specific test of relevance for this kind of projects. This was carried out prior to the BImSchG approval application. It was assessed that no complete EIA is necessary.

Other environmental aspects, such as flue gas (NOx and CO) and sound emissions can be assessed to be of minor importance.



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As the project is located in Germany it meets all requirements of the German environmental legislation (BImSchG, UVPG, TA Luft, etc.), which are very strict and cover all subjects of protection. So, according to this legislation the project has no relevant adverse effects on water quality and quantity, air quality, soil condition and biodiversity. All these subjects of protection as well as the subjects with regard to occupational safety were covered by the operational license granted by the regional environmental authority.



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5 VALIDATION OPINION

This project is intended to reduce CH4 emissions by capturing CMM and converting it in CHP plants into less harmful CO2. Furthermore the project aims to claim emission reductions from heat displacement.

A risk based approach has been followed to perform this validation. In the course of the draft validation 11 Corrective Action Request (CAR) and 3 Clarification Request (CR) were raised and successfully closed.

The review of the project design documentation and additional documents related to baseline and monitoring methodology; the subsequent background investigation and follow-up interviews have provided TÜV Nord JI/CDM CP with sufficient evidence to come to a final validation opinion.

In detail the conclusions can be summarised as follows:

- The chosen baseline is a likely scenario to describe what would occur without the project implementation.

- The monitoring plan and the monitoring practices displayed in the project documentation are transparent and adequate.

- The project additionality is sufficiently justified in the PDD.

The conclusions of this report show, that the project, as it was described in the project documentation, is in line with all criteria applicable for the validation.

Essen, 2007-11-27

Eric KruppValidation Team Leader



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6 REFERENCES

Table 6-1: Documents provided by the project proponent

Reference Document

BImSchG approval notification from environmental authority StUA Hagen.

/AN/

Approval notification from the mining authority Bergamt Kamen regarding approval of the operation plan.

/CC/ CMM Supply Contract between Green Gas Germany and the supplier Minegas.

/IHD/ Invoice for heat to the local supplier “DEW”

/IHFN/ Invoice for heat to the local supplier “Fernwärme Niederrhein”

/IRWE/ Metering confirmation from the power supplier “RWE Net”. The confirmation gives the power from NG and CMM separately. The separation was certified from TÜV NORD Umweltschutz GmbH in order to have evidences for the EEG tariff payment.

/OJ/ Operational journal

Draft PDD: Dortmund Derne CHP Plant” 2007-10-07/PDD/

Final PDD: Dortmund Derne CHP Plant” 2007-11-20

/TDS/ Technical Data Sheet

/WD/ Wiring diagram of the project.

/XLS/ Excel calculation sheet



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Table 6-2: Background investigation and assessment documents

Reference Document

/AT/ UNFCCC: Tool for demonstration and assessment of additionality

/BImSchG/ Bundes - Immissionsschutzgesetz (Federal Immission Control Act)

/CPM/ TÜV NORD JI / CDM CP Management System (incl. CP procedures and forms)

/CCX/ Rulebook of the Chicago Climate Exchange (CCX)

/DMT1/ Meiners, H.; Marzlinger, A.:Gesamtemissionen im deutschen Steinkohlebergbau, Glückauf 138, 2002

/DMT2/ Stellungnahme der Deutschen Montan Technologie GmbH: Beitrag der Gewinnung von Grubengas zur Minderung der CH4-Emissionen im Sinne des Klimaschutzkonzeptes NRW

/EEG/ Erneuerbare Energien Gesetz (German Renewable Energy Sources Act)

/IPPC-RM/ IPPC: Revised 1996 IPCC Guidelines for National Greenhouse Gas Inventories

/ProMechG/ Projekt Mechanismen Gesetz (German Project Based Mechanisms Act)

/TAL2002/ TA Luft 2002

/UVPG/ Umweltverträglichkeitsprüfungsgesetz (German Environmental Impact Assessment Act)

/VVM/ IETA, PCF Validation and Verification Manual (V. 4)

Table 6-3: Websites used

Reference Link Organisation

/bmu/ http://www.bmu.de German Federal Ministry for the Environment, Nature Conservation and Nuclear Safety

/tuv-nord/ http://www.global-warming.de TÜV-Nord JI/CDM CP

/unfccc/ http://ji.unfccc.int UNFCCC

/ggg/ http://www.gas-energie.de Green Gas Germany



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Table 6-4: List of interview persons

ReferenceMoI

1

Name Organisation / Function

/IM01/ T Mr. Ms.

Dr. Meiners DMT, Scientist

/IM02/ V Mr. Ms.

Dr. Rüffer Green Gas Germany, Asset Manager

/IM02/ V Mr. Ms.

Michels Green Gas Germany, Plant Manager

/IM02/ V Mr. Ms.

Renner Green Gas Germany, Assistant Department for Operations

/IM02/ V Mr. Ms.

Rother Green Gas Germany, Accountancy

/IM02/ V Mr. Ms.

Engels Green Gas Germany, Head of Central Control Room



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ANNEX

Annex: Validation Protocol



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* MoV = Means of Verification, DR= Document Review, I= Interview Page A-27

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ANNEX: VALIDATION PROTOCOL

Table 1: Requirements Checklist

CHECKLIST QUESTION Ref. MoV* COMMENTSDraft

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A. General Description of Project Activity

The project design is assessed.

A.1. Project Boundaries

Project Boundaries are the limits and borders defining

the GHG emission reduction project.

A.1.1. Are the project’s spatial (geographical) boundaries clearly defined?

/PDD/ DR The project boundary is sufficiently described in the PDD

OK

A.1.2. Are the project’s system (components and facilities used to mitigate GHGs) boundaries clearly defined?

/PDD/ DR The project boundary given in the figure under section B3 includes the CMM extraction process. Contradictory to this, under section B 6.2 on page 22 it is mentioned that the emissions from the pumping stations (which are definitely downstream the extraction process) are not included in the boundary, because the emissions occur in the baseline as well as in the project situation. The information should be consistent. If the extraction system is included in the boundary, it must be also included in the calculation of

CAR A1 OK



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project emissions, if it is not included, please provide sufficient information that the extraction system was also working with the same capacity in the baseline (maybe before project) situation.

The boundary includes heating grid. As the heat produced for the grid of Fernwärme Niederrhein is generated in plants falling under the EU-ETS, the replacement of heat cannot be claimed for VER after 2004-12-31 as this would lead to double counting of carbon credits. Corresponding clarification should be made in PDD

The boundary includes the power grid. The double counting statement made for the heating system is also applicable for the electrical power. Furthermore, taking the regulation for emission reduction projects in Germany (Project Based Mechanisms Act (ProMechG) into account, the benefit of the German Renewable Energy Sources Act (EEG) leads to a situation similar to public funding. Herewith the production of electricity is part of the

CAR A2

CAR A3

OK

OK



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baseline and cannot be claimed as emission reduction. Corresponding changes have to be made in all sections

A.2. Technology to be employed

Validation of project technology focuses on the project

engineering, choice of technology and competence/

maintenance needs. The validator should ensure that

environmentally safe and sound technology and

know-how is used.

A.2.1. Does the project design engineering reflect current good practices?

/TDS/

Validator´sexperience

DR Yes, assessment on the basis of Technical data sheet and experience out of comparable projects.

OK

A.2.2. Does the project use state of the art technology or would the technology result in a significantly better performance than any commonly used technologies in the host country?

/PDD/

Validators Experience

DR The project uses advanced state of the art technology for common gaseous fuels.

Alternatives would lead to less environmental benefits

OK

A.2.3. Does the project make provisions for meeting training and maintenance needs?

/PDD/ DR The core business of Green Gas Germany and their service and maintenance contractors is the planning, construction, operation and maintenance of plants for the utilisation of special gaseous fuels like LFG or CMM. Thus the project activity does not make provisions

OK



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above this extent.

B. Project Baseline

The validation of the project baseline establishes whether

the selected baseline methodology is appropriate and

whether the selected baseline represents a likely baseline

scenario.

B.1.Baseline Methodology

It is assessed whether the project applies an

appropriate baseline methodology.

B.1.1. Is the discussion and selection of the baseline methodology transparent?

/PDD/ DR Yes, sufficiently transparent. The baseline study considers diffuse methane emissions.

OK

B.1.2. Does the methodology describe the general approaches for demonstrating the additionality of the project?

/PDD/

/AT/

DR In order to prove the additionality of the project the “Tool for the demonstration and assessment of additionality” is used.

Taking into account the sectoral approach, it is shown that all other assessment steps are passed. That means that technological barriers are given.

OK

B.1.3. Does the baseline methodology specify data sources and assumptions?

/PDD/ DR Yes, 2 studies of DMT are mentioned.

OK



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B.1.4. Does the baseline methodology sufficiently describe the underlying rationale for the algorithm/formulae used to determine baseline emissions (e.g. marginal vs. average, etc.)

/PDD/ DR Yes OK

B.1.5. Does the baseline methodology specify types of variables used (e.g. fuels used, fuel consumption rates, etc)?

/PDD/ DR Yes OK

B.1.6. Does the baseline methodology specify the spatial level of data (local, regional, national)?

/PDD/ DR The applied data is consistent with the spatial project boundary i.e. only local data is applied.

OK

C. Project Baseline

The validation of the project baseline establishes whether

the selected baseline methodology is appropriate and

whether the selected baseline represents a likely baseline

scenario.

C.1.Baseline Methodology



C.1.1. What kind of methodology has been used?

/PDD/ DR CDM Approved Methodology –latest version

CDM Approved Methodology –older version

Combination of Approved Methodology

Project specific Methodology

OK



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C.1.2. Has the methodology assessment form (Table 2) been used?

/PDD/ DR Yes

N/A (only in case of latest version of approved CDM methodology)

OK

C.1.3. Is the discussion and selection of the baseline methodology transparent? Can the applied methodology be assessed as appropriate?

/PDD/ DR Yes

No

Comment: see table 2

OK

C.1.4. Is the chosen methodology applied correctly?

/PDD/ DR The methodology is applied in accordance with the underlying logic

OK

C.1.5. Does the baseline methodology specify data sources and assumptions?

/PDD//IM02/

DR, I During interview the validation team realises that the useful heat supplied to the district heating systems are produced not only in the CMM fired heating plants but in fact also by a NG fired CHP unit and a NG /heating oil fired boiler. The measurements are not separated to allocate the heat amounts to the different plants which are in operation on the same location.

CAR C2 OK

C.1.6. Does the baseline methodology sufficiently describe the underlying rationale for the algorithm/formulae used to determine baseline emissions (e.g. marginal vs. average, etc.)

/PDD/ DR Yes OK



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C.1.7. Does the baseline methodology specify types of variables used (e.g. fuels used, fuel consumption rates, etc)?

/PDD/ DR Yes OK

C.1.8. Does the baseline methodology specify the spatial level of data (local, regional, national)?

/PDD/ DR The spatial level of the applied data is specified in the PDD.

OK

C.2.Baseline Scenario Determination

The choice of baseline will be validated with focus

on whether the baseline is a likely scenario and

whether the methodology to define the baseline

scenario has been followed in a complete and

transparent manner?

C.2.1. What is the baseline scenario? /PDD/ DR The baseline scenario is the continuation of the status quo

OK

C.2.2. What other alternative scenarios have been considered and why is the selected scenario the most likely one?

/PDD/ DR As alternatives the • continuation of the status

quo• flaring• power generation• heat generation• project activity not as VER

projectwere considered.

As flaring will not generate any income except the benefit from carbon credits this alternative was eliminated correctly.



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In the baseline scenario setting the alternatives power generation and heat generation are eliminated due to the fact that the additionality of the project activity is given. Though, generation of power or heat separately should generate fewer revenues than both together, this is not sufficient to eliminate at least the heat production as the baseline. Considering the technology necessary for heat generation (e.g. in boilers) the simpler and cheaper technology and the robustness of this combustion facility (in comparison to a gas engine) has to be taken into account.

CAR C1 OK

C.2.3. Has the baseline scenario been determined using conservative assumptions where possible?

/PDD/ DR See C2.2 CAR C1 OK

C.2.4. Does the baseline scenario sufficiently take into account relevant national and/or sectoral policies, macro-economic trends and political aspirations?

/PDD/ DR Yes OK

C.2.5. Have the major risks to the baseline been identified?

/PDD/ DR The major risk to the baseline is the overestimation of the emission in the without-project-situation. This risk can be assessed as low

OK



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C.3.Additionality Determination

The assessment of additionality will be validated

with focus on whether the project itself is not a

likely baseline scenario?

C.3.1. What is the methodology selected to demonstrate additionality?

/PDD/

/AT/

DR An approach similar to the CDM tool for the demonstration and assessment of additionality has been used.

OK

C.3.2. Is the project additionality assessed according to the methodology?

/PDD/

/AT/

DR Yes OK

C.3.3. Are all assumptions stated in a transparent and conservative manner?

/PDD/

/AT/

DR The assumptions are transparent and conservative as they are based on available and traceable data.

OK

C.3.4. Is sufficient evidence provided to support the relevance of the arguments made?

/PDD/

/AT/

DR Yes the evidences were made by demonstration of gas quality and experiences within the whole sector and can be assessed as OK

OK

D. Duration of the Project/ Crediting Period

It is assessed whether the temporary boundaries of the

project are clearly defined.

D.1.1. Are the project’s starting date and operational lifetime clearly defined and evidenced?

/PDD/ DR The starting date of the project activity is clearly stated. However an evidence for this is lacking.Furthermore it is not clear on which date exactly the operation of the project ends. Corresponding

CAR D1 OK



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evidence is also required

D.1.2. Is the start of the crediting period clearly defined and reasonable?

/PDD/ DR The crediting period is given as the operational lifetime of the project (four years and two month) whereas the time beween 01.01.2003 and shut down of the plant will be used to claim VERs for CCX. Nevertheless the date of end of operation should be given acc to CAR D1

OK

E. Monitoring Plan

The monitoring plan review aims to establish

whether all relevant project aspects deemed

necessary to monitor and report reliable

emission reductions are properly addressed.

E.1. Monitoring Methodology



E.1.1. What kind of methodology has been used?

CDM Approved Methodology –latest version

CDM Approved Methodology –older version

Combination of Approved Methodology

Project specific Methodology

OK



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E.1.2. Has the methodology assessment form (S01-VA 30 – A3) been used?

/PDD/ DR Yes

N/A (only in case of latest version of approved CDM methodology)

OK

E.1.3. Is the discussion and selection of the monitoring methodology transparent? Can the applied methodology be assessed as appropriate?

/PDD/ DR Yes

No

Comment: see table 2

OK

E.1.4. Is the chosen methodology applied correctly?

/PDD/ DR The methodology is applied in accordance with the underlying logic

OK

E.1.5. Is the monitoring plan documented according to the chosen methodology and in a complete and transparent manner?

/PDD/ DR The monitoring plan is given. In the PDD. Nevertheless the plan should be revised according to the CARs and CRs raised in the following sections

Not yet OK



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E.2. Monitoring of Project Emissions

It is established whether the monitoring plan

provides for reliable and complete project emission

data over time.

E.2.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for estimation or measuring the greenhouse gas emissions within the project boundary during the crediting period?

/PDD/ DR The monitoring plan generally provides for the collection of the data necessary. Nevertheless as the replacement of power is not eligible the corresponding grid data can be removed from the monitoring plan.

The description of the organisational structure the project operator will implement in order to monitor generated emission reductions in the monitoring plan (section B8 and Annex 3) is not sufficient. The systematic structure has to be described in the logic:

• Where the data is measured (who is responsible for measuring and accuracy)

• How the data is implemente in the reporting system.

• How this raw data will be aggregated

• Etc.

CAR E1 OK



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E.2.2. Are the choices of project GHG indicators reasonable and conservative?

/PDD/ DR The choice of the indicators is reasonable in order to monitor the GHG emission reductions. Nevertheless, default data are incorrectly applied. This will be addressed in section F

OK

E.2.3. Is the measurement method clearly stated for each GHG value to be monitored and deemed appropriate?

/PDD/ DR The calculation method is not clear. It has to be clarified if the methane amount is calculated by calculation from the produced electrical power or by measurement of CMM and CH4 concentration considering density and combustion efficiency

CR E1 OK



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E.3. Monitoring of Baseline Emissions

It is established whether the monitoring plan

provides for reliable and complete project emission

data over time.

E.3.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining the baseline emissions during the crediting period?

/PDD/ DR The monitoring of the baseline emissions with respect to the destruction of methane is the same as the monitoring of the project emissions. Thus the same statements as in section E.2 apply.

For the heat replacement part of the baseline (applicable until 2004-12-31), the heat fed into the district heating grid of Fernwärme Niederrhein has to be measured. The monitoring plan do not provide for this parameter.

CAR E2 OK

E.3.2. Are the choices of baseline GHG indicators reasonable and conservative?

/PDD/ DR See E2.2 OK

E.3.3. Is the measurement method clearly stated for each baseline indicator to be monitored and also deemed appropriate?

/PDD/ DR See E2.3 CR E1 OK



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E.4. Monitoring of Leakage

It is assessed whether the monitoring plan provides

for reliable and complete leakage data over time.

Leakage is not to be applied. This

section is not applicable.

E.4.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining leakage?

N/A

E.4.2. Are the choices of project leakage indicators reasonable and conservative?

N/A

E.4.3. Is the measurement method clearly stated for each leakage value to be monitored and deemed appropriate?

N/A

E.5. Project Management Planning

It is checked that project implementation is properly

prepared for and that critical arrangements are

addressed.

E.5.1. Is the authority and responsibility of overall project management clearly described?

/PDD/ DR The responsibility and authority is not described. It has to be corrected together with CAR E1

CAR E1 OK

E.5.2. Are procedures identified for training of monitoring personnel?

/PDD/ DR The monitoring personnel is sufficiently trained as they are also involved in other CMM and LFG projects. The training will be provided acc. to certified EMS

OK



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E.5.3. Are procedures identified for emergency preparedness for cases where emergencies can cause unintended emissions?

/PDD/ DR Unintended emissions can only occur when the CMM escapes in the atmosphere. As this is the baseline scenario and in such cases no emission reductions can be claimed as VERs, no special provisions are necessary. Furthermore an escape of methane falls under the safety management.

OK

E.5.4. Are procedures identified for review of reported results / data?

/PDD/ DR No corresponding procedures are identified in the PDD. This should be corrected acc. to CAR E1

CAR E1 OK

E.5.5. Are procedures identified for corrective actions in order to provide for more accurate future monitoring and reporting?

/PDD/ DR No corresponding procedures are identified in the PDD. This should be corrected acc. to CAR E1

CAR E1 OK



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F. Calculation of GHG Emissions by Source

It is assessed whether all material GHG emission

sources are addressed and how sensitivities and

data uncertainties have been addressed to arrive at

conservative estimates of projected emission

reductions.

F.1. Calculation of GHG Emission Reductions -

Project Emissions

It is assessed whether the project emissions are

stated according to the methodology and whether the

argumentation for the choice of the default factors and

values – where applicable – is justified.

F.1.1. Are the calculations documented according to the chosen methodology and in a complete and transparent manner?

/PDD/ DR See E.2.2 (CR E1)

The definition of the standard conditions (273.25K and 1013hpa) should be given.

No traceable document (e.g. excel spreadsheet) was provided to the validation team.

The application of the GWP for CFI credits is incorrectly applied. The CCX conversion factor of 18.25 is not the GWP, but it is a common factor for calculation the emission reductions directly see here:

PE = amount of methane destroyed (CMM) * conversion factor CH4 to

CR E1

CR F1

CAR F1

CAR F2

OK

OK

OK

OK



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CO2 (CF) (2.75);

BE = CMM * GWP (21);

ER = BE – PE;

ER = CMM * GWP (21) – CMM * CF (2.75) = CMM * (GWP (21) – CF (2.75) = CMM * 18.25

F.1.2. Have conservative assumptions been used when calculating the project emissions?

/PDD/ DR The application of an electrical efficiency of 35.7% is not conservative. Several measurements on comparable plants resulted in efficiencies higher than 35.7%. Furthermore also at the verification at Minister Stein the measurement only served the purpose to check if the efficiency is not above the applied value of 37%. If the output approach will be applied, the efficiency has to be determined in the same manner as on Minister Stein to prove the conservativeness of the value 37% or a more conservative value of at least 40% (like for natural gas) has to be applied.

The application of the combustion efficiency is not clear. If the CMM amount is calculated via the output approach, the efficiency is already

CAR F3

CR F2

OK

OK



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considered.

F.1.3. Are uncertainties in the project emission estimates properly addressed?

/PDD/ DR The uncertainties have to be considered in conservative assumptions addressed in F.1.2.

OK


Baseline Emissions

It is assessed whether the baseline emissions are

stated according to the methodology and whether

the argumentation for the choice of the default

factors and values – where applicable – is justified.

F.2.1. Are the calculations documented according to the chosen methodology and in a complete and transparent manner?

/PDD/ DR See comments made under F.1 for the methane avoidance part of the baseline.

CR E1CR F1

CAR F1CAR F2

OKOKOKOK

F.2.2. Have conservative assumptions been used when calculating the baseline emissions?

/PDD/ DR The application of the replacement value for heat (0.2016 tCO2/MWh) includes the conservative assumption of 100% for the boiler efficiency.

See comments made under F.1 for the methane avoidance part of the baseline

CAR F3CR F2

OKOK

F.2.3. Are uncertainties in the baseline emission estimates properly addressed?

/PDD/ DR The uncertainties have to be considered in conservative assumptions addressed in F.1.2.

OK



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Leakage

It is assessed whether the leakage emissions are

stated according to the methodology and whether

the argumentation for the choice of the default

factors and values – where applicable – is justified.

Leakage is not to be applied. This

section is not applicable.

F.3.1. Are the leakage calculations documented according to the chosen methodology and in a complete and transparent manner?

N/A

F.3.2. Have conservative assumptions been used when calculating the leakage emissions?

N/A

F.3.3. Are uncertainties in the leakage emission estimates properly addressed?

N/A

F.4. Emission Reductions

The emission reductions shall be real, measurable

and give long-term benefits related to the

mitigation of climate change.

F.4.1. Are the emission reductions real, measurable and give long-term benefits related to the mitigation of climate change?

/PDD/ DR Yes, the emission reductions are real, measurable and give long termbenefit to the mitigation of climate change

OK



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G. Environmental Impacts

Documentation on the analysis of the environmental

impacts will be assessed, and if deemed significant, an

EIA should be provided to the validator.

G.1.1. Has an analysis of the environmental impacts of the project activity been sufficiently described?

/PDD/ DR A site-specific relevance test of environmental impacts has to be carried out prior to the BImSchG approval application. For this kind of project the environmental impacts are assessed as insignificant, so that no complete environmental impact assessment has to conduct.

OK

G.1.2. Are there any Host Party requirements for an Environmental Impact Assessment (EIA), and if yes, is an EIA approved?

/PDD/ DR In Germany an Environmental Impact Assessment Act (UVPG) exists. For this kind of project a site-specific test of relevance is required and has been carried out prior to the approval application (cp. G 1.1).

OK

G.1.3. Will the project create any adverse environmental effects?

/PDD/ DR There are only minor environmental effects (CO, NOx, emissions, noise) which are addressed to in the BImSchG approval application. The effects can roughly be estimated as comparable to motor vehicles of the same capacity.

OK



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G.1.4. Are transboundary environmental impacts considered in the analysis?

/PDD/ DR Within the BImSchG application procedure the impact of emissions to the vicinity of the plant will be assessed in accordance with the guidelines of TA Luft

OK

G.1.5. Have identified environmental impacts been addressed in the project design?

/PDD/ DR The environmental impacts will be assessed together wit the government approval. As the plant has all necessary licenses all environmental impacts were considered and have not to be displayed in the project design.

OK

G.1.6. Does the project comply with environmental legislation in the host country?

/PDD/ DR The projects compliance to the German environmental legislation will be assured by the approval notification acc. to BImSchG.

OK



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A. General requirements for baseline and monitoring

methodologies

A.1. Is the methodology internally consistent (i.e. the applicability, project boundary, baseline emissions estimation procedure, project emission estimation procedure, leakage and monitoring)?

/PDD/ DR The methodology is internally consistent. The application is not fully correct acc. to comments given in table 1

OK

A.2. Has the baseline scenario identification a clear and concise presentation of methodological steps?

/PDD/ DR Stepwise approach is required. Consisting of elimination of alternatives at least status quo and project not undertaken as VER project

OK

A.3. Has the additionality section a clear and concise presentation of methodological steps?

/PDD/ DR Stepwise approach is required. Consisting of elimination of alternatives, barrier and common practice analysis

OK

A.4. Has the emission reduction calculation section provided all relevant formula and are all used variables adequately explained?

/PDD/ DR The methodology do not provide for all formula and parameters corresponding comments were made in table 1

Not yet OK

B. Baseline Setting

The baseline is assessed to be a scenario that

reasonably represents the anthropogenic emissions by

sources or anthropogenic removals by sinks of GHGs that

would occur in the absence of the JI project. The baseline

shall cover emissions from all gases, sectors and source

categories listed in Annex A of the Kyoto Protocol, and

anthropogenic removals by sinks, within the project

boundary.



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B.1.Establishing of a baseline

B.1.1. Is the baseline established in a transparent manner with regard to the choice of approaches, assumptions, methodologies, parameters, data sources and key factors?

/PDD/ DR See Table 1 Section B

B.1.2. Is the baseline established taking account of uncertainties and using conservative assumptions?

/PDD/ DR See Table 1 Section B

B.1.3. Is the baseline established in such a way that VERs cannot be earned for decreases in activity levels outside the project activity or due to force majeure?

/PDD/ DR Decreases in activity levels would lead to lower emission reductions as less CMM will be combusted and less electicty and heat will be sold.

OK

B.1.4. Is the baseline scenario established by identifying and listing plausible future scenarios on the basis of conservative assumptions and identifying the most plausible one?

/PDD/ DR Stepwise approach is required. Consisting of elimination of alternatives at least status quo and project not undertaken as VER project

OK

B.1.5. Is the baseline established on a project specific basis and/or using a multi-project emission factor?

/PDD/ DR Multi project emission factor

21 GWP, 2.75 Conversion factor, 56 tCO2/TJ normal emission factor of natural gas in Germany.

OK

B.1.5.1. If a multi-project emission factor is applied, is it ensured that:

/PDD/ DR



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(a) the physical characteristics of the sector justify the application of a standard emission factor across the sector (e.g. in the case of an integratedelectricity network with no major transmission constraints, the physical characteristics of the system may imply that the impact of a project on emissions can be assessed irrespective of its location); and/or

(b) The emissions intensity does not vary significantly across the sector (e.g. in the case of diesel power generation in off-grid electricity systems, the emission factor for electricity generation may be based on standard factors with a reasonable degree of accuracy)?

GWP is common sense

Conversion factor is the relation between the mole weights of CO2 and CH4

Emission factor for natural gas is commonly used in the EU-ETS.

All other parameters are applied conservatively.

N/A

B.1.5.2. If a project specific emission factor is applied, is it ensured that the baseline is established in accordance of appendix B of the JI guidelines?

/PDD/ DR N/A

B.1.6. Is the baseline established taking national and/or sectoral policies and circumstances into account like:

B.1.6.1. Sectoral reform policies? /PDD/ DR Yes OK

B.1.6.2. Economic situation/growth and socio- /PDD/ DR Yes OK



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demographic factors in the relevant sector as well as resulting predicted demand. Suppressed and/or increasing demand that will be met by the project can be considered in the baseline as appropriate (e.g. by assuming that the same level of service as in the project scenario would be offered in the baseline scenario)?

B.1.6.3. Availability of capital? /PDD/ DR Yes OK

B.1.6.4. Local availability of technologies, skills and know-how and availability of best available technologies in the future?

/PDD/ DR Yes OK

B.1.6.5. Fuel prices and availability? /PDD/ DR N/A

B.1.6.6. National and/or subnational expansion plans for the energy sector, as appropriate?

/PDD/ DR N/A

B.1.6.7. National and/or subnational forestry or agricultural policies, as appropriate?

/PDD/ DR N/A

B.1.7. Have the project participants justified the choice of the baseline?

/PDD/ DR In the PDD by applying step wise approach OK

B.1.8. In case the baseline approach differs from approaches already chosen in comparable projects (same GHG mitigation measure, same country, similar technology, similar scale) positively determined by an AIE, are the differences clearly explained and reasonably justified?

/PDD/ DR Approach is already chosen in several other CMM projects (JI and VER)

OK



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B.2.Project boundary

B.2.1. Does the project boundary encompass all anthropogenic emissions by sources that are

(a) under the control of the project participants

(b) reasonably attributable to the project activity

(c) significant (i.e. emissions should accountfor more than 1 % or exceed an amount of 2000 tCO2e/a)

/PDD/ DR All sources according to the bullet points are covered. Project specific problems with the application are addressed in table 1

OK

B.2.2. Is the delineation of the project boundary and the gases and sources/sinks included described and justified in the relevant PDD by use of a figure or flow chart?

/PDD/ DR Figure is given. OK

B.2.3. Are all gases and sources/sinks included explicitly stated?

/PDD/ DR Only CH4 and CO2 are involved and included OK

B.2.4. Are exclusions of any sources/sinks related to the baseline or the project justified?

/PDD/ DR No exclusions OK

B.3.Assessment of leakage

B.3.1. Is leakage (i.e. the net change of anthropogenic emissions by sources and/or removals by sinks of GHGs which occurs outside the project boundary, and that can be measured and is directly attributable to the JI

/PDD/ DR No obvious reason for involvement of leakage is given within the scope of the methodology

OK



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project.) clearly addressed or the negligence of leakage clearly justified?

B.3.2. In case leakage is attributable to the project, is a procedure provided for ex ante calculation and is the leakage quantified?

/PDD/ DR N/A

C. Additionality

In accordance with Article 6 of the Kyoto Protocol a joint

implementation project has to provide a reduction in

emissions by sources, or an enhancement of net

removals by sinks that is additional to any that would

otherwise occur.

C.1. Is the additionality of the proposed project activity demonstrated and justified?

/PDD/ DR Via a similar approach to the CDM additionality tool.

OK

C.2. Is one of the following approaches applied:

C.2.1. Application of the most recent version of the “Tool for the demonstration and assessment of additionality” approved by the CDM Executive Board?

/PDD/ DR Similar tool OK

C.2.2. Application of any other method for proving additionality approved by the CDM Executive Board?

/PDD/ DR N/A

C.2.3. Provision of traceable and transparent information showing that the baseline was identified on the basis of conservative

/PDD/ DR N/A



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assumptions, that the project scenario is not part of the identified baseline scenario and that the project will lead to reductions of anthropogenic emissions by sources or enhancements of net anthropogenic removals by sinks of GHGs?

C.2.4. Provision of traceable and transparent information that an accredited independent entity has already positively determined that a comparable project (to be) implemented under comparable circumstances (same GHG mitigation measure, same country, similar technology, similar scale) would result in a reduction of anthropogenic emissions by sources or an enhancement of net anthropogenic removals by sinks that is additional to any that would otherwise occur and a justification why this determination is relevant for the project at hand?

/PDD/ DR N/A

D. Crediting Period

D.1. Has the project started on or after 2000-01-01? /PDD/ DR After OK

D.2. Will the crediting period start after 2008-01-01? /PDD/ DR After OK

D.3. Will the crediting period start on or after the date the first emission reductions or enhancements of net removals are generated by the project activity?

/PDD/ DR CP started with first Emission reduction. For purpose of CFI issuance the period starts 01.01.2003

OK



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E. Monitoring

A monitoring plan for the monitoring and reporting of

GHG emissions, emission reductions and/or removals of

emissions by sinks acc. to para 4 – 6 JI Guidelines has to

be provided.

E.1. Is a monitoring plan in place that provides for the collection and archiving of all relevant data necessary for estimating or measuring anthropogenic emissions by sources and/or anthropogenic removals by sinks of GHGs occurring within the project boundary during the crediting period?

/PDD/ DR Monitoring plan is in place. Problems are addressed in table 1 Section E

Not yet OK

E.2. Is a monitoring plan in place that provides for the identification of all potential sources of, and the collection and archiving of data on increased anthropogenic emissions by sources and/or reduced anthropogenic removals by sinks of GHGs outside the project boundary that are significant and reasonably attributable to the project during the crediting period?

/PDD/ DR N/A

E.3. Is a monitoring plan in place that provides for the collection and archiving of information on environmental impacts, in accordance with procedures as required by the host Party, where applicable?

/PDD/ DR N/A



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E.4. Is a monitoring plan in place that provides for quality assurance and control procedures for the monitoring process?

/PDD/ DR The methodology provides for this. The project specific information is poor and addressed to in section E of table 1

Not yet OK

E.5. Is a monitoring plan in place that provides for procedures for the periodic calculation of the reductions of anthropogenic emissions by sources and/or enhancements of anthropogenic removals by sinks by the proposed project, and for leakage effects, if any?

/PDD/ DR N/A

E.6. Are all relevant factors and key characteristics that will be monitored clearly described (incl. also all decisive factors for the control and reporting of project performance)?

/PDD/ DR Yes OK

E.7. Are the indicators, constants and variables used specified?

E.7.1. Are the indicators, constants, variables and/or models used reliable and valid and provide a transparent picture of the emission reductions or enhancements of net removals (to be) monitored?

/PDD/ DR System is consistent with all indicators constants, variables and parameter used.The emission reductions monitored are more an underestimation of the real situation due to conservative application of estimations.

OK

E.7.2. Are the project-specific indicators used, to the extent possible, indicators that are already used in normal business practice and/or have to be reported e.g. to local authorities?

/PDD/ DR Yes OK

E.7.3. Are leakage indicators used data from suppliers/utilities and/or available public

/PDD/ DR N/A



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statistics and/or surveys?

E.7.4. Are default values used in the project? Are accuracy and reasonableness carefully balanced in the selection of default values? Are default values chosen from recognized sources, be supported by statistical analyses providing reasonable confidence levels and be presented in a transparent manner?

/PDD/ DR Default values are used and properly addressed. Mistakes in the application are addressed in table 1.

Not yet OK

E.8. Are procedures for quality assurance and control for the monitoring process provided (This includes, as appropriate, information on calibration and on how records on data and/or method validity and accuracy are kept and made available on request)?


Not yet OK

E.9. Are the responsibilities and the authority regarding the monitoring activities clearly identified?


Not yet OK

F. Estimations and Calculations used in the baseline

and the monitoring plan

The emission reductions or enhancements of net

removals generated by the project have to be estimated

ex ante in the project design document (PDD) of the

project and calculated ex post according to the monitoring

plan included in the PDD

F.1. General issues

F.1.1. Are the emission reductions or enhancements /PDD/ DR Yes OK



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of net removals generated by the project estimated ex ante in the project design document (PDD) of the project and procedures provided for ex post calculation according to the monitoring plan on a project

specific basis?

F.1.2. Are the emission reductions or enhancements of net removals generated by the project estimated ex ante in the project design document (PDD) of the project and procedures provided for ex post calculation according to the monitoring plan at least from

the beginning until the end of the crediting

period?

/PDD/ DR Yes OK

F.1.3. Are the emission reductions or enhancements of net removals generated by the project estimated ex ante in the project design document (PDD) of the project and procedures provided for ex post calculation according to the monitoring plan on a source-

by-source/sink-by-sink basis?

/PDD/ DR Yes OK

F.1.4. Are the emission reductions or enhancements of net removals generated by the project estimated ex ante in the project design document (PDD) of the project and procedures provided for ex post calculation according to the monitoring plan in tonnes of

CO2 equivalent, using global warming

/PDD/ DR Yes. The application of the CCX conversion factor as GWP was addressed in table 2

OK



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potentials defined by decision 2/CP.3 or as

subsequently revised in accordance with

Article 5 of the Kyoto Protocol?

F.1.5. Is it ensured that the description of emission reductions or enhancements of net removals is consistent with the monitoring plan?

/PDD/ DR Yes OK

F.2. Algorithms and formulae used

F.2.1. Are the underlying rationale for the algorithms / formulae (e.g. marginal vs. average etc.) explained?

/PDD/ DR The formula is given. But it should be described more clearly

Not yet OK

F.2.2. Is the conservativeness of the algorithms / procedures justified (To the extent possible, methods to quantitatively account for uncertainty in key parameters should be included)?

/PDD/ DR Conservativeness can be assessed as high OK

F.2.3. Are any parts of the algorithms or formulae that are not self-evident clearly explained (It should be justified that the procedure is consistent with standard technical procedures in the relevant sector. References should be provided as necessary)?

/PDD/ DR Calculations are quite simple OK

F.2.4. Are implicit and explicit key assumptions explained in a transparent manner (It should be clearly stated which assumptions and procedures have significant uncertainty associated with them, and how suchuncertainty is to be addressed)?

/PDD/ DR Key assumptions have to be corrected acc. to CAR F3

Not yet OK



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F.3. Parameters, coefficients and variables used

F.3.1. For those values that are to be provided by the project participants, is it clearly indicated how the values are to be selected and justified, for example, by explaining:

/PDD/ DR Yes OK

F.3.1.1. What types of sources are suitable (official statistics, expert judgment, proprietary data, IPCC, commercial and scientific literature etc.)?

/PDD/ DR IPCC, scientific and county specific sources are suitable

OK

F.3.1.2. How conservativeness of the values is to be ensured?

/PDD/ DR Validation of these values by third party OK

F.3.2. For other values: /PDD/ DR

F.3.2.1. Are the precise references from which these values are taken clearly indicated (e.g. official statistics, IPCC Guidelines, commercial and scientific literature)?

/PDD/ DR IPCC scientific and county specific sources are suitable

OK

F.3.2.2. Is the conservativeness of the values provided justified?

/PDD/ DR Validation of these values by third party OK

F.3.3. Are procedures provided for all data sources, to be followed if expected data are unavailable (For instance, it could be pointed to a preferred data source (e.g. national statistics for the past 5 years), and indicated a priority order for use of additional data (e.g. using longer time series) and/or fall back data sources to preferred sources (e.g. private,

/PDD/ DR If data are unavailable this would lead to unverifiable emission reductions and thus to less VER

OK



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international statistics etc))?

F.3.4. Are International System Units (SI units) used?

/PDD/ DR Yes OK



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Table 3: Resolution of Corrective Action and Clarification Requests

Draft report clarification requests and

corrective action requests by

validation team

Ref. to checklist

question in table

2

Summary of project owner response Validation team conclusion

CAR A1

The project boundary given in the figure under section B3 includes the CMM extraction process. Contradictory to this, under section B 6.2 on page 22 it is mentioned that the emissions from the pumping stations (which are definitely downstream the extraction process) are not included in the boundary, because the emissions occur in the baseline as well as in the project situation. The information should be consistent. If the extraction system is included in the boundary, it must be also included in the calculation of project emissions, if it is not included, please provide sufficient information that the extraction system was also working with the same capacity in the baseline (maybe before project) situation.

A.1.2

The extraction process has been excluded. Whenever the engines were up and running the compressor has been supplied by the electricity that the engines produced. In this special case – the CHP was about 600 meters away from the mine the – it was too costly to pass another cable from the regular electricity grid to the compressor. Hence, the electricity consumption from the regular grid of the compressor can be considered as close to zero. The installation will be shown on a figure attached.

The PP information is correct and evidenced with a wiring plan handed over to the validation team.

CAR is closed



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validation team

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2


CAR A2

The boundary includes heating grid. As the heat produced for the grid of Fernwärme Niederrhein is generated in plants falling under the EU-ETS, the replacement of heat cannot be claimed for VER after 2004-12-31 as this would lead to double counting of carbon credits. Corresponding clarification should be made in PDD

A.1.2The 18.922 CO2 tonnes from the year 2005 have been excluded.

OK

CAR is closed

CAR A3

The boundary includes the power grid. The double counting statement made for the heating system is also applicable for the electrical power. Furthermore, taking the regulation for emission reduction projects in Germany (Project Based Mechanisms Act (ProMechG) into account, the benefit of the German Renewable Energy Sources Act (EEG) leads to a situation similar to public funding. Herewith the production of electricity is part of the baseline and cannot be claimed as emission reduction. Corresponding

A.1.2The power grid has been excluded from the boundary.

OK

CAR is closed



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validation team

Ref. to checklist

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2


changes have to be made in all sections

CAR C1

In the baseline scenario setting the alternatives power generation and heat generation are eliminated due to the fact that the additionality of the project activity is given. Though, generation of power or heat separately should generate fewer revenues than both together, this is not sufficient to eliminate at least the heat production as the baseline. Considering the technology necessary for heat generation (e.g. in boilers) the simpler and cheaper technology and the robustness of this combustion facility (in comparison to a gas engine) has to be taken into account.

C.2.2

To consider heat-production as baseline is not very convincing due to several reasons: Revenues are not only lower than for the sales of electricity but also hard to estimate for the future. Thus, the payback of the investment would not have been granted. To underline this, there was so far not one project in the hard-coal mining regions of Germany where AMM (methane gas from an abandoned mine) has been used for heat production only (see database). ). In addition, the design and equipment for heat only are different from combined heat and power plants, which e.g. affects the know-how with the procurement structure.Beyond, there is no regulatory/governmental incentive (like the EEG) for heat production from mine gas.

PP has provided additional information to the validation team, which underlines the statement that the revenues from selling heat are not sufficient to finance a project consisting of a heating boiler. Furthermore, the contractual relations with the local operator of the district heating grid are short termed, that the certainty to achieve long term benefits to refinance the investment, cannot be ensured. The alternative can be eliminated due to this information.

CAR is closed.

CAR C2

During interview the validation team realises that the useful heat supplied to the district heating systems are produced not only in the CMM fired heating plants but in fact also by a NG fired CHP unit and a NG /heating

C.1.5

The heat supply will be calculated on the basis of the measured value, the load of the CMM CHP units and their thermal capacity. As the heat supply is dependent on weather conditions, the minimum of either the calculated value or the measured value will be applied in verification.

The calculation approach can be assessed as appropriate as theoperation of the devices on this location is strictly planned as CMM comes first, NG CHP second and boiler third. This plan could be justified to the Validation team by financial assumptions regarding fuel prices, and prices for



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validation team

Ref. to checklist

question in table

2


oil fired boiler. The measurements are not separated to allocate the heat amounts to the different plants which are in operation on the same location.

power and heat.

CAR is closed

CAR D1

The starting date of the project activity is clearly stated. However an evidence for this is lacking.Furthermore it is not clear on which date exactly the operation of the project ends. Corresponding evidence is also required

D1.1

The starting date of the project has been proven by providing the first invoice that Minegas GmbH sent to us for the purchase of their minegas.

Evidence can be assessed as conservative.

CAR is closed

CAR E1

The description of the organisational structure the project operator will implement in order to monitor generated emission reductions in the monitoring plan (section B8 and Annex 3) is not sufficient. The responsibility and authority is not described. The systematic structure has to be described in the logic:

• Where the data is measured (who is responsible for measuring and accuracy)

• How the data is implemente

E.2.1The description regarding the monitoring has been amended.

OK

CAR is closed



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validation team

Ref. to checklist

question in table

2


in the reporting system.• How this raw data will be

aggregated • Etc.

CAR E2

For the heat replacement part of the baseline (applicable until 2004-12-31), the heat fed into the district heating grid of Fernwärme Niederrhein has to be measured. The monitoring plan do not provide for this parameter.

E.3.1

In order to prove the amount fed into the heating grid the invoices sent to the “Fernwärme Niederrhein” and “DEW” will be used.

OK

CAR is closed

CR E1

The calculation method is not clear. It has to be clarified if the methane amount is calculated by calculation from the produced electrical power or by measurement of CMM and CH4

concentration considering density and combustion efficiency

E.2.3 Calculated based on power production.

Corrected PDD shows this approach correctly

CR is resolved

CAR F1

No traceable document (e.g. excel spreadsheet) was provided to the validation team.

F.1.1An Excel Spreadsheet containing the necessary data has been provided.

Excel sheet was provided to validation team.

CR is resolved.



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validation team

Ref. to checklist

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2


CAR F2

The application of the GWP for CFI credits is incorrectly applied. The CCX conversion factor of 18.25 is not the GWP, but it is a common factor for calculation the emission reductions directly see here:

PE = amount of methane destroyed (CMM) * conversion factor CH4 to CO2 (CF) (2.75);

BE = CMM * GWP (21);

ER = BE – PE;

ER = CMM * GWP (21) – CMM * CF (2.75) = CMM * (GWP (21) – CF (2.75) = CMM * 18.25

F.1.1 The calculation has been adjusted.

Corrected calculation sows the correct application of GWP.

CAR is closed

CAR F3

The application of an electrical efficiency of 35.7% is not conservative. Several measurements on comparable plants resulted in efficiencies higher than 35.7%. Furthermore also at the verification at Minister Stein the measurement only served the purpose to check if the efficiency is not above the applied value of 37%.

F.1.2

I provided a document prepared by the TÜV Nord measuring the efficiency factor used for a mine called Minister Stein which is close by. It can be argued that the gas is likely to be similar. In order to support this argumentation data concerning the gas quality and quantity has been provided plus figures for the average load. Obviously, it is not anymore possible to assess the electrical efficiency in Derne. In case that the data provided is not sufficient for the verifier, a fallback position of 38.5% has

The approach can be assessed as appropriate. The value of 38.5% can be assessed as conservative in any case as the technical data sheet and the average load leads to the assumption that the electrical efficiency has not exceeded this value.

CAR is closed.



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validation team

Ref. to checklist

question in table

2


If the output approach will be applied, the efficiency has to be determined in the same manner as on Minister Stein to prove the conservativeness of the value 37% or a more conservative value of at least 40% (like for natural gas) has to be applied.

been defined.

CR F1

The definition of the standard conditions (273.25K and 1013hpa) should be given.

F.1.1

The definitions have been added in the table in which the parameters necessary to determine the emission reductions are stated.

OK

CR is resolved

CR F2

The application of the combustion efficiency is not clear. If the CMM amount is calculated via the output approach, the efficiency is already considered.

F.1.2

The combustion efficiency is not longer included in the calculation because the output approach has been chosen to determine the emission reductions.

OK

CR is resolved