CDM METHODOLOGIES IMPROVEMENT7th CDM Joint Coordination Workshop

12-13th March 2011, Bonn, Germany

Anne-Sophie Zirah - March 2011

Introduction

Bionersis • Global CDM player

• Mainly landfill gas projects: 17 landfill sites registered since 2008

• Full vertical integration : concession from landfill operators, CDM registration, financing, construction, operations, monitoring, CDM verification, ERPA, CER brokerage

OBJECTIVE: improvement ACM0001 / AMS-III.G / Tool to determine methane emissions from disposal of waste at a SWDS / Tool to determine project emissions from flaring gases containing methane

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1. ACM0001 – main points for improvement

•Use of LFG to produce energy (electricity/thermal) : • Typical LFG project is implemented in 2 steps: 1) flaring then 2) energy generation

• The methodology lacks flexibility

proposed improvements:• No commitment for implementation of the energy component in the PDD: start-

up, capacity, technical specifications, etc. (still, need for inclusion parameters in the monitoring plan)

• Baseline emissions of the electricity component not to be accounted in the ex-ante estimation of baseline emissions not over-estimating the ex-ante amount of ER in case electricity generation is not implemented or if a lower capacity is actually installed

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1. ACM0001 – main points for improvement

•CDM is not stimulating sustainable energy: • For flare only projects that wish to implement energy generation (without

provisions in the PDD), CDM process for requesting change of project activity is too painful and too risky: better option is to keep on flaring

• Wasting energy resource instead of using it

proposed improvements:• Alternative to the procedure for requesting approval of changes (EB48 Annex 66/67):

when the LFG flare has been operating for more than 2/3/4 years, PP shall be allowed to install engines/boiler/air heater without requesting approval of changes. Then no CER will be claimed for the energy component

• Allow request for approval of changes prior to implementation of the changes

• Applying EB48 Annex 66/67: - Option 1: in case the changes are rejected, allow subsequent requests for

issuance for flaring- Option 2: until the change of project activity are accepted, allow requests for

issuance for flaring only

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1. ACM0001 – main points for improvement

•Destruction efficiency : • Destruction efficiency is physically impossible to measure, by definition. One can

only measure what is actually captured and not what is not captured (!)

• The amount of methane generated by the landfill (MGhist , MGPR,y) – based on FoD Model – is theoretical and uncertain

• However the methodology uses the theoretical LFG generated and destruction efficiency in order to calculate the adjustment factor. Given that the average performance of LFG projects is 55%, this leads to a high (and unjustified) over-estimation of the adjustment factor.

• Example: if the AF is 5% in the PDD, and the project performance is 40%, the real adjustment during verification will be 5%/40% = 12.5%. Likewise, if the project performs 200%, the adjustment would be 2.5%. That is illogical.

proposed improvement:

• Parameters MGPR,y and MGhist should not be considered ex-post

• Reconsider definition/calculation of Adjustment Factor and MDBL

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1. ACM0001 – main points for improvement

•Parameters of the Tool SWDS not to be monitored: • f: capturing the methane is the project activity ;. contradiction with the tool

“can only be claimed if there is no gas from the SWDS being captured and flared or combusted” and with the methodology “applicable only if f = 0”

• W/p/z: waste is not prevented from disposal but is disposed in the landfill

• p/z: contradiction with “no waste sample is necessary” in the methodology

• No impact on claimed CER

proposed improvement:• Explicitly exclude the monitoring of these parameters for landfill gas activities

Over the last 2 years, 6 LFG projects have received a comment/ correction/request for review related to the inclusion of these parameters in the monitoring plan of the PDD = 10% of the LFG projects registered or under RfR since 2 years !

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2. Tool to determine methane emissions from disposal of waste at a SWDS

•Parameters to be monitored: proposed improvement:

• Exclude the monitoring of parameters f, W, p, z for landfill gas activities

•Parameters not monitored: high uncertainties• OX: Use 0.1 for managed SWDS that are covered with oxidizing material such as

soil or compost. Use 0 for other types of SDWS.

What if the SWDS is covered and unmanaged?

• DOCf: Use 50%.

2006 IPCC Guidelines: uncertainty DOCf ±20% , lower value when high precipitations, dependent on many factors like temperature, moisture, pH, composition of waste etc.

• MCF: 1 / 0.8 / 0.5 / 0.4

2006 IPCC Guidelines : uncertainty between ± 10% and ±30%

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3. Tool to determine project emissions from flaring gases containing methane

•MDproject,y = (LFGflare,y * wCH4 * DCH4) – (PEflare,y/GWPCH4)

Where: PEflare = TMRG,h * (1 – ηflare,y ) * GWPCH4/1000

TMRG,h Mass flow rate of methane in the residual gas in the hour h (kg/h)

Where: ηflare,y = 1 – TMFG,h/TMRG,h

TMFG,h Methane mass flow rate in the exhaust gas averaged in the hour h (kg/h)

MDproject,y = (LFGflare,y * wCH4 * DCH4) – (TMRG,h * (1 – (1 – TMFG,h/TMRG,h)) * GWPCH4 / 1000 /GWPCH4)

• Or you can simply apply this formula on an hourly basis:

MD = LFGflare * wCH4 * DCH4 * FE !

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4. Consistency ACM0001 / AMS-III.G

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ACM0001 AMS-III.GMDproject or MDflared MDy

tCH4 tCO2

LFGflared LFGburnt

MDBL MDreg

PEflare or ηflare FE

MDflared,y = (LFGflare,y * wCH4 * DCH4) – (PEflare / GWPCH4)

MDy = LFGburnt,y * wCH4 * DCH4 * FE * GWPCH4

MDBL,y = MDhist * MGPR,y / MGhist MDreg = ex-ante value

No sampling necessary. Previous studies can be used

Sampling during the crediting period.Prior to the project, evaluated based

on population, industry or other similar landfills

No leakage accounted Leakage

Use of the Tool to calculate baseline, project and/or leakage emissions

from electricity consumption

Tool to calculate baseline, project and/or leakage emissions from

electricity consumption not applicable

133 projects registered 14 projects registered

Suggested approach to improve methodologies

•More communication with stakeholdersIn particular in the context of :• Request for revision of methodologies• Methodologies with high discrepancy between issuance and ex-ante estimation of

CER• Unused methodologies• Work together with PP on improvement of applicability conditions, screening of

confusing issues, discrepancies • PP know best about methodologies inconsistencies : as long as you have not

implemented it yourself, you can’t tell the issues

•More flexibility• More flexibility at validation stage for methodologies for which claimed CER are

based on actual/direct measurement

•More simple• Improving is making it accessible, applicable and feasible. The working model

must be simple

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