Anne-Sophie Zirah - March 2011

1. CDM METHODOLOGIES IMPROVEMENT7th CDM Joint Coordination Workshop12-13th March 2011, Bonn, Germany Anne-Sophie Zirah - March 2011

2. 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

3. 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

4. 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

5. 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

6. 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 flaredorcombusted” and withthe 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 !

7. 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%

8. 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 !

9. 4. Consistency ACM0001 / AMS-III.G

10. Suggested approach to improve methodologies • More communication with stakeholders In 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