CDM METHODOLOGIES IMPROVEMENT 7 th CDM Joint Coordination Workshop th 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 2

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 3

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 4

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 (MG hist, MG PR,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 MG PR,y and MG hist should not be considered ex-post Reconsider definition/calculation of Adjustment Factor and MD BL 5

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 ! 6

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? DOC f : Use 50% IPCC Guidelines: uncertainty DOC f ±20%, lower value when high precipitations, dependent on many factors like temperature, moisture, pH, composition of waste etc. MCF: 1 / 0.8 / 0.5 / IPCC Guidelines : uncertainty between ± 10% and ±30% 7

3. Tool to determine project emissions from flaring gases containing methane MD project,y = (LFG flare,y * w CH4 * D CH4 ) – (PE flare,y /GWP CH4 ) Where: PE flare = TM RG,h * (1 – η flare,y ) * GWP CH4 /1000 TM RG,h Mass flow rate of methane in the residual gas in the hour h (kg/h) Where: η flare,y = 1 – TM FG,h /TM RG,h TM FG,h Methane mass flow rate in the exhaust gas averaged in the hour h (kg/h) MD project,y = (LFG flare,y * w CH4 * D CH4 ) – (TM RG,h * (1 – (1 – TM FG,h /TM RG,h )) * GWP CH4 / 1000 /GWP CH4 ) Or you can simply apply this formula on an hourly basis: MD = LFG flare * w CH4 * D CH4 * FE ! 8

4. Consistency ACM0001 / AMS-III.G 9 ACM0001AMS-III.G MD project or MD flared MD y tCH 4 tCO 2 LFG flared LFG burnt MD BL MD reg PE flare or η flare FE MD flared,y = (LFG flare,y * w CH4 * D CH4 ) – (PE flare / GWP CH4 ) MD y = LFG burnt,y * w CH4 * D CH4 * FE * GWP CH4 MD BL,y = MD hist * MG PR,y / MG hist MD reg = 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 accountedLeakage 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 registered14 projects registered

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 cant 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 10