final validation protocol 20051130 mx05-b-06 - netinform · conclusion cross reference / comment...

Annex 1

Final Validation Protocol

* MoV = Means of Verification, DR= Document Review, I= Interview Page A-1 CDM Validation Protocol_Mx05-B-06_20051130 rev01, Project No. 692195

Table 1 Mandatory Requirements for Clean Development Mechanism (CDM) Project Activities

REQUIREMENT REFERENCE

CONCLUSION

Cross Reference / Comment

1. The project shall assist Parties included in Annex I in achieving compliance with part of their emission reduction commitment under Art. 3

Kyoto Protocol Art.12.2

Table 2, Section E.4.1

2. The project shall assist non-Annex I Parties in achieving sus-tainable development and shall have obtained confirmation by the host country thereof

Kyoto Protocol Art. 12.2, Marrakesh Ac-cords, CDM Modalities §40a

Table 2, Section A.3

3. The project shall assist non-Annex I Parties in contributing to the ultimate objective of the UNFCCC

Kyoto Protocol Art.12.2.

Table 2, Section E.4.1

4. The project shall have the written approval of voluntary partici-pation from the designated national authorities of each party in-volved

Kyoto Protocol Art. 12.5a, Marrakesh Ac-cords, CDM Modalities §40a

The project is designed as CDM project in Mexico (as host coun-try) with two project participants: AgCert Mexico Environmental Service, S. de R.L. de C.V. and AgCert International plc.

The Mexican DNA already has issued the Letter of Approval (LoA) for this project on August 15th, 2005.

The approval does contain all elements specified in EB 16, an-



CONCLUSION


nex 6.

5. The emission reductions shall be real, measurable and give long-term benefits related to the mitigation of climate change

Kyoto Protocol Art. 12.5b

Table 2, Section E

6. Reduction in GHG emissions shall be additional to any that would occur in absence of the project activity, i.e. a CDM pro-ject activity is additional if anthropogenic emissions of green-house gases by sources are reduced below those that would have occurred in the absence of the registered CDM project ac-tivity

Kyoto Protocol Art. 12.5c, Marrakesh Ac-cords, CDM Modalities §43

Table 2, Section B.2

7. Potential public funding for the project from Parties in Annex I shall not be a diversion of official development assistance

Marrakech Ac-cords

The funding for the project does not lead to a diversion of official development assistance as ODA does not contribute to the financ-ing of the project.

8. Parties participating in the CDM shall designate a national au-thority for the CDM

Marrakech Ac-cords, CDM Modalities §29

Mexico already has established a designated national authority (DNA) for the CDM.

9. The host country and the participating Annex 1 Party shall be a Party to the Kyoto Protocol

Marrakech Ac-cords, CDM Modalities §30

Mexico has ratified the Kyoto Pro-tocol on September 7, 2000.

10. The participating Annex 1 Party’s assigned amount shall have been calculated and recorded

Marrakech Ac-cords, CDM Modalities §31b

No Annex I Party is involved at this stage of the project.

11. The participating Annex 1 Party shall have in place a national Marrakech Ac- See comment under requirement



CONCLUSION


system for estimating GHG emissions and a national registry in accordance with Kyoto Protocol Article 5 and 7

cords, CDM Modalities §31b

No. 10.

12. Comments by local stakeholders shall be invited, a summary of these provided and how due account was taken of any comments received

Marrakech Ac-cords, CDM Modalities §37b

Table 2, Section G

13. Documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts, shall be submitted, and, if those impacts are considered significant by the project participants or the Host Party, an environmental impact assessment in accordance with procedures as required by the Host Party shall be carried out.

Marrakech Ac-cords, CDM Modalities §37c

Table 2, Section F

14. Baseline and monitoring methodology shall be previously ap-proved by the CDM Methodology Panel

Marrakech Ac-cords, CDM Modalities §37e

Table 2, Section B.1.1 and D.1.1

15. Provisions for monitoring, verification and reporting shall be in accordance with the modalities described in the Marrakech Accords and relevant decisions of the COP/MOP

Marrakech Ac-cords, CDM Modalities §37f

Table 2, Section D

16. Parties, stakeholders and UNFCCC accredited NGOs shall have been invited to comment on the validation requirements for minimum 30 days, and the project design document and comments have been made publicly available

Marrakech Ac-cords, CDM Modalities, §40

A global public stakeholder proc-ess on the UNFCCC website has taken place from August 5th to September 3rd, 2005. No com-ments have been received (see link: http://www.netinform.de/KE/Wegweiser/Guide2.aspx?ID=1274&Ebene1_ID=26&Ebene2_ID=280&m



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ode=1)

17. A baseline shall be established on a project-specific basis, in a transparent manner and taking into account relevant national and/or sectoral policies and circumstances

Marrakech Ac-cords, CDM Modalities, §45c,d


18. The baseline methodology shall exclude to earn CERs for decreases in activity levels outside the project activity or due to force majeure.

Marrakech Ac-cords, CDM Modalities, §47


19. The project design document shall be in conformance with the UNFCCC CDM-PDD format

Marrakech Ac-cords, CDM Modalities, Ap-pendix B, EB Decisions

The PDD is in conformance with the currently valid CDM Project Design Document (version 02).

Page A-5 CDM Validation Protocol_Mx05-B-06_20051130 rev01, Project No. 692195

Table 2 Requirements Checklist

CHECKLIST QUESTION Ref. MoV* COMMENTS Draft Concl

Final Concl

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) bounda-ries clearly defined?

1-3,9, 10, 11, 15

DR, I

The project spatial boundaries are clearly described in general and limited to the farm sites. An exact and correct descrip-tion of the project boundaries is included in detail in chapter A.4.1 of the PDD “De-tail of physical location….” Further infor-mation can be found in chapter B, table B1: “Farm Data Characterization” and in chapter B.4, Figure B3: “Project Bound-ary”.

The PDD hereby also reflects correctly that emissions from barn systems and barn flushing systems are not considered as these emissions are not affected by the proposed practice change.

Nevertheless not all the information given in the PDD could be confirmed during the on-site visits of the farms - some of the given data have to be corrected or ad-

CAR 1–11CR 1-3



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justed:

Clarification Request No. 1: For all farms in this project the informa-tion concerning the configuration of the lagoons (size, depth, operation of the current (and future) lagoon system) is missing in the PDD and further submitted documents. This information should be submitted to the validator as the qualifi-cation of all farms for this type of CDM project and for using AM0016 has to be demonstrated.

According to Form B for some Sites the Information concerning the lagoons is different than in the PDD.

Clarification Request No. 2: This project is also, as the Project MX05-B-05, located in the state of Jalisco. Even the owner and the local city (Acatic) are the same as in some of the MX-B-05. To avoid confusions and mix-ups of farms in these two projects the correct addresses not only for the central office but also for each farm including the correct GPS-



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coordinates have to be submitted to the validator (ideally included in the PDD).

To illustrate this: There are for example neighboured farms, La Loma Sitio 3 (this farm is part of project MX05-B-06) and La Loma Sitio 1 (this farm is part of pro-ject MX05-B-05) which are not included in the same project and could be mixed up in future.

Furthermore correct and identical farm names should appear in all project documents (for example there are names as Granja Capadero 2, Granja El Ca-padero 2, El Capadero 2 etc. in different documents – this should be excluded). Especially the names in the contracts (annex 1, form A) should correspond with the names in Annex 7 (licenses and permits) and in the annexes with calcula-tions and economic analysis).

Clarification Request No. 3: In this project Farms besides the lagoons also containers are used in the AWMS (animal waste management system). The function and the operation of these



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containers should be explained and there influence/or the not existing influ-ence on the methane production. In which way will these containers be used in the project case with the biodigester?

Corrective Action Request No.1: Farms Tlacoyote 2 Sitio 1 and Tlacoyote Sitio 3:

According to the information given by the farmer during the on-site visit the farm Tlacoyote 2 Sitio 1 uses (has) only 1 pri-mary lagoon and not three as stated in the PDD. Furthermore two containers are used. Also only two and not seven con-tainment areas exist.

The same confusion is with the farm Tla-coyote Sitio 3.

So for these two farms the number (and type) of the lagoons and containment areas has to be corrected. The operation of the containers (baseline case and pro-ject case) has to be explained.

According to Form B the Information concerning the lagoons is different than



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in the PDD.

Corrective Action Request No.2: Farm Tempizque:

The information concerning the lagoons given in the PDD is not correct and com-plete:

According to Form B the Information concerning the lagoons is different than in the PDD.

Corrective Action Request No.3: Farm Nopalera Sitio 3 or Granja Nopalera:


The printout of the inventory of the farmer (note: the number of animals is almost identical with the number given for the different months in the PDD) shows only piglets (“lechones”) not fin-ishers (hembras, machos). This should



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be checked. According to Form B the Information con-cerning the lagoons is different than in the PDD.

Corrective Action Request No.4: Farm Longaniza Sitio 1 or Granja Lon-ganiza (please check the correct name):

The information concerning the lagoons given in the PDD is not correct and com-plete.

Furthermore the farm has only 6 con-tainment areas.

Corrective Action Request No.5: Farm La Loma Sitio 3 or Granja Loma (please also check the correct name of this farm):


According to the information given by the farmer during the on-site audits the farm



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has only 7 lagoons (3 primary and 4 sec-ondary; there is no tertiary lagoon).

Corrective Action Request No.6: Farm Granja 7 or Granja Ocotillo (in the printout of the farms inventory) - please check the correct name, too:


Please also explain: What does this mean for the dimensioning of the biodi-gester.

According to Form B the Information con-cerning the lagoons is different than in the PDD.

Corrective Action Request No.7: Farm Granja 4:


According to Form B the Information



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concerning the lagoons is different than in the PDD.

Corrective Action Request No.8: Farm El Sauz (or Granja Sauz – please check this):


Corrective Action Request No.9: Farm Granja Capadero Sitio 3 or El Ca-padero – please check the correct name:


According to the information given by the farmer during the on-site audits the farm uses for its waste manage-ment system 3 primary and 3 secon-dary lagoons (they have no tertiary lagoon) and also 15 containers.



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Corrective Action Request No.10: Farm Corral Falso:


The containers are cleaned daily.

For Corral Falso, according to PDD are 11 lagoons, according Form B only 3 with different dimensions and according to file “mx-fp-Corral Falso.pdf” there are only 9 lagoons including the biodigester, additionally here it is possible that not all the manure drain to the biodigester.

Corrective Action Request No.11: Farm La Autopista Sitio 3 or Granja Autopista: – please check the correct name:

The information concerning the lagoons given in the PDD is not correct and com-plete in total:

According to the information given by the farmer during the on-site audits the farm uses for its waste management system 1



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primary, 3 secondary lagoons and also 3 containers.

The containers are cleaned every 4 – 5 days.

Compendium (CAR 1-11, CR 1-3):

As there are some discrepancies for several (of the visited) farms between the information given by the farmers during the on-site visits (audits) and the information stated in the PDD and further submitted documents the fol-lowing information should be added (with written official confirmation by the farmers) as separate annex to the PDD:

• Number of lagoons (currently and in future) and number of contain-ers

• Number of biodigesters

• Dimensions of the lagoons and containers

• Operation of the la-goons/containers



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• Some of the addresses and farm names have to be adjusted

• Number of animals.

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

1-3, 9,

10, 15

DR, I

See comments in A.1.1.

The projects components in general are clearly defined in the PDD and described in figure B1 of the PDD. During the visit on site the given information has been confirmed in the main.

But see comments in A.1.1.

See CAR 1-11

CR 1-3

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 cur-rent good practices?

1-3, 5-10, 14, 26

DR, I

Yes, the project design seems to reflect current good practice. The design has been professionally developed.

Corrective Action Request No.12: Currently the design and the underlying calculations for dimensioning the size of

CAR 12



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the biodigester systems in order to fit the size of the farm are not available for all farms. This information should be submit-ted to the validator with the revised PDD. The calculations also should take into account the CRs, CARs stated above.

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?

1-3, 5-7, 9,

10, 26

DR, I

Yes, the project does apply state of the art equipment.

A.2.3. Is the project technology likely to be substituted by other or more efficient technologies within the project period?

1-3, 9

DR, I

No, the project equipment can be ex-pected to run for the whole project credit-ing period of 10 years and it can not be expected that it will be replaced by more efficient technologies.

A.2.4. Does the project require extensive initial training and maintenance efforts in order to work as presumed during the project period?

1-3, 11

DR, I

Yes, initial training and maintenance ef-forts are required. In the PDD and during the visit on site the project developer confirmed that such trainings already are envisaged (after finalising all installa-tions). In annex 6 to the PDD a “PROVI-SIONAL SCHEDULE” for the trainings is stated. But no written documentation on executed or still planned concrete train-ing activities has been submitted.

CR 4



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Clarification Request No. 4: Some of the local responsible persons for the farms had not received any con-crete information about the project until the day of the on-site audits. They also did not know about planned trainings and their responsibilities in the project.

Thus the respective documentation/ con-crete date of planned or meanwhile al-ready conducted trainings/information events should be submitted to the valida-tion team with the revised PDD (ideally the written confirmation of participation in the trainings should be added to annex 6).

A.2.5. Does the project make provisions for meeting training and maintenance needs?

1-3, 11

DR, I

See comment A.2.4. See CR 4

A.3. Contribution to Sustainable Development The project’s contribution to sustainable development is assessed.

A.3.1. Is the project in line with relevant legislation and plans in the host country?

1-4, 23, 24

DR, I

The project is in line with the relevant legislation and plans in the host country regarding sustainable development is-



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sues.

A.3.2. Is the project in line with host-country specific CDM requirements?

1-3, 23

DR, I

No CDM specific host country require-ments exist in Mexico.

A.3.3. Is the project in line with sustainable develop-ment policies of the host country?

1-3, 23, 24

DR, I

The question can be positively answered as the issuance of the Letter of Approval by the Mexican DNA documents the positive view of the government on this project.

A.3.4. Will the project create other environmental or social benefits than GHG emission reductions?

1-3, 24

DR, I

Yes. It can be expected that the project will create additional environmental benefits by reducing emissions of Volatile Organics Compounds (VOCs).

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 appropri-ate baseline methodology.

B.1.1. Is the baseline methodology previously ap-proved by the CDM Methodology Panel?

1-3, 17

DR, I

Yes, the project is based on the ap-proved baseline methodology: AM0016 “Greenhouse gas mitigation from im-proved Animal Waste Management Sys-



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tems in confined animal feeding opera-tions”. The methodology has been ap-proved by the CDM Executive Board at its 16th meeting in October 2004.

B.1.2. Is the baseline methodology the one deemed most applicable for this project and is the ap-propriateness justified?

1-3, 5,

17, 26

DR, I

The selected methodology has been de-signed for this type of projects. Therefore the respective baseline methodology is deemed to be the most applicable one for this project. The PDD responds con-vincingly to each of the applicability crite-ria which are outlined in the baseline methodology.

The criteria are fulfilled as follows:

• The captured gas flared or used to produce energy but no emis-sion reductions are claimed for displacing or avoiding energy from other sources.

• The proposed project activity manages livestock populations under confined conditions in a competitive market

• The proposed project activity comprises swine populations

• The AWMS – in the baseline as

CR 5



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well as in the project scenario – are in accordance with the regula-tory framework of Mexico and are excluding the discharge of ma-nure into natural water resources.

The project activity introduces AWMS practices and technology change with the purpose to reduce GHG emissions.

Clarification Request No. 5: All farms are in line with the regulations set by SEMADES (Secretaria de Medio Ambiente para el Desarrollo Sustenable). SEMADES is a local authority in Jalisco. Thus the farm owners are allowed to op-erate their local pig farms and to imple-ment the project.

Nevertheless there is one Point in the SEMADES license which should be clari-fied. Point 5 appoints that it is not al-lowed to burn/flare any kind or residue.

It should be made clear that this does not mean that it is forbidden to flare the methane.



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B.2. Baseline Determination The choice of baseline will be validated with focus on whether the baseline is a likely scenario, whether the project itself is not a likely baseline scenario, and whether the baseline is complete and transparent.

B.2.1. Is the application of the methodology and the discussion and determination of the chosen baseline transparent?

1-3, 8, 9, 17

DR, I

Yes, the application of the methodology and the discussion and determination of the baseline are transparent. The appli-cation follows exactly each of the steps outlined in the methodology and answers the corresponding sections in a proper manner.

Clarification Request No. 6: To assure that all the sites qualify for the baseline scenario the following parame-ters should be reported correctly to the audit team (in the revised PDD and/or additional submitted documents):

• Retention times

• Size of the lagoons

• Number of containers used in the AWMS and operation of these containers

CR 6



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• Type of manure disposal (lagoon, canal etc.)

• Intervals for manure extraction from lagoons and

• field application

• number / size of biodigesters for all sites.

This required additional information al-ready was submitted to the auditor ver-bally during the on-site audits but the in-formation should be added to the PDD in a completed separate annex (taking into account the required clarifications, cor-rections, comments above).

B.2.2. Has the baseline been determined using con-servative assumptions where possible?

1-3, 5-8, 17, 26

DR, I

The calculations are conservative for al-most all farms. But it cannot be con-firmed finally that the calculation is con-servative in total (see also comments given above).

Corrective Action Request No.13: As result of the CARs (1-11) given under A.1.1 the data for few of the farms (num-ber of animals, number of lagoons, num-

CAR 13 CAR 14



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ber of biodigesters and design of the biodigesters) have to be adjusted

In case of the farms Tlacoyote II and El Tempizque the given numbers of animals (as print-out of the monthly inventory) have been lower than stated in the PDD.

This should be checked and the data should be corrected, if necessary, to de-monstrate that all calculations are con-servative.

Corrective Action Request No.14: The envisaged time schedule for the pro-ject - date for the finishing of all construc-tions, flare operational at all sites is Oc-tober) could not be confirmed for all sites during the on-site audits. At some of the farms even the construction of the biodi-gesters was not started in early October 2005.

So it cannot be confirmed currently that all installations will be finished until No-vember 1st, 2005 (starting date of the crediting period).

This will influence the calculated emis-



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sion reductions and so it cannot be con-firmed currently that the assumptions used are conservative.

Evidence that all installations are already finished now (October 21st, 2005) or will be finished until November 1st, 2005 has to be submitted to the validator.

B.2.3. Has the baseline been established on a project-specific basis?

1-3, 8, 17

DR, I

Yes, the baseline has been based on project specific data.

B.2.4. Does the baseline scenario sufficiently take into account relevant national and/or sectoral poli-cies, macro-economic trends and political aspi-rations?

1-3, 17, 23, 24

DR, I

Yes, the baseline scenario sufficiently takes into account the respective trends. There is no legal requirement to capture and combust greenhouse gases pro-duced by swine manure in AWMS. There is currently also no planned legislation that is directed towards the emission of GHG as related to AWMS. The open air lagoon is hence considered the common AWMS practice in Mexico.

B.2.5. Is the baseline determination compatible with the available data?

1-3, 5, 8, 17, 19, 26

DR, I

Yes with the exceptions mentioned in the CRs, CARs above.

B.2.6. Does the selected baseline represent the most likely scenario among other possible and/or dis-

1-3, 7,

DR, I

Yes, it has been made plausible that the chosen baseline scenario is the one



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cussed scenarios? 17, 21

deemed most realistic under the given frame conditions.

B.2.7. Is it demonstrated/justified that the project activ-ity itself is not a likely baseline scenario (e.g. through (a) a flow-chart or series of questions that lead to a narrowing of potential baseline op-tions, (b) a qualitative or quantitative assess-ment of different potential options and an indica-tion of why the non-project option is more likely, (c) a qualitative or quantitative assessment of one or more barriers facing the proposed project activity or (d) an indication that the project type is not common practice in the proposed area of implementation, and not required by a Party’s legislation/regulations)?

1-3, 7,

17, 21, 25

DR, I

In principal, yes (Annexes to the PDD submitted via a CD on September 02nd, 2005). The economic analysis compared Net Present Value parameters; and demonstrates that the project activity is not the most economical attractive course of action.

But currently the information is only available for one site (Valles). Further-more the CARs, CRs (see above) have to be taken into account in developing the site-specific financial analysis.

Clarification Request No. 7: Site-specific information regarding the economic comparison and its underlying financial data has to be submitted to the validator to demonstrate the additionality pf the project.

Clarification Request No. 8: Additionally an independent expert opin-ion confirming the correctness of the final

CR 7 CR 8



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financial data has to be submitted.

B.2.8. Have the major risks to the baseline been identi-fied?

1-3, 8,

DR, I

Yes.

B.2.9. Is all literature and sources clearly referenced? 1-3, 17-22

DR, I

Yes, under the precondition that the re-quired CARs, CRs can be solved.

C. Duration of the Project/ Crediting Period It is assessed whether the temporary boundaries of the pro-ject are clearly defined.

C.1.1. Are the project’s starting date and operational lifetime clearly defined and reasonable?

1-3 DR, I

Yes. The starting date is May 2nd, 2005 and it was confirmed during the on-site audits.

Clarification Request No. 9: Further information concerning the ex-pected operational lifetime (21 years, much longer than in prior projects) should be submitted to the validation team (for example a written guarantee of the supplier(s) of the equipment(s) – bio-digester, flare).

CR 9

C.1.2. Is the assumed crediting time clearly defined and reasonable (renewable crediting period of max. two x 7 years or fixed crediting period of

1-3 DR, I

Yes. The length of the crediting period for this project is 10 years.



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max. 10 years)?

D. 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 ((Blue text contains requirements to be assessed for op-tional review of monitoring methodology prior to submission and approval by CDM EB).

D.1. Monitoring Methodology It is assessed whether the project applies an appro-priate baseline methodology.

D.1.1. Is the monitoring methodology previously ap-proved by the CDM Methodology Panel?

1-3, 18

DR, I

Yes, the project is based on an approved monitoring methodology AM0016 “Greenhouse gas mitigation from im-proved Animal Waste Management Sys-tems in confined animal feeding opera-tions”. The methodology has been ap-proved by the CDM Executive Board at its 16th meeting in October 2004.

D.1.2. Is the monitoring methodology applicable for this project and is the appropriateness justified?

1-3, 9, 18

DR, I

The selected methodology has been de-signed for this type pf projects. Therefore the respective monitoring methodology is deemed to be the most applicable one for this project. The PDD responds con-vincingly to each of the applicability crite-



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ria which are outlined in the monitoring methodology. The criteria are fulfilled as follows:

• The captured gas flared or used to produce energy but no emis-sion reductions are claimed for displacing or avoiding energy from other sources.

• The proposed project activity manages livestock populations under confined conditions in a competitive market

• The proposed project activity comprises swine populations

• The AWMS – in the baseline as well as in the project scenario – are in accordance with the regula-tory framework of Mexico and are excluding the discharge of ma-nure into natural water resources.

The project activity introduces AWMS practices and technology change with the purpose to reduce GHG emissions.

D.1.3. Does the monitoring methodology reflect good monitoring and reporting practices?

1-3, 18

DR, I

Yes.



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D.1.4. Is the discussion and selection of the monitoring methodology transparent?

1-3, 18

DR, I

Yes.

D.2. Monitoring of Project Emissions It is established whether the monitoring plan provides for reliable and complete project emission data over time.

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

1-3, 18

DR, I

Yes, the monitoring plan does include all relevant parameters to determine project emissions. Due to the choice made re-garding the monitoring approach only the relevant parameters have been selected.

D.2.2. Are the choices of project GHG indicators rea-sonable?

1-3, 18-22

DR, I

Yes. Due to the choice made regarding the monitoring approach only the rele-vant parameters have been selected.

D.2.3. Will it be possible to monitor / measure the specified project GHG indicators?

1-3, 18-22

DR, I

Yes, it is possible to monitor and/or measure the currently specified GHG indicators. The indicators which are not measured can be obtained from IPCC documents.

Clarification Request No. 10: According to the information on-site not all farms use an electronic data man-agement system (for example Pig Champ). It should explained for all sites

CR 10



Final Concl

how the required data are acquired, how the date are collected and stored, which data are used for the calculations (Pig Champ data, manual data)) and ex-plained how the data is transferred to the data management system of AgCert.

D.2.4. Will the indicators give opportunity for real measurements of achieved emission reduc-tions?

1-3, 18-22

DR, I

The parameters defined for the monitor-ing allow the calculation of the project emissions in a proper manner.

D.2.5. Will the indicators enable comparison of project data and performance over time?

1-3, 8,

18-22

DR, I

Yes, all data will be recorded on a regu-lar basis and stored until the end of the crediting period hence allowing a com-parison of project data and performance over time.

D.3. Monitoring of Leakage It is assessed whether the monitoring plan provides for reliable and complete leakage data over time.

D.3.1. Does the monitoring plan provide for the collection and archiving of all relevant data necessary for determining leakage?

1-3, 18

DR, I

Yes.

D.3.2. Have relevant indicators for GHG leakage been included?

1-3, 18-22

DR, I

Yes, all relevant parameters have been included. A leakage effect is not to be expected. But as electrical power will be used by the project activity, the respec-tive parameters are monitored and in-



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cluded in the monitoring plan. Other po-tential leakage effects have been evalu-ated and it has been demonstrated that these effects do not apply to this specific project.

D.3.3. Does the monitoring plan provide for the collec-tion and archiving of all relevant data necessary for determining leakage?

1-3, 18-22

DR, I

Yes, respective parameters are included in the monitoring plan.

D.3.4. Will it be possible to monitor the specified GHG leakage indicators?

1-3, 18-22

DR, I

Yes, it is possible to monitor and/or measure the currently specified GHG indicators.

D.4. Monitoring of Baseline Emissions It is established whether the monitoring plan provides for reliable and complete project emission data over time.

D.4.1. Does the monitoring plan provide for the collec-tion and archiving of all relevant data necessary for determining baseline emissions during the crediting period?

1-3, 8, 18

DR, I

Yes, the monitoring plan does include all relevant parameters to determine project emissions. Due to the choice made re-garding the monitoring approach only the relevant parameters have been selected.

D.4.2. Is the choice of baseline indicators, in particular for baseline emissions, reasonable?

1-3, 8, 18

DR, I

Yes. Due to the choice made regarding the monitoring approach only the rele-vant parameters have been selected.

D.4.3. Will it be possible to monitor the specified base- 1-3, DR, Yes, it is possible to monitor and/or



Final Concl

line indicators? 18 I measure the currently specified GHG indicators. The indicators which are not measured can be obtained from IPCC documents.

D.5. Monitoring of Sustainable Development Indicators/ Environmental Impacts

It is checked that choices of indicators are reason-able and complete to monitor sustainable perform-ance over time.

D.5.1. Does the monitoring plan provide the collection and archiving of relevant data concerning envi-ronmental, social and economic impacts?

1-3, 18, 24

DR, I

No. The project is considered to have no negative environmental, social and eco-nomic effects and a monitoring of such data is also not required by the applied monitoring methodology. This approach is deemed sufficient.

D.5.2. Is the choice of indicators for sustainability de-velopment (social, environmental, economic) reasonable?

1-3, 18, 24

DR, I

No choice has been made. See comment D.5.1

D.5.3. Will it be possible to monitor the specified sus-tainable development indicators?

1-3, 18, 24

DR, I

See comment D.5.1

D.5.4. Are the sustainable development indicators in line with stated national priorities in the Host Country?

1-3, 18, 24

DR, I

See comment D.5.1



Final Concl

D.6. Project Management Planning It is checked that project implementation is properly prepared for and that critical arrangements are ad-dressed.

D.6.1. Is the authority and responsibility of project management clearly described?

1-3, 11, 13, 14, 16

DR, I

The authority and responsibility with re-spect to operation of the biodigester are described in the operations and mainte-nance manual, but the overall CDM re-lated responsibilities (names of the re-sponsible persons) are not clearly indi-cated. Additional information was submit-ted during the on-site audit.

Clarification Request No. 11: The respective information concerning responsibilities are not clearly define in the PDD (in annex 9, please concretise the project responsibilities). The opera-tions and maintenance manual is only in English available. Please assure that all the participants are able to understand the necessary work instructions.

CR 11

D.6.2. Is the authority and responsibility for registra-tion, monitoring, measurement and reporting clearly described?

1-3, 11, 13, 14,

DR, I

See comment D.6.1

See CR 11



Final Concl

16

D.6.3. Are procedures identified for training of monitor-ing personnel?

1-3, 16

DR, I

Procedures are described in the opera-tions and maintenance manual.

D.6.4. Are procedures identified for emergency pre-paredness for cases where emergencies can cause unintended emissions?

1-3, 16

DR, I


D.6.5. Are procedures identified for calibration of moni-toring equipment?

1-3, 16

DR, I

Clarification Request No. 12: The issue of calibration of monitoring equipment and maintenance is handled rather general in the operations and maintenance manual. It should be speci-fied how calibration takes places, by whom, according to which national regu-lation and how often.

CR 12

D.6.6. Are procedures identified for maintenance of monitoring equipment and installations?

1-3, 16

DR, I

The maintenance of monitoring equip-ment will be performed by the project participants itself and the companies providing the respective installations. The Operations and Maintenance Manual de-scribes in chapter 4.2 and 6 the respec-tive procedures for each relevant project component.

D.6.7. Are procedures identified for monitoring, meas-urements and reporting?

1-3, 16

DR, I


D.6.8. Are procedures identified for day-to-day records 1-3, DR, Clarification Request No. 13: CR 13



Final Concl

handling (including what records to keep, stor-age area of records and how to process per-formance documentation)

16 I It needs to be made clear (in the PDD) whether the record storage is handled by the single farms themselves or by Ag-Cert.

D.6.9. Are procedures identified for dealing with possi-ble monitoring data adjustments and uncertain-ties?

1-3, 16

DR, I

Yes, crosschecks performed will allow identifying all necessary data adjust-ments.

D.6.10. Are procedures identified for review of reported results/data?

1-3, 16

DR, I

This issue is not clearly addressed and described in the PDD and corresponding documents.

Clarification Request No. 14: The process of monitoring supervision, reviewing and internal auditing as well as taking corrective actions should be de-scribed more detailed.

CR 14

D.6.11. Are procedures identified for internal audits of GHG project compliance with operational re-quirements where applicable?

1-3, 16

DR, I

See D.6.10 See CR 14

D.6.12. Are procedures identified for project perform-ance reviews before data is submitted for verifi-cation, internally or externally?

1-3, 16

DR, I

See D.6.10

See CR 14



Final Concl

D.6.13. Are procedures identified for corrective actions in order to provide for more accurate future monitoring and reporting?

1-3, 16

DR, I

See D.6.10 See CR 14

E. 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.

E.1. Predicted Project GHG Emissions The validation of predicted project GHG emissions fo-

cuses on transparency and completeness of calcula-tions.

E.1.1. Are all aspects related to direct and indirect GHG emissions captured in the project design?

1-3, 5, 8, 9, 26

DR, I

Yes. The required information/respective calculations are available in annex 3 to the PDD.

E.1.2. Are the GHG calculations documented in a complete and transparent manner?

1-3, 5, 26

DR, I

Yes, under the pre-condition that all re-quired clarifications and corrective action requests will be solved.

See E.1.1

E.1.3. Have conservative assumptions been used to calculate project GHG emissions?

1-3, 5, 8, 9, 26

DR, I

See E.1.1

E.1.4. Are uncertainties in the GHG emissions esti-mates properly addressed in the documenta-

1-3, DR, See E.1.1



Final Concl

tion? 5, 26 I E.1.5. Have all relevant greenhouse gases and source

categories listed in Kyoto Protocol Annex A been evaluated?

1-3, 5, 26

DR, I

See E.1.1

E.2. Leakage It is assessed whether there leakage effects, i.e. change of emissions which occurs outside the pro-ject boundary and which are measurable and attrib-utable to the project, have been properly assessed.

E.2.1. Are potential leakage effects beyond the chosen project boundaries properly identified?

1-3, 5, 26

DR, I

Yes.

E.2.2. Have these leakage effects been properly ac-counted for in calculations?

1-3, 5, 26

DR, I

Yes.

E.2.3. Does the methodology for calculating leakage comply with existing good practice?

1-3, 5, 26

DR, I

See E.2.1

E.2.4. Are the calculations documented in a complete and transparent manner?

1-3, 5, 26

DR, I

See E.2.1

E.2.5. Have conservative assumptions been used when calculating leakage?

1-3, 5, 26

DR, I

See E.2.1

E.2.6. Are uncertainties in the leakage estimates prop-erly addressed?

1-3, 5, 26

DR, I

See E.2.1



Final Concl

E.3. Baseline Emissions The validation of predicted baseline GHG emissions focuses on transparency and completeness of calcu-lations.

E.3.1. Have the most relevant and likely operational characteristics and baseline indicators been chosen as reference for baseline emissions?

1-3, 19

DR, I

Yes. The required information/respective calculations are available in annex 3 to the PDD.

E.3.2. Are the baseline boundaries clearly defined and do they sufficiently cover sources and sinks for baseline emissions?

1-3, 5, 8, 9, 26

DR, I

See E.1.1

E.3.3. Are the GHG calculations documented in a complete and transparent manner?

1-3, 5, 8, 9, 26

DR, I

See E.1.1

E.3.4. Have conservative assumptions been used when calculating baseline emissions?

1-3, 5, 8, 9, 26

DR, I

See E.1.1

E.3.5. Are uncertainties in the GHG emission esti-mates properly addressed in the documenta-tion?

1-3, 5, 8, 9, 26

DR, I

See E.1.1

E.3.6. Have the project baseline(s) and the project emissions been determined using the same ap-propriate methodology and conservative as-sumptions?

1-3, 5, 8, 9, 26

DR, I

See E.1.1



Final Concl

E.4. Emission Reductions Validation of baseline GHG emissions will focus on methodology transparency and completeness in emis-sion estimations.

E.4.1. Will the project result in fewer GHG emissions than the baseline scenario?

1-3, 5, 26

DR, I

Yes, in general this is the case but no project specific information has been submitted including the necessary calcu-lations. See various other chapters.

F. Environmental Impacts Documentation on the analysis of the environmental im-pacts will be assessed, and if deemed significant, an EIA should be provided to the validator.

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

1-3, 24

DR, I

A brief study is included in the PDD.

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

1-3, 24

DR, I

An official letter was submitted to the pro-ject owner by the Mexican DNA in which the DNA confirms that no EIA is required for this type of project.

F.1.3. Will the project create any adverse environ-mental effects?

1-3, 24

DR, I

No, negative environmental effects are not expected to be created by the pro-ject. Given the nature of the project de-sign this seems to be reasonable.



Final Concl

F.1.4. Are transboundary environmental impacts con-sidered in the analysis?

1-3, 24

DR, I

No, but as the project site is far from the national boundary, such effects are not expected.

F.1.5. Have identified environmental impacts been ad-dressed in the project design?

1-3, 24

DR, I

As no significant environmental impacts are expected, such impacts have not in-fluenced the project design.

F.1.6. Does the project comply with environmental leg-islation in the host country?

1-3, 24

DR, I

See chapter F.1.2

G. Stakeholder Comments The validator should ensure that a stakeholder com-ments have been invited and that due account has been taken of any comments received.

G.1.1. Have relevant stakeholders been consulted? 1-3, 12

DR, I

As far as required neighbours have been consulted and informed and given an opportunity to comment on the project.

G.1.2. Have appropriate media been used to invite comments by local stakeholders?

1-3, 12

DR, I

See comment above.

G.1.3. If a stakeholder consultation process is required by regulations/laws in the host country, has the stakeholder consultation process been carried out in accordance with such regulations/laws?

1-3, 12

DR, I

Not required

G.1.4. Is a summary of the stakeholder comments re-ceived provided?

1-3, 12

DR, I

Yes. The invitation letter, the announce-ment in the newspaper, the meeting min-utes and the participants list have been



Final Concl

submitted to the audit team and are at-tached to the PDD as annex 8.

G.1.5. Has due account been taken of any stakeholder comments received?

1-3, 12

DR, I

No action has been undertaken as all comment received so far have been posi-tive.


Table 3 Resolution of Corrective Action and Clarification Requests Draft report clarifications and corrective action requests by validation team

Ref. to checklist question in table 1 and 2

Summary of project owner response Validation team conclusion

Clarification Request No. 1: For all farms in this project the information concerning the configuration of the lagoons (size, depth, operation of the current (and fu-ture) lagoon system) is missing in the PDD and further submitted documents. This infor-mation should be submitted to the validator as the qualification of all farms for this type of CDM project and for using AM0016 has to be demonstrated.

According to Form B for some Sites the In-formation concerning the lagoons is different than in the PDD.

A.1.1. CR1 – Information added to site de-scriptions in the updated PDD.

Due to revisions & updates, many Form B’s no longer contain accurate data. However, AgCert’s Supplier Manage-ment System (SMS) has been updated and contains the most current informa-tion. PDD updated based on the infor-mation in the SMS. Table B1 of the PDD reflects the correct quantity of la-goons.

Clarification Request No. 2: This project is also, as the Project MX05-B-05, located in the state of Jalisco. Even the owner and the local city (Acatic) are the same as in some of the MX-B-05. To avoid confu-sions and mix-ups of farms in these two pro-jects the correct addresses not only for the central office but also for each farm including the correct GPS-coordinates have to be

A.1.1. CR2 – Owners are not the same be-tween the 2 PDDs. Address informa-tion has been updated in the PDD.

Available GPS coordinates have been included in the PDD.


Draft report clarifications and corrective action requests by validation team



submitted to the validator (ideally included in the PDD).

To illustrate this: There are for example neighboured farms, La Loma Sitio 3 (this farm is part of project MX05-B-06) and La Loma Sitio 1 (this farm is part of project MX05-B-05) which are not included in the same project and could be mixed up in future.

Furthermore correct and identical farm names should appear in all project docu-ments (for example there are names as Granja Capadero 2, Granja El Capadero 2, El Capadero 2 etc. in different documents – this should be excluded). Especially the names in the contracts (annex 1, form A) should corre-spond with the names in Annex 7 (licenses and permits) and in the annexes with calcula-tions and economic analysis). Clarification Request No. 3: In this project Farms besides the lagoons also containers are used in the AWMS (ani-mal waste management system). The func-tion and the operation of these containers should be explained and there influence/or

A.1.1. CR3 – These containers are classified as flush tanks and have no effect on emissions or subsequent calculations.





the not existing influence on the methane production. In which way will these containers be used in the project case with the biodi-gester?

Corrective Action Request No.1: Farms Tlacoyote 2 Sitio 1 and Tlacoyote Sitio 3:

According to the information given by the farmer during the on-site visit the farm Tla-coyote 2 Sitio 1 uses (has) only 1 primary la-goon and not three as stated in the PDD. Fur-thermore two containers are used. Also only two and not seven containment areas exist.

The same confusion is with the farm Tla-coyote Sitio 3.

So for these two farms the number (and type) of the lagoons and containment areas has to be corrected. The operation of the containers (baseline case and project case) has to be explained.

According to Form B the Information concern-ing the lagoons is different than in the PDD.

A.1.1. CAR1 – PDD correctly indicates 2 con-tainment areas. Number of lagoons has been updated in the PDD.






Corrective Action Request No.2: Farm Tempizque:

The information concerning the lagoons given in the PDD is not correct and complete:


A.1.1. CAR2 – PDD has been updated to re-flect correct information.


Corrective Action Request No.3: Farm Nopalera Sitio 3 or Granja Nopalera:


The printout of the inventory of the farmer (note: the number of animals is almost identi-cal with the number given for the different months in the PDD) shows only piglets (“lechones”) not finishers (hembras, machos). This should be checked. According to Form B the Information con-

A.1.1. CAR3 – PDD has been updated to re-flect correct information. AgCert as-sessor confirmed this site contains only finishers. NOTE. In Mexico, Sitio 3 is the name convention that indicates the farm is a finisher operation.

Due to revisions & updates, many Form B’s no longer contain accurate data. However, AgCert’s Supplier Manage-ment System (SMS) has been updated and contains the most current informa-tion. PDD updated based on the infor-mation in the SMS. Table B1 of the





cerning the lagoons is different than in the PDD.

PDD reflects the correct quantity of la-goons.

Corrective Action Request No.4: Farm Longaniza Sitio 1 or Granja Longaniza (please check the correct name):

The information concerning the lagoons given in the PDD is not correct and complete.

Furthermore the farm has only 6 containment areas.

A.1.1. CAR4 – The correct name is Longaniza Sitio 1 and information updated in the PDD.

Corrective Action Request No.5: Farm La Loma Sitio 3 or Granja Loma (please also check the correct name of this farm):


According to the information given by the farmer during the on-site audits the farm has only 7 lagoons (3 primary and 4 secondary; there is no tertiary lagoon).

A.1.1. CAR5 - The correct name is La Loma Sitio 3 and information updated in the PDD.

Corrective Action Request No.6: Farm Granja 7 or Granja Ocotillo (in the

A.1.1. CAR6 - Granja Ocotillo is the correct name. Correct lagoon information has





printout of the farms inventory) - please check the correct name, too:


Please also explain: What does this mean for the dimensioning of the biodigester.


been updated in the PDD. Dimension-ing is based on animal capacity and amount of water used to flush the barns.


Corrective Action Request No.7: Farm Granja 4:


According to Form B the Information concern-ing the lagoons is different than in the PDD.

A.1.1. CAR7 –Information updated in the PDD.






Corrective Action Request No.8: Farm El Sauz (or Granja Sauz – please check this):


A.1.1. CAR8 - Granja El Sauz is the correct name. Information updated in the PDD.

Corrective Action Request No.9: Farm Granja Capadero Sitio 3 or El Ca-padero – please check the correct name:


According to the information given by the farmer during the on-site audits the farm uses for its waste management system 3 primary and 3 secondary lagoons (they have no terti-ary lagoon) and also 15 containers.

A.1.1. CAR9 - Granja Capadero Sitio 3 is the correct name. Correct lagoon informa-tion has been updated in the PDD.

Corrective Action Request No.10: Farm Corral Falso:


The containers are cleaned daily.

A.1.1. CAR10 – PDD updated to include the correct information. Corral Falso origi-nally had 12 lagoons each measuring 40m x 40m x 5m but the digester was built on one of the lagoons so now there are 11 existing lagoons. There are 11 containment areas and one that





For Corral Falso, according to PDD are 11 lagoons, according Form B only 3 with differ-ent dimensions and according to file “mx-fp-Corral Falso.pdf” there are only 9 lagoons including the biodigester, additionally here it is possible that not all the manure drain to the biodigester.

is currently under construction. These containment areas are cleaned daily.

Due to revisions & updates, many Form B’s no longer contain accurate data. However, AgCert’s Supplier Manage-ment System (SMS) has been updated and contains the most current informa-tion. PDD updated based on the infor-mation in the SMS. Table B1 of the PDD reflects the correct quantity of la-goons. File “mx-fp-Corral Falso.pdf” is for illustration purposes only. ALL ma-nure flows to the biodigester. The re-maining lagoons (3) are no longer in use.

Corrective Action Request No.11: Farm La Autopista Sitio 3 or Granja Autop-ista: – please check the correct name:

The information concerning the lagoons given in the PDD is not correct and complete in total:

According to the information given by the farmer during the on-site audits the farm

A.1.1. CAR11 - La Autopista Sitio 3 is the cor-rect name and has four lagoons each measuring approx. 30m x 30m x 6m. The farm has 3 containment areas. PDD updated to include correct infor-mation.





uses for its waste management system 1 primary, 3 secondary lagoons and also 3 containers.

The containers are cleaned every 4 – 5 days.

Compendium (CAR 1-11, CR 1-3): As there are some discrepancies for sev-eral (of the visited) farms between the in-formation given by the farmers during the on-site visits (audits) and the information stated in the PDD and further submitted documents the following information should be added (with written official con-firmation by the farmers) as separate an-nex to the PDD:

• Number of lagoons (currently and in future) and number of containers

• Number of biodigesters

• Dimensions of the lagoons and con-tainers

• Operation of the lagoons/containers

Compendium - Revised PDD and ac-companying support documentation address these concerns.





• Some of the addresses and farm names have to be adjusted

• Number of animals.

Corrective Action Request No.12: Currently the design and the underlying cal-culations for dimensioning the size of the bio-digester systems in order to fit the size of the farm are not available for all farms. This in-formation should be submitted to the validator with the revised PDD. The calculations also should take into account the CRs, CARs stated above.

A.2.1. CAR12 - Information has been posted to the AgCert support documentation CD. Please refer to the volume calcula-tor on the supporting documents CD. (also sent via Email).

Clarification Request No. 4: Some of the local responsible persons for the farms had not received any concrete informa-tion about the project until the day of the on-site audits. They also did not know about planned trainings and their responsibilities in the project.

Thus the respective documentation/ concrete date of planned or meanwhile already con-ducted trainings/information events should be submitted to the validation team with the re-

A.2.4. A.2.5.

CR4 - Normally training is based on construction completion. Training schedule has been posted to the sup-porting documents CD. If actual training is conducted, attendance sheets are also posted to the AgCert support documentation CD.





vised PDD (ideally the written confirmation of participation in the trainings should be added to annex 6). Clarification Request No. 5: All farms are in line with the regulations set by SEMADES (Secretaria de Medio Ambi-ente para el Desarrollo Sustenable). SE-MADES is a local authority in Jalisco. Thus the farm owners are allowed to operate their local pig farms and to implement the project.

Nevertheless there is one Point in the SE-MADES license which should be clarified. Point 5 appoints that it is not allowed to burn/flare any kind or residue.

It should be made clear that this does not mean that it is forbidden to flare the methane.

B.1.2.

CR5 – Residue, in this case, refers to agricultural materials (e.g., rice, corn husks, etc.) and not the biogas pro-duced by these materials.

Clarification Request No. 6: To assure that all the sites qualify for the baseline scenario the following parameters should be reported correctly to the audit team (in the revised PDD and/or additional submit-ted documents):

B.2.1.

CR6 - This information is available in the assessment forms (Form B) and can be reviewed on the support docu-mentation CD.





• Retention times

• Size of the lagoons

• Number of containers used in the AWMS and operation of these con-tainers

• Type of manure disposal (lagoon, ca-nal etc.)

• Intervals for manure extraction from lagoons and

• field application

• number / size of biodigesters for all sites.

This required additional information already was submitted to the auditor verbally during the on-site audits but the information should be added to the PDD in a completed sepa-rate annex (taking into account the required clarifications, corrections, comments above).

Corrective Action Request No.13: As result of the CARs (1-11) given under

B.2.2.

CAR13 – All CARs have been address and updated in the PDD.





A.1.1 the data for few of the farms (number of animals, number of lagoons, number of bio-digesters and design of the biodigesters) have to be adjusted

In case of the farms Tlacoyote II and El Tem-pizque the given numbers of animals (as print-out of the monthly inventory) have been lower than stated in the PDD.

This should be checked and the data should be corrected, if necessary, to demonstrate that all calculations are conservative.

PDD has been updated to reflect pro-duction print out.

Corrective Action Request No.14: The envisaged time schedule for the project - date for the finishing of all constructions, flare operational at all sites is October) could not be confirmed for all sites during the on-site audits. At some of the farms even the con-struction of the biodigesters was not started in early October 2005.

So it cannot be confirmed currently that all installations will be finished until November 1st, 2005 (starting date of the crediting pe-riod).

B.2.2. CAR14 – Crediting start date has been adjusted in the PDD.





This will influence the calculated emission reductions and so it cannot be confirmed cur-rently that the assumptions used are conser-vative.

Evidence that all installations are already fin-ished now (October 21st, 2005) or will be fin-ished until November 1st, 2005 has to be submitted to the validator. Clarification Request No. 7: Site-specific information regarding the eco-nomic comparison and its underlying financial data has to be submitted to the validator to demonstrate the additionality pf the project.

B.2.7.

CR7 - Information has been posted to the support documentation CD.

Clarification Request No. 8: Additionally an independent expert opinion confirming the correctness of the final finan-cial data has to be submitted.

B.2.7.

CR8 - Information has been posted to the support documentation CD.

Clarification Request No. 9: Further information concerning the expected operational lifetime (21 years, much longer than in prior projects) should be submitted to the validation team (for example a written guarantee of the supplier(s) of the equip-

C.1.1. CR9 - Operational lifetime has been adjusted in the PDD.





ment(s) – biodigester, flare). Clarification Request No. 10: According to the information on-site not all farms use an electronic data management system (for example Pig Champ). It should explained for all sites how the required data are acquired, how the date are collected and stored, which data are used for the calcula-tions (Pig Champ data, manual data) and ex-plained how the data is transferred to the data management system of AgCert.

D.2.3.

CR10 - Data is collected by the AgCert Regional Maintenance Technician and transferred to AgCert headquarters as stated in section 6.0 of the AgCert O&M Plan.

Clarification Request No. 11: The respective information concerning re-sponsibilities are not clearly define in the PDD (in annex 9, please concretise the pro-ject responsibilities). The operations and maintenance manual is only in English avail-able. Please assure that all the participants are able to understand the necessary work instructions.

D.6.1. D.6.2.

CR11 - Project related responsibilities are described in Annex 9 of the AgCert PDD directory. Spanish translation of the O&M Manual has been posted to the supporting documents CD.

Clarification Request No. 12: The issue of calibration of monitoring equip-ment and maintenance is handled rather general in the operations and maintenance

D.6.5.

CR12 - Calibration is managed in ac-cordance with AgCert Procedure P025 (Control of Monitoring & Measurement Devices). Posted to the Quality, O&M,





manual. It should be specified how calibration takes places, by whom, according to which national regulation and how often.

Component Manuals section of the Ag-Cert PDD directory.

Clarification Request No. 13: It needs to be made clear (in the PDD) whether the record storage is handled by the single farms themselves or by AgCert.

D.6.8.

CR13 - As stated in the O&M Plan, re-cords are collected by the Regional Maintenance Technician. “Paper” cop-ies are maintained in the applicable AgCert “In Country” office. Electronic copies are maintained in the AgCert electronic database.

Clarification Request No. 14: The process of monitoring supervision, re-viewing and internal auditing as well as taking corrective actions should be described more detailed.

D.6.10. D.6.11. D.6.12. D.6.13.

CR14 - Inspection, Auditing, and Cor-rective action procedures can be found in the Quality, O&M, Component Manuals section of the AgCert PDD di-rectory.

final validation protocol 20051130 mx05-b-06 - netinform · conclusion cross reference / comment...

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