Understanding CDM Methodologies - SuSanA

Submission of
further Baseline
Scenarios
Two Requests for
Revision by same
Developer due to
constant Changes
in Baseline
Situation
New Combination
of Accepted
Scenario Elements
Box 45: Issues related to the inclusion of new baseline scenarios
Since the consolidation of ACM0006, several requests for clarification and
revision have been submitted to the MP asking for the inclusion of new baseline
scenarios in ACM0006. Only a handful of these are presented here as examples of
classic requests. “Revision of ACM0006 to reflect a baseline scenario where heat
generation occurs with both biomass and fossil fuels in boilers” 293 was submitted
to the MP requesting the inclusion of a new combined baseline scenario where
electricity generated would be supplied to the grid and heat would come from
a combination of different sources, including a black liquor fired cogeneration
plant, biomass heat boilers, and fossil fuel heat boilers. The MP recognized the
project 294 met the basic eligibility requirements of ACM0006 and recommended
including the new baseline scenario (scenario 16), leading to an EB decision to
revise the methodology accordingly. Interestingly, the same project proponent
later submitted a request for revision 295 after having realized that the combined
baseline scenario it had requested did not apply anymore to the project’s
situation. The proponent explained that heat was diverted to the project plant by
one out of the five existing heat boilers on the project site (either fired by fossil
fuels and/or biomass residues), and requested whether these pre-project boilers
could be co-fired at times even after the implementation of the project activity.
The MP argued that the electricity produced by the new biomass fired plant could
reduce the necessity of using fossil fuel in these existing co-fired boilers, hereby
displacing fossil fuel generated electricity. However, the methodological rationale
of ACM0006 assumes that the increase in energy generation from biomass
residues will contribute to displace fossil fuel generated electricity only from the
grid and not from existing plants on the project site. Based on this premise, the
MP rejected the request.
Another interesting case arose from a request for clarification inquiring whether
two combinations of baseline scenarios could be paired to suit the requirements
of a project with two boilers and one turbo generator 296 . The MP reacted
favorably to the request, arguing that though ACM0006 does not allow the
combination of multiple baseline scenarios, the proposed project proved to be
a rather unique case and that the approach proposed by the project proponent
for monitoring and calculating emissions reductions was appropriate. Because of
the particular character of the project, the MP did not recommend a revision to
ACM006 but rather encouraged the project proponent to request a deviation.
259260261262
259
See AM_CLA_0012
260
For more details about the underlying project, see NM0098 “Nobrecel Fossil-to-Biomass Fuel Switch Project in
Brazil”.
261
See AM_REV_0048
262
See AM_CLA_0042
115