ASSESSMENT OPINION POST REGISTRATION CHANGES Municipality of Montevideo

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1 ASSESSMENT OPINION POST REGISTRATION CHANGES Municipality of Montevideo International Bank for Reconstruction and Development (IBRD) UNFCCC REFERENCE NUMBER: 1349 AENOR Reference No: 2013/018/CDM/09 AENOR. 6 Génova Madrid Spain. Telephone Fax

2 Validation opinion: AENOR Reference No.: Version of this document: Date of this rev.: 2013/018/CDM/ /07/2013 Project: Title: Registration date: UNFCCC Reference Montevideo Landfill Gas Capture and Flare Project 03/02/ Project Participant(s): Host Party: Uruguay Other involved Parties: Kingdom of Spain Applied methodology/ies: Title: Code: No revision Scope: Consolidated baseline and monitoring methodology for landfill gas project activities ACM Consolidated methodology for grid-connected electricity generation from renewable sources ACM PDD: Registered PDD Revised PDD: Version 7 8 Date 13/09/ /07/2013 Estimated emission reductions 201,790 tco 2 /year 111,737 tco 2 /year Previous versions of this document: Version: Date: Validation of the changes was conducted Summary of Post registration changes: Prior to the commencement of a verification of the project activity When performing a verification of the project activity TYPE OF POST REGISTRATION CHANGE Is prior approval by CDM EB required? (According to appendix 1 of PS) Temporary deviations From To Yes No Not applicable Corrections Corrections of the coordinates of the sites of the project, and corrections on ex-ante parameters Changes to the start date of the crediting period Permanent changes from the registered monitoring plan or applied methodology Modification of the monitoring of the flare efficiency. Yes No Not applicable Yes No Not applicable Yes No Not applicable Permanent changes from the registered monitoring plan or applied methodology Change of calibration frequency of thermocouples used to measure Tflare Yes No Not applicable Changes to the project design of a registered project activity Changes in the operational lifetime of the landfill and clarifications on the project boundary. Modification of the capacity of the flaring system. Change in the date of the implementation of the monitoring systems Yes No Not applicable In accordance with paragraph 206 of the CDM Project Standard version 03.0, Project Participants shall identify and document any actual or proposed changes to the operation, implementation and/or monitoring of the registered CDM project activity taking into account the types of changes described in Appendix 1, which describes the types of changes that do not require prior approval by the Board. Page 2 of 24

3 The Spanish Association for Standardisation and Certification (AENOR) was contracted to perform the assessment opinion on the post registration changes of the project Montevideo Landfill Gas Capture and Flare Project (Registration Ref. No. 1349) to submit a request for approval by the Board prior to the first verification of the project, in accordance with requirements of CDM Project Cycle Procedure (Version 03.2). AENOR was contracted to perform the assessment opinion on the post registration changes prior to the commencement of the verification of the project. Report prepared by: Climate Change Unit. AENOR Page 3 of 24

4 Abbreviations AENOR Spanish Association for Standardisation and Certification ACM0001 Consolidated baseline and monitoring methodology for landfill gas project activities CAR Corrective action request CDM Clean development mechanism CDM-EB CDM Executive Board CER Certified emission reduction CL Clarification request CMP Conference of the Parties serving as the Meeting of the Parties to the Kyoto Protocol CO 2 Carbon dioxide CO 2 e Carbon dioxide equivalent DNA Designated national authority DOE Designated operational entity ER Emission reduction FAR Forward action request GHG Greenhouse gas(es) IPCC Intergovernmental Panel on Climate Change LFG Landfill gas MoC Modalities of communication MP Monitoring Plan MR Monitoring Report PCP Clean Development Mechanism Project Cycle Procedure (Version 03.2) PS Clean Development Mechanism Project Standard (Version 03.0) PDD Project Design Document PP Project Participant tc Carbon tonnes tco 2 eq Carbon dioxide equivalent tonnes UNFCCC United Nations Framework Convention on Climate Change VVS CDM Validation and Verification Standard (version 03.0) Page 4 of 24

5 TABLE OF CONTENT 1 Introduction Objective Scope Description of the Project Activity Methodology Appointment of team members and technical reviewers Review of Documentation Site Visits Internal Quality Control Post Registration Changes Temporary deviations from the registered monitoring plan and/or applied methodology Permanent changes. Corrections Permanent Changes from the registered monitoring plan or applied methodology Changes to project design of registered project activity Changes to start date of crediting period Adoption of the VVS PDD format Validation opinion References Annex 1. Appointment certificates Page 5 of 24

6 1 INTRODUCTION The International Bank for Reconstruction and Development (IBRD) as Trustee of the Spanish Carbon Fund (SCF) commissioned AENOR to carry out the assessment of the post registration changes request proposed for the in Uruguay. 1.1 Objective According to the modalities and procedures for the CDM (paragraph 57), project participants may revise monitoring plan in order to improve accuracy and/or completeness of information, subject to the revision being validated by a Designated Operational Entity. In accordance with paragraph 206 of the CDM Project Standard version 03.0, Project participants shall identify and document any actual or proposed changes to the operation, implementation and/or monitoring of the registered CDM project activity taking into account the types of changes described in Appendix 1, which describes the types of changes that do not require prior approval by the Board. According to the Clean Development Mechanism Project Standard (Version 03.0) paragraph 221, where there are changes to project design of a registered CDM project activity; project participants shall prepare a revised PDD which describes the nature and extent of the proposed or actual changes. This assessment opinion contains the description of the post registration changes, including their nature, extent and the proposed alternative monitoring of the project activity, as well as any other complementary information required by the PCP, PS and VVS, to submit a request for approval by the Board prior to the commencement of the verification process. 1.2 Scope The scope of the validation is to assess all changes from the project activity as described in the registered project design document, including their impact on the estimates of the emissions reductions, the level of accuracy of the monitoring activity, the additionality or scale of the project activity and the applicability and application of approved methodology. The following documents were reviewed as part of the scope of the activity: PDD and monitoring plan registered. /1/ PDD and monitoring plan revised. /2/ Validation report. /3/ ACM0001, Ver. 5 Consolidated baseline and monitoring methodology for landfill gas project activities /4/ Spreadsheet calculation /5/ Decision 3/CMP.1 and relevant decision and guidelines from the EB CDM Validation and Verification Standard, version /6/ Clean Development Mechanism Project Cycle Procedure, version /7/ Clean Development Mechanism Project Standard, version /8/ Page 6 of 24

7 Associated documentation (spreadsheet, design documentation, agreements, etc.) The validation scope is defined as an independent and objective review the post registration changes included in the revised project design document, including the revised monitoring plan and other relevant documents. The information in these documents is reviewed against Kyoto Protocol requirements, UNFCCC rules and associated interpretations. AENOR, based on the PCP, the PS and the VVS, has used a risk-based approach in the validation, focusing on the identification of significant risks for the project implementation and the generation of CERs. The validation is not meant to provide any consultancy services to the Client. However, stated requests for clarification and/or corrective actions may provide input for improvement of the revised PDD. 1.3 Description of the Project Activity Host Country: Uruguay Title of project activity: Montevideo Landfill Gas Capture and Flare Project UNFCCC registration No: 1349 Project Participants: Uruguay: Municipality of Montevideo; Kingdom of Spain: Ministry of Agriculture, Food and Environment and Ministry of Economy and Competitiveness AZULIBER 1, S.L. Comercial De Materiales De Construccion, S.L. (COMAC) Compania Espanola De Petroleos, S.A. (CEPSA) Endesa Generacion, S.A. E.ON Generacion S.L. Gas Natural SDG, S.A. Hidroelectrica Del Cantabrico, S.A. IBERDROLA Generacion S.A.U. Repsol YPF S.A. Zeroemissions Carbon Trust, S.A. Cementos Portland Valderrivas, S.A; Bilateral and Multilateral Funds Spanish Carbon Fund (SCF). Managing company: International Bank for Reconstruction and Development (IBRD) Location of the project activity: Montevideo Department of Montevideo. Uruguay Coordinates Cells , Cell 8 A/B , Page 7 of 24

8 Cell 8 C/D , Project crediting period: 02/02/2010 to 01/02/2017 (first renewable period) Project starting date: 01/10/2007 The validation and previous verifications are summarised below: Process DOE Crediting/Monitoring Period Registration Date Amount of CERs Validation process (First crediting period) Change starting date crediting period DNV 03/02/2008 to 02/02/ /02/ ,790 tco2/year AENOR 02/02/2010 to 01/02/ /07/ ,790 tco2/year The purpose of the proposed project activity is the capturing and flaring of the LFG generated at Montevideo s landfill, Uruguay. In this project, LFG will be combusted in a flare with no energy recovery The proposed project activity will contribute to mitigate the GHG emissions through the destruction of the methane contained in the landfill gas. It is expected that this contribution avoids the emission of 782,158 tco2e to the atmosphere over a period of 7 years starting on February 2, The project activity will generate CERs and the only revenues will come through the selling of CERs. The revenues obtained will contribute to eliminate the barriers preventing the implementation of this project. 2 METHODOLOGY 2.1 Appointment of team members and technical reviewers The list of involved personnel and the qualification status are summarised in the table below. The appointment certificates are included in Annex 1. Name Qualification Position on the team Technical areas Pablo Taboada Utrera Chief Validator TA 13.1 José Luis Fuentes Pérez Validator TA 13.1 Richard Gonzales Toledo Manuel García-Rosell Validator Validator Alfonso Medrano Technical Reviewer TA 13.1 Technical areas (TA) mentioned above correspond to the following: Page 8 of 24

9 TA code TA 1.1 TA 1.2 TA 2.1 TA 2.2 TA 3.1 TA 4. 1 TA 4.2 TA 4.3 TA 4.4 TA 5.1 TA 6.1 TA 7.1 TA 8.1 TA 8.2 TA 9.1 TA 10.1 TA 10.2 TA 11.1 TA 11.2 TA 12.1 TA 13.1 TA 13.2 TA 14.1 TA 15.1 TA 15.2 Technical area Thermal energy generation from fossil fuels and biomass including thermal electricity from solar (COMPLEX) Energy generation from renewable energy sources Electricity distribution Heat distribution Energy demand Cement sector (COMPLEX) Aluminium (COMPLEX) Iron and steel (COMPLEX) Refinery (COMPLEX) Chemical process industries (COMPLEX) Construction Transport Mining and mineral processes, excluding those included in TA 8.2 below Oil and gas industry, coal mine methane recovery and use (COMPLEX) Metal production Mining and mineral processes, excluding those included in TA 10.2 below Oil and gas industry, coal mine methane recovery and use (COMPLEX) Chemical process industries (COMPLEX) GHG capture and destruction Chemical process industries (COMPLEX) Waste handling and disposal Animal waste management Forestry Agriculture Animal waste management Page 9 of 24

10 2.2 Review of Documentation The desk review involved a review of: Project documentation: PDD registered and Validation Report. Relevant decisions, clarifications and guidance from the CMP and the CDM Executive Board. The applied monitoring methodology, paying close attention to the frequency of measurements, the quality of metering equipment and the quality assurance and quality control procedures. A complete list of all documents reviewed is attached in section 5 of this report. 2.3 Site Visits As part of the assessment of the post registration changes, on 27/28-08/2012, Pablo Taboada and Richard Gonzales and Manuel García-Rosell carried out the on-site visit, including visits to the facilities of the project. Also, during the on-site visit the verification team was able to complete: A review of the implementation and operation of the project activity as per the registered PDD. A review of information flows for generating, aggregating and reporting the monitoring parameters. A cross-check between monitoring information required in the monitoring plan and data from other sources such as plant logbooks, inventories, purchase records or similar data sources. A check of the monitoring equipment including calibration performance and observations of monitoring practices against the requirements of the PDD and the selected methodology. A review of calculations and assumptions made in determining the GHG data and emission reductions in accordance with the proposed changes. An identification of quality control and quality assurance procedures in place to prevent or identify and correct any errors or omissions in the reported monitoring parameters. Interviews with relevant personnel to confirm that the operational and data collection procedures are implemented in accordance with the monitoring plan and the registered PDD. The interviewed persons are indicated below: Page 10 of 24

11 Interviewed organization Person/Position Montevideo Landfill Gas Capture and Flare Project World Bank Manuel Luengo Intendencia de Montevideo Juan Canessa Jorge Alsina Adriana Bentancur Aborgama (landfill operator) Pablo Zamonsky Interview topics Flows for generating, aggregating and reporting the monitoring parameters. Crosscheck between information provided in the monitoring report and data from monitoring system, plant log books, minutes meeting with stakeholders, purchase records, etc. Monitoring report and emission reduction calculations. Testing of monitoring equipment and observation of monitoring practices. Calibration of meters. Running of specific checks and trials on data sources and data management practices where risks are detected. Clarifications related to monitoring procedures. Sufficiency of monitoring plan. Reliability of internal and external data. Internal data quality control. 2.4 Internal Quality Control Following the completion of the assessment process by the validation team, all documentation undergoes an internal quality control through a technical review before submission to the CDM-EB. The technical reviewer is a qualified member of AENOR, independent from the team that carried out the validation of the project activity. The technical reviewer or the team appointed for the technical review are qualified in the technical area(s) and sectoral scope(s) of the project activity. Page 11 of 24

12 3 POST REGISTRATION CHANGES Some changes to the registered PDD have been previously communicated to and approved by the EB: Project participants. The starting date of the crediting period has been delayed 3.1 Temporary deviations from the registered monitoring plan and/or applied methodology No temporary deviations are included in the present post registration changes assessment. 3.2 Permanent changes. Corrections Description The coordinates of the landfill have been adapted to decimal format, including a new description of the different areas inside the landfill. The following parameters have been removed from section B.7.1 (Data and parameters to be monitored), and they have been included in section B.6.2 (Data and parameters fixed ex ante): D CH4 : Methane density. According to the Tool to determine project emissions from flaring gases containing methane, EB 28 Annex 13, the methane density is a constant used in equation, with a value of kg/m3 CEF electricity,y : CO2 emissions intensity of the electricity displaced/consumed. This parameter is defined ex-ante by the UTE (Uruguay National Administration for Electricity Transmissions) Assessment AENOR has assessed that the correct coordinates and description have been added now in the updated PDD. Coordinates were verified during the verification onsite visit. Regarding the changes in the parameters, both changes are deemed as appropriate due to the fact that both parameters are defined as constant figures in an ex-ante manner. 3.3 Permanent Changes from the registered monitoring plan or applied methodology Description For the proposed project activity, an enclosed flare has been installed. The flare efficiency is continuously monitored and it is calculated from the methane content in the exhaust gas of the flare, corrected for the air Page 12 of 24

13 used in the combustion process, and the methane content in the residual gas in accordance with option (b) Continuous monitoring of the methane destruction efficiency of the flare of the methodological Tool to determine project emissions from flaring gases containing methane. The registered monitoring plan includes also an enclosed flare, but with a monitoring of the project emissions from flaring (PE flare,y ) using a default value of the efficiency in accordance with option (a) To use a 90% default value, where continuous monitoring of compliance with manufacturer s specification of flare (temperature, flow rate of residual gas at the inlet of the flare) must be performed. Project proponents have decided to implement a continuous monitoring of the flare efficiency aiming to obtain a more accurate result of the emission reductions measurements. The request for approval of the permanent changes to the registered monitoring plan seeks to adjust the PDD to the real operation of the landfill. The fact to decide to use a continuous monitoring of the flare efficiency obliges to change some parameters to be monitored. Parameters used for determining Project Emissions from flaring of the residual gas stream in year y (PE flare,y ) should be monitored as per the Tool to determine project emissions from flaring gases containing Methane. When using a continuous monitoring approach, parameters are different from which are used in the default value approach, thus some changes have to be done in the monitoring plan. To a more clear understanding, the changes are shown in the following table: PDD Registered PDD Revised LFG flare,y (= FV RG,h ) LFG flare,y (= FV RG,h ) w CH4,y (= fv CH4,h ) w CH4,y (= fv CH4,h ) D CH4 D CH4 (fixed ex-ante) T LFG T LFG P LFG P LFG T flare T flare EL IMP CEF electricity,y EL IMP CEF electricity,y (fixed ex-ante) h flare - Uruguay s legislation and regulatory Uruguay s legislation and regulatory Page 13 of 24

14 PDD Registered PDD Revised - LFG total,y - PE flare,y - fvi,h - t O2,h - fv CH4,FG,h Assessment As it has been explained above, the proposed revision of the monitoring plan has been carried out to improve the description of the monitoring plan with clearer information, and changing some inconsistencies contained in the registered monitoring plan. The registered PDD of Montevideo Landfill Gas Capture and Flare Project (Ref: 1349) uses the approved consolidated methodology ACM0001 version 5. The proposed revision of the Monitoring Plan is in accordance with the approved monitoring methodology. The difference is only in the methodological option chosen for the monitoring of emission reductions obtained by the flaring of the LFG. The new parameters to be monitored included in the proposed monitoring plan are due to the use of option (b) Continuous monitoring of the methane destruction efficiency of the flare of the methodological Tool to determine project emissions from flaring gases containing methane. They are as follows: LFG total,y : Total amount of landfill captured at normal T and P PE flare,y Project emissions from flaring of the residual gas stream in year y f vi,h : Volumetric fraction of component i in the residual gas in the hour h where; i = CH 4, CO 2, O 2 t O2,h : Volumetric fraction of O2 in the exhaust gas of the flare in hour h fv CH4,FG,h : Concentration of methane in the exhaust gas of the flare in dry basis at normal conditions in the hour h On the other hand, and due to the methodological option taken, h flare, is not necessary to be monitored any more. Page 14 of 24

15 The proposed new monitoring plan also includes an option, in case of the continuous monitoring system is unavailable for maintenance or failure, to assume a default value for the flare efficiency. AENOR has assessed other landfill registered projects that operate in the same way that the changes requested for Montevideo Landfill in sections B.6.6, B.7.1 and B.7.3 of the monitoring plan, in relation to the monitoring of the flare efficiency. Projects assessed are: Proactiva Tijuquinhas Landfill Gas Capture and Flaring project (Reference 1506) Bionersis project on La Duquesa landfill, Dominican Republic (Reference 2595) Bionersis LFG project Colombia 2 (Reference 3332) Landfill gas recovery and utilization in Nam Son, Tay Mo landfills in Hanoi (Reference 3733) In conclusion, the proposed changes to the registered monitoring plan are to provide more accurate information of the current operation of the project and change some mistakes, ensuring that the level of accuracy or completeness in the monitoring and verification process is not reduced as a result of the revisions. Therefore, the proposed revision of the monitoring plan only improves the information of the registered monitoring plan and changes to a methodological option that allows a more accurate calculation of emission reductions; the revised monitoring plan is also in accordance with the approved monitoring methodology applicable to the project activity. Description The second permanent change from the registered monitoring plan is related to the calibration frequency of thermocouples. These are used to measure the temperature in the exhaust gas of the flare. According to the registered monitoring plan, thermocouples should be replaced or calibrated every year, however, the proposed change is to carry out the replace or calibration of thermocouples as per manufacturer s specifications, not exceeding 1 year from the time of installation. Assessment AENOR has assessed this change and considers that is in compliance with the applied methodology and does not reduce the level of accuracy of the monitoring compared with the requirements contained in the registered monitoring plan. Hence, in opinion of AENOR this change does not lead to a reduction in the accuracy of the calculation of emission reductions. Page 15 of 24

16 3.4 Changes to project design of registered project activity Description There are several changes proposed to project design of registered project activity. They are as follows: a) The expected operational lifetime of the landfill included in the registered PDD is 2011, when the last cell was designed to be closed, but in the revised PDD this last cell is extended, by operational reasons, to be operational up to Calculations of the baseline have been modified accordingly. b) The flare system (enclosed flare and monitor exhaust gas components) has been installed with a total capacity of Nm 3 /h of biogas (maximum), instead of the Nm 3 /h included in the registered PDD. c) Although the approved starting date of the crediting period is 02 February 2010, the real implementation date of the monitoring system is 01 August Due to this fact, only the emission reductions generated from August 2012 will be claimed. Assessment a) Changes in the configuration of the cells do not have any impact neither on the scale of the project activity or on the additionality of the project activity. Data for the calculation of the baseline have been assessed and checked with information from the Municipality of Montevideo obtained during onsite visit. The new estimations for waste to be deposited annually in years have been deemed to be realistic. AENOR considers that new baseline calculations are correct. b) Changes in the total capacity of the flare system do not have any impact neither on the applicability of the applied methodology under which the project was registered nor on the compliance of the monitoring plan, and thus it is in line with Section Changes to the project design of a registered project activity of the Clean Develop Mechanism Project Standard version c) The delay in the implementation of the monitoring systems affects the total amount of emission reductions foreseen by the project activity. The amount of emission reductions expected for the first 7 years of crediting period changes from 1,412,530 tons of CO2e to 782,158 tco2e, and the annual average over the crediting period from 201,790 tons of CO2e to 111,737 tco2e. AENOR considers that both the description of the project scenario and the calculations are conservatives. Taking into account that the demonstration of the additionality of the project is based on barrier analysis, and the barrier analysis is not affected by the amount emission reductions, there is no effect in the additionality of the project activity due to the change in the emission reductions. Apart from the issues explained above, the rest of the facilities are implemented as described in the registered PDD and no significant changes were identified related to the situation envisaged. Page 16 of 24

17 AENOR has assessed that the changes requested do not affect the following issues: The additionality of the project activity, as the additionality of the project was based on barrier analysis, and the barriers are still valid under the new circumstances. The scale of the project activity, as the project activity is still a large scale project activity. Applicability and application of approved baseline methodology under which the project activity has been registered and the project complies with all applicability criterion of the methodology applied. The compliance of the monitoring plan with applied monitoring methodology; or The level of accuracy of the monitoring compared with the requirements contained in the registered monitoring plan. 3.5 Changes to start date of crediting period Description Project participants do not want to request changes to start date of crediting period. Assessment Not applicable. 3.6 Adoption of the VVS PDD format The proposed new PDD has adopted the Project Design Document Form for CDM Project Activities (F-CDM- PDD) Version AENOR has assessed the information included comparing with which was included in the registered PDD due the fact it was registered under the previous regulatory framework (VVM track). Once compared both versions, it is AENOR opinion that the material included in the new form is materially the same as the information in the registered PDD. The changes that are the subject of the request for approval have been highlighted. Page 17 of 24

18 4 VALIDATION OPINION AENOR was contracted to perform the assessment opinion on the post registration changes of the project. (Registration Ref. No. 1349) to submit a request for approval by the Board prior to the first verification of the project. AENOR has performed the validation of the proposed changes according to the approved consolidated methodology ACM0001 (Version 05) Consolidated baseline and monitoring methodology for landfill gas project activities", VVS (Version 03.0), PS (version 03.0) and PCP (Version 03.2). AENOR planned and performed its work to obtain the information and explanations considered necessary to provide sufficient evidence to give reasonable assurance of the level of accuracy of GHG emission reductions. This assessment opinion is prepared on the basis of the monitoring plan included in the revised PDD and compared with registered monitoring plan of the project activity which is not adversely affected. This assessment included: Collection of evidence supporting the reported data. Checking whether the provisions of the revised monitoring plan, were consistently and appropriately applied. This revision improves the accuracy of information provided and consistency in the registered PDD and the monitoring plan. Furthermore, we confirm that: The proposed revision issues have been described, and an assessment has been provided to substantiate the reason for each of the proposed revision issues of the registered PDD and monitoring plan, using objective evidence. The proposed post registration changes ensure that the level of accuracy or completeness in the monitoring and verification process is not reduced as a result of the revisions. The proposed post registration changes are in accordance with the approved monitoring methodology applicable to the project activity and ensuring the conservativeness of the emission reductions calculation. Madrid, 10 July 2013 Pablo Taboada Utrera Chief Validator Jose Luis Tejera Oliver Authorised person Page 18 of 24

19 5 REFERENCES 1 PDD registered 2 PDD v8 3 Validation report 4 ACM0001, Ver. 5 Consolidated baseline and monitoring methodology for landfill gas project activities 5 Spreadsheet calculation 6 Clean Development Mechanism Validation and Verification Standard (version 03.0) 7 Clean Development Mechanism Project Cycle Procedure (Version 03.2) 8 CDM Project Standard (version 03.0) Page 19 of 24

20 . ANNEX 1. APPOINTMENT CERTIFICATES CERTIFICATE OF QUALIFICATION Subject: Validation and Technical Review Team for Madrid, 10/07/2013 Hereby I confirm the following records of qualification, according with AENOR internal instruction Validation, Verification and Certification of Clean Development Mechanism (CDM) project activities IE-DTC-039, and in relation with the validation process of the above mentioned project activity: Name: Pablo Taboada Utrera CDM Chief Validator: Yes CDM Validator: Yes CDM Chief Verifier: N/A CDM Verifier: N/A External Technical Expert: N/A Technical areas related with the project activity: TA 13.1: Waste handling and disposal. Page 20 of 24

21 CERTIFICATE OF QUALIFICATION Subject: Validation and Technical Review Team for Madrid, 10/07/2013 Hereby I confirm the following records of qualification, according with AENOR internal instruction Validation, Verification and Certification of Clean Development Mechanism (CDM) project activities IE-DTC-039, and in relation with the validation process of the above mentioned project activity: Name: José Luis Fuentes Pérez CDM Chief Validator: Yes CDM Validator: Yes CDM Chief Verifier: N/A CDM Verifier: N/A External Technical Expert: N/A Technical areas related with the project activity: TA 13.1: Waste handling and disposal. Page 21 of 24

22 CERTIFICATE OF QUALIFICATION Subject: Validation and Technical Review Team for Madrid, 10/07/2013 Hereby I confirm the following records of qualification, according with AENOR internal instruction Validation, Verification and Certification of Clean Development Mechanism (CDM) project activities IE-DTC-039, and in relation with the validation process of the above mentioned project activity: Name: Richard Gonzales Toledo CDM Chief Validator: Yes CDM Validator: Yes CDM Chief Verifier: N/A CDM Verifier: N/A External Technical Expert: N/A Technical areas related with the project activity: Page 22 of 24

23 CERTIFICATE OF QUALIFICATION Subject: Validation and Technical Review Team for Madrid, 10/07/2013 Hereby I confirm the following records of qualification, according with AENOR internal instruction Validation, Verification and Certification of Clean Development Mechanism (CDM) project activities IE-DTC , and in relation with the validation process of the above mentioned project activity: Name: Manuel García-Rosell CDM Chief Validator: Yes CDM Validator: Yes CDM Chief Verifier: N/A CDM Verifier: N/A External Technical Expert: N/A Technical areas related with the project activity: Page 23 of 24

24 CERTIFICATE OF QUALIFICATION Subject: Validation and Technical Review Team for Madrid, 10/07/2013 Hereby I confirm the following records of qualification, according with AENOR internal instruction Validation, Verification and Certification of Clean Development Mechanism (CDM) project activities IE-DTC , and in relation with the validation process of the above mentioned project activity: Name: Alfonso Medrano CDM Chief Validator: N/A CDM Validator: N/A CDM Chief Verifier: N/A CDM Verifier: N/A External Technical Expert: N/A Technical areas related with the project activity: TA 13.1: Waste handling and disposal. Page 24 of 24