Info Report Check
Submission incomplete:
The DOE shall determine whether the calculations of baseline GHG emissions or baseline net GHG removals, project GHG emissions or actual net GHG removals, and leakage GHG emissions have been carried out in accordance with the formulae and methods described in
the registered monitoring plan, the applied methodologies and, where applicable, the applied standardized baselines (VVS for PA paragraph 376 (c)).
The DOE (p 17) states that "The BM emission factor (EFBM=0.5444 tCO2/MWh) is calculated as the generation-weighted average emission factor of all generating power plant within KEPCO grid during the most recent year y for which power generation data is available." In the spreadsheet of "BM calculation sheet”, there are many power plants that have not been considered for BM calculation, including renewable power plants. However, the applied methodology (p 9) defines the build margin as "the generation-weighted average emission factor (tCO2/MWh) of a sample of power plants... where Fi,m,y, COEFi,m and GENm,y are analogous to the variables described for the simple OM method above for plants m" Further, it (p 6) states that "the generation-weighted average emissions per electricity unit (tCO2/MWh) of all generating sources serving the system". Therefore, the DOE is required to provide further information on how it has verified the calculation of the BM emission factor as per the applied methodology.