Info Report Check
Submission incomplete:
1: Page 9 of the CPA-DD states that in the baseline scenario end-user either had access to electricity through carbon intensive mini-grids, stand-alone generators, or utilized other forms of energy (non-electrical) through fossil fuel use. However, such statement is not consistent with page 16 of the CPA-DD and page 18 of the monitoring report, which have excluded the existing consumers (i.e. existing consumers are those who were supplied electricity from the mini-grid system prior to project implementation) from the project boundary. The DOE is requested to provide information on how it has verified the specification of actual electricity consumers of the CPA, including the types of consumers and number of each type. Please refer to paragraph 6 and 10 of AMS III.BB version 2.


2: Page 2 of the CPA-DD describes the technology to be applied in the CPA as gird extension (i.e. connecting households and institutions/SMEs to the national grid who were not connected prior to the implementation of the project activity). However, page 13 of the monitoring report indicates that the CPA involves generating electricity from renewable electricity systems and supplying the same to end users. The DOE is requested to provide clarity on the actual technology implemented in the CPA (i.e. CPA 10186-0001).


3: Paragraph 12 of AMS III.BB version 2 requires an ex-ante census of project energy consumers of the CPA which documents the physical location of each consumer and the anticipated connected load and usage hours of each consumer. However, such information was neither included in the CPA-DD, nor reported in the monitoring report. The DOE is requested to provide information on how it has verified the compliance with paragraph 12 of AMS III.BB version 2.


4: Paragraph 32 of the applied methodology (i.e. AMS-III.BB version 2) requires considering leakage on account of construction of new transmission/distribution lines (e.g. carbon stock loss due to deforestation). However, in this request of issuance, leakage is considered as zero despite of the statement that medium to low voltage distribution lines are constructed (i.e. page 20 of the monitoring report). In addition, such statement in the monitoring report is not consistent with page 37 and 38 of the verification report, which states leakage is neglected in line with the methodology as it contributes to less than 5% of the ex-ante estimated emission reductions. Besides addressing the inconsistency, the DOE shall also provide evidence on how it has concluded that the leakage due to deforestation is within 5 per cent of the estimated emission reductions of the project.


5: In accordance with the approved PRC (i.e. PRC-10186-002), the emission factor (i.e. EFgrid,CO2,y) for project emissions is to be determined as per paragraph 46(c) of AMS III.BL version 1, which provides two alternatives (i.e. zero can be applied if the share of renewable energy mix is greater than 95%; or default emission factor prescribed in the Table 6 of the most GHG intensive fuel used in the national or regional grid). In this request for issuance, an EF of zero is to be applied by claiming that the percentage of renewable energy mix in the grid for the previous 3 years (2014, 2015, and 2016) is 96.04 % (page 32 of the verification report). However, (a) such calculation sheet of the renewable energy mix is not submitted; (b) it is not clear how the electricity imported is considered, given the fact that the host country (i.e. Uganda) imports electricity from both Kenya and Rwanda (page 28 of the verification report); and (c) the value of EFgrid,CO2,y was projected as 0.513 tCO2/MWh (page 11 of the CPA-DD) at the time of requesting for PRC approval.
The DOE is requested to provide: (a) the calculation sheet of the renewable energy mix; (b) clarity on the basis of the projected EF of 0.513 tCO2/MWh, when requesting for PRC approval; and (c) information on how it has verified the compliance of the applied EF (i.e. zero) with paragraph 34 of the applied methodology (i.e. AMS-III.BB version 2), in particular footnote 6 under the paragraph 34.