19:56 23 Nov 24
Info Report Check
Submission incomplete:
1: The DOE is requested to explain how it has validated the correct application of equations and parameters in line with paragraphs 122 and 123 of VVS-PoA, in particular:
(a) Responding to the incompleteness, the generic CPA-DD for scenario 2 now includes equation 12 of the methodology, in addition to equation 3 of the methodology. Equation 12 of the methodology is to be used in conjunction with equation 13 and they are applicable for activities that retrofit or modify an existing renewable energy generation facility, as described in paragraph 58 of the methodology. Whereas equation 3 is applicable for activities that retrofit or modify an existing facility for the purpose of fuel switch from fossil fuels to biomass in heat generation equipment, as described in paragraph 63 of the methodology. The DOE is requested to clarify which type(s) of activity to be carried out under scenario 2 (i.e. retrofit of existing renewable energy generation facility, retrofit of existing facility for the purpose of fuel switch from fossil fuels to biomass, or both) and the corresponding equations;
(b) Responding to the incompleteness, the generic CPA-DD for scenario 3 has removed parameters to be monitored that were initially listed but not used in the equations. However, it is observed that the equations to determine EGthermal,PJ,y are not as per definition of the parameter. The parameter EGthermal,PJ,y corresponds to the total actual thermal energy produced in year y by all units. The equations to determine this parameter may not reflect the total actual thermal energy produced by all units. For example, page 155 of the PoA-DD describes the equation to determine EGthermal,PJ,y (last equation in the page). This equation includes ‘EGthermal,old,y’ which has been defined by the methodology (equation 11) and does not necessarily equal actual generation of the existing unit. The same is also observed for equation to determine EGthermal,PJ,y for heater.
2: The generic CPA-DDs include a fixed ex-ante parameter EFkm,CO2. However, this parameter is not used in any of the formulas. Refer to paragraph 124(a) of VVS-PoA.
3: The DOE is requested to explain how it has validated the eligibility criterion to demonstrate additionality of a CPA in line with paragraph 137 of VVS-PoA, in particular as the PoA-DD and generic CPA-DDs have not explained under which activity/scenario/case each of the simple cost analysis, investment comparison analysis and benchmark analysis applies and will be used, including the relevant input values for each of the simple cost analysis, investment comparison analysis and benchmark analysis.
1: The DOE is requested to explain how it has validated the correct application of equations and parameters in line with paragraphs 122 and 123 of VVS-PoA, in particular:
(a) Responding to the incompleteness, the generic CPA-DD for scenario 2 now includes equation 12 of the methodology, in addition to equation 3 of the methodology. Equation 12 of the methodology is to be used in conjunction with equation 13 and they are applicable for activities that retrofit or modify an existing renewable energy generation facility, as described in paragraph 58 of the methodology. Whereas equation 3 is applicable for activities that retrofit or modify an existing facility for the purpose of fuel switch from fossil fuels to biomass in heat generation equipment, as described in paragraph 63 of the methodology. The DOE is requested to clarify which type(s) of activity to be carried out under scenario 2 (i.e. retrofit of existing renewable energy generation facility, retrofit of existing facility for the purpose of fuel switch from fossil fuels to biomass, or both) and the corresponding equations;
(b) Responding to the incompleteness, the generic CPA-DD for scenario 3 has removed parameters to be monitored that were initially listed but not used in the equations. However, it is observed that the equations to determine EGthermal,PJ,y are not as per definition of the parameter. The parameter EGthermal,PJ,y corresponds to the total actual thermal energy produced in year y by all units. The equations to determine this parameter may not reflect the total actual thermal energy produced by all units. For example, page 155 of the PoA-DD describes the equation to determine EGthermal,PJ,y (last equation in the page). This equation includes ‘EGthermal,old,y’ which has been defined by the methodology (equation 11) and does not necessarily equal actual generation of the existing unit. The same is also observed for equation to determine EGthermal,PJ,y for heater.
2: The generic CPA-DDs include a fixed ex-ante parameter EFkm,CO2. However, this parameter is not used in any of the formulas. Refer to paragraph 124(a) of VVS-PoA.
3: The DOE is requested to explain how it has validated the eligibility criterion to demonstrate additionality of a CPA in line with paragraph 137 of VVS-PoA, in particular as the PoA-DD and generic CPA-DDs have not explained under which activity/scenario/case each of the simple cost analysis, investment comparison analysis and benchmark analysis applies and will be used, including the relevant input values for each of the simple cost analysis, investment comparison analysis and benchmark analysis.
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