12:55 21 Nov 24
Info Report Check
Submission incomplete:
1: The DOE is requested to describe all the assumptions/ data/references listed in the PDD for the baseline identification as per VVM v1.2 paragraph 87 (a).
Section 3.5.2 of the validation report - Baseline identification – concludes that the baseline corresponds to the combined margin CO2 emission factor for the Georgian national grid. However, it is not clear how the DOE has concluded that the national grid of Georgia (i.e. and the Georgian EF) is a reasonable baseline, considering that the MoU signed on 2009 between the PP and the Georgia Government for utilization of the energy potential of Chorokhi River in the borders of Georgia establishes that 40% of the energy produced will be used for internal consumption of the Country and the remaining 60% should be exported to Turkey, meaning that 60% of the project’s generation will displace electricity that would have otherwise been produced by other sources unrelated to the identified baseline (i.e. Georgia’s national grid)
2: The DOE is requested to state if the baseline methodology is correctly applied to calculate project/baseline emissions, leakage and emission reductions as per VVM v1.2 paragraph 92(d).
While validating the estimation of GHG emissions reductions, the DOE has concluded that baseline emissions will be the result of multiplying the total (100%) of net electricity produced by the project (517,880 MWh/year) by the combined emission factor calculated for the national grid of Georgia. However, it is not clear how the DOE has assessed that all data sources and calculations are appropriate and correct and that at the same time will result in a conservative estimate of the emission reductions, considering that:
- The MoU signed on 2009 between the PP and the Georgia Government for utilization of the energy potential of Chorokhi River in the borders of Georgia establishes that 40% of the energy produced will be used for internal consumption of the Country and the remaining 60% should be exported to Turkey. Hence, 60% of the project’s generation will displace electricity that would have otherwise been produced by other sources unrelated to the identified baseline (i.e. Georgia’s national grid)
3: The DOE is requested to state whether the data and parameters are conservative and appropriate if they are fixed ex-ante (not need to monitor) during the project activity crediting period as per VVM v1.2 paragraph 91.
While validating the emission factor, the DOE has made reference to the “Baseline emission factor of the electricity system of Georgia”, published by the Ministry of Environment. However, it is not clear how the DOE has assessed that all data sources and calculations are correct and that at the same time will result in a conservative estimate of the emission reductions, considering that: i) The values for OM and BM presented in both the PDD and the validation report differ from the values published in the abovementioned document published by the DNA; ii) Links provided on the val. report /15/ and on the excel spreadsheet lead to different versions of the official BL-EF document from the Georgian DNA.
1: The DOE is requested to describe all the assumptions/ data/references listed in the PDD for the baseline identification as per VVM v1.2 paragraph 87 (a).
Section 3.5.2 of the validation report - Baseline identification – concludes that the baseline corresponds to the combined margin CO2 emission factor for the Georgian national grid. However, it is not clear how the DOE has concluded that the national grid of Georgia (i.e. and the Georgian EF) is a reasonable baseline, considering that the MoU signed on 2009 between the PP and the Georgia Government for utilization of the energy potential of Chorokhi River in the borders of Georgia establishes that 40% of the energy produced will be used for internal consumption of the Country and the remaining 60% should be exported to Turkey, meaning that 60% of the project’s generation will displace electricity that would have otherwise been produced by other sources unrelated to the identified baseline (i.e. Georgia’s national grid)
2: The DOE is requested to state if the baseline methodology is correctly applied to calculate project/baseline emissions, leakage and emission reductions as per VVM v1.2 paragraph 92(d).
While validating the estimation of GHG emissions reductions, the DOE has concluded that baseline emissions will be the result of multiplying the total (100%) of net electricity produced by the project (517,880 MWh/year) by the combined emission factor calculated for the national grid of Georgia. However, it is not clear how the DOE has assessed that all data sources and calculations are appropriate and correct and that at the same time will result in a conservative estimate of the emission reductions, considering that:
- The MoU signed on 2009 between the PP and the Georgia Government for utilization of the energy potential of Chorokhi River in the borders of Georgia establishes that 40% of the energy produced will be used for internal consumption of the Country and the remaining 60% should be exported to Turkey. Hence, 60% of the project’s generation will displace electricity that would have otherwise been produced by other sources unrelated to the identified baseline (i.e. Georgia’s national grid)
3: The DOE is requested to state whether the data and parameters are conservative and appropriate if they are fixed ex-ante (not need to monitor) during the project activity crediting period as per VVM v1.2 paragraph 91.
While validating the emission factor, the DOE has made reference to the “Baseline emission factor of the electricity system of Georgia”, published by the Ministry of Environment. However, it is not clear how the DOE has assessed that all data sources and calculations are correct and that at the same time will result in a conservative estimate of the emission reductions, considering that: i) The values for OM and BM presented in both the PDD and the validation report differ from the values published in the abovementioned document published by the DNA; ii) Links provided on the val. report /15/ and on the excel spreadsheet lead to different versions of the official BL-EF document from the Georgian DNA.
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