Info Report Check
Submission incomplete:
There is a lack of information on how the DOE validates the calculation of emission factor in accordance with the VVS for PA paragraph 112 as the issues found below.
(1) Spreadsheet grid emission factor tab Step 3 cell F5 has the provision “LCMR 2013, 2014, 2015 = 77% of RIA total energy generation” to demonstrate the application of the criteria of the Tool to calculate the emission factor for an electricity system paragraph 40,(a),1) which has the provision of average of the 5 most recent years.

(2) Spreadsheet grid emission factor tab Grid data cells I14-I15, I24-I25, J14-J15, J25 show respective 28116 MWh, 1632 MWh, 75988 MWh, 936 MWh, 157682 MWh, 117733 MWh and 1330 MWh were generated in the years 2016 and 2017 from power plants Mandroseza (GO), CTA 2 25 MW (FO), AGGREKO (A) and AGGREKO (T/N); however, respective cells N14-N15, N24-N25, O14-O15, O25 for Fuel consumption (FC, L) values are empty. It is not clear whether Spreadsheet grid emission factor tab Step 4 cells D34 and E34 have taken into account the fuels consumed for the generation of respective energy for 28116 MWh, 1632 MWh, 75988 MWh, 936 MWh, 157682 MWh, 117733 MWh and 1330 MWh while calculating the emission factor of operating margin EFOM.

(3) In addition to the empty cells as mentioned in the item (2) above, some other cells in the columns I and J (energy generation in 2016 and 2017) and N and O (Fuel consumption in 2016 and 2017) are also empty. The DOE is requested to provide clarification to ensure that these empty cells are not missing data but having values as zero.