Comments on Baseline Methodology for New Capacity That Displaces Electricity Generation

By: 
Barbara Haya
Date: 
Saturday, August 20, 2005

In a Centrally Dispatched Hydrothermal Interconnected Power System

From the UNFCCC’s CDM Public Comment Form #NM0125

[Only completed sections of the form appear here. Full form may be downloaded from www.unfccc.int]

A. Comment on the proposed new methodologies:

I. Comments on the proposed new baseline methodology:

Title of new baseline methodology:
Baseline Methodology for New Capacity that Displaces Electricity Generation in a Centrally Dispatched Hydrothermal Interconnected Power System

  1. Conditions under which this methodology is applicable to other potential projects (e.g. project type, region, data availability): [no comment]
  2. Strengths and weaknesses of the methodology: Most importantly, the additionality criteria in the methodology are weak and should be significantly strengthened, or the "Tool for the Demonstration and Assessment of Additionality" should be used.

The use of a dispatch model updated annually can be a relatively good estimation of emissions reduced by the project.

II. Comments on the proposed new monitoring methodology:

Title of new monitoring methodology:
Monitoring Methodology for New Capacity that Displaces Electricity Generation in a Centrally Dispatched Hydrothermal Interconnected Power System

  1. Conditions under which this methodology is applicable to other potential projects (e.g. project type, region, data availability): [no comment]

  2. Strengths and weaknesses of the methodology: [no comment]

  3. Any changes needed to improve the methodology: [no comment]

    1. Minor changes: [no comment]

    2. Major changes: The model should be tested against what actually happened in the previous year to minimize systematic inaccuracies in the model. The level of accuracy of the model should be reported and the spreadsheet itself or its data inputs should be made publicly available.

B. Details of the comments on the proposed new methodology:

(2) Basis for determining the baseline scenario:

  1. State whether the basis for determining the baseline scenario and for assessing additionality is appropriate and adequate: The additionality criteria are very weak in this methodology. No justification is given as to why the methodology doesn’t use the "Tool for the demonstration and assessment of additionality." Though the methodology mentions a test for common practice it does not include one. The methodology should include a test for common practice such as in step 4 of the "Tool for the demonstration and assessment of additionality." To adequately test for Project additionality, the methodology should also include other provisions in the "Tool for the demonstration and assessment of additionality" most notably sub-step 2d (sensitivity analysis), sub-step 3b, (show that the identified barriers would not prevent the implementation of at least one of the alternatives), and step 5 (impact of CDM registration).

    Without such provisions additionality is not adequately tested.

(3) Assessment of the description of the proposed methodology and its applicability:

  1. State whether the methodology has been described in an adequate manner: [no comment]

  2. State whether the proposed methodology is appropriate for the referred proposed project activity and the referred project context (described in Sections A - E of the draft CDM-PDD and submitted along with CDM-NMB): Under section A.3. Conditions under which the methodology is applicable to CDM project activities, should be included the condition that actual dispatch decisions made on the grid are made in a similar fashion to that used in the model.

  3. State whether the application of the methodology could result in a baseline scenario that reasonably represents the anthropogenic emissions by sources of greenhouse gases that would occur in the absence of the proposed project activity: The methodology includes the following sentence under section D.1.: "beyond this period, the influence of the presence of the project activity over decisions of other independent power producers is practically insignificant." This is not necessarily true and should probably be taken out. In fact, the opposite can also be argued, that over time projects are more likely to affect the timing of the building of new projects, since projects are planned to meet the difference between supply and expected demand.

    Regarding the inclusion of expansion plans in the without-project model run, they should only be included if expansion plans have been reasonably accurately followed in the past. In many countries expansion plans are very different than what actually happens, and in these cases, the CDM project should not be attributed with these differences. In these cases it is probably more accurate to just use operating margin in a dispatch model.

(6) Key assumptions/parameters (including emission factors and activity levels) and data sources:

  1. State possible data gaps: The methodology should require that all information needed to reproduce the model results be included in the PDD. This is necessary to evaluate the reliability of the model used.