June 29, 2004 UNFCCC Cooperative Mechanisms Programme P.O. Box 26024 D-5353 Bonn, Germany (E-mail: cdm-info@unfccc.int) Subject: Comment on Consolidated baseline methodology for zero-emissions grid-connected electricity generation from renewable sources" Dear Sirs, In order to comment the proposed consolidated methodology I would like first to explore some of the results of the application of it. In the enclosed pictures one can see, for the years 998, 999 and part of 2000, the following graphics: Load duration curves organized by generating sources and sorted from the highest to the lowest level; Lambda calculation; and Daily hydroelectricity demand profile 2 of selected months. My present impression is that the proposal has some drawbacks but a lot of merit. It can be seen that the way the lambda-adjustment is calculated is conservative. For the example years the lambda-factor is almost always smaller than the baseload calculated as the monthly average value of the lowest hydro share of the peak demand for each day, and sometimes even smaller than the lowest value of the month. The trend is even stronger with the growing power generation by fossil fuels shown in the 3 analyzed years (average always smaller than lambdafactor for 999 and 2000). If the objective of the method is to be conservative, it seems clear that conservativeness would be achieved by the consolidated methodology. Talking as project developer, I can identify a slight loss (up to 0% less CERs for the Brazilian case in the Chronological data (in ) for each hour of a year and for each power plant in the South-Southeast-Midwest interconnected system data is available for the years 998 (total of 8,754 ), 999 (no data for October, total of 7,980 ) and 2000 (up and including July, total of 5,856 ). In the case of inconsistent information (for example, for the 5 th of January, 998, there are 3 with no figures) the data for the whole day was discarded. 2 Calculation of the ratio of hydropower generation for each hour of the day to the peak demand of the day. Comment on consolidated methodology Page of 8 Version 2004.Jun.29
analyzed years) in carbon emission reductions using the consolidated methodology instead of the day-by-day hydro baseload calculation. On the other hand if the real objective of the CDM is to support real evolution in developing countries towards a lower carbon emission future in the power generation industry, instead of meticulous and long-lasting methodology approval for each single few projects independent of similarities, the potential gain with the conservative simplification and little degree of standardization is huge. For example, Ecoinvest has already submitted two methodologies for grid-connected electricity generation from renewable sources to the CDM-EB, and is considering submitting two more, but will decline further development if the consolidated methodology is approved. One final observation is that he document is written for engineers, probably by engineers (I know, I m one), and is quite difficult to understand. Following the explanation in the document it took me to correctly figure out how to calculate the lambda for one single year (now I have an algorithm that could be given to facilitate that). Looking forward to hearing your decision, Sincerely yours, ECOINVEST Ricardo Esparta File: Ecoinvest-2004_06_30-Input on cons meth.doc Enclosure By E-mail cc: CL, BK, BE, IFC, CAF Comment on consolidated methodology Page 2 of 8 Version 2004.Jun.29
Annex Load duration curves, lambda-factor and hydro baseload calculation for 998, 999 and 2000 in Brazil. 45000 Load duration curve all sources, Brasil 998 () 40000 natural gas oil coal nuclear hydro 35000 30000 25000 20000 5000 228 455 682 909 36 363 590 87 2044 227 2498 2725 2952 379 3406 3633 3860 4087 434 454 4768 4995 5222 5449 5676 5903 630 6357 6584 68 7038 7265 7492 779 7946 873 8400 8627 Load duration curve all sources, Brasil 998 others low-cost/must-run (hydro+nuclear) Intersection point --> 300 h Prepared by Ecoinvest (Raw data source: ONS) λ = 5,753 8,754 = 0.6572 (Total of 8754 with full information available) 5753 5,000 23 46 69 92 5 38 6 84 207 230 253 276 299 322 345 368 39 44 437 460 483 506 529 552 575 598 62 644 667 690 73 736 759 782 805 828 85 874 95% 85% 75% 65% 55% 6 7 8 9 20 2 22 23 24 25 26 27 28 29 30 3 Average of the lowest demand = 68.42 % Daily hydroelectricity demand profile, January 998 (no data for 5th) 62.43% 74.03% 59.34% Comment on consolidated methodology Page 3 of 8 Version 2004.Jun.29
Daily hydroelectricity demand profile, April 998 Average of the lowest demand = 60.5 % 66.82% 22 54.07% 53.24% Daily electricity demand profile, August 998 22 3 Average of the lowest demand = 58.24 % 65.08% 52.04% 52.3% 0% Daily hydroelectricity demand profile, December 998 Average of the lowest demand = 63.90 % 69.54% 57.79% 22 57.3% 3 Comment on consolidated methodology Page 4 of 8 Version 2004.Jun.29
Load duration curve in Brazil, all sources (999) natural gas oil coal nuclear hydro 5,000 207 43 69 825 03 237 443 649 855 206 2267 2473 2679 2885 309 3297 3503 3709 395 42 4327 4533 4739 4945 55 5357 5563 5769 5975 68 6387 6593 6799 7005 72 747 7623 7829 Hours Load duration curve all sources, Brasil 999 others low-cost/must-run (hydro+nuclear) Intersection point --> 3588 h Prepared by Ecoinvest (Raw data source: ONS) λ = 4,392 7,980 = 0.5504 4392 (Total of 7,980 with full information available) 5,000 2 42 63 84 05 26 47 68 89 20 23 252 273 294 35 336 357 378 399 420 44 462 483 504 525 546 567 588 609 630 65 672 693 74 735 756 777 00.0% 95.0% Daily hydroelectricity demand profile, January 999 (no data for 27 th and 28 th ) 90.0% % of the daily total peak demand 85.0% 80.0% 75.0% 70.0% 65.0% 60.0% 55.0% 50.0% Average of the lowest demand = 64.54 % 7.5% 3 4 9 0 58.7% 5 6 57.4% 2 22 29 30 3 Comment on consolidated methodology Page 5 of 8 Version 2004.Jun.29
Hydroelectricity daily demand profile, April 999 Average of the lowest demand = 59.4 % 67.42% 22 52.29% 52.05% Hydroelectricity daily demand profile, August 999 22 3 Average of the lowest demand = 57.80 % 63.35% 53.55% 52.33% Hydroelectricity daily demand profile, December 999 Average of the lowest demand = 60.80 % 65.99% 53.25% 22 52.94% 3 Comment on consolidated methodology Page 6 of 8 Version 2004.Jun.29
Load duration curve in Brazil, all sources (2000) natural gas oil coal nuclear hydro 5,000 53 305 457 609 76 93 065 27 369 52 673 825 977 229 228 2433 2585 2737 2889 304 393 3345 3497 3649 380 3953 405 4257 4409 456 473 4865 507 569 532 5473 5625 5777 Hours Load duration curve all sources, Brasil 2000 others low-cost/must-run (hydro+nuclear) 5,000 55 309 463 67 77 925 079 233 387 54 695 849 2003 257 23 2465 269 2773 2927 308 3235 3389 3543 3697 385 4005 459 433 4467 462 4775 4929 5083 5237 539 5545 5699 5853 Intersection point --> 2,830 h Prepared by Ecoinvest (Raw data source: ONS) λ = 3,026 5,856 = 0.567 (Total of 5,856 with full information available) 3,026 00.0% 95.0% Daily hydroelectricity demand profile, January 2000 90.0% % of the daily total peak demand 85.0% 80.0% 75.0% 70.0% 65.0% 60.0% 55.0% 50.0% Average of the lowest demand = 62.57 % 69.4% Series Series2 Series3 Series4 Series5 Series6 Series7 Series8 Series9 Series0 Series Series2 Series3 Series4 Series5 Series6 Series7 Series8 Series9 Series20 Series2 Series22 Series23 Series24 Series25 Series26 54.8% Series27 Series28 Series29 Series30 Series3 54.2% Comment on consolidated methodology Page 7 of 8 Version 2004.Jun.29
Hydroelectricity daily demand profile, April 2000 22 Average of the lowest demand = 58.26 % 63.78% 53.06% 49.33% Hydroelectricity daily demand profile, August 2000 Average of the lowest demand = 53.9 % 58.9% 3 4 9 0 5 6 2 22 47.9% 27 28 46.64% 3 Comment on consolidated methodology Page 8 of 8 Version 2004.Jun.29