Case Study 1: Comments on Transparency and Conservativeness Alan Silayan klima-Climate Change Center

Transparency and Conservativeness In the calculation of baseline values In the calculation of baseline values In assumptions and uncertainties relating to these calculations In assumptions and uncertainties relating to these calculations Operating assumptions Operating assumptions

Transparency of Case I Method is relatively simple compared to other methodologies (ie. Afforestation and Reforrestation). Method is relatively simple compared to other methodologies (ie. Afforestation and Reforrestation). Baseline I uses a simple ‘Average Operation Margin’ calculation. (instead of simple OM, Simple adjusted OM, Dispatch Data Analysis OM as other options suggested by ACM0002) Baseline I uses a simple ‘Average Operation Margin’ calculation. (instead of simple OM, Simple adjusted OM, Dispatch Data Analysis OM as other options suggested by ACM0002) Use of existing actual or historical emissions (assumption: calibrated instruments) Use of existing actual or historical emissions (assumption: calibrated instruments) For baseline 1: all data taken from steel operations / power plants and IPCC data guidelines For baseline 1: all data taken from steel operations / power plants and IPCC data guidelines For baseline 2: data taken from public database and IPCC guidelines and steel operations For baseline 2: data taken from public database and IPCC guidelines and steel operations

Transparency of Case I Only one source of data for steel operations data and power plant data. Only one source of data for steel operations data and power plant data. Comment: Preferable third party data Comment: Preferable third party data Comment: Operation Margin and Build Margin inadequately defined therefore baseline II is not as intuitive as baseline I. Comment: Operation Margin and Build Margin inadequately defined therefore baseline II is not as intuitive as baseline I. Assumption: data is readily available and is reliable for use by the validator / verifier. Assumption: data is readily available and is reliable for use by the validator / verifier.

Conservativeness of Case I Ultimate effects of the CDM project is uncertain. Thus, conservative assumptions that are likely to underestimate rather than overestimate project reductions should be adopted. Ultimate effects of the CDM project is uncertain. Thus, conservative assumptions that are likely to underestimate rather than overestimate project reductions should be adopted. Conservativeness also depends highly on accuracy of data provided. Conservativeness also depends highly on accuracy of data provided. Project assumes that steel mill will operate with a consistent supply of BOF waste gases - ie. BOF gas stored in the Gas Holder will be able to consistently supply the fuel demands of the existing power plant and/or proposed power plant. Project assumes that steel mill will operate with a consistent supply of BOF waste gases - ie. BOF gas stored in the Gas Holder will be able to consistently supply the fuel demands of the existing power plant and/or proposed power plant.

Conservativeness of Case 1 Net Calorific Value (TJ/10 3 tons); Carbon Emission Factor (tC/TJ) and Oxidation Factors taken from IPCC guidelines Net Calorific Value (TJ/10 3 tons); Carbon Emission Factor (tC/TJ) and Oxidation Factors taken from IPCC guidelines “All values of the parameter to be used for computation of emissions should be taken as maximum, minimum or 95% of spatial and temporal values in a way that demonstrates that the emission reduction value is conservative and not overstated/ doubly accounted” – NMB sec. G “All values of the parameter to be used for computation of emissions should be taken as maximum, minimum or 95% of spatial and temporal values in a way that demonstrates that the emission reduction value is conservative and not overstated/ doubly accounted” – NMB sec. G Potential impacts of uncertainties must be at least qualitatively understood (ie. Economic factors) – appropriate decisions in the interest of conservatism be made – NMB sec. F (assessment of uncertainties) Potential impacts of uncertainties must be at least qualitatively understood (ie. Economic factors) – appropriate decisions in the interest of conservatism be made – NMB sec. F (assessment of uncertainties)

Conservativeness of Case I From ACM0002: possible leakage From ACM0002: possible leakage Power plant construction Power plant construction Fuel handling (extraction, processing and transport) Fuel handling (extraction, processing and transport) Land inundation Land inundation “Project participants need not consider these emission sources as leakage in applying this methodology”. “Project participants need not consider these emission sources as leakage in applying this methodology”.

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