Ånund Killingtveit-NTNU

Subject: Comments to Draft Specifications for Application of UNFC-2009 to Renewable Energy Resources: from Professor Ånund Killingtveit, Norwegian University of Science and Technology (NTNU), Norway
12 September 2014
 
Seen from the "Renewable side" this document can be a little bit confusing, because people are used to defining Energy Resources as Annual averages, and therefore the summation to "cumulative quantities", which can be compared to oil or coal resources is not very easy to accept.
The central concept in this document is the Project, because it is the possible extraction of energy during the lifetime of a project that is measured. For non-renewables the project will usually cover a lifetime long enough to extract all the economical useful resource, but for renewables this is of course not so. The resource is still there for further use, and not reduced, even after the project has been closed down. It is not very meaningful to sum up energy from a renewable source and compare to stored resources with limited quantity, like oil or coal. Important questions will be type of technology, lifetime of projects and discounting.

1. If we change the view from comparing energy resources to comparing energy projects, things becomes more logical. I will therefore suggest a slight, but important, modification of the Title for the report, replacing "Renewable Energy Resources" with "Renewable Energy Projects" to make this clear. Now we can compare the cumulative energy produced during the typical lifetime of projects, which may be what an investor needs in order to use the classification.
    
2. I will also suggest to delete the two last lines in Part II Section A, "Renewable Energy Resources are the cumulative ...". This sentence is not needed, it only adds to the confusion. Also the definition of Renewable Energy Resources in Annex 1 should be deleted for the same reason.
    
3. In Part III the two lines below the grayed out text (with quotes from UNFC-2009), I will suggest to change to:
   "Additional context is added to the tables below, where deemed necessary for the application of the UNFC-2009 to Renewable Energy quantities"
   Same change should be made in Part IV B. Bridging document in the Box Renewables - additional guidance: Replace "Resources" with "Quantities".
    
4. Then, I have some problems with the statement on top of Page 11 under D. Commodity or product type. In the Box it is stated that "For Renewable Projects producing multiple sales products, the non-energy commodity output shall be excluded from the Renewable Resource quantity. This could be a problem for Multi-purpose projects where other "non-energy commodities" could be a major part of the output, but I am not sure how to include this. It will not be energy, but still an important contribution from the project, increasing its value and viability. This is mostly a problem for Hydropower, where Multi-purpose projects are very common, and energy generation is only one of the outputs from the project.
    
5. Finally, in the Table for Category E1-E3 I have some problems with the use of "..economicaly viable". We need to include a wider view on viability, not only the economical but also include legal, environmental and social factors that could have a big impact on viability. I am not quite sure how this could be formulated in good English, but I think it is important in some way to make clear that Economical in a narrow sense is not enough, maybe this could be explained in a foot-note?
    
6. Some other minor corrections:

 
Comments from Professor Ånund Killingtveit, Norwegian University of Science and Technology (NTNU), Norway, to Draft Specifications for Application of UNFC-2009 to Renewable Energy Resources.