Marinela Panayotova-University of Mining and Geology of Bulgaria

Page, paragraph

Text in the proposed draft document

Text with the proposed amendment

Page 3, Paragraph 4 from the top

The main difference with fossil fuels or solid minerals is that, during the life time of the project, the renewable energy source is being replenished3

The main difference with fossil fuels or solid minerals is that, during the life time of the project, the renewable energy source is being replenished at an average annual rate equalor higherthan consumed³

Justification/Comment
The text proposed in the draft document, especially with the footnote 3, leaves room for classifying non-RES as RES. A RES has to ensure the replenishment at an average annual rate equal or higher than the consumption rate even, if varying in the seasons.

Page 5, Footnote 6

6 In the renewable context, the G set of categories does not necessarily represent the level of confidence in the geological knowledge and potential recoverability (except for Geothermal) but in other factors that play a role in the uncertainty in the quantity of Renewable Energy Source that may be available for extraction via the Project. 

⁶ In the renewable context, the G set of categories does not necessarily represent the level of confidence in the geological knowledge and potential recoverability (except for Geothermal) but in other factors that play a role in the uncertainty in the quantity of Renewable Energy Resource that may be available for extraction via the Project. 

Justification/Comment
For the sake of clarity

Page 7, column 3, Table-line 1

Extraction is currently taking place; or, implementation of the Renewable energy Project is underway; or, sufficiently detailed studies have been completed to demonstrate the feasibility of extraction by implementing a development Project or mining operation.

Extraction is currently taking place; or, implementation of the development project or mining operation is underway; or, sufficiently detailed studies have been completed to demonstrate the feasibility of extraction by implementing a defined development project or mining operation.

Justification/Comment
The term "renewable energy project" is not available in the UNFC-2009 Annex I (ECE ENERGY SERIES No.39). Either it has not to be in gray, or the term "development project" to be left in column 3, which is clear with the explanation from column 4. Otherwise, the text in column 3 is a mixture of UNFC-2009 Annex I and the new proposal

Page 8, column 4

The G-axis represents the level of confidence in estimates of the quantities of extractable, or potentially extractable, Renewable Energy Resources associated with the Project. These could be considered as reflecting uncertainties impacting the Project and typically would cover areas such as meteorology, climatology, ecology, geography and geology (for Geothermal Projects).
Typically the various uncertainties will combine to provide a full range of possible outcomes, comparable to the extraction of fluids in the petroleum sector. In such cases, categorisation should reflect three scenarios or outcomes that are equivalent to G1, G1+G2 and G1+G2+G3.

The G-axis represents the level of confidence in estimates of the quantities of extractable, or potentially extractable, Renewable Energy Resources associated with the Project. These could be considered as reflecting uncertainties impacting the Project and typically would cover areas such as meteorology, climatology, topography and other branches of geography, ecology, and geology (for Geothermal Projects).
Typically the various uncertainties will combine to provide a full range of possible outcomes, comparable to the extraction of fluids in the petroleum sector. In such cases, categorisation should reflect three scenarios or outcomes that are equivalent to G1, G1+G2 and G1+G2+G3.

Justification/Comment
For the sake of clarity

Page 10,
C. Effective date

New

Renewables – additional context: Reported quantities are estimates of those energy quantities that are potentially recoverable from renewable sources on the basis of existing technology or technology currently under development, and are associated with actual or possible future Projects development.

Justification/Comment
It is difficult to speak about remaining quantities when discussing solar, wind and hydro energy.

Page 11, Footnote 8

8 For example, the sugar produced from a Sugarcane Ethanol mill and the minerals, such as silica, lithium,
manganese, zinc and sulfur, that can be extracted from geothermal fluids represents a value to the project (and the revenue generated by their sale may be included in the economic evaluation of the project), but would not be classified as Renewable Energy resources 

8 For example, the sugar produced from a Sugarcane Ethanol mill and the inorganic materials, such as silica, lithium, manganese, zinc and sulfur, that can be extracted from geothermal fluids represents a value to the project (and the revenue generated by their sale may be included in the economic evaluation of the project), but would not be classified as Renewable Energy resources 

Justification/Comment
For the sake of clarity - actually metals are extracted mainly under the form of minerals from the geothermal fluids; however the metals lithium, manganese, zinc are too broadly classified as minerals.

Page 12

Renewables – additional guidance:
Typical uncertainties that impact the level of confidence in the estimated quantities of Renewable Energy Resources are meteorology, climatology, ecology, geography and geology (for Geothermal Projects)

Renewables – additional guidance:
Typical uncertainties that impact the level of confidence in the estimated quantities of Renewable Energy Resources are related to meteorology, climatology, ecology, geography and geology (for Geothermal Projects)