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Marinela Panayotova

Subject: Comments/proposals to Draft Specifications for the application of UNFC to Bioenergy Resources from Marinela Panayotova, Department of Chemistry, University of Mining and Geology, Sofia, Bulgaria

The proposed Specifications for the application of the United Nations Framework Classification for Resources to Bioenergy Resources (BioRES-Specifications), especially when considered together with the case studies developed, is complete and comprehensive. They fully comply with the United Nations Framework Classification for Resources (categories and subcategories; classes and subclasses; generic specifications and Renewables Specifications).

The BioRES-Specifications will be a useful guide and aid to all types of stakeholders - investors, industry, regulators, governments - working at all levels (company - both mature and new, country, regional or global level). The BioRES-Specifications can be a practical tool also for consumers and NGOs.

With the introduced lists for describing the Energy Products, the Bioenergy feedstocks and co-products, the Business and Contractual Models typically used in the Bioenergy sector to access biomass, the Business and Contractual Models typically used in the Bioenergy sector to access biomass conversion/processing, as well as with the introduced additional criteria (Access and Entitlement, Market and Sales Connectivity, Authorisation, Economic Case Validation, and Social and Environmental Considerations) and the key terms (Reasonable Expectations, Reasonable Time Frame and Foreseeable Future) for E-axis, the BioRES-Specifications are especially valuable means for the project evaluator. The evaluator, as well as other stakeholders,  will be facilitated in their work by the proposed lists of estimates that shall be considered to form direct and indirect evidence for the Bioenergy Source availability and the ability for its subsequent conversion into Energy Products.

The case studies covering different energy products (ethanol, renewable Diesel or renewable electrical power) and different Bioenergy Source for the same energy product (i.e. bioethanol from corn, sugarcane and cellulosic source) are an invaluable aid for all stakeholders.

See additional comments in the PDF document attached

Comments received from Marinela Panayotova, Department of Chemistry, University of Mining and Geology, Sofia, Bulgaria