Skip to content
New issue

Have a question about this project? Sign up for a free GitHub account to open an issue and contact its maintainers and the community.

By clicking “Sign up for GitHub”, you agree to our terms of service and privacy statement. We’ll occasionally send you account related emails.

Already on GitHub? Sign in to your account

Small scale self-consumed solar methodology, by PeerCo #2

Open
wants to merge 20 commits into
base: main
Choose a base branch
from
Open
Changes from 17 commits
Commits
File filter

Filter by extension

Filter by extension

Conversations
Failed to load comments.
Loading
Jump to
Jump to file
Failed to load files.
Loading
Diff view
Diff view
281 changes: 281 additions & 0 deletions PeerCo/small_scale_self_consumed_solar.md
Original file line number Diff line number Diff line change
@@ -0,0 +1,281 @@
<!--

This is a template to be used for methodology development. The content of this file shall follow the Markdown conventions with Github flavour.


If you need help on the Markdown syntax for Github, here is a good link:
https://docs.github.com/en/get-started/writing-on-github/getting-started-with-writing-and-formatting-on-github/basic-writing-and-formatting-syntax

And if you need a tool to make the rendering work in VSCode, here is a good plugin:
https://marketplace.visualstudio.com/items?itemName=bierner.markdown-preview-github-styles

-->
# Small scale solar self-consumption methodology

**Name**: *Small scale solar self-consumption*

**Developed by**: *[PeerCo](www.peerco.earth)*

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Let's discuss when development attribution should be stated. My thought is that it makes sense for this early stage where we should have a central champion to answer questions, but eventually we want these to be generic/coming from the EAC Alliance

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Sample for once we get there:

"This methodology was developed by the Technical Committee on Solar Consumption, under the jurisdiction of the Strategic Steering Committee, and has been formally approved by the Technical Committee.

If needed This methodology has been developed in compliance with XYZ (Level 10, Green-e etc.) requirements."

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

In the voluntary carbon markets, the people who develop the methodology are paid a small licensing fee of some kind to recover costs of developing the methodology in the first place. In this model, the group that develops and approves this would be compensated. Does the initiating company get some form of 'lead author' or 'initiating company' designation so that any questions can go back to us specifically. Some of the people in the technical committee might be representing their personal views, whereas PeerCo is initiating this as a company. There needs to be a clear distinction or understanding. One to be discussed in the steering committee.


**Revision date**: *July 5th 2024*

**Sectoral scope**: *Energy / Energy Distribution / Energy Demand*


## Summary description

This methodology is for measurements and verification of self-consumed small-scale on-site solar generation on a given site. The purpose of this methodology is to generate *Environmental Attribute Certificates* representing the self-consumed solar energy (at a specific time and geographical location), which can then be used in reporting or traded.

## Definitions

This section provides definitions of the key aspects of this methodology.

### Normative language

The following terminology is used throughout this document to outline requirements and guidelines (accordingly with common standardisation practices):
- **shall** indicates a *requirement*,
- **should** indicates a *recommendation*,
- **may** indicates an *option* that is permitted.

### Acronyms

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Comment for OpenEAC committee rather than on this specific method: should there be a central library of acronyms & glossary, to avoid a future situation where we are seeing the same terms used with different definitions?

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

good idea

Copy link
Collaborator Author

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

In principle, that's a good idea. However, for validation purposes given that methodologies with a given version are considered normative, there would be a need to always synchronise a given methodology version with the corresponding glossary/acronym list etc.
The current approach where methodologies are self-contained allows us to circumvent that complexity.


*(this section shall contains the list of acronyms in alphabetical order)*

| Acronym | Full text |
|---------|---------------------|
| CDM | Clean development mechanism |
| EAC | Energy Attribute Certificate |
| GHG | Greenhouse gas(es) |
| kWh | Kilowatt-hour (energy unit) |
| kWp | Kilowatt peak (installed capacity power unit for PV) |
| MWp | Megawatt peak (installed capacity power unit for PV) |
| PV | Photovoltaic |
| UN | United Nations |

### Glossary

- **Digital certificate** is a generic term designating environmental attributes in digital form generated using this methodology, which will correspond to Energy Attribute Certificates (EACs).

- **Emission intensity** (or *carbon intensity*) is a measure of how clean grid electricity is. It refers to how many grams of carbon dioxide equivalent (gCO2e) are released to produce a kilowatt hour (kWh) of electricity. In this methodology, an *average* measure of this factor *on the demand side* is considered at every hour and for a given grid area, meaning that this number reflects the carbon intensity of the *average kilowatt-hour consumed* in this given hour and grid region.

- **High resolution data** is data whose time resolution is hourly or sub-hourly (e.g. every 15 or 30 minutes).

- **Grid region** is a generic term used here to refer to a specific sub-division of a large-scale power system. This may be a balancing region, a country-wide grid, a market-bidding region depending on the local context. The spatial resolution used for the grid region used in a given application should be as granular as allowed by the data available.

- **PV asset** is a set of photovoltaic arrays and associated inverter(s) converting solar irradiance to electrical power.

## Applicability conditions

This section lays out the requirements on a given context for this methodology to be applicable.

### System eligibility requirements

The system to which the methodology is applied shall meet the following requirements to be eligible:

1. the rating of the PV is below 5 MWp

2. the system is a fixed installation, meaning that the PV system is mounted on a unique specific site where it will operate throughout the project

3. generation is measured by the inverter(s) or a digital meter with high resolution data, which can either be communicated automatically by digital means (e.g. Rest API) or retrieved manually

4. the asset owner documents the following:

a. PV asset type and brand

b. location of the installation (address, or GPS coordinates if an address is not available)

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Smart. Maybe require both? Also, we should state that the address must be complete, and maybe we should put the onus on the asset owner to report the grid and grid subregion e.g. Zone J NYISO

Copy link
Collaborator Author

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

It's easy to retrieve one from the other using an API, so for user practical/convenience reasons we're sticking to one mandatory here.
Regarding the disclosure, I wouldn't put that burden on the asset owner, as (1) not all of these might have that kind of fluency, (2) the choice also depends on the carbon intensity data available for the zone, (3) the zone details might change over time (e.g. geographical granularity becomes better) while we wouldn't want to have to update an agreement with the user if this changes (as the elements disclosed in this list are likely to be part of a written contract with an asset owner, it's good to stay minimal)


c. date when the PV panel started generating power on this site

5. the power produced by the PV asset does not displace other on-site power generation (i.e. there is no on-site power generation whose output is affected by the generation of the PV asset)

6. the asset owner or operator is not already being rewarded for self-consumption by another entity (e.g. government subsidies, ...)

7. site demand (either as total demand or grid import) is measured by a digital meter with high resolution data, which can either be communicated automatically by digital means or retrieved manually

In cases where power is exported from the site (i.e. not all solar generation is self-consumed), the following requirements shall also be met:

8. the electricity export from the site is measured by a digital meter with high resolution data, which can either be communicated automatically by digital means or retrieved manually.

### Requirements on the system during the project lifetime

During the whole duration of the project, the PV asset owner shall demonstrate proof of ownership of the asset and continued operation of the self-consumption. This documentation shall be made via all of the following:

- sharing of consumption data throughout the period,

- in the case of usage of the environmental attribute in reporting:
- contractual renunciation to the possibility of transfer of the environmental assets to a third party.

- in the case of sales of the environmental attribute to a third party:
- contractual transfer of the environmental attribute ownership of the self-consumed generation,
- carbon accounting for the site (location and market-based) should reflect the sale of the carbon reduction corresponding to the transfer of the certificate.


### Requirements on the operating context

The project country shall meet the following criteria:
1. delivery of micro-solar is not a requirement for building development or to meet an enforced carbon quota,
2. emission intensity data is available at the hourly (or sub-hourly) level for the national or local grid.

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

intensity data at the national level does not align with my understanding of how OpenEAC was intended to function (maybe it's me that's wrong there!). If this would be sufficient in exceptional circumstances, we need to say clearly what those are

Copy link
Collaborator Author

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

As a specific example of country-wide data: France where regional data is not available today. Data granularity varies a great deal from one place to another, and we therefore need to support a variety of cases - with, of course, the principle that good local data is always better than national or worse.

More details on this in the next answer to your comment below



## Project boundary

GHG sources included or excluded from the project boundary.

| Source | Gas | Included | Justification |
| -------------------------- |---------|----------|------------------------ |
| Grid electricity displaced | $CO_2$ | Yes | Main emission source |
| Grid electricity displaced | $NO_x$, $SO_x$ | No | Emissions data is not sufficiently granular and available the half hour or hour |

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Have you thought about the emissions due to other life-cycle phases e.g. manufacturing, installation etc?

Copy link
Collaborator Author

@Pierre-VF Pierre-VF Jul 16, 2024

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Whether these are taken into account depends on the emission intensity data. ElectricityMaps uses lifecycle data (from IPCC) so that it would take this into account if you use that specific factor of theirs. Other providers typically take a fuel-based approach (i.e. more or less scope 1), which would not account for the lifecycle.
On this level, we're therefore bound by what's available for a given geography.

Speaking of lifecycle, we would then need to also have a model of the emission intensity for the PV panels (lifecycle impact of the installation / expected MWh of production over lifetime) which adds significant complexity. At this stage, data available on most installations wouldn't allow us to accurately compute such a number - so I would not advocate for making it a mandatory requirement (however, optional might make sense, just like EnergyTag does)


## Measurement

This section introduces the underlying data requirements.

### Asset data

PV production data shall be acquired via automatic digital communication once the project is established. However, in the initial phase of setting up a project (qualifying the site, its data and quantifying the benefits of the scheme), offline extractions of the data in an open format (which may be CSV, XLSX, etc.) may be accepted.

All self-consumption data (and related generation data) shall be quality controlled prior its usage to generate verified certificates. This verification shall include:
1. the maximum PV generation is in line with the PV asset's nominal rating,
Pierre-VF marked this conversation as resolved.
Show resolved Hide resolved
2. self-consumption is always lower than the total consumption,
3. no significant PV generation is happening when there is no solar irradiance (e.g. at night).

Where data is missing, data filling (e.g. with interpolation) shall not be carried out. Digital certificates shall therefore be generated based upon measured data only.

When carrying out this asset data verification, a tolerance should be given for numerical purposes (e.g. to account for rounding of measurements by digital systems). This tolerance shall however not be of a magnitude that significantly impacts the volume of the certificates generated.

### Emission intensity data

The emission intensity data used in calculations shall meet the following requirements:

1. the time resolution of the data is hourly or higher,
2. the geographical resolution of the data is country-level or higher,

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Reinforcing my earlier point - this language would allow for gaming, ie. pick local or national emissions factors based on which would earn the most $$$

Copy link
Collaborator Author

@Pierre-VF Pierre-VF Jul 16, 2024

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

When selling EACs, the value is first and foremost going to be about the kWh, rather than the carbon (which acts as contextual data for buyers, and might provide a premium value).
Ideally, we should indeed have very clear guidelines on this. However, it is tricky to enforce from an international perspective, as granularity hugely depends on the area (you can for example check here comparing European countries where some have national, while others have sub-regions (e.g. Norway, Italy and Sweden) and states like Florida in the US where the resolution is much higher). And the fact that different intensity sources exist for some zones (e.g. carbonintensity.org.uk and electricityMaps for UK, with different methods each) only makes this worse.

We could include that the geographical resolution "should be as high as allowed by the data source" but even this leaves an open door to gaming and update difficulties if the granularity increases in the future (expecting to see an increasing amount of detail enabled in the coming years, if the current trends continue). On the other hand, enforcement with a "must be" would only make these difficulties worse (by invalidating the certificates after time of non compliance).

At this stage, we propose to address this by greater transparency (i.e. disclosing source and resolution) rather than complex criteria whose practicality is far from clear. See the update here as well as the rest of the list of information contained in the EAC

3. the signal corresponds to an average emission intensity of *consumed* electricity,
4. the source of the carbon intensity data shall be recorded as part of the digital asset generated.

Data may originate from one of the sources listed in *Appendix 2*.

## Verification and additionality

This section provides the key aspects of the verification methodology, based upon the data of the previous section.

### Baseline scenario

The baseline scenario considered is a scenario where the PV asset is not installed, therefore zero generation happens from this asset and electricity is imported from the grid instead.

### Quantification of GHG emission reduction and/or clean energy produced

This methodology supports the generation of EACs accounting for the energy consumed on site, which also account for the avoided carbon emissions (as an extra information embedded in the certificates).

The clean energy generation accounted in this methodology shall be limited to the self-consumed part of the PV asset (i.e. exports are thereby excluded, as they may already be accounted for in another certificate scheme).

Certificates shall be generated for specific time periods, where the length of these time periods shall not exceed one hour. In contexts where the electricity market's settlement period is less than an hour (e.g. 30 minutes for Great Britain), the certificates may be issued for durations matching this settlement period.

For each period *i*, the certificate's energy content shall be:
> EAC energy content[i] [kWh] = Self-consumed PV asset generation[i] [kWh]

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

It seems to me that the offset should be based on the difference between the amount of grid electricity that would have been consumed in the counterfactual no-solar-panel world, and which is not consumed because of the installation.

Is that number the same number as the total self-consumption? I think it could be, but I could also imagine a customer self-consuming more electricity than they otherwise would have without panels. You could even end up with a perverse incentive where people deliberately self-consume more and more electricity to fraudulently generate larger credits. Have you thought about checking for this?

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

We are assuming there are other incentives at play that make the maximising for self-consumption aligned with those other incentives. If they have a battery, they will also be trying to use that and discharge rather than using the grid. If they have an electric car, they may be trying to charge it. For SMEs the idea of having contextual data so that we can show their per unit energy and carbon intensity (and that it is going down) will also be possible.

Copy link
Collaborator Author

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

@paulteehan - the counterfactual in this methodology is indeed assumed to be grid import for the whole value for the PV production (i.e. we assume that no demand change happens following the installation of PV - neither in amount or time of demand).

Here, we need to remember that the credits are either used in reporting or trading.

  • When reporting, they wouldn't really profit from more demand, as that's a cost implying more import or less export (while no profit from EAC sale).
  • For trading, the same applies (bearing in mind that the EAC value is likely going to be significantly under the kWh value for the electricity itself - so that they would actually make a loss by gaming). On top of this, entities that need to report would therefore give away the 'greenness' of that demand (as the attribute is sold) which would then result in degrading their carbon reporting further and have even less incentive to game it.

Does that make sense to you?

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

We discussed this in the open EAC alliance meeting today and the following points came through:

  • It's not obvious if the assumption of no demand change following PV installation is valid or not.
  • Because these EACs will be used as carbon offsets, any optimistic over-counting of emissions reductions will result in double-emissions so it's important to get the numbers right
  • The group recognizes that the burden of evaluating counterfactuals is significant, especially if you get into the full protocol of 12 months of baseline data, max bias and error thresholds, non-routine event adjustment, etc. Some people think this analysis is necessary and some take a more pragmatic approach to getting the projects done.
  • Are there studies that exist which could validate the assumption?
  • Perhaps this could be an issue for residential but not commercial customers
  • Perhaps customers that make material changes e.g. EV installation following installation should be excluded

Copy link
Collaborator Author

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Thanks for the summary of your subgroup's reflection yesterday. We definitely agree that counterfactual building is a difficult task where the method and outcome depend on the application case (eg. residential, industrial process, commercial,...). Without resorting to a full-scale literature review, the following demand changes can be named: demand flexibility to match local production (which in practice is a combination of PV installation and the introduction of a demand control scheme), further electrification on site (EV, heat pump, ... - where again a combination of actions is happening), increase in demand (either due to rebound effect on power cost, or production expansion for industry). While some of these are a combination of actions, where solar might have acted as a trigger, it isn't clear how and where to draw the line of the solar-specific change.

Having said that, and witnessing the agreement on the complexity of the matter, there's a question whether we could specify counterfactual models precisely enough to be transparent while covering most cases. Another question arising then is whether this would reach a methodology size, consensus level and complexity that is compatible with our review process. On this level, we would expect that the answer is far from a 'yes' within a reasonable time horizon.

This is why we propose to stand by the current counterfactual, maybe making it more explicit so that it doesn't appear to be a blind spot but rather a mindful choice. The specification of this counterfactual could be a more central/defining element of this methodology (eg by also adjusting the title to signal this), so that it'd be clear and transparent to users and EAC buyers. For applications where counterfactual building can be specified and agreed upon more easily, we should promote the creation of new versions as opportunities arise.

From a tradeable instrument perspective (rather than carbon credit), it is also worth bearing in mind that the counterfactual might need to be thought of differently and more from a market based approach. Specifically here, what the EACs represent is the solar power that was used on a site (rather than importing) which is transacted with another party as a way to 'swap' their import of power with the solar production on the other site. Adopting this perspective does raise much fewer questions as to the validity of the current counterfactual.

However, this is more of an EAC discussion than an M&V one.

Please let us know what your thoughts are on the above.

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Hi @Pierre-VF , I'm happy to give my personal perspective on this approach, with the caveat that I'm not sure what happens when I do - do we have to reach a kind of consensus in order to move the method forward, or is it more that you might take my comments under advisement? I might make a critique in the interests of maximizing rigour, but I wouldn't necessarily want to be an obstacle, and I'm just a practitioner with a perspective which is as valid as anyone else's here. Perhaps a question for someone from WattCarbon (@ssuffian ?)

My opinion is that if you have factors in your equation that are uncertain or unknown, such as rebound effects, additional electrification, etc, then you need to model these as accurately as you can, and issue a credit which is conservatively on the low end of your range to account for the unknowns. (This also holds for life cycle impacts mentioned above.) I don't think that measurement complexity or difficulty in obtaining good numbers are reasons to conclude that factors can be ignored completely or assumed to be zero. Rather these are arguments that an accurate calculation cannot be made at all, and therefore we should not be issuing credits at all. I do agree with the point about tradeable instruments; I would hold offsets or credits to a far higher methodological standard since they are associated with actual physical emissions and if the numbers are found to be overly optimistic that could undermine the integrity of the market and the goal of decarbonization itself.

If this was my project, my next step would be to try to get hold of some pre/post data for a sample of customers and see if I could measure the change in demand and determine whether increased self-consumption perfectly matches decreased demand, and if it's off, by how much. Or, perhaps find some reasonably proxies in the literature. Then I would include that error in my equations so that I'm reporting a pessimistic number.

and its carbon content shall be:
> EAC carbon content[i] [gCO2e] = (Self-consumed PV asset generation[i] [kWh]) x (Average grid emission intensity[i] [gCO2e/kWh])


### Information content of the digital certificate

The following conventions shall apply to the information provided:
- timestamps are given in UTC timezone
- dates are given in the local timezone where the asset is located
- "period" refers to the specific time range with explicit start (inclusive) and end (exclusive) where the corresponding amount of energy was generated
- energy amounts are expressed in Wh

The digital certificates resulting from this verification methodology shall contain the following information:

- PV asset informations:
- Name of the production device
- A unique identifier
- Address of the site where it is installed (optional if GPS coordinates are provided)
- GPS coordinates of the installation (optional if full address is provided, as it will be inferred from it)
- Rated power (kWp)
- Date when the PV panel started generating power on the site

- Grid connection information for the site:
- Grid region type (e.g. "market-bidding zone")
- Identifier of the grid region (e.g. "UK")
- Identification of the grid connection (such as power meter number), where this identifier should correspond to the standard identification for the country/zone of application when such a standard exists (e.g. MPAN meter numbers in the United Kingdom).

- Time information about the period:
- Start timestamp
- End timestamp

- Energy content:
- Amount of PV generation from the asset that was self-consumed over the period (in Wh)

- Emission intensity of the grid:
- Average emission intensity of the grid over the period
- Source of the average emission intensity data (e.g. "carbonintensity.org.uk")
- Identifier of the grid region corresponding to the emission intensity data (e.g. "London")

- Details about certificate issuance:
- Timestamp when the certificate was generated
- Country for which the certificate is issued
- A link to this methodology (where the URL points to the specific version used to generate the certificate)

- Legal information:
- Reference to the contractual proof of ownership of the environmental attributes generated by the PV asset.


## References

*(None)*

---

# Appendix

Contextual information is provided in the appendices below. These only contain informational elements which do not hold normative value.

## Appendix 1 - Underlying motivation for the methodology

**Market failure**

Small-scale rooftop solar generation costs more to deliver per kWh of electricity produced than commercial solar arrays, and the economic case worsens for urban sites where installation is usually more costly. Electricity generated from a solar array can either be consumed immediately on-site, stored in a battery for later use, or exported to the grid. When renewable electricity is sold to the grid, it effectively creates an Energy Attribute Certificate (EAC), which can be resold, with or without a sale of electricity, to cover either a green power purchase agreement or an EAC sale. In the case of the solar electricity, from the same array, which was self-consumed on-site or stored in a battery, it has the same attributes as the electricity sold to the grid and, likewise, has a linked EAC. Typically, because self-consumed electricity does not pass onto the grid there is no verification of its creation and therefore no revenue stream. PeerCo recognises that a carbon backed revenue stream either, in the form of an EAC or a carbon credit for self-consumed renewable electricity, has the potential to positively shift the business case for smaller sites including public buildings, schools, individual roof-tops within designated energy communities, commercial and industrial buildings, and a multitude of urban buildings were installation is expensive and roof-tops are small relative to overall building size.

There is no specific market tool other than the retail price of electricity that encourages self-consumption, even though decentralised solar has huge potential to both provide renewable electricity with less burden on the grid, improve resiliency, and reduce the carbon footprint of the building user. Furthermore, urban solar generation is providing renewable electricity at the points of consumption.

The only real difference between self-consumed electricity and electricity exported to the grid is that the exported electricity flows through a payment meter and this provides verification. Self-consumed electricity also often flows through a sub-meter and can be captured through a range of smart meter and e-Car charging apps. The data is now there to fully account for this electricity. The UN Clean Development Mechanism does allow for generation of a carbon credit linked to grid connected, self-consumed electricity generation in Annex 1 Countries, and accounts for this value through its methodology. PeerCo is addressing this same carbon savings for small-scale arrays located in more countries provided that there is metered data and third-party verification.

**Tools and methods used as a reference**

This methodology used the latest version of the following tools:
- CDM methodological tool Demonstration of additionality of small-scale project activities
- CDM methodological Tool for the demonstration and assessment of additionality

This methodology is based upon approaches used in the following methodologies:

- CDM methodology for Grid Connected electricity generation from renewable sources
- CDM Methodology for zero-emissions grid-connected electricity generation from renewable sources in Chile or in countries with merit order based dispatch
- CDM Small-scale Methodology for Renewable Electricity generation for captive use and mini-grid.
- [AMS-IA: Electricity generation by the user --- Version 19.0](https://cdm.unfccc.int/methodologies/DB/1TIFADHWTMIW25TAL778RLEFJ6AWBB)


All of the relevant existing methodologies are published by the UN Clean Development Mechanism, which focuses on larger scale projects in emerging economies. The small-scale methodology for renewable sources can include projects such as tidal and hydro and can be as large as 15MW. These are still large installations when compared to the small arrays that are being placed individually on roof-tops of homes, offices, warehouses and commercial and industrial buildings.

This methodology being presented by PeerCo is for even smaller-installations than outlined in the CDM methodology, between 30 kWp and up to 4.9 MWp. The micro-versus small-scale is a key distinction as the economics are quite different. In this way, the methodology is new, but fits within the same structure, aims and similar emissions calculations to the CDM methodologies.

The other key difference is that this methodology is intended to be used in any country where the delivery of micro-solar is not a requirement for building development or to meet an enforced carbon quota.

**Additionality considerations**

The concept of additionality is that a project or investment would not have happened were it not for the additional carbon revenue stream. However, there is sufficient market evidence to prove that without subsidy, small-scale solar, particularly urban solar, has a long repayment period resulting in a marginal business case. Any user of this methodology should use direct carbon funding to those organisations that are making these marginal investments. In countries that are not Kyoto Protocol Annex 1 Countries, there is an even higher threshold for meeting additionality.

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

That's an interesting strategy, can you say what percentage of income is re-invested and how you chose that number?

Do you see a possibility of free-riders in your programs and is this investment meant to balance against those?

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

We were initially addressing this for carbon market audiences and because we are now purely looking at EACs, the point made here is more for the carbon markets and we should potentially remove this. We don't see people 'free riding' but we want to - as much as possible - prove an ongoing journey of electrification and decarbonisation which means we would like to see them build on their investments. One solar provider did want to offer this kind of proof of reinvestment and another wanted to use the proceeds to invest in more metering. but this is likely to be on a case by case basis.

Small-scale, self-consumed solar electricity is additional because it has the potential to enable grid systems to decarbonise faster by generating electricity at the location of consumption, within the low voltage, electricity network (after the substation). Small-scale, intermittent, solar electricity that is exported to the grid can create capacity problems in local areas, requiring investment, but its delivery at scale can also reduce the need for larger investments in the transmission network. Incentivising self-consumption of solar is a win-win where the local burden on the network is reduced in tandem with overall demand. Furthermore, more local solar PV and on-site use, supports Sustainable Development Goal 7 - Affordable and Clean Energy, by capturing the carbon value and making it more affordable.

Additionally, there may be situations where solar was delivered as a requirement for development approval for a larger project. The methodology is valuing the carbon reduction that is delivered by choice, not as a requirement. In some countries and regions, there are financial incentives that may shift the financial case for a solar investment and self-consumption, and for these reasons, the applicability of this methodology needs assessment on a country by country basis.

## Appendix 2 - potential sources of emission intensity data

The emission intensity data used in calculations shall originate from the source in the table below for the geography corresponding to the location of the assets.

| Geography | Emission intensity source |
|---------------|--------------------------------------------------------|
| Great Britain | [National Grid ESO's *carbonintensity.org.uk* API](https://www.carbonintensity.org.uk/) |
Copy link
Member

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Add an additional source for US

Suggested change
| Great Britain | [National Grid ESO's *carbonintensity.org.uk* API](https://www.carbonintensity.org.uk/) |
| Great Britain | [National Grid ESO's *carbonintensity.org.uk* API](https://www.carbonintensity.org.uk/) |
| US | [EIA's Hourly Electric Grid Monitor](https://www.eia.gov/electricity/gridmonitor/) |

| Global | [ElectricityMaps API](https://www.electricitymaps.com/) |

The source of the carbon intensity data shall be recorded as part of the digital asset generated.