In e-Consultation, a ‘Call for funding: Investment in energy efficiency measures and high-efficiency cogeneration in the manufacturing industry’ has been published. The condition is that the project (purchase of machines) must achieve a minimum energy savings of seven percent or a total reduction of CO₂ by five percent. In the comments, it is pointed out that this threshold is too high, especially for large manufacturing companies, so I hope that the Ministry of Environment and Green Transition will consider the proposed suggestions.
In addition to reducing these percentages, there are other rational proposals related to them. For example, Miroslav Božić, advisor to the president of the Croatian Sugar Industry, while praising the initiative, also finds a flaw in the set minimum. He believes that investing in machines that will save energy and reduce CO₂ emissions will be difficult to achieve at the company level, and like others, he suggests defining the term ‘project unit’. This would mean that energy savings and CO₂ reduction are measured only for the machines that are purchased compared to those that are replaced. Thus, Božić emphasizes, the measurement of savings should be conducted only in part of the production process and at measurement points at the location where the specific investment is made, rather than at the level of total energy consumption and total emissions of the company. ‘We believe it is important, as in other calls for energy efficiency and renewable energy sources, to introduce the concept of project unit and to foresee the declaration of savings on the project unit that is the subject of investment and on which energy and emission savings are achieved. Namely, project investment should be viewed at the project unit level, which can be the entire production facility, part of the production facility, or multiple parts of the production facility where savings are achieved,’ writes Božić.
Suggestions and Proposals
He illustrates this with the example of facilities with high energy consumption intensity (consumption exceeding 150 thousand megawatt-hours per year) where it is difficult to achieve seven percent energy savings when only part of the facility is changed with one project, and the measurement of energy savings and CO₂ reduction refers to the entire facility. It is particularly difficult to achieve this, he adds, with just one project proposal with a support limit of five million euros, and therefore he suggests that a definition of project unit be incorporated into the call text.
In the consulting company Revent Smart, they think the same but also offer an alternative. For example, they propose that the minimum level of savings that the project must achieve be removed or reduced if the entire production facility will be relevant for measurement. They emphasize that even a small percentage of savings at the level of large production facilities can result in significant absolute savings.
The Vindija Group also believes that some things should be clarified, namely that a greater effect would be achieved if these conditions were reduced at least for projects at locations where there is currently high energy consumption and large CO₂ emissions. In this way, all projects that have high absolute energy savings and absolute reductions of CO₂ in tons at the implementation locations could compete. This would make it easier to achieve effects, and those who are currently the largest polluters could apply for the call with large absolute energy savings and absolute reductions of CO₂ in tons. Therefore, Vindija proposes that: a) the project must achieve a minimum energy savings of at least five percent or a total reduction of CO₂ of three percent or b) a minimum energy savings of at least seven percent and a total reduction of CO₂ of five percent, with the condition that in the case when the project is implemented at a project unit that is a large polluter, it achieves a minimum energy savings of at least five percent or a total reduction of CO₂ of three percent.
Consider the proposals
This published call in e-Consultation is one of the examples where it can be seen that commentators and proposers breathe as one. This fact should catch the attention of people in the Ministry and encourage them to think about everything that has been written. No one here criticizes the call proposal, but only warns of shortcomings (from their perspective), so it would be good for the relevant authorities to discuss everything written with processors.
POST SCRIPTUM
There are also many ambiguities in the call. For example, one commentator writes that both the context and the timing of the call’s publication suggest that the submission of project proposals will begin in the current year, and since we are at the beginning of the second half of the year, it is clear that the reference period, or reference year for energy consumption and emissions will be 2023. However, to eliminate any doubt regarding possible misinterpretation that some other year after 2023 could also be a reference, he suggests that this should be emphasized.
