Comment No. 1
Ref No.: VN005
Title: Introduction of High Efficiency Air-conditioning in Hotel
Name:Thomas Grammig

Affiliated Organization:

independentE-mail:trgram@compuserve.com

Country:

Germany

Part of the document (A/B/C/etc): B.2. Criterion 5 of

JCM_VN_F_PDD_ver01.0

Page of the document: p.2 of JCM_VN_F_PDD_ver01.0
Input on the page:The methodology VN_AM006

repeats similar erroneous assumptions in theemission reduction calculation thanthe JCM refrigeration and air-conditioner ("RAC") methodologies in Bangladesh andIndonesia. The baseline oughtto include the leakage of refrigerant in the baseline case and the project emissions
ought to include the leakage ofrefrigerant in the project case. Both in baseline and project case leakage is assumedzero.
There seems to be a pattern among all JCM methodologies that a "monitoring plan toprevent the emissionof refrigerants during replacement" is deemed sufficient. Typically including adeclaration of intent what project
participants want to do without means to verify whether they eventually act
accordingly. The criterion 5 on page 2 of
JCM_VN_F_PDD_ver01.0

is another version of similar criteria for refrigerant

emissions.
However, refrigerant emissions do not only occur during the replacement of equipment
but also during normal operation. Certainly air-conditioner manufacturers know quite
well what the leakage is and furthermore loss of refrigerant during
operation can easily be monitored by documenting how much refrigerant is being
refilled.

It is worrying that a PDD does not include details about the project equipment and thisone has exceptionally little information.
Despite of this lack of transparency, it is possible to estimate refrigerant emissions
during operations:assuming a refrigerant charge of 0.2 kg R410a / kWand twelve air-conditionersof 109 kW
the total volume of refrigerant is 261 kg R410a. With GWP of 2088 and 5%
leakage per year, theleakage in the project case amounts to 27.2 tCO2e.
Because R410a

consists of two HFC gases, it is relevant to underline that it is dealt

with both by theMontreal Protocol and the Kyoto Protocol.
As I have commented previously on JCM projects and methodologies, I would like topoint out that yourbaseline for refrigerant emissions is incomplete and fundamentally of lowerenvironmental integrity thanother RAC methodologies.
Bangladesh chiller methodology BD_PM001 does not account for the impact of there-use ofrefrigerant and does to account for leakage from the project chiller that uses HFC-245
as refrigerant.
https://www.jcm.go.jp/bd-jp/methodologies/32/comment_file
Indonesia ID_AM003 andcriterion 5

ID_AM004 do not account for the re-use of old

refrigerant anddo not account for normal leakage of refrigerant from the project chillers.
https://www.jcm.go.jp/id-jp/projects/2/public_comment_file

criterion 7

Final comment for the proposed project concerns the level of efficiency of the projectequipment.
The air-conditioners have an average COP around 4.09.
Related JCM projects in Thailand, Bangladesh and Indonesia have efficiency levels inthe presentmarket on average between COP 5 to 6, for inverter type equipment. The proposedequipmentin Vietnam compares somewhat unfavourably.

I don't want to abuse your attention, but I would like to point out that the interactions
between different climate regimes
can be taken into account. Regarding VN_AM006, as for BD_PM001, ID_AM002 andID_AM003, there are interactionsand overlapping effects with the Montreal Protocol, with the Californian emission
trading because of its CFC destruction
projects, and with the Kyoto Protocol CDM with its methodologies AM0060 and AMSIII.X.
Perhaps these interactions can be encouraged or be prevented, reflecting what policy
goals are important to JCM.
And the encouragement or discouragement of the relations between VN_AM006 andMontreal Protocol projects, theCalifornian "Compliance Offset Protocol Ozone Depleting Substances", ACR "Use ofCertified Reclaimed HFC
Refrigerants and Advanced Refrigeration Systems" and CDM might be adequatelydefined at the methodology level
because thereby a precedent is set for fruitful co-existence between various nationaland regionalemissions trading systems. The case of refrigerants could be suitable for this also
because the interactions can be
defined in physical quantities (kg of CFC or HFC), rather than interactions via prices
and markets.
It might be of overarching policy concern to JCM, in light of the Paris Agreement Article
6.2, that these differencesin accounting of refrigerant emissions should be aligned so as to not block theintegration of JCM under theParis Agreement.

I would be pleased to provide more information or comment on the accounting ofrefrigerant emissions.
sincerely yours
Thomas Grammig