The WCI Electricity Team invites stakeholder comment on the 2006 Draft Default Emissions Factor Calculator and the 2007 Draft Default Emissions Factor Calculator.  In addition to the “Lite” versions of the Draft Calculators that were previously posted, we have now posted the full versions that include the underlying plant and unit level data.  We appreciate comment on any aspect of these analyses, but we are particularly looking for information on the questions provided below:

• How often should the factor be updated?
• How far in advance should it be finalized?
• How many years’ worth of data should be used? One year or an average of 2 or 3 years?
• Are you aware of any major or systematic errors in Energy Information Administration data on generation or fuel consumption?
• How are losses handled on e-tags and what is an appropriate transmission loss factor? Does the loss factor only need to account for losses from actual sources to first Point of Receipt?
• Should capacity factors be based on nameplate capacity or net summer capacity?
• How large are discrepancies between Continuous Emissions Monitoring System (CEMS) data and fuel-based calculations? Which is more accurate?
• Are you aware of any other facilities that need to be disaggregated into distinct plants based on fuel and/or generation technology?