Section 3: Assigning…

Section 3: Assigning transitional BEI's and production parameters:
I fully support the concept of assigning transitional BEI's and adjusting or clarifying production parameters for a facility that is under construction or in an exploration phase and one in which production of the final product will take years. Although no production of the final product is taking place large quantities of fossil fuels are nonetheless being consumed during start-up operations. Looking at intermediate products being analysed during start-up operations and considering/clarifying these as production parameters in setting the transitional BEI would be help in the challenges these industries face during start-up operations that at times may be as long as 4 to 5 years in duration.

Section 6: Proposal to adjust electricity and co-generation thermal energy methods for calculation of an annual emissions limit so that additional facilities with a co-generation system can use these methods.
Can you please clarify the change in this section. It is my understanding that a facility with a co-generation system and producing electricity as a secondary activity can already use Method C or Method B in the Methodology.