European Commission Directorate-General for Regional and UrbanPolicy
«In detail, some of the calculations in the ex ante assessment are not fullyclear and estimations are not justified; for example:
1)according to the data in table. 4.2, the saving of 1 MWh costs, onaverage, around 800 EUR (average eligible costs). It is not thereforeclear why in a later calculation 1.500EUR/ MWh is used.
2)Table 4.6 does not provide an estimation of private funding availableon the market (see above). In table 4.6 it is only included the amount of3.25 MEUR, corresponding to "energy efficiency investments of themanufacturing industry, for measures independent from the ESI Fundfor funded projects" (and not included in the calculation of the leverageeffect). This concept is not clear and more detail would be needed.
3)In addition it should be noted that historical investments show that thetotal eligible costs of an energy efficiency project were around EUR407.000, however the estimated number of 65 supported enterprisesgives a calculation of ESI fund support of around EUR 590.000, whichwith co-financing rate of 30% would mean a total cost of a project ofaround EUR 2 million. This difference should be clearly explained andjustified.»
1)Table 4.2 of the ex-ante assessment report includes historical data ofthe Climate Change Financial Instrument during 2010-2014. Thefunding gap calculation in Table 4.6 includes a maximum estimatedvalue 1,500 EUR/MWh considering the current district heating tariffand maximum planned investment payment period of 20 years(excluding 30% grant effect). According to opinion of SJSC“Development Financial Institution Altum” engineering experts, 1,500EUR/MWh is more reliable benchmark value. In projects financed bythe Climate Change Financial Instrument reported energy savingswere in certain cases overestimated. As mentioned in the ex-anteassessment report, it is not excluded that some investment projects willbe more energy efficient requiring less investment per saved MWh.
2)Please refer to explanation above. Private funding included in Table4.6 is outside the calculation of the leverage effect because thisfunding (own funds of manufacturing industry enterprises used forsmall scale energy efficiency activities) will not directly contribute toco-finance the proposed industrial energy efficiency programme.Besides, it`s impact of EUR 3.25 million is rather negligible comparedto the total calculated leverage.
3)The average value of an investment project depends on the investmentamount (EUR 1,500) per saved MWh of energy consumption. As theadditional energy efficiency requirements are in place, as well as wehave to take into consideration that the technologies and solutions usedin energy efficiency measures evolve and are getting more expensive,investment cost EUR 2 million per project is a reasonable investmentfor medium and large enterprises (considering the fact that energyefficiency of equipment is included in eligible costs). These are alsocalculations that are used to set the result indicators within theOperational Program “Growth and Employment”, where the numberof support enterprises is 65, but taking into consideration that not allcompanies will apply for maximum available funding, the number ofbeneficiaries could be higher.