* Atleast Project Title is Required.
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Project No. |
EWG 06 2017A
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Project Title |
Economic and Life Cycle Analysis of Solar Photovoltaic Systems in APEC Region toward Low-Carbon Society
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Project Status |
Project in Implementation
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Publication (if any) |
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Fund Account |
APEC Support Fund
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Sub-fund |
ASF: Energy Efficiency
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Project Year |
2017
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Project Session |
Session 1
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APEC Funding |
130,000
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Co-funding Amount |
3,000
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Total Project Value |
133,000
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Sponsoring Forum |
Energy Working Group (EWG)
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Topics |
Energy
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Committee |
SOM Steering Committee on Economic and Technical Cooperation (SCE)
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Other Fora Involved |
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Other Non-APEC Stakeholders Involved |
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Proposing Economy(ies) |
Malaysia
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Co-Sponsoring Economies |
Korea; United States
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Expected Start Date |
01/07/2017
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Expected Completion Date |
31/12/2018
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Project Proponent Name 1 |
Dr Norasikin Ahmad Ludin
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Job Title 1 |
Research Fellow / Head of Quality
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Organization 1 |
Solar Energy Research Institute (SERI)< Universiti Kebangsaan Malaysia
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Postal Address 1 |
Research Complex, Universiti Kebangsaan Malaysia (UKM), Bangi 43600, Selangor, Malaysia
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Telephone 1 |
60-3 89118586
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Fax 1 |
Not Applicable
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Email 1 |
sheekeen@ukm.edu.my
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Project Proponent Name 2 |
Not Applicable
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Job Title 2 |
Not Applicable
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Organization 2 |
Not Applicable
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Postal Address 2 |
Not Applicable
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Telephone 2 |
Not Applicable
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Fax 2 |
Not Applicable
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Email 2 |
Not Applicable
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Declaration |
Dr Norasikin Ahmad Ludin
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Project Summary |
Environmental impact and sustainability as well as tax credit and incentives play key roles in conducting an economic analysis of solar PV system. In this study, the report and guideline of economic and life cycle assessment (LCA) of solar PV systems of each type solar technology will be developed. The project team will be on-site investigated at least three case studies such as grid connected solar PV system for residential home, off-grid connected solar PV system at remote area and solar PV farm for power generation. Two rounds of workshops over two years will be conducted for in-depth discussion, sharing ideas, gathering information and developing the report and guideline of economic and LCA of solar PV system in these regions. The workshops will be attended by solar PV manufacturers, PV installers, financial institutions and related policy makers in APEC economies. The tool of analysis used is SimaPro and Enco Invent database system. At the end of the project, the report will be disseminated to all APEC member economy.
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Relevance |
PV systems are still expensive sources of electricity compared with fossil fuel generation, financial incentives, either direct or indirect, are often necessary for application. Support for use of PV systems in APEC economies such as subsidies, green electricity promotion, net metering, enhanced feed-in tariffs and loans with reduced rates or tax credits are required. Policy makers and financial institutions, who will be involve in making decisions on providing the supports require knowledge of economic and LCA of these systems in order to make an informed decision. This project will directly benefit the all players in solar PV industries, financial institutions and indirectly give benefit to the society to be more proactive in reducing carbon emission by using the solar PV systems.
This project can be classified as Rank 1 and Rank 2 as follow:
Rank 1: Next Generation Trade and Investment Issues
The economic and LCA analysis will provide information on the latest technology of solar PV based on the low carbon emission and investment opportunity in the future.
Rank 1: Ease of Doing Business
The report and guideline will be one of the tools for the PV industries and financial institution to make any comparison for investment.
Rank 2: Balanced Growth (Macro‐economic policy coordination and information sharing and financial markets -including financial regulatory systems and capital market development, financial inclusion and ensuring long‐term fiscal sustainability)
The report and guideline will be shared among PV industries and financial institutions in APEC economies.
Rank 2: Sustainable Growth (Energy efficiency, energy security and energy resiliency including the development of low carbon technology and alternative energy sources)
The solar PV system is one of the alternative energy sources that can reduce the use of fossil fuel and it will contribute a sustainable technology for low carbon society.
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Objectives |
The project has the following objectives:
1) To develop recommendation for report and guideline of economic and life cycle assessment of solar PV system for future development.
2) To create a network of solar PV players and financial institutions in APEC economies for multilateral and regional cooperation.
3) To increase knowledge of participants and society on the environmental impact of solar PV systems through workshops and publication.
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Alignment |
Alignment - APEC: The project directly supports the Leaders’ aspirational goal to reduce aggregate energy intensity by 45 percent by 2035 by promoting energy efficiency efforts toward this goal. It also addresses priorities set forth in the APEC Leaders’ Sustainable Growth Strategy to enhance energy security and promote energy efficiency and low-carbon policies; and supports the Leaders’ commitment to “urbanization featuring green, energy-efficient, low carbon, and people-oriented development” (Leaders’ 2015 Declaration). The project also linked to the APEC energy efficiency goal as a newer aspirational goal to double the amount of renewable energy used based on a 2010 base by the year 2030 (2014 APEC Economic Leaders Declaration).
Alignment – Forum: The project is also aligned with the Energy Working Group’s (EWG) Strategic Plan 2014-2018, which aims to promote energy efficiency and sustainable communities. Specifically, this project applies to this objective: Facilitate the exchange of best low carbon policies, practices and tools among APEC Member Economies to promote the development of sustainable communities across the region and to achieve progress towards the goal of reducing APEC’s aggregate energy intensity by 45 percent from 2005 levels by 2035. Other than EWG, the project will also benefited to other fora such as Policy Partnership on Science, Technology and Innovation (PSTI) and Sub-committee on Standards and Conformance (SCSC).
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TILF/ASF Justification |
APEC Member Economies have diversified approaches in reducing APEC’s aggregate energy intensity by 45 percent from 2005 levels by 2035. Although experiences vary in magnitude and complexity, APEC Member Economies are undergoing policy and programme shifts to promote the development of sustainable communities across the region. The needs on the database of the environmental impact of the solar PV system is essential to be the supporting documentation in developing new measures or tools in the guideline or action plans for their justification to select the best practice and convince the bankers and policy makers.
The Workshops on Economic and Life Cycle Analysis of Solar Photovoltaic Systems in APEC Region toward Low-carbon Society will provide a platform particularly for APEC developing economies to gather all experts from related solar PV industries in sharing solar technologies, project development, LCA and LCCA frameworks and analysis and best practices of project management.
The project is expected to lay down the framework for collaborative undertakings in research and development, deployment of technologies, inventory of existing polices and incentives, gender-fair capacity building, energy contingency plans and other forms of technical assistance. Given the multi-pronged approach to realize the projects’ objectives, resource persons from specialized fields of profession such as but not limited to energy engineering, environmental engineering, technology innovation, economics and finance will be invited to share their expertise and recommendations. The Guidelines on Economic and Life Cycle Analysis of Solar Photovoltaic Systems in APEC Region toward Low-carbon Society is the start off point where APEC Member Economies especially APEC financial ministries can adopt or contextualize its applicability based on their respective circumstances. Documentation will be undertaken during the Workshops leading to the development of a compilation of the environmental impact findings, experiences and best practices of the selected technologies and case studies.
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Beneficiaries and Outputs |
Outputs: The project will create the following outputs:
1) A research paper on framework of developing database inventory for Life Cycle Inventory (LCI) and Life Cycle Cost Analysis (LCCA) of solar PV systems (grid-connected PV system for residential, solar PV farm and off-grid connected PV system);
2) A meeting to discuss a framework of LCA, LCCA and potential sites for the case studies in APEC economies;
3) Report of case studies 1 for grid connected solar PV system for residential home, case study 2 for solar PV farm for power generation in APEC economies and case study 3 for off-grid connected solar PV system at remote area in APEC economies;
4) LCA and LCCA report of case studies detailing findings on the management, technologies, operation, maintenance and financial of selected case study 1 for grid connected solar PV system for residential home, case study 2 for solar PV farm for power generation in APEC economies and case study 3 for off-grid connected solar PV system at remote area in APEC economies;
5) A workshop to discuss the LCA and LCCA reports and to develop a guideline including the action plans for improving the solar PV industries toward low carbon society in APEC economies; and
6) Guideline and action plans.
Outcomes: The project outcomes include the following:
1) Enhanced cooperation among international energy agencies and joint undertakings on R&D and capacity buildings, among others;
2) Report of the LCA and LCCA of the solar PV systems to be utilised as one of the tools or reference for PV industries players and financial institutions in selecting the best practise technologies of solar PV systems in their future investment;
3) Policy recommendation based on the LCA studies, analysis and issues or obstacles raised by the solar PV players;
4) Strong communication highway as the reports and guideline will be made available through various media platforms. Such will create a culture of openness, transparency and good governance among APEC member economies;
5) A dialogue within PV industries players, policy makers and financial institutions on the impact of the environment at the stage of development, operational, costing, and issues or obstacles hindered the industries to rapidly grow in the APEC member economies; and
6) Increase awareness among the PV industries and society on the environmental impact of the solar PV systems.
Beneficiaries:
a) Direct project participants include the APEC Member Economies and their relevant institutions such as Energy Ministries, Finance Ministries, energy authority agencies, international trade organizations, solar energy related academe, bankers and solar PV developers. The participants are expected to have at least science, engineering, environment, management or financial background and have been in the solar related industries for at least 5 years. The selected APEC Member Economies and organizations will be invited in the first meeting based on the selected case studies. However, all APEC economies will be invited for the workshop to discuss the outputs and recommendation of the report/guideline. The involvement of men and women will be equal or at least 50:50 based on their expertise area in solar related area. The solar PV system experts (academe, science and technology centres and research institutes) from various APEC member economies will benefit through the exchange of expertise on methods of technology evaluation, operation and analysis. The workshop participants, ranging from solar PV players, financial institutions to policy makers, can benefit from discussion among experts on data collection and certain issues on development of solar PV systems. APEC Member Economies will have the chance to network, share experience, views, best practices, and policy solutions on matters relating the environmental impact of solar PV system, which can shorten the learning curve and achieve better understanding for recommendations on strengthening the policy measures and tools to facilitate the solar PV industries in the APEC region.
b) Users of the project outputs include solar PV players, bankers, government entities and consumers of APEC Member Economies. Solar PV players such as developers, manufacturers and installers will gain from the project’s sharing of best practices and dissemination of advance technologies, know-how, and skills through workshop programs reinforcing their capacity building activities. Business entities such as bankers will benefit from the project through the establishment of reports and guideline in making decision to select the viability and efficient solar technology with optimum cost and lower environmental impact. Government officials or policy makers will benefit from the project through the establishment of sound and effective policies in introducing the actions plans to reduce aggregate energy intensity by solar PV systems. Research institutes and universities from APEC Member Economies will receive valuable data and workable solutions produced from the project for reference materials in courses like environmental engineering and energy management and economics courses. Consumers of APEC Member Economies such as investors will benefit from the project through the confident level of the technologies available and the advantages of declared minimal environmental impact and favourable cost.
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Dissemination |
a) Form, content, number and format: Workshop materials including introductions to the issue, case studies, LCA results, LCCA findings and overall documents used in the Workshop will be distributed to participants. In addition, results from the Workshop consisting of presentations and interactive discussions of participants will be disseminated in a report. The report will consist of various Workshop materials and discussion results.
b) The format and number of copies for publication: A Report and Guideline on Economic and Life Cycle Analysis of Solar Photovoltaic Systems in APEC Region toward Low-carbon Society will be made available electronically through the APEC Publications Database (publications.apec.org).
c) Target audience: The target audience will include key government entities, the financial institutions, solar PV players, media, the academe, specialists and scholars in solar PV systems, research institutes and centers, regional and international organizations.
d) The Reports and Guidelines will be disseminated among APEC Member Economies.
e) Press release will be prepared on key summaries and cooperation of the workshop. All the materials for dissemination will meet the requirements of the APEC publication Guidelines and copyrights. No intention to sell outputs arising from this project. Any report/publications from the project will meet the APEC IP, Publications and Logo Guidelines
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Gender |
The project will ensure the participation of women in the design and implementation of the project. The project will abide by the principle of equal opportunity for men and women, whereby the selection is based on their expertise as solar PV specialist, resource speakers, and participants. Women will be involved from planning to project execution and monitoring. At least 50% of women involvement will be identified in this project. Women will be participated in executing and implementing the project specifically in technical, financial and policy. If the participation of women falls below 50%, an action will be undertaken such as identify the certified women energy managers and solar PV developers in APEC economies to get them involve as expert, speakers or participants in the meeting and workshop. At the same time, it emphasizes that the transition to sustainable energy by using the solar PV system creates benefits and opportunities for both women and men, such as job creation, market opportunities, and better health conditions.
The project aims to recognize the competence women in the solar PV industries, financial institutions and government entities including the researchers. It is also the aim of the project to integrate women in solar PV related expertise during the workshop as appropriate. It will target significant women participation in the project activities. This project is substantively address the issue of gender as below:
a) The women involvement in energy interventions, leadership and participation in sustainable energy solutions in the transition to sustainable energy for all and to reaching internationally agreed development goals;
b) Women are underrepresented in the energy industry work force, in ministerial positions in the field of energy and are rarely considered as key stakeholders for energy initiatives;
c) Recognize the importance of women in the energy sector and to engage them directly in policy making and project design.
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Work Plan |
Activity |
Deliverables |
Deadline |
Develop Term of Reference (TOR) for appointment of researchers |
TOR |
1-30 Jul 2017 |
Appointment of researchers |
Researchers appointment |
1-15 Aug 2017 |
Identify goal and scope definition of the project |
A draft research paper on Framework of developing database inventory |
15 Oct 2017 |
Identify agenda and venue for Meeting |
Program and venue |
15-30 Oct 2017 |
Identify participants (selected solar PV players, financial institutions and government entities) from APEC economies. Total participant is 11 persons. |
List of participants |
1-15 Nov 2017 |
Organize Meeting for related researchers, industries and stakeholders |
A framework of LCA and LCCA
Selected 3 case studies |
16-30 Nov 2017 |
Develop Term of Reference (TOR) for procurement of consultancy services |
TOR |
1-15 Dec 2017 |
Submit bid document |
Bid documents |
16 Dec 2017-15 Jan 2018 |
Procurement of consultancy services |
Consultancy services procured |
16-30 Jan 2018 |
Survey and site visit to Case Study 1, Case Study 2 and Case Study 3 |
Detailed report for each Case Study |
1 Feb – 31 Mar 2018 |
Analysis by using SIMA Pro and report write-up |
Draft report of LCA and LCCA |
1 Apr - 30 Jun 2018 |
Identify agenda, venue, dinner for Workshop |
Program and venue |
1-15 Jul 2018 |
Identify, secure and finalize attendance of target participants. Total participant is 30 persons. |
List of participants |
30 Aug 2018 |
Organize Workshop 2 to discuss LCA and LCCA findings and develop guideline and action plan |
Recommendation of Report and Guideline |
18 Sep 2018 |
Submission of first draft of the Guidelines to the proponent by the researchers |
Guideline (1st Draft) |
16-30 Oct 2018 |
Circulation of first draft of the Guidelines, for APEC Member Economies comments |
Guideline 1st Draft - Review |
1-15 Nov 2018 |
Submission of final draft of the Guidelines to the proponent by researchers |
Guideline – Final Draft |
16-30 Nov 2018 |
Review and approval of final draft of the Guidelines by APEC Member Economies |
Guideline Presentation |
1 -15 Dec 2018 |
Posting of the Guidelines PH DOE and APEC-EWG and Secretariat Websites |
Guideline Posting |
16-31 Dec 2018 |
The primary output of the project is the publication and dissemination of the Report on Economic and Life Cycle Analysis of Solar Photovoltaic Systems in APEC Region toward Low-carbon Society to the 21 APEC Member Economies, other participants, and non-APEC stakeholders. In addition, workshop data – e.g. presentations, discussion summaries and all note speech – in CD-ROM or DVD format will be disseminated to all participants and public and private sectors. All data circulated and list of contact persons will be available on the APEC website.
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Risks |
The project has the following risks:
a) Project launching delay
Possible risk management strategies: The Project Coordinating Team (PCT) will send the calendar of activities in advance. Invitation letters and follow-up emails will be forwarded to participants and other stakeholders.
b) Difficulty getting data for analysis
Possible risk management strategies: identify and work closely with relevant industrial players and convince the advantage of sharing data for the action plan of the new policy to accelerate the industry to grow in the APEC economies.
c) Low interest in participation for the workshop and data collection
Possible risk management strategies: ongoing consultation with economies on speakers, strategies and agendas etc; clear communication and “marketing” strategy, survey of demand.
d) Lack of interest from Finance Ministries in engaging with the Project.
Possible risk management strategies: close work with targeted participants from Finance Ministries and on-going communication with the top management of the Finance Ministries.
e) Duplication of work of other APEC fora or fora outside APEC
Possible risk management strategies: close consultation with relevant fora; comprehensive research into similar projects; consultation with overseers of precursor projects
f) Project benefits are not sustained beyond project completion and recommendations do not move forward.
Possible risk management strategies: The EWG will be requested to require regular updates under the notable development from PCT and implementing APEC Member Economies. Likewise, the project team will closely collaborate with appropriate APEC fora partners.
g) Delays or untimely preparation
Possible risk management strategies: ongoing consultation, adequate visa application time; early stakeholder/contractor engagement, early adoption of agenda; strict internal deadlines
h) Budget over-run Possible risk management strategies: The PCT will prepare work and financial plan that will serve as guide in the disbursement of project funds and accordingly, quarterly financial reports will be submitted to the Project Overseer (PO).
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Monitoring and Evaluation |
This project’s progress, outcome and impact can be measured by how the recommendation for report and guideline of solar PV system to be used as a support document for financial and environmental impact analysis and future recommendation of incentives to accelerate the solar PV market in APEC member economies.
Information and Mode of Collection:
Information to be collected to assess progress and impact |
Success Indicators |
Mode of Collection |
Workshop Participants’ feedback |
Participants’ approval/acceptability/satisfaction level |
Post-activity survey and random interviews
80 percent acceptability rating through post-activity survey forms to be accomplished by participants |
Date of the completion of The Guidelines |
Timely completion of the Guidelines |
Gantt Chart |
Completion of the activities |
Number of workshop participants
Summary Reports Completed |
Attendance Sheet
Reports Review
Periodic review; Gantt Chart |
Fund disbursement |
Full fund utilization |
Financial Reports |
Project Coordinator Team Performance |
Participants’ approval/acceptability/satisfaction level |
Post-activity survey and evaluation |
Gender Impact Measurement |
Gender-fair participation
30 -40 percent of expected participants are women |
Participants evaluation or Post-activity survey and random interview |
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Linkages |
This project will seek active cross-fora collaboration with appropriate tax and rebate incentives policy experts from APEC Finance Ministries through the APEC Senior Finance Officials group. The Guideline and action plan will be open-accessed among both APEC and non-APEC economies via the APEC website. This in-directly attract the potential investors to explore the solar PV related business opportunity in the APEC region.
The lessons learnt from the existing projects eg. EWG 21 2015A - Long term Reliability Study of PV Systems for Installation on Islands is the delay of the subcontractor appointment due to the unfamiliar with APEC project application process. In this regards, the PO and PD have to understand the APEC project management process at the start of the project and work concurrently all the related activities that is expected to be delayed. The project has different focus area of PV system as it is more looking on the maintenance of the systems whilst this project proposal is aim to look on the environmental impact and the economic of the existing solar PV systems. The other lesson learnt from the other existing project (EWG 23 2015A – Best Practices for Developing the Green Energy Smart Farm in the APEC Region) is the difficulty in the selection of demonstration site and the longer time needed for data collection. Based on the difficulties, the selection of case studies in this project will be undertaken according to the schedule and the best existing solar PV systems in the APEC economies will be identified. The researchers will be appointed directly for the data collection. In comparison, the existing project is aims to demonstrate a best practical model for developing the green energy smart farm with the small-scale standalone distributed renewable energy system, and also introduce an ESCO financial mechanism to benefit the farmers’ family directly in the APEC Region, especially in APEC’s developing economies. Nonetheless, this project proposal will cover various type of solar systems such as solar farm, intergrated PV system and off-grid solar system. It will cover the on-grid and off-grid solar PV systems. The guideline and the action plan to accelerate the PV industries will also develop in this project.
The 21-member economies are the main beneficiaries of the Workshop. The Guidelines which is the main deliverable of the project will assist the APEC energy decision makers and APEC Finance Ministries in formulating policy measures on energy efficiency and in adapting best practices and initiatives applicable towards low carbon society.
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Sustainability |
The project is expected to have profound and long-term impact on related APEC fora and APEC as a whole, even after project completion. Substantial contribution can be had through the project in strengthening the energy efficiency by solar PV business sector in APEC economies via implementation of incentives and measures based on the Guideline and action plans delivered by the project. This is to support and promote energy efficiency and sustainable communities as stipulated in the Energy Working Group’s Strategic Plan 2014-2018.
Here, the project builds on and strengthens existing APEC work. For instance, the Energy Working Group (EWG) may continuously carry out sustainability initiatives. APEC Member Economies are expected to continuously carry forward the results and lessons of the project after its completion, since Guidelines on Economic and Life Cycle Analysis of Solar Photovoltaic Systems in APEC Region toward Low-carbon Society will be drawn up to assist APEC Member Economies especially in formulating the new policies or incentives to reduce the environmental impact of solar PV system. The network of the solar PV players and financial institutions in APEC region for multilateral and regional cooperation mentioned under the section on Ouputs will be sustained via an online group. Workshop report consolidating best practices and successful stories from both public and private sectors will serve as reference for capacity building activities. To maximize the benefits of the project, continuous follow-up may be undertaken and appropriate revisions in the Guidelines may be deliberated upon by the APEC Member Economies and thereafter agree to integrate the same in the Guidelines. The continuous updating of the Guidelines will ensure that contents remain relevant and that future Economies will be able to benefit from knowledge and lessons learned. Regarding the Energy Working Group’s Strategic Plan 2014-2018, the project of solar PV system is included in the objective 2 which is Promote Energy Efficiency and Sustainable Communities with the indicator facilitate the exchange of best low carbon policies, practices and tools among APEC Member Economies to promote the development of sustainable communities across the region. After 3 years, Malaysians will survey and review the implementation of the Guideline and the action plans to APEC member economies. This survey will report on progress as well as on policy and program measures undertaken by member economies. The data on the total solar PV system installation in APEC region will also be collected after 3 years to measure the impact of the action plans imposed by the project. As part of sustainability initiatives, the Project Overseer is expected to provide regular updates to Malaysiaan EWG under the Notable Development Agenda of the EWG.
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Project Overseers |
Dr. Norasikin Ahmad Ludin is a Research Fellow at Solar Energy Research Institute (SERI), Universiti Kebangsaan Malaysia (UKM). She obtained her PhD in Chemistry (Dye-sensitized Solar Cells) from University of Wales, United Kingdom in 2012. Her expertise is solar cell technologies, renewable energy policy, life cycle analysis (LCA) and life cycle cost analysis (LCCA) of the solar PV system. She has produced and presented more than 60 publications in high impact journals and conferences. She also supervised more than 20 local and international postgraduate students (MSc and PhD) in related renewable energy areas. In term of research and development, she has involved in the field of renewable energy for more than 18 years including the international and government projects. She acts as a project leader and co-researcher for external and internal grants related to solar energy with cumulative total of RM4 million (2011-2017). She was also previously the Project Manager and Coordinator for Biomass based Power Generation and Cogeneration (BioGen –RM40 million) under the UNDP/GEF in promoting and formulating RE policy, tariff and financing in Malaysia (2002-2007) and Country Focal Point (Biomass for Electricity Generation) for ICRA Project RESSN Sub-sector Network (2004-2005). She also has a research linkage related to solar energy and life cycle analysis with various local and international institutions such as Centre of Innovative Nanostructures and Nanodevices (COINN) at Universiti Teknologi Petronas (UTP), Chemistry Department at Universiti Malaya (UM), Malaysia-Japan International Institute of Technology (MJIIT), Life Cycle Sustainablity Assessment Laboratory, King Mongkut University, Thailand, Centre of Ecole Polytechnique Federale Lausanne (EPFL), Switzerland and Fraunhofer Institute for Solar Energy System, Germany. For the community engagement, she was involved in developing a Solar Industry Roadmap (MIGHT, 2015), R & D for Solar Energy Roadmap (MOSTI, 2016), a country representative for the SEA-EU-NET II Project “Development, Planning and Decisions: Impact of Water, Energy and Food Nexus in Mekong Region” (AIT, 2015), a country representative for developing Renewable Energy Curriculum for United Nation University (UNU, 2012) etc. For a professional qualification, she is a Certified Energy Manager (CEM) by Asean Energy Management Scheme (AEMAS).
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Cost Efficiency |
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Drawdown Timetable |
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Direct Labour |
Direct labor funded by APEC will consist of the consultant, researchers and clerk. The consultant will be selected competitively via an APEC Request for Proposals. The researchers will be appointed based on the specific qualification for the activities.
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Waivers |
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Are there any supporting document attached? |
No
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Attachments
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