LCA (Life Cycle Analysis)
If the candidate wishes to use optimized GWP coefficients, and to use what the CRE calls “Method 2”, a Life Cycle Analysis has to be carried out at the considered production sites. This is an overall assessment of the environmental impacts of the product realized, by quantifying all that’s involved in the manufacture of the product (raw materials and energy), and all that’s released (waste, gaseous emissions, liquid by-products…). All these are governed by ISO14040 standard, required in the CRE specifications.
The LCA must undergo an independent Critical Review from a design office that has already carried out LCA on the production chains of PV modules. This critical review should be carried out in line with the Life Cycle Assessment. The critical review and the LCA must then be sent to ADEME for verifications, no later than 3 months before the deadline for submission of tenders. Within one to two months, ADEME sends a certificate that will confirm the new GWP coefficient, while mentioning the reference(s) of the concerned modules, as well as their manufacturing site(s) (see Figure 1)
In addition to the calculation itself, a detailed documentary process must be followed (see Figure 1), in order to obtain the ECS certificate issued by an accredited body (e.g. CERTISOLIS). The latter will verify the information used for the final calculation of the carbon impact, as well as the credibility of the supply and the considered production sites.
It is therefore ESSENTIAL that the manufacturer provides the most complete and clear information possible.
If the information provided is insufficient or not demonstrated, the certifying body shall issue “provisional” licenses, with reservations. Developers can apply for tenders with such licenses. However, if the project is awarded on the basis of a provisional license, the candidate will have to request the modules’ supplier to provide supplementary evidence in order to withdraw the reservation within 6 months of the project award, otherwise the file will be canceled (for the CRE4 period). We will see later that the candidate therefore needs to opt for a proven existing solution, which is equally in line with the market, in terms of availability.
The documentary process for obtaining ECS license from the certifying body is described below.
Fig. 1: The ECS documentary process. Source: CERTISOLIS
The total time is very variable, depending on both the efficiency of the collection, as well as the number of LCAs that the manufacturer has decided to perform, and the location of the production sites (dispersed or not). Nevertheless, it can be said that if one decides to carry out one or more LCAs, the ECS license will not be issued before at least 6 months.
SYNAPSUN invites manufacturers who want to position themselves on the French AO CRE, to invest well upstream in a LCA approach. We can help you analyze your supply chain, identify the ideal supply scenario, conclude with a competitive advantage or not, and assist you in your dealings with consulting firms and certifying bodies.
LCA: Life Cycle Analysis
GWP: Global Warming Potential
ECS: Evaluation Carbone Simplifiée (Simplified Carbone Footprint)
ADEME: French Environmental and Energy Agency
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