A grant application for energy efficiency improvements submitted to the Canary Islands Government by the Mogan Mall Owners' Association, which Maspalomas24H has obtained, is at a critical juncture due to a series of serious inconsistencies and omissions detected by the evaluating administration. The project appears to be built on questionable administrative and technical foundations, jeopardizing the viability of the requested aid.
The first red flag is raised by the complete absence of statutory documentation. The homeowners' association has failed to submit its Articles of Incorporation, a fundamental document that establishes the legal personality and legitimacy of the applicant entity. Without this cornerstone, the association's very existence before the administration is questionable, and therefore, so is its capacity to receive public funds. The application requires the submission of the registered Articles of Incorporation of the Homeowners' Association to rectify this deficiency.
This lack of documentation is compounded by a tangle of technical inconsistencies that undermines the credibility of the presented energy efficiency project. The building's energy performance certificate, in its current and duly registered state, reports a primary energy consumption of 911.600 kWh per year for the entire property. However, the detailed project report blatantly contradicts this figure, declaring an annual final energy consumption of 1.800.000 kWh/year. This initial declaration is clearly a dramatic underestimation of actual consumption, since a standard conversion would place the equivalent non-renewable primary energy at around 5.263.200 kWh/year. The discrepancy between the reported primary energy and the declared final energy is of an almost unbelievable magnitude, suggesting that the starting point of the improvement project is either flawed or deliberately manipulated.
Given this situation, the administration demands a clear explanation or, failing that, the submission of a new study containing the expected results for primary and final energy savings and reduction of greenhouse gas (GHG) emissions. The option of providing a non-simplified energy efficiency certificate, which more accurately reflects the existing facilities, including lighting, cooling, and pumping, is also being considered.
The contradictions are not limited to the initial energy consumption figures. The detailed report attempts to justify a minimum 30% reduction in final energy consumption, a threshold frequently required for the approval of this type of subsidy. However, the calculations presented do not support this claim. The report states a total consumption for the shopping center of 1.800.000 kWh/year and attributes a consumption reduction of 160.859 kWh/year to the self-consumption of the photovoltaic plant. This figure represents a modest 8,9% reduction in the shopping center's total annual consumption, a percentage far from the required 30% target.
To try to bridge this gap, the report introduces a further inconsistency by attempting to recalculate the reduction based on primary energy, reverting to the erroneous initial figure of 911.600 kWh/year as the initial consumption, a figure that is then contradicted by its own declaration of final energy consumption of 1.800.000 kWh/year. This interplay of conflicting figures and disjointed data creates a lack of technical traceability that makes it impossible to validate the actual energy improvement.
Finally, the inability to justify energy savings makes it impossible to quantify the reduction in greenhouse gas (GHG) emissions. It is necessary to indicate the RCR29, which corresponds to the total estimated GHG emissions for the supported entities or processes. In the submitted report, the community only provides the avoided emissions attributable to the photovoltaic production system (124.820,000 kgCO2eq/year), omitting the essential calculation of the building's total emissions in its current state, which is necessary for comparison.
In short, the Mogan Mall project is a statistical house of cards. The lack of bylaws, fundamental contradictions between the energy performance certificate and the project report, and the inability to demonstrate a 30% reduction in final energy consumption or emissions place the application in an extremely precarious position. The administration has issued an ultimatum: clarification must be provided, or a study must be submitted outlining the expected savings that rigorously and coherently justifies a reduction of at least 30% in emissions compared to the building's current state. Otherwise, the project risks being rejected, revealing an attempt to access public funds without the necessary technical support.
