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IEA_Energy_Dataset

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Georgia has the potential to become a significant player in the global bioenergy market with a focus on sustainability and job creation.
The state's agricultural sector is well-positioned to provide the feedstocks for this industry, while its manufacturing base can supply the equipment and technology needed to process these feedstocks into biofuels.
Bioenergy production can also contribute to Georgia's energy security by reducing its reliance on imported fuels and creating a new domestic industry that supports in-state job creation and economic growth.
Additionally, the production of biofuels from agricultural residues or other organic waste materials can help reduce greenhouse gas emissions and mitigate the environmental impacts associated with traditional fossil fuel-based energy systems.
Georgia can achieve these benefits while also promoting sustainable agriculture practices and supporting rural development by creating new markets for agricultural products and providing opportunities for farmers to diversify their income streams.
The purpose of this roadmap is to provide a comprehensive overview of bioenergy development in Georgia.
This report has been structured to provide an introduction to the key institutions and stakeholders involved in bioenergy in Georgia, followed by an analysis of the current policy landscape for bioenergy.
To address the challenges facing the sector, it is essential to understand the supply side of biomass in Georgia, as well as its consumption patterns.
Modernising biomass consumption is crucial to ensure that the potential benefits of bioenergy are realised.
Ensuring biomass supply sustainability requires a combination of measures to promote sustainable forest management and the use of agricultural residues.
Sustainable bioenergy in Georgia: A 2030 vision highlights the need for a coordinated approach to achieving this goal.
Conclusions from this report highlight the need for a sustained effort to develop bioenergy in Georgia.
Wider considerations associated with biomass heating in Georgia include the potential for increased demand and the need to ensure that any expansion is sustainable.
the international energy agency ie has produced this sustainable b ioenergy for georgia roadmap as part of the eu4energy programme a five year initiative funded by the european union eu4energy s aim is to support the development of evidence based energy policy design and data capabilities within the countries of the eastern partnership and central asia including georgia
the central purpose of this document is to guide policymaking at all levels related to the supply and sustainable use of biomass for producing bioenergy in georgia and to act as a precursor for a national bioenergy strategy the government of georgia is therefore invited to consider incorporating the actions needed to modernise the use of biomass resources as outlined in this roadmap into a dedicated bioenergy strategy
although b ioenergy is a broad issue encompassing a wide range of fuels technologies and end use applications this roadmap s primary focus is on increasing the sustainability of biomass based heating in georgia to mitigate the social and environmental impacts of inefficient firewood use
this roadmap aims to help georgia formulate its integrated national energy and climate plan nep for 2030 as part of the ministry of economy and sustainable development s wider state energy policy in addition to other relevant strategies and plans across all levels of government it is also intended to support and guide the activities of other key stakeholders notably nongovernmental organisations ngos providers of development financing and the private sector
current georgian practices are summarised for these two areas and examples of international best practices in bioenergy from ie member countries are offered the roadmap then outlines the policies technologies and management practices needed for georgia to harness its biomass potential securely and sustainably these are presented as a set of overarching policy actions underpinned by detailed biomass supply and consumption recommendations
the recommended actions are compiled as a coordinated package of measures to be implemented during 2020 25 to modernise georgia s bioenergy industry and make it sustainable by 2030 the social economic and environmental benefits for the country are summarised as a vision of georgia s modern bioenergy industry in 2030
As bioenergy falls under the jurisdiction of multiple government ministries and departments, a co-ordinated approach to policymaking, governance and market development is required.
The Ministry of Economy and Sustainable Development (MoESD) has overall responsibility for renewable energy policy through its Energy Department. It is also responsible for implementing energy efficiency measures in the energy, industry and transport sectors, and it develops technical regulations for transport and implements overall transport policy.
The Georgian Energy Development Fund (GEDF) is a state-owned company under the jurisdiction of the MoESD. Created in 2010, the GEDF’s key mission is to promote the development of commercially viable renewable energy projects. The GEDF supports project development by conducting preliminary research, project feasibility assessments and initial environmental impact assessments, and it facilitates contact between project developers and investors.
The Ministry of Environmental Protection and Agriculture (MEPA) is the highest executive body in charge of developing national forestry policies. MEPA has overall responsibility for strategic planning and policymaking regarding forestry and agricultural resource management. It also defines and implements Georgia’s national climate change policy, issuing environmental permits for energy sector projects and defining and implementing air quality policy.
The Public-Private Partnership (PPP) Agency is a new body created following adoption of the PPP Law in May 2018. The PPP Agency’s mandate is to lead the development and implementation of public-private cooperation projects. PPP arrangements could prove effective in reducing the investment risks of early-stage bioenergy projects and could support modern bioenergy heating projects in public buildings.
The Ministry of Regional Development and Infrastructure is in charge of municipal capacity-building, which will be essential considering the new skills associated with modern heating solutions for public sector buildings.
The National Statistics Office of Georgia (Geostat) compiles official energy statistics. It also conducts and analyses household energy consumption surveys, which are an invaluable source of quantified information on the final consumption of biomass. The first of these was conducted in 2017, and the next is scheduled for 2022.
As these organisations proactively develop sustainable bioenergy policy proposals and project pilots, the modernisation of Georgia's bioenergy consumption will require their ongoing support.
Private sector activity in the biomass industry currently consists of fragmented entrepreneurial initiatives. The Biomass Association of Georgia was established in 2017 with UNDP support. Its remit is to create a common and effective platform for co-operation as well as information- and knowledge-exchange in the area of biomass to accelerate biomass policy deployment and market development.
To integrate bioenergy into energy policy development and create the market conditions for growth of a modern bioenergy industry, the responsibilities of all relevant stakeholders must be clearly defined. This requires co-ordination among the public and private sectors and the various levels of government.
No single body currently has overall responsibility for a future bioenergy strategy. Considering the various cross-sectoral aspects of bioenergy, a co-ordinating body directly responsible for promoting biomass supply sustainability and efficient resource use is needed. Such an agency could be integrated into an organisation with a wider renewable energy remit.
Despite the widespread use of solid biomass for residential heating, bioenergy is not broadly incorporated into energy policy. Furthermore, no specific support measures are in place to facilitate renewable heat production, including by using modern biomass fuels and efficient technologies.
Since Georgia’s accession to the Energy Community Treaty, the country has begun to create a legal and regulatory framework to comply with the EU acquis. This includes introducing national legislation to harmonise its energy market with the EU Renewable Energy, Energy Efficiency and Energy Performance of Buildings directives.
Under the Energy and Water Supply Law, the MoESD is responsible for a comprehensive State Energy Policy that addresses all aspects of the energy sector. The law covers all forms of energy, including biomass.
Georgia’s parliament passed a Renewable Energy Law in December 2019 that has provisions for setting renewable energy targets and monitoring progress in meeting them. It also provides a framework for introducing renewable energy support mechanisms; although these are in development, there are currently no details on whether bioenergy technologies will be included.
The several articles of the Renewable Energy Law that make specific reference to bioenergy: Outline that Georgia’s National Renewable Energy Action Plan should implement policies to develop existing biomass resources and mobilise new ones. Ensure adequate certification of technologies, including biomass boilers and stoves.
Consider the ability of renewables-based district heating to meet energy objectives by 2030, and to facilitate infrastructure development. Stipulate biannual reporting of renewable energy consumption, including the bioenergy portion, and any associated changes to consumer good prices and land use.
Georgia is preparing its NECP for 2021-30 with an outlook to 2050 to ensure consistency with long-term EU, United Nations Framework Convention on Climate Change (UNFCCC)
All of Georgia’s forests are currently under state ownership and are administered according to the Forest Code of Georgia, a new version of which was adopted in 2020 under the authority of the Forestry Agency. The National Forestry Program (NFP) facilitates stakeholder dialogue to support forestry sector reform through a working group on alternative energy sources and sustainable firewood use.
Georgia’s parliament has adopted a National Waste Management Code and the government has approved a national waste management strategy and action plan until 2030. These prescribe less landfilling of biodegradable wastes, with waste sorting starting in 2020 and creating opportunities for energy-from-waste (EfW) project development.
Georgia's domestic energy production met less than 30% of its demand in 2018, and almost all the fossil fuels the country used were imported from neighbouring countries. Bioenergy accounted for 6% of total primary energy supply and provided one-fifth of all domestic energy production, making it the second-largest indigenous energy source after hydropower.
Georgia's diverse climatic conditions and substandard building stock mean there is strong seasonal demand for building heat, with most heat consumed between October and March. The types of heating fuels used differ between urban and rural areas. Natural gas is a major source of heating for households in urban areas (accounting for just under 60% of the country's 3.7 million inhabitants), but access to natural gas is not widespread in rural areas, where energy poverty is most prevalent.
Of Georgia's 1.2 million households, almost half (around 500,000) use biomass as a fuel. It is consumed primarily as fuelwood for heating, and to a lesser extent for cooking. Around 80% of consumption is in the rural areas that are home to just over 40% of Georgia's population.
Forests cover around 40% – some 3 million hectares (ha) – of Georgia’s land area. The y are more than 90% natural in origin and almost universally under state control. Georgia’s rural population relies on forestry biomass for its energy needs due to both a lack of affordable alternatives and ingrained cultural practice.
Fuelwood demand far exceeds the sustainable level of supply, however, as Georgia’s 2018 energy balance indicates 1.4 million m3 of consumption. Only 343,000 m3 of the social-cutting allocation was consumed that year, indicating that around 75% of consumption was unaccounted for; a significant proportion is illegal and unsustainable.
Social-cuting licences in remote areas are often underutilised, as illegal harvesting activity in the vicinity of settlements is favoured because it entails lower transport costs. Given data uncertainties, the level of illegal consumption could be even higher.
Forest degradation in accessible areas (e.g. near roads and settlements ) also results in biodiversity loss and lower CO2 uptake. The estimated annual cost of deforestation in Georgia is between GEL 54 million and GEL 93 million (USD 17-29 million) (World Bank, 2015). From a social perspective, overreliance on firewood raises the risk of fuel poverty in areas where supply is degraded.
National-level data on the state of forests is currently insufficient, hampering long-term forest management planning and the tracking of deforestation. The National Forestry Agency bases plans for long-term management on data gathered from regular forest inventories undertaken in 2013. As of 2020, only one-quarter of territories under National Forestry Agency management had updated their forest management plans for the next ten years.
Georgia has the potential to utilise a wider range of biomass wastes and residues from forestry, agriculture, industrial and municipal sources for energy purposes. This would diversify domestic heating fuel supplies, both easing pressure on forestry resources and supporting the rural economy. These resources are largely untapped at present, as the use of biomass wastes and residues is not subject to any formalised government policy or industrial strategy.
Around 80% of Georgia’s rural households consume wood for energy purposes. Basic and inefficient heating appliances fuelled by firewood are their main heating system, and almost one-quarter also use fuelwood for cooking. Furthermore, significant quantities of firewood are consumed in the public sector (e.g. in educational buildings, hospitals and offices) and the private sector (e.g. in restaurants and hotels).
The low energy efficiency of the building stock and of heating appliances heightens demand for fuelwood. Three-quarters of dwellings were constructed between 1951 and 1990, and findings from a recent World Bank study indicate that 85% of buildings surveyed had no roof or wall insulation, and almost one-third of the households consulted indicated their homes are cold and damp during the winter.
In most households, only a small area of the total building is heated. Underheating residential and public buildings has significant health, social and economic impacts. In 2018, 4% of Georgia’s deaths were attributed to underheating, with the corresponding economic cost estimated at 3.5% of the country’s GDP.
Furthermore, Georgia’s particulate matter (e.g. PM2.5 and PM10) concentrations are significantly above the recommended average in both urban and rural areas. Although there is a range of causes for this, household combustion of firewood (particularly wet wood) in inefficient appliances is a notable contributor.
Indoor air pollution from inefficient combustion of solid biomass and poor ventilation also has serious human health consequences, causing 2.5 million premature deaths worldwide each year. The mortality rate attributed to air pollution (indoor and outdoor) in Georgia is around 100 people per 100,000, with the significant economic impact estimated at 2% of the country’s GDP.
Biomass use in Georgia has implications not only for the energy sector, but far beyond. As the principal fuel used for household heating in rural areas, biomass is an important part of Georgia’s energy system. There is considerable scope to improve biomass supply sustainability and the efficiency of its consumption through better heating and cooking appliances, and to develop a modern bioenergy industry based on upgraded biomass fuels produced from diverse waste and residue feedstocks and potentially energy crops.
These developments would help counteract the negative impacts of the current unsustainable use of Georgia’s forestry resources, as well as facilitate modern bioenergy applications to support some of Georgia’s economic, environmental and social goals. These include: Improving energy security by maximising consumption of domestic energy resources rather than increasing reliance on imported natural gas and other fossil fuels. Ensuring the sustainable use of natural forest resources and the integrity of the natural environment and reducing the risk of natural disasters such as floods and landslides. Expanding formalised employment in biomass fuel supply in rural areas. Reducing the health impacts of indoor air pollution.
Fundamentally changing current practices in biomass supply and consumption is complex and requires a co-ordinated effort across government ministries and departments, the private sector and international development agencies. A more comprehensive set of policies, support schemes and regulations will be required to establish a modern bioenergy industry.
To facilitate the development of such a strategy, this roadmap focuses on: Ensuring biomass supply sustainability; Modernising the consumption of biomass fuels.
However, while improvements in these two areas are important, these alone will not be sufficient to remedy the environmental issues associated with the management of Georgia’s forestry resources, or social problems such as fuel poverty and indoor air pollution. This will also require comprehensive action in a number of areas outside the scope of this roadmap, such as raising the energy efficiency of the housing stock and supporting the installation of a wider range of sustainable heating systems such as solar thermal panels and heat pumps.
It may also be necessary to evaluate the extent to which public investments affect the achievement of sustainability goals. Other areas that warrant further assessment are fossil fuel subsidisation (e.g. related to natural gas infrastructure and consumption) and policies related to waste management.
Employing best-practice forestry management can ensure biomass fuel supplies while avoiding deforestation and its associated environmental impacts. Furthermore, using waste and residues can diversify the types of biomass used as heating fuels and reduce pressure on Georgia’s forestry resources, while also providing rural job creation opportunities and an avenue for managing municipal, agricultural and forestry wastes and residues.
Georgian context: This section provides an overview of the different biomass resources available in Georgia. Forestry management and forest residues: There is considerable scope to improve the management of Georgia’s forests, and the production of sustainable biomass fuels.
Georgia's current "social cutting" policy allows the population to source a designated volume of fuelwood from the forest. However, this policy and the wider issue of illegal firewood harvesting is problematic for many reasons.
Unqualified people with inadequate equipment often carry out firewood sourcing, which damages the forest ecosystem, and a lack of supervision heightens the risk of accidents.
Black market activity deprives the state of revenue and diverts timber suitable for higher-value uses to lower-value energy production.
It hinders the market prospects of more sustainable fuels, as the extra collection and processing costs for wastes and residues cannot compete with low-cost unsustainably sourced logwood.
The updated Forest Code proposes abolishing the social-cutting system by 2023 – a key step to resolve some of the issues outlined above. Nevertheless, given citizens' reliance on fuelwood for residential heating and cooking, affordable alternative heating fuels must be made available to reduce fuel poverty and maintain social stability.
One solution is to maximise the use of available forestry residues, such as those that have accumulated in forests after illegal forest harvesting and those arising from environmental events, as well as biomass made available through forest management practices not currently being undertaken.
Residue recuperation could provide around 8 PJ of material annually to produce upgraded biomass fuels – more initially, as these unexploited resources have accumulated over time. However, as this assessment includes residues arising from illegal forest activities, their successful phaseout could reduce this energy potential by approximately half.
Challenges associated with using these forestry residues include collection costs given the difficult terrain in many areas, logistics because of limited road networks in some areas, and the lengthy time required for residues to dry to a suitable energy content for upgrading.
overall however very little agricultural residue potential has been realised because of collection and logistics challenges that make it difficult to ensure reliable fuel supplies residues are produced seasonally for example waste biomass is available from spring to autumn while heating fuel demand is highest in the autumn and winter requiring fuel storage and raising costs
consequently agricultural residues either remain uncollected or in some cases are burned in the field eg wheat straw and vine trimmings not only does this not valorise their fuel potential it produces particulate matter emissions that deteriorate air quality field burning can also unintentionally destroy windbreak trees which is detrimental as the soil in many parts of georgia is susceptible to wind erosion
wine production in georgia is expanding rapidly vine trimmings are produced seasonally usually during the three-month spring period and there is no industry standard for their sustainable disposal they are commonly burnt as transportation and storage costs outweigh their value for fuel production in the current market context if this dynamic were to change vine-pruning residues could be converted to heating fuels through baling drying and size-reduction processes eg shredding following this they could also be upgraded to pellets
there is potential for wine producers to either produce fuels or to avoid the trimming collection and disposal costs that would otherwise be borne by the winery enter into a mutually beneficial relationship with fuel producers to take trimmings for fuel production costs can be around gel 100/ ha usd 30/ ha for trimming and collection with additional disposal costs in 2020 a project was initiated in the telavi municipality to test equipment for collecting and processing vine clippings with the goal of providing heating fuel for two municipal kindergartens
aside from difficulties in establishing supply chains further challenges need to be overcome to accelerate the development of agricultural residue-based fuels so that they can make a notable contribution to the biomass fuel market
energy crops can further diversify the supply of biomass fuels and georgia appears to have favourable climatic conditions for the cultivation of certain species notably poplar which grows well on poor-quality land unsuitable for food crops and alder species
Another potential benefit of energy crop plantations is rural job creation, as people are required for planting, maintenance and harvesting, as well as for fuel production. The number of jobs (e.g. jobs per hectare of land) will fluctuate over a plantation’s lifetime, however, with most employment opportunities arising in the planting and harvesting phases.
International experience shows that developing markets for energy crop production can be difficult. From a production standpoint, securing investments to establish plantations is challenging because an initial investment is required to purchase and clear the land and plant the crop, and the subsequent delay before any revenues are realised is long (for poplar trees, the first harvest could be five years after planting). Some economic support from the government and offtake commitments for fuel are therefore likely to be needed to kick-start plantations.
Georgia has over 60 registered landfills, around 30 unofficial ones in villages without formalised waste management services, and numerous illegal dumping areas. There is considerable scope to modernise waste management and reduce associated environmental impacts to land, water and air, and the release of methane from waste disposal. With donor and international financial institution (IFI) support, old landfills are being closed and remediated, and new landfills compliant with EU requirements are being constructed.
A bioenergy roadmap for Georgia has been developed to provide a framework for sustainable bioenergy development in the country. Implementing these requirements has proved challenging so far. While many municipalities are integrating provisions from municipal waste management plans, actual progress is currently limited. However, as successfully meeting these targets will enhance the quality of waste management and facilitate EfW project development, Georgia has adopted a National Waste Management Strategy for 2016-2030 to guide implementation.
Unfortunately, Article 2 of the Waste Management Code specifically excludes non-municipal biomass materials, e.g. agricultural/forestry residues and sewage, which permits informal biomass residue utilisation and is not conducive to best-practice use of these resources.
Around 70% of forest wood growth is felled each year, and the remainder is untouched, providing ongoing carbon uptake. All elements of harvested trees are used, with the highest-value material used for lumber, pulp and paper products, and other wood products. Higher-value stemwood is generally not used for energy, with the exception of small trees removed from forest management operations (e.g. through clearing and thinning), or when it has been discarded and cannot be used for industrial purposes.
Harvested areas are replanted, with this form of active management leading to higher growth than in mature forests and therefore greater CO2 uptake. Furthermore, sustainably managed forests are more resistant to forest fires and infestations, reducing the risk of significant CO2 release that can result from such events.
Because the low energy density and form of vine cuttings impede direct utilisation in small-scale combustion systems, initiatives in Europe have focused on energy densification through pelletisation.
Energy recovery from municipal wastes offers multiple benefits compared with landfill disposal, as indicated by its higher position in the waste management hierarchy.3 EfW facilities reduce waste volumes significantly and require less land area than landfill sites.
Sustainable Bioenergy for Georgia: A Roadmap. In the European Union, almost 30% of waste produced in 2017 was used to produce energy. However, several countries achieved higher shares, with four over 50%, Denmark, Sweden, Finland, and Norway.
There is a close correlation between waste disposal costs and EfW deployment, as all four countries have landfill taxes and certain forms of landfill bans, e.g., for organic material. EfW projects can be highly sustainable. For example, the city of Utrecht in the Netherlands has a 30-megawatt thermal biomass plant that provides heat to 50,000 households and businesses through a district heating system.
The key policies for biomass supply sustainability are: Actively implement the updated Forest Code drawn from best-practice sustainable forestry management principles adapted to the Georgian context. Promote an appropriate transition away from the social-cutting policy, with measures that ensure affordable and sustainable alternatives to fuelwood to avoid increasing fuel poverty. Establish a regulatory framework for the collection and disposal of commonly produced agricultural residues, which prohibits in-field burning and facilitates sustainable energy uses.
With international donor support and using best-practice examples, enact replicable sustainable biomass fuel and waste management pilots to identify those with most promise.
Specific policies and actions for consideration Forestry: Expand the number of Forestry Agency business yards (for forestry residue collection depots) and potentially as locations for fuel upgrading, with equipment purchased through PPPs or co-operatives. Consider transferring some current harvesting and fuelwood jobs in rural areas to a sustainable biomass industry.
Agricultural residues: Obtain international donor assistance to aid ‘technology leapfrogging’ to the most appropriate equipment and processes to combust straw and other agricultural residues.
Energy crop plantations: Support the establishment of a ‘showcase’ energy crop plantation, with the aim of guaranteeing a future off-take of fuel produced for public sector heating demand.
Wastes : Adopt policies to increase the cost of (or prohibit) landfill waste disposal, such as banning the landfilling of certain materials or imposing landfill taxes, to encourage higher-value end uses, including EfW processing. Enact the collection of urban green wastes and source segregation of municipal solid waste (MSW) to improve waste management and boost supplies for fuel production.
Assess the amount of waste and residue feedstock available for biogas production and determine the contribution biomethane could make to natural gas supplies. Develop a regulatory framework that covers biomass waste and residues and requires disposal routes in keeping with the waste management hierarchy (including energy recovery).
The single most effective measure to improve the sustainability of biomass use in Georgia is to transition to more efficient heating appliances. Using more sophisticated biomass heating systems that combust upgraded fuels has multiple benefits. First, replacing the basic systems used for biomass combustion with improved heating appliances would offer more controlled and complete combustion, which, coupled with adequate ventilation (e.g. a flue), would reduce indoor air pollution and consequential health impacts.
Thermal comfort and automation would also be improved. Second, higher-efficiency modern systems using upgraded fuels means less fuel for the same heat output, reducing pressure on Georgia’s fuel supply and forestry resources. Furthermore, programmes to instal l improved biomass heating systems and develop
Basic firewood heating stoves are commonly used. The y generally have a low efficiency of 25-35% (GIZ, 2019), although stove efficiency is not verified through testing. Their design is simple, with no mechanism to control air inflow, and they are not airtight. Consequently, combustion is uncontrolled and occurs quickly at high temperatures, and the lifespan of basic stoves is relatively short at around five years. Open fires, which are even less efficient, are also commonplace.
Combustion efficiency is hindered by many households using wet firewood to slow the pace of combustion. In a residential context, it is advisable that solid biomass fuels not have a moisture content >25%, as higher moisture levels reduce the combustion temperature and result in greater smoke formation and health-damaging particulate matter emissions.
The single most effective measure to improve the sustainability of biomass use in Georgia is to transition to more efficient heating appliances. Changing to more modern heating stoves and boilers is required for two key reasons: first, to increase the efficiency of fuel combustion; and second, to facilitate the use of drier wood fuels and (preferably) upgraded fuels produced from a diverse set of biomass feedstocks. Both would reduce pressure on Georgia’s forestry resources from residential heat demand.
Improved wood stoves with combustion chambers and air inlet controls are produced domestically on a small scale and in a nonstandard manner. They are likely to be more efficient than the basic stoves currently used.
Efficient stoves can reduce firewood consumption by around one-third compared with a 25%-efficient appliance, while a stove with 75% efficiency would cut firewood consumption by two-thirds compared with the basic alternative.

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IEA_Energy_Dataset

Dataset Details

Dataset Description

The dataset is energy-related, covering topics of Oil, Coal, Wind, Hydrogen, Bioenergy, Electric vehicles, Heating, Building envelopes, Methane abatement and Chemicals.

Dataset Creation

Source Data

The dataset sources are reports from the webiste of International Energy Agency(IEA).

Data Collection and Processing

We scraped free open reports from IEA's website. The reports are all pdf files and then we used the Llama 3 model to extract useful texts.
After getting the raw text, we have the two following steps:

Remove too short sentences(e.g length < 100)
Use Monocleaner to detect disfluent sentences. Each sentence will have a score(0~1), and then we set a threshold to filter.

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Text Generation • Updated Jul 19 • 22