OK, I'm re-reading Smith (comparing to 1MW spec).
Expert report 1 : 194-01 http://coldfusioncommunity.net…/01/0194.01_Exhibit-1.pdf
He reads that the ecat supplies (slightly) superheated steam, so he spends a several pages (7,9 ..) on a multi-megawatt electricity-generating plant.
p13 : He complains that penon gives supplied energy as "247,000 wh/day", and complains about the rounding. Gee ... looks to me like Penon measured in kWh/day 247 (that's what my electric meter gives me!) and just converted to watts.
p13: complains about the flow meter reading 36,000 not 35,837 kg/day. Again, that's what the dial reads ... steps of 1,000 kg. He could have asked why it didn't show 35,000 or 37,000. Quibbling over precision that's not there! (Funny that in version 2 he complains about too many digits!
p14: he complains that the steam temperatures are above 100C. Um, yes : it's super-heated slightly. OK, quibbles about bar vs barg.
p14: "If an appropriate energy measuring device had been installed in the outlet of the ecat the produced energy would be a tabulation of those readings."
Like what? We need the flow (done, in the condensate return line .. that IS on the output side) and delta-T (done : tank temperature, actually ignored, and steam temperature, measured on the output).
p14: says COP can only be used to calculate LOSSES. COP as total output energy/total input energy is well established in the realm of over-unity devices.
p16: Legitimately complains about lack of steam quality measurement.
p16: Says that the condensate return is an INPUT to the eCat. No. The condensate tank is the "center" of the system. Anything between the ecat and the tank is OUTPUT. Between the tank and the ecat, INPUT. (Does say it could be tampered with).
On the heat-dissipation end he's a bit more convincing. (Remember that I calculated the requirement for a roof fan, lo many months ago, though I came up with a number of 30K CFM, which would fit in the installed duct). I bet I could find a smaller 50K CFM fan ... but this is moot because it was apparently non-operational.
http://www.globalindustrial.co…NebtqzBk9MCFYVhfgodp1IIgg
That's a bit less intimidating!
So really his whole report 1 comes down to two things : steam quality was not measured, and 1MW couldn't be dissipated.