Connecting the emission report to the monitoring plan

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2 Connecting the emission report to the monitoring plan Lisa Buchner German Emissions Trading Authority (DEHSt) Implementation of the EU ETS, TAIEX 27th of September, Zagreb

3 Outline Legal Framework for EU ETS Monitoring and Reporting in Germany Operator Obligations EU ETS Compliance Cycle for Monitoring and Reporting Installation-specific Monitoring Plan Emissions Reporting Compliance Checks Main Subjects and Requirements for Monitoring 3

4 Legal Framework for EU ETS Monitoring and Reporting in Germany EU Emissions Trading Directive (2003/87/EC) German Green House Gas Emissions Law ( Treibhausgas- Emissionshandelsgesetz-TEHG ) EU Monitoring and Reporting Guidelines (2007/589/EC) (MRG) 4

5 Operator Obligations Delivery of a complete and transparent Monitoring Plan to be approved by the Competent Authority before starting operation Submission of a verified annual Emission Report (based on the Monitoring Plan) to the Competent Authority by 31st March each year Use an accredited Third Party Verifier, Verifier access to all required information Retention of relevant records for at least 10 years 5

6 Shared Competences in Germany Federal States (Länder): Validation and approval of Monitoring plans, random checks of Emission Reports DEHSt (German emissions trading authority): Control of Emission reports, Enforcement and Sanctioning National Compliance Forum: Close co-operation between Federal and Länder level 6

7 EU ETS Compliance Cycle for Monitoring and Reporting Approval of the Monitoring Plan Emissions Reporting Monitoring Plan Verification black: Operator s tasks blue: Authorities tasks red: Verifier s tasks Checking, Enforcement (Sanctions) Surrendering Allowances 7

8 Installation-specific CO2 Monitoring Plan MP describes methods used for calculating CO2 emissions Approval of MP: Existing installation: before the start of the monitoring period New entrant installations: part of the permitting procedure In case changes in operation of the installation cause a different monitoring methodology later on Monitoring Plan has to be adjusted and approved by the regional regulator again. 8

9 Emissions Reporting (2) Operator provides report including MP to regional regulator (March 1st) (1) Verifier validates and verifies the received report and sends indication notice with the total amount of CO 2 emissions to DEHSt (VET) 9

10 Compliance Checks (3) After clarification if needed, DEHSt imposes a sanction of 100 /t CO2 for operators which did not surrender sufficient allowances (1) Regional regulator checks installation-specific issues randomly till March 31st (2) DEHSt examines reports more closely with additional automatic checks for all and manual checks for some questionable reports 10

11 MRG Relevant Chapters Annex I - General Guidelines Annex II - Guidelines for Combustion emissions Annex III-XI - Activity-specific Annexes include individual requirements for installations in the following sectors: mineral oil refineries, coke ovens, metal ore roasting and sintering, pig iron and steel, cement clinker, lime, glass, ceramic, pulp and paper Annex XII - Guidelines for determination of greenhouse gas emissions by continuous emission measurement system Annex XIII - Guidelines for determination of N2O Annex XIV-XV Guidelines for determination of emission and tonnekilometre data from aviation activities 11

12 Main subjects and requirements for Monitoring (MRG) Monitoring Plan Methods for determination of CO2-emissions Tier approach of MRG 2007 Activity data 12

13 Monitoring Plan (MP) MP contains methods for the determination of the CO2 emissions: Description of the site and the processes List of all sources & fuels/material streams Description of chosen calculation or measurement methods Evidences demonstrating compliance with required uncertainties (where applicable) for the determination of all relevant parameters for the determination of the CO2 emissions, Description of data flow, management of competences, QS, corrective action, records and much more 13

14 Methods for determination of CO2 - emissions (section 4.2 MRG 2007): Calculation of combustion emissions: fuel flow * net calorific value * emission factor * oxidation factor Measurement of combustion emissions (CEMS): flue gas flow * CO 2 - concentration Application of measurement based methodology is subject to approval by the competent authority (and can only be used if it delivers a more accurate result compared to calculation based methodology) 14

15 Tier approach of MRG 2007 (1) (Section 5.2, Annex I) Corresponding to the reported average annual emissions over the previous trading period the MRG 2007 differentiate on principle between three installation categories: - Cat. A installations: annual CO 2 -emissions t CO 2 - Cat. B installations: annual CO 2 -emissions t CO 2 - Cat. C installations: annual CO 2 -emissions > t CO 2 Tier requirements (specific methodologies, uncertainty requirements) for all source streams and activities are based on the categorization of an installation. 15

16 Tier approach of MRG 2007 (2) (Section 5.2, Annex I) Category B and C installations (> 50 kt CO 2 /yr) must generally meet highest tiers (defined in the activity-specific Annexes of the MRG) Category A installations ( 50 kt CO 2 /yr) must meet minimum tier requirements (defined in table 1 MRG) Small emitters (< 25 kt CO 2 /yr) must also meet the minimum tier requirements but can use additional monitoring simplifications (section 16, Annex I) Lower tiers are allowed for minor and de minimis source streams as well as for pure biomass fuels and for technical or economical reasons if approved by the regional regulator 16

17 Activity data Determination of consumption data has to be carried out with a maximum uncertainty according to the tier requirement Evidence demonstrating compliance with tier requirement necessary Example: the amount of a major source stream of a category C power plant has to be determined with a maximum uncertainty of ±1.5% (tier 4) Uncertainty assessment according to Section 7.1, Annex I MRG 2007: uncertainty for a measurement system comprises: 1) specified uncertainties of the applied measuring instruments; 2) uncertainties associated with calibration; 3) any additional uncertainties connected to practical use. 17

18 Importance of a proper MP There are usually several possible methods, measurement and analyses procedures as well as measurement and analyses devices available in an installation to determine the emissions of the installation. Even if everyone of these methods, procedures and devices fulfills the requirements of the MRG 2007, the different approaches lead to different results and therefore to different emissions Monitoring plan Transparent, consistent and complete Monitoring Plans where the operator shows that all necessary data are determined with the required accuracy are the basis for the Emissions Report Emission reports are only as good as the underlying monitoring plans. Emissions report 18

19 Thank you very much for your attention. Lisa Buchner Internet:

20 Minor / de-minimis source streams (section 5.2 Annex I) Minor and de-minimis source streams are components of total fossil CO2-emissions of an installation Thresholds: minor source streams: summed up < t CO 2 / y or < 10% (max t CO 2 / y) check next lower tier level, minimum: tier 1 de-minimis source streams (component of minor source streams): summed up < t CO 2 / y or < 2% (max t CO 2 / y) use of own no-tier estimation methods Subject to approval by the competent authority (CA) 20

21 Simplification for commercially traded fuels (Section 7.1, Annex I) Determination of annual fuel or material flow based solely on the invoiced amount when national legislation ensures that respective uncertainty requirements for activity are met requires permit by CA no further individual proof of associated uncertainties necessary DE: no waiving of uncertainty proofs when fuels are stored (coal stockyard, fuel oil tank), because uncertainty of stock balancing generally is much higher than uncertainty limits in legal metrology. DE: no waiving of uncertainty proofs when source streams are distributed between ETS installation and non-ets installations (difference between total fuel flow to a site and fuel flow to an ETS installation). 21

22 Slajd 21 BuchL3 wäre es hier nicht noch sinnvoll zu erläutern, was in Deutschland die nationalen Bestimmungen hierzu sind? Verkehrsfehlergrenze (=die im Handelsverkehr geltende Unsicherheitsanforderungen) muss die Anforderungen der ML einhalten) buchner;