Phase III Allocation Data Collection and Methodology Report. Phase III Workshop 06 April 2011

Transcription

1 Phase III Allocation Data Collection and Methodology Report Phase III Workshop 06 April 2011

2 Summary of Presentation Legal Requirements Process of Data Collection Main Elements of the Baseline Data Report Main Elements of the Methodology report Information sources 2

3 Legal Requirements CIMS The Commission Decision provides Community Implementation Measures (CIMS) = legal context for allocation rules. Article 7 covers Baseline data collection. For each incumbent installation eligible for free allocation MS shall for all years 1/01/ /12/2008 or 01/01/2009 to 31/12/2010, during which the installation has been operating, collect from the operator all relevant information and data set out in Annex IV of the CIMS MS shall accept the Operators use of the Commission template Operator shall submit a Methodology Report In the process of collecting data in accordance with Article 7(baseline data) Member states shall only accept data verified as satisfactory by a verifier. 3

4 Legal Requirements Inputs, outputs and corresponding emissions for which only data as a whole is available for the installation shall be proportionally attributed to relevant sub installations: Production of different products on same line, emissions attributed sequentially based on usage time/yr for each sub installation Or where this is not possible the mass or volume of individual products, or other scientifically corroborated estimation methodologies Operator shall submit complete and consistent data to avoid overlaps and double counting between sub-installations Operator must exercise due diligence and submit highest achievable accuracy data hence the Methodology Report requirement. 4

5 Legal Requirements Operator justifies any missing data Operator substitutes missing data with conservative estimates based on best industry practice, recent scientific, technical knowledge Where data are partly available, the value extrapolated shall be not more than 90% of the value obtained using the available data 5

6 Data collection Process The Operator should become familiar with the allocation rules including the relevant guidance documents and how they apply to the installation prior to completing the data collection template. The Operator should contract a Verifier accredited for Phase III baseline verification for the particular activity. Become familiar with the template and data collection Guidance and identify relevant sections for completion and identify relevant sub-installations and benchmarks applicable Organise internal team meetings with technical experts to discuss availability and quality of data and to collect data sources of best available data. Seek clarification from the EPA as required. 6

7 Data collection Process For all product benchmark sub-installations and other subinstallations with significant capacity change, or no two full years within a chosen baseline period, determine initial installed capacity based on 2 highest monthly production volumes or where not possible arrange for experimental verification (48 hour test)supervised and approved by a verifier For installation with less than 2 full calendar years in chosen baseline period determine the relevant capacity utilisation factor based on independently verified, duly substantiated data For significant capacity change determine the historic capacity utilisation factor, start of changed operation, HALinitial +HALchange Complete the data collection template and methodology report. Arrange for the verification of both reports and submission by due date. 7

8 Data Sources The process of data collection and verification must be transparent and data used should be highest achievable accuracy Highest achievable accuracy data includes: AIER independently verified data Financial data (invoices) Data produced for commercial or legal purposes Data reported for use by statistical offices especially for determining PRODCOM/NACE codes Data from operation protocols transparently documented and cross checked by a second person, in absence of better data Indirect correlation data should only be used in the absence of better data When attributing data to sub-installations subtract data for the subinstallation with best available data from total installation in preference to applying lower accuracy methods to each sub-installation 8

9 Baseline Data Report Content A. General Information to be completed by all Operators A.I. Identification of the Installation A.II. Info on the baseline report (eligibility and application for free allocation, electricity generator etc) (where not eligible for free allocation no further sections require completion) A.III List of sub-installations, carbon leakage exposure status and data required to determine initial installed capacity (for product benchmarks, significant capacity changes, less than 2 years data). A.IV List of technical connections only required where heat, waste gases or CO2 imported or exported 9

10 Baseline Data Report Content B. Source streams data: energy and process emissions C. Source streams data: mass balance, CEM,s N2O, PFC etc Sections B and C are only relevant where there are no verified AIERS, or boundaries of installations have changed due to increase scope of EU ETS from (B.1 mandatory for all) D. Attribution of Emissions completed by all Operators Total direct GHG emissions and energy input from fuels Attribution of emissions to sub-installations where relevant. D.II.3 (private household) not relevant to Ireland Waste gases (not relevant in most cases) refer to Guidance Document 8 if unsure. 10

11 Baseline Data Report Content E. Data on energy input from fuels, measurable heat and electricity only required for heat and fuel benchmark subinstallations. Relevant sections to be filled in. The electricity section is required only for electricity producers. F. Sub-installation data relating to product benchmarks Historic activity levels and disaggregated production details. G. Sub-installation data relating to fall-back subinstallations (required for heat, fuel and process emissions) Historic activity levels and disaggregated production details H. Special data for some product benchmarks e.g., Refineries and Lime production. MS Specific requirements only for small emitters (Article27) 11

12 Baseline Data Report Content J. Comments and further information. To be completed by all operators. All documents submitted with the baseline data report are referenced here. K. Summary Sheet. This sheet fills in automatically, giving extensive overview of all relevant data. Installation data, baseline period and eligibility, sub-installation data (BM type, HAL data, CL), calculation of preliminary annual amount of allowances allocated free of charge, data for calculation SCUF. Contains a tool which can calculate final allocations once cross-sectoral correction factor known. This is an information source only. Final decision on allocation made by CA after all data in template approved. Incomplete data, errors etc results in misleading result. 12

13 Methodology Report The methodology report describes the installation, the compilation methodology applied, different data sources, calculation steps and where applicable, assumptions and methodology to attribute emissions to relevant sub installations and demonstrates the accuracy and completeness of data provided. Section 2 covers installation data and boundaries. A detailed description of the installation and sub-installations and any change from 2013 and detailed flow charts to be submitted. Justify baseline period chosen. Section 3 Source Streams (Only section 3.1 to be completed unless boundary of installation changes from 2013.) 13

14 Methodology Report Product Section 4. Product Benchmark sub-installations. Completed separately for each product benchmark Describe how inputs, outputs and emissions (data) identified, aggregated and attributed to sub-installation, avoiding double counting. Detail how production data determined in accordance with product definition and the data sources used. Detail how data attributed to sub-installations where several products produced on one production line. Justify any missing data and detail conservative estimates. Where several sub-installations how are system boundaries set and where are products, materials, measurable heat etc measured and monitored. 14

15 Methodology Report Detailed description of determination of monthly production data or justification and description procedure to experimentally verify capacity. Detailed information on all aspects of significant capacity change where relevant. Detailed description of determination relevant capacity utilisation factor where required(normal operation, maintenance, common production cycle, energy and GHG efficient techniques.) Additional data for refineries. 15

16 Methodology Report Heat, Fuel, Benchmarks, Process Emissions Section 5 Heat Benchmark sub-installations Similar information to Product benchmark in addition: Describe processes measurable heat stems from and transfer mediums used (include temperature, pressure saturation levels) Describe in detail the determination of net heat content by measurement or proxy data and provide evidence as required Describe quantification of measurable heat exported or imported Describe the division of data between carbon leakage and non carbon leakage exposure status. 16

17 Methodology Report Heat, Fuel, Benchmarks, Process Emissions Section 6 Fuel-Benchmark Sub-Installations Similar information to Product benchmark in addition: Describe the avoidance of double counting or data gaps where both fuel and heat benchmark present. Identify source streams and units relating to each non-measurable heat amount. Where flaring relevant explain classification as safety flaring and describe methodology to quantify fuel usage Section 7 Process Emissions Sub-Installations Similar information to Product benchmark in addition: For CO2 process emissions state whether or not waste gases are relevant and describe which activities listed in Article 3(h) of CIMS carried out. 17

18 Methodology Report Section 8 Waste Gases Section 9 Electricity Relevant where electricity produced during baseline period or for exchangeability of fuel and electricity for product benchmark Section 10 Technical Connections Only relevant where cross-boundary flows of measurable heat, waste gases, transferred CO2. Section 11 Data Acquisition and Data Quality Management Simple analysis of inherent and control risk with data management to prevent material misstatements Describe control measures to mitigate risks. Describe measures to ensure only data of highest achievable accuracy used. Detail how data handled and stored and double counting avoided. 18

19 Information Sources Commission website m EPA website heme/phaseiiioftheeuets / Send queries to under the Subject Phase III 19

20 The End Thank You for your attention Annette Prendergast Inspector Climate Change Unit 20