VERIFICATION ACTIVITY PURSUANT TO EUROPEAN REGULATION 600/2012 ANNEXES

Transcription

1 PAG. 1 / 20 ANNEX 1 - DEFINITION OF VERIFICATION TIMES VERIFICATION TIMES FOR EMISSIONS REPORT VALIDATION ACTIVITIES I. PURPOSE Defining the duration of the verification, or time allocation, as specified in article 9 of EU Regulation 600/2012, is fundamental for managing and contributing to reducing the verification risk, that is, the risk, as a function of the intrinsic risk, the control risk and the non-identification risk, that the verifier expresses an insufficient opinion on the verification when the report of an operator or aircraft operator contains material misstatements. When allocating time for verification, RINA bears in mind at least the following elements: inherent risk associated with the type of activity; risk associated to the number of flows for stable plant; risk associated with size category for aircraft operators; the level of information and complexity of the monitoring plan approved by the competent authority; threshold required; the complexity and completeness of the data flow activities and control system of the plant or aircraft operator; the location of the information and data related to greenhouse gas emissions or tonne-kilometer. In general, the following applies: the total time of verification must be explicitly stated in the offer sent to the operator or aircraft operator; in case of organizations made up of a homogeneous group of plants (for example: N gas compressor stations or N production facilities of electricity and heat of the same operator), the offer must state the total time of verification associated with the amount of 'offer and the time of verification at the individual plant for each plant of the group; in the contract review should be made explicit time in relation to individual steps of verification activities if different from those reported in the next chapter BREAKDOWN OF TOTAL TIME INTO ALL THE VERIFICATION PHASES; in case of organizations made up of a homogeneous group of plants, in the contract review form it must be explained the total audit time to be spent at the individual plant and its subdivision for each verification activities, either if it is being held at the same plant or if it is made at a joint location where the organization groups together cross-cutting activities carried out by the Operator (for example, archiving, data analysis and processing, storage controls and calibration instruments, etc.). II. PRELIMINARY DEFINITIONS Complexity of the Installation/Aircraft Operator : this is an intrinsic characteristic of the operator/aircraft operator that is independent from the monitoring and control system and its level of implementation; the complexity of the installation/aircraft operator depends on whether or not there are CO 2 or CO 2e process emissions and on the number of major and minor streams in the installation, regardless of the de minimis streams, as detailed in the following tables:

2 PAG. 2 / 20 Table 1 - Complexity of the installation in the absence of process emissions. RISK LOW N= number of MAJOR streams n= number of MINOR streams N=1 n 2 both conditions must be met, otherwise go to N=2 n>2 both conditions must be met, otherwise go to N>2 regardless of n Table 2 - Complexity of the installation in the presence of process emissions. RISK N= number of MAJOR streams n= number of MINOR streams N 3 n 2 both conditions must be met, otherwise go to N>3 Regardless of n Table 3 - Complexity of the aircraft operator. RISK ANNUAL CO 2 EMISSIONS LOW annual tco2 < annual tco2 < annual tco Size category : this is the installation characteristic connected with CO 2e emissions, as defined in article 19 of EU Regulation 601/2012: Category A installation, where average verified annual emissions of the trading period immediately preceding the current trading period, with the exclusion of CO 2 stemming from biomass and before subtraction of transferred CO 2, are equal to or less than tonnes of CO 2e Category B installation, where the average verified annual emissions of the trading period immediately preceding the current trading period, with the exclusion of CO 2 stemming from biomass and before subtraction of transferred CO 2, are more than tonnes of CO 2e and equal to or less than tonnes of CO 2e

3 PAG. 3 / 20 Category C installation, where the average verified annual emissions of the trading period immediately preceding the current trading period, with the exclusion of CO 2 stemming from biomass and before subtraction of transferred CO 2, are more than tonnes of CO 2e. III. DEFINITION OF VERIFICATION TIMES Total time, in days * man (mandays - Md), for the verification of a plant / air operator includes time taken for the verification planning (which also includes the definition of the time of verification), examination of documents, the strategic analysis and the risk analysis, verification of on-site processes, reporting, technical review and job management in general. The duration of the verification considers the following aspects: 1. the inherent risk associated with the asset category; 2. the risk associated to the number of flows for stable plants; 3. the risk associated with the size category for aircraft operators; 4. the level of information and the complexity of the monitoring plan approved by the competent authority; 5. the threshold required; 6. the complexity and completeness of the data flow activities and control system operator or aircraft operator; 7. the location of the information and data related to emissions of greenhouse gases or the tonnekilometers; 8. the results of previous audits, if available. It has been defined reference times of the duration of the verification, based on the sum of the times attributed to the two parameters, which are defined below and the necessary steps and/or possible reductions described in Table 7. Parameter 1: Corresponds, depending on the circumstances applicable to the risk associated with the numerosity 'flows of the system in absence of process emissions, the risk associated with the numerosity' flows of the system in presence of process emissions, the risk associated the dimensional category of the aircraft operator, as defined in the previous tables. Parameter 2: Monitoring and reporting In Table 5and Table 6 are indicated the typical times provided for each parameter depending on the value of the parameter itself, to be considered unaltered state if are not needed increments and / or possible reductions, for the reasons described in Table 7. In the "Contract Review" the CU / CM, along with a competent technician in the scheme should include: - On time, according to Table 5and Table 6 and the times applied, indicating the reasons of due increases and/or possible reductions for each parameter, as shown in Table 7. Below is the list of activities included in the ETS Directive.

4 PAG. 4 / 20 Table 4 - List of activities 'included in Directive Eu ETS. Eu ETS activity Description of activity Greenhouse gas code 1 Attività energetiche 1.a/1.1 1.b/1.1 Combustion of fuels in installations with a total rated thermal input exceeding 20 MW (except in installations for the incineration of hazardous or municipal waste) Limited to: Combustion of fuels in installations, where only commercial standard fuels as defined in Regulation (EU) No 601/2012 are used, or where natural gas is used in category A or B installations. Combustion of fuels in installations with a total rated thermal input exceeding 20 MW (except in installations for the incineration of hazardous or municipal waste) Combustion of fuels in installations, without restrictions 1.2/1.2 Refining of mineral oil 1.3/1.3 Production of coke Production and processing of ferrous metals 2.1/2.1 Metal ore (including sulphide ore) roasting or sintering, including pelletisation 2.2/ /NA 2.4/NA 2.5/NA 2.6/NA Mineral industry 3.1/ /NA 3.3/ / /NA Production of pig iron or steel (primary or secondary fusion), including continuous casting, with a capacity exceeding 2.5 tonnes per hour Production or processing of ferrous metals (including ferro-alloys) where combustion units with a total rated thermal input exceeding 20 MW are operated. Processing includes rolling mills, re-heaters, annealing furnaces, smitheries, foundries, coating and pickling Production of primary aluminium Production of secondary aluminium where combustion units with a total rated thermal input exceeding 20 MW are operated Production or processing of non-ferrous metals, including production of alloys, refining, foundry casting, etc., where combustion units with a total rated thermal input (including fuels used as reducing agents) exceeding 20 MW are operated Production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or in other furnaces with a production capacity exceeding 50 tonnes per day Production of lime or calcination of dolomite or magnesite in rotary kilns or in other furnaces with a production capacity exceeding 50 tonnes per day Manufacture of glass including glass fibre with a melting capacity exceeding 20 tonnes per day Manufacture of ceramic products by firing, in particular roofing tiles, bricks, refractory bricks, tiles, stoneware or porcelain with a production capacity exceeding 75 tonnes per day Manufacture of mineral wool insulation material using glass, rock or slag with a melting capacity exceeding 20 tonnes per day and perfluorocarbons 1 The Eu ETS activity code column indicates the new code, connected to the activities of Directive 2009/29/EC and, after the slash, the corresponding old code, if it exists, and NA if it does not exist, according to Directive 2003/87/EC

5 PAG. 5 / /NA Drying or calcination of gypsum or production of plaster boards and other gypsum products, where combustion units with a total rated thermal input exceeding 20 MW are operated Other activities 4.1/4.1a Production of pulp from timber or other fibrous materials 4.2/4.1b Chimica 5.1/NA 5.2/NA 5.3/NA 5.4/NA Production of paper or cardboard with a production capacity exceeding 20 tonnes per day Production of carbon black involving the carbonisation of organic substances such as oils, tars, cracker and distillation residues, where combustion units with a total rated thermal input exceeding 20 MW are operated Production of nitric acid Production of adipic acid Production of glyoxal and glyoxylic acid and nitrous oxide and nitrous oxide and nitrous oxide 5.5/NA Production of ammonia 5.6/NA 5.7/NA 5.8/NA Production of bulk organic chemicals by cracking, reforming, partial or full oxidation or by similar processes, with a production capacity exceeding 100 tons a day Production of hydrogen (H 2) and synthesis gas by reforming or partial oxidation, with a production capacity exceeding 25 tons a day Production of sodium carbonate (Na 2CO 3) and sodium bicarbonate (NaHCO 3) Capture, transport and storage of GHG 6.1/NA 6.2/NA 6.3/NA Air transport 7.1/5.1 e 5.2 Capture of greenhouse gas from installations covered by this directive for the purpose of transport and geological storage in a storage site permitted under Directive 2009/31/EC Transport of greenhouse gases by pipelines for geological storage in a storage site permitted under Directive 2009/31/EC Geological storage of greenhouse gases in a storage site permitted under Directive 2009/31/EC Aviation Flights which depart from or arrive in an aerodrome situated in the territory of the European Union Are considered intrinsic high-risk activities those highlighted in yellow in the above list, i.e. the following: 1.2, 2.4, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 6.1, 6.2, 6.3

6 PAG. 6 / 20 Table 5 - Total time of verification applicable to categories of activities 1.a, 1.3, 2.1, 2.2, 2.3, 2.5, 2.6, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 4.1, 4.2, 7.1. Basic elements for defining man*days Parameter 1 LOW MDs 1,5 (+/-1,0)* 2,0 (+/-1,0)* 2,5 (+/-1,0)* Parameter 2 1,5 (+/-1,0)* * NOTE 1: Both for parameter 1 and parameter 2 the increase and the reduction does not exceed 1 Md * NOTE 2: In the case of option out operator, the total time verification is set at 0.5 MDs. Table 6 - Total time of verification applicable to categories of activities 1.b, 1.2, 2.4, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6, 5.7, 5.8, 6.1, 6.2, 6.3. Basic elements for defining man*days Parameter 1 LOW MDs 2,5 (+/-1,0)* 3,0 (+/-1,0)* 3,5 (+/-1,0)* Parameter 2 1,5 (+/-1,0)* * NOTE 1: Both for parameter 1 and parameter 2 the increase and the reduction does not exceed 1 Md * NOTE 2: In the case of option out operator, the total time verification is set at 1 MDs. Table 7 - Factors to bear in mind when increasing or decreasing man*days. Factors that may lead to an increase in man*days For parameter 1: 1. the quality characteristics of the streams (EF, NCV, OF ) were determined by non-accredited laboratories whose correspondence to the minimum requirements of equivalence must be verified 2. complex alternative approaches 3. simultaneous presence of calculation and measurement monitoring 4. complex mass balances 5. complex assumptions and estimation methods 6. supplementary/special authorisations/regulations for the sector 7. permitted waivers, the conditions of technical infeasibility and/or disproportionately elevated costs must therefore be assessed. Any other customer specifications, to be clearly illustrated and documented.

7 PAG. 7 / 20 For parameter 2: 1. complex logistics (e.g.: the information and data connected with greenhouse gas emissions or tonneskilometre are kept in more than one location) 2. very complex activities concerning data streams and the control system of the manager or aircraft operator 3. employees speaking different languages; 4. outsourced monitoring activity phases; 5. management system covering extremely complex processes; 6. immature management system; Any other customer specifications, to be clearly illustrated and documented. Factors that may lead to a decrease in man*days: For parameter 1: 1. presence of fuel/loaded material streams for commercial processes or even standard commercial processes; 2. presence of any specific authorisations/regulations for the sector simplifications authorized. Any other customer specifications, to be clearly illustrated and documented. For parameter 2: 1. simple logistics; 2. knowledge of the installation/aircraft operator's system (e.g.: Installation/aircraft operator already subject to CO 2e emissions verification); 3. installation/aircraft operator's certified for a company management system scheme by RINA or by a Body accredited by a signatory to a Mutual Recognition Agreement (MLA EA and IAF agreements); 4. consolidated management system; 5. high reliability of the basic data source (e.g.: fiscal measuring instruments, measuring instruments with operating codes approved by competent authorities). Any other customer specifications, to be clearly illustrated and documented. Example 1: Consider an oil refinery, already certified for a company management system scheme by RINA or by a Body accredited by a signatory to a Mutual Recognition Agreement (MLA EA and IAF agreements) 2 : - Quantification of the time required for parameter 1: as the complexity of the installation is due to both the presence of process emissions and the fact that there are several major streams, the commitment is assumed to amount to 2.5 man*days without the need to increase or decrease the value indicated in the table; - Quantification of the time required for parameter 2: the installation is certified to ISO 14001:2004. The data collected from the monitoring plan should presumably be traceable and well-organised as the installation has a certified management system; the commitment is assumed to amount to 1.5 man*days with a reduction factor of 1.0 and, therefore, a minimum commitment of = 0.5 man*days; 2 The list of Accreditation Bodies participating in the above agreement can be viewed at

8 PAG. 8 / 20 - Quantification of the minimum overall time: therefore the total minimum commitment is: = 3.0 man*days, to divide between the documents review, strategic analysis and risk analysis, onsite process verification, reporting, technical review and general job management. Example 2: Consider a paper mill in which the only source of CO 2 emissions comprises two natural gas steam generators. The installation is already certified for a company management system scheme by RINA or by a Body accredited by a signatory to a Mutual Recognition Agreement (MLA EA and IAF agreements): - Quantification of the time required for parameter 1: In this case, the complexity of the installation is LOW and the commitment is assumed to amount to 1.5 man*days; a reduction factor of -1,0 can be applied as there is just one single source powered by natural gas. Given that the decision to implement the Community guidelines into the Italian system allows for considerable simplification, the minimum commitment is therefore assumed to be = 0.5 man*days; - Quantification of the time required for parameter 2: the installation is certified to ISO 14001:2004. The data collected from the monitoring plan should presumably be traceable and well-organised as the installation has a certified management system; the commitment is assumed to amount to = 0.5 man*days; - Quantification of the minimum overall time: therefore the total minimum commitment is: = 1.0 man*days, to divide between the documents review, strategic analysis and risk analysis, on-site process verification, reporting, technical review and general job management. Generally speaking, the times are established on a case-by-case basis considering the level of knowledge of the installation and the activities of the installation involved. IV. BREAKDOWN OF TOTAL TIME INTO ALL THE VERIFICATION PHASES Table 8 below shows the breakdown of the total time of verification for single activity to be applied in general, unless otherwise stated included in the signed Contract Review and reported in the field "Notes" for the practice on ASCESI. Table 8 - Breakdown of total time into all the verification phases. MDs totali Strategic Analysis Risk Analysis Process Verification Reporting Independent Technical Review >4 Define breackdown for each case Define breackdown for each case Define breackdown for each case Define breackdown for each case Define breackdown for each case

9 PAG. 9 / 20 VERIFICATION TIMES FOR NER APPLICATION REPORT VALIDATION ACTIVITIES I. PURPOSE Defining the duration of the verification, or time allocation, as specified in article 9 of EU Regulation 600/2012, is fundamental for managing and contributing to reducing the verification risk, that is, the risk, as a function of the intrinsic risk, the control risk and the non-identification risk, that the verifier expresses an insufficient opinion on the verification when the report of an operator or aircraft operator contains material misstatements. When allocating time for verification, RINA bears in mind at least the following elements: intrinsic risk associated with the category of activity; risk associated with the size category of the plant; risks associated with the effect of the variation in case of substantial capacity changes; risk associated to the number of sub-installations subject to request for allocation or modification of free allocation of allowances. II. PRELIMINARY DEFINITIONS Intrinsic risk associated with the category of activity : it was assessed on the basis of the processes that are normally present in the various categories of activity and the resulting sub-installations (subinstallation object of a product, heat (CL and / or non-cl), fuel (CL and / or not CL) or process emissions (CL and / or non-cl) benchmark) in which the facility is divided for the free allocation of allowances and also on the basis of the level of complexity underlying the determination of levels of activities associated with the different sub-installation in the event of reference parameters of products at so-called "special" (e.g. CWT in the case of refineries, on CONCAWE method). See the following table: Table 9 - Level of risk associated with the category of activity. Code Energy industries Description of activity Level of risk associated 1.a Combustion of fuels in installations with a total rated thermal input exceeding 20 MW (except in installations for the incineration of hazardous or municipal waste) Limited to: Combustion of fuels in installations, where only commercial standard fuels as defined in Regulation (EU) No 601/2012 are used, or where natural gas is used in category A or B installations. LOW 1.b Combustion of fuels in installations with a total rated thermal input exceeding 20 MW (except in installations for the incineration of hazardous or municipal waste) Limited to: Combustion of fuels in installations, without restrictions 1.2 Refining of mineral oil 1.3 Production of coke LOW Production and processing of ferrous metals 2.1 Metal ore (including sulphide ore) roasting or sintering, including pelletisation

10 PAG. 10 / Production of pig iron or steel (primary or secondary fusion), including continuous casting, with a capacity exceeding 2.5 tonnes per hour 2.3 Production or processing of ferrous metals (including ferroalloys) where combustion units with a total rated thermal input exceeding 20 MW are operated. Processing includes rolling mills, re-heaters, annealing furnaces, smitheries, foundries, coating and pickling 2.4 Production of primary aluminium LOW Production of secondary aluminium where combustion units with a total rated thermal input exceeding 20 MW are operated Production or processing of non-ferrous metals, including production of alloys, refining, foundry casting, etc., where combustion units with a total rated thermal input (including fuels used as reducing agents) exceeding 20 MW are operated LOW Mineral industry Production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or in other furnaces with a production capacity exceeding 50 tonnes per day Production of lime or calcination of dolomite or magnesite in rotary kilns or in other furnaces with a production capacity exceeding 50 tonnes per day Manufacture of glass including glass fibre with a melting capacity exceeding 20 tonnes per day Manufacture of ceramic products by firing, in particular roofing tiles, bricks, refractory bricks, tiles, stoneware or porcelain with a production capacity exceeding 75 tonnes per day Manufacture of mineral wool insulation material using glass, rock or slag with a melting capacity exceeding 20 tonnes per day 3.6 Other activities Drying or calcination of gypsum or production of plaster boards and other gypsum products, where combustion units with a total rated thermal input exceeding 20 MW are operated 4.1 Production of pulp from timber or other fibrous materials 4.2 Chemical 5.1 Production of paper or cardboard with a production capacity exceeding 20 tonnes per day Production of carbon black involving the carbonisation of organic substances such as oils, tars, cracker and distillation residues, where combustion units with a total rated thermal input exceeding 20 MW are operated 5.2 Production of nitric acid 5.3 Production of adipic acid 5.4 Production of glyoxal and glyoxylic acid 5.5 Production of ammonia Production of bulk organic chemicals by cracking, reforming, partial or full oxidation or by similar processes, with a production capacity exceeding 100 tons a day Production of hydrogen (H2) and synthesis gas by reforming or partial oxidation, with a production capacity exceeding 25 tons a day Capture, transport and storage of GHG

11 PAG. 11 / Air transport 7.1 Capture of greenhouse gas from installations covered by this directive for the purpose of transport and geological storage in a storage site permitted under Directive 2009/31/EC Transport of greenhouse gases by pipelines for geological storage in a storage site permitted under Directive 2009/31/EC Geological storage of greenhouse gases in a storage site permitted under Directive 2009/31/EC Aviation Flights which depart from or arrive in an aerodrome situated in the territory of the European Union Risk associated with the size category of the plant : it was assessed based on the installation total emissions. Table 10 - Level of risk associated with the Installation size category. Installation size category C B A Level of risk associated LOW Table 11 - Level of risk associated with the OA size category. OA size category emissions t CO2 emissions < t CO2 Level of risk associated Risks associated with the effect of the variation in case of substantial capacity changes : it was evaluated based on the incidence rate of change compared to the installation total emissions. Table 12 - Level of risk associated with the incidence rate of change. % incidence of change Level of risk associated % % < % < 15 LOW Risk associated to the number of sub-installations subject to request for allocation or modification of free allocation of allowances (not applicable for OA): it was evaluated based on the number of subinstallations of the installation as a whole and for which is requesting the assignment / modification of free allocation of allowances. Table 13 - Level of risk associated with the number of sub-installations. No. sub-installations (n) Level of risk associated

12 PAG. 12 / 20 n > 2 n = 2 n = 1 LOW Only for OA: Risk associated to the different tipe of load Table 14 - Level of risk associated to the different tipe of load. Different tipe of load Presence of passengers and freight for whom are not used standard weights Presence of only passengers for whom are not used standard weights Presence of only passengers for whom are used standard weights Level of risk associated LOW III. DEFINITION OF VERIFICATION TIMES Total time, in days * man (mandays - Md), for the verification of a plant / air operator includes time taken for the verification planning (which also includes the definition of the time of verification), examination of documents, the strategic analysis and the risk analysis, verification of on-site processes, reporting, technical review and job management in general. Table 15 - Total times for NER verification activities. Overall indicator value In case where at least 2 of the 4 indicators were classified as risk. Overall verification risk level MDs associated 3 In all other cases 2 In case where at least 3 of the 4 indicators were classified as LOW risk. LOW 1 Note to the table: it should be noted that the resulting MDs are considered indicative and however minimal. In the "Contract Review" specifically for NER, the CU/CM, along with a competent technician in the scheme, must include the evaluation of the parameters that enter into the calculation of the duration of the test and the total days defined accordingly.

13 PAG. 13 / 20 IV. BREAKDOWN OF TOTAL TIME INTO ALL THE VERIFICATION PHASES The total time of verification breakdown for each activity takes full Table 8 of Chapter IV above, unless otherwise stated included in the signed Contract Review and reported in the field "Notes" for the practice on ASCESI.

14 PAG. 14 / 20 ANNEX 2 VERIFICATION OVERVIEW This document gives operating indications for managing and performing the various verification phases, as indicated in EU Regulation 600/2012, according to the following main stages: - Documents review; - On-site process verification; - Reporting methods. This annex considers the contents of the reference documents referred to in 2 of this instruction and all the deliberations issued by the Competent Authority which, in all cases, remain the reference documents for all the activities to perform. DOCUMENTS REVIEW The documents review outlines a general framework for planning the verification as indicated in Art. 13 of EU Regulation 600/2012. On the basis of the documents review, the verifier performs the following activities during the verification process. Strategic analysis The verifier: - must check that the monitoring plan has been approved by the Competent Authority and that the version is correct; if not, the verification must be halted apart from the elements that are clearly not affected by the non-approval; - must understand each activity performed by the installation/aircraft operator, the emissions sources and source streams of the installation, the measuring instruments used to control or measure activity data, the origin and application of the emissions factors and the oxidation/conversion factors, all other data used to calculate or measure the emissions, and the operating environment of the installation; - must understand the operator's monitoring plan, the data flow and the control system used, including the overall organisation of monitoring and communication activities; - must apply the materiality level as indicated in article 23 of EU Regulation 600/2012 and indicated in the following table: Materiality Level Category A and B installations or aircraft operators with annual emissions equal to or less than 500 kilotonnes of CO 2 Category C installations or aircraft operators with annual emissions greater than 500 kilotonnes of CO 2 Total tonnes-kilometre data indicated in the reporting period subject to verification 5% 2% 5%

15 PAG. 15 / 20 The verifier performs the strategic analysis in order to perform the risk analysis described below; if necessary, the strategic analysis can include an on-site inspection. Risk analysis The verifier: - analyses the intrinsic risks and control-related risks as regards the field of application and complexity of the operator's activities and of the sources and emission source streams that could cause material misstatements and non-conformities (substantial); - draws up a verification plan on the basis of the risk analysis. The verification plan describes how the verification activities must be performed and contains a verification programme and a data sampling plan. The verification programme describes the type of activity, the relative time allocation and the scope to ensure the verification plan is completed. The data sampling plan defines the data that must be verified to reach a conclusion on the verification, the type of test to apply and the acceptance values of the test results in order to assess when an aspect is compliant. NOTE: It 'possible that when strategic analysis and risk analysis are completed it is required to change the duration of the verification and then to reissue the offers to the customer and to retrace the precontract steps planned. This option is clearly indicate in the offer to be submitted to the customer. I. EMISSIONS REPORT VALIDATION ACTIVITIES The operator/aircraft operator provides at least the following documents to the verifier: a) the operator's greenhouse gas emissions permit when this concerns the verification of an operator's emission report; b) the latest version of the operator/aircraft operator's monitoring plan as well as any other relevant versions of the monitoring plan approved by the competent authority, including evidence of the approval; c) a description of the operator's or aircraft operator's data flow activities; d) the operator's or aircraft operator's risk assessment referred to in article 58, paragraph 2, letter a), of regulation (EU) n 601/2012 and an outline of the overall control system; e) the procedures mentioned in the monitoring plan as approved by the competent authority, including procedures for data flow and control activities; f) the operator's or aircraft operator's annual emission or tonne-kilometre report, as appropriate; g) where applicable, operator's sampling plan referred to in article 33 of regulation (EU) n 601/2012 as approved by the competent authority; h) where the monitoring plan was modified during the reporting period, a record of those modifications in accordance with article 16, paragraph 3, of Regulation (EU) n 601/2012; i) where applicable, the report referred to in article 69, paragraph 4, of regulation (EU) n 601/2012 (remembering that the first deadline for this fulfilment is 30th June 2014); j) the verification report from the previous year if RINA did not carry out the verification the previous year; k) all relevant correspondence with the competent authority, in particular information related to the notification of modifications of the monitoring plan; l) information on databases and data sources used for monitoring and reporting purposes, including those from Eurocontrol (for the aircraft operator); m) where the verification concerns the emission report of an installation carrying out the geological storage of greenhouse gases in a storage site permitted under directive 2009/31/EC, the monitoring plan required by that directive and the reports required by article 14 of the same, covering at least the reporting period of the emissions report to be verified;

16 PAG. 16 / 20 n) where applicable, the approval of the competent authority for not carrying out site visits for installations pursuant to article 31, paragraph 1 of EU Regulation 600/2012; o) any other relevant information necessary for the planning and carrying out of the verification. II. NER APPLICATION REPORT AND t-km REPORT VALIDATION ACTIVITIES The operator provides at least the following documents to the verifier: a) the operator's greenhouse gas emissions permit; b) the latest version of the operator/aircraft operator's monitoring plan as well as any other relevant versions of the monitoring plan approved by the competent authority; c) Emission Report and Verification Report of the previous year, if any d) methodological report or other technical description document of the monitoring activity levels corresponding to the sub-installations object of assignment request, or change the assignment for free allocation of allowances; e) initial CIMs and any NER Application Report elapsed before current request for assignment or change the assignment of free allowances; f) NER Aplication Report compiled by Operator; g) Documents project for the definition of new installed capacity or capacity modified (enlarged or reduced); h) Production data to support the definition of the starting data of normal operation of the installation, in case of sub-installation object to a product benchmark; i) Useful heat production data to support the definition of the starting data of normal operation of the installation, in case of sub-installation object of heat benchmark; j) Consumption data of different fuels to support the definition of the starting data of normal operation of the installation, in case a sub-installation object of fuel benchmark; k) process emissions data to support the definition of the starting data of normal operation of the installation, in case a sub-installation object of process benchmark; l) Technical Report in support of the definition of RCUF; m) Operator's spreadsheets used to calculate the CO 2 and/or CO 2equivalent emitted by the installation; n) heat and power balance; o) Adjustment reports and any calibration reports. p) all relevant correspondence with the competent authority q) any other relevant information necessary for the planning and carrying out of the verification. The aircraft operator provides at least the following documents to the verifier: a) the latest version of the monitoring plan as well as any other relevant versions of the monitoring plan approved by the competent authority; b) Emission Report and Verification Report of the previous year, if any c) methodological report or other technical document describing the t-km monitoring; d) t-km initial comunication and any t-km Report elapsed before current request for assignment or change the assignment of free allowances; e) t-km Report filled; f) Spreadsheets or other recordings (eg. Balancing Models) for the pay load processing; g) Spreadsheets or other recordings (eg. ATL aircraft technical log books) for the kilometers covered processing; h) all relevant correspondence with the competent authority i) any other relevant information necessary for the planning and carrying out of the verification.

17 PAG. 17 / 20 ON-SITE PROCESS VERIFICATION I. EMISSIONS REPORT VALIDATION ACTIVITIES Within the scope of the verification, the verifier performs an on-site visit (on-site process verification at the installation/aircraft operator) to inspect the operation of the installation or the activity phases of the aircraft operator and of the measuring instruments and monitoring systems, hold interviews and gather sufficient information and evidence. Additionally, the verifier: - implements the verification plan by gathering the data to base the verification conclusions on, consistently with the required sampling methods, the documents review, the analytical procedures and the data verification procedures, as well as all other objective elements of interest; - confirms the validity of the information used to calculate the level of uncertainty defined in the approved monitoring plan; - checks that the approved monitoring plan is implemented and makes sure it is updated; - asks the operator /aircraft operator to provide any missing data and to describe the methods used to reconstruct missing data; to explain any changes in the emission data, to review the calculations or update the report data, before reaching a final conclusion as regards the verification; - the verifier promptly reports any misstatements or non-conformities found during the verification to the operator or aircraft operator and asks for suitable corrections to be made; - documents and indicates as solved, on the Internal Report, all the misstatements or non-conformities corrected by the operator or aircraft operator during the verification; - establishes whether the misstatements that were corrected, individually or aggregated with others, have a significant effect on reported emissions or total tonnes-kilometre data. When assessing the incidence of the misstatements, the verifier considers their extent and nature as well as the specific circumstances in which they occurred; - assesses whether the non-conformity that was not corrected, individually or aggregated with others, has an impact on the reported data and if this generated material misstatements; - can also consider the misstatements as relevant if these, individually or aggregated with others, are lower than the materiality level, where this is justified by the extent and nature of the misstatements and the specific circumstances in which they occurred. When performing verification on an aircraft operator the verifier also: - cross-checks the operator's flight data with the aircraft traffic data gathered by EUROCONTROL - checks the correspondence and consistency of aggregated fuel consumption data with total fuel purchased - performs spot checks, according to stochastic sampling principles, on payload data and fuel consumption. II. NER APPLICATION REPORT AND t-km REPORT VALIDATION ACTIVITIES For operators: within the scope of the verification, the verifier performs an on-site visit (on-site process verification at the installation/aircraft operator) to inspect the operation of the installation or the activity phases of the aircraft operator and of the measuring instruments and monitoring systems, hold interviews and gather sufficient information and evidence. Additionally, the verifier:

18 PAG. 18 / 20 - implements the verification plan by gathering the data to base the verification conclusions on, consistently with the required sampling methods, the documents review, the analytical procedures and the data verification procedures, as well as all other objective elements of interest; - confirms the validity of the information used to calculate the new installed or changed capacity; - confirms the validity of the information used for the definition of the starting data of normal operation; - confirms the validity of the information used for the Technical Report in support of the definition of RCUF; - verifies the consistency of product production data, useful heat, energy balance with the operating data of installation; - asks the operator /aircraft operator to provide any missing data and to describe the methods used to reconstruct missing data; to explain any changes in the emission data, to review the calculations or update the report data, before reaching a final conclusion as regards the verification; - the verifier promptly reports any misstatements or non-conformities found during the verification to the operator or aircraft operator and asks for suitable corrections to be made; - documents and indicates as solved, on the Internal Report, all the misstatements or non-conformities corrected by the operator or aircraft operator during the verification; - determines whether incorrected misstatements, individually or aggregated with others, have a material effect on data reported on NER Application Report. In assessing the impact of misstatements, considering the size and nature of the misstatement and the specific circumstances in which this occurred. For aircraft operators: within the scope of the verification, the verifier performs an on-site visit (on-site process verification) to check the monitoring systems, hold interviews and gather sufficient information and evidences. Additionally, the verifier: - implements the verification plan by gathering the data to base the verification conclusions, consistently with the required sampling methods, the documents review, the analytical procedures and the data verification procedures, as well as all other objective elements of interest; - confirms the validity of the information used to fill the t-km Report; - traces, according to the sampling plan defined, the reconstruction of the information submitted in t-km Report from the data source (ATL, Balancing Models, etc.). REPORTING METHODS I. EMISSIONS REPORT VALIDATION ACTIVITIES Once process verification has concluded, the verifier prepares the Internal Report. This report contains all the elements demonstrating that the strategic analysis, the risk analysis and the monitoring plan were performed in their entirety and provides sufficient information to support the findings of the verification. On the basis of the results of the Internal Report, the verifier assess the presence of any material misstatements in the annual Emissions Report with respect to the materiality level and the presence of any significant non-conformities or other elements that could be useful for closing the verification. As well as the Internal Report, the verifier prepares a draft verification report in the standard format provided by the European Commission via the local Emissions Trading Directive implementation committee. The verification report must include at least one of the following findings: - the report is verified as satisfactory;

19 PAG. 19 / 20 - the operator s or aircraft operator s report contains material misstatements that were not corrected before issuing the verification report; - the scope of verification is too limited pursuant to Article 28 of EU Regulation 600/12 as the verifier could not obtain sufficient evidence to issue a verification opinion with reasonable assurance; - non-conformities, individually or combined with other non- conformities, provide insufficient clarity and prevent the verifier from stating with reasonable assurance that the operator s or aircraft operator s report is free from material misstatements. The operator's or aircraft operator's report may be verified as satisfactory only where it is free from material misstatements. The above verification report must indicate: - any identified misstatements and non-conformities that were not corrected before the issuance of the verification report; - confirmation whether the method used is conservative and whether it does or does not lead to material misstatements where approval by the competent authority cannot be obtained in time for the method used to complete the data gap pursuant to article 18, paragraph 1; - a description of the modification and related observations, where the verifier has observed changes to the capacity, activity level and operation of the installation which might have an impact on the installation's allocation of emission allowances and which have not been reported to the competent authority within 31 st December of the reporting period in accordance with article 24, paragraph 1, of decision 2011/278/EU; - any recommendations for improvements. The verifier shall describe the misstatements and non-conformities in sufficient detail in the verification report to allow the operator or aircraft operator as well as the competent authority to understand the following: - the size and nature of the misstatement or non-conformity; - why the misstatement has material effect, or not; - to which element of the operator s or aircraft operator s report the misstatement or to what element of the monitoring plan the non-conformity refers to. For the purposes of the final outcome of the verification and the classification of the findings, the following definitions, taken from EU Regulation 600/2012, are used: «material misstatement» (IR), a misstatement that, in the opinion of the verifier, individually or when aggregated with other misstatements, exceeds the materiality level or could affect the treatment of the operator s or aircraft operator s report by the competent authority. «misstatement» (INR), an omission, misrepresentation or error, not considering permissible uncertainty. «non-conformity» (NC), any act or omission of an act by the operator/aircraft operator that is contrary to the greenhouse gas emissions permit (only for operators) and the requirements in the monitoring plan approved by the competent authority. «recommendation» (R) is a comment made by the verifier providing information that an installation can use to improve the performance of its emissions monitoring and reporting activities. The Internal Report and draft Verification Report are sent to ITR according to the methods indicated in operating instruction IS-QPT-ETS-01.

20 PAG. 20 / 20 II. NER APPLICATION REPORT AND t-km REPORT VALIDATION ACTIVITIES Once process verification has concluded, the verifier prepares the Internal Report. This report contains all the elements demonstrating that the strategic analysis, the risk analysis and the monitoring plan were performed in their entirety and provides sufficient information to support the findings of the verification. On the basis of the results of the Internal Report, the verifier assess the presence of any material misstatements with respect to the materiality level and the presence of any significant non-conformities or other elements which may affect the emission Verification Certificate. As well as the Internal Report, the verifier prepares a draft Verification Certificate on RINA format available on LOTUS. The Verification Certificate must include at least one of the following opinions (ex Italian Deliberation 30/2011): - positive verification opinion; - verification opinion positive with comments; - negative verification opinion. The Verification Certificate takes the minimum contents as provided in Annex 3 of Italian Deliberation 30/2011. The Internal Report and draft Verification Certificate are sent to ITR according to the methods indicated in operating instruction IS-QPT-ETS-01.