B 3.1: Guidelines for the Monitoring, Reporting and...
Transcript of B 3.1: Guidelines for the Monitoring, Reporting and...
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About the Project "Emissions Trading System: Capacity Building" is a programme of the German
Ministry for the Environment [BMUB], in cooperation with the German
Emissions Trading Authority [DEHSt] and leading German emissions trading
experts, to share knowledge and experience to help interested countries
establish an emissions trading system. Fundamental principles and “best
practices” of emissions trading are offered with a focus on the EU and German
experiences. Participants gain the necessary expertise to develop and
implement concepts to design their own national ETS.
The programme offers training modules in selected countries and in Germany
and has been specially designed for experts and policy makers. The
programme comprises a number of modules that can accommodate individual
interests and prior knowledge of participants.
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Content
• Goal and Objectives
• Why Monitoring & Reporting
• Background
• Overview of Monitoring and Reporting Process
• Monitoring Plan
• Emission Report
• Determination & Verification Process
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Content
• Goal and Objectives
• Why Monitoring & Reporting
• Background
• Overview of Monitoring and Reporting Process
• Monitoring Plan
• Emission Report
• Determination & Verification Process
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Goal & Objectives
• Goal of this presentation is to deliver an overview of the existing MRV system under the European Emissions Trading Scheme 2013-2020.
• Objectives are to:
Understand the importance of a monitoring system;
Become familiar with the main design features of the process;
Get to know who are the main actors in this system & who is responsible for what;
How to build such a system at home;
Use that experience also for data acquisition for preparing decisions on Emissions
Trading Scheme and Allocation planning.
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Content
• Goal and Objectives
• Why Monitoring & Reporting
• Background
• Overview of Monitoring and Reporting Process
• Monitoring Plan
• Emission Report
• Determination & Verification Process
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Why Monitoring & Reporting?
• ETS gives flexibility to the operators …
… allows emissions to be cut where cheapest!
• Flexibility ends when actual emissions must be reported.
• Operators must surrender allowances on the basis of annual Monitoring & Reporting.
• Monitoring & Reporting – „The flip side of the coin“
… free allocation vs. compliance costs
• Monitoring principle: „One tonne CO2 emitted must be one tonne CO2 reported.“
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
You can only control, what you can measure!
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Content
• Goal and Objectives
• Why Monitoring & Reporting
• Background
• Overview of Monitoring and Reporting Process
• Monitoring Plan
• Emission Report
• Determination & Verification Process
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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EU ETS Legal Framework - Overview
Module B 3.2: Institutional & Legal Framework of the EU Emissions Trading System (ETS)
Emissions Trading Directive
(2003/87/EC)
Linking Directive
JI-/CDM projects
(2004/101/EC)
Directive amending
EU ETS from 2013 onwards
(2009/29/EC)
Directive
on aviation
(2008/101/EC)
EC Decision
on free
allocation
of emission
allowances
(2011/278)
EC Regulation
on auctioning
of GHG
emissions
(1031/2010)
EC Decision
on list of
sectors and
subsectors
which are
deemed to be
exposed to
a significant
risk of carbon
leakage
(2010/2)
EC Regulation
of establishing
a Union
Registry
(No 389/2013)
EC Regulation
on the
verification of
greenhouse gas
emission reports
and
tonne-kilometre
reports and the
accreditation
of verifiers
(No 600/2012)
EC Regulation
on the
monitoring
and reporting
of greenhouse
gas emissions
(No 601/2012)
EC Regulation
on determining
international
credit
entitlements
(No 1123/2013)
EC Decision
on the effort
of Member States
to reduce their
greenhouse gas
emissions to
Meet the
Community’s
greenhouse gas
emission
reduction
commitments
Up to 2020
(No 406/2009)
EC Regulation
on
establishing a
scheme for
GHG emission
allowance
trading in view
of the
implementation
by 2020 of an
international
agreement
applying
a single global
market-based
measure to
international
aviation
emissions
(No 421/2014)
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Background
• Robust, simplified, transparent, consistent and accurate monitoring and reporting of GHG emissions is essential!
• The Monitoring and Reporting Regulation (MRR) of the EU entered into force on 1 August 2012 and applies to emissions monitoring from 1 January 2013 on. It replaces the Monitoring and Reporting Guidelines (MRG) of the EU which were adopted in 2004 (revision 2007).
• The MRR provides the regulatory framework for the monitoring and reporting of GHG emissions within the ETS in the third trading period. Its regulations are directly applicable to all member states and to all participants.
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Monitoring and calculating CO2 emissions & emission reports are
essential elements of the emissions trading system!
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Content
• Goal and Objectives
• Why Monitoring & Reporting
• Background
• Overview of Monitoring and Reporting Process
• Monitoring Plan
• Emission Report
• Determination & Verification Process
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Overview: Allocation, MRV, Compliance
8. CO2-
Monitoring
2. Allocation
Application 3. Verification of
Allocation Application
4. Allocation
Decision
1. Definition Legal
Framework,
Scope, GHG
permission
7. Issuance of
Allowances
9. Emission Report
11. Submission
of Emission
Report
13. Obligatory
and in-depth
checks Steps 7-14 are repeated annually!
10. Verification of
Emission Report
14. Surrender of
Allowances
Plant Operator
Verifier Legislative Body Competent Authority
Source: FutureCamp 2014
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
12. Entry into
Registry (VET)
5. Establishment of
Monitoring Plan 6. Approval of
Monitoring Plan
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Content
• Goal and Objectives
• Why Monitoring & Reporting
• Background
• Overview of Monitoring and Reporting Process
• Monitoring Plan
• Emission Report
• Determination & Verification Process
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Step 5: Establishing a Monitoring Plan
8. CO2-
Monitoring
2. Allocation
Application 3. Verification of
Allocation Application
4. Allocation
Decision
1. Definition Legal
Framework,
Scope, GHG
permission
7. Issuance of
Allowances
9. Emission Report
11. Submission
of Emission
Report
13. Obligatory
and in-depth
checks Steps 7-14 are repeated annually!
10. Verification of
Emission Report
14. Surrender of
Allowances
Plant Operator
Verifier Legislative Body Competent Authority
Source: FutureCamp 2014
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
12. Entry into
Registry (VET)
5. Establishment of
Monitoring Plan 6. Approval of
Monitoring Plan
The operator must: • Reveal monitoring method (calculation or measurement); • Explain whether and how MRR requirements are met; • And where the method deviates from the MRR.
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Step 5: Monitoring Plan (2013-2020)
• Existing installations: installation-specific monitoring plan (MP) shall be developed before start of the monitoring period.
• New entrant installations: MP has to be submitted before start of operation
• MP is the basis for the emission reports.
• MP to be submitted to competent authority for approval before start of the monitoring period.
• MP is compiled using standardized electronic templates. In Germany this is done by application of a national form management system (FMS).
• DEHSt has published special guidance documents for this.
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Monitoring Plan: Design and Content
Monitoring Plan Supporting documents
General plant information
Summary of process instructions
Proof of meeting tier requirements
Results of risk analysis
Information on changes and updates
Documentation of methods
• Calculation-based methodology • Measurement-based methodology • Categorisation of source streams • Calculation factors • Emission sources
Procedures / Process instructions
• Data management • Control system • Sampling plan • Analysis • QA for measurement instruments • ...
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Methods for CO2 Emissions Determination
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
A combination of methods is possible.
Calculation-based methodology
Measurement-based methodology
Standard Methodology Mass balance Methodology
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Standard Methodology
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Fuels for combustion
Process input materials
products
waste
actorOxidationFctorsEmissionFamsInputStreaEmissions **
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Combustion Emissions Determination
• Formula for calculating:
• Oxidation factor for Germany is 1.
• Determination of the emission factor and net calorific value:
– Commercial standard fuels and small installations – using standard factors from
German regulation, e.g.:
– Other fuels & large installations – calculation is done by analysing fossil C-content &
net calorific value. Invoicing data from supplier can be used if information relevant for
tier requirements is available.
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
actorOxidationFctorEmissionFaicValueNetCalorifFuelFlowEmissionsCombustionCO ***2
Natural gas 0.056 t CO2/GJ 36.0 GJ/1.000 Nm3
Mine gas 0.055 t CO2/GJ 17.8 GJ/1.000 Nm3
Fuel oil, light 0.0741 t CO2/GJ 42.6 GJ/t
Fuel oil, heavy 0.0809 t CO2/GJ 39.5 GJ/t
Raw lignite 0.099-0.114 t CO2/GJ 8.8-10.7 GJ/t
Biomass 0.000 t CO2/GJ - -
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Material Flows Emissions Determination
• Formula for calculating:
• Determination of the emission factor:
– For small installations – using a product standard factor according to MRR and
German regulation, e.g.:
• Cement clinker 0.525 t CO2/t
• Gypsum 0.258 t CO2/t
– For large installations – emission factor shall be determined on-site e.g. by lab.
analysis at the plant. Invoicing data from supplier can be used if information relevant
for tier requirements is available.
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
FactorConversionctorEmissionFataActivityDa
ionocessEmissCO
**
Pr2
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Mass balance
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
∑CInput ∑COutput
)(* OutputInput CCfEmissions
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Continuous Emissions Measurement
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Concentration
Volume flow CO2e
Emissions
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Tier Approach in Monitoring Plan and Reports
• Principle:
– Each tier has a number (1-4), having been allocated per parameter and activity.
– Selection of tier depends on the amount of annual total emissions of the
installation in the previous emissions trading period.
• Rule: higher number of tier and higher total emissions require higher accuracy level.
• Plants > 50,000 t annual emissions (Category B and C) must generally meet the
highest level of accuracy, meaning tier 4
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
The tier approach defines the accuracy level for each parameter
per activity.
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Tier Approach: Categorised according to CO2 Emissions
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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A B C
CO2 emissions [in 1,000t/a] 500
Tiers for Activity Data for Category A Facilities and
Commercial Standard Fuels
Sourc
e:
Excerp
t fr
om
A
nnex V
and A
nnex I
I M
RR
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Calculation Method: Categories and Tiers
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Category C 1 tier lower
possible
Commercial
standard
fuels
Up to 2 tiers lower
possible
Highest
Tier as per
Annex II
Fall-
bac
k A
pp
roac
h
Further
facilitations
Lower tier possible
for transition period
(up to 3 years);
plan for achieving
required tier
necessary
Minimum requirement Tier 1
Minimum
require-
ments as
per Annex
V
Category B
Category A
Small
emitters
if this is technically not feasible or incurs unreasonable costs
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Step 5: Establishing a Monitoring Plan
8. CO2-
Monitoring
2. Allocation
Application 3. Verification of
Allocation Application
4. Allocation
Decision
1. Definition Legal
Framework,
Scope, GHG
permission
7. Issuance of
Allowances
9. Emission Report
11. Submission
of Emission
Report
13. Obligatory
and in-depth
checks Steps 7-14 are repeated annually!
10. Verification of
Emission Report
14. Surrender of
Allowances
Plant Operator
Verifier Legislative Body Competent Authority
Source: FutureCamp 2014
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
12. Entry into
Registry (VET)
5. Establishment of
Monitoring Plan 6. Approval of
Monitoring Plan
The operator must: • Reveal monitoring method (calculation or measurement); • Explain whether and how MRR requirements are met; • And where the method deviates from the MRR.
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Example Power Plant: Process Overview
CO2 - emission for combustion & process (desulphurisation)
Ammonia
Chimney
Desulphuri-sation Lime
susp.
Combustion Air Boiler
Condenser
E-Filter
Denox
Gypsum
Coaldust
Air and Steam
CO 2
Steam
Cooling Tower
Air
Cooling-Water Circuit River
Source: www.leifiphysik.de
Module D 1: Guidelines for the Monitoring, Reporting and Verification in the Energy Sector
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Example Power Plant: Source Stream Diagram
Boiler silo
Boiler A Boiler B
NG Oil
Lime Coal pile Coal
Delivery silo Coal
Waste
Desulph-
urisation
CO2
System boundary
Coal mass balance
Source: eins energie in sachsen GmbH & Co. KG Chemnitz
Module D 1: Guidelines for the Monitoring, Reporting and Verification in the Energy Sector
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Example Power Plant: Identify Requirements
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Category C plant
Gas-fired power plant with total emissions of ≥ 500,000 t CO2/yr
CO2 Emissions = Activity data * Emission factor * Oxidation factor
Tier 4 Tier 3 Tier 3 Tier 1
Amount of fuel (ex: Gas) * NCV
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Example Power Plant: Activity Data
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Tier 4
The fuel consumption over the reporting period shall be determined by the operator or fuel
supplier within a maximum uncertainty of less than ± 1.5% taking into account the effect of stock
changes where applicable.
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Example: Requirements Emission Factor
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Example: Requirements Net Calorific Value
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Sampling & Analysis
Implementation and Quality Assurance
• For Sampling & Analysis, applied methods shall be based on EN standards (alternatively,
ISO or national standards, industry best practice guidelines)
• Batch specific sampling & analysis, consistency in applying calculation factors to
underlying fuel/material streams/batches, for which they are representative
• Establish sampling plan: written procedure, including sampling method, location,
frequency, quantities, responsibilities, method for storage and transport
• Adapt sampling plan in case of high heterogeneity of fuel/material
• Laboratory shall be accredited in accordance with EN 17025
• If not available, demonstrate that the non-accredited laboratory meets equivalent requirements
• Frequencies for analysis
• As listed in Annex VII of the monitoring regulation
• Alternative: Demonstrate that variation of parameter < 1/3 of uncertainty threshold set by tier
concept for respective activity data
Module D 1: Guidelines for the Monitoring, Reporting and Verification in the Energy Sector
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Example: Small Power Plant’s Monitoring Requirements
Category A plant
Gas-fired power plant with total emissions of < 50,000 t CO2/yr
CO2 Emissions = Activity data * Emission factor * Oxidation factor
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Tier 2 Tier 2a/2b Tier 1
Amount of fuel (ex: Gas) * NCV
Tier 2a/2b
Source: BMU/DEHSt, December 2011
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Example: Small Power Plant’s Monitoring Requirements
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Tier 2
The fuel consumption over the reporting
period shall be determined by the operator
or fuel supplier within a maximum
uncertainty of less than ± 5 % taking into
account the effect of stock changes where
applicable.
Tier 2a/2b
• Country-specific NCV or
• For commercially traded fuels the NCV as derived
from the purchasing records for the respective fuel
provided by the fuel supplier is used, provided it
has been derived based on accepted
national/international standards.
Tier 2a/2b
• Country-specific emission factors (EF) or
• EF is derived by the density measurement
of specific oils or gases common, e.g. to the
refinery or steel industry, and
• EF is derived by the net calorific value for
specific coal types.
Tier 1:
Standard Oxidation
factor of 1 is used.
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Uncertainty Assessment
• Simplified approaches:
• Measuring instrument is subject to national legal metrological control:
Overall uncertainty = Maximum permissible error in service
• In case of calibrated devices the operator has to show that all requirements
of the following four steps are met:
• Step 1: Operating conditions regarding relevant influencing parameters are
available
• Step 2: Operating conditions regarding relevant influencing parameters are met
• Step 3: Performing quality assured calibration procedures
• Step 4: Further quality assurance procedures for measuring activity data
• In other cases the operator has to carry out a specific uncertainty
assessment
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas
Emissions
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Frequencies for analyses
• Minimum frequencies for analyses for
relevant fuels and materials listed in Annex
VII MRR
• Use of a different frequency allowed where
minimum frequencies are not available or
where the operator demonstrates one of
the following:
– Any variation in the analytical values
for the respective fuel or material does
not exceed 1/3 of the uncertainty value
to which the operator has to adhere
with regard to the activity data
determination of the relevant fuel or
material
– using the required frequency would
incur unreasonable costs
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
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Typical Problems for Companies with ETS Introduction
• Inside of a company: extent of issue sometimes underestimated:
– Often treated as classical „environment issue“, underestimating financial relevance;
– Lack or only slow provision of personal and / or financial capacities;
– Necessary processes not defined (e.g. “who is responsible for what?”);
– Sometimes also excessive care for minor important (technical) details;
– Lack of or not well defined internal management systems.
• Related to government action beyond MRV:
– High time pressure;
– Belated release of legal prescriptions / other requirements;
– Some important business regulation appeared only with considerable delay
(e.g. treatment of EUAs within taxes and balances for companies).
• Conditions like:
– Delay of registries;
– High dynamics in regulatory environment.
• Problem for performance and
intra-company acceptance!
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
49
Steps 6: Approval of Monitoring Plan
8. CO2-
Monitoring
2. Allocation
Application 3. Verification of
Allocation Application
4. Allocation
Decision
1. Definition Legal
Framework,
Scope, GHG
permission
7. Issuance of
Allowances
9. Emission Report
11. Submission
of Emission
Report
13. Obligatory
and in-depth
checks Steps 7-14 are repeated annually!
10. Verification of
Emission Report
14. Surrender of
Allowances
Plant Operator
Verifier Legislative Body Competent Authority
Source: FutureCamp 2014
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
12. Entry into
Registry (VET)
5. Establishment of
Monitoring Plan 6. Approval of
Monitoring Plan
• The monitoring plan has to be submitted once to the competent authority for approval before starting the operation.
• In case of adjustments of the monitoring plan which are subject to authorization, reapproval necessary.
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Step 8: CO2 Monitoring
8. CO2-
Monitoring
2. Allocation
Application 3. Verification of
Allocation Application
4. Allocation
Decision
1. Definition Legal
Framework,
Scope, GHG
permission
7. Issuance of
Allowances
9. Emission Report
11. Submission
of Emission
Report
13. Obligatory
and in-depth
checks Steps 7-14 are repeated annually!
10. Verification of
Emission Report
14. Surrender of
Allowances
Plant Operator
Verifier Legislative Body Competent Authority
Source: FutureCamp 2014
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
12. Entry into
Registry (VET)
5. Establishment of
Monitoring Plan 6. Approval of
Monitoring Plan
• Plant operator is obliged to monitor his emissions on the basis of the approved monitoring plan and to report them in Step 9.
• Information regarding the methods for CO2 emissions determination has been already provided in Step 5.
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Content
• Goal and Objectives
• Why Monitoring & Reporting
• Background
• Overview of Monitoring and Reporting Process
• Monitoring Plan
• Emission Report
• Determination & Verification Process
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
52
Step 9: Emission Report
8. CO2-
Monitoring
2. Allocation
Application 3. Verification of
Allocation Application
4. Allocation
Decision
1. Definition Legal
Framework,
Scope, GHG
permission
7. Issuance of
Allowances
9. Emission Report
11. Submission
of Emission
Report
13. Obligatory
and in-depth
checks Steps 7-14 are repeated annually!
10. Verification of
Emission Report
14. Surrender of
Allowances
Plant Operator
Verifier Legislative Body Competent Authority
Source: FutureCamp 2014
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
12. Entry into
Registry (VET)
5. Establishment of
Monitoring Plan 6. Approval of
Monitoring Plan
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Step 9: Emission Report
• To be submitted to competent authority by 31 March
• Using available EU Templates or
• Special Software „Formular Management System“ (FMS), which must be used in Germany. It:
– Provides automatic checks;
– Reduces potential for errors (data import from monitoring plans);
– Increases cost-effectiveness of checking reports on the part of DEHSt and
– Facilitates verifiers‘ work.
• Guidance for reporting is given by:
– Guideline of EU or the national authority (DEHSt);
– User manual of FMS;
– Downloads on DEHSt homepage (e.g. FAQs, etc.).
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
55
Content of the Emission Report
• General information about the plant;
• Address data (operator, responsible person, responsible authority, verifier);
• Description of the plant sections;
• For each operation carried out, following data should be defined:
– Activity data;
– Net calorific value;
– Emission factors;
– Oxidation factors;
– Actual annual CO2 emissions;
• Information regarding the reporting period;
• Reference to monitoring methodology and plan;
• CO2 emissions reporting according to plant sections;
• Verification report.
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
Example of an emission report
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Step 10: Verification of Emission Report
8. CO2-
Monitoring
2. Allocation
Application 3. Verification of
Allocation Application
4. Allocation
Decision
1. Definition Legal
Framework,
Scope, GHG
permission
7. Issuance of
Allowances
9. Emission Report
11. Submission
of Emission
Report
13. Obligatory
and in-depth
checks Steps 7-14 are repeated annually!
10. Verification of
Emission Report
14. Surrender of
Allowances
Plant Operator
Verifier Legislative Body Competent Authority
Source: FutureCamp 2014
Module B 3.1: Guidelines for the Monitoring, Reporting and Verification of Greenhouse Gas Emissions
12. Entry into
Registry (VET)
5. Establishment of
Monitoring Plan 6. Approval of
Monitoring Plan
Angelika Smuda
Federal Ministry for the Environment, Nature Conservation, Building and Nuclear SafetyDivision KI I 3 – Legal Issues Climate Policy, Emissions Trading
Felix Nickel
FutureCamp Climate [email protected]