MRV IN TURKEY: FROM THEORY TO PRACTICE CEMENT SECTOR EXPERIENCE

Canan DERİNÖZ GENCEL

Head of Environment and Climate Change Department

Turkish Cement Manufacturers’ Association

COP 23, Bonn/Germany 14 November 2017

TURKISH CEMENT MANUFACTURERS’ ASSOCIATION- TCMA

Formal representative of the Turkish Cement Producers

Founded in 1957

Based in Ankara/Turkey

64 employees (R&D, laboratory analyses, certification and environment)

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• Links sector - government – public

• Local and international relations

• Issues: production, quality, training and technology

• Certification Body (environment & product quality)

TCMA Memberships/Memorandum of Understanding/Partners

1972 • European Cement Association

2009 • European Concrete Paving Association

2009 • Arab Union for Cement and Building Materials

2010 • Indian Cement Association

2011 • China Cement Association

2014 • European Cement Research Academy

2015 • Cement Sustainability Initiative (CSI)

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www.tcma.org.tr

Country-wide Production

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Turkish Cement Sector

1911

20.000 tons/year

2011

100th Anniversary

2016

80 Million tons/year

(Europe 1. World 4.)

72 plants

(54 integrated, 18 grinding)

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Share of Local Capital %81 Share of Foreign Capital %19 (French, Italian, German, Brazilian and Greek companies)

Turkish Cement Sector – Important Topics

Housing

Infrastructure

Energy Projects

Concrete Road

& Barriers

Climate Change

AF/ARM Utilization

Iran, Iraq, Syria

& S. Arabia

Environmental Liabilities

Technological Investments

Energy Efficiency

TCMA has a dedicated department for climate change and environment

MRV Scope

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Energy

Energy+ CO2 Fossil Fuels + O2

Proces- Calcination

Oxides + CO2 Raw Meal (Carbonates) + Energy

Raw Meal + Fuel

Clinker

Grinding

Cement

MRV Profile of Turkish Cement Sector

Total emissions generally >500.000 tons CO2 eq/year

Category C

Highest Tier required

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MRV Profile of Turkish Cement Sector

Standard Calculation

• Method A- input based

• Method B- output based

Mass Balance Calculation

(input and output is clear)

Continuous Measurement

(Calibrations, Annual Surveillance Tests)

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General Preference

Aim of MRV in Cement Sector

So simple:

Determine CO2 from fuels and calcination correctly and precisely

Verify your emissions

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Turkey’s MRV Pathway and the Cement Sector

2011

Start-up

2012 Monitoring regulation

2014

Revised monitoring regulation

2015

Verifier regulation

2017

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• Regulations in line with EU MRV Legislation (some exceptions, i.e. unreasonable costs) • Contributed to drafting legislation of the Turksih Ministry of Environment (MOE) • Sector completed duties in the legislation

Cement sector • Submitted monitoring plans • Monitoring emissions • Verifying emissions reports

Cement Sector Capacity Building- Trainings/Exercise

Trainings organized by TCMA

• 2008/2009 –CSI methods- sector filled out CSI forms for CO2 budgeting

• 2013- Monitoring Plans

• 2013-Emissions Calculations

• 2016-2017-Emissions Calculations (EU Experience)

• 2017-Emissions Calculations/Uncertainty (German Experience)

• 2017- Uncertainty Calculations (Dec, 2017)

Trainings organized by GIZ & MOE

• 2014- Monitoring Plans – as per the new regulation

• 2015-Emissions Calculations– as per the new regulation

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Capacity Building efforts for more than 10 years for the sector specialists

Capacity Building

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Cement Sector Capacity Building-Pilot Projects

GIZ Capacity Building Project – 1 Pilot Plant

The World Bank Partnership for Market Readiness Project, Turkey- 5 Pilot Plants

Sectoral participation to ‘Lessons Learnt’ Seminars

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Application of the Turkish MRV Regulation

EU started MRV with Phase I and Phase II (2005-2012)- learning period

Members states had flexibility for scope of monitoring plans and reporting in Phase I and Phase II

Turkish MRV is adoption of EU Phase III regulation (EU 601/2012 –

Monitoring and Reporting Regulations)

• Detailed

• Covers missing points in Phase I and II

• Provides harmonization in the EU

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Application of the Turkish MRV Regulation

•Turkish Ministry of Environment and Urbanization-Great ambition& performance to accomplish the new system – continuous dialogue with private sector

•Capacity Building Projetcs of the MOE (Detailed GIZ supported trainings/guidelines on monitoring plans/ emission reports/verification was very helpful)

•Transition period of 3 years for using lowest tiers provided room for adaptation to beginners (2015-2016-2017)

•Monitoring plan software provided harmonization

• Difficult and time consuming ‘learning by doing’ period and expected to continue

• Sector was familiar with CSI methodology but (EU adopted) MRV rules were different- thus need to change emissions reporting methods

• Text too complicated and detailed for EU legislation beginners

• Turkish translation of the monitoring plan software should have been in parallel to issue of the regulation (Companies that do not have English speaking staff could not use the MP template on time)

• Authorization of verifiers and verifier companies were delayed.

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Challenges: Transition Period ends in 2018

By 2018, highest Tiers will be used (Tier 3 and Tier 4)

Detailed Uncertainty calculations

Revision of measurement devices may be required

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Tier Maximum uncertainty to report quantity of fuel (t or m3)

1 7,5%

2 5,0 %

3 2,5 %

4 1,5 %

Challenges: Transition Period ends in 2018

Frequent analyses for process and fuel emissions and waste fuels (fossil and biomass) Higher precision Additional workforce (sampling etc.) and costs Representativeness of the samples

Rough estimate for number of analyses required by 2018

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Frequency Total Consumption*

Number of Analyses

Carbonates each 50.000 tons (CaCO3, MgCO3)

104 million ton 2000 -4000 analyses/year

Solid fuels each 20.000 ton (for lots containing higher amount, analyses of each lot)

8 million ton 400 -800 analyses/year

Waste Fuels

0.6 million ton

150-450 analyses/year

* TCMA Data- 2016

Challenges and Recommendations Use of Non Accredited Laboratories

Legislation requires accredited laboratories for analyses. Laboratories non accredited (e.g. cement plant laboratories) are allowed if accredited labs are;

technically not feasible

that the non-accredited laboratory meets requirements equivalent to ISO standard for accreditation of analysis laboratories (EN ISO/IEC 17025)

Issue of a formal guideline/technical paper on equivalency procedure and conditions for technical unfeasibility will be helpful for the industry

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Challenges and Recommendations

Emissions monitoring and reporting is not the job of environmental staff only- it is an integrated job.

More accredited laboratories are required

Conflict of interest definitions should be more clear

Number of experienced verifiers and verifier companies expected to increase in forthcoming years

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Cement sector has been working seriously to fulfill its MRV requirements and support of the Ministry for capacity building has always been very important for the sector

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Thank You

Turkish Cement Manufacturers’ Association

www.tcma.org.tr info@tcma.org.tr