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Combustion Installations. Stakeholder Day on the EU-Monitoring and Reporting Guidelines Cologne, 12 May 2005. Dr Giuseppe MONTESANO Member, EURELECTRIC Climate Change Working Group. BACKGROUND. Principles of ANNEX IV of Directive 2003/87/EC include: Use of standardised or accepted methods
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Combustion Installations Stakeholder Day on the EU-Monitoring and Reporting Guidelines Cologne, 12 May 2005 Dr Giuseppe MONTESANO Member, EURELECTRIC Climate Change Working Group
BACKGROUND • Principles of ANNEX IV of Directive 2003/87/EC include: • Use of standardised or accepted methods • Co-ordination with existing reporting requirements to minimise burden on business • EURELECTRIC considers that the Guidelines should be: • Consistent, accurate, verifiable, cost-effective
EURELECTRIC CONCERNS • Economic / Cost effectiveness • Strategic • Technical
ECONOMIC CONCERNS • Replacement of existing “accepted methods” • Some proposed tier levels are unrealistic and excessively costly • Well-established procedures exist for determination of fuel quantity and quality to serve commercial transaction requirements and revenue / taxation determinations • Requirement for EN/ISO 17025 accreditation • Measurement bodies and companies apply recognised standards • Procedures are in place to validate / audit reported data
STRATEGIC CONCERNS • Impact on the extension of ET scheme to other activities / gases • Clear intent of Directive (Art. 24, 30) BUT • Are similar accuracy requirements for other activities / gases reasonable or achievable? • Activity data uncertainty • Emission factor uncertainty • If not does MRG act as a barrier to extension of ET scheme?
TECHNICAL CONCERNS • Validity of Table 2 (metering uncertainty) data • Inability of current metering devices / methods to provide required uncertainty levels • Justification for EN/ISO 17025 requirement? • Evidence of failure of existing procedures? • Impact of limited number of laboratories on reporting • Timescale for accreditation of sufficient number of laboratories • Accuracy impacts for high moisture content fuels • Standard factors may be sometimes more accurate
PROPOSALS (I) • Respect EU competitiveness requirements • Highest practicably achievable accuracy without excessive cost • Improve transparency: • Either specify in more detail the Tier requirements to reflect practical experience • Or give wider discretion to authorities to determine compliance with the general principles • Include a common definition for “batches” • Remove requirement for EN/ISO 17025 accreditation
PROPOSALS (II) • Review assumed Tier uncertainty values to reflect current practical experience • Improve presentation by use of schematics (esp. Annex I) and practical worked examples • Include more comprehensive list of fuels in Table 4 (Annex I) • Subject Reporting Templates to a pilot verification exercise
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