Dr Rob Gemmill Technical Adviser Monitoring & Assessment Process Management

1. EU MONITORING AND REPORTING GUIDELINES STAKEHOLDER DAYCologne, 12th May 2005UK APPROACH: PAST PRESENT AND FUTURE Dr Rob Gemmill Technical Adviser Monitoring & Assessment Process Management

2. Objectives To indicate: • Approach taken in the UK • Things that have worked well - successes • Issues arising and going forward • Permit conditions to gain maximum benefit from verification • Challenges for the MRG Review

3. UK Regulatory Timetable • Directive (2003/87/EEC): October 2003 • UK GHG Emissions Trading Scheme Regulations entered into force 31.12.03 • Commission Decision establishing guidelines for M&R of GHG Emissions 29.01.04 • 1,100 Permits issued by 31.03.04 • Re-issue of 1,100 permits including approved M&R plans by 31.12.04 • Re-issue of Consolidated Regulations 2005

4. Successes (Permitting 1) • Time-scales met including notifications regarding >500kt CO2 installations • M&R Guidelines (Commission Decision) • Well established communications between Government, Regulators, Verifiers and Industry (consultation/workshops) • Dedicated “National Once Task and Finish Groups” established to deliver • Lean approach - costs kept down

5. Successes (Permitting 2) • Electronic application and permitting system (England and Wales) • Standard forms and templates provided • Helpdesks and websites for queries and products/guidance • eu.ets@defra.gsi.gov.uk • ethelp@environment-agency.gov.uk • www.defra.gov.uk/environment/climatechange/ trading/eu/index.htm • Baseline Verification

6. Successes (Communications) • European - WG3, IETA, Member State led projects/liaisons • UK Emissions Trading Group - SG3 (Verification), SG7 (Permitting and Data) • Competent Authority/Regulator Meetings • MRV Group • Workshops for industry CCC - CENTRAL CO-ORDINATION CRUCIAL

7. Location of M&R Products Competent Authority websites Environment Agency: http://www.environment-agency.gov.uk/emissionstrading Select: “What operators need to do”, “Apply for a permit”, “Get an application form”

13. Website Products: Summary • Permit application forms, examples and guidance • M&R Guidelines (Commission Decision) • Guide to the Guidelines • Monitoring & Reporting Plan Template • Guidance to Completing the M&R Template • Exemplar M&R Plans • M&R Protocols • Uncertainty Paper • Frequently asked Questions and Answers

14. Issues Arising 1 (Combustion) • Scope of installation/activity • “Processes”/emissions included • Aggregation and no “de minimus” • Fuel supply complications (natural gas) • Compliance difficulties - limited scope for “no-tier” • Country-specific or IPCC factors not always available • Meter upgrade/installation not always technically feasible or reasonable cost

15. Issues Arising 2 (Combustion) • Input metering requirement - back-calculation/ modelling not allowed (even for 100% biomass combustion) • Meter accuracy or uncertainty analysis requirement • Meter calibrations (Section 7.2 requirements) • Representative sampling guidance limited • Net CV reporting requirement • Representative sampling of some fuels not practical, e.g. tyres (standard European factor?)

16. Issues Arising 3 (Combustion) • ISO17025 • Section 10: Mandatory top tier requirement for laboratory services • Waste of non-accredited installation-specific data (counter to the MRG accuracy principle) • Big drop between top and next tier • Appropriateness of country-specific factors • MRG definition inflexible • Baseline versus permitted discrepancy

17. Issues Going Forward • Interface with verifiers • Confidence in the verification process • Standard and electronic reporting template • Improvement to monitoring methodologies • What is good practice? - IMPEL project • Commission MRV review • Frequently asked questions • Phase 2 (NAP by June 2006)

18. Relationship with Verification (1) Permit definition • "Verifier" means a verification body accredited to carry out the verification requirements of Article 15 of the Directive and, in this context, “accredited” means accredited by a member of the ‘European Co-operation for Accreditation’ having regard to the latter’s greenhouse gas verification guidance

19. Relationship with Verification (2) Planned permit condition • The Operator shall submit a report to the Regulator, by 30 June each year, identifying all the potential improvements, in monitoring and reporting, identified by the Verifiers during the previous year. This report shall include the Operator’s proposals for implementing the identified improvements or justify why the improvements are not to be made

20. MRG Review Challenges 1 Further promote consistency/level playing field: • Remove confusion over uncertainty/accuracy • Confirm ISO17025 requirements (position on use of non-accredited installation-specific data) • Extend indication of acceptable Section 10 sampling methods, and what is representative • Clarify Section 7.2 requirements/responsibilities • Further define “representative sampling”, “batch”, “country-specific factors”, “minor/no-tier sources”, “verification requirements”, etc.

21. MRG Review Challenges 2 Reduce disproportionate burdens: • Set a combustion activity de minimis via the MRG • Allow overall-installation uncertainty compliance • Provide small emitters greater protection from disproportionate implementation/running costs • Accommodate alternatives to metering • Modify discretion for “no tier” compliance - change to a cost-based as well as emission-proportion consideration

22. Conclusions • Excellent progress made on permitting • Effective communications established and products published • Seeking added feedback from verification • Support harmonization initiatives • Issues arising need to be shared across the EU quickly - MRG review is not soon enough

23. EU MONITORING AND REPORTING GUIDELINES STAKEHOLDER DAYCologne, 12th May 2005UK APPROACH: PAST PRESENT AND FUTURE Dr Rob Gemmill Technical Adviser Monitoring & Assessment Process Management