Enhancing Cost-Effective Accuracy in Combustion Installations

1. Technical Session I: Combustion Installations Jochen Harnisch, Ecofys Cologne, 12 May 2005 EU-MRG Stakeholder Day

2. Overview • 26 questionnaires and 6 position papers/other written comments received • Comments on cross-cutting as well as on technical issues with focus on accuracy requirements EU-MRG Stakeholder Day

3. Comments – Accuracy and Cost-Effectiveness I • Accuracy requirements need to be balanced against cost effectiveness • Stringent accuracy requirements could exclude future inclusion of further greenhouse gases into the EU-ETS • Give concept of materiality more weight regarding accuracy requirements • Allow deviations from tiers where overall uncertainty is still met EU-MRG Stakeholder Day

4. Comments – Accuracy and Cost-Effectiveness II • Allow simplified provisions for smaller installations • Misinterpretation of existing provisions by national authorities can lead to distortion of competition: lay down provisions in more detail or allow deviations from tier system EU-MRG Stakeholder Day

5. Comments – Accuracy and Cost-Effectiveness III • Current provisions require investment in new metering equipment without leading to an increase in data quality  Allow use of existing accepted and proven measurement methods (commercial, fiscal) • Include reference to further standards, e.g. on sampling • Appropriate batch definition is necessary to avoid excessive cost EU-MRG Stakeholder Day

6. Comments – EN ISO 17025 • EN ISO 17025 accreditation does not lead to improved accuracy, but to higher costs • To date only a small number of accredited laboratories exists, which all EU-ETS participants will have to rely on • Transport of samples to an external lab can reduce sample quality • Allow alternative methods of quality control, e.g. laboratory practice equivalent to EN ISO 17025 EU-MRG Stakeholder Day

7. Some input on EN ISO 17025for the discussion during the Stakeholder Day EU-MRG Stakeholder Day

8. EN ISO 17025 accreditation: increase of confidence by external stakeholders (market, authorities, public)! • EN ISO 17025 does not require organisational independence of the laboratory • EN ISO 17025 has a significantly different scope than EN ISO 9000 and 14000 • EN ISO 17025 is the only globally accepted standard for lab accreditation • Core requirements: documentation of procedures and traceability of individual measurement results EU-MRG Stakeholder Day

9. Availability and Costs • 5600 accredited labs across EU – not evenly distributed across all Member States • Time requirement for accreditation (<12 months) of additional labs an issue for an interim phase • Internal costs - depend on current status of labs: - Professionally managed labs: little extra efforts - Basic labs: approx. 3-6 man months • External costs: - Initial fee: 4000 Euro - Annual fee (incl. control audit): 1200 Euro EU-MRG Stakeholder Day

10. Summary • Accreditation requirement in EU-MRG is necessary to ensure confidence by external stakeholders • Costs for well managed labs are limited • Need for interim solutions to bridge the time until accreditation: - define transition time (<12 months) - participation inter-lab comparisons with accredited labs - pre-accreditation audits to define deviations from EN ISO 17025 EU-MRG Stakeholder Day

11. Stakeholder Presentations... EU-MRG Stakeholder Day

12. Items for Discussion • How in detail to implement better cost-effectiveness • Appropriate batch definitions for solid, liquid, gaseous fuels • Alternative measurement methods as alternatives to tier provisions – if same accuracy is achieved? EU-MRG Stakeholder Day

13. Options for Lunch : Carbon Expo or Dorint-Sofitel across entrance Congress-Ost Technical Sessions will start at 13:45!