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GHG Monitoring in the UK Emissions Trading Scheme

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Title: GHG Monitoring in the UK Emissions Trading Scheme


1
GHG Monitoring in the UK Emissions Trading Scheme
  • Tatiana Bosteels
  • COP8
  • New Delhi
  • October 2002

2
Agenda
  • The UK ETS
  • Aim of the GHG monitoring system
  • Key Principles
  • Issues behind the requirements
  • Monitoring requirements

3
UK Emission Trading Scheme
  • Economy wide voluntary scheme with a variety of
    entry routes and types of participants
  • Climate Change Agreement
  • Direct Participants through government incentives
  • Future potential participants
  • Projects
  • Links with other national and regional schemes

4
Aim of the Monitoring system
  • Ensure accurate and transparent
    calculation/estimation and reporting of emissions
  • By provision of the detailed steps for
    measuring and reporting emissions
  • Final Objective
  • Facilitate third party verification of baseline
    and yearly performance

5
Monitoring procedures
  • Procedures Intended to be consistent with
  • Good practices issued by the Intergovernmental
    Panel on Climate Change (the IPCC)
  • UK Environmental Reporting guidelines
  • Climate Change Agreements

6
Monitoring System Key Principles
  • Faithful representation
  • Of transactions and event, quantify uncertainties
  • Completeness
  • Data within bounds of materiality and rules of
    scheme
  • Consistency
  • Over time between baseline and subsequent years
  • Reliability
  • Data free from material misstatement and bias
  • Transparency
  • Data shall be replicable by a third party through
    provision of sufficient information and a clear
    audit trail

7
Issues Behind Monitoring Requirements
  • Double Counting.
  • Only one participant to claim responsibility for
    a single emissions source.
  • Verifiability.
  • The Baseline and claimed emission reductions
    shall be supported by data of sufficient
    quality.
  • Cherry Picking.
  • Must present the complete picture of emissions,
    no picking of preferred sources only
  • National boundary.
  • Emissions of UK- based operations only
  • Leakage.
  • Ensure that Participants cannot claim emissions
    reductions by shifting the responsibility outside
    their Source List.

8
General Rules of Monitoring System
  • Management Control
  • Dominant influence over the emission from a
    source
  • Ability to direct the financial and operating
    policies governing the emissions from the source
  • Materiality threshold in annual reporting figures
    and baseline
  • Relative significance or importance of
    misstatement in the total emissions figure
  • Material if
  • Broad guideline aggregate uncertainty in the
    total emissions figure gt 5 of total emissions
  • Accepted Reasons for Exclusions of sources
  • Lack of management control
  • Based on size threshold (individually lt1 total
    baseline)
  • No protocol for the source and not willing to
    develop one
  • Lack of verifiable data during baseline period

9
Direct Participants
  • Participants shall be monitoring and reporting
    emission reductions at the source level
  • Sources can be aggregated to a level which makes
    sense in the context of the business activities
  • The collection of one or more point
    sources of the same type within a site
  • point source is any separately
    identifiable point from which greenhouse
    gases are emitted

10
Direct Participant Emission Sources
  • Energy related emissions sources include
  • On-site combustion of fossil fuels for on-site
    use
  • On-site consumption of electricity that is
    generated off-site
  • On-site consumption of electricity generated
    on-site
  • On-site consumption of heat or steam generated
    off-site
  • On-site consumption of heat or steam generated
    on-site.
  • Exclusions
  • Heat or electricity exported from a site will not
    be counted
  • Process emissions
  • CO2 process emissions protocols provided for
    main activities
  • non-CO2 process emissions participants to
    propose protocol to the Government

11
Direct Participant Monitoring requirements
  • Identifying source list and calculating baseline
  • Identify the sources it is bringing into the
    Scheme
  • Management control
  • Source within a sector
  • verifiable emission data
  • eligibility for entry
  • coverage of GHG
  • Coverage within reporting guidelines
  • Calculate Baseline emissions
  • Estimate annual emission over period 98-99-00
  • Identify sources below the size threshold (1)
  • Keep a written record of the decisions taken at
    each step

12
Direct Participant Monitoring requirements
  • Data to be monitored and reported on annual basis
  • Series of protocols that specify in detail the
    methodology to be used to measure and report
    emissions from sources.
  • Effective data management system must be in place
  • Processes for internal audit, data checking, and
    quality assurance
  • Clear definition of responsibilities for data
    management
  • Risk management procedure in place
  • Track adjustments to Baselines, Source Lists and
    targets

13
Direct Participant Monitoring requirements
  • Series of protocols that specify in detail the
    methodology to be used to measure and report
    emissions from sources.
  • Protocol for energy related emission
  • Fuel consumption related CO2 emissions
  • Import of export of heat and power
  • Renewable
  • Protocol for process related emissions
  • Cement manufacture
  • Lime production
  • Limestone and dolomite use
  • Soda Ash
  • Ammonia use of fuels as feedstock
  • Metal production
  • Waste incineration, Municipal Solid Waste and
    Sewage
  • Non CO2 process related emissions developed by
    participants
  • CH4 from Flaring
  • HFCs

14
Example of required data - Baseline
15
Example of required data Annual Emissions
16
CCA Participants
  • Minimum Monitoring requirements
  • To demonstrate compliance with target
  • Get 80 reduction of Climate Change levy
  • Requirements for trading into the ETS
  • More stringent requirement
  • Independent third party verification

17
CCA Participants Minimum Requirements
  • Energy use by fuel
  • Including fuel ascribed to bought-in heat or
    electricity from CHP or other dedicated plant and
    excluding fuel ascribed to heat or electricity
    exports
  • Measure of output
  • For sectors with efficiency targets
  • Qualitative performance measures
  • Where these form part of the agreed target
  • Volume of allowances bought or sold in the Scheme

18
CCA Participants Minimum Requirements
  • Energy figures to be reported in terms of primary
    energy units
  • A standard set of conversion factors is to be
    used to convert to delivered energy
  • Same factors as Direct participants but for two
    exception LPG and Coke
  • Conversion factors for energy efficiency targets
  • Common unit tonnes of CO2 equivalent
  • Must take account of both the average emission
    factor, and the annual production level
  • Guidelines provided

19
CCA Participants trading in the UK ETS
  • However, to sell emission reduction in the market
  • Must have third party verification
  • energy use
  • emissions data
  • output and product mix data where relevant
  • evidence of a systematic approach to data
    management
  • Must follow monitoring requirement of Direct
    Participants

20
Thank You
  • Tatiana Bosteels
  • ERM Climate Change Team
  • Tel 44 20 7465 7318
  • email tatiana.bosteels_at_erm.com

21
Monitoring procedures
  • Procedures Intended to be consistent with
  • Good practices issued by the Intergovernmental
    Panel on Climate Change (the IPCC)
  • IPCC guidelines are designed for use at the
    national level, but the recommended methodologies
    for data collection, calculation of greenhouse
    gas emissions,reporting conventions, plus both
    data quality control/assurance and treatment of
    uncertainties in the data are also relevant for
    emissions trading. Need to adapt to site level
  • UK Environmental Reporting guidelines
  • Same methodology, but different approach as ETS
    must be more prescriptive on issues such as
    eligibility, scope, inclusion of sources,
    boundaries, and double counting
  • Climate Change Agreements

22
Aim of the Monitoring Guidelines
  • Specify the key principles which Direct
    Participants must follow when
    calculating/estimating and reporting emissions.
    These principles shall be taken into account in
    the development of new protocols submitted by
    Direct Participants to DEFRA. These principles
    are given in section 2.
  • Give practical guidance to Direct Participants
    on a number of the requirements of the
    Scheme outlined in the framework document. These
    are provided in sections 2-5.
  • Provide the detailed steps for measuring
    and reporting emissions. These are set
    out in the annexes

23
Monitoring System Key Principles
  • Faithful representation
  • Information shall represent faithfully the
    transactions and other events it either purports
    to represent or could reasonably be expected to
    represent.
  • Uncertainties shall be quantified and data shall
    neither be systematically overestimated nor
    underestimated so far as can be judged.
  • Uncertainties shall be reduced so as to be
    immaterial.
  • Completeness
  • Complete within the bounds of materiality and the
    rules of the Scheme, such that information shall
    not be misleading or unreliable in terms of its
    relevance.
  • All sources above the Size Threshold within the
    defined and chosen Source List shall be included
    in the Baseline and annual emissions.
  • Leakage effects shall be accounted for

24
Key Principles
  • Consistency
  • Consistent methodologies and measurements shall
    be used between the Baseline and subsequent
    years.
  • Data shall be comparable over time.
  • Estimates shall be comparable with the UK
    inventory estimates and with international
    guidelines including IPCC guidance.
  • Reliability
  • Baseline and annual emissions and related
    disclosures shall be free from material
    misstatement and bias and capable of being
    depended upon by users to represent faithfully
    that which it either purports to represent or
    could reasonably be expected to represent.
  • Changes in methodologies shall derive from
    continuous improvement of data quality and shall
    be clearly stated and documented to allow for
    year-to-year comparisons.

25
Key Principles
  • Transparency
  • Reported data shall be replicable by a third
    party through provision of sufficient information
    and a clear audit trail.
  • References and methodologies shall be clearly
    documented.
  • Changes over time shall be clearly documented to
    allow clear understanding.
  • Third party verification by an accredited
    verifier shall be undertaken

26
Issues Behind Monitoring Requirements
  • Double Counting.
  • It is not acceptable for more than one
    Direct Participant to claim responsibility for
    a single emissions source. This is of primary
    importance for Direct Participants when
    determining the sources over which they have
    management control.
  • Verifiability.
  • The Baseline and any claimed emission
    reduction from a source shall be supported
    by data of sufficient quality.
    Consideration of the key principles
    underpinning the Reporting Guidelines should
    help guide Participants towards obtaining data of
    sufficient quality to satisfy an independent
    accredited verifier.

27
Issues Behind Monitoring Requirement
  • Cherry Picking.
  • Participants shall not be allowed to
    include only those elements of their
    operations which they consider would provide the
    easiest scope for emissions reductions. There is
    an obligation to present the complete picture
    of emissions in order to prevent
    organisations from claiming emissions
    reductions in one area of their operations
    while simultaneously increasing emissions from
    other areas.
  • National boundary.
  • Since the Scheme is to contribute to UK emissions
    reduction (and hence to the UKs target under the
    Kyoto Protocol), the scope for reporting
    emissions under the Scheme will not extend beyond
    the scope of the UK inventory. Thus for the
    purposes of the UK Scheme, the emissions
    associated with UK- based operations must be
    separately identifiable.

28
Issues Behind Monitoring Requirements
  • Leakage.
  • Having defined the Source List for reporting
    emissions, it is important to ensure that
    Participants cannot simply claim emissions
    reductions by shifting the responsibility outside
    their Source List. One example of this would be
    to outsource a product or service which
    transfers accountability of the associated GHG
    emissions to another organisation. Such changes
    need to be accounted for.

29
Direct Participant Monitoring requirements
  • Effective data management system must be in place
  • Clearly defined responsibilities for issues such
    as data collection, collation, aggregation, and
    quality control
  • The existence of appropriate tools or procedures
    to support consistency in data estimation and
    collation within an organisation
  • Methods for systematic data archiving and process
    documentation
  • Processes for internal audit, data checking, and
    quality assurance.
  • Processes for taking corrective and preventative
    actions.
  • Clearly articulated methods of data
    interpretation.
  • Processes for periodic review of the data
    management system itself.

30
Direct Participant Monitoring requirements
  • In order to track adjustments to Baselines,
    Source Lists and targets following data must be
    recorded
  • Identify any changes in management control to
    individual sources within the Source List that
    are above the Change Threshold as defined in the
    framework document
  • Identify whether the cumulative effect of
    changing management control of sources within the
    Source List meets or exceeds the Change Threshold
    as defined in the framework document
  • Provide evidence showing whether sources within
    the Source List have been divested to another
    Direct Participant or divested in any other way
    (including closure)
  • Provide evidence of any contractual arrangements
    for maintaining a source in the Baseline in the
    case of divestment or acquisition from another
    Direct Participant
  • If substitute sources are added to the Source
    List, evidence shall be provided showing details
    of this substitution.

31
Climate Change Agreement Participants
  • Energy figures to be reported in terms of primary
    energy units
  • where an agreement is set in terms of an energy
    or energy efficiency target, the reported
    quantity is primary energy (i.e. losses
    associated with delivery of the energy are
    associated with the end-user).
  • Conversion factors for energy efficiency targets
  • Converted to a common unit, i.e. tonnes of CO2
    equivalent
  • Must take account of both the average emission
    factor, and the annual production level.
  • Guidelines provided
  • (Guidelines for carrying out this conversion are
    given in Climate Change Levy technical guidance
    notes NA(99)30 and NA(00)07. )
  • A standard set of conversion factors is to be
    used to convert to delivered energy
  • Same factors as Direct participants but for two
    exception LPG and Coke

32
  • Methodologies for calculating/estimating CO2
  • Protocols
  • emissions from fuel-related sources
  • Emissions from industrial processes (termed
    .process emissions.).

33
BAU Emissions
98-00 average 2002 baseline
Govt payment /tonne
2003 baseline
2002 target
Successful bid quantity
Emissions tCO2eq
Govt payment
2003 target
2004 baseline
Govt payment
2005 baseline
2004 target
Govt payment
2005 target
2006 baseline
Govt payment
2006 target
2002
2003
2004
2005
2006
34
Outline of proposed UK ETS
adapted from ETG slide
UK Renewable Obligations ROCs, Energy efficiency
Commitments
ETS, JI, CDM AAUs, ERUs, CERs
Emission Saving Projects 0.3mtC pa?
Unit Participants
Absolute participants
Gateway
CCA cos with output related target
Incentives bidding cos 2 mtC pa?
CCA cos with absolute targets 2.5mtC pa?
Reconciliation retire permits
Reconciliation retire permits
Approval and Certified credits
Emissions Trading Authority
35
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