Combustion Installations

1
Combustion Installations
Stakeholder Day on the EU-Monitoring and
Reporting Guidelines Cologne, 12 May 2005
Dr Giuseppe MONTESANO Member, EURELECTRIC Climate
Change Working Group
2
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

3
EURELECTRIC CONCERNS

• Economic / Cost effectiveness
• Strategic
• Technical

4
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

5
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?

6
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

7
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

8
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

9
At the forefront of the electricity industry.
www.eurelectric.org

32 2 515 10 00

eurelectric_at_eurelectric.org