1 / 9

Combustion Installations

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

angelawillis
Download Presentation

Combustion Installations

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  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@eurelectric.org

More Related