Stakeholder day on the EU-Monitoring and Reporting Guidelines – Experiences of the Pulp and Paper

1. Stakeholder day on the EU-Monitoring and Reporting Guidelines– Experiences of the Pulp and Paper Esa HyvärinenConfederation of European Paper Industries (CEPI) Cologne, 12 May 2005

2. The pulp and paper industry • Energy is a key input for the pulp and paper industry: • Up to 30% of production costs. • 40% of electricity used is produced on site, of which 90% is produced through combined heat and power (CHP) and 52% of all energy consumed comes from renewable energy sources. • The industry still purchases 70 TWh of electricity per year.

3. The pulp and paper industry • 880 companies, about 1.300 mills: • Several big multinationals, many SMEs. • Processes are very different; • Chemical pulping generates more energy than the process requires. • Mechanical pulping an energy intensive process. • Paper mills do not necessarily have any direct emissions (some mills have zero quota). • Recycling process demands less energy than mechanical pulping, but does not have a natural source of biomass to be used.

4. MRG - General comments • Not much experience yet – not very much feedback from the mills. • Testing in practice next year. • Considered to be unnecessary tight for the purpose. • Need for some big changes but not very big number of changes.

5. Accuracy – Flexibility – Cost-effectiveness – Level playing field • Very accurate – not too flexible – cost-effectiveness can be improved: • High accuracy requirement leads to inflexibility and low cost-effectiveness. • Possibility to exclude minor emissions, which are smaller than the error margin or uncertainty related to the total emissions of the installation. • Tier approach has a potential to lead unnecessary tight requirements and create an un-level playing field.

6. Combustion • Possibility to use mill-level calculation must remain: • Most (if not all) of the emissions from pulp and paper industry are from combustion of fossil fuels that come outside the mill. • Based on current practices in taxation for example. • Can benefit of the documentation from normal bookeeping (fuel purchaces).

7. Combustion • Tier approach: • Installations emitting more that 50 kt/y: • Batch level analysis of the net calorific value, emission factor, composition and oxidation factor to be carried out by a laboratory certified according to EN ISO 17025. • Standard emission and oxidation factors: • The more standard emission and oxidation factors the better.

8. Combustion • Biomass: • General method to define biomass content of mixed fuels still missing. • Biomass content to be analysed by a laboratory certified according to EN ISO 17025. • Why analyse the net calorific value if the emission factor is assumed to be zero anyhow? • List also crude tall oil, tall oil and pitch oil as pure biomass.

9. Production of pulp and paper • Process emissions: • Emissions from the use of carbonates as make-up chemicals in pulp mills (CO2 from CaCO3 that compensates biogenic lime mud): • The amount is negligible (e.g. in Finland 2.000 t out of 5.000.000 t of total emissions from the pulp and paper industry). • The lost material is usually landfilled, which means that there are no emissions. • These emissions should be excluded as a minor source.

10. Production of pulp and paper • Process emissions: • CEPI currently assessing what in the end should be considered as process emissions in the case of pulp and paper industry: • Lime kiln, recovery boiler, infra- red dryers in papermachines, etc.

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