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Monitoring & Reporting Guidelines

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  1. Monitoring & Reporting Guidelines remarks on Reporting, Uncertainties, CEMs Chris Dekkers Directorate of Climate Change & Industry Ministry of Environment (VROM)

  2. Definitions in M&R Guidelines Definitions & Principles not sufficiently precise for translation into national legislation-regulation: • Level of assurance: what level of assurance obliged by the verifier? • Materiality: the exact and precise definition of what is required? • Monitoring methodology: QA and QC part of the permit? • Legal requirements not clearly and consistently formulated and not sufficiently precise in legal sense • Precise criteria lacking: “technically not feasible” , “economically not justified” • Difference Uncertainty – Accuracy - Precision not clearly explained • How to use “cost effectiveness” in practical situations? • How to use principles of Good Governance in practical situations?

  3. Uncertainty Aspects VROM initiated two studies by KEMA: Assess uncertainty approach in M&R Guidelines and propose solutions • Current practice • Practicability of TIER approach • Practical experiences • Assess improvements to be made

  4. Current Practices • Required tier achievable in Power Plants and in general: industries buying fuels from outside • Problems arise in sectors generating their own fuels: refineries, production of base chemicals, coke in steel manufacturing • Current practice built on technical assumptions on uncertainties

  5. Sectors with own fuels Major differences between various refineries, chemical plants and steel producing plants: • Uncertainties directly related to type of internal produced fuel, variations in these fuels and number of measure points • Uncertainties often installation specific, depending on the number and type of processes • Tiers reported based on assumed uncertainties of various meters • Uncertainties of meters rarely tested for wear & tear: reported uncertainties have an “artificial” element

  6. Leads to following Questions: • Uncertainties of meters rarely tested for wear & tear: Should we require that: • real world uncertainties be measured? • measured values be used? • reported uncertainties be demonstrated? • If so, how? • When is uncertainty acceptable and when should further investments in new meters be justified? • How can we make concept of cost effectiveness applicable in real world situations? • On what basis does Competent Authority decide that further improvements are justified?

  7. Other observations Requirements on verification are not sufficiently clear and defined in legal terms • What level of assurance is to be provided by the verifier, what does it imply and what is the basis for that? • Accreditation: should MS have their own accreditation schemes or should there be common standards and procedures? • How does the requirement of accreditation comply with the draft directive on services? In category C installations all sources to be measured with highest tier. This may result to odd decisions • How to decide for which situation highest tier for all sources is justified - when not? De-minimis criterion not always applicable • How to assess uncertainty and further improvements in complex installations?

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