Certification Criteria for the EU Emissions Trading Scheme

Certification Criteria for the EU Emissions Trading

Scheme Greenhouse Gas Lead Auditor Training Course

IRCA/2117/ Draft 1 post CC March 2005

Page i IRCA/2117 draft 1 post CC March 2005

The International Emissions Trading Association (IETA) Validators & Verifiers work group: These Certification Criteria for the European Union Emissions Trading Scheme Greenhouse Gas (EU GHG ETS) Lead Auditor Training course were developed by the sub committee “GHG Auditor Training” of the IETA Validators & Verifiers work group: Coordination:

• Edwin Aalders, IETA Secretariat

Members:

• DNV (Chair Validator & Verifiers working Group) • SGS (Project Manager) • LRQA • TUV • KPMG • KPMG Sustainability • Umweltbundesamt Austria • Defra • RvA • BP • COFRAC

In conjunction with IRCA. These Certification Criteria have been developed to facilitate the delivery of uniform, transparent and effective training of GHG auditors operating within the EU ETS. Although these criteria may be subject to changes as a result of feedback received from users, IETA encourages the use of this document by all interested parties. For general comments regarding this document and questions concerning the work of IETA, please contact Edwin Aalders, IETA at +41 22 839 3192 or [email protected]. For all other questions, please contact IRCA at www.irca.org or [email protected]. WAIVER: THIS DOCUMENT WAS PREPARED BY IETA EXERCISING ITS BEST DUE

DILIGENCE. HOWEVER, IETA, THE IETA MEMBERS, REPRESENTATIVES AND IETA BOARD

OF DIRECTORS INVOLVED IN ITS PREPARATION AND APPROVAL SHALL NOT BE LIABLE OR

OTHERWISE RESPONSIBLE FOR ITS USE AND ANY DAMAGES OR LOSSES RESULTING OUT

OF ITS USE IN ANY INDIVIDUAL CASE AND IN WHATEVER JURISDICTION. IT IS

THEREFORE THE RESPONSIBILITY OF EACH PARTY WISHING TO USE THIS DOCUMENT TO

ENSURE THAT ITS TERMS AND CONDITIONS ARE LEGALLY BINDING, VALID AND

ENFORCEABLE AND BEST SERVE TO PROTECT THE USER’S LEGAL INTEREST. © Clauses 2 and 3 of this document are the copywrite of the International Emission Trading Association (IETA) and may be freely used, copied and distributed on the condition that each copy shall contain this copyright notice. © For all other parts of this document, all rights are reserved and may not be reproduced, stored in a retrieval system or transmitted in any form or by any means - electronic, mechanical, photocopying, recording or otherwise, without prior permission of the IQA International Register of Certificated Auditors (IRCA).

Page ii IRCA/2117 draft 1 post CC March 2005

Foreword The International Emissions Trading Association (IETA) is a non-profit organization created in June 1999 to establish a functional international framework for trading greenhouse gas emissions reductions. Our 100 international members include leading multinational companies from across the carbon trading cycle: emitters, solution providers, brokers, insurers, verifiers and legal compliance. IETA works for the development of an active, global greenhouse gas market, consistent across national boundaries. In doing so IETA focuses on the creation of systems and instruments that will ensure effective business participation. In March 2004 the IETA Validators & Verification Group on the invitation of the European Commission, initiated the drafting of a framework for harmonization of verification under the EU ETS. Following an initial conference held on 27 May 2004, in which the outlines of the possible harmonization were formulated, the Work Group set up a number of sub-working groups which would be responsible for drafting:

• the EA Guidance Note for the accreditation of verifiers operating within the EU ETS

• a Verification Protocol and

• the GHG auditor required competence and training programme requirements (this document).

The objective of this document is to facilitate the training of GHG Auditors in a transparent and professional manner, with a high degree of confidence that the auditors who have participated and passed the training are of high quality with an excellent knowledge of verifying emissions under the EU ETS. A Work Group subcommittee chaired by SGS has produced these Certification Criteria for the EU ETS GHG Lead Auditor training course. These criteria are based on: training courses of the member Validators & Verifiers, comparable training courses and existing IRCA certification criteria for lead auditor training courses. The Work Group subcommittee included representatives of both industry and member states and earlier drafts of the documents were widely distributed and reviewed by a wider stakeholder group. It is envisaged that these Certification Criteria for the GHG training course will mark the beginning of a process to develop standardized training of GHG Auditors within the European Community and form a model for other trading schemes currently being developed outside the European Community.

Andrei Marcu President & CEO, IETA

Certification Criteria for the EU ETS GHG Lead Auditor Training Course

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IRCA/2117 draft 2, 23 March 2005

Contents

1. INTRODUCTION 2. LEARNING OBJECTIVES 3. ENABLING OBJECTIVES – KNOWLEDGE & SKILLS 4. TRAINING METHODS 5. COURSE CONTENT 6. COURSE DURATION 7. TUTORS & STUDENTS 8. VARIATIONS

9. STUDENT ASSESSMENT & EXAMINATION 10. COURSE PUBLICITY & ADVERTISING

GLOSSARY OF ACRONYMS AND TERMS APPENDIX 1: NOTES FOR GUIDANCE


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1 INTRODUCTION

1.1 About this document

This document, the specification for a certified training course for greenhouse gas (GHG) lead auditor course was prepared by a working group of International Emissions Trading Association (IETA) members and selected stakeholders in conjunction with the International Register of Certificated Auditors (IRCA). The document is intended to be used by approved training course providers to ensure that GHG auditors are trained to a common standard, thereby facilitating a common approach to verification throughout the European Union (EU).

1.2 About the training course

In designing a GHG Lead Auditor training course to meet the requirements of this document you, the course provider, should consider the following:

1.2.1 Aim of this training course. The aim of this course is to equip students with the knowledge and skills required to verify GHG emissions from facilities captured in the EU Emissions Trading Scheme (ETS). The focus of this course must be on verifying that a facility has implemented the current version of their approved monitoring and reporting plan and that the emissions declared have been reported in a manner that is consistent with the general reporting principles.

1.2.2 Experience and education. Students who successfully complete a certified GHG Lead Auditor training course will satisfy the training requirements for certification as a GHG auditor, and are likely to satisfy the training requirements for a GHG auditor acting for an accredited GHG verification body.1

1.2.3 Prior knowledge. This course is not intended to be an implementer’s course, or one that will create an expert in GHG emissions, or one that will train to an acceptable standard a student with no prior knowledge of the monitoring, reporting and verification of GHG emissions. It is strongly recommended that students have already successfully completed a recognized ISO 14001 Lead Auditor course and have an awareness of the issues relevant to GHG emissions in industry, EU ETS and/or data verification prior to joining this training course. Students with no prior knowledge of ISO 14001, the EU ETS or data verification are not expected to successfully complete this course.

1.2.4 Prior knowledge testing. Before accepting students on the course, they must complete the IETA/IRCA pre-course questionnaire to establish their pre-course awareness. Any students who do not have the require pre-course knowledge must be informed that this course is unsuitable for them, that it is unlikely that they will pass the assessment and examination elements and that they will not be provided with coaching to cover these knowledge areas during the course.

1 In order to fully qualify as a GHG auditor, education and experience in activities or sectors is likely to be required [guidance on experience requirements to work in selected sectors is being developed as part of this initiative]. Successful completion of the course alone will not qualify the individual as a certified GHG auditor.


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1.2.5 Flexibility in course design. These criteria specify the requirements for training courses including the knowledge and skills to be covered during the course. You must design and deliver courses in accordance with these criteria, although flexibility may be exercised through the inclusion of additional material, and in the structure and selection of specific training methods used during the course. Many of the certification requirements common to the management and control of courses are detailed in IRCA/2000, Requirements for training organization approval. These requirements are in addition to the requirements of this document and are mandatory. It is essential, therefore, that you are familiar with the requirements of IRCA/2000.

1.2.6 Training methods. This course may be designed to be presented in a variety of ways:

a) classroom-based over 5 day’s full-time (i.e. over five consecutive working days) involving lectures and case studies

b) classroom-based as a series of part-time modules over a longer period involving lectures and case studies

c) blended as a combination of self-study (i.e. e-learning course, correspondence course etc) and classroom-based learning, with case studies being completed in the classroom.

Note: however it is designed, students must complete the whole course of study with the same training provider and within a period of 3 months from start to finish.

Note: we will not accept courses that are wholly based on self-study learning.

1.2.7 Training vs. Assessment. There must be two distinct aspects to courses based on these criteria:

a) effective training to help students develop and acquire the knowledge and skills defined in this document

b) effective assessment of each individual student’s achievement of the skills and learning objectives through objective testing based on defined outputs. This includes continual assessment of understanding throughout the course, evaluation of contribution to case studies and performance in a written examination.


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2 LEARNING OBJECTIVES

Learning objectives describe in outline what the successful student will know and be able to do by the end of the course.

By the end of the course successful students will be able to:

2.1 EU ETS

Awareness

2.1.1 Describe the EU ETS trading and compliance mechanisms including the role of verifiers and the registry and demonstrate an understanding of the importance of third party verifiers in protecting the environmental and financial integrity of the EU ETS.

2.1.2 Describe relevant ISO and other standards referred to in M&R Decision.

Knowledge

2.1.3 Describe the purpose of EU ETS Directive and M&R Decision and requirements.

2.1.4 Describe quality assurance (QA) and quality control (QC) requirements in M&R Decision by demonstrating knowledge of ISO 14001 EMS and what to expect from installations as part of their compliance with M&R Decision.

2.1.5 Explain interrelationships between EU ETS Directive and M&R Decision and verification.

2.1.6 Explain the means of complying with the requirements of the EU ETS directive and M&R Decision including preparation and implementation of a monitoring plan and changes in monitoring plans.

Key Skills

2.1.7 Assess compliance with the EU ETS Directive and M&R Decision and requirements.

2.2 Data and Information Auditing

Knowledge:

2.2.1 Describe the monitoring and reporting principles (completeness, consistency, transparency etc), how compliance with each principle may be demonstrated and the possible consequences of failure to comply with the principles.

2.2.2 Demonstrate understanding of the term “materiality”, its interrelation with inaccuracy and the tier structures and permitted uncertainty in the M&R Decision, qualitative uncertainty and aggregation.

2.2.3 Explain the objectives and key elements of an uncertainty assessment, and instances when one is required.

2.2.4 Describe how companies may use commercial accounting and finance packages to monitor and report GHG emissions.


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2.2.5 Describe the role of sampling within data verification, how and when sampling can be used within EU ETS verification engagements and how to implement a sampling plan and review its adequacy.

2.2.6 Describe methods of checking data for errors demonstrating an understanding of the potential impact of different data collection and handling methods and reporting and control environments (i.e. QA/QC procedures) upon the reported data.

Key Skills

2.2.7 Prepare a data sampling plan and apply it to detect errors in reported data and determine whether the errors are material or immaterial.

2.3 Performing a verification engagement

Knowledge

2.3.1 Explain and understand the verification process of strategic analysis (SA), risk analysis (RA) and process analysis (PA), incorporating knowledge of EU ETS requirements with respect to monitoring and reporting, quality control and sampling.

2.3.2 Explain and understand the roles of different team members including Team Leader, Lead Auditor, Auditor, Expert and Independent Decision Maker, and the selection of team members to address competency requirements.

2.3.3 Explain the role of a Lead Auditor in planning, conducting, following-up and reporting a verification engagement in accordance with the EU ETS Directive (this may be addressed by comparing an EU ETS verification engagement with an ISO 14001 engagement).

2.3.4 Explain how to arrive at a verification conclusion and describe the content and consequences of a qualified and an unqualified verification statement.

Key Skills

2.3.5 Perform the role of a Lead Auditor in planning, conducting, following-up and reporting a verification engagement in accordance with the EU ETS Directive.

2.3.6 Prepare, based on the findings of a verification engagement, a verification report and recommendation for a facility participating in the EU ETS.

2.3.7 Perform the role of an Independent Decission Maker (IDM) to make an appropriate decision.


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3 ENABLING OBJECTIVES –KNOWLEDGE & SKILLS

In order for students to achieve the overall learning objectives, they will need to acquire and develop specific knowledge and skills. These are specified below as “enabling objectives” and can be considered as steps to achieving the learning objectives. All of the enabling objectives should be considered from the perspective of a GHG verifier and with regard to EU ETS.

By the end of the course successful students will be able to:

3.1 Describe the EU ETS trading and compliance mechanisms including the role of verifiers and demonstrate an understanding of the importance of third party verifiers in protecting the environmental and financial integrity of the EU ETS.

3.1.1 Describe the basics of EU ETS trading and how it works, including penalties and control mechanism.

3.1.2 Describe the basics of the functioning of verifiers and their interrelationship with the other bodies in the EU ETS e.g. competent authorities, national authorities, ministries, accreditation and installations.

3.2 Describe relevant ISO and other standards referred to in M&R Decision.

3.2.1 Describe the circumstances in which ISO 17025 should be applied.

3.2.2 Demonstrate awareness of other ISO standards that may be applied in the case of measurement of emissions and the use of CEMS.

3.2.3 Demonstrate awareness of standards that may be used in the calibration of instrumentation.

3.3 Describe the purpose of EU ETS Directive and M&R Decision and requirements.

3.3.1 Explain the EU ETS Directive requirements as they apply to installations and verifiers.

3.3.2 Explain the M&R Decision requirements as they apply to installations and verifiers.

3.4 Describe QA/QC requirements in M&R Decision by demonstrating knowledge of ISO 14001 EMS and what to expect from installations as part of their compliance with M&R Decision.

3.4.1 Explain how an ISO 14001 EMS meets and exceeds the QA/QC requirements of the M&R Decision.

3.4.2 Explain the impact of QA/QC requirements on an installation’s data and system.

3.4.3 Explain for each QA/QC requirements what is expected compliance by an installation

3.4.4 Explain the consequences of non compliance with a QA/QC requirement.


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3.5 Explain interrelationships between EU ETS Directive and M&R Decision and verification.

3.5.1 Explain the relationship between EU ETS Directive, M&R Decision and verification.

3.5.2 Explain how different competent authorities may interpret the M&R Guidelines and how this will impact upon approved methodologies in the M&R Plans.

3.6 Explain the means of complying with the requirements of the EU ETS directive and M&R Decision including preparation and implementation of a monitoring plan and changes in monitoring plans.

3.6.1 Describe the general processes, as laid down in EU ETS Directive and M&R Decision, an installation covered by the EU ETS has to go through to obtain permission to emit GHG.

3.6.2 Outline the typical content of a GHG permit and its monitoring plan.

3.6.3 Describe processes for management of changes to information provided in a GHG permit and where relevant the monitoring plan including requirements laid down in the M&R Decision and EU ETS Directive (note: include discussion about timeframes and relevant players).

3.6.4 Explain the time frames for monitoring, reporting and verification of emissions.

3.7 Key Skill: assess compliance with the EU ETS Directive and MR Decision and requirements, taking into account the issues in 3.3-3.6 above, by completing one or more case studies to:

3.7.1 Key skill: assess compliance of an Emissions Report with its M&R Plan and associated GHG Permit.

3.7.2 Key skill: assess compliance of the M&R Plan against the requirements of the M&R Decision.

3.8 Describe the monitoring and reporting principles involved in data and information auditing, how compliance with each principle may be demonstrated and the possible consequences of failure to comply with the principles.

3.8.1 Understand the meaning of each of the terms; Completeness, Consistency, Transparency, Accuracy, Cost Effectiveness, Materiality, Faithfulness and Improvement in performance of monitoring and reporting emissions.

3.8.2 Explain how each of these principles can be addressed within a monitoring and reporting system, and in the absence of a monitoring and reporting system.

3.8.3 Key Skill: identify compliance with monitoring and reporting principles and distinguish between individual mistakes that can be corrected, and generic or repeated mistakes that compromise the monitoring and reporting principles and therefore indicate non-compliance with the requirements of the scheme.


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3.9 Demonstrate understanding of the term “materiality”, its interrelation with inaccuracy and the tier structures and permitted uncertainty in the M&R Decision, qualitative uncertainty and aggregation.

3.9.1 Key skill: distinguish clearly between controllable errors that arise through the collection and handling of data and uncontrollable errors that are associated with permitted uncertainty in metering and measurement instruments and sampling regimes.

3.9.2 Key skill: identify and understand aggregated errors, the absolute and relative magnitude of errors and the implications of aggregated errors that exceed the materiality threshold.

3.9.3 Key skill: address material errors and explain how errors may be reduced through “New Information Requests”.

3.9.4 Key skill: demonstrate understanding of uncertainty and inaccuracy, application of 95% confidence intervals in an uncertainty assessment, and the preparation of a full uncertainty assessment for the measurement of GHG emissions.

3.10 Explain the objectives and key elements of an uncertainty assessment, and when one is required.

3.10.1 Understand when uncertainty assessments are required (when operators propose to use measurement as a means of determining GHG emissions) and the sources of uncertainty that need to be considered in an assessment.

3.10.2 Understand how overall uncertainty is calculated from a number of sources of uncertainty.

3.11 Describe how companies may use commercial accounting and finance packages to monitor and report GHG emissions.

3.11.1 Describe a range of commercial accounting and finance packages such as SAP and Hyperion, and how these may be used to monitor and report GHG emissions.

3.12 Describe the role of sampling within data verification, how and when sampling can be used within EU ETS verification engagements and how to implement a sampling plan and review its adequacy.

3.12.1 Describe understanding of the advantages and disadvantages of sampling in terms of level of effort required and the risks of missing material errors.

3.12.2 Explain and understand the application sampling guidance within sources, between sources within a site and between sites.

3.12.3 Describe how to implement a sampling plan and select records at random.

3.12.4 Describe how to review the adequacy of a sampling plan and adjust it throughout an engagement, if the findings indicate that sampling has not been effective.

3.12.5 Describe methods of checking data for errors, demonstrating an understanding of the potential impact of different data collection and handling methods and reporting and control environments (i.e. QA/QC procedures) upon the reported data.


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3.12.6 Describe how to review small and large quantities of data to check for a range of errors including transcription errors, data entry errors, incorrect units, incorrect default factors using tools such as graphical analysis, trend analysis and percentage / ratio calculations to review large quantities of data.

3.12.7 Describe the nature and impact of random and systematic errors and their potential impact upon the verification decision.

3.12.8 Explain how unexplained variations in trends can highlight errors that may be material.

3.12.9 Understand how data handling can distort data and how data collection procedures can be designed to minimize such errors and how QA/QC procedures can reduce the likelihood of such errors.

3.12.10 Explain the different types of human errors (slips, lapses, mistakes, acceptable violations and unacceptable violations), how these arise and how these can be efficiently screened out in QA/QC procedures.

3.12.11 Explain and understand how abnormal events may impact upon data and how and where such events are normally recorded.

3.12.12 Explain and understand how internal QA/QC procedures (or the lack of them) can impact upon the verification engagement, the ability to sample data and sampling intensity.

3.13 Key skill: prepare a data sampling plan and apply it to detect errors in reported data and determine whether the errors are material or immaterial. Demonstrate the ability to:

3.13.1 Key skill: review a set of data collection and QA/QC procedures and prepare a sampling plan that efficiently allocates resources to complete the task. If appropriate, set thresholds to revise the sampling plan (up or down) depending on the interim and preliminary findings

3.13.2 Key skill: apply the sampling plant to the data set and select records at random.

3.13.3 Key skill: review the adequacy of a sampling plan and adjust it throughout an engagement, if the findings indicate that sampling has not been effective.

3.13.4 Key skill: use methods of checking data for errors, demonstrating an understanding of the potential impact of different data collection and handling methods and reporting and control environments (i.e. QA/QC procedures) upon the reported data.

3.13.5 Key skill: review small and large quantities of data to check for a range of errors including transcription errors, data entry errors, incorrect units, incorrect default factors using tools such as graphical analysis, trend analysis and percentage / ratio calculations to review large quantities of data.

3.13.6 Key skill: identify any potential errors or omissions in the data set and classify them, individually and in aggregate, as material or immaterial

3.13.7 Key skill: reach a conclusion on whether the data have been reported in compliance with the monitoring and reporting principles.


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3.14 Performing a verification engagement. Explain and understand the verification process of strategic analysis, risk analysis and process analysis, incorporating knowledge of EU ETS requirements with respect to monitoring and reporting, quality control and sampling.

3.14.1 Demonstrate a thorough understanding of the verification process described in Annex V of the Directive.

3.14.2 Explain the objective of, and how to conduct, a SA and RA, what information is required, how and where that information is obtained, and what the expected outputs are. Demonstrate an understanding of the impacts that the M&R Plan has on the SA and RA.

3.14.3 Identify how the output from an SA and RA contribute to the preparations and implementation of the PA, including the preparation of a sampling plan and verification checklist, and a review of team member competencies and time input.

3.14.4 Explain how to use the PA is used to verify the reported emissions.

3.15 Understand the roles and responsibilities of the client and different team members including Team Leader, Lead Auditor, Auditor, Expert and Independent Decision Maker (IDM), and the selection of team members to address competency requirements.

3.15.1 Explain what the client is expected to present by way of permits, monitoring and reporting plans, reports of emissions and supporting documentation.

3.15.2 Explain the roles and responsibilities of the Lead Auditor and Auditor and the resources (other team members) that are at the Lead Auditor’s disposal.

3.15.3 Explain the competencies that are required in all teams and how and when to identify additional competencies that may be required for specific engagements.

3.15.4 Explain how the Lead Auditor reports the findings from the engagement to the IDM and how the IDM makes a decision.

3.16 Explain the role of a Lead Auditor in planning, conducting, following-up and reporting a verification engagement in accordance with the EU ETS Directive. This may be addressed by comparing an EU ETS verification engagement with an ISO 14001 engagement.

3.16.1 Describe the process of planning an audit.

3.16.2 Describe typical forms of pre-audit contact, their purpose and when they might be appropriate.

3.16.3 State the purpose of a document review/stage one audit and document review process and outputs.

3.16.4 Explain the purpose and significance of the audit scope, the importance of team competency and selection of team members particularly with regard to process knowledge and local environmental regulations.

3.16.5 Explain the use, benefits and potential limitations of a checklist (or alternative), and considerations for planning an audit of an activity for which there are no documented procedures.


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3.17 Explain how to arrive at a verification conclusion and describe the content and consequences of a qualified and an unqualified verification statement.

a) describe the contents of a verification opinion including confirmation of number of emissions, confirmation that the emission report complies with the GHG permit and associated monitoring plan.

b) identify the conditions that will lead to the issuing of a qualified verification opinion.

3.18 Key skill: perform an audit and prepare, based on the findings of a verification engagement, a verification report and recommendation for a facility participating in the EU ETS, by.

3.18.1 Key skill: completing a contract review, a skills justification and an audit plan.

3.18.2 Key skill: completing a document review, including documentation required to confirm the completion of the SA, RA and PA.

3.18.3 Key skill: completing the data sampling (see 3.13 above).

3.18.4 Key skill: ensuring that sufficient documentation has been prepared to demonstrate compliance with the EA guidance for verifiers / accreditation requirements (i.e. contract review, skills justification, checklists etc.).

3.18.5 Key skill: preparing a verification report for submission to the Technical Reviewer / IDM, complete with a recommendation to award a qualified or unqualified verification opinion.

3.18.6 Key skill: taking the role of an IDM to review a complete audit report and make an appropriate independent decision.

4 TRAINING METHODS

The course may be presented as a wholly classroom-based course or as a blended course (in other words part self-study and part classroom-based). The course may also be presented as a series of separate modules, either as full-time or part-time study.

4.1 Classroom-based training

4.1.1 You must provide students with an environment conducive to effective learning. At the beginning of the course you must provide the students with a description of the learning objectives, course structure, format and programme, student responsibilities and the assessment processes and assessment criteria, and you must deal with any concerns or worries that students may have.

4.1.2 Your course must be based on the learning cycle (see guidance in Appendix 1) and include opportunities for students to:

a) experience new ideas and skills. (Note that tutor-led slide presentations as a sole method to help students learn new knowledge is not acceptable).


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b) reflect on their learning and identify strengths and weaknesses. (Note that your course must include methods for monitoring and providing time for tutors and students to review tasks and activities and each student’s achievement of the learning objectives).

c) address and improve on areas of weakness. (Note that your course must include provision for review and remedial work, and individual coaching, where necessary.)

4.1.3 Your course must include a variety of learning methods to suit the range of learning styles (see guidance in Appendix 1).

4.1.4 Your course must not rely on tutor presentations and tutor-led discussions to teach knowledge-based learning objectives. We expect to see students learning these elements mostly through a process that requires students to complete a task or activities, often in teams, and to produce a defined output.

4.1.5 All students must practise the skill-based learning objectives of the course through participation in appropriate tasks and activities (role play, simulation etc). Key Skills (see clause 2 and 3 above) must be practised and tested through practical activities such as case studies. Note that we expect the majority of the course to be focused on developing these Key Skills (see Appendix 1 for an illustrative course programme). Not also that students will require extensive example data and records associated with tasks and case studies in order to practise these skills effectively.

4.1.6 Timekeeping, planning and programme management are essential elements in the performance of an audit and, although we recognise that effective training is responsive to students’ needs, deviations from the timetable must be managed so that all learning objectives are adequately covered and students are kept informed of significant changes to the programme.

4.1.7 You must submit session plans or tutor notes for each individual training session. Session plans must specify:

a) learning objectives and duration for the session

b) nature of the activity and training method to be used

c) organizational arrangements, tutor and student briefing details

d) deliverables required from students for practical sessions

e) materials, exercises and equipment required to run the session

f) where training methods or use of exercises etc. are optional, this must be clearly indicated in session plans.

Note: The format of your session plans will depend to an extent on your approach to tutor competence and training and the size and complexity of your organization. Medium and high complexity training organizations (see IRCA/3000 appendix) will require more comprehensive tutor notes to ensure that training in new and amended materials is controlled and effective.


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4.2 Blended courses (a combination of self-study, including electronic media, and classroom based learning)

4.2.1 Only knowledge-based learning objectives may be covered by self-study methods.

4.2.2 Auditing skills learning objectives must be completed in a classroom environment in terms of practice and student assessment. See clause 4.2 of this document for requirements for the classroom element of blended learning courses.

4.2.3 Training methods selected should seek to involve and engage students throughout the duration of the course. Simply providing students with a set of reading materials will not be acceptable. Your self-study materials must be designed around a clearly structured learning process with:

a) theory

b) examples (scenarios, case studies etc)

c) practice (activities, case studies, progress tests, etc.)

d) feedback/self-assessment on activities and tests where relevant, to ensure students are able to self-assess their understanding and achievement of the learning objectives and identify any areas requiring further work.

4.2.4 Self-study course materials must be clearly presented and structured for ease of use, with appropriate navigational aids. You must make the following information clear to students to help them manage their learning:

a) the learning objectives for the overall self-study element of the course

b) the learning objectives for each section within the course

c) how the self-study element of the course links with the classroom component

d) the structure and suggested or intended sequence of the materials

e) instructions for the students’ use of the materials, including realistic timescales

f) examples of typical documents, reports, forms etc

g) how, when and how often students may contact tutors for help, guidance and feedback

h) methods for students to assess their learning and to seek timely feedback and coaching from the tutor(s).

4.2.5 You must ensure that each student has timely access to a course tutor to answer questions and queries.

Note: as a guide, a response to communications from students within 24 hours would be acceptable.


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5 COURSE CONTENT

5.1 At the beginning of the course presentation you must provide the students with a description of the learning objectives, course format and programme, student responsibilities and student evaluation processes and criteria.

5.2 You must ensure students have available a copy of the relevant standards or you must provide them with a copy for self-study (if relevant) and for classroom-based elements of the course.

5.3 The course must cover:

5.3.1 All aspects defined in clause 2 learning objectives and amplified in clause 3 enabling objectives.

5.3.2 Local requirements, culture, practices or approaches to auditing and the application of the EU ETS as appropriate for each country in which the course is presented.

6 COURSE DURATION

6.1 Classroom-based learning

6.1.1 Where the course is wholly classroom-based, the total course must be at least 40 hours net, calculated as detailed in IRCA/2000.

6.1.2 This course may be presented over a minimum of 5 consecutive days full-time or on a part-time (modular) basis over a maximum of 8 weeks.

Note: although not mandatory, we recommend that this course be residential if presented over the consecutive day’s option.

6.2 Blended learning

6.2.1 Elements of the courses that are delivered through self-study will allow students three times longer than classroom training (i.e. approximately 80 hours for the knowledge-based learning objectives).

6.2.2 The classroom element (i.e. the skills learning objectives as a minimum) must be timed to allow each student to practise and be assessed on the skills learning objective. The amount of time given to this classroom element will depend on the learning objectives being covered, however normally 60% (or 3 days, or 26 hours gross as calculated in IRCA/2000) duration will be devoted to classroom-based learning and assessment. Courses with a reduction in classroom time may be allowed if agreed in advance with us. See the Appendix for guidance for instances where reduced classroom time may be allowed.

6.2.3 Each student must complete both the self-study and the classroom part of the training course within no more than 90 days.


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6.2.4 Students must complete each element of blended courses in the correct sequence. For example, for courses with a self-study element that is followed by a classroom element you must ensure that students who do not complete the self-study element of the course must not be accepted onto the classroom-based element. You must have a process for recording and validating each student’s completion of each element of blended courses to ensure students complete the course in the correct order.

6.3 Translators

6.3.1 If the course is given through translators, the time must be increased as necessary to satisfy the learning objectives.

7 TUTORS AND STUDENTS

7.1 Classroom-based learning

7.1.1 The number of students per course shall not exceed 20, nor be less than 4.

7.1.2 The course shall be run with two designated tutors, both of whom shall be present for the full duration of the course. At least one tutor shall satisfy the requirements for a lead tutor as stated in IRCA/2000. Additional resources or trainee tutors may be used for specific activities, however the two tutors remain responsible for the entire presentation.

7.1.3 Where the number of students is 4 to 10 inclusive, the course may be run with one designated tutor, who shall be present for the full duration of the course. That tutor shall satisfy the requirements for a lead tutor.

7.2 Self-study based learning

7.2.1 Tutors who provide educational support on self-study elements of blended learning must be competent to operate any media required.

7.3 All courses. Tutors for this course must demonstrate competence in key attributes:

7.3.1 Competence in training; by satisfying the tutor or lead tutor requirements as appropriate (see IRCA/2000).

7.3.2 Competence as an ETS GHG auditor; by demonstrating auditing competence as a currently certificated GHG Auditor (when issued) or meeting the requirements for such certification.

7.3.3 Competence to deliver training and student assessment on your specific course.

8 VARIATIONS

8.1 Requests for variations to any of these criteria, or in respect of any special circumstances, will be considered for approval on written submission by you to us. We require you to submit such a request immediately upon the reason for the variation request becoming apparent.

8.2 We will consider the following when evaluating any request for variation:

8.2.1 Reasons for the requested variation.


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8.2.2 Proposed modifications to the training.

8.2.3 The impact on the learning and assessment processes and how this will be managed.

9 STUDENT ASSESSMENT AND EXAMINATION

Note: we regard the assessment and examination of students to be a very important part of this course.

9.1 Successful completion: in order to satisfactorily complete the course each student must:

9.1.1 Complete/attend all elements of the course.

9.1.2 Pass the continuous assessment (focused on the learning objectives).

9.1.3 Pass the written examination (focused on the learning objectives).

9.2 Conduct and management of continuous assessment

9.2.1 Students must demonstrate acceptable levels of performance in all learning objectives. During the course you must test each student's achievement of the learning objective. These tests must be based on practical tasks and activities with defined outputs that students must produce.

9.2.2 You must provide tutors with model outputs and a marking scheme/guidance to assess each student's performance and outputs (see appendix).

9.2.3 Tutors must provide students with feedback on their performance.

9.2.4 Tutors must give further help and guidance to students who do not initially achieve elements of the learning objectives. They must provide these students with opportunities to complete further tasks to demonstrate competence.

9.2.5 Each student’s achievement of learning objectives must be recorded on his/her continuous assessment record.

Note: See the appendix for guidance on continuous assessment.

9.3 Conduct and management of the written QMS auditor/lead auditor examination.

9.3.1 Students must sit one of the current issues of IRCA-set ETU GHG Auditor examination papers.

9.3.2 IRCA must be conducted in accordance with the criteria set out in IRCA/2000.

9.3.3 IRCA examination papers must state on every page:

“IRCA EXAMINATION PAPER NUMBER [X]” amended for use on approved course [xxxx] operated by [TO], [the date of issue and page number].


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Please insert at X the IRCA reference number for the paper, at TO the name and IRCA certification number of your training organization and at xxxx the IRCA certification number of your course.

9.3.4 You may modify the IRCA examination papers as indicated below, but must not change the structure of the paper.

a) minor changes in the wording may be made to reflect local language differences

b) changes in wording may be made to better reflect a specific context; e.g. a production or a retail application. These changes must NOT represent substantive changes to either the question or the solution

c) a maximum of 25% of each paper may be replaced but this must NOT change the structure of the paper

d) on replacing a question, you must:

Provide a solution and marking scheme for the alternative question

Send us the alternative question (identifying clearly which question it is intended to replace) and its solution for approval before it is incorporated into the IRCA examination paper.

10 PUBLICITY AND ADVERTISING

10.1 Course advertising and promotional literature shall not state or imply that this course satisfies more than the training requirements for certification as an IRCA EU GHG Auditor.

10.2 Prior to the commencement of the course, you must communicate to potential students the prior knowledge requirement.


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Glossary of Acronyms and Terms

CEMS Continious Emission Monitoring System

EU European Union

ETS Emissions Trading Scheme

GHG Greenhouse Gas

GHG Auditor The competent person who performs the assessment to verify GHG emissions from facilities captured in the EU ETS. Note that the terms ‘assessor’ and ‘auditor’ are considered interchangeable for the purposes of this program.

IDM Independent Decision Maker

IRCA International Register of Certificated Auditors

Contact IRCA at www.irca.org

IETA International Emissions Trading Association

Contact IETA at www.ieta.org or:

M&R Monitoring and Reporting

QA Quality Assurance

QC Quality Control

RA Risk Analysis

SA Strategic Analysis

Verifier a competent, independent, accredited verification body with responsibility for performing and reporting on the verification process, in accordance with the detailed requirements established by the Member State pursuant to Annex V to the Directive.


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APPENDIX 1: NOTES FOR GUIDANCE

1. Illustrative course programme

Pre-reading: EU ETS and Briefing Notes; M&R Decision; visit Europa.com / Competent authority website / UNFCCC.int

Day 1 a.m. Background and introduction to EU ETS knowledge input, including discussion with illustrative examples

p.m. Case study #1. Assess compliance with Permit and M&R Decision for a simple site (e.g. invoice based gas consumption).

Materials required: Emissions Report, GHG Permit and associated M&R Plan.

Day 2 a.m. Data verification and auditing knowledge input, including discussion with illustrative examples.

p.m. Continue Case Study #1. Prepare and implement a sampling plan and verify the data, checking for compliance with the key principles.

Day 3 a.m. Perform a verification engagement knowledge input, including discussion with illustrative examples.

p.m. Complete Case Study #1. Ensure all necessary documents have been prepared (contract review, skills justification, document review, checklists), including a verification report and recommendation.

Introduce Case Study #2

Day 4 Complete the verification of an Emissions Report against the requirements of the EU ETS and the facility’s GHG Permit and associated M&R Plan. Prepare a full set of documentation and a verification report with recommendation for submission to an Independent Decision Maker.

Day 5 a.m. Discuss Case Study #2; review findings; finalize report and recommendation for submission to Tutor.

p.m. Written examination.

2. Helping students learn new knowledge & skills

We promote the use of accelerated learning approaches because they are more efficient, in terms of speed and depth of comprehension, and more effective, in terms of long term retention of new knowledge. Therefore, you should employ practical tasks and activities to help students to understand new concepts and ideas. You should not rely on tutor focused lecture/presentation to transfer new ideas and concepts.

The Learning cycle

There is a clear link between Deming's familiar Plan-Do-Check-Act and the learning cycle:

- Students experience something

- Students reflect on what they did & identify what they learned and what they still do not fully understand or cannot do

- Students take action to address weak areas


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Ensuring that your training sessions follow this simple model will make students' learning more effective. We referenced the learning cycle described by David A Kolb in developing these criteria and you might find it useful to consider this when developing your course.

Learning styles

We promote a variety of training methods in your course design. Different people learn in different ways so your sessions should follow the learning cycle and your course should include a variety of different learning activities to cater for all needs as far as possible. Honey and Mumford (Learning Style Questionnaire, Peter Honey Publications, ISBN 1 902899 07 5) provide one model for describing different learning styles that you may find useful as a basis.

Session plans

Developing session plans is a natural part of designing learning and training processes. Session plans should be simple and easy to use working documents to help your tutors manage effective learning. For organizations with only a few tutors, outline session plans are acceptable. For larger organizations with a number of branches or subcontractors, and the consequent number and turnover of tutors, we will require more comprehensive session plans. A sample session plan is provided below.

3. Continuous assessment

Continuous assessment should have a clear link between: session plans (for tutors), clear task/activity instructions with defined and measurable outputs (for students and tutors), activity marking schemes / model answers (for tutors), model answers (for students), individual student continuous assessment record (for recording student performance).

4. Blended Learning – course duration & tutor:student ratios

We will consider courses designed with less than 60% of the course duration (as calculated in IRCA/2000) devoted to classroom activity in circumstances where, for example, there is a smaller tutor:student ratio: for example 2 tutors and a maximum of 6 students.

5. Self-Study

We recommend that you consider the following documents when developing training based on information technology solutions: BS 7988:2002 A Code of Practice for the use of information technology for the delivery of assessments BS 8426:2003 A code of practice for e-support in e-learning systems

Documents

Certification Criteria for the EU Emissions Trading Scheme