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Managing differencies in coverage, institutional and
methodological issues (EU ETS vs GHG inventory) case of France
Jean-Pierre FONTELLE
Centre Interprofessionnel Technique d’Etudes de la Pollution Atmosphérique
www.citepa.org
Workshop on data consistency between National GHG inventories and reporting under the EU ETS 9 – 10 February 2006, Copenhagen
Raising issues of discussion
scope and classification problems
benefits for inventories
impact on emission inventory process
management and institutional arrangements for ETS & GHG inventory
Scope and classification
• A boiler is a boiler, • A stack is a stack,• 1 ton of CO2 is 1 ton of CO2,• 1 ton of coal, heavy fuel oil or gas is the same and CO2 emissions are identical,
• BUT A PLANT IS NOT NECESSARILY THE SAME PLANT because of :
For GHG inventory as well as EU ETS with regard to CO2 emission sources :
differences in scope (all plants included in GHG Inventory vs plants with particular characteristics (size, type of process, type of equipment, sectoral classification),
differences in fuel allocation (case of blast furnace, coke oven and steel gases), differences in emission estimation methods and accuracy, differences in data reporting
Therefore, the same plant may be differently accounted for GHG inventory and ETS
Scope and classification
• A boiler is a boiler, • A stack is a stack,• 1 ton of CO2 is 1 ton of CO2,• 1 ton of coal, heavy fuel oil or gas is the same and CO2 emissions are identical,
• BUT A PLANT IS NOT NECESSARILY THE SAME PLANT because of :
For GHG inventory as well as EU ETS with regard to CO2 emission sources :
differences in scope (all plants included in GHG Inventory vs plants with particular characteristics (size, type of process, type of equipment, sectoral classification),
All
equipments
included except
engines for
transportation
• Refinery
• Steel industry• Coke ovens • Cement > 500 t/d• Lime > 50 t/d• Glass > 20 t/d• Tiles & ceramics
> 75 t/d• Paper & pulp
> 20 t/d• Energy produc.
> 20 MW
Only boilers, gas turbines and engines
except emergency
units
EU ETS France IPPC / EPER
Larger list
of sources
and
emission
threshold
100 000 t
CO2
GHG inventory
All sources included
whatever the sector, the
capacity and the
equipment
Classification is different
EU ETS DirectiveLCP, NEC,
EMEPNot
concerned by CO2 but
consistency with activity
rate (fuel comsump-
tions, produc-tions)
Plant specifi-cations
more or less restricted
(eg LCP > 50 MW)
Scopes of inventories / registers are different
EU ETS
EMEP EPER
LCP
GHG & NEC
IPPC
Scope and classification
• A boiler is a boiler, • A stack is a stack,• 1 ton of CO2 is 1 ton of CO2,• 1 ton of coal, heavy fuel oil or gas is the same and CO2 emissions are identical,
• BUT A PLANT IS NOT NECESSARILY THE SAME PLANT because of :
For GHG inventory as well as EU ETS with regard to CO2 emission sources :
differences in scope (all plants included in GHG Inventory vs plants with particular characteristics (size, type of process, type of equipment, sectoral classification),
differences in fuel allocation (case of blast furnace, coke oven and steel gases),
Limitation of the source-oriented approach
Fossil,fueland
various products
Steel industry By-products(tars, chemical products,
…)
Blast furnace gasCoke oven gas
Steel conversion gas
Externalrecovery
FlaringRecycling
Pig iron, steel, …
External recovery (eg power plant)
Blast furnace
Gas(268)
Coal(95)
(kgCO2/GJ) CO2 (t)
500 000
500 000
Total 1 000 000
ETS allocation 950 000 t
Situation A Situation B
NaturalGas(57)
Coal(95)
(kgCO2/GJ) CO2 (t)
500 000
106 000
Total 606 000
• Supplementary CO2 emission by flaring 500 kt
• National total + 106 kt
• CO2 non emitted by the power plant 344 kt (x20€/t = 6,88 M€)
Between situations A and B
• for ETS, the optimal approach is not always the source-oriented approach, • maintaining a single data collection and reporting system for ETS and GHG inventory heightens the difficulty and needs more resources• it is necessary to be careful of the impact of particular flows or activities on data reporting and management,• consistency between ETS and GHG inventory requires more stringent QC procedures,
Example / previous case : Is the sum of BFG fuel consumptions and CO2 emissions consistent with the sum of plants consuming BFG and the production of BFG minus flaring and losses ?
Consequences :
Scope and classification
• A boiler is a boiler, • A stack is a stack,• 1 ton of CO2 is 1 ton of CO2,• 1 ton of coal, heavy fuel oil or gas is the same and CO2 emissions are identical,
• BUT A PLANT IS NOT NECESSARILY THE SAME PLANT because of :
For GHG inventory as well as EU ETS with regard to CO2 emission sources :
differences in scope (all plants included in GHG Inventory vs plants with particular characteristics (size, type of process, type of equipment, sectoral classification),
differences in fuel allocation (case of blast furnace, coke oven and steel gases), differences in emission estimation methods,
Inventories based on
bottom-up approach
EPER
LCP (*)
ETS
Inventories based on top-
down approach
UNFCCC
UNECE (*)
NEC (*)
NAMEA
In practice, top-down inventories are partly processed on a mixed
approach
Some sectors are totally compiled as purely bottom-up, some other are partly compiled from bottom-up then balanced with top figures
EMEP (*)
(*) not dealing with CO2 but concerned by activities
Accuracy requirements from ETS >> GHG requirements
The situation depends on specific characteristics for each MS inventory
Combustion
Sectors in ETS
Methodological approach in GHG
inventory
Problems with ETS ?
Impacts ?
Centralized electricity production
and oil refinery
100% bottom-up No problem, already in use for GHG inventory
Increase of accuracy, more detailed data available, minimal impact on emissions at plant level and national level
Other sectors
Partly bottom-up or national figures
No problem, possible differences compensated within energy balance
Increased accuracy at local and/or sectoral levels, no change at national level, compensation of possible differences, reporting more complicated
Σ non individual installations = All installations - Σ individual installations
Σ fueli cons. from non indiv. instal. = energy balance fueli - Σ fueli cons. indiv. instal.
Decarbonizing - Example 1 : bricks and tiles
52 ETS plants vs ~140 GHG plants
Individual data available for 49 / 52 ETS plants (combustion and decarbonizing separately) and total emission (combustion + decarbonizing) for 3 others
Calculation of ratio (CO2 decarbonizing / total CO2) based on 49 ETS plants
Estimation of decarbonizing CO2 for 3 plants
Total decarbonizing emission for 52 ETS plants 276 kt CO2 -> EF 50 kg CO2/t prod
National EF in GHG inventory 40 kg CO2/t prod -> 230 kt CO2
CONSEQUENCE : change in national EF 40 -> 50 kg CO2/t prod -> 287 kt CO2
The difference corresponds to ~90 non ETS (very small) plants.
Decarbonizing - Example 2 : lime – auto-producers excluded
22 ETS plants vs 23 GHG plants
Individual data available for 20 / 23 ETS plants (combustion and decarbonizing separately) and total emission (combustion + decarbonizing) for 3 others
Calculation of ratio (CO2 decarbonizing / total CO2) based on 20 ETS plants
Estimation of decarbonizing CO2 for 3 plants
Total decarbonizing emission for 22 ETS plants 2474 kt CO2
National emission by using EFs in GHG inventory 2534 kt CO2
CONSEQUENCE : no change in national EFs for lime production (decarbonizing)
The difference (2,4%) corresponds to 1 non ETS plant.
• more details in data collection are required to operate conveniently with specifications of various needs, • additional appropriate QC actions have to be implemented,• more confidence in some sectoral emissions,• greater completeness, consistency and comparability,• collateral benefit for non-CO2 emissions,• possible impact on inventory processes (GHG and non GHG),• increased inventory burden.
Consequences :
Scope and classification
• A boiler is a boiler, • A stack is a stack,• 1 ton of CO2 is 1 ton of CO2,• 1 ton of coal, heavy fuel oil or gas is the same and CO2 emissions are identical,
• BUT A PLANT IS NOT NECESSARILY THE SAME PLANT because of :
For GHG inventory as well as EU ETS with regard to CO2 emission sources :
differences in scope (all plants included in GHG Inventory vs plants with particular characteristics (size, type of process, type of equipment, sectoral classification),
differences in fuel allocation (case of blast furnace, coke oven and steel gases), differences in emission estimation methods and accuracy, differences in data reporting
Reporting
The National Inventory System is based on a single system providing results for GHG and non GHG inventories. The system does not specifically focus on EU ETS reporting.
Both, EU ETS and inventories (GHG and non-GHG) use individual industrial data from the national emission reporting system on Internet (GEREP).
Specific information for EU ETS reporting is required (fuels / products consumptions, productions, CO2 emission, emission factors, methodological information, etc.).
To a large extent, the information requested for ETS is already collected for emission inventories (GHG and non GHG) within GEREP.
Data collection and treatment have been adapted to take on board new specifications from ETS.
GEREP was amended in late 2005 in order to include the ETS demand within the annual common reporting from facilities
Number of installations according to CO2
allocations for France in EU ETS
6%13%
34%
47%
>500 kt
100-500 kt
25-100 kt
<25 kt
CITEPA 02/2006CO2 allocations for France in EU ETS
64%20%
12% 4%
>500 kt
100-500 kt
25-100 kt
<25 kt
CITEPA 02/2006
84% of allocations from 19% of plants
96% of allocations from 53% of plants (those > 25 000 t)
156 Mt CO2 – ~1100 installations
CO2 allocations and number of installations
by sector for France in EU ETS
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
annualallocations
number of installations
GAS TRANSPORTATION
ENERGY OTHER
GLASS
PETROLEUM REFFINERY
PAPER & PULP
FOOD AND DRINK INDUSTRY
CHEMICAL INDUSTRY
ELECTRICITY PRODUCTION
CEMENT
LIME
DISTRICT HEATING
TILES AND CERAMICS
IRON AND STEEL
CITEPA 02/2006
156 Mt CO2 – ~1100 installations
CO2 allocation according to the number
of installations for France in EU ETS
1 000
10 000
100 000
1 000 000
10 000 000
0 100 200 300 400 500 600 700 800 900 1000 1100 1200
nb installations
allocations
CITEPA 02/2006
t
~1100 ETS plants within over 5500 industrial facilities concerned
Overview of the reporting flow sheet
Accreditationof verifiers
(Min. of Envt)
Individual regulation
(Local authority)
National regulation
28/07/2005 (Min. of Envt)
National annual
reporting system GEREP (Min. of Envt
and local authority)
Review, 1st check Report and conclusion (Verifiers)
2nd level of verifications
(Local authorities)
Internal arrangements,
implementation of monitoring plans
(Operators)
Reporting on Internet (GEREP)
of annual emissions
(Operators)
Additional verifications and
synthesis for further improvements (Min.
of Envt)
ETS registry (CDC) and Inventory compiler (CITEPA)
Requests and characteristics from UN, EC and national authorities on ETS and Inventories (GHG and non-GHG)
Data treatment in inventories
More individual figures have to be considered within inventory processes.
Additional checks have to be performed : for instance concerning energy balances (sectoral and total).
The use of specific figures from individual plants will imply annual changes in emission factors and consequently raise several items such as additional remarks from UNFCCC reviewers or additional risks on adjustments.
Increase the « cost » of emission inventories. But possibly less with the current integrated national inventory system than it would be if two separate processes were implemented.
,
Conclusion
EU ETS requirements :
• introduce additional complexities in emission data collection and reporting as well ETS as inventories,
• allow greater accuracy and consistency in GHG inventories,
• allow additional benefits for non-GHG inventories,
• increase the burden of work both for ETS and inventories due to differences in specificities (scope is different, methodological impact due to allocation of CO2 and related management of risks, additional checks, etc.),
• need for more resources (development of reporting procedures, guidance, advice, verification for ETS, more data to compile in inventories, additional checks)