Managing differencies in coverage, institutional and methodological issues (EU ETS vs GHG inventory) case of France Jean-Pierre FONTELLE Centre Interprofessionnel.

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






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






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 :






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 :






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)

Managing differencies in coverage, institutional and methodological issues (EU ETS vs GHG inventory) case of France Jean-Pierre FONTELLE Centre Interprofessionnel.

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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.