Summary of Member States’ responses to questionnaire Krzysztof Olendrzyński preliminary conclusions based on MS responses workshop agenda – division into sessions; overlaps unavoidable! practical conclusions for all Member States Workshop on data consistency between National GHG inventories and reporting under the EU ETS at EEA 9-10 February 2006 Tytuł

Institutional arrangements – an important factor! - in some Member States (MS) the same institutions/organizations or bodies (but usually different teams) are responsible for the national GHG emission inventories and implementation of EU ETS (NAP, national registry), while in others, there are different ones - to a large extent, the institutional arrangements determine whether and how the data are exchanged (confidentiality) between ETS and GHG groups (in some cases also LCP/EPER) - involvement of public statistics bodies in GHG/ETS? (verification) - a national bottom-up (plant level) data collection system? - National Inventory System (Kyoto Protocol/UN FCCC) in use? - NAP data collection made by survey(s)/questionnaires? - links to other emission reporting systems (LCP/ EPER/ PRTR/ NEC/ UN ECE/EMEP)?

Methodological issues: AD, energy balances, confidentiality, EFs, coverage, quality of ETS data, interplay between ETS-GHG, recalculations of time series in GHG inventories, impact on base year estimates? some MS have already used plant-level (activity) data collected during NAP elaboration (surveys) for GHG inventory development and verification purposes others not yet due to – inter alia - confidentiality issues, but they plan to do so in 2006 (based on 2005 reporting) or for the 2nd trading period of EU ETS use of ETS data generally leads to improvements in GHG inventories, especially in the Industrial Process sector, where often gaps in GHG inventories were found and filled and sectoral EFs updated (most commonly in iron&steel, dolomite and limestone use sectors)

differences between ETS and GHG sectoral totals exist although they are generally minor the differences come from gaps identified in GHG, based on plant level data coming from ETS; also EFs and OFs (oxidation factors) differ in cases when GHG is strictly top-down in cases when bottom-up ETS data are used directly in GHG (especially in Industrial Processes), there are no differences some MS have already carried out recalculations of GHG time series including the base year based on data collected for NAP elaboration while others are planning to do so the need for recalculations comes from the identified differences in EFs and sometimes AD and subsequent changes made in GHG inventories

quality of ETS data is considered to be good or very good and should even get better after verification by accredited verifiers; the quality was improved when sectoral consultations were held or site visits were made by the respective authorities in some MS, there exist independent bottom-up systems other than the national statistical system; in such cases, plant level data are generally available but not necessarily for GHG use; if a bottom-up system is part of the statistical office operation, then the key issue is whether the statistical authorities are directly involved in either national ETS or GHG inventory systems some MS are not sure and indicate that it will require further analysis

the sectors in which differences were identified include: cement/clinker production, lime production, iron&steel and ceramics – basically in the IPCC Industrial Processes sector for which GHG inventories use nationally averaged EFs while ETS data are plant specific the sources of identified differences include: AD, EFs and oxidation factors - OFs; default OFs are different in IPCC than in ETS a few MS already made recalculations going back to base year while several other plan to do so in 2006; sectors recalculated include: refineries and several subsectors in Ind. Proc. sector: e.g. lime, coke plants and blast furnaces in case GHG includes sectoral average EFs for fuels, the recalculations may also affect the IPCC Energy sector (especially 1A1 and 1A2). recalculated base year emissions are sometimes lower and sometimes higher than earlier estimates

• generally ETS/NAP data are going to be available for GHG inventory purposes but sometimes confidentiality may become a problem for other than emissions inputs • confidentiality is considered to be a problem only in selected MS and concerns mainly production statistics in Industrial Processes sector of GHG; the extent of confidentiality issue may depend on requests of operators • few MS report any formal links between ETS/GHG and national energy statistics on a plant level; in some countries data collected for NAP/ETS are used by statistical authorities for verification purposes

MS report mostly complete coverage of GHG sectors by the respective by ETS sectors: refineries, cement, lime, iron and steel, coke ovens; other sectors are subject to threshold induced differences problems with identification and quantification of differences (ETS/GHG) include: definitions, process emissions (mass balance), confidentiality; some countries have not yet made systematic analysis surprisingly few MS use data collected in ETS for other reporting obligations: LCP/EPER (or vice versa) but do not perceive this as a problem with ensuring consistency for various reporting obligations differences in definitions and coverage between LCP/EPER/ETS should not prevent comparison of comparable data (mainly AD but also EFs and OFs where appropriate) several MS maintain that analysis/comparison of AD data (especially for 1A1 and 1A2)  between GHG and ETS should be combined with analysis of respective elements of national energy balances

Workshop agenda? the energy balance to be be discussed during a separate session, possibly with handling of confidentiality (especially fuel use and production levels), while other sessions could be devoted to practical experiences of MS with issues like: - interplay of bottom-up vs. top-down systems; differences in coverage (ETS v GHG); identified gaps in GHG based on reported ETS data, - methodological issues: EFs, OFs, process emissions; mass balance approach - experiences with recalculations of time series in GHG (including base year) - how to assure data consistency for various reporting systems? - activities planned in 2006?

Session 1: Interplay of bottom-up vs. top-down systems Managing differences in coverage (EU ETS vs. GHG inventory) - institutional and methodological issues etc. Session 2: Comparison of activity data in EU ETS and GHG inventories. Energy balances and national statistics, bearing on recalculations etc. Summary of Day 1 Session 3: Methodological issues regarding differences in emission factors oxidation factors used under the EU ETS and GHG inventories etc.. Conclusions and practical recommendations Closing remarks

Questions/issues to be discussed: Session 1: Interplay of bottom-up vs. top-down systems Managing differences in coverage (EU ETS vs. GHG inventory) - institutional and methodological issues etc. Is there a bottom-up (plant level) data collection system (AD, EFs, OFs, emissions, APCs) run by environmental authorities? How statistics authorities are involved in ETS/GHG inventories? Access to confidential data (AD)?

Session 2: Comparison of activity data in EU ETS and GHG inventories. Energy balances and national statistics, bearing on recalculations etc. Data flow and links between ETS/GHG and national energy statistics? Are sectoral totals (e.g. fuel use, electricity and heat production) consistent between ETS/GHG and official energy statistics? Session 3: Methodological issues regarding differences in emission factors oxidation factors used under the EU ETS and GHG inventories etc..