Stakeholder day on the EU-Monitoring and Reporting Guidelines – Experiences of the Pulp and Paper Esa Hyvärinen Confederation of European Paper Industries (CEPI) Cologne, 12 May 2005

2 The pulp and paper industry Energy is a key input for the pulp and paper industry: Up to 30% of production costs. 40% of electricity used is produced on site, of which 90% is produced through combined heat and power (CHP) and 52% of all energy consumed comes from renewable energy sources. The industry still purchases 70 TWh of electricity per year.

3 The pulp and paper industry 880 companies, about mills: Several big multinationals, many SMEs. Processes are very different; Chemical pulping generates more energy than the process requires. Mechanical pulping an energy intensive process. Paper mills do not necessarily have any direct emissions (some mills have zero quota). Recycling process demands less energy than mechanical pulping, but does not have a natural source of biomass to be used.

4 MRG - General comments Not much experience yet – not very much feedback from the mills. Testing in practice next year. Considered to be unnecessary tight for the purpose. Need for some big changes but not very big number of changes.

5 Accuracy – Flexibility – Cost-effectiveness – Level playing field Very accurate – not too flexible – cost-effectiveness can be improved: High accuracy requirement leads to inflexibility and low cost-effectiveness. Possibility to exclude minor emissions, which are smaller than the error margin or uncertainty related to the total emissions of the installation. Tier approach has a potential to lead unnecessary tight requirements and create an un-level playing field.

6 Combustion Possibility to use mill-level calculation must remain: Most (if not all) of the emissions from pulp and paper industry are from combustion of fossil fuels that come outside the mill. Based on current practices in taxation for example. Can benefit of the documentation from normal bookeeping (fuel purchaces).

7 Combustion Tier approach: Installations emitting more that 50 kt/y: Batch level analysis of the net calorific value, emission factor, composition and oxidation factor to be carried out by a laboratory certified according to EN ISO Standard emission and oxidation factors: The more standard emission and oxidation factors the better.

8 Combustion Biomass: General method to define biomass content of mixed fuels still missing. Biomass content to be analysed by a laboratory certified according to EN ISO Why analyse the net calorific value if the emission factor is assumed to be zero anyhow? List also crude tall oil, tall oil and pitch oil as pure biomass.

9 Production of pulp and paper Process emissions: Emissions from the use of carbonates as make-up chemicals in pulp mills (CO2 from CaCO3 that compensates biogenic lime mud): The amount is negligible (e.g. in Finland t out of t of total emissions from the pulp and paper industry). The lost material is usually landfilled, which means that there are no emissions. These emissions should be excluded as a minor source.

10 Production of pulp and paper Process emissions: CEPI currently assessing what in the end should be considered as process emissions in the case of pulp and paper industry: Lime kiln, recovery boiler, infra- red dryers in papermachines, etc.

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