1. www.boc.ie Draft for SEI Review SEI Workshop on IS 393 December 7 th 2005 The potential synergies between IS 393 and other energy related Drivers and Regulations i.e. IPPC, EU ETS etc. in the light of the recent preparatory work on Ireland’s Second National Allocation Plan for emissions trading in period 2008-2012 A presentation by Tom Cleary Senior Partner Byrne O Cleirigh

2. www.boc.ie Objective of Presentation p To inform group of context of energy use by industry and main drivers to reducing emissions p Examine requirements of the IPPC Directive and IPPC Licensing wrt Energy p Examine overlap and synergies between IS 393 and other drivers particularly IPPC Licensing by EPA, EU ETS and higher energy prices. p Highlight need for a range of support measures to meet challenges

3. www.boc.ie How are Developments in Key Sectors likely to influence the role of IS 393 1. Power sector – EU ETS & Security of Supply 2. Trading sector industry energy emissions 3. Trading Sector Process Emissions 4. Non-trading sector industry Nos. 1, 2 and 4 are main areas for IS 393 though IS 393 disciplines could also assist identify reductions in process emissions

4. www.boc.ie Relevance of IS 393 to Power Sector p Power sector – prices rising due to rising prices of oil and gas and coal p EU ETS will add a cost to power sector which will have knock on impacts on industry and services and competitiveness p Power companies are not immune to the need to reduce energy costs and hence EU ETS costs p We in BOC see great synergies between all drivers – because of escalating energy costs it is nearly impossible to have too many stimuli for energy efficiency. IS 393 potentially important in sector

5. www.boc.ie 2003 Contributors of CO 2 Emissions by Industrial Sectors within in Trading Sector in Ireland

6. www.boc.ie 1990 Emissions Contribution Total 53.974 MT CO2e

7. www.boc.ie 1990 Emissions Contribution Total 53.974 MT CO2e

8. www.boc.ie 2003 Contributors of CO 2 Emissions by Industrial Sectors in Trading in EU ETS in Ireland Cement 17.1% Power 66% Alumina 5.2% Food & Drinks

9. www.boc.ie Trading Sector – Manufacturing Industry p Some highly energy intensive firms p At least 2 sectors and several installations with emissions > 1 million tonnes CO2e pa p 2003 total of non power generation CO2 emissions in trading sector (industry plus a small number of commercial / institutional buildings) ~ 6.8 million tonnes (including direct emissions from fossil fuels and process emissions)

10. www.boc.ie Data collection on emissions from Non-Trading Sector of Manufacturing Industry – NAP 1 survey p We estimated trading sector emissions from mfg. industry. for 2003 by bottom up surveys in 2003. p By subtracting the estimated trading sector emissions from the total national inventory for all industry we got a more accurate value for this sector than in 2003. Non trading industries – emissions of around 1.0 MT CO2 in 2003. p Split between Trading and Non Trading sectors of Industry in 2003 is –Energy Emissions from trading industries ~ 3.99 MT [~ 80 sites] –Energy emissions non trading industries ~ 1.0 MT [> 4000 sites]

11. www.boc.ie Why the Need for IS 393 at this time p In 2003 SEI had reported on potential for negotiated agreements for Industries outside EU ETS. Identified potential energy savings of ~ 640,000 tonnes per annum in 650 firms the non trading sector based on a carbon energy tax of €17.5 and an 80% rebate for undertaking a programme of measures p Carbon tax has been scrapped in meantime

12. www.boc.ie Clear from This Mornings Speakers that IS 393 could be an important part of a Suite of Measures p Identification of need for and benefits from IS 393 addressed by other speakers p Other SEI initiatives to assist firms e.g. LIEN, EMAP p We in BOC have Identified several groups of organisations for which IS 393 may be appropriate –Firms and Commercial Sites in EU ETS –High Electricity users whether in EU ETS or not –The largest firms in Non trading sector of industry –Members of LIEN (big overlap with EU ETS firms) –IPC Licensed Sites (480 excluding agricultural sector)

13. www.boc.ie IS 393 and IPPC Directive’s Requirement for Efficient Resources Use p EU IPPC Directive 96/61 is concerned with integrated pollution prevention and control p Implemented in Ireland via Protection of the Environment Act 2003 p Sections 82(10)(a) and 82 (11) provide power to EPA to review IPC licence and update them to IPPC licence p IPPC Directive has requirements under the headings of Resource Use and importantly Energy Efficiency

14. www.boc.ie IS 393 and IPPC Requirements for Efficient Resources Use – Current Position p In 2003 EPA asked BOC to draw up a template for energy auditing in preparation for IPPC p Energy Auditing now a condition of many IPC and all IPPC licences – by June 2005 the energy efficiency condition had been included in 120 IPC licences. p The audit template is now on EPA web site p Letters with conditions to create many IPPC Licences have been issued in the last few months Oct/Nov 2005 p Where these letter contain Amendments to older IPC licences the requirement for energy management is now explicitly listed as is a similar requirement for efficiency water use and efficient use of raw materials.

15. www.boc.ie Typical Wording of Energy Efficiency Conditions in EPA’s IPPC Licences 1. To carry out an audit of energy efficiency of the site within a pre-determined time from issue of Licence 2. The audit shall –Identify all opportunities for energy use reduction –Use EPA template for audit –Repeat audit at agreed intervals 3. Recommendations from Energy Audit are to be incorporated into a schedule of Environmental Objectives and Targets [EO&Ts was already a condition of all IPC licences before energy efficiency was incorporated]

16. www.boc.ie How do Key Requirements of IPPC and IS 393 Compare? Energy Conditions of IPPC Licences IS 393 Requirement Carry Out Energy AuditCovered by Requirement to Review of Energy Aspects Identify all opportunities for energy use reduction Explicitly part of review of Energy Aspects Incorporate recommendations from audit into Objectives and Targets in AER – Annual Environmental Report Audit to be conducted in accordance with EPA audit template IS 393 has comprehensive requirements covering all topics in EPA template

17. www.boc.ie Reminder of National Projections of BAU Emissions as of Feb 2004 – ICF-BOC – Gap to Kyoto Target 9.1 MT CO2e – latest refinements may reduce slightly

18. www.boc.ie Most Recent Work in Preparation for NAP 2 p New work by EPA and FAPRI on emission factors and activity levels in Agriculture p Recent review by DoEHLG on emissions from waste p New work by ESRI on Mid Term Review and Energy Use Projection p New work by COFORD on sequestration p New work by EPA on historical emission of “F” gases p Transport 21 – will need to ascertain how massive investment will impact on national emissions

19. www.boc.ie Conclusion is that Drivers for IS 393 and Energy Efficiency Aspects of IPPC are likely to increase p Although national GHG emissions peaked temporarily in 2002 the subsequent dip was due to major plant closures IFI, Irish Steel/ISPAT, etc. and emissions are projected to increase progressively to 2012 p The cost of energy is unlikely to fall p Therefore at emissions costing €15 per ton for any gap above our Kyoto target will be expensive nationally p IS 393 seems to provide an extra edge which all industries and major commercial organisations could well use to their financial benefit. p Speakers this morning indicated that EU ETS will not deminish role of IS or Danish standards.

20. www.boc.ie How many firms are likely to find IS 393 of Benefit p 80 industrial firms in Emissions Trading – will provide a structured way to seek emissions reductions from energy p 80 industrial firms in SEI’s Large Industry Energy Network p Some of the 120 Firms which had energy efficiency conditions in their IPC licences as of June 2005 p Other IPC firms which are likely to have the energy efficiency condition included in their IPPC licences over the coming months.

21. www.boc.ie Summary p There will be serious and sustained drivers to increase energy efficiency driven by –EU ETS and Kyoto Protocol –Higher energy prices –New EU Directives such as IPPC Directive. p Industries will need a range of initiatives to counter these challenges p IS 393 holds the prospects of providing a structured approach to energy management which will help to meet these challenges.

22. www.boc.ie Emission Trends by Sector and Relative Importance of Sectors

23. www.boc.ie September 2005 ICF-BOC Projection of Distance to Kyoto Target 2008-2012