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

2. Raising issues of discussion scope and classification problems benefits for inventories impact on emission inventory process management and institutional arrangements for ETS & GHG inventory

3. Scope and classification A boiler is a boiler, A stack is a stack, 1 ton of CO 2 is 1 ton of CO 2, 1 ton of coal, heavy fuel oil or gas is the same and CO 2 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 CO 2 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

4. Scope and classification A boiler is a boiler, A stack is a stack, 1 ton of CO 2 is 1 ton of CO 2, 1 ton of coal, heavy fuel oil or gas is the same and CO 2 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 CO 2 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),

5. 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 FranceIPPC / EPER Larger list of sources and emission threshold 100 000 t CO 2 GHG inventory All sources included whatever the sector, the capacity and the equipment Classification is different EU ETS Directive LCP, NEC, EMEP Not concerned by CO 2 but consistency with activity rate (fuel comsump- tions, produc- tions) Plant specifi- cations more or less restricted (eg LCP > 50 MW)

6. Scopes of inventories / registers are different EU ETS EMEP EPER LCP GHG & NEC IPPC

7. Scope and classification A boiler is a boiler, A stack is a stack, 1 ton of CO 2 is 1 ton of CO 2, 1 ton of coal, heavy fuel oil or gas is the same and CO 2 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 CO 2 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),

8. Limitation of the source-oriented approach Fossil, fuel and various products Steel industry By-products (tars, chemical products, …) Blast furnace gas Coke oven gas Steel conversion gas External recovery Flaring Recycling Pig iron, steel, …

9. External recovery (eg power plant) Blast furnace Gas (268) Coal (95) (kgCO 2 /GJ) CO 2 (t) 500 000 Total 1 000 000 ETS allocation 950 000 t Situation ASituation B Natural Gas (57) Coal (95) (kgCO 2 /GJ) CO 2 (t) 500 000 106 000 Total 606 000 Supplementary CO 2 emission by flaring 500 kt National total + 106 kt CO 2 non emitted by the power plant 344 kt (x20/t = 6,88 M) Between situations A and B

10. 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 CO 2 emissions consistent with the sum of plants consuming BFG and the production of BFG minus flaring and losses ? Consequences :

11. Scope and classification A boiler is a boiler, A stack is a stack, 1 ton of CO 2 is 1 ton of CO 2, 1 ton of coal, heavy fuel oil or gas is the same and CO 2 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 CO 2 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,

12. 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 CO 2 but concerned by activities Accuracy requirements from ETS >> GHG requirements The situation depends on specific characteristics for each MS inventory

13. Combustion Sectors in ETS Methodological approach in GHG inventory Problems with ETS ? Impacts ? Centralized electricity production and oil refinery 100% bottom-upNo 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 fuel i cons. from non indiv. instal. = energy balance fuel i - Σ fuel i cons. indiv. instal.

14. 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 (CO 2 decarbonizing / total CO 2 ) based on 49 ETS plants Estimation of decarbonizing CO 2 for 3 plants Total decarbonizing emission for 52 ETS plants 276 kt CO 2 -> EF 50 kg CO 2 /t prod National EF in GHG inventory 40 kg CO 2 /t prod -> 230 kt CO 2 CONSEQUENCE : change in national EF 40 -> 50 kg CO 2 /t prod -> 287 kt CO 2 The difference corresponds to ~90 non ETS (very small) plants.

15. 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 (CO 2 decarbonizing / total CO 2 ) based on 20 ETS plants Estimation of decarbonizing CO 2 for 3 plants Total decarbonizing emission for 22 ETS plants 2474 kt CO 2 National emission by using EFs in GHG inventory 2534 kt CO 2 CONSEQUENCE : no change in national EFs for lime production (decarbonizing) The difference (2,4%) corresponds to 1 non ETS plant.

16. 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-CO 2 emissions, possible impact on inventory processes (GHG and non GHG), increased inventory burden. Consequences :

17. Scope and classification A boiler is a boiler, A stack is a stack, 1 ton of CO 2 is 1 ton of CO 2, 1 ton of coal, heavy fuel oil or gas is the same and CO 2 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 CO 2 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

18. 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, CO 2 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

19. 84% of allocations from 19% of plants 96% of allocations from 53% of plants (those > 25 000 t) 156 Mt CO 2 – ~1100 installations

21. t

22. ~1100 ETS plants within over 5500 industrial facilities concerned

23. Overview of the reporting flow sheet Accreditation of 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, 1 st check Report and conclusion (Verifiers) 2 nd 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)

24. 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.

25. , 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 CO 2 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)