Wed 24 Aug 2011 – New draft regulations will be coming into force for the EU Emissions Trading Scheme (ETS) in 2013, replacing the existing Monitoring and Reporting Guidelines (MRGs). These regulations, which are fully enforceable pieces of legislation, will replace the two existing MRGs that operators are currently required to follow. This unification of two documents has resulted in a set of guidelines that are more coherent and easier to read than before, reports Neil Duffy.
There are few major changes, but the most significant is the raising of the threshold for operators to use the Simplified Method, opening up the Small Emitters Tool and the ETS Support Facility to many smaller commercial operators. The new regulations are still in draft form and although there might be a few minor changes to the wording, no substantial changes are expected before the legislation is voted on in mid-September.
At present, only private operators emitting up to 10,000 tonnes of CO2, or flying less than 243 flights in three consecutive 4-month periods, on flights to and from EU airports can use the Small Emitters Tool or the ETS Support Facility. This change means that commercial operators who emit between 10,000 t and 25,000 t, and all private operators up to 25,000 t of CO2 will now qualify to use the simplified method. Under the current draft, commercial operators under 10,000 t would most likely remain exempt from the scheme.
The use of the Simplified Method, which is a collective term for the Small Emitters Tool and the ETS Support Facility, can reduce the internal burden on operators as it reduces the amount of internal data required for compliance, thus saving time in collecting, processing and quality checking this data. It also allows for a shorter verification, further reducing costs.
The disadvantage is that the Simplified Method is based on estimations of fuel burn rates, which can be less accurate than direct monitoring and may result in an overestimation for some types, meaning more allowances may need to be surrendered than if direct monitoring was used. It also does not reflect actual fuel savings that result from an operator’s use of technology or operational procedures, reducing the incentive for operators to take steps to improve efficiency. For this reason, operators who now fall into the Small Emitter category should consider which approach is best for them.
The operators who will benefit most from this change are commercial business aircraft operators based in Europe and airlines based near Europe with a relatively small number of flights to Member States. It should be noted by all operators, and especially any who would like to switch method, that 2011 and 2012 data will need to be gathered following the existing rules.
It should also be noted that it is the MRG that is being changed, not the overriding Directives (2003/87/EC & 2008/101/EC), and it is the Directives which set the exemption criteria. So commercial operators which are emitting less that 10,000 t will most likely continue to be exempt, while all private operators must continue to comply with the scheme. The 243 flights in three consecutive 4-month period threshold is not affected by this change, so operators will still only need to be under one of these two thresholds to either use the Simplified Method or to be exempt, depending on their operational circumstances. There have also been changes to other aspects of monitoring, such as the way the density of fuel uplift is measured, so all operators need to become very familiar with the new regulation before it comes into force.
Another regulation currently being drafted is designed to harmonise the accreditation and verification process across Europe and allows for increased recognition of verifier accreditation in other states. There is also a clause built into the original legislation requiring the Commission to review the main Directive before the end of 2014, with recommendations for improvement to be made based on experience. This shows a commitment to improving the scheme and to iron out the teething problems operators are currently facing, even if operators would rather the process was a little quicker.
Neil Duffy is Technical Manager at ICM ETS, which specialises in the verification of aircraft emissions, and offers a service tailored to the needs of operators while satisfying the regulators. For more information go to www.i.im/aviation/ets.php, or contact Neil at firstname.lastname@example.org
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