Accounting For Industrial Emissions [Jan 2006]

So - what sort of testing should we be advocating?

Accounting For Industrial Emissions

So - what sort of testing should we be advocating?

The EU ETS Monitoring and Reporting Guidelines are undergoing revision in anticipation of the second compliance cycle of Directive 2003/87/EC - the greenhouse gas (GHG) emissions trading scheme, which starts in 2008. This article highlights the changes introduced that call for standardisation (i.e. ISO, CEN, and BS standards), these relate mainly to the future expansion of emissions trading to non-CO2 GHGs and new industries. In particular, the opportunities offered to international standards makers to assist the successful extension of mass emissions trading to wider geographical scales.

We would probably all agree, in principle, that rules are needed for monitoring and reporting the mass emissions of industrial greenhouse gas emissions to be traded between countries or organisations. If there is a need for cost effective solutions for providing information to the market of the actual emissions, as is suggested by the European Commission, should these rules be traceable to materially referenced systems; by this I mean standard reference materials or reference artefacts? Probably not - provided we restrict agreements to regional groupings of countries and restrict ourselves to a limited number of industries and process emissions. Indeed calculation has been the method preferred by the EU member states (and industry) for reporting CO2 emissions under the first compliance cycle of the EU ETS - it is a 'rule/procedure' referenced approach. Consequently the monitoring and reporting guidelines used for the first compliance period of the EU's Emission Trading Scheme (EU ETS) had relatively little need to reference international standards. But what happens if we subsequently find that, on the balance of probabilities, the environmental gains from our existing GHG reduction policies are not sufficient or are too uncertain? It is interesting to note that greater prominence is given to using international standards in the revised EU Monitoring and Reporting Guidelines. The Commission has challenged environmental professionals to develop tools to enable industry to operate more sustainably in a global market - and it is our business interest to show that we can rise to the occasion.

International standards are high on the list of the tools that could and should be used to extend emissions trading. ISO is an independent technical resource operating globally, CEN focuses European expertise and resources in international standardisation. ISO and CEN standards are vital in guaranteeing both the value of traded commodities and the quality of environmental testing. Standardisation offers policy makers in government and industry an independent, technical, resource. The standardisation process draws on a network of experts/expertise created by CEN and ISO (and its national member bodies) from the skills and experience of its wide range of stakeholders. Standards are increasingly being seen by the European Commission as vehicles through which to promote better and more sustainable regulation. They should, on this basis, have a role in setting the systems whereby mass emissions of non-CO2 GHGs are traded globally and improving the comparability of annualised mass emission reporting under international environmental agreements (as part of improving emission inventories for instance). Significant work has already been done at a systems level by introducing ISO 14064 - see Box 1. It is interesting to note - see Box 2 - how little the current suite of emission standards is directly applicable to GHG reduction policies; there is much work to be done putting in place the functional standards needed to support the established superstructure.

Rule based systems tend to use value judgements of behaviour and they use vocabulary such as 'confidence' or 'warranted belief'. Rule based systems have referees, judges, and auditors/verifiers and are perfectly adequate for many important aspects of our lives - not least our financial systems. They rely, moreover, on standards that promote testable conformance with prescribed behaviours (like ISO 14064:2006 pts 1-3:2006 - Greenhouse gases)
When testing conformity with a required physical result we tend to use the measurement/counting related terminology of statistics - accuracy, precision, and uncertainty. For such physically based systems we have rule systems that are supplemented by reference artefacts (mass, time, length etc) and the means of demonstrating the equivalence of alternative (physical) methods. Examples of these are the suite of CEN standards for testing compliance with the waste incineration directive (EN 1948 for dioxins, EN 1911 for hydrogen chloride, EN 14789 for oxygen etc). From this perspective we need to decide whether we should be promoting the inclusion of independent testing in GHG monitoring and reporting schemes from their inception, not just to demonstrate compliance but also as a way to quantify the outcome. So - what sort of testing should we be advocating? How can international standards assist in accounting for GHG emissions?

The process of standardisation and the use of standards:

1. Avoids or reduces ambiguity in emissions statements and encourages the use of a common approach by operators, auditors, and service supply organizations by:

Ensuring that testing procedures are capable of independent verification.
Avoiding procedures that might lead to an infinite regress to ever more detailed sub-procedures by, for example, selecting approaches that avoid error (which is more practical and understandable) rather than setting requirements to demonstrate 'accuracy'.
Reducing ambiguity in the use of vocabulary and terminology, advocating - for example - the use of wording such as confidence or warranted belief when judging conformity with behaviours and only using the terms 'accuracy, precision, and uncertainty' when talking of the conformity to outcomes with a required physical result (such as with an absolute reduction in emission) - in that given in ISO's International vocabulary of basic and general terms in metrology (VIM): 1993, which is currently under revision).

2. Could improve the default emission factors (and other calculation factors) that are so indiscriminately shared between GHG reporting schemes by:

Harmonising the procedures used for up-dating default emission factors (and their uncertainty estimates).
Ensuring the likely range of an emissions estimate is transparent to the user of an emission statement, identifying tools to spot out of range values (i.e. detecting possible error)
Developing the reference artefacts needed for calibration and the reduction of uncertainty (thereby improving accuracy).

3. Improve calibration procedures for continuous monitors and meters, drawing on the experience gained with national (i.e. MCERTS) or international standards specifications the accuracy of metering equipment to estimate the uncertainty of the annual activity level. CEN TC 264 has experience of developing standards to establish/maintain acceptable performance characteristics for metering devices and provides user confidence that instruments are fit for purpose - TC264 is air related but the principles are applicable to all media - see Box 3.

International standardisation of mass emission reporting

A joint CEN/ISO Working Party has recently reviewed the air emissions standards needed to enable the extension of emission trading. Currently standards only exist for stack concentration measurements required for testing the application of best available technology. There are no suitable standards for measuring flow, relating emitted pollutant concentrations to fuel consumption or process activity, or for converting measurements to mass, or combining measurements, to producing sector averages, or for annualising data. It concluded that ISO: EN standards are needed for flow measurement and the determination of emission factors. This work is urgent because it can take up to 3 years to design, test, and publish an International standard and the standards are needed inform policy developments or regulations scheduled for 2008 onwards.

Subsequently both the CEN and ISO air quality technical committees have agreed that:

There is indeed a need for International standards to facilitate the reporting of mass emission data and a willingness of ISO and CEN members to undertake work in this field
They would co-operate to produce the most urgently needed standards and adapt their working procedures accordingly
Promote the benefits of international standard(s) for mass emission reporting to the potential users and in so doing define any further development needs, validation requirements, and the field-testing needed to characterise the uncertainty associated with mass emission reporting

As a result ISO/TC 146 - Air Quality, at its October 2006 meeting, agreed to work with CEN TC/264 Working Group 23 to develop a new standard on flow measurement. It also created an ad-hoc group on Mass Emission Standards (AHG MES) to work with CEN/TC 264 - Mass emissions, to develop a new standard for mass emission factors. ISO already has work items to develop standards for N₂O and CH₄.

UK environmental professionals can participate in the work by being nominated, by their trade or professional associations, to BSI Technical Committee EH2 - Air Quality. EH 2 and its sub-committees covers the standardisation of tools for the characterisation of: stationary source emissions, workplace air, ambient air, indoor air, gases in and from the ground, and deposition of air pollutants. The work includes the development of measurement methods for air pollutants (particles, gases, odours, micro-organism) and meteorological parameters, methods for the determination of the efficiency of gas cleaning systems, measurement planning, procedures for Quality Assurance/ Quality Control (QA/QC), and methods for the determination of the measurement uncertainty.

Author

Mike Woodfield is an analytical chemist with over 30 years professional experience of air pollution control policy development, the evaluation of the cost of emissions reductions, the compilation of emission inventories and projections, and the implementation of monitoring programmes. Mike works closely with the UN ECE, the European Commission and its agencies, as well as the UK Environment Agency, DEFRA, and industry. He is the current chairman of BSI Technical Committee EH 2 - Air Quality, convenor of CEN TC/264 Working Group 24 - Mass emissions, and the chairman of ISO TC/146 ad-hoc group on mass emissions.

www.bsi-global.com

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