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According to TEHG Annex 2 Part 1,“operators of installations that were commissioned no later than ten months before the start of a trading period” must submit their monitoring plans by VPS to DEHSt for approval by 31.07.2020. Otherwise, a fine of up to €50,000 may be imposed.

The monitoring plans to be submitted must comply with the new requirements for the 4th trading period.

DEHSt has published the following documents for this purpose as of 06.05.2020:

Here you will find a
brief summary of the news relevant from 2021
on the topics of monitoring plans and emission reports:

1. levels 1 to 3 are introduced for the biomass fraction

  • Level 1: value provided by the competent authority or the Commission or values referred to in Article 31(1) of the MAO
  • Level 2: Approved estimation method referred to in the second subparagraph of Article 39(2) of the CMO
  • Level 3: Sampling and analysis in accordance with the first subparagraph of Article 39(2) and Articles 32 to 35 of the CMO.

2. calculation factors “guaranteed by the supplier

If a supplier of a fuel or material can demonstrably guarantee values that the carbon content has a 95 % confidence interval of no more than 1 %, this corresponds in the 4th trading period of accuracy level 2 instead of level 1 in which the 3rd trading period. In the 4th trading period, values guaranteed by the supplier can now also be approved instead of the values in the DEHSt list.

3. empirical correlation

Plant operators with the highest level requirements according to the MVO were able to avoid disproportionately high costs of e.g. daily analyses in the 3rd trading period determine emission factors on the basis of empirical correlations, for example using a density correlation. This methodology was considered to be Level 2. What is new is the classification in Level 3 in the 4th trading period if the operator demonstrates that the uncertainty of the empirical correlation does not exceed 1/3 of the otherwise required accuracy value. Proof of disproportionality may not be required in such cases.

4. transmission of (inherent)CO2

In the 3rd trading period, an ETS plant operator was not liable to pay a levy for the inherentCO2 that it surrendered as part of a fuel to another ETS plant, nor was it liable to pay a levy for theCO2 surrendered to a CCS plant.

In the 4th trading period, the following applies in simplified form (without special cases):
A plant that transfers (inherent)CO2 is not liable to pay a levy for the transferred (inherent)CO2 if it

  • to an ETS facility, regardless of whether the inherent CO2 is passed on as part of a fuel
    or a material
     is passed on
  • to a so-called CCS facility for permanent geological storage.

As a matter of principle, purchasers of forwardedCO2 must surrender emission allowances for this. IfCO2 is transferred to a plant not subject to emissions trading, the transferring plant is liable to pay the levy.

5. standard calculation factors of the DESHt list

The default calculation factors for six material streams were updated in the DEHSt list, including natural gas H. Natural gas Altmark was removed from the list.

6. highest tier requirement for low-emission material streams and emission sources

The distinction between high-emission and low-emission material flows is practically no longer relevant for monitoring methods. In the case of deviations from the highest tier requirements, evidence of disproportionality or technical infeasibility shall be provided. This change in enforcement also affects the submission of improvement reports. In contrast to the 3rd trading period, improvement reports must now also be submitted in the case of approved deviations from the highest tiers for low-emission material flows and emission sources.

7. proof of disproportionality for non-accredited laboratories laboratories

If non-accredited (laboratories) are used for the analyses, evidence of disproportionality or technical infeasibility shall be submitted with the monitoring plan for approval.

8. information on measuring instruments in the FMS

In the FMS, various changes were made to the measuring instruments with regard to quality assurance. This concerns, inter alia, quality assurance by calibration, verification or by other means and the expression of uncertainties as the MPE or MPE. This information and the “interval” shall be revised by the operator after the import of the last monitoring plan.

9. uncertainty analyses for the determination of the quantity of substances

DEHSt has “completely” revised Chapter 6 “Determination of substance quantities and preparation of uncertainty analyses” in the Guidance Document. It is a question of a more comprehensible presentation and of the systematic preparation of uncertainty proofs.

„As part of the approval of monitoring plans for the 4th trading period the uncertainty proofs. Therefore, operators should review and, if necessary, revise the evidence prepared for the 3rd trading period using the explanations in Chapter 6 of the Guidance Document.“

10. conversion from natural gas L to natural gas H

Plant operators are requested to document any conversion from natural gas L to natural gas H in the monitoring plan.

11. municipal sewage sludge, municipal sewage gas

For the material flows “municipal sewage sludge” and “municipal sewage gas”, the standard factor of 80 % for the biogenic share can be applied under certain circumstances by way of simplification.

12. notification of non-significant changes to the monitoring plan

Non-significant changes are to be notified to DEHSt collectively earlier, by 31 December at the latest. of the respective reporting year.

13. submission of improvement reports

An improvement report is required under Art. 69 para. 1 to 3 MVO to be submitted to DEHSt

  • for high-emission and low-emission material streams as well as large and small emission sources in Category B and C installations (installations with more than 50,000 t CO2 eq/a), if their monitoring has so far not complied with the highest tiers pursuant to MVO,
  • for high-emission and low-emission source streams as well as large and small emission sources in Category A installations (installations with no more than 50,000 t CO2 eq/a), if their monitoring has so far fallen short of the facilitations already allowed by the MVO,
  • for a fall-back monitoring method in accordance with Article 22 of the MVO.

In the 3rd trading period, these rules only applied to high-emission material flows, so that plant operators will certainly have to submit more frequent and more extensive improvement reports to DEHSt.

Author: Markus Kasten

Date: 11.05.2020

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