• How can CO2 emissions be conservatively estimated as a direct and immediate result from one of the processes under Section 2(29)(b) ZuV 2020 (for example kilns in the ceramics industry) if there is no metrologically determined data on the incompletely oxidised carbon content in the raw gas prior to thermal afterburning? (027)

  CO2 emissions that do not arise as a direct and immediate result in a process pursuant to Section 2(29)(b) ZuV 2020 are not eligible for allocation as process emissions type b. If no measurement data are available to determine these emissions, conservative estimates should be made in accordance with Section 6(4) ZuV 2020 on the basis of good industrial practice and current scientific and technical information.

  The process is explained below using an installation for firing backing bricks as an example.

  A possible reference point for determining the incompletely oxidised carbon can be the state of the raw gas, i.e. before it enters the thermal afterburner (TNV) downstream of a kiln. The basis for a conservative estimate of the non-oxidised carbon in the raw gas can be the maximum permissible concentration in the raw gas (organic compounds and carbon monoxide) before the TNV according to the technical data provided by the manufacturer. If these data are not available, literature data that must meet current scientific criteria can be used. For example, Table 3.4 in the 'Bulletin on Best Available Techniques in the Ceramics Industry' (BAT-Bulletin Ceramics 08.2007) ['Merkblatt über die Besten Verfügbaren Techniken in der Keramikindustrie' (BVT-Merkblatt Keramik 08/2007)] contains such data. The prerequisite for this is that the literature data used for the estimation describe the installation sufficiently conservatively, that means the amount of non-oxidised carbon in the installation’s raw gas is not underestimated.

  According to the BAT Bulletin for Ceramics, the carbon monoxide concentration and the carbon concentration from volatile organic compounds in the raw gas are 1500mg CO/m³ and 250mg C/m³. For the stoichiometric factor for converting CO to C of 0.4288, a maximum carbon concentration in the raw gas Craw gas can be derived as follows:

  Craw gas = (1500 *10-9 * 0.4288 + 250 *10-9) t C/m³ = 893*10-9 t C/m³

  The amount of emissions ARcorrection (in t CO2) that cannot be allocated in the allocation element for process emissions type b can be estimated as follows:

  ARcorrection = Craw gas * Vraw gas * t-operation * (1 - Cbio process) * 3.664

  with

  Vraw gas maximum flow rate of raw gas in m³/h according to the technical data specified by the manufacturer or the maximum value from Table 3.5 in the BAT information sheet for ceramics

  t-operation number of operating hours of the TNV for the respective year

  Cbio process biogenic carbon content of the materials used whose emissions are to be allocated to the allocation element with process emissions.

  3.664 stoichiometric factor for converting carbon to carbon dioxide

  For ARcorrection the annual activity rate of the process emissions ARtype b eligible for allocation, is calculated from the emissions of the materials used; they are allocated to the allocation element with process emissions (ARtotal), as follows:

  ARtype b = ARtotal - ARcorrection

  The annual value ARtype b is entered in the field 'Annual value of process emissions' in the FMS.

  The estimation procedure must be described in detail in the allocation application (accompanying document, if applicable). The verifier must confirm that the assumptions on which the estimation process is based, in particular the derivation of the raw gas concentration and the above mentioned C-containing materials, describe the actual conditions of the installation in a sufficiently conservative manner.

• What must be considered when entering the verified emissions (VET value)? (040)

  Operators and aircraft operators must submit their emissions reports for the previous year to the German Emissions Trading Authority by 31 March each year.

  By 31 March, the verifier commissioned by you must have entered or confirmed the volume of the verified CO2, N2O and PFC emissions (VET value), in the Union Registry in CO2 equivalents. The entry can also be made by the operator's authorised representatives, but not its confirmation. However, the entry and the confirmation of the entry must always be made by two different people.

  If there were no emissions for the respective greenhouse gas, '0' must always be entered. If the operator or the aircraft operator had no emissions at all, '0' should be entered in all three fields.

  By 30 April of each year, operators and aircraft operators must surrender the number of allowances in the Registry corresponding to the emissions caused and verified in the previous calendar year.

  The surrender must be initiated by the authorised representative of the respective operator or aircraft operator holding account.

• Low-emission installations: what information is to be provided in the FMS? (Emission determination 4. trading period 001)

  The monitoring plan in the FMS must be completed in full and in accordance with the plant set-up.

  The relief for low-emission installations shown in the following table can only be claimed if no activities are carried out in the installation for which N2O emissions are subject to monitoring pursuant to Annex 1(2) TEHG (see Article 47(1) MRR). If this is the case, the question: 'Are N2O emissions monitored?' must be answered with 'No' on the 'Cover sheet' form.

  'Installation' form

  Field	Answer	Additional information
  Categorisation of the installation as per the Monitoring & Reporting Regulation	A	… if the installation emits ≤ 50,000 t CO2eq per year.
  Is it a low-emission installation?	Yes	… if the installation emits < 25,000 t CO2eq per year. (Note: The field is automatically filled in with 'No' if activities are carried out in the installation for which N2O emissions are subject to monitoring as per Annex 1(2) TEHG).

  'Source stream forms'

  Quantity consumed	Answer	Additional information
  Level according to Monitoring & Reporting Regulation (target level)	Field is automatically filled in	... depending on the 'Categorisation of the installation according to the Monitoring & Reporting Regulation ('Installation' form) and the 'Activity according to Annex IV Monitoring & Reporting Regulation’ (Page 1 of the source stream form).
  Envisaged level	Estimated value or entry of the envisaged level	In principle, purchase records can be used and inventory changes can be estimated. If the operator measures the input volume himself and knows the uncertainty of his measurement, the corresponding level must be entered.
  Is there a deviation from the level according to the Monitoring & Reporting Regulation?	No	… as allowable relief.
  Measuring instrument	No measuring instrument	… if the source amount is determined on the basis of purchase data.
  Description of determination method	Determination based on purchase records and estimation of inventory changes	If the operator performs the measurements himself, the determination method must be described.
  Note: If the operator measures the substance volumes himself, ‘Measuring instrument’ forms must be created and completed. However, an uncertainty assessment can be dispensed with.
  Calculation factors	Answer	Additional information
  Level according to Monitoring & Reporting Regulation (target level)	Field is automatically filled in	…depending on the ‘Categorisation of the installation according to the Monitoring & Reporting Regulation‘ (‘Installation‘ form) and the ‘Activity according to Annex IV of Monitoring & Reporting Regulation‘ (Page 1 of the source stream form).
  Envisaged level	Level 1/ Level 2a	As it is generally sufficient to comply with Level 1 when determining calculation factors, ‘Level’ can be indicated in the field unless the substance is included in the DEHSt list. The DEHSt list corresponds to Level 2a.
  Is there a deviation from the level according to the Monitoring & Reporting Regulation?	No	… as allowable relief.
  Determination method	Standard figure	If standard factors are used, ‘Standard figure’ should be entered into the field.
  Data source	Field is automatically filled in	The field ‘Name of substance’ is automatically filled in depending on the selection.
  Description of data source or determination method	Indication of source for the standard factor	If the entry ‘Other’ appears in the field ‘Data source’, the data source (e.g. bibliography) for the standard factor used must be specified.
  Note: The ‘Analysis method’, ‘Frequency of analysis’ and ‘Laboratory’ fields do not have to be filled in if standard factors are used. However, if analyses are carried out, it must be shown that the requirements of Article 32-35 MRR have been complied with. The fields mentioned above and the forms ‘Analysis method’ and ‘Laboratory’ must then be filled in as for all other installations.

  Further notes:

  • Low-emission installations are exempt from submitting a risk assessment (that is evidence that the stipulated control activities adequately address the identified risks of reporting errors and deviations from the monitoring plan) according to Article 47(3) MRR. However, sources and causes (risks) of potential errors and deviations from the monitoring plan must be identified in the ‘Explanation of risks’ field on the ‘Data management’ form, even for low-emission installations (compare Annex I Section 1(1 e) MRR and Article 58(2) MRR).
  • An improvement plan based on recommendations of authorised experts is not required. An improvement plan only needs to be submitted if the operator still falls short of the relief allowed by the MRR for low-emission installations (compare Chapter 4.4 in the Guidance Document on the Preparation of Monitoring Plans).

All FAQ for stationary installations