Mike McMahon (BP/IETA)
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Mike McMahon (BP/IETA)

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Mike McMahon (BP/IETA) Mike McMahon (BP/IETA) Presentation Transcript

  • MRG Cross-cutting issues from the perspective of industry/verifier MRG Stakeholder Day Koln, 12 th May 2005 Mike McMahon, IETA/BP
  • IETA MRG Work Group
    • One of a number of IETA WGs looking at Phase II issues
    • Representatives from Industry Sectors and Verifiers
    • Desire to cooperate with Commission and Ecofys in producing a user-friendly Phase II MRG.
  • Cross-cutting issues: Ambiguity
    • Consistency in application across Member States is important
    • Need to review and incorporate the Commission's Q&As
    • Recommend that the Q&As be kept live to promote consistent application across Member States
  • Cross-cutting issues: ISO 17025
    • Limited number of accredited labs
    • Use of equivalent “standards”
    • Problem of dropping a Tier
      • Use of default emission factors
      • Introduces a known bias
      • Conflict with principle of accuracy
  • Cross-cutting issues: Role of overall uncertainty
    • Overall uncertainty analysis
      • Required or not?
      • Ambiguous
    • Purpose of Table 3
    • Could be used to select the appropriate Tier for activity data based on the contribution of that source to the overall uncertainty.
  • Cross-cutting issues: Cost effectiveness
    • Table 1 specifies minimum required Tiers for individual sources based on the overall emissions from the installation.
      • In many cases this will involve considerable expense to improve the accuracy of individual meters with negligible improvement in the overall uncertainty.
  • Cross-cutting issues: uncertainty threshold for activity data Tiers
    • What is “maximum permissible uncertainty”
      • Of the metering process
      • Over a reporting period
      • Impact of maintenance and calibration schedule
      • Impact of sampling frequency for eg density
    • Uncertainty is not well understood by the operators
      • Need additional guidance with examples
  • Cross-cutting issues: CEMs
    • Operator compliance with EN 14181 and EN ISO 14956
      • Very onerous requirements
      • Lack of reference standards