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ETS2.

2 Monitoring Plan Template


Version 1.1 (26-08-07)

The Greenhouse Gas Emissions Trading Scheme Regulations 2005

Confidentiality Statement
The information submitted in respect of this application will be subject to public access to information requirements, including the
Environmental Information Regulations 2004 and any subsequent replacement to these Regulations. If you consider that any information you
provide in connection with your application should be treated as commercially confidential, please let us know. You should be aware that under
the provisions of the Freedom of Information Act 2000 and regulations made under it, the Department may be obliged to disclose information
even where the applicant requests that it is kept confidential.

Introduction to this template

This template is provided by the Department for Business Enterprise and Regulatory Reform (BERR) to assist Operators in the development
of their monitoring plans for Phase II of the EU Emissions Trading Scheme. Use of this template will facilitate approval of your monitoring
plan.

The approved monitoring plan will form part of a greenhouse gas emissions permit issued under the Greenhouse Gas Emissions Trading
Scheme Regulations 2005. The completed template satisfies the requirement to describe planned monitoring of reportable emissions,
inclusive of monitoring methodologies and frequencies, in accordance with the Commission Decision dated 2007, establishing guidelines for
the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/7/EC of the European Parliament and of the Council,
hereafter referred to as MRG 2007

In completing this template Operators should have regard to the MRG 2007 and demonstrate that accurate and verifiable monitoring and
reporting of greenhouse gas emissions will be carried out in accordance with the MRG 2007 principles, which are reproduced in the attached
Annex 1.

Further details on the ETS Regulations can be found at the DEFRA web site:
http://www.defra.gov.uk/environment/climatechange/trading/eu/index.htm
Completion of the template

The template has been designed in Excel to allow it to be filled in electronically. Once completed, please email it to us so that we can
approve your plan more efficiently.

All relevant sections of the template should be completed. Incomplete templates may result in the delay in acceptance of the monitoring plan.
Once completed, this template can be sent by email.

Additional information
Any additional documents you may want to submit as part of this monitoring plan need to be identified with a filename (if submitted
electronically) or document reference number (if submitted as a hardcopy).

For monitoring plans submitted electronically, additional documents can also be emailed. They must be clearly marked, stating the:
- date of plan submission;
- emissions trading permit number (if a permit has already been issued);
- operator's name; and
- name of the installation.

We can accept additional information in the following formats:

- Microsoft Word, Microsoft Excel, Adobe Acrobat pdfs

If you need help and advice


We have made the monitoring plan template as straightforward as possible, but please get in touch with us if you need any advice on how to
set out the information we need.

You can contact us by email on: emt@berr.gsi.gov.uk


ETS 2.2 Phase II Monitoring Plan

Form ETS2.2 Monitoring Plan (Phase II) Hide


HideExamples
Examples

A1 About your monitoring plan

A1.1 What are your emissions trading permit and National Allocation Plan numbers?

GB-ETS-0909 Emissions trading permit number

National Allocation Plan (NAP) Number

A1.2 What is the Operator name ?


Operator Name

Please use name stated within the ETS permit, or in the application if permit has not yet been issued.

A1.3 What is the name of the installation and its location?


Installation name

Installation location (Quad/Block)

Please use name of the installation/site stated in the ETS permit or in the application if a permit has yet to be issued.

A1.4 Who can we contact about your monitoring plan?


It will help us to have someone who we can contact directly with any questions about your monitoring plan. The person you name should have the authority to act
on your behalf. This could be an agent rather than the Operator.

Organisation name (if acting on behalf of the Operator)

Contact person (Title, First name, Last name)

Job title

Telephone number

Facsimile number

Email address

A1.5 What is your estimated annual emission of CO2?

This information should enable indication of the appropriate MRG 2007 tiers (as outlined in Section 5.2 of MRG 2007).

kt Estimated annual emission from installation (kilo tonnes)

This should be based on the verified annual fossil CO2 emissions data OR your best estimate for the forthcoming reporting period and should take into account
any planned changes.

A1.6 Do you satisfy the criteria for installations with low emissions (as defined by Section 16 of MRG 2007)?

Installations with annual fossil CO2 emissions less than 25 ktonnes per year are defined as installations with low emissions as per Section 16 of MRG 2007. If
you have ticked this box you will not need to complete sections 4.2b, 4.3 and 4.4 of this form.

Yes

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ETS 2.2 Phase II Monitoring Plan

A2 About the installation

MRG 2007 (Section 4.3) requires that monitoring plans include a description of "the installation" and activities to be carried out and monitored. An installation is
defined in the ETS Regulations as a stationary technical unit where one or more Schedule 1 activities are carried out and any other directly associated activities
carried out on the same site. Any permits issued will relate to the whole installation but it should be noted that monitoring and reporting requirements only relate
to emissions from Schedule 1 activities. The MRG 2007 definition of activities is restricted to listed (i.e. Schedule 1) activities. The information you provide in this
template should relate to the Schedule 1 activity(ies) comprised in the installation in question, and should relate to a single installation.

Only the installation, activities and emission points identified within the ETS permit should be included below. You should only include the activities that you
operate and you should not include any Directly Associated Activities (DAAs).

A2.1 Please provide the following technical details for all Schedule 1 activities

Schedule 1 Emission Emission point description Emission sources & unique reference identifier Source streams (fuels/materials) and unique
activity no. point ref (please use S1, S2, etc) reference identifier

1.1 A1 Main stack Heaters B1-B3 (S1-S3) Natural Gas (F1)


Gas oil (F2)

1.1 A2 Flare HP Flare (S4) Process Gas (F3)

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A2.2 Please provide details for any non-scheduled activities where fuel consumed by these activities is accounted for by
meters that also supply scheduled activities
Emission Emission point description Emission sources & unique reference identifier Source streams (fuels/materials) and unique
point ref (please use S1, S2, etc) reference identifier
A3 Vent relief Oil storage tank (S5) Natural Gas (F1)

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ETS 2.2 Phase II Monitoring Plan

A3 Monitoring
Emissions may be determined using either a calculation based methodology ("calculation") or measurement based methodology ("measurement"). [MRG 2007
Section 4.2]. Please note that methodologies need to include due account of transferred CO2 (as defined in MRG 2007 Section 5.7). Please identify below the
methodologies you propose to use.

N.B. The operator may, subject to BERR approval, combine measurement and calculation for different sources. The operator is required to ensure and
demonstrate that neither gaps nor double counting of reportable emissions occurs.

A3.1 Please tick the methodologies that you propose to apply

✘ Calculation
Measurement
A3.2 Please provide a concise description of the calculation approach used to determine your annual CO2 emissions in the
text box below:
The site comprises a mixture of scheduled and non-scheduled activities fed by a single natural gas supply meter (GM01). Reportable emissions are determined by
subtracting the gas consumed by non-scheduled activities (sub-meter GM02) from GM01. Meters GM01 and GM02 are read on a monthly basis and are are
converted to m³ at standard temperature and pressure (0ºC, 101.325 kPa). Data from the Gas Chromatograph are used to derive monthly average Net Calorific
Values (TJ/m³) and Emission Factors (tCO2/MJ), and are also corrected to standard temperature and pressure. The Tier 2 country-specific Oxidation Factor is
applied for gaseous fuels. The CO2 emission (tCO2) is calculated on a monthly basis as the product of Activity x NCV x EF x OF. The monthly tCO2 values are
then summed for the reporting year.
The uncertainty associated with the metering of natural gas is calculated by the root sum squares method for the uncertainties of the individual meters GM01 and
GM02. The uncertainties are weighted according to the proportion of flow through each meter.

Diesel consumption is calculated by reference to invoiced quantities. As consumption is very low, a "no tier" approach has been adopted. This assumes that any
diesel puchased in a reporting year is all combusted during that period. Data for NCV and EF are taken from the latest National Inventory data as submitted to the
UNFCCC.

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ETS 2.2 Phase II Monitoring Plan

A4 Calculation
A4.1 Please describe the specification and location of the metering devices to be used for each source stream identified in
A2.1 - MRG 2007 Section 4.3(f)
Provide a description of all metering devices, including sub-meters and meters used to deduct non-schedule 1 activities, to be used for each source and source
stream.
Please list any references to uncertainty analysis calculations and/or schematics in section B2. If sending such documents by post, please include reference to
the permit number, operator name and installation name.

Emission Source Type of metering Unique reference to the Individual meter Overall metering Location
source ref. stream device device uncertainty uncertainty
ref. (+/-%) (+/- %)

S1-S3 F1 Turbine meter GM 01 1.58% 1.53% Adjacent to main boiler house.


S1-S3 F3 Estimated from n/a 10.00% 10.00% Purchasing Dept.
purchase records

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A4.2 Are you intending to apply a Fall-Back Approach (MRG 2007 Section 5.3)?

Please tick this box if you are intending to apply a fall back approach. If you tick this box, the tiers to be applied in A4.2a should be entered as "n/a".
Yes All other parts of Table A4.2a must still be completed.

A4.2a Please identify the tiers applied for each emission source (MRG 2007 Section 4.3(e) and Annexes II to XI)

The highest tiers should be used by Category B and C installations to determine variables for all sources unless the Operator can demonstrate to the
satisfaction of BERR that this is not technically feasible or would lead to unreasonable cost, where upon a next lower tier may be applied. The justification for
not applying the highest tier should be made in Table A4.2b.

During the period 2008 to 2012 the tiers set out in Table 1 of MRG 2007 apply as a minimum to all installations, except those with low emissions, unless the
Table
Table11 Operator can demonstrate that this is not technically feasible. This justification should be made in Table A4.2b.

With approval from BERR, the operator may apply lower tiers or a "no tier" estimation method for the variables used to calculate emissions from minor and de
minimis sources. "Major", "Minor" and "De minimis" sources are all defined in MRG 2007 Section 2(4).

* Note: installations with low emissions (i.e. <25 kt fossil CO 2 per year) may choose to apply the minimum activity tier 1, without further proof of the actual
uncertainty. In such cases, a tier 1* should be selected from the drop down list.

Emission Source Tiers to be applied Estimated annual % of total fossil Source Highest
source ref. stream (corresponding to MRG 2007 Annexes II to XI as applicable) fossil CO2 emission CO2 emission category tiers
ref. from source stream applied?
Activity data Net Emission Composition Oxidation Conversion tCO2
CV factor data factor factor

S1-S3 F1 3 3 3 n/a 2 n/a 95,000 95.0% Major No


S1-S3 F2 2 3 3 n/a 2 n/a 4,500 4.5% Minor n/a
S1-S3 F3 No tier 2a 2a n/a 2 n/a 500 0.5% De minimis n/a

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ETS 2.2 Phase II Monitoring Plan

A4.2b Please provide your justification(s) for all the selected tiers for each source and fuel/material stream (MRG 2007 section
5.2)
Emission Source Parameter Justification for the applied tier
Source ref. stream
ref.

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A4.3 Please describe the approaches to be used for sampling batches of fuels and materials - MRG 2007 Section 4.3(h)

For each source identified above, succinctly describe the approach to be used for sampling of fuels and materials for the determination of net calorific value,
carbon content, emission factors and biomass content for each fuel or material batch. (if applicable to the selected tier)

Emission Source Parameter Description Standard Frequency


source ref. stream
ref.

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ETS 2.2 Phase II Monitoring Plan

A4.4 Please describe the reference sources or analytical approaches to be applied to each source stream - MRG 2007 Section
4.3(i)
For each source stream identified in A4.3 for sampling, succinctly describe the intended sources of information for the emission factor, analytical services or
analytical approaches, for the determination of net calorific values, carbon content, biomass fraction, etc.

Emission Source Parameter Description Standard ISO17025 Frequency


source ref. stream
ref.

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ETS 2.2 Phase II Monitoring Plan

A6 Management

A6.1 Please identify the responsibilities for monitoring and reporting within the installation (MRG 2007 Section 10.3)

Please identify the relevant job titles/posts and provide a succinct summary of their role relevant to monitoring and reporting. Only those with overall responsibility
and other key roles should be listed below (I.e. do not include delegated responsibilities)

These could be outlined in a tree diagram or organisational chart referred to below and referenced in section B2.

Job Title/Post Role Summary of any other information


Environment Manager Co-ordination of monitoring data collection and reporting of calculated emission.

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A6.2 Please tell us about your arrangements for monitoring and reporting greenhouse gas emissions including a description
of the quality assurance and control procedures for data handling (MRG 2007 Section 10.3)
Please refer to specific management and control procedures and documents where relevant. For example, specific quality or environmental management
procedures (MRG 2007 Section 10.2)

Item Procedure Title and Reference Is this procedure part of a certified Environmental
Management System?

Management of competences for the EU ETS Monitoring & Reporting Procedure (ETS-002-1) Yes
responsibilities assigned

The sequence and interaction of data


acquisition and handling activities,
including methods of calculations and
measurements

Risk assessment of the definition and


evaluations of the control system

Management of competences for the


responsibilities assigned

Quality assurance of measuring


equipment and information
technology used

Internal reviews of reported data

Outsourced processes

Corrections and corrective action

Records and documentation

Other 1:

Other 2:

Other 3:

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ETS 2.2 Phase II Monitoring Plan

A6.3 Quality management systems

Does your organisation have a documented quality management system? Yes No

If "yes" is this externally certified? Yes No

If yes, describe to which standard this is certified? (e.g. ISO9001)

A6.4 Environmental management systems

Does your organisation have a documented environmental management system? Yes No

If "yes" is this externally certified or verified? Yes No

If yes, describe to which standard this is certified or verified? (e.g. EMAS, ISO 14001)

A7 Reporting and record keeping


The reporting requirements and mandatory reporting format provided in Sections 14 of the MRG 2007 shall be used.

The Operator shall retain all information, required to support the completion of this monitoring and reporting plan and the annual emissions report for at least ten
years after submission of the relevant emissions report (as listed in Section 9 of MRG 2007).

A8 List of used definitions and abbreviations


Please list any abbreviations, acronyms or definitions that you have used in completing this monitoring plan.
Abbreviation Definition

B1 Data protection notice


The Data Protection Act 1998 requires that the Department for Business Enterprise and Regulatory Reform advise its customers how data relating to individuals
will be processed and disclosed.

The information you give will be used by the Department in the exercise of its functions including to review the adequacy of your monitoring plan and to check
compliance with permit conditions.

We may also use and/or disclose any of the information you give us in order to:
- offer / provide you with our literature/services relating to environmental matters
- consult with the public, public bodies and other organisations (for example DEFRA for environmental issues, Health and Safety Executive, local authorities,
emergency services, Food Standards Agency)
- provide information on the environment in accordance with legal responsibilities;
- carry out statistical analysis, research and development on environmental issues
- investigate possible breaches of environmental law and take any resulting action
- prevent breaches of environmental law
- assess customer service satisfaction and improve our service

We may pass on the information to our agents/representatives to do these things on our behalf.
Individuals have a right to see the information we hold about them. We will correct it if it is inaccurate. You should ensure that any person named in this
application (including supporting information) is informed of the content of this Data protection notice.

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ETS 2.2 Phase II Monitoring Plan

B2 Additional information
If you are providing any other information that you wish us to take into account in considering your plan, tell us here. Please provide this information in an
electronic format wherever possible. You can provide information as Microsoft Word, Excel, and Adobe Acrobat formats.

You are advised to avoid supplying non-relevant information as it can slow down the approval. Additional documentation provided should be clearly referenced,
and the file name / reference number provided below.

Please provide file name(s) (if in an electronic format) or document reference number(s) (if hard copy) below:

File name or reference Document description

Evidence of uncertainty analysis supporting details provided in Table A4.1

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B3 What next?
Now please return this form by email or post, together with all supporting information to:
emt@berr.gsi.gov.uk
We may request any further information needed to determine your monitoring plan by notice issued under the Greenhouse Gas Emissions Trading Regulations.

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Monitoring and Reporting Principles (MRG Section 3)
To ensure the accurate and verifiable monitoring and reporting of greenhouse gas emissions under Directive 2003/87/EC, monitoring
and reporting shall be based on the following principles:
Completeness. Monitoring and reporting for an installation shall cover all process and combustion emissions from all emission
sources and source streams belonging to activities listed in Annex I to Directive 2003/87/EC and of all greenhouse gases specified in
relation to those activities while avoiding double-counting.
Consistency. Monitored and reported emissions shall be comparable over time, using the same monitoring methodologies and data
sets. Monitoring methodologies can be changed in accordance with the provisions of these Guidelines if the accuracy of the reported
data is improved. Changes in monitoring methodologies shall be subject to approval from the competent authority and shall be fully
documented in accordance with these guidelines.

Transparency. Monitoring data, including assumptions, references, activity data, emission factors, oxidation factors and conversion
factors shall be obtained, recorded, compiled, analysed and documented in a manner that enables the reproduction of the
determination of emissions by the verifier and the competent authority.
Trueness. It shall be ensured that the emission determination is systematically neither over nor under true emissions. Sources of
uncertainties shall be identified and reduced as far as practicable. Due diligence shall be exercised to ensure that the calculation and
measurement of emissions exhibit highest achievable accuracy. The operator shall enable reasonable assurance of the integrity of
reported emissions to be determined. Emissions shall be determined using the appropriate monitoring methodologies set out in these
Guidelines. All metering or other testing equipment used to report monitoring data shall be appropriately applied, maintained and
calibrated, and checked. Spreadsheets and other tools used to store and manipulate monitoring data shall be free from error.
Reported emissions and related disclosures shall be free from material misstatement, avoid bias in the selection and presentation of
information, and provide a credible and balanced account of an installation's emissions.

Cost effectiveness. In selecting a monitoring methodology, the improvements from greater accuracy shall be balanced against the
additional costs. Hence, monitoring and reporting of emissions shall aim for the highest achievable accuracy, unless this is technically
not feasible or will lead to unreasonably high costs. The monitoring methodology itself shall describe the instructions to the operator in
a logical and simple manner, avoiding duplication of effort and taking into account the existing systems in place at the installation.

Faithfulness. A verified emissions report shall be capable of being depended upon by users to represent faithfully that which it either
purports to represent or could reasonably be expected to represent.
Improvement of performance in monitoring and reporting emissions. The process of verifying the emission reports shall be an
effective and reliable tool in its support of quality assurance and quality control procedures, providing information upon which an
operator can act to improve its performance in monitoring and reporting emissions.

ETS2 FINAL template v2.11


ETS 2 Guidance

GUIDANCE ON THE COMPLETION OF ETS2.2 MONITORING PLAN TEMPLATE

Introduction
The Department for Business Enterprise and Regulatory Reform (BERR) is committed to the assessment and approval of monitoring plans as
efficiently as possible. The Department has provided the following guidance to help applicants complete the monitoring plan template ETS2.2.
Please note that the Department may have to return any templates that are not fully completed and/or do not contain all the relevant information. If
you are unsure on any aspect of the template you can contact the Department by e-mail on:

emt@berr.gsi.gov.uk
If your completed monitoring plan is returned to you, either for administrative or technical reasons, this could result in your revised plan not being
received in time to enable approval to be granted by 1st January 2008.
This guidance should be read in conjunction with the following documents:
- The Commission's Monitoring and Reporting Guidelines (MRG 2007) for Phase II
- The Competent Authorities’ Guide to the Guidelines
- The Competent Authorities' Note on Uncertainty Assessment
- The exemplar monitoring plan

Note that all relevant sections in the monitoring plan template must be completed. Relevant sections will become apparent as you read through this
guidance. Macros within this spreadsheet are used to hide parts of the form that are not relevant to you, based on your responses to questions.

In order to minimize the time and costs associated with the processing of plans and the issue of their approval, the Regulator has developed
electronic systems to handle all aspects of the process. These systems will only be effective if plans (including any additional information noted in
section B2) are submitted electronically.
You are therefore requested to submit the monitoring plan (including any additional documents) electronically, if at all possible, and to avoid the
submission of non-electronic documents. (The inclusion of non-electronic location maps will not significantly affect the efficiency of the determination
process.)
Please do not submit both electronic and paper versions of your monitoring plan as this creates additional administrative work; a single electronic
monitoring plan is all that is required.
The template should be downloaded from BERR's web page and saved on the hard drive of the applicant’s computer. The monitoring plan should
then be completed by entering data directly into the saved version of the template.
Completed spreadsheets should NOT be copied and pasted into separate workbooks as this prevents the import of data. The template only allows for
details of a single installation, or a part of a single installation, (where the Operator is only responsible for part of an installation). Please do NOT
submit a monitoring plan covering more than one installation.

Commercial-in-Confidence Information / National Security


The Regulations do not provide for public registers in respect of permits or monitoring plans (which form part of the permit) and therefore do not need
to provide for exclusion of permitting information from public registers either on the grounds of commercial confidentiality or national security. The
data protection notice in section B1 of the template form explains the purposes for which the Department may use information provided by you in the
form.

Completion of monitoring Template ETS2.2


Please note that in using this guidance you will also need to refer to a copy of the European Commission's Monitoring and Reporting Guidelines,
which can be found on the Commission’s website.

Please note that macros are used in this spreadsheet to aid completion, e.g. the ability to add further rows to any of the tables. It is strongly
recommended that macros are enabled for the completion of this form. If your IT systems prevent the use of macros, you will still be able to enter
data into the form, but you may receive warning messages about macros being disabled if you click on the macro buttons. This is completely normal.

Section A1 About your monitoring plan


The purpose of this section is to link your monitoring plan with your permit (or permit application), National Allocation Plan (NAP) allocation and for you
to identify a contact to discuss any queries that may arise in assessing your plan. You are also asked to provide an estimate of your likely CO 2
emissions in the forthcoming year.

Section A1.1
You are asked to provide your Greenhouse Gas Emissions Trading Scheme (ETS) permit reference number and associated NAP numbers to enable
the Department to link the monitoring plan to the relevant permit. If you do not have a permit or NAP number, please leave both boxes blank.

Please enter just the numerical part of your permit reference. For example if your permit has the reference DTI0001, enter just 0001 into the box.
The spreadsheet automatically formats this cell to display the permit reference number with the prefix "GB-ETS-". A warning box will display if you
attempt to enter letters or symbols into either the permit ID or NAP ID boxes.

Section A1.2
You are asked to identify the Operator’s name. This should be identical to that stated within the ETS permit, (or the permit application form, if the
permit has yet to be issued).

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ETS 2 Guidance

Section A1.3
You are asked to confirm the installation name and the location. These must be identical to those given in the ETS permit, (or if a permit has yet to be
issued, as you have stated in the permit application form).
Section A1.4
You are asked to identify a person, and their contact details, who we can contact directly should we have any questions about your monitoring plan. If
the contact person is an employee of the installation subject to this plan then leave the Organisation box blank. If the contact person is an agent (e.g.
consultant) acting on your behalf then the name of the organization should also be specified.

Section A1.5
You are asked to provide an estimate of your annual fossil CO 2 emissions expressed as kilo tonnes (kt) of carbon dioxide.
Your estimate should be based on verified annual emissions data or the best available data, and should also take into account any planned changes.

Fossil CO2 includes CO2 from all fuels and process emissions with the exception of biomass fuels. Fossil CO 2 should include the contaminants in any
pure-biomass fuel, (i.e. that component of the pure-biomass fuel <3% of the total).
The purpose of the estimate is to enable the Department to check the relevance of the tiers you are planning to apply, including the context of minor
and no tier considerations. Note: a “Tier” means a specific methodology for determining activity data, emission factors, NCV, composition and
oxidation or conversion factors, as applicable.

Section A1.6
If you have estimated your annual emissions to be less than 25 kt (25000 tonnes), then certain exemptions are provided for by Section 16 of MRG
2007. Accordingly, the amount of information you are expected to provide in your monitoring plan is reduced. Specifically, there is no requirement for
you to complete sections A4.2b, A4.3 or A4.4 of this form. If you have macros enabled, these tables will be hidden from view. Otherwise, please
leave these tables blank.

Section A2 About the installation


The purpose of this section is to succinctly describe your installation in terms of linking your activities and emission sources (points and processes) to
source streams (fuels and materials).

Section A2.1
The purpose of this section is to list each Schedule 1 activity with a corresponding emission point, an emission source and the fuels and/or materials
giving rise to CO2 emissions from that activity.
MRG 2007 defines an emissions source as "a separately identifiable part (point or process) of an installation from which relevant greenhouse gases
are emitted."
This table should only include those activities and emission points as identified in Table 2 of the ETS permit and should not for instance include any
Directly Associated Activities (DAAs).
The following are also important in relation to completion of the table in section A2.1:
- The Schedule 1 activity numbers, emission point references and descriptions (columns one, two and three of Table 2.1) should be as stated
within the ETS permit or, if a permit has yet to be issued, in the ETS permit application (Table A4.2 of the permit application form).
- You are asked to list all process emission sources associated with a particular emission point. (More than one process emission source may be
associated with a single emission point.) A succinct description of the emission source e.g. Boiler 1, Kiln 2, Furnace 3, etc. should be provided
together with a unique reference. Please note that as the unique reference number will be used in all subsequent sections of the template, it is
recommended that you use simple references, for example, S1, S2, S3... Sxx.
- For each process emission source you are asked to list each fuel and/or material associated with that source together with a unique identifier.
For fuels or materials that feed into more than one source these should be listed separately against each source, retaining the same reference
numbers. Please note that as the unique identifiers are used in subsequent sections of the template, it is recommended that you use simple
references such as F1, F2, F3, etc. for fuels and M1, M2, M3, etc. for materials.
Please avoid using long or complicated references as this can make the permit less transparent.

Section A2.2
The purpose of this section is to list any non-Schedule 1 activities, where fuel consumed by such activities is measured by meter(s) that also supply
Schedule 1 activities.
For example, if a main supply meter provides fuel to a 20 MW boiler (Schedule 1 activity) and also to direct fired space heaters (non-Schedule 1
activity) on the same installation, only the CO 2 emissions arising from the boiler are reportable. In this example, if a sub-meter is fitted to the boiler,
then it is relatively straightforward to account for the non-Schedule 1 activities, by subtracting the sub-meter from the main supply meter consumption.
Where sub-metering is not available, it will still be necessary to take account of the non-reportable fuel use, whilst observing the principle to avoid
under-reporting of emissions.

Please do not list any non-Schedule 1 activities that are independently metered or where these are not affected by meter(s) feeding Schedule 1
activities.
Section A3 Monitoring
The purpose of this section is for you to indicate your proposed methodology for monitoring your carbon dioxide emissions i.e. a calculation method
and/or a direct measurement method using continuous emission monitors.
Section A3.1
MRG 2007 provides for both calculation and measurement based approaches, or a combination of the two approaches. Accordingly, you are asked to
identify, by clicking on the tick boxes provided, which methodologies you propose to use to monitor your CO 2 emissions.
If you have macros enabled, only the relevant sections of the form will display depending on your answers to this question. (For example, if you have
ticked the calculation approach, Section A3.2 and Section 5 of the form will be hidden.) If macros are disabled or you are completing the form
manually, please ignore those sections of the form that are not relevant to your installation.

Please note that an Operator may measure carbon dioxide emissions only if they can demonstrate to the Department that:
- The measurement method reliably results in a more accurate value of annual emissions than an alternative calculation based methodology, while
avoiding unreasonable costs; and

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ETS 2 Guidance

- The comparison between measurement and calculation is based on an identical list of sources and emissions. (MRG 2007 Section 4.2)

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ETS 2 Guidance

Section A3.2
You are asked to provide a generic description of the methodology used to calculate your annual CO 2 emissions. This is required to increase the
transparency of the calculation approach for Regulators and Verifiers and will form part of your permit. Accordingly this description should be concise
to avoid the need for frequent variations, but include sufficient detail to explain how data from your measurement devices, together with fuel/material
quality information is used to calculate your annual CO2 emissions.
For example, you should include in your description (as relevant):
- how consumption of fuel/material in non-schedule 1 activities is accounted for;
- how meter data is corrected to standard temperature and pressure conditions (consistent with other factors used in the calculations);
- whether fuel/material quality data is determined on a site specific basis, or whether the National Inventory data is used;
- any assumptions/estimates for "no tier" activity data methods;

Section A3.3
Not relevant to offshore

Section A4 Calculation
The purpose of this section is for you to describe your approach to calculating your carbon dioxide emissions in terms of the metering devices to be
used (Section A4.1), the tiers to be applied (Section A4.2a), justification for the applied tiers (Section A4.2b) and the approaches to be used for
sampling (Section A4.3) and analysis (Section A4.4) of batches of fuels or materials.

Do not complete this section if you only propose to use a measurement approach for determining your carbon dioxide emissions. Proceed instead to
Section A5.

Section A4.1
You are asked to list the metering device type, metering uncertainty, overall uncertainty and the location of metering devices to be used for each
emission source and each source stream.
The following are important in completing Table 4.1:
- The emission source ref. (e.g. S1) and the source stream ref. (e.g. F1, M1) should be consistent with those designated in Table A2.1. MRG 2007
refers to an emission source as "a separately identifiable part (point or process) of an installation from which relevant greenhouse gases are emitted."

For example, a refinery may meter fuel from a single header tank that feeds into a number (e.g. five) of separate processes. It may be both technically
difficult and expensive to install, and to regularly maintain and calibrate five different flow meters. Accordingly, in this example it should be sufficient to
recognize the header tank as a single “source stream” for these five processes.
Conversely, if a single fuel or material stream is metered and then split into different processes which have different oxidation or conversion factors, it
will be necessary to specify additional metering to ensure that the appropriate fractions of the fuel or material streams can be multiplied by the
appropriate oxidation, emission, conversion factors etc.
- The type of metering device should be selected from the drop down list of meter types, or where the device is not listed can be manually entered into
the relevant cell. Please provide a concise description of the metering device, suitable to characterise the type of device.
- The unique meter reference should enable the Regulator and Verifier to trace the actual metering device through to the collection and processing of
data used in calculating your annual CO2 emissions. Typically, a meter serial number would be a suitable unique reference, but generic references
e.g. Meter Point Reference (MPR) numbers or other suitable references could be used, as long as the permit requirements to notify any changes are
observed.

- The uncertainty of the individual metering device, taking into account any additional uncertainties from context specific factors and
pressure/temperature corrections should be specified in column 5 of the table. Uncertainties should also be specified for those sub-meters feeding
non-schedule 1 activities, as relevant, as this may impact on the overall uncertainty of a metering system. (Please note that evidence of the
uncertainty assessment should be included as Section B2 information.)

- The uncertainty of the overall metering system should be specified in column 6 of the table. For example, if a sub-meter recording consumption from
a non-schedule 1 activity is subtracted from a meter feeding schedule 1 activities, then this will affect the uncertainty of the overall metering system.
In the example where a series of meters are used to determine consumption for a particular source stream, the overall uncertainty will be based on an
assessment of the individual meter uncertainties. (Refer to Section 7 of MRG 2007 and to the Competent Authorities note on Uncertainty
Assessment.) Where this is the case, the overall uncertainty should be copied into each relevant row alongside the corresponding individual meter
uncertainty.
Please note that evidence of the overall metering system uncertainty assessment should be included as Section B2 information.

- The location of the metering device or system i.e. where it can be physically found should be succinctly described here. This may include, a
reference to “supplier’s weighbridge”, or a reference to a specific item on an attached schematic or plan, as well as to process and instrumentation
diagrams that may be inspected on-site.
Where applicable, the Operator should identify all metering devices normally used and those alternatives used on a stand-by or contingency basis.

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ETS 2 Guidance

Section A4.2
The fall back approach is reserved for installations for which it is not technically feasible or would lead to unreasonable costs to apply at least a tier 1
requirement for all (except de minimis) source streams.
If applying the fallback approach you will be required to demonstrate that the overall uncertainty of all variables and parameters used for calculating
the annual CO2 emissions meet the thresholds listed in Table 2 of the MRG 2007 and summarised below:
Category A +/- 7.5%
Category B +/- 5.0%
Category C +/- 2.5%
Evidence of the uncertainty should be submitted as further information and referenced in section B2.
On ticking "Yes" in response to this question you will be advised to enter n/a against each of the the tiers in table A4.2a. However, all other parts of
table A4.2a, e.g. source stream references, CO2 contribution/% of total, major/minor/de minimis should still be completed.

Section A4.2a
Note: In completing this table you will need to refer to the appropriate activity specific annex (annexes II to XI) and Table 1 of MRG 2007, which
identifies the minimum tier requirements. A copy of Table 1 is provided within this spreadsheet itself and can be viewed by clicking on the button
labelled "Table 1".
You are asked to identify, against each emission source and each source stream, the tiers to be applied for Activity Data, Emission Factor, Net
Calorific Value (NCV), Oxidation Factor, Composition, and/or Conversion Factors as appropriate to the methodologies described in Annexes II to XI.

MRG 2007 outlines specific methodologies corresponding to these tiers in Annexes II to XI. In general terms, as the tier value increases, the
associated uncertainty decreases. Section 5.2 “Tiers of approaches” of MRG 2007 provides detailed guidance concerning the application of different
tiers. In particular:
- For Category B (between 50 and 500 kt fossil CO 2) and Category C (>500 kt fossil CO2) installations, operators shall use the highest tier approach
to determine all variables for all source streams. If it is shown to the satisfaction of the competent authority that it is technically not feasible or will
lead to unreasonably high costs, a next lower tier may be used for that variable. (Please note that the Competent Authority is required to notify the
Commission any Category C installation that is not applying the highest tier approach for all major sources.)

- For all installations with annual fossil CO2 emissions > 25 kt, the tiers set out in Table 1 of MRG 2007 shall be applied as a minimum for all major
source streams, unless this is technically not feasible.
The Operator should also take note of the further derogations provided for in section 5.2:
- Minor source streams: With the approval of the Competent Authority, an Operator may apply a minimum tier of 1 for variables used to calculate
emissions from minor source streams.
- De minimis allowance: For those source streams jointly emitting 1 ktonne or less per year or that contribute less than 2% of total annual fossil CO 2
emissions of that installation (up to a total maximum of 20 ktonnes per year), whichever is the highest in terms of absolute emissions, the operator
may apply a “no tier” approach for monitoring and reporting using their own estimation method, subject to the approval of the Competent Authority

- Pure biomass source streams: For pure biomass fuels a "no tier" approach may be applied unless the calculated value is to be used for the
subtraction of biomass carbon from carbon dioxide emissions derived by means of continuous emission measurement (note reference to “pure”
defined in Section 2(4) of the MRG 2007).
- Installations with low emissions: for those installations with annual fossil CO 2 emissions less than 25kt, it is possible to specify an activity tier of 1,
regardless of the actual metering uncertainty and without the need to supply evidence of the associated uncertainty. (See also Section 16 of MRG
2007.) If this is the case tier 1* should be selected from the drop down list, rather than tier 1.

Note on tiers for Net Calorific Values and Emission Factors


For all fuels and materials for which emission factors are provided within the UK Greenhouse Gas (GHG) Emissions Inventory/National Atmospheric
Emissions Inventory (http://www.naei.org.uk) then Tier 2a must be applied as a minimum for both Net Calorific Value and Emission Factor tiers.
Where an Operator intends to apply these factors, reference to the extant UK GHG inventory should be cited in Section 4.4 of the template for the
appropriate fuel/material. The GHG inventory is reviewed annually.

Section A4.2b
This section should be completed with the following information:
- An explanation of how the metering uncertainties indicated in Table A4.1 correspond to the activity tier listed in A4.2a. This explanation may be
presented in terms of a detailed uncertainty assessment, which should be referenced as Section B2 information.
- A justification of why the highest tiers cannot be met on the basis of either unreasonable cost or technical feasibility for those installations which
emit in excess of 50kt fossil CO2 per annum (i.e. Category B and C installations).
- A justification for how you intend to comply with at least the minimum tier requirements as listed in Table 1 of MRG 2007, for those sites that emit
less than 50 kt fossil CO2 per annum.
- A succinct justification for the application of a lower tier or no-tier methodology, where you cannot or do not intend to meet at least the Table 1 tier
requirements of MRG 2007.
Please refer to any additional sheets if necessary and reference these in B2.
Please note that sites with annual fossil CO 2 emissions <25 kt are not required to complete section A4.2b. If macros are enabled and you have
selected "Yes" in response to question A1.6, this section of the form will be hidden.

Section A4.3
For each emission source and each source stream you are asked to provide a succinct description of your proposed approach to the sampling, for the
determination of net calorific value, carbon content, oxidation factor and biomass content, etc.
You are asked to provide a concise description of the sampling approach together with relevant standards used and also the sampling frequency.
Standards could relate to CEN, ISO or BS standards but may also include in-house procedures.

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ETS 2 Guidance

In particular it should be noted that:


The procedures applied to sample the fuel and to determine its net calorific value, carbon content and emission factor shall be based on relevant
CEN standards (such as on the sample frequency, sampling procedures, determination of gross and net calorific value, and carbon contents for
the different fuels and materials) as soon as they are available. If CEN standards are not available, ISO standards or national standards shall
apply. Where no applicable standards exist, procedures can be carried out where possible in accordance with draft standards or recognised
industry best practice guidelines.

To achieve appropriate accuracy of the activity-specific emission factor (in addition to the precision of the analytical procedure for the
determination of the carbon content and the net calorific value) the sampling frequency, the sampling procedure and the sample preparation are
critical. They depend greatly on the state and homogeneity of the fuel/material. The required number of samples will be larger for very
heterogeneous materials such as municipal solid waste and be much smaller for most commercial gaseous or liquid fuels. The determination of
the carbon content, net calorific values and emission factors for batches of fuel shall follow generally accepted practice for representative
sampling. The operator shall provide evidence that the derived carbon content, calorific values and emission factors, etc. are representative and
free of bias, in accordance with Section 13.6 of MRG 2007.)

Please note that details of standards and method statements should not be attached to your monitoring and reporting plan. A reference within this
section that can be traced to these documents (e.g. during a verification audit) is adequate.

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ETS 2 Guidance

Section A4.4
For each emission source and each source stream you are asked to provide a succinct description of your intended sources of information, analytical
services or analytical approaches for the determination of net calorific value, carbon content, oxidation factor, biomass fraction, etc.

You are asked to provide a concise description of the analytical approach together with any relevant standards that apply, whether the analysis is
undertaken by an ISO17025 accredited/non-accredited laboratory and the frequency of the analysis undertaken.
Operators should seek to demonstrate compliance with the standards hierarchy and ISO 17025 requirements of section 13 of the MRG 2007.
Non-accredited laboratories can only be used in situations in which the operator can demonstrate to the Competent Authority that the laboratory
meets the equivalent requirements as outlined in Section 13.5.2 of MRG 2007. Details of the non-accredited laboratories and evidence that the
laboratory is technically competent should be supplied as Section B2 information.
The use of online gas chromatographs and extractive or non-extractive gas analysers is subject Competent Authority approval. The operator must
operate a management system conforming to the requirements of ISO 9001. In addition, the gas chromatograph should be subject to an initial and
annual performance evaluation to ISO 10723 by an ISO17025 accredited organisation.
Where no site specific analysis is undertaken, the operator should state: "Data to be taken from the latest UK national inventory as submitted to the
United Nations Framework Convention on Climate Change" from the drop list in this cell.
The frequency of analysis shall be in accordance with Section 13.6 of the MRG 2007, namely:
- the annual average of the relevant parameter is determined with a maximum uncertainty of 1/3 of the maximum uncertainty for the corresponding
activity tier. For example, if the activity tier is 4 (i.e. uncertainty <1.5%), then the maximum uncertainty associated with the analysis frequency
would be 0.5%.
- if the above uncertainty cannot be met, then the indicative frequency of analysis specified in Table 5 of the MRG 2007 should be applied. For
example, natural gas - at least weekly, process gas (refinery) - at least daily, liquid waste - every 5,000 tonnes or 4 times per year, etc.

- in all other cases the frequency must be defined by the Competent Authority.
Please do not provide detailed descriptions of test methods or append these to your monitoring and reporting plan.
Section A5 Measurement of CO2 emissions
The purpose of this section is for you to justify the use of continuous monitoring equipment for direct measurement of carbon dioxide and to describe
the system to be used. Please note: you are asked to complete this section only if you are proposing to undertake direct measurement of carbon
dioxide emissions using continuous emission monitoring equipment. If this is your intended approach, it is important that you note the following

An Operator may measure carbon dioxide emissions, using continuous emission monitoring equipment, but only if they can demonstrate to the
Competent Authority that:
- The measurement method reliably results in a more accurate value of annual emissions than an alternative calculation based methodology, while
avoiding unreasonable costs; and
- The comparison between measurement and calculation is based on an identical list of emission sources and source streams.
(Monitoring and Reporting Guidelines Section 6)
Section A5.1
You are asked to provide your justification for measuring carbon dioxide emissions for each emission point e.g. each duct, chimney stack etc. Your
justification should be concise but also confirm compliance with the notes in bullet points above as well as meet other requirements stated in Section
6 of the MRG 2007. Your detailed assessment to demonstrate that your measurement method meets the highest tiers, based on identical sources etc.
should be provided in an attachment to your monitoring and reporting plan and referenced in Section B2.

Section A5.2
For each emission point (column 1) you are asked to provide a brief description of the measurement system to be employed (column 2). In Column 3
you are asked to provide a more detailed description that should include the:
- points of measurement (i.e. where the sample point(s) is/are located);
- frequency of measurement (i.e. how often is measurement data logged);
- description of the equipment used (i.e. identify the components of the system and how they are linked)
- calibration procedures (i.e. to what standard or reference method is the equipment calibrated, by whom and how often);
- data collection and storage procedure (i.e. how is data collected and handled and how is it retained)
Do not include a detailed description of your procedures (e.g. procedures for calibration) in this table, simply provide an identifying reference in Table
A5.2.
Section A5.3
You are asked to specify the tier to be applied, (as outlined in Annex XII of MRG 2007), corresponding to the uncertainty of the measurement based
approach. Where the highest tier approach is not applied for those installations with annual fossil CO2 emissions greater than 50 kt, you are required
to justify this on the basis of either unreasonable cost of technical feasibility.

Section A6 Management
The purpose of this section is for you to describe your management arrangements for ensuring implementation of your monitoring plan. This includes
identification of responsibilities (Section A6.1), associated procedures (Section A6.2) and the management systems you have in place (Section A6.3
and Section A6.4).

Section A6.1
You are asked to identify the key job titles/posts within your organisation with a formal responsibility for monitoring and reporting and provide a
succinct description of their role in relation to implementing the monitoring and reporting plan. These must include:
- Responsibility for monitoring and reporting greenhouse gas emissions; and
- Responsibility for maintenance and calibration of relevant metering or measurement devices.
You may use the additional rows to describe other posts that you feel are relevant. You should only include those functions or posts with a direct role
in implementing the monitoring and reporting plan. Please use job titles or functional posts (e.g. “Head of Environment”) where possible and do not
refer to names of individuals. A third column is provided for any other information or explanation that you may wish to provide.

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ETS 2 Guidance

Section 6.2
The purpose of this section is to identify your arrangements for ensuring that monitoring and reporting is undertaken in accordance with your plan.
When completed, Table A6.2 should direct either the Department or a verifier to the appropriate specific element of your management system
covering each of the mandatory management issues or items listed.
You are asked to identify against each item that you list in Table 6.2 your related arrangements concerning monitoring of greenhouse gas emissions.
The items listed in the table A6.2 of the template are mandatory quality assurance and control procedures stated as required (amongst other things) in
Section 10.3.1 of MRG 2007. You should include just the title and reference number of the document, together with an indication as to whether this
part of a certified environmental management system.

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ETS 2 Guidance

Section 6.3
You are asked to identify, by clicking on the tick boxes provided, whether or not your organisation has a documented quality management system and,
if so, whether it is certified to a specific standard. If you have a certified quality management system please identify to which standard it is certified in
the box provided.

Section 6.4
You are asked to identify, by clicking on the tick boxes provided, whether or not your organisation has a documented environmental management
system and, if so, whether it is certified or verified to a specific standard, e.g. EMAS, ISO 14001. If you have a certified or verified environmental
management system please identify to which standard to which it is certified or verified in the box provided.

Section A7 Reporting and record keeping


This purpose of this section is to remind you of the mandatory requirements for reporting and record keeping.
Section A8 List of definitions and abbreviations
You are asked to provide a list of any abbreviations or acronyms that you have used in completing your monitoring plan.
Section B1 Data protection notice
Please see notes on Commercial-in-Confidence Information / National Security in page two of this guidance
Section B2 Additional information
You are asked to identify and reference additional documentation that is submitted as part of your plan. Please do not attach copies of procedures
(e.g. management system manuals, calibration procedures etc.) that are referred to within your plan.

20
Return to form Activity Data Emission factor Composition Data Oxidation factor Conversion factor
Fuel Flow Net calorific value
Annex Activity A B C A B C A B C A B C A B C A B C
II: Combustion
II: CombustCommercial standard fuels 2 3 4 2a/2b 2a/2b 2a/2b 2a/2b 2a/2b 2a/2b n/a n/a n/a 1 1 1 n/a n/a n/a
II: CombustOther gaseous and liquid fuels 2 3 4 2a/2b 2a/2b 3 2a/2b 2a/2b 3 n/a n/a n/a 1 1 1 n/a n/a n/a
II: CombustSolid fuels 1 2 3 2a/2b 3 3 2a/2b 3 3 n/a n/a n/a 1 1 1
Mass balance approach for carbon black
1 2 3 n/a n/a n/a n/a n/a n/a 1 2 2 n/a n/a n/a 1 2 3
II: Combustproduction and gas processing terminals
II: CombustFlares 1 2 3 n/a n/a n/a 1 2a/2b 3 n/a n/a n/a 1 1 1 n/a n/a n/a
II: CombustScrubbing - Carbonate 1 1 1 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a n/a n/a n/a
II: Combust Gypsum 1 1 1 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a n/a n/a n/a
III: Refineries
III: Refiner Catalytic Cracker Regeneration 1 1 1 n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a
III: Refiner Hydrogen Production 1 2 2 n/a n/a n/a 1 2 2 n/a n/a n/a n/a n/a n/a n/a n/a n/a
IV: Coke Ovens
IV: Coke O Mass balance 1 2 3 n/a n/a n/a n/a n/a n/a 2 3 3 n/a n/a n/a n/a n/a n/a
IV: Coke O Fuel as process input 1 2 3 2 2 3 2 3 3 n/a n/a n/a n/a n/a n/a n/a n/a n/a
V: MO Roasting & Sintering
V: MO RoasMass balance 1 2 3 n/a n/a n/a n/a n/a n/a 2 3 3 n/a n/a n/a n/a n/a n/a
V: MO RoasCarbonate input 1 1 2 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a 1 1 1
VI: Iron & Steel
VI: Iron & Mass balance 1 2 3 n/a n/a n/a n/a n/a n/a 2 3 3 n/a n/a n/a n/a n/a n/a
VI: Iron & Fuel as process input 1 2 3 2 2 3 2 3 3 n/a n/a n/a n/a n/a n/a n/a n/a n/a
VII: Cement
VII: CemenKiln input based 1 2 3 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a 1 1 2
VII: CemenClinker output 1 1 2 n/a n/a n/a 1 2 3 n/a n/a n/a n/a n/a n/a 1 1 2
VII: CemenCKD 1 1 2 n/a n/a n/a 1 2 2 n/a n/a n/a n/a n/a n/a n/a n/a n/a
VII: CemenNon-carbonate carbon 1 1 2 n/a n/a n/a 1 1 2 n/a n/a n/a n/a n/a n/a 1 1 2
VIII: Lime
VIII: Lime Carbonates 1 2 3 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a 1 1 2
VIII: Lime Alkali earth oxide 1 1 2 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a 1 1 2
IX: Glass
IX: Glass Carbonates 1 1 2 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a n/a n/a n/a
X: Ceramic
X: CeramicCarbon inputs 1 1 2 n/a n/a n/a 1 2 3 n/a n/a n/a n/a n/a n/a 1 1 2
X: CeramicAlkali oxide 1 1 2 n/a n/a n/a 1 2 3 n/a n/a n/a n/a n/a n/a 1 1 2
X: CeramicScrubbing 1 1 1 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a n/a n/a n/a
XI: Pulp & paper
XI: Pulp & Standard method 1 1 1 n/a n/a n/a 1 1 1 n/a n/a n/a n/a n/a n/a n/a n/a n/a