presentation of the ceef2014-018-md project and its ets...
TRANSCRIPT
Presentation of the CEEF2014-018-MD project and its ETS component.
Recommendations for the government of Moldova Dr István Bart
Chisinau, 22 July 2015
Overview:
• The project
• The speaker
• The Association Agreement and its relevant sections
• Links with the Industrial Emissions Directive
• ETS provisions to be approximated
• Perspectives and recommendations for Moldova
• The Roadmap
Project for approximating climate
acquis
• „Clima East Expert Facility for Expert input under the Expert Facility Services CEEF2014-018-MD”: Approximation of the national legislation to the EU Directives listed in Annex XII (Chapter 17, Climate Actions) of the Association Agreement”
– Part 1: Emissions Trading Directive
– Part 2: Fuel Quality Directive
• Objective: To prepare MD administration to implement legislative and institutional changes for MRV of GHG emissions under the EU ETS
• Outputs: i) report, ii) roadmap for implementation • Acquis /a’ki:/: the body of EU legislation that already exists and is to be adopted
by new MS
About the speaker
• István Bart is from Hungary
• Implemented ETS in Hungary’s Ministry of Economy between
2003-2005
• Worked at the EU Commission (ENV and CLIMA) on ETS
between 2005 and 2010
– ETS implementation
– Registries
– Accession countries (RO, BG, HR)
• Since 2011 consultant on ETS policy for various governments
The Association Agreement
• Signed 27 June 2014 – entry into force: Sept 2014
• Climate Section requires that parts of ETS are approximated
– Indentifying installations
– Setting up MRV systems
– Setting up enforcement systems
– Setting up public consultation systems
The Association Agreement
(contd.)
• The AA Does NOT require the implementation of the full
ETS (only preparation for the time of full EU Membership)
– ETS would not work for MD only (too small, not diverse
enough)
– Linking MD to ETS in principle would be possible, but
requires a lot of intergovernmental work
– MD ETS sector is only about 0,25% of the total EU ETS
cap (incl. Transnistria)
The Association Agreement
(contd.) • The (Environment section) AA also requires the implementation of
the EU Integrated Prevention Pollution and Control system
(Industrial Emissions Directive)
• ETS installation coverage and IED installation coverage overlaps
• ETS permits may be merged with IED permits
Timelines
in the AA:
The Association Agreement
(contd.)
• AA requires the designation of many other competent authorities for various climate action and environmental legislative instruments. – F-gases, – ozone depleting substances, – fuel quality – environment impact assessment, – access to environmental information, – air quality
• The implementation process should be harmonised, wherever possible
EU ETS (a recap)
• Half of all installations covered in EU, since 2005
• Concept:
– Government cannot know what the best emission limit for a single polluter is
– Govt sets limit for all polluters jointly
– Polluters decide who will be able to emit through trading with pollution permits
– Each polluter can buy rights to emit (allowances) , invest in more efficient opeartions or reduce production, depending on what makes more business sense
– This way, reducing emissions can become a godd business choice
• Initial allocation of emission rights can be free or in auction – it does not matter for ETS to work
• Key requirements:
– Scarcity (less permits than demand)
– Lot of diverse industries involved (lot of reduction opportunities)
– Reliable MRV (a ton is a ton)
– Regulatory certainty (lobbying should not be te key compliance strategy)
– Trading infrastructure (registries and trading exchanges)
Scope of the ETS: activities and
gases CO2 • Combustion installations above 20 MW • Oil refineries • Ferrous metals production above 2,5t/hr • Cement production • Glass production above 20 t/d • Ceramics production above 75 t/day • Pulp and paper production above 20 t/d • Aircraft operators
N2O
• Aluminium • Chemicals
IPPC (IED)
• Industrial Pollution Prevention and Control Directive in 1996
• 2010: renamed Industrial Emisssions Directive (IED)
• Requires industrial installations emitting into air and water to obtain permits for their polluting activities
• To be introduced in MD by 2020
• In the EU, ETS and IED were set up at different times, and in many countries they are under different regimes – but this is inefficient and also not necessary
Comparing ETS to IED • Activity coverage is different
• Pollutant coverage: ETS has only GHGs, IED has a road range of pollutants: SOx, NOx, CO, VOCs, chlorine, biocides, etc.
• Scope of permit: ETS permit contains no emission limit, while under IED, there is an emission limit
ETS elements to approximate
• A system for indentifying installations
• Legislative action: transpose Annex of ETS Directive
• Administrative action: Find installations (both for ETS and IED)
– Collect potential installations from statistical sources (BNS, ANREE permits, water permits)
– Send out questionnaire about activities carried out
– Narrow down the list to installations within scope of ETS and IED
ETS elements to approximate
(contd.) • A system for MRV, enforcement and public
consultation
• Legislative action:
– transpose relevant parts of ETS Directive (jointly with IED) - with reference to the EU implementing legislation in force (MR and VR)
– Set up penalty system (in line with current MD system for penalties)
– Set up verification and accreditation system
– Create competent authority for permitting (best to use one that does both IED and ETS, and all other permits)
ETS elements to approximate
(contd.)
• Question: Why does the AA require the approximation of Art 19 and 21?
– Art 19 is about registries – it cannot be implemented without being part of the ETS
– Art 21 is about reporting on ETS implementation by Member States (on the basis of a questionnaire sent by EU) – again not something for non-Member States
• Suggest to ask DG CLIMA about this in writing
• In the meantime, assume that this is about making sure that MRV data is available to the public (also a requirement under the Aarhus Convention)
Approximation process
• Suggestion: draft a new single statute on ETS (limited to MRV for the time being)
• Possibly jointly with IED
• Not bother with adopting Monitoring Regulation and Verification Regulation – because it will change again and again. Enough to refer to them (they are directly applicable in EU MS, so MS do not transpose them either)
Roadmap
Perspectives for Moldova in ETS
• What is the use of the MRV system without participating in the EU ETS?
• MS is too small for domestic ETS (too high fixed costs, not enough diversity in reduction opportunities)
• Linking with EU ETS is possible in principle, but requires Parliament and Council and therefore unlikely to be pursued by the EU (although one could always ask)
• Option: a reliable MRV system can be used to create reduction credits for sale on the international carbon markets (provided that there are such options after Paris)
Recommendations
• Create a harmonised timeline, legislative, adminstrative
and institutional framework for the implementation of
climate and environment acquis
• Think about the process as a way to prepare for
international crediting mechanisms
• Aviation: wait until the fog clears
• Ask DG CLIMA about Articles 19 and 21
EU ETS Structure
Verifiers
Verification
Operators
Allocation
Permits
Reporting, surrender allowances
Inspections, sanctions
European Union
Legislation
Legislation
EU Member State
Competent Authority
Source: NEA (NL)
Thank you
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