The monitoring plan pursuant to the EU ETS rules must be supplemented by written procedures which the operator or aircraft operator establishes, documents, implements and maintains for activities under the monitoring plan, as appropriate.
The M&R Guidance document No. 1, Version of 16 July 2012 (available here) contains the following list of elements which are by default expected by the M&R Regulation to be put into written procedures:
1. Managing responsibilities and competency of personnel;
2. Data flow and control procedures;
3. Quality assurance measures;
4. Estimation method for substitution data where data gaps have been found;
5. Regular review of the monitoring plan for its appropriateness (including uncertainty assessment where relevant);
6. A sampling plan, if applicable, and a procedure for revising the sampling plan, if relevant;
7. Procedures for methods of analyses, if applicable;
8. Procedure for demonstrating evidence for equivalence to EN ISO/IEC 17025 accreditation of laboratories, if relevant;
9. Procedure for uncertainty assessment in case of fall-back methodologies applied;
10. Procedures for use of measurement based methodologies, including for corroborating calculations and for subtracting biomass emissions, if relevant;
11. Only if the Member State requires this: A procedure for ensuring that the requirements of Article 24(1) of the Commission Decision of 27 April 2011 determining transitional Union-wide rules for harmonised free allocation of emission allowances are met.
It is noteworthy that the operator should have the specific written procedure for regular assessment of whether the monitoring plan is up-to-date.
Procedures should be established, documented, implemented and maintained separately from the monitoring plan, however, they must be summarised in the monitoring plan providing the following information:
1. The title of the procedure;
2. Traceable and verifiable reference for identification of the procedure;
3. Identification of the post or department responsible for implementing the procedure and for the data generated from or managed by the procedure;
4. Brief description of the procedure allowing the operator or aircraft operator, the competent authority and the verifier to understand the essential parameters and operations performed;
5. The location of relevant records and information;
6. The name of the computerised system used, where applicable;
7. List of EN standards or other standards applied, where relevant.
It is noteworthy that the written procedures referenced by the monitoring plan need to be developed, but do not need to be attached to the monitoring plan when submitting it to the competent authority.
In effect, the procedures are mentioned and described briefly in the monitoring plan but are not considered part thereof.
The M&R Guidance document No. 1, Version of 16 July 2012 stresses that the operator has the full responsibility for the procedure. This gives him the flexibility to make amendments to the procedure whenever needed, without requiring update of the monitoring plan, as long as the procedure’s content stays within the limitations of its description laid down in the monitoring plan.
The said approach appears to be the strategic issue when designing the monitoring plan and the required procedures as well as when deciding on the allocation of the relevant content and its details.
The full text of the procedures must be made available to the competent authority only upon request as well as to the verifier for the purposes of verification.
Further remarks and guidance on specific procedures regarding emissions monitoring under EU ETS rules are available under the following links: