Ministry of Environment Greenhouse Gas Verification
a- Monitoring, reporting and verification of EU ETS emissions
Monitoring and reporting of greenhouse gas emissions must be robust, transparent, consistent and accurate for the EU emissions trading system (EU ETS) to work effectively.
Industrial facilities covered by the EU ETS are required to have an approved monitoring plan to monitor and report annual emissions. This plan is also part of the required operating permit for industrial facilities.
The annual monitoring, reporting and verification procedure (MRV), with all associated processes, is known as the ETS compliance cycle. The rules for the compliance cycle are set out in two regulations:
- Monitoring and Reporting Regulation (MRR)
- Accreditation and Verification Regulation (AVR)
Facilities within the scope of the Monitoring and Reporting Communiqué are obliged to submit their annual verified emission report to the Ministry of Environment and Urbanization by 30 April.
b- Monitoring Plan Preparation Process
The preparation of a transparent and verifiable monitoring method for an enterprise whose activities are specified within the scope of Annex-1 of the Regulation on the Monitoring of Greenhouse Gas Emissions is called Monitoring Plan.
After the Monitoring Plan is approved by the Ministry, it will be valid until the next decision of the Ministry. Improvements in monitoring plans may be requested if deemed necessary by the verifier or entity that has approved the Emissions Reports. In this case, the changes made in the monitoring plans must be re-approved by the Ministry.
The Monitoring Plan proposes a method for monitoring emissions and reporting the monitored emissions accurately under the Emissions Report. This monitoring method should be one that can be applied technically and financially at the facility. It is extremely important that the Monitoring Plan is correct and complete, as the wrong construction of the Monitoring Plan and forgetting some emission sources will result in a complete miscalculation of the emission amount.
The facility should first check whether it carries out the activities within the scope of ANNEX-1 of the Regulation. For this, all activities taking place in the facility are determined without any elimination. Afterwards, these activities are divided into two main titles: the burning of fuels and other activities listed in Annex-1 of the Regulation.
- If there is no other activity in the facility other than the burning of fuels, the burning units are listed. Then, hazardous and domestic waste incineration units, units using biomass, and units with a rated thermal power below 3 megawatts (MW) are removed from these units (the unit that uses only biomass is defined as the unit that uses fossil fuel only at the start and end. Finally, the rated thermal power of the remaining units is summed up. If the total rated thermal power of these units exceeds 20 megawatts (MW), the units using only biomass and units with a rated thermal power below 3 megawatts (MW) are included in the Monitoring Plan. If the total rated thermal power does not exceed 20 megawatts (MW) thermal, the facility is not included in the ANNEX-1 of the Regulation, so the establishment does not need to prepare a Monitoring Plan.
- If other activities are taking place in the facility other than burning fuels, it is checked whether these activities exceed the threshold specified in ANNEX-1 of the Regulation. If the activity or activities exceed the specified threshold value, it is decided that this facility falls within the scope of the Regulation after these activities are defined. In addition, the activities related to the burning of fuels carried out within the facility are also included in the Monitoring Plan. However, if this activity or activities do not exceed the threshold value specified in Annex-1 of the Regulation, it is determined that the facility is not within the scope of these activities. Then, the activities of burning the fuels in the facility are taken into consideration. In this case, the procedure for burning the fuels described above is followed.
Definition of Activity: Activity is the actions listed in Annex-1 of the Regulation and is what causes greenhouse gas emissions. Businesses should define their activities within the scope of Annex-1 of the Regulation in the Monitoring Plan. Therefore, they must accurately indicate the activities within the scope and the capacities of these activities (annual production amounts for each activity) in the Monitoring Plan.
Emission Source: The emission source is the unit where the process or combustion that takes place in the facility and causes emissions takes place. In other words, the emission source refers to the units that cause emissions in the facility. It is important to specify the emission sources completely, to calculate the emissions and to fill the Monitoring Plan in full.
Emission Point: The emission point is the exit point where the greenhouse gas emissions from each emission source are released into the atmosphere (eg chimney, etc.). After the emission sources are determined, it is necessary to determine the emission points where the emissions are released to the environment. Determination of emission points is very important as it facilitates the monitoring of emissions.
Annual Estimated Total Emission: “Annual emission” means the sum of greenhouse gas emissions caused by the facility in the previous calendar year and resulting from the activities specified in Annex-1 of the Regulation. The facility should base its annual emissions on a prudent calculation according to the capacity report, excluding CO2 emissions from biomass and including transferred CO2.
Facility Category: Facility category is a classification that helps determine the level of detail or the effort required for monitoring to be undertaken. The category of the facility is decided according to the Annual Estimated Emission amount determined in the Monitoring Plan.
- Category A (DE): Confirmed annual emissions equal to or less than 25,000 tons of CO2 (eq) in the reporting period, excluding CO2 originating from biomass, including transferred CO2,
- Category A: Confirmed annual emissions equal to or less than 50,000 tons of CO2 (eq) in the reporting period, excluding CO2 originating from biomass, including transferred CO2,
- Category B: Confirmed annual emission of more than 50,000 tons of CO2 (eq) and equal to or less than 500,000 tons of CO2 (eq) in the reporting period, excluding CO2 originating from biomass, including transferred CO2,
- Category C: Confirmed annual emissions of more than 500,000 tons of CO2(eq) in the reporting period, excluding CO2 originating from biomass, including transferred CO2.
c- Verifying Body Selection
Businesses have to sign verification contracts every year until 15 November of the year of the greenhouse gas emission report to be verified. Since verifiers can only provide verification services to businesses that carry out activities within the scope of accreditation, this issue should be considered when choosing a verifier.
Verification Contracts must comply with the minimum wages and deadlines determined by the Ministry of Environment.
d- Strategic Analysis
At the beginning of the verification, the verifier conducts a strategic analysis of all relevant activities of the facility to determine the nature, scale and complexity of the activities to be carried out during the verification process.
The verifier collects and reviews the information and documents necessary to understand the activities carried out by the facility, evaluate the competence of the verification team, evaluate the appropriateness of the verification period specified in the contract, and conduct the risk analysis.
It is not obligatory for the verification body, which has verified with the facility in the last 2 (two) years, to conduct a strategic analysis site visit.
Strategic analysis should be done in the field and should not be less than the minimum periods determined by the Ministry of Environment and Urbanization.
e- Process Analysis
During the verification process, the verifier shall verify the boundaries of the facility and the resource flows in order to evaluate the operation of the measuring devices and monitoring systems, to conduct interviews, to carry out the activities required by this Communiqué, to collect sufficient data, information and documents to enable it to conclude that the greenhouse gas emission report does not contain material misstatements and conducts one or more site visits to assess the completeness of emission sources.
It is obligatory to have personnel with technical competence in the relevant activities in the verification team that will make site visits.
In order to verify the GHG emission report, the verifier carries out additional visits, if necessary, regarding the relevant data flow activities and control activities carried out at other locations such as company headquarters and other off-site offices, based on the risk analysis.
Process Analysis consisting of site visit and office work should not be less than the periods determined by the Ministry of Environment and Urbanization.
f- Submission of the Verified Report to the Ministry of Environment
The GHG emission report can only be verified with reasonable confidence if it does not contain material misstatements. After the site visit and office work are completed, the verification opinion is prepared by the verifier via the online software portal of the Ministry of Environment and Urbanization and submitted to the facility with an electronic signature. The process is completed by submitting the report approved by the facility authority to the Ministry of Environment and Urbanization through the portal.