3.1.2 Integration of EU ETS monitoring and reporting guidelines

The Monitoring and Reporting Guidelines (MRG) under the EU ETS Directive (Commission Decision 2007/589/EC and its amendment Commission Decision 2010/345/EU) provide monitoring and reporting guidelines (MRG) for greenhouse gas emissions from the capture, transport and geological storage of CO2 (Implementation of Directive 2009/31/EC, 2011). The MRG specify how emissions of the CO2 storage activity have to be accounted for and reported for purposes of the EU ETS (MRG Annexes I and XVIII). The following emission sources at a storage site have to be monitored under the EU ETS:

  • Combustion emissions at the injection site;
  • Fugitive emissions and emissions from venting at the injection site;
  • Emissions from vents and flaring at enhanced hydrocarbon recovery;
  • Leakage from the storage reservoir into the water column or atmosphere.

The MRG places emphasis on the verification, accounting and reporting of any emissions, including quantification of greenhouse gas emissions. Some monitoring methods used for monitoring under the EU CCS Directive may be suitable for quantification of any emissions resulting from leakage. Furthermore, quantification of any leakage will be useful in assessing the significance of the leakage risk as required under the CCS Directive. Monitoring activities and plans need to meet the requirements of the EU CCS Directive, but should be extended to meet the requirements of the MRG under the EU ETS. It will be more efficient for both the operator and the competent authority of a storage site to set up and manage monitoring on an integrated basis, covering both CCS and EU ETS issues.

Emissions sources at the injection site and from enhanced hydrocarbon recovery can be monitored using existing approaches from the MRG. Combustion emissions at injection can be monitored with approaches from Annex II (stationary combustion), vented emissions at injection and at enhanced hydrocarbon recovery with approaches from Annex XII (continuous emission measurement) and fugitive emissions at injection by industry best practice. For the MRG formats for monitoring plans already exist at Member State level. This includes industry best practice approaches.