Why do you need Procedures?
Under the EU ETS, recording what you do is as important as what you actually do.
The reason for this is that there are financial implications for the data you collect, both for yourselves and for third party investors, so it is important that all operators can demonstrate to the verifiers that they are following the approved methodologies.
Many operators have submitted their Monitoring Plans, and think that is all they have to do on the compliance side and just focus on the data, but the Monitoring Plans are just signposts to the procedures that need to be in place.
For example, if you look at your Monitoring Plan (or this sample), each section is laid out as follows:
Title for Procedure
AE - Monitoring Methodology
Reference for Procedure
ETS – 001
Brief Description of Procedure
This procedure outlines the assessment process for the determination of fuel monitoring methodology to be used…
The text in the ‘Brief Description of Procedure’ part is not a procedure, it is just a rough outline of what the actual procedure will do. So the procedure needs to be set out in a separate document called ‘AE – Monitoring Methodology’ with the reference, ‘ETS-001’. In practice, they don’t need to be very detailed, but they should have sufficient information on how to actually carry out the relevant process.
What needs to be in these Procedures?
Section 10.3 of the Monitoring and Reporting Guidelines sets out what needs to go into the procedures. From this, the layout of the Monitoring Plans was created, and it requests procedures for each of these functions:
- Monitoring Methodology
- Asset List*
- Flight Recording
- Annex I Flight Recording
- Handling, calculations and measurements procedures for EU ETS
- Risk assessment and Control Systems for EU ETS
- Personnel Review Procedure
- QA of Systems under EU ETS
- Quarterly Review of EU ETS Data
- Supplier Systems and Data for EU ETS
- Corrective actions systems for EU ETS
- Recording Systems for EU ETS
*The template wording issued by the competent authorities uses the term 'Asset List',
and implies it already existed before the ETS, however experience has taught me that operators rarely have them. The term ‘Fleet List’ is also more suitable in my opinion as it includes leased
You are also required to retain sufficient information to recreate a verification up to 10 years later, so you need to keep hold of previous versions of the procedures for this length of time so a verifier doing this can see what processes were being followed at the time. For this reason, your procedures should include document control. Responsibilities should also be clearly defined throughout and anyone involved in ETS data collection should have ready access to them.
Most small emitters are single aircraft operators who have a small pool of crew and simple processes, and their procedures can be relatively simple reflect this. Large emitters, however, have more people involved in the data gathering process and written procedures can aid in ensuring consistency in how different people carry out the same task. Raising awareness of the scheme is also a problem within larger organisations, with many people not realising the role they play in the EU ETS compliance. Issuing written procedures to these people can help them to see how they fit into it.
Are there any benefits?
While this is mostly a box ticking exercise, it is not completely pointless. I have seen more than one case where individuals responsible for an operator's ETS compliance has left the organisation, and the person taking over doesn’t have a clue what they need to do. Having written procedures in place allow for better continuity when there are changes to key staff.
Also, while some aspects of the scheme are ongoing throughout the year, others are not, and only happen once a year. Having a process written down which you can refer to can make it easier to remember what you need to do (note, that in time for the next compliance cycle, this site will include checklists which will also help with this).
Another benefit is that it actually increases flexibility. Anything put in your Monitoring Plan becomes a legal requirement, even if the MRG or Directive do not require it. Because of this, it is best to keep your Monitoring Plan as vague as possible. Making changes to the Monitoring Plan can be slow, and in some member states, they actually charge operators to make changes. Your procedures are, however completely internal documents. You can change them as much as you like, so if you wish to change how you comply with the scheme, these changes don’t need to be approved by the Competent Authority.
Can I buy Procedures?
This page does contain sufficient information to create your own procedures, but if you wish to save the time and effort, ETS Checklist can provide you with procedures for a reasonable fee. As with everything on this site, the procedures will be written by an aviation professional, who set up and ran a verification body during the first two difficult years of the scheme. This means that the procedures can be written both to reflect the expectations of the verifiers and regulators, but also remain practical to how aircraft operate in the real world.
Procedures for small emitters can be provided relatively quickly, following a few simple questions about how you operate. Discounts can be offered to management companies/consultants who look after several operators.
Large emitter procedures need to be more tailored to the individual way you collect your data. They can be prepared remotely, but a face to face meeting or site visit can also be arranged to create more personalised procedures. Other services, such as consultancy and training of staff can also be provided.
If you would like more information about this, or any other service, please Contact Us