Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55

DHL Group is the worlds leading logistic company. The Group employs ca. 600,000 people in over 220 countries and territories worldwide and generated revenues of more than 94 billion Euros in 2022. With our mission to achieve net-zero emissions by 2050, we strive for clean operations for climate protection.

UNIDEN (Union of Energy Utilising Industries) LUNIDEN welcomed proposals on the draft update of Regulation 2018/2066 on the monitoring and reporting of emissions from the system. Mr LUNIDEN would like the proposals to be taken into account by the Commission.

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easyJet is Europes leading airline offering a unique and winning combination of the best route network connecting Europe's primary airports, with great value fares and friendly service. easyJet flies on more of Europes most popular routes than any other airline and carried more than 81 million passengers in 2022. The airline has over 300 aircraft on nearly 1000 routes to more than 150 airports across 35 countries.

Euroheat & Power welcomes the opportunity to contribute to the proposed draft implementing act concerning the revision of greenhouse gas emissions monitoring and reporting within the revised EU Emissions Trading System (EU ETS) framework, referred to as the MRR revision. EHP regards the recent EU ETS revision as significant progress towards industrial sector decarbonisation.

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) is an independent environmental and consumer protection organisation that promotes waste prevention and sensible use of valuable resources in the field of circular economy.

FEAD, the European Waste Management Association, welcomes that the proposal maintains full flexibility for Waste-to-Energy (WtE) operators to either apply a calculation-based or a measurement-based methodology. Nevertheless, FEAD notes a number of points in relation to the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas…

The European Federation of Energy Traders (EFET) appreciates the opportunity to submit our comments to the proposal of the EU Commission revising the MRR Regulation pursuant to the revision of the EU ETS Directive.

SOLVAY welcomes the possibility to provide feedback on the draft amending Regulation 2018/2066. The regulation under revision represents an opportunity > to remove a competition distortion situation amongst bicarbonate producers and > to avoid double counting and reporting of the same quantity of CO2 bound into sodium bicarbonate. 1.

Itad opinion: MRR ITAD welcomes the flexibility of a calculation or measurement-based methodology for municipal waste incineration plants (Wte). Suggestions 1. Applicability The specific requirements of Wte for greenhouse gas (GHG) determination are not properly taken into account. The plant design and operation of Wte are not comparable to power stations or cement plants.

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HUMENS -NOVACARB feedback on EU emission trading system (ETS) Uupdate of the rules for monitoring and reporting emissions. HUMENS - NOVACARB welcomes the possibility to provide feedback on the draft amending Regulation 2018/2066. The regulation under revision represents an opportunity · to avoid double counting and reporting of the same quantity of CO2 bound into sodium bicarbonate.

Liquid Gas Europe welcomes the opportunity to provide feedback on the EU emissions trading system (ETS) update of the rules for monitoring and reporting emissions. This overall ambition is fully supported by Liquid Gas Europe, the European LPG association, representing national LPG associations, European LPG distributors, and equipment manufacturers, as one of the means of achieving the EU net zero emissions target…

en2x welcomes the possibility of feedback on the draft Implementing Regulation supplementing Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions. Our comments can be found in the attached document.

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Proposal for a new formulation of Amendment 34 (a) (ii): [] where a source stream is waste, the relevant type of waste codes." Reasoning: The use of Codes that provide more information about the composition should be possible. Regarding incineration, the AT national code also expresses the quality assurance that has been carried out.

The European Panel Federation (EPF) welcomes the opportunity to provide feedback on the Draft Implementing Regulation amending Implementing Regulation (EU) 2018/2066 as regards updating the monitoring and reporting of greenhouse gas emissions.

Airlines for Europe (A4E) welcomes the opportunity to provide its feedback on the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to the revision of the ETS Directive.

Following the Fit for 55 package and the revision of the ETS Directive, several regulatory acts must be revised, Bellona Europa welcomes to opportunity to provide feedback to the Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council and amending Commission Regulation (EU) No…

The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We would like to provide the following feedback for the European Commission on EU emissions trading system (ETS) update of the rules for monitoring and reporting emissions.

LOT Polish Airlines response to the proposed revision on EU ETS MRV regulation. In Article 54, paragraph 2, we believe that SAF volume should be used to reduce emissions from the flight for which it was tanked. This provision also lacks the information on how the evidence that the biofuel is attributed to the flight immediately following the uplift of the flight shall look like.

The International Air Transport Association (IATA) is the trade association for the worlds airlines, representing some 300 carriers based in 120 countries. IATA appreciates the opportunity to provide feedback on the update of the rules for monitoring and reporting emissions of the EU emissions trading system. Please find attached IATA`s response to the consultation on updating EU ETS MRV rules.

The European Union (EU) has taken a leadership role in establishing a roadmap to achieve climate neutrality by 2050. Carbon Capture and Storage (CCS) is one of the technologies that will be needed to reach this objective. To get CCS projects off the ground, the EU legislative framework should be consistent in supporting these technologies.

SNAM welcomes the opportunity to provide feedback on the draft act to update the rules for monitoring and reporting emissions: Recognition of the benefits of hydrogen in the emission trading system: -The combustion of hydrogen does not release carbon dioxide.

Albioma is an independent renewable energy company with most of its operations in the French overseas territories, including Reunion Island, Mayotte, Guadeloupe, Martinique, French Guiana, and Mauritius. Our power plants currently provide up to 50% of the electricity needs of the territories in which they operate.

CEMBUREAU welcomes the proposed revision of the rules for monitoring and reporting emissions (MRR) for the EU ETS. The European cement industry has laid out its decarbonisation ambition in its 2050 Carbon Neutrality Roadmap published in May 2020. A significant lever for the emissions reductions in the cement industry in the EU27 will come from the use of materials with biogenic sources.

ESWET the European Suppliers of Waste to Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy (waste incineration with energy recovery, in short: WtE) plants in operation in Europe. It seeks to promote the technology which, within the frame of the Waste Hierarchy, recovers energy from waste that would otherwise end up in landfills.

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the Proposal of COMMISSION IMPLEMENTING REGULATION (EU) amending Implementing Regulation (EU) 2018/2066 as regards updating the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council. Please find detailed comments in the Attachment.

Aither is a Swiss-based carbon credit trading and investment company that works in the EU-ETS and voluntary market. To be more competitive in the global market, we suggest that the EU considers other methods for transferred CO2 that are supported by the scientific community such as Buffered Ocean Alkalinity Enhancement, Ocean alkalinity enhancement, Enhancement weathering of limestone, etc.

The German Chemical Industry Association (VCI) welcomes an early adoption of clear monitoring and reporting rules for the emissions trading system for buildings, road transport and additional sectors (Chapter IVa / ETS II) to facilitate an orderly implementation and reducing administrative burden by ensuring the maximum possible consistency between monitoring methodologies.

The European Biogas Association welcomes the opportunity to provide feedback on the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions. Please find the full version of the reply in the attached file.

The Enel Group welcomes the revision of the EU ETS and its implementing provisions as a further step in increasing the effectiveness and efficiency of the EU ETS in reducing GHG emissions and fighting climate change.

IBLU (IREN Group) attributes the opportunity to provide feedback on the draft Amending Regulation 2018/2066. The regulation under revision presents an option to promote the circular economy, recycling, and decarbonisation, by creating a Sinergy with the EU ETS system. Please, find our comments and representations in the attached file.

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The Spanish Magnesite Association (MAGES) welcomes the possibility to give its view on the Update of the rules for monitoring and reporting of greenhouse gas emissions Please refer to the attached document for MAGES comments to the articles of the draft implementing regulation. We believe the draft should be further aligned with Directive 2018/2001/EC and with implementing regulation 2022/996.

The Spanish cement association (OFICEMEN) welcomes the possibility to give its view on the Update of the rules for monitoring and reporting of greenhouse gas emissions Please refer to the attached document for OFICEMEN comments to the articles of the draft implementing regulation. We believe the draft should be further aligned with Directive 2018/2001/EC and with implementing regulation 2022/996.

Belgian waste-to-energy (BW2E) groups all 14 Belgian plants that process both household and similar residual waste with energy recovery. In total, they convert 2.8 million tonnes of waste annually into energy and materials for today and tomorrow. BW2E is grateful to use this consultation to provide feedback on the changes made to MRR: 1.

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We are professors of chemistry at the Politecnico di Milano (Italy), currently carrying out research on ocean-based carbon dioxide removal (CDR) and the enhancement of the oceans alkalinity, to contrast climate change and the acidification of seawater due the increase of atmospheric CO2 levels.

Recommendations for amendments to the regulation 2018/2066 from Latvia are provided below. Recommended to make corrections regarding the (27) point, to ensure consistency with the existing emission trading system and alignment with existing legislation on sustainability set out in Directive (EU) 2018/2001.

We have identified one provision that is problematic for stationary installations the proposed changes to Article 18 thresholds on unreasonable costs of the Implementing Regulation (EU) 2018/2066. The raised thresholds make it harder for stationary installations to show that i) applying a specific monitoring method, or ii) improving an existing one, incurs unreasonable costs.

The Spanish Confederation of Mineral Raw Materials Industries-PRIMIGEA-is a national business association that represents the interests of businessmen dedicated to non-energy mining in Spain. PRIMIGEA was created to promote the access of the industrial, energy, construction, and public works sectors in Spain to the necessary mineral raw materials.

The Spanish Confederation of Mineral Raw Materials Industries-PRIMIGEA-is a national business association that represents the interests of businessmen dedicated to non-energy mining in Spain. PRIMIGEA was created to promote the access of the industrial, energy, construction, and public works sectors in Spain to the necessary mineral raw materials.

The Spanish Confederation of the Non-Energy Extractive Industries of Industries COMINROC - is a national business association that represents the interests of businessmen dedicated to non-energy extractive industries (Aggregates, Cement, Ceramics, Expanded Clay, Gypsum, Industrial Minerals, Mining, Natural Stones and Salt) in Spain.

Please find attached a file with comments from Utilitalia, the Federation which brings together the companies operating in the public services of water, the environment, electrical energy and gas, representing them in the national and European institutions. It associates over 450 companies providing environmental services to more than 55 % of the Italian population. The comments relate to the following topics: 1.

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In this field, we must exploit the Ocean and the natural methods of storing CO2, that are actually alread existing, e.g.the geological carbon cycle. CO2 isnaturally stored as carbonates (solid and ionic phase) in sea water. If we really wish to be competitive on markets, we have to add known methods of CO2 storage, so that we can increase the regulations on these fronts.

Repsol welcomes the opportunity to provide its feedback on the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to the revision of the ETS Directive. Please find our comments in the document enclosed.

Transport and Environment (T&E) supports the European Commissions proposed Implementing regulation amending the MRV Regulation (Implementing Regulation (EU) 2018/2066) which aims to enhance transparency in airlines annual emission reporting, particularly with regards to their Sustainable Aviation Fuels (SAF) usage.

Westenergy Ltd is a Finnish circular economy company owned by seven municipal waste management companies. We own and operate the largest single-line WtE plant in Finland producing district heating, electricity and recycled materials and aim to fully decarbonize our operations before the early 2030s.

FuelsEurope welcomes the opportunity to provide its feedback on the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to the revision of the ETS Directive. Please find our comments in the document enclosed.

Annex Xa in the proposed regulations requires Operators of Stationary Installations to submit a report containing additional information for each purchased fuel. It is understood this is to avoid double counting of emissions associated with fuel released by regulated entities such as fuel suppliers.

Zero Waste Europe, a leading organization dedicated to promoting sustainable waste management practices across the continent, hereby submits a formal response to the ongoing public consultation concerning the measurement method for Municipal Solid Waste (MSW) emissions.

CEWEP (Confederation of European Waste-to- Energy Plants) is the umbrella association of the operators and owners of Waste-to-Energy (WtE - waste incineration with energy recovery) installations in Europe, representing about 400 plants from 23 countries. We are pleased to actively participate to the consultation. Please find our response also attached.

With a view to the revision of Commission Implementing Regulation (EU) 2018/2066 of 19 December 2018 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council and amending Commission Regulation (EU) No 601/2012, Limenet S.r.l. Società Benefit would like to suggest an amendment to letter b) of article 49 - CO2 transferred.

A2A welcomes the opportunity to provide its feedback on the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions under the ETS Directive ("MRR"). Please find our comments in the document attached.

EDF welcomes this opportunity to give feedback on the draft implementing regulation of the EU ETS. We would like to draw your attention to the need for consistency between the revised Directive (EU) 2018/2001 -RED- and the Implementing Regulation 2018/2066 -MRR.

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