This session at the 2025 Energy from Waste conference focused on how the monitoring, reporting and verification process will work when energy from waste is included in the UK’s emissions trading scheme (ETS).

Session chair, Chris Jonas from Tolvik, stressed the “extreme importance of getting this right” in the complicated landscape of waste constantly moving around – making it different to other participants of the ETS. He highlighted the potential negative ramifications if the MRV process goes wrong, including, but not limited to compliance failures and leakage to landfill.

Jonas introduced the context for the UK, in which MRV is the process required to measure emissions, embodied within the Greenhouse Gas Permit which will have a monitoring plan attached to it.  

Guidance on composing the monitoring plan

Helen Wood, MRV Lead at the Environment Agency, laid out the core principles to bear in mind when composing the monitoring plan. These are:

• Accuracy
• Transparency
• Consistency
• Completeness

Wood advised that the monitoring plan is almost a ‘how-to guide’ on how to report your emissions, in which nothing should be left out. The Environment Agency will be releasing guidance on how to comply (or participate) depending on whether we go into a voluntary or mandatory period for permits in 2026.

Wood gave her assurance that EfW operators “will have these guidelines in time”.

Stewart Davies, FrMetS MCIWM Principal Consultant, Waste & Resources, WRc, followed Wood to shed light on the challenges from an operator-perspective, and what they will need from this guidance.

Davies highlighted the importance of stability and transparency (reiterating one of Wood’s guiding principles) throughout the whole supply chain, and not just EfW.

On the timeline issue, he flagged concerns around having to make potentially necessary infrastructure changes in the given timescale before the monitoring plan deadline.

Davies also mentioned the challenge around measurement uncertainty, recognising that for most participants in the EfW sector, they will be in the middle tier of emissions (50-500 thousand tonnes of CO2). This would equate to 7.5% measurement uncertainty, which Davies felt was not sufficiently specific to the energy from waste sector.

So what lessons can we learn from Europe who have already begun the process?

Fabio Poretti, Technical and Scientific Officer at CEWEP, shed light on some of the complexities at an EU level with 27 member states. Poretti explained that the majority of operators in Europe are using the measurement-based approach (stack measurement). However, the EU ETS Monitoring and Reporting Regulation (MMR) still allow for the calculation-based approach, for which CEWEP strongly advocates in order to leave some flexibility for the operators, especially during this transition period.

Poretti reiterated Davies’ concerns around the uncertainty measurements, stating CEWEP felt these were “copy and pasted from combustion of fuels”. He highlighted that the UK should take these challenges into consideration from the outset to avoid making the same mistakes as the EU.

The industry response

Charlotte Rule, Head of Climate and Energy Policy at the Environmental Services Association, closed the session by sharing the current views from industry, in particular around the debate Poretti raised: what is the best approach for monitoring?

Rule shared that industry believe the bottom-up approach (using emission factors) is the best way to deliver decarbonisation in the waste sector.

She added: “It is important that the method we report on emissions is the same as that which we re-allocate carbon back to the waste produced in the first place”, which is why industry believe using carbon and emissions factors best to link the two parts of the chain.

The Environmental Services Association has compiled six suggestive emissions factors relating to local authority derived waste, which will be calibrated with C14 data on a yearly basis, to form a mixed approach.