COMMISSION STAFF WORKING PAPER Summary of the Impact Assessment
Date: 2011-11-23
Institutions: European Commission
Subjects: air quality, climate change, environmental monitoring, exchange of information, greenhouse gas, tradeable emission permit

EUROPEAN COMMISSION 

Brussels, 23.11.2011 
SEC(2011) 1406 final 

COMMISSION STAFF WORKING PAPER 

Summary of the Impact Assessment 

Accompanying the document 

Proposal for a Regulation of the European Parliament and of the Council 

on a mechanism for monitoring and reporting greenhouse gas emissions and for 
reporting other information at national and Union level relevant to climate change 

{COM(2011) 789 final} 
{SEC(2011) 1407 final} 

EN 

   EN 

 
 
 
 
  
 
1.  Problem definition 

Because  of  concerns  with  the  growing  threat  of  global  climate  change  from  increasing 
concentration of greenhouse gases (GHG) in the atmosphere, the EU has been implementing 
and  planning  a  series  of  mitigation  policies  and  actions.  The  establishment  of  solid 
monitoring,  evaluation,  reporting,  and  verification  framework  is  an  important  component  of 
this  process  as  it  enables  the  EU  among  other  to  more  effectively  develop  and  implement 
future policies and to assess and demonstrate that it is delivering on its commitments.  
Decision  280/2004/EC1  ("Monitoring  Mechanism"  Decision-  "MMD")  concerning  a 
mechanism  for  monitoring  EU  greenhouse  gas  emissions  and  for  implementing  the  Kyoto 
Protocol and its implementing provisions (Decision 2005/166/EC)2  are the main monitoring, 
reporting, and verification instruments with regard to GHG emissions. They set out the details 
for  reporting  of  anthropogenic  GHG  emissions  by  sources  and  removals  by  sinks  and  for 
providing  information  as  regards  national  programmes  to  reduce  emissions,  greenhouse  gas 
emission  projections,  and  policies  and  measures  in  accordance  with  the  United  Nations 
Framework Convention on Climate Change (UNFCCC).  

The  six  years  of  experience  with  the  implementation  of  Decision  280/2004  and  its 
implementing  provisions  Decision  2005/166  as  well  as  the  additional  experience  gained 
through  the  international  negotiations  and  the  implementation  of  various  UNFCCC 
requirements  have  shown  that  there  are  a  number  of  areas  where  significant  improvements 
could be made. In addition, the need to enhance our mitigations actions and to fulfil our new 
or  upcoming  international  and  domestic  commitments,  including  the  Europe  2020  strategy, 
requires an enhanced monitoring and reporting system to be put in place. 

Specifically  the  problems  that  the  revision  of  the  Monitoring  Mechanism  Decision  will 
attempt to address are the following: 

(cid:131)  The  existing  monitoring  and  reporting  system  is  not  adequate  to  implement  new 

requirements resulting from new legislation.  

The  climate  change  and  energy  package  as  agreed  between  the  Council  and  the  European 
Parliament and as adopted by the European Parliament on 17 December 2008 introduced new 
requirements as regards monitoring and reporting for MS, which need to be incorporated in a 
revision of Decision 280/2004/EC to enter into effect. 

(cid:131)  There  is  not  adequate  data  available  at  the  EU  level  to  support  future  policy 

development and implementation 

In  a  number  of  areas/sectors  of  great  significance  in  reducing  GHG  emissions  and  taking 
action  at  the  EU  level,  there  is  currently  not  adequate  data  or  not  accurate  enough  data 
collected to enable and support effective policy design and implementation. Such areas are: a) 
maritime transport, b) aviation, c) Land-use, land-use change and forestry (LULUCF) and c) 
adaptation.  

(cid:131)  The current monitoring and reporting system does not take into consideration the most 
recent  international  developments  under  the  UNFCCC  and  is  not  adequate  to  ensure 
compliance with new international commitments 

1 OJ L 49, 19.2.2004, p.1 
2 Commission Decision 2005/166/EC of 10 February 2005 laying down rules implementing Decision No 280/2004/EC of the 
European Parliament and of the Council concerning a mechanism for monitoring Community greenhouse gas emissions 
and for implementing the Kyoto Protocol (OJ L 55, 1.3.2005, p. 57) 

1

 
 
                                                 
technological  support 

The  EU  committed  internationally  to  provide  significant  fast-start  and  long-term  climate 
financing  and 
to  developing  countries.  Transparency  and 
comprehensiveness  on  the  type  and  amount  of  support  provided  is  key  to  ensure  the  EU's 
visibility, efficient delivery and credibility vis-à-vis our international partners. The problems 
identified above have often led to severe criticism by other countries that the EU and its MS 
are not fulfilling their commitments and need to be resolved. 

(cid:131)  Additional  data  and  information  are  needed  to  monitor  the  progress  towards  the 

emissions limitation target, in particular under the Europe 2020 strategy. 

The Europe 2020 strategy, the new integrated economic policy strategy for growth and jobs, 
includes the European and national emissions limitation targets as headline targets. 

(cid:131)  There  is  an  observed  lack  of  transparency,  timeliness,  consistency,  completeness, 
comparability of the information currently reported under the Monitoring mechanism 
Decision 

The  relatively  high  rate  of  non-compliance  cases  over  the  last  years  indicates  that  the 
transparency,  accuracy,  consistency  and  efficiency  of  the  existing  monitoring  and  reporting 
system could be improved.  

(cid:131)  Experience has shown that an increased need for simplification and streamlining of the 

current reporting requirements is needed. 

Experience  with  the  implementation  of  the  monitoring  mechanism  decision  has  shown  that 
certain reporting requirements did not deliver as expected or the information was not used as 
anticipated. It has also shown that some linkages among various reporting instruments could 
be strengthened.  

2.  Analysis on subsidiarity 

The legal basis for the legislative proposal is Article 192(1) TFEU. The legislative proposal 
pursues a legitimate objective within the scope of Article 191(1) TFEU, namely, combating 
climate  change  (mitigation  and  adaptation).  The  purpose  of  the  legislative  proposal  is  to 
improve  the  availability  of  information  for  Union  policy  and  decision  making  and  the 
coordination and consistency of EU and Member States' reporting under the UNFCCC. This 
objective pursued cannot be achieved by less restrictive means than the legislative proposal. 
Action at the national level would not allow the compliance against the internationally agreed 
commitments  and  would  also  not  suffice  in  the  fulfilment  of  the  objectives  and  the 
achievement  of  the  targets  set  under  the  Effort  Sharing  Decision  (406/2009/EC).  It  is 
therefore necessary that the Union creates the enabling framework, establishing a harmonised 
reporting framework, to the extent feasible, so as to address the specific international and EU 
requirements. Action at EU level would also produce clear benefits compared with action at 
the national level by reason of its effectiveness.  

3.  Objectives of EU initiative 

The  general  objective  is,  through  timely,  and  transparent,  accurate,  complete,  consistent, 
comparable (TACCC) reporting at EU and MS level, to:   

(a) support the EU and the MS in meeting their commitments under the UNFCCC,  
(b) support  the  EU  and  the  MS  in  meeting  their  domestic  mitigation  and  adaptation 

commitments,  

(c) support the effective development and implementation of EU policies. 

2

 
 
3.1 Specific and operational objectives 

(cid:131) 

the  monitoring  and  reporting  requirements  of 

Implement 
Decision(ESD) and the revised EU Emissions Trading System (EU ETS) Directive 
o  Operational objectives:  

the  Effort  Sharing 

(cid:131)  Establish a review and compliance cycle under the Effort Sharing Decision;  
(cid:131) 

Incorporate  the  reporting  requirements  for  the  use  of  auctioning  revenues  as 
stipulated in the revised ETS Directive; 

(cid:131)  Enhance  the  current  monitoring  and  reporting  framework  so  as  to  meet  the  needs  of 

future EU and international legislation 
o  Operational objectives: 

(cid:131)  Establish monitoring and reporting requirements for maritime transport; 
(cid:131)  Establish reporting requirements for non-CO2 climate impacts from aviation;  
(cid:131)  Establish reporting requirements on climate change adaptation; 
(cid:131)  Establish additional reporting requirements on LULUCF; 

(cid:131)  Enhance  EU  and  MS  reporting  on  financial  and  technology  support  provided  to 
developing  countries  ensuring  adherence  to  international  commitments  under  the 
UNFCCC 
o  Operational  objective:  Specify  reporting  requirements  on  financial  and  technical 

support provided to developing countries;  

(cid:131)  Enhance  consistency  of  reporting  under  the  MMD  with  the  reporting  under  other  legal 

instruments in the EU that address air pollutants 
o  Operational objective: Establish links with the reporting of GHG emissions under the 
EU ETS,  the reported information under the E-PRTR, the NEC Directive and the F-
Gas Regulation; 

(cid:131)  Enhance reporting taking  into account lessons learned from past implementation 

o  Operational objectives 

(cid:131) 
(cid:131) 

Improve reporting on projections, policies and measures; 
Improve the preparation of the national inventory report; 

4.  Policy options and assessment of impacts 

The  revision  of  the  MMD  is  supporting  the  implementation  of  adopted  EU  policies  and 
commitments,  in  particular  the  EU’s  commitments  under  the  UNFCCC,  the  targets  and 
legislative instruments under the Climate and Energy package, and the implementation of the 
Europe  2020  strategy.  Specific  environmental,  social  and  economic  impacts  have  already 
been assessed for many of the areas in question when the Climate and Energy Package which 
included  specific  targets  and  policies  was  adopted3.  The  revision  of  the  MMD  and  the 
implementing  provisions  contribute  to  the  environmental  benefits  identified  in  the  impact 
assessments of these instruments by ensuring the appropriate monitoring of the achievement 
of the targets. 

Environmental impacts 

The MMD is being revised to increase the EU's environmental performance:  

a)  through  ensuring  the  availability  of  better  quality  and  more  complete  data  and 
information (data quality/completeness),  

3 The impact assessment is contained in the Commission staff working document on the impact assessment document 
“accompanying the Package of Implementation measures for the EU's objectives on climate change and renewable energy for 
2020” (SEC (2008) 85/3) and its annex SEC (2008)85) Vol II. 

3

 
 
 
 
                                                 
through  enabling  better  compliance  with  domestic  and 

b) 
commitments  and 
commitments), and  
c) through enabling further future policy actions in this field to be designed, developed and 
implemented (further policy development/implementation).  

(compliance  with  domestic  and/or 

targets, 
international 

requirements 

international 

The environmental impacts have been assessed for each of the proposed options based on a 
combination of the three criteria above as applicable (ratings used: + or – is used to denote 
positive  or  negative  impacts  respectively.    =  signifies  no  impact,  +/-  low  impact,  ++/--, 
medium impact, +++/--- high impact). 

The  aspects  of  compliance  and  simplification  were  also  specifically  assessed.  (Ratings  used 
with regard to compliance: LL: low likelihood, ML: medium likelihood, HL: high likelihood). 

Economic impacts 

The MMD is an instrument through which domestic and international reporting requirements 
are  implemented.  These  requirements  are  at  the  national  level,  hence  the  main  economic 
impacts  linked  to  the  revision  of  the  MMD  relate  to  the  administrative  burden  that  public 
authorities at the MS level would incur once these changes were implemented.  

Other impacts (social, employment, industry, SMEs) 

The proposed options will have minor social impacts related to the provision of information to 
the public, these have not been specifically addressed in the impact assessment.  

No  direct  or  indirect  reporting  requirements  are  imposed  on  SMEs  or  industry  through  the 
MMD  and  the  MMD  is  not  likely  to  have  any  impacts  on  employment  either,  thus  such 
impacts were not further assessed.  

4.1 Establishment of an EU review and compliance cycle under the Effort Sharing 
Decision  

Option  1:  No  internal  review  at  EU  level.  Rely  on  current  UNFCCC  review.  ("no  policy 
change"). (This sub-option was discarded at an early stage.) 

Option 2: An internal inventory review at the European level is implemented for target setting 
purposes  (initial  review)  while  the  EU  continues  to  rely  on  the  inventory  review  under  the 
UNFCCC, as in the current MMD, for the annual compliance cycle under the ESD. (This sub-
option was discarded at an early stage.) 

Option  3:  Establish  a  "light"  EU-level  annual  review  and  compliance  cycle  for  the 
implementation of the ESD and a comprehensive initial review. (The annual review would be 
performed in a shorter time frame with mostly automatic checking routines supplemented by 
an  analysis  of  the  previous  UNFCCC  review  reports,  building  on  existing  checks  and 
procedures  currently  carried  out  by  the  European  Environment  Agency  (EEA)  under  the 
MMD). ("Light review") 

Option 4: Establish a comprehensive EU annual review process and compliance cycle for the 
implementation of the ESD along with a comprehensive initial review. This review would be 
mirrored  after  the  UNFCCC  review  but  in  a  shorter  time-frame  to  allow  for  a  compliance 
assessment during the calendar year. ("Comprehensive review") 

Option 3:Light review 

Environmental Impacts4 
+ 

Administrative burden 
€15,000-30,000 

4 Ratings used: + or – is used to denote positive or negative impacts respectively.  = signifies no impact, +/- low 

impact, ++/--, medium impact, +++/--- high impact 

4

 
 
 
 
                                                 
Option 4: Comprehensive review 

Environmental Impacts4 
+++ 

Administrative burden 
€50,000-100,000 

Suboptions  related  to  the  treatment  of  recalculations  resulting from  a)  the  business  as  usual 
annual methodological or data improvements in the greenhouse gas inventories (case 1), and 
b)  from  a  change  in  the  reporting  rules  at  the  international  level  (case  2),    in  the  annual 
reporting, review and compliance cycle were also considered. 

4.2  Incorporate  the  reporting  requirements  for  the  use  of  auctioning  revenues 
under the revised ETS Directive 

The  revised  ETS  Directive  has  clearly  specified  that  the  additional  reporting  requirements 
related to the use of revenues from auctioning of allowances shall be reported in the reports 
submitted under Decision No 280/2004/EC5.  

4.3  Establish  monitoring  and  reporting  requirements  for  emissions  from 
international maritime transport 

Option 1: Continue with current monitoring and reporting of GHG emissions from domestic 
and  international  maritime  transport  in  GHG  inventories  without  establishing  the  basis  for 
improved underlying data. ("no policy change") 

Option 2: Establish detailed monitoring and reporting requirements for Member States.(This 
option  would  include  defining  the  basis  for  monitoring,  the  criteria  for  the  allocation  of 
emissions  to  MS  and  the  administrative  details  related  to  reporting.  ("Detailed  reporting 
requirements now") 

Option  3:  Establish  the  basis  for  new  monitoring  and  reporting  guidelines  allowing  for  the 
detailed provisions to be adopted in future legislation through comitology once a measure has 
been  adopted  by  the  International  Maritime  Organization  or  the  EU.  ("Framework  now, 
details later") 

Option 1: no policy change 
Option 2: Detailed reporting requirements now 
Option 3: Framework now, details later 

Environmental 
Impacts 
 - - 
+  
+ + + 

Compliance  Administrative 

na 
ML 
HL 

burden 
na 
- - - 
- 

4.4 Establish reporting requirements related to the non-CO2 impacts of aviation 
on the global climate 

Option 1: Continue with current reporting of GHG emissions from domestic and international 
aviation in GHG inventories limited to CO2 emissions.("no policy change") 

Option 2: Require that Member States report on the non-CO2 climate impacts of aviation by 
multiplying  the  CO2  impacts  by  a  pre-defined  factor.  (This  factor  would  be  changed  by  the 
Climate Change Committee to reflect the latest scientific results.) ("Multiplier Approach") 

Option 3: Require that Member States report the non-CO2 climate effects of aviation based on 
detailed models. ("Modelling approach") 

Option 4: Adopt new reporting requirements for the non-CO2 effects of aviation for MS based 
on a two-tiered system. (Under this option, those Members States which reported more than 

5  The  use  of  the  reports  submitted  under  Decision  No  280/2004/EC  for  the  reporting  of  the  auctioning  revenues  is  not 
specifically  provided  for  the  "aviation"  allowances  in  Article  3d(4),  nevertheless,  for  consistency  will  be  implemented 
accordingly.  

5

 
 
 
 
 
 
 
 
                                                 
3% of the total EU CO2 emissions from aviation would report the non-CO2 effects of aviation 
based  on  detailed  models.  (Currently,  this  would  apply  to  France,  Germany,  Italy,  the 
Netherlands,  Spain  and  UK  which  are  jointly  responsible  for  approx.  80%  of  the  CO2 
emissions.)   All other MS could report using detailed models but, if not feasible, they could 
use the multiplier approach instead. ("Tiered approach") 

Option 1: no policy change 
Option 2:  Multiplier Approach 
Option 3: Modelling approach 
Option 4: Tiered approach 

Environmental 
impacts 
- 
+ 
++ 
+++ 

Compliance 

= 
HL 
LL 
ML 

Administrative 
burden 
= 
€ 24,000 
€ 6.75 million 
€ 1.52 million 

4.5 Establish reporting requirements on climate change adaptation 

Option  1:  Continue  with  current  reporting  on  climate  change  impacts,  vulnerability  and 
adaptation  in  Member  States’  national  communications  under  the  UNFCCC  and  use  this 
information for EU purposes. ("no policy change") 

Option 2: Require that MS comprehensively report on an annual basis on their climate change 
impacts,  vulnerability  and  adaptation  actions.(This  option  would  cover  among  other  the 
observed  and  projected  impacts  per  sector,  the  assessment  of  key  vulnerabilities  per  region 
and per sector, the existing national and/or regional adaptation strategy and implemented and 
planned  measures,  information  on  strategies  and  on  bilateral  and  multilateral  projects  on 
adaptation and the respective budget allocated). ("Comprehensive reporting") 

Option  3:  Require  that  MS  report  on  an  annual  basis  on  their  implemented  and  planned 
climate change national adaptation actions. In this option an indicative list of information to 
be reported would be provided. ("Reporting on actions") 

Option 1: no policy change 
Option 2:Comprehensive reporting 
Option 3: Reporting on actions 

Environmental 
impacts 
- 
+++ 
++ 

Compliance 

= 
LL 
HL 

Administrative 
burden 
= 
€ 1 to 2.24 million 
€ 120,000 

4.6 Establish additional reporting requirements on LULUCF 

Option  1:  Continue  with  current  reporting  on  land  use,  land  use  change  and  forestry.  ("no 
policy change") 

Option  2:  Establish  revised  reporting  requirements  for  LULUCF  activities,  based  on 
information from the ongoing international negotiations (and in addition to existing reporting 
requirements), in the following areas ("Detailed requirements now"):6 

(cid:131)  Estimate  and  report  emissions  and  removals  from  forest  management  activity  on  a 

mandatory basis 

(cid:131)  Estimate and report data on emissions from the harvested wood products pool (mandatory) 
(cid:131)  Estimate and report emissions and removals from rewetting and drainage7 (voluntary) 

6   The detailed elements are based on a draft decision under the Kyoto Protocol 
7   Rewetting  and  drainage”  is  a  system  of  practices  for  rewetting  and draining  on  land  with  organic  soil  that 
covers a minimum area of 1 hectare. The activity applies to all lands that have been drained and/or rewetted 
since 1990 and that are not accounted for under any other activity as defined in this annex, where drainage is 
the direct human induced lowering of the soil water table and rewetting is the direct human-induced partial or 
total reversal of drainage; 

6

 
 
 
 
 
 
 
                                                 
(cid:131)  Estimate and report emissions and removals subject to “force majeure”8 (voluntary) 
(cid:131)  Updating  of  forest  management  reference  level  values  based  on  new  data  or 

methodological improvements 

Option 3: Establish the basis for new reporting guidelines allowing for the detailed provisions 
to be adopted in future legislation once relevant measures have been adopted at the EU level 
or  internationally.  (Effectively,  this  means  that  the  scope  of  reporting  would  be  determined 
through  the  co-decision  procedure  of  legislating  on  the  role  of  LULUCF  in  the  EU's  GHG 
emission  reduction  commitment  whilst  the  technical  details  would  be  established  through 
delegated acts ("comitology") within the framework agreed by the European Parliament and 
Council.) ("Framework now, details later") 

Option 1: no policy change 
Option 2:Detailed requirements now 
Option 3:Framework now, details later 

Environmental 
impacts 
- - - 
+ + 
 + + + 

Compliance 

= 
ML 
HL 

Administrative 
burden 
= 
€ 610,000 to € 710,000  

< € 610,000 to € 

710,000 

4.7 Establish reporting requirements on financial and technology support provided 
to developing countries 

Option 1: Continue with current reporting of financial and technology support to developing 
countries  through  MS’  national  communications  under  the  UNFCCC  without  separate 
reporting requirements at EU level.("no policy change") 

Option 2: Require MS to voluntarily report information on financial and technology support 
provided  every  2  years  based  on  the  national  communication  guidelines.  ("Voluntary 
reporting") 

Option 3: Require that MS report on an annual basis through streamlined formats the financial 
and  technical  support  provided  to  developing  countries  building  on  the  existing  national 
communication  guidelines  but  requiring  more  comprehensive  information  on  technology 
programmes  and  the  use  of  methodologies  developed  within  EU  for  reporting  on  financial 
support and indicators for financial flows of the OECD Development Assistance Committee 
(DAC). ("Comprehensive reporting") 

Option 1:no policy change 
Option 2: Voluntary reporting 
Option 3:Comprehensive reporting 

Environmental 
impacts 
- - - 
+ 
+++ 

Compliance 

= 
ML 
ML 

Administrative 
burden 
= 
€65,000 
€195,000  

4.8  Enhance  consistency  with  other  legal  instruments  in  the  EU  targeting  air 
pollutants 

Option  1:  Deal  with  reporting  requirements  in  the  MMD  and  other  legal  instruments 
separately  and  do  not  streamline  the  reporting  under  different  instruments.  ("no  policy 
change") 

8   Events  beyond  the  control  and  not  materially  influenced  by  the  country  including  a  demonstration  that  no 
land use change has occurred on lands subject to force majeure events, a demonstration that the occurrences 
were beyond the control of the Party, a demonstration of efforts taken to rehabilitate the lands subject to force 
majeure events, a demonstration that emissions associated with salvage logging were not excluded. 

7

 
 
 
 
 
 
 
 
                                                 
Option  2:  Establish  requirements  to  report  on  the  consistency  of  information  between  the 
reporting  under  the  MMD  with  the  reporting  under  the  EU  ETS,  the  E-PRTR,  the  NEC 
Directive and the F-Gas Regulation and to report on the QA/QC checks conducted to ensure 
consistency  across  the  different  legal  instruments  (including  share  of  ETS  emissions). 
("Report on consistency") 

Option 3: Establish requirements that MS' existing inventory national systems are amended to 
allow access to data resulting from other reporting instruments (e.g., ETS, EPRTR, NEC) and 
consequently  that  inventory  data  is  also  being  made  available  for  reporting  under  other 
reporting instruments. ("Amend national system") 

Option 4: Establish requirement to use the data reported via other instruments directly, such 
as  EU  ETS,  EPRTR,  F-Gas  Regulation,  NECD,  by  aligning  reported  pollutant  data  via 
reconciling the: disaggregation, contents, procedures,  tools and formats they use/define.(This 
sub-option was discarded at an early stage.) 

Option 1:no policy change 

Environme
ntal 
impacts 
- 

Option 2 :Report on consistency 

+ + 

Simplific
ation 

Complian
ce 

Administrative burden 

- - 

++ 

= 

HL 

HL 

Potential costs if lack of 
QA/QC is raised by 
UNFCCC review 
€ 525,000 (not including 
simplification benefits) 
€ 380,000 

Option 3:Amend national system 

+ + + 

+++ 

4.9  Enhance  reporting 
implementation 

taking 

into  account 

lessons 

learned 

from  past 

Option 1: Keep existing reporting guidance under the MMD and the implementing provisions 
and rely on the methodological guidance specified under the UNFCCC. Pursue changes of the 
reporting guidance under the UNFCCC. ("no policy change") 

Option  2:  Require  annual  reporting  and  further  specify  type  of  information/data  to  be 
reported, and/or the relevant formats (" Streamline formats") 

Option  3:  Further  specify  methodological  guidance  for  the  effects  of  policies  and  measures 
and the preparation of GHG emission projections. ("Harmonize methodologies") 

Option 4: Require the establishment of a national system for reporting on projections, policies 
and  measures  9  (along  similar  main  principles  as  for  that  established  for  GHG  inventories) 
("Establish national system") 

Option 1: no policy change 
Option 2: Streamline formats 

Environment
al impacts 
= 
++ 

Option 3:Harmonize methodologies 

+++ 

Compliance  Simplificati

= 
HL 

LL 

on 
 - - - 
+ + 

- 

Administrative 
burden 

€980,000-
€1.3million 
Higher than 
for option 2 

9  The  objective  of  the  national  system,  as  known  under  the  Kyoto  protocl  is  to  guarantee  the  preparation  of  an  annual 
greenhouse  gas  inventory,  which  complies  with  the  quality  criteria  set  for  the  inventories,  and  its  reporting  to  the 
secretariat  of  the  United  Nations  Framework  Convention  on  Climate  Change  (UNFCC)  and  the  Commission  of  the 
European Union. The national system produces the emission and background data of the inventory. Included are also the 
archiving of the data used in emission calculations, the publication of the results, participation in inventory investigations 
and the quality management of the inventory. 

8

 
 
 
 
 
 
 
                                                 
Option 4:Establish national system 

+++ 

ML 

+ + + 

290,000 

5.  Comparison of options 

Main objective of the MMD is to support the EU and its MS in meeting their, domestic and 
international,  commitments  and  goals,  and  future  policy  development,  through  ensuring 
transparent,  accurate,  consistent,  comparable,  complete  reporting.  The  preferred  scenario 
ensures  that  these  objectives  will  be  met  in  an  efficient  and  effective  way.  The  overall 
administrative burden linked to the preferred scenario is in the range of € 4-5 million for the 
EU-27. 

Given the uncertainties linked to a future climate regime, the preferred scenario foresees the 
establishment of an EU level review process of the GHG data submitted by the MS so as to 
ensure  that  compliance  with  the  ESD  targets  is  assessed  in  a  comprehensive,  transparent, 
credible  and  timely  manner  as  foreseen  in  the  Climate  and  Energy  package.  With  regard  to 
reporting on emissions from international maritime transport and the LULUCF sector where 
policy discussions, both domestically and internationally, are on-going a prudent approach is 
followed  by  ensuring  that  the  MMD  provides  an  adequate  framework  for  establishing  the 
detailed  reporting  requirements  at  a  later  stage  when  a  concrete  policy  outcome  is  reached 
(either domestically or internationally). This way coherence with a future policy framework is 
ensured  and  duplication  of  efforts  is  avoided  while  it  is  also  ensured  that  the  EU  is  able  to 
most  efficiently  implement  the  detailed  requirements.  With  regard  to  the  non-CO2  climate 
impacts of aviation coherence is again ensured with existing domestic policy which requires 
that an effort be made to take into consideration its impacts. The proposal included in the draft 
Regulation on the non-CO2 climate impacts of aviation, which requires that the Commission 
assess biennially those impacts on the basis of the latest available emission data and scientific 
advancements,  differs  from  those  explored  in  the  impact  assessment  and  reflects  the  useful 
input  received  by  other  Commission  services  during  the  interservice  consultation  process. 
This new proposal was included in the draft Regulation as it was deemed to ensure coherence 
with  existing  Union  policy,  and  to  achieve  equivalent  benefits  at  a  significantly  lower 
administrative burden. With regard to finance and technology support the preferred option of 
enhancing reporting based on common methods is again coherent with the EU's obligation to 
provide transparent and complete information on the financial and technology support it has 
been  providing  to  developing  countries  and  results  in  limited  burden.  With  regard  to 
adaptation,  the  annual  reporting  on  adaptation  actions  will  help  further  define  an  EU-wide 
adaptation  strategy  and  will  also  support  the  EU  Clearinghouse  Mechanism.  This  is  an 
efficient option as it is linked to limited administrative burden while it also ensures that the 
EU  is  better  able  to  address  its  international  reporting  obligations.  Finally,  the  preferred 
scenario  also  foresees  the  enhancement  of  the  existing  national  system  in  the  MS  to  also 
address reporting on projections and policies and measures, as well as consistency with other 
legal  instruments  targeting  air  pollutants.  This  is  an  efficient  way  forward  as  despite  the 
related  burden  it  leads  in  the  long-run  to  better  compliance,  simplification  of  efforts  and  an 
eventual reduction of costs. The preferred scenario also foresees better QA/QC provisions and 
the  introduction  of  streamlined  reporting  formats  and  guidance  so  as  to  increase  the  quality 
and completeness of the data provided and to simplify existing reporting requirements without 
imposing undue administrative burden. 

6.  Monitoring and evaluation 

As  all  the  policy  options  relate  to  monitoring  and  reporting  requirements  the  completeness, 
transparency,  and  adherence  of  the  resulting  reports  to  the  domestic  and  international 

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requirements will in itself demonstrate whether the objectives set have been achieved through 
the revised MMD.  

A set of specific indicators corresponding to the general, specific and operational objectives 
set in this impact assessment will also be used to monitor and evaluate the performance of the 
MMD. These indicators will focus among other on the extent to which the resulting reports 
and data adhere to the established guidelines and/or guidance, their timeliness, completeness, 
and the identified cases of non-compliance. 

The  reports  prepared  under  the  MMD  will  continue  to  be  assessed  at  the  EU  and/or  the 
international level annually, every 2 years and/or every 4 years.  

The  actors  that  have  been  traditionally  involved  at  the  EU  level  in  the  monitoring  and 
evaluation  exercise,  besides  DG  CLIMA,  are  the  EEA,  the  JRC  and  Eurostat.  These  same 
actors will continue to assist in this exercise in the future. 

The results of both the EU and the international assessment besides being used for compliance 
purposes  will  also  continue  to  be  used  to  most  effectively  direct  improvement  efforts  and 
capacity building activities at the EU and the MS level.  

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