The EU ETS Phase IV Baseline Exercise – NIMs

In preparation for the transition into Phase IV of the EU ETS, baseline exercises are currently underway. All EU ETS installations are required to submit National Implementation Measures (NIMs report) baseline figures and an accompanying Monitoring Methodology Plan (MMP) for this next phase of the EU ETS. Reports must be produced, verified and submitted to the competent authority by 30th May 2019.

What does the NIMs involve?

The NIMs Phase IV Baseline exercise will dictate the amount of free allowances your installations your installation will be eligible for, come Phase IV. This allocation is based on several factors and, importantly, you must submit five years of historical data for verification.

What are the pitfalls?

This is a complex and critical exercise. The timescale is short and there are many opportunities for misunderstanding and misinterpretation of the underpinning regulations. There is a risk of errors being made in completing templates and the supporting evidence trails, which may only become apparent when reports are submitted for verification.

The ultimate penalty for not completing the exercise, or completing it incorrectly, is no free allocation for the first five years of Phase IV of the EU ETS.

Do you have to complete it?

The simple answer is yes, you must.

All incumbents of the EU ETS, whether they receive free allocation or not, must complete this exercise to some extent.

Electricity generators and small emitters and hospitals that opted out under Article 27 must as well, although electrical generators don’t have to submit any data.

All installations are, in principle eligible for free allocation, except installations solely producing electricity and installations operated for the capture, transport, and storage of CO2

What is the impact of Brexit?

Some of you may be thinking about how Brexit will impact your EU ETS participation.

Something we do know for certain is that all current participants in the EU ETS will have to take part in the NIMs regardless of any political outcome.

How can Swan Energy help?

The exercise is likely to be an arduous task. Just think about how difficult it has been getting data verified on time for 2018 alone.

Here at Swan Energy we are EU ETS compliance experts, we’ve been involved with the EU ETS since its inception and have dealt with baseline exercises in the past. We currently manage over 50 EU ETS installations and will be completing the NIMs Phase IV baseline exercise at no additional cost to our existing clients.

We’ve also now participated in a series of consultancy webinars run by the Environment Agency and Lucideon CICS, one of the foremost UK verification bodies.

If you would like our assistance in conducting the NIMs Phase IV Baseline, we are happy to do this for any clients that sign up to an ongoing contract for EU ETS consultancy support through Phase IV of the EU ETS. 

Rebecca Scarratt

Carbon Consultant

Rebecca Scarratt

Carbon Consultant

Rebecca has joined the Swan Energy team in 2021. She graduated from the University of Hull with a BSc in Geology with Physical Geography in 2020 and went on to do a MSc in Renewable Energy. Her Masters’ thesis focused on how future climate change may impact the Humber region’s wind energy sector and how adaptation strategies could be used to reduce vulnerability.

In her role at Swan Energy, Rebecca supports the consultancy work the team does with clients across the UK.