Once you have established that your energy-from-waste or waste incineration installation qualifies for the UK ETS voluntary MRV-only period, your next step is to prepare a Voluntary Monitoring Plan (VMP). In this update we take you through what “METS” is, what the VMP needs to include, how to structure it, and how to get it approved.
What is METS?
Manage your UK Emissions Trading Scheme (METS) is the online portal where UK ETS operators apply for an emissions monitoring plan/permit, manage emissions monitoring plans/permits, and submit annual reports.
Waste operators must apply for a METS accounts in order to take part in the voluntary MRV-only period.
What is a Voluntary Monitoring Plan?
A Voluntary Monitoring Plan (VMP) is a structured document that outlines how your installation will monitor, report, and verify greenhouse gas emissions during the MRV-only period (2026–2027). It is based on the same principles as a full ETS monitoring plan, but tailored for voluntary participation.
What should a VMP include?
A VMP must cover the following core components:
1 – Installation Overview
- Name, location, permit details
- Description of waste types and incineration processes
2 – Emission Sources and Source Streams
- Identify all relevant emission sources (e.g. combustion units, flue gas)
- List all waste and fuel streams contributing to CO₂ emissions
3 – Monitoring Methodology
- Choose between:
- Measurement-based approach (e.g. CEMS)
- Calculation-based approach (e.g. emission factors, calorific values)
- Outline how data will be collected.
4 – Sampling and Analysis
- Describe how biomass vs. fossil carbon content (e.g. C-14 testing) will be determined
- Outline frequency, methods, and quality assurance procedures
5 – Data Flow and Control Systems
- Map out how data moves from source to report
- Identify roles, responsibilities, and risk controls
6 – Written Procedures
- Provide separate documents detailing:
- Sampling and analysis
- Data handling and validation
- Missing data protocols
Structuring your VMP
The UK ETS guidance recommends using the standard VMP template provided by the Environment Agency. This ensures consistency and makes the approval process smoother.
Operators will also need to submit supporting documents, including:
- Written procedures
- Diagrams of your installation and data flow
- Evidence of quality assurance systems
Getting your VMP approved
Once your VMP is complete:
1 – Submit it on METS to the relevant regulator, for example, Environment Agency, Natural Resource Wales, Scottish Environment Protection Agency, Northern Ireland Environment Agency)
2 – Await feedback and make any requested changes
3 – Receive confirmation that your VMP is accepted
Our team of Carbon Consultants are well versed in the intricacies of METS and monitoring plan applications. If you would like us to support you through the voluntary MRV-only period, please contact us here.
In our next update we will be looking into the two monitoring approaches: measurement-based and calculation-based so make sure to follow us on LinkedIn to get notified when the next blog in the EfW series is released. If you would like to speak to a Swan Energy consultant, get in touch.
