How to make a Monitoring Plan under CCTS

Ishan Rahman

Co-Founder

ccts-monitoring-plan

A CCTS emissions report does not begin with the emissions calculation. It begins with the monitoring plan.
Under India’s Carbon Credit Trading Scheme, the monitoring plan tells BEE and the verifier what your plant will measure, where the data will come from, who owns it and how each number will be checked.
For obligated entities, the monitoring plan must be submitted within three months of the compliance cycle starting and updated for subsequent compliance years.

Start with the reporting boundary

First, define what belongs in the GEI calculation.

Boilers, process heaters, calcination, captive power, DG sets, purchased electricity, PPAs and imported steam may all fall within the boundary. The question is not whether the equipment exists. The question is whether its emissions or energy use are part of the plant’s reported performance.

The exclusions need the same care. Employee townships, Scope 3 transport and product-use emissions sit outside the boundary.

Renewable electricity is a common area of confusion.

👉🏻 Purchasing Renewable Energy Certificates alone does not make grid electricity zero-emission under CCTS. The plan must show the eligible source and the methodology used for the claim.

Build the data hierarchy before filling the workbook

The CCTS workbook is not a set of independent sheets. Each entry must reconcile with the next.

Every reported number should trace back through four levels:

  • Activity: What happens at the plant
  • Emission source: Where it happens
  • Source stream: The fuel, material or energy input involved
  • Measurement point: How the data is measured

Each item needs a unique code. Those codes link the workbook together.

Document how production, fuel and power are measured

For every major product and input, record:

  • The measuring instrument
  • Its location, range and uncertainty
  • Calibration frequency
  • The procedure for stock opening and closing

This matters because annual consumption is not the same as annual purchase. It is purchase adjusted for stock change.

For direct emissions, document the source stream, metering method and calibration process.
The plan must also state whether the plant uses:

  • Type 1 emission factors: BEE default values
  • Type 2 emission factors: Plant-specific measured values

👉🏻Type 2 factors need supporting evidence such as sampling records, test results and laboratory details.

For indirect emissions, document purchased electricity, imported steam and other energy sources.

Show how data reaches the report

A verifier will not only review the final emissions number. They will ask where it came from.
Your plan should show the full path:

👉🏻 Meter → Logger → ERP or spreadsheet → Review → Report

At each point, define the control.

The person collecting the data should not be the only person approving it.

Run the verifier’s checklist before the verifier does

Do not wait for the ACVA to find the gaps.

  • Maintain a compliance tracker with a named owner for every requirement.
  • Keep version history for every revision and submission
  • Record the plant registration ID, baseline year, trajectory period, GEI target, ACVA and calculation methodology before the data-entry work begins.

Learn how to prepare a BEE CCTS Monitoring Plan

Preparing your first CCTS monitoring plan?

LatSpace can help map plant data, evidence and ownership into a verification-ready workflow.