BACI presented to MOEW its positon concerning version 2

BACI presented to MOEW its positon concerning version 2 of a draft decision of the European Commission determining transitional Union-wide rules for harmonised free allocation of emission allowances pursuant to Article 10a of Directive 2003/87/EC of the European Parliament and of the Council

During a meeting between representatives of BACI and MOEW and also by a letter to MOEW, BACI presented the positions and proposals for changes and suggestions in respect of amendments and revisions to a draft decision of the European Commission determining transitional Union-wide rules for harmonised free allocation of emission allowances pursuant to Article 10a of Directive 2003/87/EC of the European Parliament and of the Council, of the European Cement Association (CEMBUREAU) and of the Alliance of Energy Intensive Industries, which fully match the position and suggestions of BACI.

The key suggestions BACI asked MOEW to focus on are the following:

  • Take the median, instead of the arithmetic mean, to determine the Historical Activity Level, so as to avoid using non-representative years for the respective installation;
  • The dynamic allocation provision should be possible to apply as of the start of Phase IV of the European Trading Scheme (ETS), i.e., the allowances for 2021 should reflect the production changes in the two preceding years (2019 and 2020);
  • Retain the concept for significant capacity extension of the installations occurring as a result of identifiable physical changes relating to their technical configuration and functioning. This concept was introduced with Commission Decision of 27 April 2011 determining transitional Union-wide rules for harmonised free allocation of emission allowances, and is applied in the current ETS phase;
  • The free allocation of emission allowances should be known prior to the start of the next ETS trading period, i.e. before January 2021.

The position of BACI, coinciding with that of CEMBUREAU and AEII, was requested by MOEW to be reflected in the national position vis-à-vis draft decision of the European Commission determining transitional Union-wide rules for harmonised free allocation of emission allowances pursuant to Article 10a of Directive 2003/87/EC of the European Parliament and of the Council.