UNIDEN would like to contribute to the consultation on EU ETS allocation rules for the period 2021-2030, in particular on two main issues
A) Determination of activity levels
A1) Initial Activity Level
A2) Adjustment due to production change (relative and absolute threshold)
A3) Special case for activity level of installations allocated with fuel and heat benchmarks
B) Update of benchmarks.
B1) Benchmark products
B2) Fuel and heat benchmarks
For each item, UNIDEN 's recommendations are explained in detailled in the attached file.
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