• Forum welcomes the draft implementing regulation. We appreciate the wording of Art. 3.1, allowing for the pragmatic approach regarding the start of activity level reporting already in 2021, based on the data for two preceding years. Forum also understands the pragmatic approach to adjust the allocation only above the threshold of 100 allowances and supports the adjustments of activity changes at sub-installation level.
• Forum is in favor of the proportional adjustment within a certain intervals in comparison with the initial allocation level, with the first interval set at 15% and subsequent intervals of 5% to limit administrative burden. However, under Art 5(3) once the activity falls back the 15% threshold even by a marginal amount, the allocation equals the initial allocation. Forum recommends to improve the dynamic character of the system without increasing the administrative burden, and once the initial threshold of 15% has been reached and the dynamic system applies, to use the 5% intervals in both directions.
• In case of very large installations, relative interval of 15% might be very difficult to reach so we would suggest to add optional absolute threshold, for example of 50 000 EUAs as is the case in ETS 2013-2020.
• We welcome the avoidance of allocation decrease in case of energy efficiency, however the threshold of 15% improvement is too restrictive as it requires considerable capital investment. There is a risk that energy efficiency projects that are spread over several years would be penalized.
• With allocation set at zero in years with zero activity there is a great risk of under allocation. Instead, we strongly suggest to use the rolling average as a rule.
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