Feedback (28)

Showing results 1 to 10

  • VIK - German Association of Industrial Energy Consumers (Germany)
    17 April 2018 Company/business organisation
    VIK - German Association of Industrial Energy Consumers (Germany)

    Please see attachment

  • Eurometaux (Belgium)
    17 April 2018 Business association
    Eurometaux (Belgium)

    Key Guiding Principle The EU ETS should be a more dynamic system which safeguards and rewards the growth of sectors identified at risk of carbon leakage. A lower, even more dynamic threshold (i.e. <15%) is need to better reflect industrial requirements for free allocation. Furthermore, under allocation in times of growth can be avoided with a better designed, fairer, more dynamic system. 1. Determination of the historical activity levels...

  • UNIDEN (France)
    17 April 2018 Business association
    UNIDEN (France)

    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)...

  • Norsk Hydro ASA (Norway)
    17 April 2018 Company/business organisation
    Norsk Hydro ASA (Norway)

    Guiding principle: To avoid the risk of carbon leakage, free allocation in Phase 4 should incentivize GHG reduction friendly industrial growth at updated benchmark level and avoid overcompensation. 1. Rules to be applied to free allocation: According to article 11(1) of ETS Directive, free allocations given to individual installations must be calculated on the data from 2014 to 2018. The rules to be applied for calculating the initial...

  • FEIQUE (Spanish Chemical Industry Federation) (Spain)
    17 April 2018 Business association
    FEIQUE (Spanish Chemical Industry Federation) (Spain)

    - "Fall-back benchmarks" (heat, fuel, process emissions): they are expected to be updated according to the levels of the sectors during 2016-2017 (for example, in the case of the first sub-period), just like the product benchmarks. However, an Impact Assessment must be carried out in order to contemplates and evaluates the different alternatives and availability of raw materials and energy uses that could affect the improvement observed in the...

  • Anonymous (Austria)
    17 April 2018 Company/business organisation
    Anonymous (Austria)

    Please see the attached pdf file RHI Magnesita position regarding the Commission roadmap `Revising the rules for free allocation in the EU ETS´.

  • BASF SE (Germany)
    17 April 2018 Company/business organisation
    BASF SE (Germany)

    Initial activity Level: The formula used for calculating the Initial activity level should led to a result as close as possible to the production levels. In particular years that are not representative of the normal production level (e.g.: big overhaul every X years) should not be taken in the calculation. As for the ETS phase III, the median of the reference period would be an adequate formula reflecting well activity level. Dynamic...

  • Anonymous (United Kingdom)
    17 April 2018 Business association
    Anonymous (United Kingdom)

    Thank you for the opportunity to review the Roadmap for revising the free allocation rules for the emissions Trading System. We would value the opportunity to be remain engaged on the proposals for Phase IV ETS and on consultations for the proposed implementation acts.

  • Verein Deutscher Zementwerke (Germany)
    17 April 2018 Business association
    Verein Deutscher Zementwerke (Germany)

    Initial Activity Level According to article 11(1) of the ETS Directive, free allocations given to individual installations must be calculated from the data of the years from 2014 to 2018. It is essential that the same rules apply across all sectors and installations as to avoid any distortion. As regards the calculation itself the initial activity level should be determined by the median value of production data from 2014 to 2018. As a general...

  • CEMBUREAU, the European Cement Association (Belgium)
    17 April 2018 Other
    CEMBUREAU, the European Cement Association (Belgium)

    CEMBUREAU’s response on revising the rules for free allocations in the EU ETS ACTIVITY LEVEL Initial Activity Level According to article 11(1) of ETS Directive, free allocations given to individual installations must be calculated from the data of the years from 2014 to 2018. It is essential that the same rules apply across all sectors and installations as to avoid any distortion. Adjustment of Activity Level due to production changes To...

Pages