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Free allocation of emission allowances

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Public consultation

ID: 1967

Lobbying Activity

29 responses

Chemical Industry Seeks Limits on EU Carbon Benchmark Updates

European Chemical Industry Council, 23 Nov 2018

Cefic requests limiting data collection to 2016-2017 and 2021-2022, maintaining current fallback benchmark methodologies based on gas boilers, and excluding biomass installations from heat benchmark calculations. They argue that collecting data from diverse local circumstances could lead to unrepresentative and unrealistic performance assumptions.
This would prevent tighter efficiency standards that their members cannot technically achieve.
Climate goals lose as stricter benchmarks based on best performers are avoided.

European steel industry warns against unfair emission allowance rule changes

The European Steel Association, 23 Nov 2018

EUROFER calls for maintaining existing methodologies for waste gases. They oppose new penalties for flaring and demand legal certainty. The association requests corrections for iron-bearing materials used in furnaces.
This prevents double penalties and avoids sudden reductions in free carbon permits.
The European steel sector loses investment capacity due to increased costs and legal uncertainty.

Consultation response

Vereniging VNO-NCW, 23 Nov 2018

VNO-NCW has been supporting EU ETS as the main driver for European industry to reduce emissions and to incentivise investments in low carbon technologies, provided that the competitive position of the energy-intensive industry is guaranteed. Following the revised EU ETS Directive, VNO-NCW would…

Consultation response

industriAll European Trade Union, 22 Nov 2018

IndustriAll European Trade Union’s feedback to the European Commission’s Draft Delegated Regulation on free allocation rules IndustriAll European Trade Union would like to officially raise the concerns of European steelworkers in relation to the European Commission’s Draft Delegated Regulation…

Eurometaux warns draft carbon allowance rules threaten industrial growth

EUROMETAUX, 23 Nov 2018

Eurometaux requests heat benchmarks based on natural gas rather than biomass. They want flexibility to use the best production years for historical levels. Rules should reward physical investments even below the fifteen percent threshold.
This approach secures higher free allowance volumes and reduces the carbon leakage risk.
Environmental health and Southern European nations with limited forests face disadvantages under current proposals.

Consultation response

ENGIE, 21 Nov 2018

Please see attached file (includes pictures)

European Aluminium urges more flexible emission allowance rules

European Aluminium AISBL, 23 Nov 2018

The group requests flexibility to exclude unrepresentative years from baseline production levels. They also want free allowances for incremental production growth that falls below the 15% threshold.
This would reduce their compliance costs and incentivise investments in plant efficiency.

Consultation response

Ørsted A/S, 22 Nov 2018

We welcome the view stated in Recital 30 of the regulation, acknowledging the need to enhance incentives for emission reductions for activities that produce the same product. Furthermore, in Article 10a(8) of Directive 2003/87/EC (the innovation fund) there is reference to supporting products…

Consultation response

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 23 Nov 2018

The German Energy and Water Association – BDEW e.V. represents a large number of member companies in the scope of the EU-ETS. BDEW’s members operate large and medium-sized combustion plants for electricity and district heat generation as well as compressor stations for gas supply in…

Cement industry urges fairer calculations for free carbon allowances

CEMBUREAU - The European Cement Association, 23 Nov 2018

CEMBUREAU requests using median values instead of arithmetic means for historical activity levels. They argue technical capacity increases should be treated as new entrants to prevent delays.
The industry would avoid losing significant carbon credits during the long wait for adjustments.
Public budgets lose revenue because the proposal reduces the volume of permits auctioned.

Ceramic industry urges stable rules for free emission allowances

European Ceramic Industry Association, 23 Nov 2018

They propose keeping the process emission factor at 0.97. The industry also requests that natural gas remains the reference fuel.
This would help companies manage the significant cost burden of climate regulations.

Consultation response

Verband der Chemischen Industrie e.V., 23 Nov 2018

VCI-Contribution to the stakeholder consultation on Free Allocation Rules (FAR) https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-5486983_de Within the Free Allocation Rules the heat benchmark is of utmost importance for the chemical industry. The draft FAR indicate that a…

Spanish Employers Seek Favorable Changes to Free Emission Rules

CEOE - Confederación Española de Organizaciones Empresariales, 23 Nov 2018

CEOE proposes using the median activity level rather than the arithmetic mean to eliminate statistical outliers. They advocate for maintaining the concept of capacity increases with technical changes to avoid discriminatory treatment. They also argue only years with at least ten percent activity should be counted.
This ensures companies receive more free allowances and avoid gaps in credit allocation.
Member State treasuries lose revenue as the volume of allowances available for auction is reduced.

Consultation response

Euroheat and Power, 23 Nov 2018

HISTORICAL ACTIVITY LEVEL (ARTICLE 15) In article 15, it is stated that historical activity level shall be the arithmetic mean of all annual activity levels during the baseline period (only taking into account calendar years during which the installation has been operated for at least one…

Norsk Hydro urges more flexible emission allowance allocation rules

Norsk Hydro, 23 Nov 2018

Hydro requests flexible options for calculating activity levels, including medians or top production years. They want allowance adjustments for investments even if growth is under fifteen percent. Clearer definitions are sought to ensure consistent enforcement across the EU.
This would prevent the company from being penalized for production dips during maintenance or crises.

Consultation response

Aurubis AG, 23 Nov 2018

Please find the feedback form AURUBIS in the attached document

Consultation response

The European Association for the Promotion of Cogeneration, 23 Nov 2018

COGEN Europe asks that the heat benchmark update foreseen in Phase IV maintains the Phase III approach and methodology to account for CHP heat emissions, to ensure comparability between the two phases and reflect actual observed improvements in the carbon efficiency of heat. This would ensure that…

Consultation response

EVONIK INDUSTRIES AG, 9 Nov 2018

Impacts of a change in the heat benchmarks’ methodology 1. The determination of the new heat benchmark in the fourth trading period needs to remain comparable to the previous methodology. Therefore it should be based on: a) Energy source natural gas, because of its high level of availability…

Sugar manufacturers warn EU carbon rules penalize efficient energy use

COMITE EUROPEEN des FABRICANTS de SUCRE, 23 Nov 2018

The organization requests clearer guidance to protect manufacturers using efficient energy systems. They argue for unambiguous rules that prevent the reduction of free emission allowances.
Sugar producers would maintain their current financial support and avoid higher compliance costs.
The environment loses as manufacturers may switch back to less efficient gas boilers.

Consultation response

EUROALLIAGES, 23 Nov 2018

EUROALLIAGES is the European association of ferro-alloys and silicon producers. It represent more than 95% of the sector in the EEA. The European ferro-alloys and silicon industry is highly affected by the EU ETS, both directly and indirectly, and therefore takes great interest in the drafting…

Czech Industry Group Urges Simpler Carbon Reporting and Waste Gas Rules

Svaz průmyslu a dopravy ČR, 23 Nov 2018

The group wants to merge new reporting requirements with existing systems to simplify paperwork. They also seek to expand the legal definition of safety-related gas flaring.
Streamlining reporting would reduce administrative costs and prevent a spike in regulatory duties.
Climate advocates may see weakened flaring rules as undermining incentives to reduce industrial emissions.

German metals association urges revisions to carbon allowance rules

WirtschaftsVereinigung Metalle, 22 Nov 2018

WVMetalle requests heat benchmarks based on natural gas rather than biomass. They advocate using the median for production calculations to account for maintenance. Finally, they want heat transported in crucibles to be officially recognized.
This would prevent high costs and reduce the risk of companies leaving Europe.
Forest-rich northern EU countries would lose a competitive advantage over southern member states.

Consultation response

IFIEC Europe, 22 Nov 2018

IFIEC Europe response on Commission consultation on delegated regulation on free allocations IFIEC-Europe has three main comments on the draft Delegated Act on Free Allocation Rules 1) The benchmarking exercise may not be implicitly included in the current draft Delegated Act on Free…

Consultation response

STARCH EUROPE, 23 Nov 2018

We note that the Commission proposal for FAR outlines the methodology for the update of the fall-back (heat and fuel) benchmarks based on the data collection to take place in 2019, collecting data for years 2016-2017. Starch Europe is concerned that the results of the data collection will be…

Consultation response

Fédération belge des industries chimiques et des sciences de la vie, 23 Nov 2018

1)Preliminary remarks According to the ETS Directive, the EC shall adopt implementing acts for the purpose of determining the revised benchmark values (Art.10a(2)) and to define arrangements for adjusting free allocation levels (Art.10a(20)). Decisions re the benchmark update or dynamic allocation…

Consultation response

Linde Public Limited Company, 22 Nov 2018

The allocation formula for the hydrogen benchmark (ANNEX III number 6) should be amended to avoid adverse effects on specific installations in the chemical industry. Depending on customer requirements, those installations produce an aggregated synthesis gas with a high carbon monoxide fraction…

Consultation response

Luossavaara - Kiirunavaara Aktiebolag, 23 Nov 2018

LKAB’s feedback relates to Annex 1 which deals with product benchmarks. LKAB proposes to amend the sintered ore product definition from ‘Expressed in tonnes of sintered ore as leaving the sinter plant' to ‘Expressed in tonnes of sintered ore as leaving the production plant’. The argumentation is…

Consultation response

Chemical Industries Association, 23 Nov 2018

The ETS Directive instructs the Commission to adopt implementing acts to determine the revised benchmark values (Art. 10a(2)) and to define an approach for adjusting free allocation where there is a change in production throughput (Art. 10a(20)). The free allocation rules therefore (organised…

Consultation response

Association for District Heating of the Czech Republic, 23 Nov 2018

The Association for District Heating of the Czech Republic calls for the official publication of the FAR regulation as soon as possible in order to leave a timeframe long enough to adapt to the new rules and to progress on the corresponding benchmarks. Secondly, we would like to ask for the…