Европейска схема

4.2. Early action

4.2.1 If early action has been taken into account in the allocation to individual installations, please describe in which manner it is accommodated. Please list and explain in some detail the measures that were accepted as early action and what the criteria for accepting them were. Please demonstrate that the investments/actions to be accommodated led to a reduction of covered emissions beyond what followed from any Community or national legislation in force at the time the action was taken. 4.2.2 If benchmarks are used, please describe on what basis the grouping of installations to which the benchmarks are applied was made and why the respective benchmarks were chosen. Please also indicate the output values applied and justify why they are considered appropriate.

4.2.1. According to Annex III to the Directive early action may be taken into account. The Commission’s guideline on this criterion states:

“Early action” is to be understood as actions undertaken by an operator of an installation covered by the Directive to reduce emissions before the National Allocation Plan is published and notified to the Commission. In line with criterion 4, only measures that operators undertake beyond requirements arising from Community legislation can qualify as early action. More stringent national legislation, applied to all covered installations or to an activity, will impact the potential to reduce emissions (criterion 3). Therefore, early action is limited to reductions of covered emissions beyond reductions made pursuant to Community or national legislation, or to actions undertaken in the absence of any such legislation.

The guidelines also state that early action, if used, should be applied to determine the quantity of allowances to be allocated to individual installations.

There are two issues to be considered here: first, identifying clear cases of early action, and second, devising a mechanism within the NAP to reward this early action.

In relation to the first of these issues, it is clear from the guidelines of the Commission that the allocation of allowances for early action depends on the motivation behind the emission reduction action. Any action undertaken for involuntary reasons, such as compliance with legislation, is excluded. When a reduction has been achieved accruing a net economic benefit, which would arise even in the absence of future carbon constraints, there would appear to be little justification for rewarding early action.

It should be mentioned that, because of the process of accession of Bulgaria to the ЕU and the foreseeable future measures to reduce greenhouse gas emissions, the objective application of those two criteria to identify early action is difficult.

Instead, the methodology used in the NAP provides for the use of an average sum from a two-year historical period with highest emissions during the period 2000-2004. This approach gives a market regulated bonus to installations which have invested in emission reduction as a form of early action during this period, without need of any additional administrative action. To some extent, this historical approach rewards also the co-generation.

4.2.2. Benchmarking has not been used.