Европейска схема

3. Determination of the quantity of allowances at installation level

3.1. By what methodology has the allocation been determined at installation level? Has the same methodology been used for all installations? If not, please explain why a differentiation between installations belonging to the same activity was considered necessary, how the differentiation by installation was done, in detail, and why this is considered not to unduly favour certain undertakings within the State?

According to the applied Methodology, the quantity of allowances that the country will include in the Emission Trading Scheme will depend on the macroeconomic indicators of the country for the period up to 2012, the forecasts for the economic development in general and by sectors, the emission reductions according to the Kyoto Protocol, the opportunities for using the flexible mechanisms under the Kyoto Protocol for emission reduction, and the forecasts for the development of the installations. The determination of the quantity of allowances and their proportion to the emissions from sources outside the scheme is based on two sources of information:

• 
  National GHG emissions inventory for the year 2003;
  
• 
  Data about the installations based on a questionnaire, filled in by the operators of the installations.
  

Based on the analyses of collected and verified data on the activities of each installation, historical emissions have been calculated and data about “base year” have been determined at installation level. As base year is accepted the average sum of the emissions from the installation for the two years with highest emissions during the period 2002-2004. The base year of an installation which did not function during two years of this period, is the year of operation of the installation.

In accordance with the requirements of the EU, the NAP envisages equal effort, equal right and equal obligation to changes (increase or reduction) in emission levels for the two groups of emission sources (participating and not participating) and preservation of the ratio of the emissions of both groups. After the determination of the various types of reserves set aside for later periods and calculative reserves, a table is structured that shows the quantity of emission allowances by sectors and overall reserves for the Country which could be allocated through the Scheme based on the macro-economic indicators.

The allocation of allowances among installations within each sector is based on the historical emissions from registered installations whose operators have submitted data on time, the projected production volume and emissions by sectors and the methodology proposed below which shall be applied to the sectors and the installations by sectors.

3.2. If historical emissions data were used, please state whether they have been determined in accordance with the Commission’s monitoring and reporting guidelines pursuant to Article 14 of the Directive or any other set of established guidelines, and/or whether they have been subject to independent verification.

Operators of identified installations were required to provide historical emissions data, following the Commission’s guidelines. The guidelines were approved by the Inter-ministerial working group on the development of the NAP on 3 May 2005; on their basis, letters were sent to operators of installations; information about the activities regarding the development of the NAP was also published on 5 May 2005 at the web-sites of the MOEW, the MEER and the MI.

After verification of the accuracy of historical data through comparison with official data from the NSI, information was sent to operators of installations about final historical emissions, calculated basing on the data they submitted. Operators were asked to confirm it – a process which played the role of additional verification on a consensus base with stakeholders.

3.3. If early action or clean technology were taken into account at this level, please state so here and give details in Sections 4.2 or 4.3 below.

Bulgaria does not intend to take into account neither early actions, nor clean technologies (for details see Sections 4.2 and 4.3).

3.4. If the Member State intends to include unilaterally installations carrying out activities listed in Annex I below the capacity limits referred to in that Annex, please explain why, and address, in particular, the effects on the internal market, potential distortions of competition and the environmental integrity of the scheme.

Bulgaria does not intend to include unilaterally installations carrying out activities listed in Annex I to the Directive below the capacity limits as referred to in Art.24 of the Directive.

The Government’s decision on the total number of installations to which allowances will be allocated is based on the best available information about the installations covered by the Directive. Bulgaria does not need to include additional installations in the Scheme for fulfilling its obligations under the Kyoto Protocol; therefore, the costs and the administrative burden related to the inclusion of lower capacity installations in small and medium-size enterprises would not be justified.

3.5. If the Member State intends temporarily to exclude certain installations from the scheme until 31 December 2007 at the latest, please explain in detail how the requirements set out in Article 27(2)(a)-(c) of Directive 2003/87EC are fulfilled.

At this stage, Bulgaria does not intend to temporary exclude any installations before 31 December 2007.