For allocation of allowances for greenhouse gas emissions trading for participation of bulgaria in the european greenhouse gas emission

3. Allowances for Allocation at Installation Level

3.1. What method of allocation has been used at installation level? Has the same method been used for all installations? If not, explain the distinction between installations within the same activity, how it has been drawn, in detail, and why it is believed this will not give the installations concerned an undue advantage within the country

With the Decision of the European Comission of 26 October 2007 and the Decision of the EC of 04 December 2008 – Revision of Decision of the Comission of 26 October 2007, the total quantity of allowances to be allocated per year for the period 2008-2012 has been determined to be 42,433,833 t СО2, which reflected in significant decrease of the allowances to be allocated to each installation. In relation to this, has been made a change in the methodology of allocation at installation level. The previos methodology was based on the historical emissions for the period 2002-2004 and the prognosis for increase of emissions up to 2012. Considering the fact that the deadlines for submission of the first two reports of verfied emissions of carbon dioxide by all installations participating the the Scheme and holding GHG emissions permits have passed (31.03.2008 and 31.03.2009), the Interministerial Working Group on developing the NAP, pursuant to the Comission Decision, took decision the allocation of allowances to be based on the verified emissions from the annual reports for 2007 and 2008 of the operators of the installations participating in the EU ETS. The new methodology will ensure to the largest degree the equitable for all participants allocation and will ensure adherence to the criteria under Annex III of Directive 2003/87/ЕC.

Thus, the allocation of allowances at Installation level is based on the verified emissions from the annual reports for years 2007 and 2008 of the operators of installations participating in the EU ETS, corrected with the necessary reduction to adjust to total annually permitted quantity, by accounting for:

1. 
   The quantity of allowances, reserved for avoiding the effect of direct and indirect double counting effect from approved and supported Joint Implementation projects (that submitted Project Design Document (PDD) in MOEW before 31 June.2008);
   
2. 
   The planned reserve for New entrants.
   

The Directive and the European Commission recommendations from letter 30973/24.02.2009 suggest that the best available information is used for the allocation. Towards the moment of allocation of allowances (15.10.2009) this information includes data about the verified emissions of carbon dioxide of all operating installations for 2007 and 2008 and reliable information about the operation of the installations during this period. The best available information also includes new capacities placed into service and correction of volume by decreasing capacities during 2008, as well as information about the planned inauguration of new installations and decommissioning of installations during the period 2009-2012.