|Multiple heat producers, heat network and multiple consumers – how to collect data on carbon leakage exposures? - Page 2|
|Monday, 13 June 2011 06:00|
Page 2 of 3
Carbon leakage exposure factor – evidence needed
Carbon leakage exposure factor can be 100 % (for entities exposed to carbon leakage) or less (for non-exposed entities) – see Article 10a(11) and (12) of the Directive 2003/87/EC.
As a general rule, the carbon leakage factor to be used is the carbon leakage exposure factor for the heat consumer, i.e. the importing sub-installation. The non-ETS entities are by default deemed not exposed to carbon leakage.
According to the Guidelines, the carbon leakage exposure factor to be used in both factual circumstances specified in sections 3.2 and 3.5 (i.e. generally, when heat is supplied to the heat network) is the carbon leakage factor for non-carbon leakage exposed sectors unless evidence on the carbon leakage exposure of the heat consumer can be provided. The share of heat delivered to carbon leakage exposed heat consumers on the total heat delivered applies to all ETS installations delivering the heat.
The case where the heat producer has a direct contractual relationship with the heat consumer is more manageable, the request for additional data can be submitted by the heat producer directly to the heat consumer, and, if needed, supported with mutually negotiated contractual amendment. As regards the intermediation of the heat distributor, the Guidance Document n°6 on the pages 20 and 37 makes the reservations that such data can only be delivered by the heat distributor on a voluntary basis as there are no legal obligations for these entities in the context of the data collection.
1) amount of heat to non-ETS-installations or entities (not private households, differentiated: carbon leakage/non-carbon leakage exposed) and
2) amount of heat to private households.