|Multiple heat producers, heat network and multiple consumers – how to collect data on carbon leakage exposures? - Page 3|
|Monday, 13 June 2011 06:00|
Page 3 of 3
Risks for heat producers
It is quite surprising, because the conclusion in the Guidance document that such data can be delivered by the heat distributor to the heat producer on the voluntary basis does not end the issue. Some further questions arise – is the heat distributor legally entitled to deliver such data to the heat producer assuming that the agreement between the heat distributor and heat consumer does not regulate the matter? In passing - it is quite probable, it does not regulate, because when the agreements were concluded the concept for carbon leakage exposure factor was hardly known.
At the end of the point 3.5 the Guidance Document n°6 states that, ‘Member States may ask for more information, if needed’. It seems that there really is a need to ask for more information as regards the said issue.