Allowance allocation in the European emissions trading system: a commentary

We review the total allocations under the EU ETS first phase and compare these against historical emissions, projections, and national Kyoto targets. We conclude that most Phase 1 allocations are excessive on all these measures, particularly the last, and argue that this is potentially damaging in several respects. We argue that: fundamentally different allocation methodologies (that avoid updating and referencing against projected emissions) must be considered for Phase 2; that industrial concerns about competitiveness should be carefully scrutinized on a specific sub-sector basis rather than taken as a generic reason for generous allocations; and that EU-level institutions should agree stronger guidelines to ensure a greater degree of coordination, comparability and transparency in Phase 2 national allocation plans.