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186 WASTE HEAT AND EUROPEAN CLEAN ENERGY POLICIES Diagram no. 9: Allowances Purchased by Method of Generation The formula for type (c) process emissions is designed to minimise this discrepancy by subtracting hypothetical reference emissions from the historical activity level of the installation. However, the surprisingly low emission factor of waste heat electricity suggests that the energy content implied by the default value of a 75/25 mix might need to be adjusted in favour of a higher hypothetical CO-share, ultimately decreasing the historical activity level eligible for free allocation and increasing the inherent allowance bill of waste heat electricity. On the other hand, the competitiveness of the primary product, which the allowances are allocated and must be surrendered for, must not be impaired by considerations of a potential market distortion caused by waste heat electricity, if this distortion is only of minor relevance. Moreover, it should be kept in mind that a non-quantifiable amount of grid electricity needs to be taken in first so as to trigger and maintain the reduction process, effectively increasing the allowance bill for waste heat electricity. Moreover, it should be noted that the number could change dramatically if the production of ferro- alloys lost the status of being exposed to a significant risk of carbon leakage and accorded the regular CLEF. 5.2.3 Conclusion on the Delivery of a Level Playing Field The comparison of the relevant allocation levels produced the following results: Electricity from industrial waste heat receives fewer allowances than the combustion of waste gas for the generation of heat, but it also reduces the allowance bill rolled over by power suppliers. The number of allowances the operator has to purchase is higher than in the case of renewable energies, but lower than in the case of mean grid power energy. The rules on free allocation have a potential of distorting the respective markets only in relation to the latter. Here, the subtraction of reference emissions from the historical activity level fails to balance the disparate allowance bills of waste heat electricity and grid electricity. Therefore, the default value for the off-gas mix (and hence, for the energy content of the off-stream) could be adjusted. Beforehand, however, the actual market distortion caused by this difference needs to be evaluated by an economic analysis, as the adjustment would primarily reduce the allocation level for the ferro- alloy production and impair its global competitiveness. This must not be made without prior comprehensive deliberation. 5.2.4 General Conclusion Electricity generation from industrial waste heat adds significantly to the efficiency of the carbon-intensive process of ferro-alloy production; for that reason, the installation of corresponding turbines should be in the interest of both operators and policy-makers. The rules governing the free allocation of emission allowances fail to provide explicit incentives to install respective capacities through appropriate product benchmarks orPDF Image | ELECTRICITY PRODUCTION FROM INDUSTRIAL WASTE HEAT
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