Eu Emmissions Trading Scheme

Can anyone help?

There is an impending deadline (end of Jan) where operators have to apply to the environment agency for a permit - for CO2 emissions.

The difficulty I have is that the official definition as prescribed in the EU Directive (2003/87/EC) is (surprise surprise) suitably ambiguous!

"Operator - means any person who operates or controls an installation or, where this is provided for in national legislation, to whom decisive economic power over the technical functioning of the installation has been delegated"

Where I am having difficulty is that we sub contract our energy / steam production plant which is wholly managed by the said third party. They cover maintenance / running & improvement of equipment. The significant fact is that the boiler plant is on our site.

Our sub contractor is of the opinion that we as the site owner and demander of the energy (to fit in with our production requirement) have the 'economic power' as such are the obligated party.

I personally see the interpretation differently - I agree that we say when we want the energy but does this mean we have control over the efficiency / CO2 emissions of the plant?

Doe anyone have any experiences of this?

Thanks

Richard

Richard,

Guess what...I haven't got a clue what you are talking about.

Regards,
Simon :P

Don’t worry - I just had a conversation with the EA and they have confirmed we are not obligated.. (Yet).

Anyway - thanks for your insight.. :P