Previously, as a plant operator, you had to submit the notification of operation to DEHSt by January 31 of each year. This is no longer the case. As of the 4th trading period, the notification of operation will be replaced by the allocation data report.
The allocation data report not only means a shift away from a capacity-based allocation calculation to a dynamic allocation concept with automatic annual allocation reductions or increases, but also administrative changes. Like the annual CO2 report, the allocation data report must also be submitted to DEHSt in verified form and this must also be done annually by March 31.
As with the operational notification, the allocation data report is a compilation of operational data intended to provide information on changes in the activity rates of your allocation elements.
In the future, allocation adjustments will be made according to the Allocation Data Report whenever the reported 2-year average activity rate deviates more than 15% from the historical activity rate noted in the allocation application. A new adjustment in the same direction within an allocation period is only made if the newly determined value is again exceeded or fallen short of by at least 5%. Only if the value falls below the 15 % threshold again will the original entitlement to free allocation be restored.
The aim of DEHSt is to adjust the free allocation to your current, actual operating status and to the demand for allowances.
Further information on the Allocation Data Report in the menu item Emission Knowledge.
What's the problem?
An incorrect or incomplete allocation data report can have a nasty impact on your company's coffers, considering that an automatic allocation adjustment is the consequence if the rolling 2-year average deviates more than 15% from the activity rate stated in the allocation application.
However, an allocation reduction is not the only scenario you may face as an operator. Missed chances for an increase of the free allocation as well as fines for omitted mandatory notifications up to 50,000 Euros can make life difficult for you as an operator.
In particular, we would like to point out at this point that an allocation adjustment made under certain circumstances does not have to be accepted without complaint. In order to prevent false incentives in the context of the application of heat or fuel benchmarks, DEHSt can refrain from an automatic allocation reduction if you can prove that a falling activity rate is due to an increase in efficiency. In the same way, DEHSt can also deny you an allocation increase if it can prove that an increased activity rate is not associated with an increase in production but is due to a deterioration in efficiency.
We can help you!
If you need concrete help for the preparation of your allocation data report in spring and do not want to take over the data entry into the special form management system (FMS) of the responsible authority DEHSt, please contact Emissionshändler.com® immediately to request an appropriate offer. We will take over the review and evaluation of your production data and related peculiarities, such as missing measured values, fuel changes, technical changes to the plant that affect the activity rates.
Subsequently, we take over the often time-consuming communication with your verifier in the course of the verification process on the one hand and the input of all data into the special Form Management System (FMS) on the other hand. All that remains for you to do is to transmit the completed allocation data report to the DEHSt via the virtual mailroom.
Do you feel that you have been treated unfairly because your allocation has been reduced or you have been denied an allocation increase? We would be happy to take a look at your situation and support you in presenting your interests to the DEHSt.