15 August 2016

Morgan Foundation's Climate Cheats II: Who’s the Real Cheat Here? The Dozen Dirty Now thats a title!

Geoff Simmons and the Morgan Foundation have done it again! They have just released a sequel to 'Climate Cheats', the fantastically-named 'Who’s the Real Cheat Here? Climate Cheats II: The Dozen Dirty Businesses'. Simon Johnson breathlessly reviews Climate Cheats II and concludes that while it's about time we had some transparency over Government and corporate shenanigans with emissions trading, we mustn't forget that these are symptoms of the root problem - the uncapped design of the New Zealand emissions trading scheme.

Shock Newsflash Horror! The Morgan Foundation and Geoff "Wild-Shirt" Simmons have done it again! They have just released another tell-all critique of corporate emissions trading shenanigans! A sequel in the franchise they started in April 2016 with the report Climate Cheats. As we know, 'Cheats I' outlined this sad course of events:

  • the 'flood' of low-cost and low-integrity Russian and Ukrainian emissions reduction units into the NZ emission unit market
  • which then crashed the domestic emission unit price
  • which allowed NZ emitters to meet emissions trading obligations for next to nothing
  • which allowed the Government to own surplus (but dodgy) units
  • which meant Paula Bennett could claim 'form over substance' compliance with climate charge targets out to 2020
  • not withstanding the real increases in both gross and net NZ emissions of greenhouse gases.

Weighing in at a thankfully concise 16 pages, the wonderfully named 'Who’s the Real Cheat Here? Climate Cheats II: The Dozen Dirty Businesses' starts with a simple question. Which companies had the most dodgy Russian and Ukrainian emission units? Well, here they are.

Simmons and co then note that Minister Bennett has refused requests to cancel the surplus dodgy units the Government holds, giving the excuse she is 'seeking advice' (That would seem to be a perpetually applicable excuse!). So they ask 'who owned and used dodgy emission reduction units?' The dirty dozen corporates, of course.

The report then discusses three types of liability (physical, liability and transition) that may fall on companies who used the emission reduction units. To paraphrase, Simmons is thinking 'did they really think this would never come back and bit them?' And he is making the point that if Government is failing to act ethically, then why don't we shine a spotlight on our corporate citizens and ask them to shoulder some of the responsibility for the dodgy unit fiasco?

Simmons assigns highest culpability to New Zealand Steel and Fonterra. Because they are emitters who received generous free allocations of NZ units but who also owned dodgy emission reduction units. Referencing a blogger (meaning me!), the report notes New Zealand Steel booked $4.4 million Australian dollars of profit from emissions trading that is probably from arbitrage trading of their free NZ units while also owning dodgy units.

Five forestry companies are on the dozen list. Some sympathy is due to some of them as the unit price crash devalued their allocations of units. But none is due to any foresters who carried out 'forest re-registration arbitrage' in the ETS. This was exiting and re-entering the same forest in and out of the ETS several times. For each ETS 'exit', the forester would 'square-up' the refund of carbon liabilities with emission reduction units costing several cents each. For each 're-entry' to the ETS, the forester would be given an allocation of free NZ emissions units worth a few dollars each. The result being instant no-effort windfall profits. The Government took far to long to clamp down on this practice.

Finally, energy companies get their turn in the spotlight. BP, Chevron, Z Energy, Contact Energy and Genesis Energy all owned and used some dodgy international units. Did these companies price their products to NZ customers on the basis of the higher NZ unit prices or the lower dodgy unit price? The Morgan Foundation approached the energy companies for comment which is in an appendix. All give worthy statements saying they followed the rules and of course they put customers first. However, Mobil shows up the fine words of the others. Mobil never owned any dodgy international units and managed to supply fuel just as competitively as the others.

Climate Cheats II concludes by suggesting that the companies who owned dodgy international units and lowered their costs (as well as those who made windfall profits) have two options to put things right.

  1. They could voluntarily cancel NZ units to match the dodgy units used
  2. They could alternatively pressure Paula Bennett to cancel the surplus units the Government holds.

With NZ emission unit prices now hovering between $17 and $18 per tonne, the latter option will hurt much less than the former.

In summary, it's hard not to like a Morgan Foundation report that references me! But leaving that bias/good taste aside, Climate Cheats II is a concise readable summary of the abject state of New Zealand's emissions targets and trading policies and practices. As Kevin Anderson would say, we need to see clearly where our rose-tinted spectacles have brought us. Climate Cheats II mostly does that.

However, if anything, the report, by focusing on the top dozen owners of the dodgy international units, underplays the persuasiveness of the ownership and use of those international units. Most entities with emissions trading accounts owned some dodgy units. In 2013, more than 400 entities (out of 496 account holders) owned some share of the almost 35 million emission reduction units in private hands. You can check this with this Google sheet of Kyoto Units obtained from the Emission Unit Register at the EPA.

Finally, I have one concern which is perhaps more about how 'Climate Cheats II' will be received rather than what message it has. It seemed to me that the media response to initial splash of 'Climate Cheats I' (they loved the emotive framing - 'fraud!' - 'cheating!') really missed the fundamental point that I think both reports support, and that other assessments of the ETS support, that an emissions trading scheme that has no cap on emissions, that earns no revenue and that isn't economy-wide, is an excuse and rationalisation for doing nothing and not an effective mitigation policy at all.

08 August 2016

Where is the Two Degrees Celsius Carbon Budget for New Zealand?

I have been reading up about carbon budgets on and off since the Paris Agreement at COP21 last December.

By 'carbon budget' I mean "a finite amount of carbon that can be burnt before it becomes unlikely we can avoid more than two degrees of global warming". And I have been asking myself "where is New Zealand's carbon budget that is consistent with no more than two degrees Celsius of average global warming"?

I see that Canadians Simon Donner and Kirsten Zickfield asked themselves similar questions about Canadas contribution to meeting the Paris temperature targets and Can Canada live up to the promise of the Paris Agreement? The chart on the left shows three Canadian 'temperature' budgets/emission pathways under a share of emissions approach.

In short, Donner and Zickfield have calculated several "2C"-consistent carbon budgets, based on a range of temperature goals, a range of probabilities of success, and a range of sharing principles used for allocating part of the global carbon budget to Canada. They wrapped that up in a short 3-page paper "Canada’s Contribution to meeting the temperature limits in the Paris Climate Agreement".

Simon Donner also wrote a more policy-oriented summary What do the temperature targets mean for Canada?

This is their summary table of budgets by temperature targets and probabilities.

Simon Donner's conclusion from Can Canada live up to the promise of the Paris Agreement is:

The analysis in our report suggests that the current Canadian target of a 30% reduction below 2005 levels by 2030 could be consistent with maintaining a likely chance (66%) of limiting warming to less than 2°C globally, but only if Canada is given a generous allocation of the world’s “remaining” future carbon budget (based on the present fraction of the world’s emissions). A target consistent with a likely (66%) chance of avoiding 1.5°C of warming globally is extremely limited regardless of the method of allocation. Even under a generous allocation to Canada, national net CO2 emissions would need to decline 90-99% below 2005 levels by 2030.

Simon Donner also notes that "The 1.5°C limit is “at best unrealistic, at worst politically impossible.”

Simon Donner is also highly aware that 'sharing-on-current-emissions' unfairly favours developed highly carbon-intensive OECD countries like Canada (or New Zealand) over the developing countries with much lower greenhouse gas emissions per capita.

Allocating the remaining carbon budget based on present-day emissions places an unfair burden on developing and rapidly industrializing countries that historically have had low per-capita emissions. Despite being far less responsible for climate change to date, and currently having low per-capita emissions, countries like India would essentially be asked to bear an equal part of future mitigation efforts.

Good work Canada! But where the bloody hell is New Zealand's 2C consistent carbon budget?

25 July 2016

Kevin Anderson Beyond Dangerous Climate Change Does Paris Lock-out 2 Degrees?

There is another new talk by Kevin Anderson. The image is his title page and the title is Beyond Dangerous Climate Change: Does Paris Lock-out 2 Degrees?.

Kevin Anderson gave the talk on 9th of March 2016 to the Institute of International and European Affairs which is Ireland’s leading think tank on European and International affairs. They describe his message in this way.

In his presentation, Kevin Anderson revisited the scale of the climate challenge, arguing that whilst the science of climate change has progressed, there has been no corresponding acknowledgement of the rate at which our emissions from energy need to be reduced. He suggested that the Paris Agreement exemplifies this duality. Similarly, he argued that the focus on green growth continues to eclipse analysis which demonstrates the need for radical social as well as technical change. Prof. Anderson developed a quantitative framing of mitigation, based on IPCC carbon budgets, before finishing with more qualitative examples of what a genuine low-carbon future may contain.

Anderson's key message is that due to the constant privileging of economic analysis over physics, the finite carbon budget consistent with no more than two degrees Celsius of average global warming will only be achievable with an "outside" probability of 33% if the developed countries suppress energy demand and reduce carbon dioxide emissions by 10% each year and fully de-carbonise their energy sectors by 2035.

The talk is available as a podcast in mp3 format. Also available is Kevin Anderson's slide presentation.

The talk is also available on Youtube in two parts. Part One has had 1,975 views. Part Two has had 664 views.

I usually browse with Firefox and I have installed an add-on called Down load helper. That enables me to download talks as mp4 files I can listen to later.

There are two differences from the talk given to the University of Sheffield. The sound is a bit boomy and not as clear as the University of Sheffield recording. And when Kevin Anderson says "people with grey hair or no hair have failed the generation born since the IPCC was established", the grey-hairs seems to be the audience from the two in the foreground.

19 July 2016

New Kevin Anderson talk Delivering 2 Degrees Triumph and Tragedy in Paris

The other day I noticed that Kevin Anderson has tweeted a new talk.

Anderson spoke at the University of Sheffield on 28 April 2016. Anderson's host was the Carbon Neutral University Network Sheffield and they provide a fulsome description of Anderson's 47 minute talk. However, you should watch it for yourself or better still download the talk from Youtube. The sound quality is very good.

06 July 2016

Minister for Climate Change Issues Paula Bennett and the surplus emission units

A wee while ago, back on 23 May to be precise, I wrote an open letter to Minister for Climate Change Issues Paula Bennett calling on her to cancel the surplus Kyoto emission units held by the Crown.

I received an undated reply from Bennett on Monday 4 July 2016.

To crudely sum it up, Bennett's reply is "No we won't cancel any units. Those bad bad Ukrainian units! It was bad. But we stopped being bad, we won't bad again, at any rate no more bad than any one else!"

Here is the text of Bennett's letter. For reference, I have put the text of my open letter at the bottom of this post.

Thank you for your letter of 23 May 2016 about surplus Kyoto Protocol assigned amount units.

As you say, the Government has a surplus of 123.7 million Kyoto Protocol emission units which were left over after we retired units to meet our target for the first Kyoto commitment period.

I accept that there were up to 97 million Emission Reduction Units (ERUs) bought and surrendered in the New Zealand Emissions Trading Scheme (NZ ETS) before the Government stopped accepting them. That was within the rules, but we now know many of the ERUs are likely to have had poor environmental integrity. We are not accepting international units now, and we are working hard to make sure any international units traded in the NZ ETS in the future are of high environmental integrity. We are reviewing the NZ ETS to make sure it will be fit for purpose in the future.

As we have said in the past, we will meet our target of -5 per cent by 2020 using a combination of domestic abatement, forestry removals, and some international purchasing. There is information about the target on the Ministry for the Environment website at www.mfe.govt.nz.

We have not made a decision about what to do with any Kyoto units that are left over after we have met the 2020 target.

Nearly all other Kyoto developed countries also have surpluses. Some of them have said they will cancel units, but haven't actually cancelled them yet. There is no urgency to do anything with these units, and the fact that we are not cancelling them at this stage doesn't put us out of step with other countries.

Let's look a little harder at three statements in Bennett's letter.

  1. "We are not accepting international units now"
    Bennett is implying that the New Zealand Government made an express decision to stop the importing of some low-integrity international emission units. In fact, New Zealand ended up with no access to international carbon markets when Tim Groser told the UNFCCC that New Zealand was not going to have a formal emissions reduction commitment under the Kyoto Protocol for 2013 to 2020. Ms Bennett and the Ministry for the Environment should stop implying that some positive decision was made. Its just not true.
  2. "we will meet our target of -5 per cent by 2020 using a combination of domestic abatement, forestry removals, and some international purchasing."
    The translation of this spin back into plain language is 'we will still be using creative carbon accounting' to pretend we are reducing emissions when we know we are not. Bennett should really stop saying such a disingenuous statement. The Ministry for the Environment's 2020 Net Position Statement still explicitly shows the 123.7 million surplus units plugging the gap.
  3. "not cancelling them... doesn't put us out of step with other countries"
    Heaven forbid that New Zealand should be out of step with the many other countries who are also doing nothing about climate change!

My open letter to Paula Bennett - Your ethical duty to cancel 124 million surplus assigned amount units

Dear Minister,

I see that last Friday (20 May 2016) the Ministry for the Environment released New Zealand's Greenhouse Gas Inventory 1990–2014 and the summary 'Snapshot'.

I see that in the Snapshot summary on Figure 5, page 5, that New Zealand is still intending to use 123.7 million emission units (Assigned Amount Units or 'AAUs') that were 'surplus' from the Kyoto Protocol first Commitment Period to meet the 2020 emissions reduction target and still have a surplus of 92.6 million units.

You are aware that the Morgan Foundation's report 'Climate Cheats' and the Stockholm Environment Institute report (Kollmuss, Schneider and Zhezherin 2015) set out a persuasive case that the 97 million Emission Reduction Units ('ERUs') that were imported to New Zealand were “questionable or of low environmental integrity”. Those ERUs were surrendered by NZETS participants into Crown holding accounts.

According to the Kyoto Protocol 'True-Up' Report, in December 2015, the Ministry for the Environment cancelled (transferred Crown-owned units to cancellation accounts) 373 million emission units to comply with the Kyoto Protocol. The numbers and types of units cancelled were: the 97 million imported ERUs, 16 million imported Certified Emission Reduction units ('CERs'), 81 million removal units ('RMUs'), and 179 million AAUs . The 'surplus' units remaining in Crown holding accounts were 124 million AAUs.

In a nutshell, the only reason New Zealand (the Crown) has so many 'surplus' AAUs is because of the inflow and use of the dubious ERUs in the NZETS. Each dubious imported ERU has allowed one additional AAU to be carried forward in a Crown holding account as a 'surplus' unit. Because the ERUs have no credibility, the AAUs no longer represent carbon safely stored out of the atmosphere. No emissions were reduced. Therefore to use these surplus AAUs to comply with the national 2020 emission reduction target is simply an exercise in creative carbon accounting. It is simply unethical.

I put it to you that as Minister for Climate Change Issues, you are morally obliged to cancel these surplus units owned by the Crown. Will you cancel the units? It may hopefully to some small extent restore New Zealand’s very tarnished reputation with respect to mitigating climate change policy.

Yours sincerely

30 June 2016

Turn off Meridian open letter to Mark Binns on why I am divesting from coal-pushing Meridian Energy

When is a renewable electricity generator not a renewable electricity generator? Or what do you do when the electricity generator who are claiming to supply your home with 100% renewable electricity enters into a commercial contract that keeps a coal-thermal power station emitting carbon dioxide for an additional four years?

Meridian Energy has recently signed a contract with Genesis Energy to keep the Huntly coal thermal power station open for four more years instead of closing in 2018.

New Zealand has made some predictions of future reductions in emissions that we have confidently sent off to the United Nations Framework Convention on Climate Change (UNFCCC). Unfortunately Meridian's action has had the effect of sending the emissions savings up in a puff of coal smoke.

So I decided to divest from Meridian Energy and move my account to electricity supplier to Ecotricity who own only 100% renewable generation capacity and who are certified as carbon neutral. I used the Consumer Power Switch website. There is also Whats my number web site.

I thought I should let Meridian Energy know I was voting with my account so I sent this open letter to Meridian Energy two weeks ago on 16 June 2016. I have not yet received a reply.

Mark Binns
Chief Executive
Meridian Energy Limited
PO Box 2128
Christchurch 8140

16 June 2016

Re: Meridian Energy’s support for four more years of thermal coal electricity carbon dioxide emissions from Huntly Power Station

Dear Mr Binns,

I am a Meridian retail customer. My customer number is TrJ5I19vcteK2 My account number is 1.h@"]41Y6x#5-r.

I consider climate change to be a serious risk that we are all morally obliged to respond to. In 2012 I deliberately chose Meridian as my electricity retailer because of it's 100% renewable generation.

I am aware that to some extent the electricity I consume inevitably draws on some fossil-fueled capacity due to the networked nature of the grid. However, I was satisfied that choosing Meridian as my retailer was the best I could do in terms of reducing carbon dioxide emissions as I would not be contributing my money to any fossil-fueled thermal generation. In the past four years I have been very happy with that choice and with the service I have received from Meridian. Unfortunately, I did not know that Meridian had a contract with Genesis to keep the Huntly coal thermal power station operating to 2018.

On 28th April 2016, Meridian Energy announced that it had signed a new contract with Genesis Energy that would keep the Huntly coal thermal power station operating for an extra four years. This contract therefore postpones the expected closure from the planned 2018 date to 2022. I have read the statement on the Meridian website explaining the contract as a means of reducing the risk of low levels in the hydro lakes. The explanation fails to take climate change seriously.

The Fifth Assessment Report of the IPCC sets out very simply the carbon budget consistent with limiting global warming to less than two degrees Celsius. The global warming we will experience will be linearly proportional to the cumulative volume of carbon dioxide emissions emitted by humanity. To prevent further dangerous levels of warming with a reasonable probability, cumulative emissions cannot exceed the carbon budget. At that point, emissions must not exceed net zero.

As a matter of physics, the additional emissions that will come from Huntly for the extra four years will result in higher and more dangerous eventual global warming. Meridian Energy's actions have facilitated these additional emissions.

I find Meridian’s actions to be completely contrary to the IPCC's finite carbon budget conception of mitigation and with Meridian’s previous statements on renewable electricity. Those statements now appear very shallow and insincerely held to say the least.

Therefore, it gives me some satisfaction to inform you I am moving my electricity account to a 100% renewable electricity generator who has carbon neutral certification and who is not a party of the Huntly contract. It is my sincere wish that as many customers as possible who are concerned about climate change also leave Meridian.

Yours sincerely

18 June 2016

Emissions Trading Scheme unit allocations are open data but units surrendered and actual emissions are state secrets

It would be good if we could compare actual company emissions under the NZETS to the generous free allocations of unit some entities receive. But we can't. It's half secret. So how will we ever know if allocations are excessive?

Someone recently asked me if there was enough publicly available information to be able to tell how the free allocation of NZ emission units to some privileged ETS participants under the NZ Emissions Trading Scheme related to the emitters actual emissions of greenhouse gases.

This information would be the number of emission units allocated to some emitters on the one hand, and on the other hand, the actual emissions of the emitters as reported to the Environmental Protection Authority and the actual numbers of corresponding emission units they surrender to the Environmental Protection Authority.

I replied "No, the data is not available". A response which, although it contains a grain of truth, still doesn't reflect the whole story. So this post is an attempt at that story.

In the past few years, I have written several posts about the significance of the free allocation of emission units to New Zealand Aluminium Smelters Ltd, Norske Skog Tasman and New Zealand Steel. In each case I concluded that the free allocation of units (including units for energy costs) were excessive. That these were cases of 'over-allocation'.

In those posts I had to make estimates of the actual emissions and actual units surrendered. Although the Ministry for the Environment completely discloses the annual free allocation of units, neither the Ministry or the Environmental Protection Authority report the emissions and units surrendered by entity.

As I noted recently I have compiled a Google sheet of all units allocated to emitters from 2010 to 2014.

So good on the Ministry for the Environment. A while ago I made this pie chart of the 2011 allocations from the Ministry. Yes, awful rainbow colours I know! But it still makes it clear that the vast bulk of free units get allocated to the top ten or so emitters - who happen to also be some of New Zealand's largest and most influential companies.

I was running out of emitters like NZ Steel and NZ Aluminium Smelters Ltd who both have unique operations. Both are the only example of their industry in New Zealand. So I could look at 'category' emissions for 'aluminium smelting' and 'steel making from iron sands' in the Ministry for the Environment's greenhouse gas inventory reports and be confident the category emissions were the same as the company emissions.

So, back on 28 March 2013, I made a request under the Official Information Act (OIA) to the Environmental Protection Authority, who administer the reporting of emissions and surrendering of units in the ETS.

I asked for number of units surrendered by the top eleven ETS participants (New Zealand Steel Limited, New Zealand Aluminium Smelters Limited, Methanex New Zealand Limited, Fletcher Concrete and Infrastructure Limited, Ballance Agri-Nutrients Limited, Holcim (New Zealand) Limited, Carter Holt Harvey Pulp & Paper Limited, Pan Pac Forest Products Limited, McDonalds Lime Limited, Winstone Pulp International Limited, Whakatane Mill Limited) for 2010 and 2011.

On 18 April 2013, the Environmental Protection Authority declined my request.

On 19 April 2013 I made a complaint about the EPA decision to the Office of the Ombudsman.

Almost a year later, on 8 April 2014, the Ombudsman concluded his investigation and said that the EPA were correct in refusing to give me the information as the Climate Change Response Act 2002 explicitly applies to the surrender of units in priority to the Official Information Act 1982.

The Deputy Ombudsman Leo Donnelly advised that he agreed with the EPA view that they did not have to provide the information on units surrendered. This is the key passage from his letter dated 8 April 2014.

"I am not persuaded that the Official Information Act is an Act that provides for the disclosure of information in s 99(2)(a) of the Climate Change Response Act.
The Official Information Act confers a right to request official information and requires that such requests be processed in accordance with its provisions, but those provisions do not provide for the disclosure of information under the Climate Change Response Act (or any other Act that imposes restrictions on the availability of official information).
Instead, section 52(3)(b)(i) of the Official Information Act provides that nothing in that Act derogates from any provision which is contained in any other Act which imposes a prohibition or restriction in relation to the availability of official information. Section 99 is such a section.
Accordingly, the Official Information Act does not override the restrictions imposed by section 99 of the Climate Change Response Act and it would be contrary to that section for the requested information to be made available to you. Consequently, section 18(c)(1) of the Official Information Act provides a reason to refuse your request on that basis."

I was bloody disappointed with that response. Here is the Ombudsman's letter. I also didn't know that the Official Information Act only applies if another statute allows it too. I will look at the relevant sections in detail.

Section 52(3)(b)(i) of the Official Information Act states;

(3) Except as provided in sections 50 and 51, nothing in this Act derogates from—
(a) ....
(b) any provision which is contained in any other Act of Parliament or in any regulations within the meaning of the Regulations (Disallowance) Act 1989 (made by Order in Council and in force immediately before 1 July 1983) and which—
(i) imposes a prohibition or restriction in relation to the availability of official information;...

So if another statute (or regulation) prohibits or restricts the availability of official information, then that statute or regulation applies irrespective of the Official Information Act.

Section 99 of the Climate Change Response Act certainly appears to prohibit the availability of information. It states;

This section applies—
(a) to the chief executive, the EPA, an enforcement officer, and any other person who performs functions or exercises powers of the chief executive, the EPA, or an enforcement officer under this Part and Part 5; and
(b) at the time during which, and any time after which, those functions are performed or those powers are exercised.
(2) A person to whom this section applies—
(a) must keep confidential all information that comes into the person’s knowledge when performing any function or exercising any power under this Part and Part 5; and
(b) may not disclose any information specified in paragraph (a), except—
(i) with the consent of the person to whom the information relates or of the person to whom the information is confidential; or
(ii) to the extent that the information is already in the public domain; or
(iii) for the purposes of, or in connection with, the exercise of powers conferred by this Part or for the administration of this Act; or
(iiia) for the purposes of, or in connection with, reporting requirements of the Public Finance Act 1989; or (iv) as provided under this Act or any other Act; or
(v) in connection with any investigation or inquiry (whether or not preliminary to any proceedings) in respect of, or any proceedings for, an offence against this Act or any other Act; or
(vi) for the purpose of complying with any obligation under the Convention or the Protocol.
(3) A person to whom this section applies commits an offence under section 130 if the person knowingly contravenes this section.....

So why does the Ministry for the Environment publish the annual allocations of units on its website? Why is the policy for unit allocation effectively open data (with complete public disclosure) when the policy for emissions and units surrendered in the ETS, the policy is 'Official Secrets Act?

The answer is the perfect bureaucrat's answer, because the Act says so. Section 86B Decisions on applications for allocations of New Zealand units to industry and agriculture of the Climate Change Response Act states:

(5) The EPA must, as soon as practicable, after deciding an eligible person’s final allocation for an eligible activity in respect of a year,—
(a) publish the decision in the Gazette; and
(b) ensure it is accessible via the Internet site of the EPA

Where does this leave us? It's the old story of the three-handed forestry consultant. 'On the one hand, on the second hand, but on the third hand..' Its great that the data on free allocation of units to emitters is fully disclosed. I am sure many of them wouldn't want that. However, without data on units surrendered and actual annual emissions under the ETS, no one can make much of an assessment of whether the units allocated are reasonable or over-allocated in terms of exceeding actual emissions. Transparency (and legitimacy) would be very much improved if the actual emissions and unit surrenders were just as open as the unit allocations