The presentation at issue further points out that the regulation and resulting compliance obligation must:
1) facilitate an appropriate and timely price signal,
2) minimize unintended market signals that would inhibit or interfere with market structure or operation,
3) treat all first deliverers equally, whether they are in-State generators or electricity importers.
Notably the last-mentioned argument - concerning a necessity for equal treatment of domestic electricity generators and electricity importers - is convincing. The other two are, however, equally appealing. Why this argumentation has not been considered so far as a sufficient basis for re-examination of certain assumptions formulated while adopting the climate-energy legislative package - it remains unknown.
As opposed to California, the EU ETS regulatory approach does not assign the first deliverer as the point of regulation. It seems, however, doubtful whether such a stance is viable any longer.