2. Another difficult choice in the context of the emission factor used for the calculation of state aid is whether to take into account for this purpose actual terms of supply of electricity for the installation concerned (self-generation and electricity supply contracts that explicitly specify the level of pass through of the EUA price per MWh) or the average CO2 emission factor for the EU, irrespective of the real situation of the particular companies. This is the choice between the methods 1-3 on the one side, and the method 4 on the other.


It could be supposed that the situation where electricity supply contracts  explicitly specify the level of pass through of the EUA price per MWh will be rather rare and exceptional. Also the self-generation won’t probably be the most common point. I suppose that the most representative situation will, in practice, be the purchases of electricity not covered by the two instances mentioned above. For solving this issue would be helpful, however, the empirical data on the scale of self-generation in the industry concerned. If the scale of this phenomenon is marginal, maybe it could be passed over as a case that has no impact on the whole issue.


It is necessary to mention that the said questionnaire marks off also the method 1, where the CO2 factor of the marginal plant setting the electricity price for the installation concerned is used (where electricity is purchased on the grid), but it seems that the reasons for simplicity and avoiding excessive administrative burden not opt for this variant.


To conclude, it is surprising that the very Directive has gap in it’s wording as regards such a pivotal element like an emission factor.