The EU emissions trading scheme (ETS): how linked to JI/CDM?

The paper first argues that the Directive for EU-wide greenhouse gas emission trading still carries a number of weaknesses, such as: <list> <list-item> • still no clear link with other climate policies in the Member States; </list-item> <list-item> • the subsidiarity with regard to the allocation of allowances may distort intra-EU competition; </list-item> <list-item> • lack of clarity as to what the (future) scope and coverage of the scheme may look like. </list-item> </list> Then, it is argued that not convincingly linking the scheme to the flexibility instruments of the Kyoto Protocol, JI and CDM, or establishing such a link only later or based on some supplementarity rule, not only carries a number of risks, but may also be circumvented by the Member States using their freedom with regard to their national climate policy design.