The Measures for the Administration of Carbon Emission Trading (for Trial Implementation) approved by the Ministry of Ecology and Environment was officially implemented on February 1. On March 1, the Regulations on the Administration of Pollution Discharge Licensing was officially implemented, providing a legal basis for the implementation of the pollution discharge licensing system with the supervision of fixed pollution sources as the core. The author believes that the promulgation of the "Regulations on the Administration of Emission Permits" can provide reference and reference for the formulation of higher level regulations on national carbon emission trading.

Implement classified management to reduce the management cost of the competent department. The Regulations on the Administration of Pollutant Discharge Permits proposed that pollutant discharging units should be classified according to the amount of pollutants produced, discharged or the degree of impact on the environment. In the future, the management of carbon emission report verification of key emission units under the national carbon emission trading can use this method for reference. In addition to classification according to the size of emissions, it can also be considered to distinguish according to the quality of enterprise data to further save management costs.

We will strengthen total emission control and achieve effective emission reduction. According to the Regulations on the Administration of Emission Permits, when applying for emission permits, the pollutant discharging units of new construction, reconstruction, expansion projects and technical transformation projects that discharge key pollutants shall also submit explanatory materials to obtain the total emission control indicators of key pollutants through reduction of pollutant emissions instead of reduction, so as to strengthen the total emission control of pollutants. At present, the total amount setting of the national carbon emission trading market is still based on the bottom-up total amount control. The author suggests that the future national carbon emission trading market should also be included in the total amount control as soon as possible.

Clarify the management requirements for data quality, standardize data records from the source, and strengthen corporate responsibility. The Regulations on the Administration of Pollutant Discharge Permit clarifies the provisions for enterprises to establish an environmental standing book system, standardizes the data records of enterprises from the source, and requires pollutant discharging units to be responsible for the authenticity and accuracy of the self monitoring data while conducting self monitoring. Data quality is an important basis for the stable operation of the carbon market. Next, we should strengthen the standardization of enterprise production and operation accounts and carbon emission related data records, ensure the quality of carbon emission data submission from the data source, and provide reliable evidence for back-end carbon emission verification.

Clarify information disclosure and strengthen cross departmental information sharing and result application. The Regulations on the Administration of Pollutant Discharge Permit requires pollutant discharging units to fully disclose information such as pollutant discharge and law enforcement inspection results, and the punishment decisions for violations should also be included in the national credit information sharing platform, strengthening the application of the credit information system. The author suggests that, in the next step, the contents of information disclosure can be refined, such as the disclosure of greenhouse gas emission reports and performance information of key emission units. While strengthening the punishment for enterprises that fail to perform on time, they should also be included in the national credit information sharing platform.

It is clearly included in the ecological environment law enforcement plan, and post supervision is strengthened. According to the Regulations on Emission Permit, the competent department of ecological environment should include the inspection of emission permit law enforcement into the annual plan of ecological environment law enforcement, which strengthens the connection between law enforcement and daily management. For enterprises participating in the national carbon emission trading system, the local ecological and environmental authorities at or above the municipal level with districts can determine the key points and frequency of supervision and inspection based on the verification results of greenhouse gas emission reports of key emission units, and supervise and inspect by means of "double random and one open". As an important part of the effective operation of the carbon market, the implementation of the carbon market should strengthen the supervision of carbon emission trading enterprises in the next step, and clarify the regulatory methods for greenhouse gas emissions and carbon emission quota clearing of key emission units.

Formulate strong penalty clauses to form effective deterrence. The Regulations on the Administration of Pollution Discharge Permits has increased the penalties for illegal pollution discharge, setting a fine of less than 50000 yuan and more than 1 million yuan for different illegal situations; At the same time, if the circumstances are serious, the violator may be ordered to restrict production, suspend production for rectification, suspend business, or close down; If a crime is constituted, criminal responsibility shall also be investigated according to law. Carbon emission trading is restricted by the legal hierarchy, and only a fine of 10000 to 30000 yuan is provided for violations, which is difficult to form an effective deterrent for enterprises that fail to perform. The formulation of the future regulations can refer to the punishment intensity of the Regulations on the Administration of Pollution Discharge Licensing and the punishment means for illegal acts, so as to effectively deter the enterprises that violate the regulations.

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