Other "loopholes" identified in the paper include a handout of 100m surplus ETS allowances, worth an expected €2bn, to nine countries to help them meet their emissions obligations on paper.
Those funds could potentially be at risk going forward if Poland does not live up to its stated RES and emissions obligations.
In some cases, private investors may also be eligible for carbon credits that can be traded or used to offset their emission reduction obligations.
The central piece of the CPP imposes emission reduction obligations on existing power plants — those that are in operation and spewing GHGs into the atmosphere.
The idea behind Redd is that developed economies with emission reduction obligations pay developing countries, where most of the world's major intact forests are found, for the service they provide in absorbing carbon dioxide from the atmosphere and locking it up.
The states urged the Supreme Court to take immediate action to block what they called a "power grab" under which "the federal environmental regulator seeks to reorganize the energy grids in nearly every state in the nation". Though the first emission reduction obligations do not take effect until 2022, the states said they had already started to spend money and shift resources.
The Kyoto Protocol, which has been the primary international agreement to reduce the greenhouse-gas emissions that cause global climate change, included mandatory emissions-reduction obligations only for developed countries.
This is achieved by distributing emission-reduction obligations away from the growers, and onto the emitters.
The paper distinguishes between a market effect of emissions trading and compliance costs for meeting the emission reduction obligation.
This is the instrument under Kyoto that allows wealthy countries to offset their emissions reductions obligations through investment in green projects in the developing world.
