Well here's a suggestion: Forget the whole thing.
Not just the free allocation of 55 million tradable credits but the policy for which it is a partial offset, the retrospective deforestation tax.
andIn the meantime, while we wait and see what international rules emerge, it would seem to make sense for the Government to shelve plans to devolve the deforestation liability, and avoid the complications around the associated allocation of free units.
It should focus more on what will encourage the afforestation of a millon hectares of bare, erosion-prone land and less on locking in what may be a sub-optimal use of country already forested.
All those confused by policy in this area (it is complex) and the potential implications of this policy should read Fallow's article.We see a further benefit to the following of Fallow's advice. We would not need to rush through ill thought out policy this year! Right now, the rush is on because the Crown is wanting to limit its potential Kyoto liability (though others suggest that winning the General Election might also be a factor).