This is also an effect of the merit order (Figure 7). Keppler and Cruciani (2010) have estimated these windfall profits for the utility sector as a whole at more than EUR 19 billion for the first phase of the EU ETS, and state that this phenomenon will only be partially mitigated by the auctioning of emission allowances from 2013 on. From this perspective, the interaction between RE and C02 policy instruments, which work in opposite directions in transferring wealth from utilities to industry customers and vice versa, tend to off-set each other's effects, at least in part.