The carbon market From a Carbon Price to Carbon

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							         The carbon market
From a Carbon Price to Carbon Finance

            Patricia Rosenthal, Environmental Markets Originator




20 April 2010             Designator | author                      1
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 2




Agenda
 Fortis Carbon Banking

 Overview of Carbon Markets

 Origination – Kyoto Mechanisms

 Financing with carbon Assets

 Final Remarks
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 3




Fortis Carbon Banking
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 4




Fortis – Global Leader in Carbon
 Fortis is a global leader in the carbon markets with a wide array of offering and has been involved since the inception of the carbon markets.Today
  we serve more than 200 clients in their carbon needs
 We have a dedicated team of specialised sales and analysts in carbon who can give you specialised market insight and intelligence
 As a major investor in the European Carbon Fund (investing 15 million Euros), we have built up considerable experience combining commercial
  and legal expertise in the CDM & JI approval processes and the associated risks




                  – March 2004: Executed first trade under the EU ETS
                  – June 2004 Executed first trade under the ISDA agreement winning Carbon Deal of the Year
    2004          – November 2004: Became co-sponsor of and investor in the European Carbon Fund


                  –   May 2005: Started offering carbon clearing services
                  –   October 2005 Won best diversified financial and launched its Climate Change Leadership Index
    2005          –   November 2005: Signed landmark deal with European Carbon Fund for placing over 50 million tonnes
                  –   December 2005: first index-based carbon compliance trade

                  –   January 2006: European Carbon Fund awarded Most Promising investment Opportunity
                  –   February 2006: Structured and executed first ever CER call option deal
    2006          –   April 2006: Concluded first complete second phase strip transaction from 2008-2012
                  –   September 2006 „Best in Class‟ for our excellent approach to climate change (Carbon Disclosure Project survey report)
                  – Launch of Carbon Neutrality Programme
                  – June 2007: selected by the United Nations as the Financial Services Provider (FSP) to the UN Millennium Development Goals
    2007            (MDG) Carbon Facility which will deliver 15 million Kyoto Credits. Fortis provides carbon services including custodian, financing,
                    purchase of credits and credit marketing tools
                  – September 2007: Fortis wins the first ever carbon auction in Brazil and acquires 808,000 CER‟s from the Sao Paulo government
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 5




Fortis: new products for the emerging carbon markets

Carbon Financial Services                 Trading Services
Accepting returns in carbon               Trading on demand or to order
Including carbon value in financing       Index based
and due diligence                         procurement/divestment
Clean Development Mechanism               CER purchasing and sales
project financing                         Delivery date swaps (quasi repos)

Administration and Trust                  Investing in and developing
Managing customers carbon                 funds
accounts                                  Co-sponsorship of the European
Custody of other Kyoto Compliance         Carbon Fund to ensure reliable
Units                                     deliveries of Kyoto Compliance
Fund custody and administration           Units for customers

Clearing
                                          CDP Climate Leadership 2006 – Top 50 Global

Eliminate counterparty risk and           Co-sponsor and guaranteed placement CP for European Carbon Fund
                                          Initiated index based position management contracts for customers
guarantee trades
                                          Trading on behalf of >100 customers
Cross commodity correlation model         Cross selling successfully with trust, custody, escrow & settlement
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 6




FORTIS BANK SUITE OF PRODUCTS FOR THE EMERGING
CARBON MARKET
Fortis has been trading the EU ETS for 3 years and offers a wide            Liquidity access
range of products


Spot contracts                                                              Fortis has market access via 10
All standardised Forwards                                                   brokers, 3 exchanges and a large
Listed Futures and Options                                                  number of actively trading
                                                                            companies throughout Europe
Delivery date swaps (quasi-repo)                                            allowing to offer competitive pricing
Bespoke cross commodity solutions including CER structures




Index based products                    On demand purchases and             Contracts
                                        sales
The customer buys or sells a
                                                                            Fortis uses the standard ISDA
predetermined quantity of EUAs over     The simplest form of market         master agreement annex, the IETA
a specified period of time at the       access. The customer simply calls   master agreement and the IETA
average ECX closing price for the       Fortis for the market price and     single trade agreement. Examples
period. This has the advantage of       decides whether to deal or not      can be obtained on request.
smoothing out the inter and intra day
                                                                            Recently adopted the GRV
volatility seen in the market.
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 7




Overview of carbon Markets

-   Kyoto Protocol
-   EU ETS
-   Voluntary Market
-   Difference – CER/ERU, EUA, VER
          UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 8




Kyoto protocol and global greenhouse gas emissions


                  30,000
million ton CO2




                  25,000       Rest
                              of the
                  20,000      World

                  15,000

                  10,000
                              Annex I
                                              Kyoto
                   5,000
                                             Ratified
                                                                 EU25
                      0                                                       ETS
                              World          Annex I         Kyoto Ratified   EU25   ETS



                           In 2008, the greenhouse gas market becomes a lot bigger
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 9




Kyoto Market
       ANNEX I                                 ANNEX I
                               ERU



                                 CER

                                                              CO2             1
                                                              CH4 (methane)   21
                                          Non                 N2O             310
                                        ANNEX I               HFCs            150-11700

                                                              PFCs            6500-9200

                                                              SF6             23900
  UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 10




CDM current status
projects in the pipeline (volumes)


       Global                                                   already issued
                                                                at least 1 issued, yet to be issued
                                                                registered, before issuance
        China
                                                                LoA obtained, before registration
                                                                PDD written, before LoA

         India


        Brazil


         Rest
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 11




JI current status


 - February saw the first JI project submitted for determination
 - In May Russia‟s prime minister signed the country‟s JI procedure, but no
   LoA have been given yet
 - JI potential in the new EU ETS member states is limited due to double-
   counting rules
 - For those countries JI potential is concentrated in non-CO2 projects
 - JI host countries remain non-EU members as Russia and Ukraine
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 12




CDM project cycle, different levels of CERs
             CDM project identification

             Project Design Document

                  Validation starts                  After the validation by a Designated Operational
                                                     Entity and the approval by a Designated National
                 Letter of Approval                Primary CERs project is submitted to the United
                                                     Authority, the
                                                     Nations‟ CDM Executive Board for registration.
                                                   Price of ERPA (Emission Reduction Purchasing
                  Validation ends                    procedure normally takes 6 to 10 months,
                                                   Agreement) depends on remaining risks
                                                     can occasionally go up to 18 months
                    Registration

                     Monitoring                      If the project gets officially registered at the UN CDM
                                                     EB, it is recognized as a CDM project. by transferring
                                                     CERs can be imported in the EU-ETS Following that,
             Verification + Certification            them from thecertification occurs every 1-3 years.
                                                     verification & International Transaction Log (ITL)
                                                     Upon verification, a to a registry account on CERs
                                                     managed by the UNcorresponding number ofthe
                      Issuance                       Community Independent Transaction Log (CITL)
                                                     will be issued by the UN CDM EB. This quantity will
                                                     managed by the
                                                     vary compared European Commission. the link
                                                   Secondary CERsto the planned quantity in The PDD.
                  CER Distribution                   between the ITL and the CITL
                                                   Project origin matters - bilateral has not yet been
                                                     established but the European Commission has
                CER for compliance
                                                   Secondary CERslink will be ready before April 2009.
                                                     guaranteed the
                   in EU-ETS
                                                   Project origin does not matter (if it is EU-ETS compliance)
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 13




                EU Emission Trading Scheme


-To help Member States comply with their Kyoto obligations, the EU
 established the EU Emissions trading scheme (EU ETS)
-First International Emission Scheme ever
-Industry from 27 EU countries under cap and trade ~12,000 installations from
 ~5,000 companies
-EU ETS ~ 45% of EU emissions
-Large emitters of CO2 must monitor and report their CO2 emissions. Every
 year these companies are obliged to surrender a certain amount of emission
 allowances to the government
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 14




                EU Emission Trading Scheme

-Compliance Mechanisms:
 -Get allowances for free from the government (this may change in the future)
 -Purchase allowances from other installations
 -Internal abatement
 -Reducing emissions outside: Kyoto Credits
-2 Phases: 2005 - 2007 (pilot phase)
            2008 - 2012 (Kyoto period)
-EU has already indicated that a scheme after 2012 will be in place giving more
 confidence the market
-The use of Kyoto Credits (CER/ERU) are restricted to a limit set by member
 states and European Commission.
-On average companies can use up to 13% (~) of their allocated certificates in
 the form of CERs-ERUs for compliance purposes – arbitrage potential
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 15




EU-ETS Fundamental Signals

 Distance between cap and physical emissions
      – Physical emissions not known: forecasts, estimates, predictions / NEWS SENSITIVE
      – Cap set by European Commission and member states: NEWS SENSITIVE

 Weather
      – Precipitation impacts hydro power generation and compensation by fossil fuel fired plants
      – Wind impacts wind power generation and compensation by fossil fuel fired plants
      – Temperature impacts energy demand (heating in winter, cooling in summer) and corresponding
        emissions

 Primary energy prices – fuel switch
      – If gas is cheaper than coal, gas is preferred = low emissions
        If coal is cheaper than gas, coal is preferred = high emissions
      – Depends on the balance gas/coal/CO2 prices

 Supply from Kyoto projects
      – Other countries outside EU also demand CERs for compliance
      – Supply and Demand of CER/ERU uncertain
  UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 16




EU-ETS Success to Date
Does emissions trading work?
Q1 : Is the market sufficiently liquid?
 YES!
    – daily volumes increased by a factor 50 in two years


Q2 : Are EUA prices justified?
 YES!
    – market responds logically to fundamental signals weather, news, allocations, fuel prices

Q3 : Does the ETS lead to emission reduction?
 YES!
    – about 150Mton CO2 emission reduction in the EU power sector throughout 2005 and 2006
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 17




Voluntary Market


 – Non-regulatory purpose. Usually for marketing purpose, carbon neutrality
   programs or companies‟ strategy to be front runners in future compliance
   schemes
 – VER (Verified Emission Reduction)
 – There is no unified watchdog. The process to generate those credits is not
   standardized
 – Market is developing new standards in order to secure carbon credit quality and
   to avoid double count of credits: e.g. Gold Standard Foundation, Voluntary
   Carbon Standard
 – Those credits are traded with a premium compared to other VERs
 – There is no real market price. Only one future contract available from CCX
   (Chicago Climate Exchanges). Other exchanges are planning to launch more
   VER contracts as for example Nymex in 2008
                              Great Increase Potential!
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 18




Price Dynamics

                                      Variables                     Price Range
                                      (Direct and Indirect)
                                      Weather, fuel switch (coal-     Delivery Dec08-22.18€
             EUA                      gas), politics, supply of Kyoto
                                      credits, bankability
                                      Politics, EUA price, ITL link, Primary Market – 8-13 €
             CER                      project status, guarantees      Delivery Dec08 -17.10 €
                                      Establishment of procedures, Only Primary Market
                                      politics, EUA price, ITL link, 6-10€
             ERU                      project status, guarantees
                                      Label, quality (environmental 2-10 €
                                      and social)
             VER
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 19




Today‟s Carbon Markets: CER/ERUs versus EUAs

                                                   EUA                 CER/ERU


             Value                       right to emit 1ton CO2   right to emit 1ton CO2eq.


            Validity                               EU-ETS                  global

                                                                    primary, secondary,
            Market                        one market, EU-ETS
                                                                       different prices
                                                                     (1)import limit and
Use in EU-ETS Phase Two                              YES
                                                                      (2) ITL-CITL link
          UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 20




EUA and CER/ERUs
Market opportunity (arbitrage)
                                                                        Why the price difference?
                  30
                                                                        – link ITL-CITL not yet established
                  25                                                      operators like to physically own what they buy
prices [€/tCO2]




                  20                                                    – Phase Two allocations not yet finalised
                  15
                  10                                                    Why is this arbitrage?
                   5                                                    – import limits not yet known
                   0                                                      as long as there is a price difference, a
                   Jul 07   Aug 07 Sep 07 Oct 07 Nov 07 Dec 07 Jan 08
                                                                          company can exchange EUAs for CERs and
                                EUA Dec08       CER Dec08
                                                                          cash in the price difference
                                                                        – not enough CERs available to cover all needs
        Window of opportunity
                                                                          expected supply < expected global demand
        Price difference is expected to disappear
          before Mid2009
        – CITL-ITL linked
        – Phase Two allocation and import limits
          fully known
        UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 21




Global potential demand outlook
                                                             Japan
                                                                                         Canada
                                                           BAU short
                                                                                        BAU short
                                                           >1,000Mt
                                                                                        ~1,500Mt
                                                                ?
           EU non ETS                                         (100)
         >50% emissions                                       1,000           ?
                                           (700) 1,000
                                                            CER & ERU

                                                               2,400M                 ???           Post 2012
MtCO2




        2,400
                                                  ~1,400
        2,300

        2,200

        2,100                                                          ?
        2,000

        1,900

        1,800
                                                                             OTHERS
                2005 2006 2007 2008 2009 2010 2011 2012
                       emissions   allocations
                                                                            US states,
                                                                           Australia, NZ,
           Phase II total ~1,400Mt short
                                                                           voluntary, …
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 22




Origination – Kyoto Mechanisms
  UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 23




CDM / JI PlayersFinancial                                             Government
                                   Institutions                          DNA

                                                                                          Government
                   DOE                                                                     ministries



                                                  Financier
                                                                                                 Compliance
   Multilaterals                                   /Funds
                                                                                                   Buyers


                                  Trading house               Plant manufacture      Equipment

Carbon broker                                                                                     Equipment
                                        CDM/JI project developers                                 manufacture
                                                                                     Order

                                  Energy company                Construction



Carbon Exchanges                                                                                  Consultant
                                                    Operator
                                                                                                 /Aggregator




                Construction
                    firm                    Other players                EB/Supervisory
                                              (law firm)                     Board
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 24




Main Financial Players and Buyers CDM/JI


 – Financial Institutions (EU): Fortis Bank, Merrill Lynch, Morgan Stanley,
   Barclays, Deutsch Bank, Dresdner, KfW, Credit Suisse
 – Brokers: TFS, Evolution, CO2e
 – Exchanges: Noordool, EEX, ECX
 – Compliance Buyers: Utilities, Cement, Glass, chemical, petrochemical, oil
   refineries, coke ovens iron and steel plants; energy-intensive industry,
   lime, brick, ceramics, pulp and paper industries.
 – Multilateral: World Bank, EBRD, ADB
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 25




Origination Process
                     Contact Client or Prospect

                          Project Identification

                           Screening Process

                                Term Sheet

             Due Diligence and Client Acceptance

                  Emission Reduction Purchase                  Origination process
                           Agreement                           does not stop after
                                                               agreement has been
                                                               achieved
                 Administration Process – project
                 participant, monitoring, transfer of
                               credits
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 26




An example of screening criteria
Fortis Carbon Desk

 – Project size: The project should generate an expected quantity of at least 500,000 tonnes
   of CERs up to and including 2012. We accept bundled smaller scale projects. There are no
   upper limits to the project size. We could consider smaller projects based on other merits
   such as sustainability advantages.
 – Technology: The project should use an approved methodology by the United Nations
 – Sectors: Renewable energy, energy efficiency, methane recovery and utilization, industrial
   processes, waste management and fuel switch
 – Start date: Usually projects that have already started or plan to start operation over the
   next 1-2 years
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 27




CDM project‟s risk assessment

                          Technological                        - Fortis Bank Environmental Markets has
                              Risk                               undertaken significant research in the field
                                                                 of CDM project risk assessment.

                                                               - A thorough understanding and assessment
                                                                 of the CDM project‟s delivery risk will
                                                                 enable us to maximize our investment
                                                                 return by constructing a diverse CERs
                                                                 portfolio in terms of technology, stage, size
        Country             Delivery           Counterparty
                                                                 and geography.
         Risk                Risk                 Risk

                                                               - Fortis Environmental Markets‟ desk has
                                                                 developed a highly objective and auto-
                                                                 improving Delivery Risk Model to screen
                                                                 most CDM projects.

                           Operational                         - This model combines a serie of quantitative
                              Risk
                                                                 and qualitative metrics to help us gauge a
                                                                 potential CDM project‟s expected
                                                                 performance.
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 28




Delivery Risk Model applied to a biomass CDM project
in China
                                                                                       Expected       Expected
    Project Number         CCF001
                                                                                                    Performance in
     Country Name          CHINA
                                                                    2007          Performance in % tonnes of CERS
  Country risk exposure        1
                                                                 Base Case             78.95%           23,684
     Country Default        0.18%
                                                             Pessimistic Scenario      68.67%           20,602
       Probability
                                                             Optimistic Scenario       94.08%           28,223
    Adjusted Country        0.18%
   Default Probability
                                                  30,000                                                             28,223
   Counterparty Name          N/A
                                                  25,000                   23,684
                                                                                               20,602
   Fortis/International      BB+                  20,000
      Credit Rating
                                                  15,000
  Implied Counterparty      0.74%
   Default Probability                            10,000
     Project Stage           After
                          Registration             5,000
 Base Case operational       10%
                                                      0
   failure probability
                                                                              Expected Performance in tonnes of CERS
      Project Type        Renewable -
                           Biomass                                       Base Case   Pessimistic Scenario    Optimistic Scenario


                             2007         2008              2009         2010            2011                2012                   Total
 Planned CERs Quantity      30,000       40,000            50,000       60,000          60,000              60,000                 300,000
       % of total            10%          13%               17%          20%             20%                 20%                    100%
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 29




Financing with carbon Assets
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 30




Factors that influence CER/ERU price


 - Prices of CER/ERUs depend on a number of key factors, including:
      - EU carbon allowance benchmark price
      - Scope and methodology. Some buyers are willing to pay a premium for credits with
        great environmental and social track record
      - Credit of the Seller
      - Existing relationships with buyer-seller
      - Stage of project development: PIN, PDD, Registered, issuance
      - Project Size
      - Does the counterparty want advance payment?
      - Local investment climate
      - Delivery guarantee and damages for non-delivery
  UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 31




CDM project‟s IRR and its enhancement drivers
  IRR calculation from a CDM project will very
  much depend on the CER price convened
  between the project sponsor and the CER buyer:

                                                                          Fixed           Indexed         Hybrid
-CDM projects distinguish themselves
from other projects due to the enhanced                   Description     Price agreed in Percentage of Floor plus a
                                                                          term sheet level EUA             portion of EUA
cash flows generated by CERs sales.
                                                                                           benchmark       positive
These additional cash flows could                                                                          movement
significantly enhance the IRR.                            Benefits        Stable and       Possibly higher Minimum
-Depending on the technology used, a                                      easier to        cash flow       income known
CDM project‟s IRR could be doubled due                                    secure finance                   in advance
to CERs sales. The carbon revenue of the                  Disadvantage            --      Market has       Still very
project thus significantly increases the                                                  large volatility difficult to
project‟s financial viability.                                                            and very         secure finance
                                                                                          difficult to
- It is easy to understand that the extra                                                 secure finance
IRR from a CDM project will also depend                   Target People     Risk averse Risk Taker        Conservative
on the effective quantity of CERs issued                                                                  Risk Taker
to this project by the UN CDM EB (project
Performance).
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 32




CDM/JI Project Financing

        Risks                                           Mitigation
        Technology Risk                                 – Proven Technology
        Sponsor Risk                                    – Equity First
                                                        –Track Record
        Feedstock Supply                                Long Term Supply Contract (Volume &
                                                        Price)
        Market Risk (other than CER/ERU)                Offtake Contract
        Country Risk                                    ECA Insurance/Transfer
        CDM/JI Market Risk                              STRONG Offtake Contract (Volume &
                                                        Price)
        CDM/JI Regulatory Risk                          Non
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 33




Project Financing CDM/JI

- Financial Models CDM/JI projects
     – Equity: a company finances part of a CDM/JI project in return for shared financial returns and CERs
     – Loan and Advance Payment: a company provides loan at concessional rates in return for CERs
     – ERPA: a company agrees to buy CER/ERUs from the project


- The main factors that affect successful closing of financing are:
     - The cash flow of the business to be purchased enables the business to comfortably service the
       proposed debt;
     - a strong management team
     - A strong business model (a profitable history and an ability to generate a predictable cash flow)
     - The accounts of the business which is being purchased/built shows steady growth in revenue and in
       profit margin
     - The purchaser is committing their own personal finance to the transaction and if the business is not
       a success, they will personally suffer a financial loss.


– Financing CDM projects would be further facilitated, if
     – Offtakers commit to purchase credits for a long term
     – Country Risks are covered by the ECAs.
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 34




Nature of carbon finance for a typical CDM/JI project
                                             Capital Markets
                                 (Financial Institutions, Private Equity,
                                             Hedge Funds...)


                                   Equity                     Ownership + Dividend
                                 and/or Debt                   and/or Principle +
                                                                    Interest




                                                                                       Power
                          CERs                                                        Purchase
                                                                                     Agreement




                                                                            Cash
        Global Carbon
                                        Cash
           Market


                        By-product:
                                                                                                 Main product:
                          CERs
                                                                                                  Electricity
UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 35




Final Remarks
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 36




Beyond 2012…



                                          ???
                         “Investment in clean technology is risky,
                Not including a value for CO2 in investment projections
                          CO may not have a value beyond 2012”
                       as will 2become increasingly hazardous

 Some observations
      – The EU-ETS has no sunset clause; it will continue after 2012.
        Currently, this commitment has only been given concrete form up to 2012.
      – Europe has already announced its determination to cut emissions further by up to 30% of 1990
        emissions by 2020; (20% if other global regions don‟t take on similar targets).
      – Players outside the EU have already expressed interest and are likely to start similar (compatible?)
        schemes soon.
      – As the emission reduction target becomes more ambitious, it is very likely that high CO2 price
        signals will be maintained in order to facilitate the necessary emission reductions.
      – To date, many of the world‟s premier institutional investors have invested in CDM projects. This
        strong interest is mainly due to CDM projects‟ unique return profile and superior diversification
        benefits due to its total lack of correlation with traditional securities market.
      – The next wave of carbon reduction projects will need to account for the value of carbon abatement
        in their discounted cash flow models, and in part rely on the carbon credits for repayment.
                         Thank you

                patricia.rosenthal@nl.fortis.com




20 April 2010        Designator | author           37
 UNDP Regional Workshop | Istanbul, January 21-22, 2008 | 38




EU-ETS Success to Date
Logical response to fundamental signals
 Market Fundamental : Phase One Policy & News

            price [EUR/ton]
            30
                                                     EC demands cuts in             Italy publishes
                                                                                                                          first verified emission
                          Czech Rep.                    Italian NAP                  adapted NAP
            25             increases
                                                                                                                          reports reveal lower
                                                                                                                         emissions than forecast
                        allocation limit          UK accepts
                                                 smaller NAP
            20
                                     EC demands cuts
                                      in Polish NAP                                                                                            Phase One unanimously
            15                    EC accepts 5 NAPs
                                                                           EC demands                                                               forecast long
                                                                          cuts in Czech
                                   unconditionally
                                                                               NAP
            10                                                                             UK "wins" law suit
                                                                                              agains EC

             5
                   NAP drafts     EC likely to      official start of     EC rejects revised
                   generous       reject NAPs           EU-ETS                UK NAP
             0
              Jan 04            Jul 04               Jan 05               Jul 05               Jan 06           Jul 06            Jan 07             Jul 07




   market responds logically and consistently to policy & news on
                          - allocations (number of allowances put in the market)
                          - verified emissions (number of allowances needed)

						
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