Emission News Practical Information for Emission Trading E dition
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1 CO2 Monitoring Concept and ETS Report Generation CO2 Registry-Services for enterprises CO2 Certificates Purchase/Sale EUA, aeua, CER, ERU CO2 Certificates Swap, Spot- and Forward Trading CO2 Portfoliomanagement and consulting For Information using the Freecall Emission News Practical Information for Emission Trading E dition EUA DEC Source: ECX London Special features by the transactions of certificates in the new union registers at the end of the trading period Actually ended the 2. Trading period of the European Emissions Trading Scheme after it started already on on In practice, the legal process and return the stock exchange and bilateral trade, however, this happens only on , because plants and aircraft operators until this date to meet their legal return in the European Register. This is not done on time for during the year 2012, it is subject to penalty of 100 EUR per ton of CO2 emitted. This comes as nothing news, since this rule at the end of the 1st Period or at the time was already "junk certificates" could be purchased at almost zero cost. What is new, however, now that it is first come to companies that in the past period were less than their free allocation of CO2 was emitted amount, this time certificates must be physically delivered to already significant price and their delivery must be ensure until The end of the 2. Trading period and the new register provides operators with new challenges Most plant operators will think that they know already the effects of the end of a period from April Then surely some of it was similar to the current situation. However, some of the fundamental things have changed. Operators in the period have generally less free certificate available as before. The EUA1 was then with 1-2 cents/t to the end of period worthless. CO2 exchange in the first trading period was not yet possible. The operation of the Register at that time was much simpler than today. For the above reasons there is a closer look, that may just be smaller and a number of medium-sized enterprises for the first time certain legal and economic challenges to a much greater degree by the end of the 2nd Trading period will have to ask. Emissionshändler.com has thereby identified four scenarios that occur after the latest findings currently quite frequently and increase the stress level at the operators significantly affected employees: 1. Access to the new Union registry has become more complex and still not guaranteed by every operator. The failure of timely delivery to can be threatening for the existence. 2. The timely (often first-time) can purchase of allowances and their timely delivery fail 1
2 to deadlines for the establishment of trust accounts. 3. The financial gain from a recommended DEHSt CO2 exchange can vanish into the air when the corresponding required authorized agents are not correct installed in the registry account (if the exchange has not taken place). 4. The stock of obsolete CERs and ERUs in the registry account that expired on can have unpleasant conesquences house. Any of the above themes and situations companies bring in economic and organizational critical layers, which also have to be involved for the account representatives and managers of companies a load at a higher level. Access to the new Union registry has become more complex and poses new dangers Accordance with the relevant EU legislation plant operators have in the European emissions trading scheme from on an EU-registered account and a KP- registry account (Koyoto- Protocol), which have emerged from an ITmigration of DEHSt register account of the plant operator to In relevant IT- migration by the EU Commission safety measures have been taken to make important organizational changes in the activation of the accounts and the operation required by the plant operator. By the introduction of roles at least two (active) authorized agents and the ability to name additional (passive) account representatives that equal the varied activities of the 1. and 2. authorized agents control and must certify achieved in connection with the establishment of trust accounts and the use of the new SMS-TAN procedure for driving the technical and organizational effort on a new dimension. Moreover, since the newly established authorized agent under a Security Review procedure, the competent authorities to submit in electronic form for approval and the accompanying documents must meet certain conditions, while accessing not entirely correct registry established accounts to considerable organizational and time problems. By the European Commission as part of the migration furnished ECAS authentication system, which must now use all agents will, while other requirements for many small and medium enterprises, which can lead under time pressure, especially in massive consequences. In practice, this may mean for current experiences of Emissionshändler.com that operators after the successful IT migration in June 2012 represented only by one authorized agent on the register as an additional authorized agent has resigned from the operation and then obtained access codes and confirmation letters of the national authority are no longer simple to find. Would that, under these circumstances the transfer of allowances is no longer possible, is the remaining agents usually too late clear. Info Box External Register Account and Hotline for Registry Problems To help companies with the aim also for any human or technical changes its CO2 registry accounts cause anytime safely and efficiently, comply with internal standards of risk management, to observe legal requirements and deadlines and execute the legal and economically necessary operations on the register to be able to offer Emissionshändler.com service to a registered account. Emissionshändler.com helps companies fully comprehensive account setup (have not already done) and takes in a row all the essential technical and administrative tasks for this. Here, Emissionshändler.com may with the approval of the company in the register account put in one or the other role of an authorized agent and allow almost complete account service. By that, at any time (even in case of loss of authorized agent of the operator) all the necessary extensions, institutions, statutory returns and transactions are ensure unless they are requested by the account holder and certified. Prospective operators who have current issues or problems to register account or would like to more information on the individual services of the Account Services tab to get report, in at our free telephone hotline at or contact via info@emissionshaendler.com It dramatically, however, when the last remaining Agents his address or phone number has changed or has himself also never registered since June 2012 in the account register. Under such circumstances, it is a controlled return of certificates for submission to the 2012 Russian roulette where the major corporate values are at 2
3 stake (100 EUR/t penalty for the amount of emissions 2012). Recent experience has shown, however, yet another doomsday scenario: If the last remaining authorized agent does not know exactly what he's doing, then it is not uncommon that they lack clarity and exercise (and who is already sufficient) still want to quickly use a second agent and up itself "replaced". This is in the form of language DEHSt nothing more than the "self-extinction" of an authorized agent. Since this was the last agent with authorized access, then no return is impossible, with all the economic consequences for the company. In these and other now known cases, it makes sense to have an experienced external Authorized Agent before to consult and instruct. See also Info Box page before: External Register Account and Hotline. The timely purchase of certificates has become more difficult Plant Operators, who must first end of the period due to repurchase of underfunding its register account will be surprised possibly uncomfortable when a supply of CERs/ERUs or EUA2 certificates despite supposedly timely order is no longer time for the deadline on Assuming that easy access of all authorized representatives to the Union Registry is possible without any problems (see section above), it can happen in all likelihood, that overlooked is that the supply of allowances to the companies lack of prior establishment of an appropriate trust account with the supplier, including the transfer of calendar days needed. This means that the disclosure of its own register account number of potential suppliers must be made no later than at 13:30, so a charge of missing certificates is guaranteed to In this context should also be noted that a charge of "EUA3" certificates (also called 0-5 EUA) is not possible and allowed to return to the year This coming from auctions of 2013 EUA certificates of the 3rd Trading period are already in a high amount in circulation and may therefore not be the operators with the current conditions "EUA2" (EB-certificates /emission rights) confused and leave. The financial gain from a possible CO2 exchange can disappear Since March 2010, supported by the national registration authority DEHSt exchange of EUA certificates in CER/ERU certificates is referred to in a corresponding brochure in Opportunities for Business/Companies. It says: "Companies can get by participating in international JI or CDM projects additional emission reduction certificates (CERs or ERUs). The German Greenhouse Gas Emission Trading Act (TEHG) allows plant operators to their tax liability up to a limit of 22 percent (based on their individual allocation ) comply with these certificates. This may mean for companies a significant cost advantage over emission-reducing measures at its own plant or against the purchase of EB. Because JI- and CDM offset projects are carried out internationally in many sectors to reduce all greenhouse gases, ERUs and CERs are cheaper than EB. " Critical it is only when, because of the previously described access and authorization problems installation owners in April 2013 are unable to ensure the timely yet attractive exchange rates. Who has not had full access to their own account or in the absence of another authorized agent is not able to set up a trust account in time, which will find it difficult to bring to the end of April his financial gain of up to 4.50 EUR/t. In the event that a decision to Backloading on is negative or is further delayed, can be quite certain that an exchange revenue that is generated from the price difference between EUAs and CERs/ERUs on, due to a price crash of the EUA under 2 EUR/t shrinks to a minimum of 1.50 EUR/t. Here, only an intelligent and secure agreement costing an exchange whose EUA delivery can then be later in May 2013, when successfully established trust accounts will then allow using 2 authorized representative of the operator. More information you will get on request at Emissionshändler.com. The stock of obsolete CERs and ERUs in the account register A surprising number of plant operators and aircraft operators have to information from Emissionshändler.com called CO2 exchange EUAs in 3
4 CERs/ERUs in 2011 and 2012, too late or done only partially and are based on double-swap agreements or at rental stores by new legislation in EU ETS been surprised. This could mean that these operators to end of April 2013 CER or ERU certificates on their KPaccount (Koyoto- Protocol-Account or old account called DE-120) or its EU ETS account (EU-100- XXXXXXX-0-YY) have available that for the return in the 3.Trading period will be invalid. Whether the certificates are still seen from to the relevant account (but invalid) or are simply no longer there, is not mentioned by the national registration authorities in detail. In any case, there will be two types from the CER/ERU certificates available from the : Grey Certificates or as mentioned for the first time by Emissionshändler.com in October 2010 in the issued Emissions Letter predicts NTPC- Certificates called (Non-Third-Period-Certificates) Green Certificates, issued in the second trading period and must be converted to in EUA 0-5 and new certificates issued from , certain requirements must be fair, valid until Absolute caution is advised in the possible but, conversely, that in the second trading period issued CERs / ERUs certificates would continue to be valid for delivery from Equally wrong is the reverse, that the first time in 2013 issued CERs / ERUs certificates for delivery to the 3.Trading period would be valid. Examples which may be mentioned that CERs from industrial gas projects - issued in not to return in the 3rd period are valid and that ERUs from projects in EU countries from renewable energies/sources issued in is not eligible to return to the 3rd period. More complex special rules currently make difficult the survey. It's a fact that all of these CERs and ERUs for the delivery of 2012 valid until , but only a few beyond until or until the end of Since operators with excess CERs and ERUs to register their accounts - even if this is only a small number - have mostly been supplied by their suppliers with the gray on expiring certificates are, it makes sense to think about what it means for business. For the period April 2008 to remember the former decaying EUA1 that the timely off booking, that means sell an invoice was a sure way to avoid internal subsequent inconvenience. At that time, controllers and accountants (probably rightly) reacts with absolute lack of understanding of the fact that corporate values - even if they are very small - "disappear" without documents easily. Info Box CO2 exchange urgently recommend Buying invalid CER/ERU- Certificates Considerable number of operators has in April 2013 after the statutory maximum return of CERs / ERUs to the national authorities to remaining stocks of these types of certificates. According to a partial or complete deletion of becoming invalid certificates to to avoid possible internal clarifications and protracted litigation, Emissionshändler.com buys until these certificates on an invoice. Emissionshändler.com is an existing since 2006 consulting and trading company, which in Germany and Poland has 450 regular customers, which in part also in April 2013 require CER/ERU certificates for delivery. Interested operators can be provided by Emissionshändler.com under the mailadress info@emissionshaendler.com with the appropriate form, which must be requested until Through the necessary establishment of a trust account with a period of approximately 10 days, a request after this date will not be acceptable and not be handled. It would make sense then, that operators who have little CER / ERU volumes undefined origin and validity of sale, this time on account. Here, the minimum revenue is to be avoided no incentive but only a means to an end, a subsequent intercompany probably much higher cost of controllers and accountants. See also Info Box above: Purchase of grey CER/ERU. Conclusion on Handling the Deadline Relevant plant operators and aircraft operators deadline to submit their certificates for the year 2012 falls this time also with the end of the 2nd Trading period together. Since a borrowing of 4
5 allowances from the next year, 2013 is not possible and permissible, are significantly more operators come in situations where legal and economic consequences threaten the event that internal processes have not been adjusted or deadlines will not be observed. In an environment of a new registered account system, which greatly increased with safety standards makes the responsible persons to create, also lying on the hand economic benefits will be difficult to attain. Furthermore, should it be assumed that the use of additional time in the new register and a higher level of stress will impact the employees which are responsible. Here it makes sense that many of these very special, legally and economically critical processes should be given to an external service to protect its own staff capacity and create to remaining employees a backup or redundancy. The process of accounting registers belongs to all experiences that could previously do in the last 8 years, to those who have to be recorded in an in-house risk management and governed competently and redundant. Due to actual occasion! Performances of Emissionshändler.com for exemption from the EEG-levy 2014 Emissionshändler.com has appropriate experience in advising and supporting companies who now want to first submit an application for exemption from the EEG-levy or already have one or more times been unsuccessful in their application for reduction. Emissionshändler.com offers a pre-project in which an inventory of all relevant company's existing documentation is done and their evaluation with respect to the necessary conditions for determining the gross value creation, the certification of the energy consumption and energy consumption reduction potential, as well as the eligible power purchase amounts, especially in energyintensive parts of the operation. After the compilation of the results, an analysis of the extent to which all the requirements for the exemption are possible and achievable or not. Finally, this documentation is created, which allows the client to determine what additional expenses he will need with its employees or Emissionshändler.com to make his first successful EEG request. If it is desired by the customer, can Emissionshändler.com create another offer, in which the works are created in a major project to create the EEG request for exemption. This can be based on a resource-oriented, or a flat rate agreement. For more information on the free hotline at or over info@emissionshaendler.com Attention! The new account number in the register of Emissionshändler.com : EU Disclaimer This letter is issued by the emission GEMB mbh and is for information only. The GEMB Ltd. is neither legal nor tax advice. If this impression, it is hereby clarified that this is neither intended nor desired. The GEMB mbh assumes no responsibility for the accuracy and completeness of the information or its suitability for a particular purpose, either express or implied, This letter is not written with the intention that readers make an investment decision, a purchase or sale decision regarding a CO2 product or market and / or a contract decisions in all other respects active. Our offer Please contact us without obligation at +49 (0) or Freecall , info@emissionshaendler.com as well as via mail or find out more about the Internet services under Kind emission regards Michael Kroehnert Responsible for content: Emissionshaendler.com GEMB mbh, Helmholtzstraße 2-9, Berlin HRB Amtsgericht Berlin Charlottenburg, USt-ID-Nr. DE Phone: +49 (0) , Fax: +49 (0) Web: Mail: nielepiec@handel-emisjami.pl, info@emissionshaendler.com Member of Executive Board Federal Association Emission Trading and Climate Protection BVEK 5
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