Carbon Credits Are A Girl’s Best Friend

The emerging market of carbon emissions trading

Mari Kooi, Wolf International
Originally published in the June 2006 issue

This quarter's commentary focuses on carbondioxide emissions trading and is particularly timely due to the recent 70% drop in allowance prices trading on the European Emission Trading Scheme (EU ETS). We see great opportunities for investment in this area and are in the middle of evaluating how to invest for clients. At the moment, this girl prefers carbon credits to diamonds and gold (okay, I prefer diamonds).

Environmental Markets are immature, inefficient and ripe for experienced managers to exploit. Greenhouse gas emissions (GHG), water rights, renewable energy credits and a range of other related products are covered in this environmental market spectrum. While I believe that all of these market-based environmental instruments present opportunities for investors, I am focusing primarily on the European Union's market for carbon-dioxide (CO2) and other opportunities that exist in the emerging markets.

The recent 70% plunge in the price of CO2 allowances can only be described as a crash. Someone used the word correction but I beg to differ. A two week 70% plunge is not a correction. It is a warning shot to those who think trading new markets like this will be easy. The marginal buyers have been funds and banks, meaning there is now some considerable pain in the market. It is not finished. Some funds in particular have a mismatch in their liquidity which will lead to forced selling on the horizon. The best opportunity is about 90 days away.

The crash was a result of Swedish, Estonian, Belgian, Czech, Dutch and French factories and power stations signaling that they had more emission allowances than they needed. The findings of all of the EU's participants were not to be released until 15 May, but these countries' results were leaked into the market early and the consequence was a dramatic drop in the price of CO2 allowances. The price plummeted even further when German factories, the largest emitters of GHG in the EU, signaled that Germany issued a surplus of 14 million tons (Mt) of CO2 emission allowances. Analysts at UBS quickly indicated that there could possibly be a total surplus of allowances of as much as 200 Mt which could conceivably drive the price of the carbon emission credits to as low as €5 from almost €30 per Mt.

The study below is a summary of the emission trading markets, their history and the opportunities that present themselves to sophisticated investors. As usual, I start simple and move to the complex.

Emissions trading overview for beginners Emission trading systems are set up as a way to reduce greenhouse gas emissions through the utilisation of tradable market-based environmental instruments. These instruments have historically been employed by governments to curb negative environmental factors through the use of the free market. Someone who spews too much pollution may be forced to purchase a pollution security from someone who spews less than they are allowed. The rest of us are middlemen.

Tradable environmental market-based instruments typically exist in two forms; cap-and-trade schemes and credit programs. Under a cap-and-trade scheme, the government grandfathers or auctions a set number of allowances into the market for a target level of pollution emission. Firms then trade these allowances as needed to comply with their emission activity. The other instruments, credit programs, assign credits when a source reduces its emissions below its specific required limit. While these two instruments are the most common instruments, other devices that are emerging as tradable instruments are used to regulate the negative consequences that arise from natural resource consumption.

The EU ETS is one of the largest and most nascent markets for credit programs and cap-and-trade systems. It is a prime example of a growing environmental market where pricing inefficiencies exist.

The EU ETS, which began operation in January 2005, is the largest multi-national, multi-sector greenhouse gas emissions trading scheme in the world. The system was set up as the EU's response to the Kyoto Protocol to the United Nations Framework Convention on Climate Change which was negotiated in 1997 and ratified in 2005. It is a commitment among participating industrialised nations to curb the rise in global temperature by abating their emissions of six greenhouse gases including carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, perfluorocarbons (PFCs) and hydrofluorocarbons (HFCs). To date, 162 nations have ratified the agreement. Notable exceptions are the United States and Australia. Furthermore, two of the fastest growing economies, India and China, are not required to reduce their carbon emissions under the current agreement.

The Kyoto Protocol provides three implementation mechanisms to regulate greenhouse gas emissions. The first, International Emissions Trading (IET), permits countries below their current emissions limits to sell their excess allowances to other countries on the open market. The second, Joint Implementation (JI), allows investors from industrialised countries financing greenhouse gas emissions reduction projects in other industrialised countries to receive emission credits called "emissions reduction units" (ERUs). The third, Clean Development Mechanism (CDM), lets investors from industrialised countries accumulate "certified emission reduction units" (CERs) for helping finance carbon reduction projects in developing countries.

The EU ETS exists in two phases and encompasses all of the high use energy and power sectors. The first phase, which started in 2005 and will end in 2007, allows for the trade of CO2 allowances with the potential to expand into the other five greenhouse gasses. So far, it has set caps on the emissions of 12,000 to 15,000 industrial installations across Europe. It covers 45% of emission activities including power, concrete, pulp, paper, and ferrous metals. The second phase, from 2008 to 2012, could possibly cover all greenhouse gases and installations, and will include JI and CDM credits in the market. It is important to note that in the first phase an amendment called the Linking Directive was implemented which enabled installations to use CERs and ERUs from JI and CDM to meet their emission targets.

The EU ETS is monitored and regulated by the EU Commission (EUC). In both phases, the EUC places limitations on GHG which are satisfied through the trading of EU emission allowances (EUAs). The goal is to force companies to find the lowest cost of abatement by decreasing their GHG internally and selling any unused EUAs into the market. During the first phase, the EUC imposes a penalty of €40 per ton of CO2 for installations that emit more than their target limit. In addition, these installations must acquire their excess emissions in the market. This penalty will go to €100 per ton of CO2 in the second phase.

Participating countries in the EU ETS submit their target GHG reductions through National Allocation Plans (NAPs) which then are approved by the EUC. According to the Norwegian consultant Point Carbon, during the first phase of the EU ETS, the EUC approved circa 6.3 billion allowances and allowed for another 2.1 billion to be distributed each year.

The chart on the left demonstrates the first phase sector allocations. The Power and Heat sector makes up the largest allocation of CO2 allowances in the first phase. Point Carbon reports that there were approximately 10,000 industrial installations with commitments under the EU ETS. With Power and Heat leading the way, industrial installations emitting more than 10 Mt of CO2 accounted for 34% of total allowances; installations emitting between 1 Mt and 10 Mt had 47% of the allowances; and smaller installations emitting less than 1 Mt of CO2 totaled 19% of all allowances. This distribution is likely to change during the second phase as all emitting industries are capped.

According to Point Carbon, the EUC cut 300 Mt of CO2 emissions in the first phase and then distributed the average annual cap among the Member States. This was 4% less than the original NAPs submitted to the commission. As I will discuss soon, one of the main lessons from the recent crash is that the EUC should have placed a tighter cap on emissions because the cut of 300 Mt CO2 originally implemented looks like it is going to cause a surplus of allowances in the range of 100 to 200 Mt.

The lack of an effective cap is more obvious when looking at the largest emitting countries in the EU on acountry by country basis: the caps just don't look like they're caps at all. The reason for this is that when submitting their NAPs, countries such as Poland and France claimed they had a lot of growing to do and needed less stringent caps placed on their industries. The UK and Germany could not make the case for such growth. The EUC listened, and provided loose emission restrictions on countries that made the case for industrial expansion, and placed tighter caps on those which could not make the case because they were already developed. When the second period comes, the EUC will look at the poor results of the first phase, and put much more stringent emission caps in place.

Clean Development Mechanisms (CDM) and Joint Implementation (JI)

CDM and JI are the mechanisms used for investment in emission reduction projects and are specified under the Kyoto Protocol. These mechanisms are highly complicated and held down by long bureaucratic processes which can significantly prolong bringing their output to market. Nonetheless, from a long term perspective, these mechanisms provide for attractive investment. While I will not go into all of the details of how these mechanisms work, I think it's important to provide you with a brief overview.

As mentioned before, Clean Development Mechanisms (CDM) are a way for investors in industrialized countries to receive Certified Emission Reduction units (CERs) through funding emission reduction projects in developing countries. In order for investors in an industrialised country to receive CERs, the developing country must first give its consent that the project will add to sustainable development. Next, the investor must use methodologies to establish "additionality" which revolves around demonstrating two themes; (1) that the project would have happened without the CDM, and (2) that the emissions from the project are lower than the baseline emissions from the project had the CDM not been implemented. The case must then be verified by a Designated Operational Entity, which is a third-party agent who ensures the project is measurable and will produce long-term emission reductions. Lastly, the CDM Executive Board (EB) issues its final approval and awards the applicant a number of CERS based on the difference between the baseline emissions of the project in absence of CDM and the actual emissions the CDM produces. These CERs can be created from projects started in 2000 and have no specific end date; however, Point Carbon notes that the majority of current projects are only contracted until 2012.

Unlike CDM, Joint Implementation (JI) is transacted between two industrialized countries which already have an emission reduction requirement under the Kyoto Protocol. Under JI, one country acts as an investor and the other as a host. The investor in an emission reduction project will receive Emission Reduction Units (ERUs) from the hosting country equal to decrease in GHG that is spurred by the venture. JI is comparable to CDM in that it follows similar "additionality" guidelines; however, as long as both participants are players within the Kyoto Protocol, it provides for an approval option focusing on the participating countries rather than acting authorities such as the EB.

Current Exchanges

Thus far, the majority of trading has taken place OTC. This is because the relevant exchanges were only introduced in 2005. These exchanges provide fairly good information on market activity. However, according to Point Carbon, the movement of direct company-to-company trades has been harder to measure. The bilateral company-to-company market was strong in 2004 but slowed during 2005 and 2006 as many companies opted to do their trading on the emerging exchanges. I have chosen to briefly mention several of these emerging exchanges below.

The European Climate Exchange (ECX), which is owned by the Chicago Climate Exchange (CCX), is the largest exchange for carbon emissions offering standard contracts and clearing guarantees. It operates on an electronic platform across Europe. It had a total volume of 94.3 million contracts in 2005, of which 37% were futures contracts with cleared OTC trades making up the remainder. So far in 2006, its volume has reached 140.2 million with 45% futures contracts and the rest cleared OTC trades. The other two large exchanges are Nord Pool, for the Nordic Regions, which does roughly a quarter of total exchange volume, and PowerNext of France which has grown increasingly over the past year. Nord Pool is the only other exchange besides the ECX which offers the clearing of OTC contracts. The German market operates under the European Energy Exchange (EEX) and its carbon volume is small in comparison to the EUCX. The EEX did 2.7 million in volume in 2005 and has done 3.3 million in volume so far in 2006. The indication is that these exchanges are advancing over time. For example, the ECX recently announced that it plans to offer listed options contracts for EUAs by the end of this year.

Market Discussion

Overview of 2005 and Q1 2006 Point Carbon reported that with the introduction of the first phase of the EU ETS, €9.7 billion worth of carbon was traded in 2005, up from €377 million in 2004. This amounted to approximately 362 Mt on the EU ETS. Furthermore, 25% of the EU ETS's 2005 volume had already been traded in January 2006 alone. To demonstrate the EU ETS volume growth, I have chosen to use the above graph of ECX activity.

Point Carbon also reported that contracts were signed for 397 Mt of carbon credits from CDM projects in 2005 which could be valued at €1.9 billion assuming payment on delivery and a 7% discount rate. 2005 JI activity saw 38 Mt of carbon credits totaling around €95 million. This was significantly smaller than the CDM transactions, yet still its volume tripled.

Outside of the 2005 activity in the EU, project support for CDM continued with the main suppliers being in China, India and Brazil. Point Carbon states that China was noticeably the largest CDM supplier, contracting volumes close to 300 Mt. These emerging market contributions are important and I will discuss their implications in greater detail in the following section. As noted above, the EU ETS implemented a Linking Directive that allowed industrial installations to use CERs directly for compliance. When the prices of EUAs increased so did the demand for CERs.

There was a 55% correlation between CO2 and Natural Gasprices until the sudden movement of CO2 futures. Until several weeks ago, the market price of emissions allowances was largely linked to fuel prices. This is because the power and heat sectors total over half of the installations that are regulated on the EU ETS. These power and heating facilities burn fossil fuels to produce their output. More expensive fuel types such as natural gas produce less CO2 emissions, and less expensive fuel types, such as coal, produce more CO2 emissions.

The market for CO2 allowances was trading on the fundamental movements in fuel prices because this was a period when natural gas tensions between Russia and the Ukraine were escalating. With Russia threatening to shut off gas to much of Western Europe, European gas prices jumped and simultaneously caused power plants to burn more coal in order to avoid these unnaturally high gas prices. This occurred during a cold winter and the EU ETS began to perceive that with the large amount of CO2 being emitted by power plants burning more coal, there could be a shortage of around 200 Mt to 300 Mt of CO2 allowances. But the data leaked into the market in recent days indicated otherwise. This shortage was actually a surplus of 100 to 200 Mt. The market crashed and we find ourselves in the current situation. If the market is in surplus, then like any commodity the value is the cost of carry from now to the second phase when they again are in shortage. That market using the futures is 17.80 Euros. If we can buy them at 9.30 now, then the IRR to the 2008 futures contract is 38.29%. One is not deliverable against the other but it shows the large disparity in value.

The surplus of allowances at a time when industrial installations were emitting more carbonthan normal demonstrates that the EUC did not set effective caps on their industries. However, it is important to note at this time that some of the largest emitting countries such as Poland, Italy and the UK have yet to report their figures. A complete picture of recent events will be possible only after the dust settles.

Implications from 2005 activity and opportunities on the horizon

It is difficult to create an investment theme in this volatile environment. Clearly the buy and hold strategy has extraordinary risks. At the moment, the best risk adjusted returns are focused on trading and capturing market inefficiencies. A well-oiled team with a diversified approach can print money just like any other market in a state of chaos. Opportunities principally fall into five areas. These are; 1) an immature policy structure, 2) distressed market participants, 3) regional disparities, 4) CDM projects in the emerging markets, and 5) a correlation to volatile energy prices.

The first, and most apparent implication from 2005 activity, is the inefficiency that came from the immature policy structure set up by the European Commission. In hindsight, when pricing CO2 allowances, the markets were looking at the wrong signals. Instead of focusing on the effectiveness of company internal abatement strategies, the market was assuming companies were strained and thus priced CO2 allowances in accordance with the changes in the price of fossil fuels. In the second phase, caps will be tighter. Therefore, a team that understands the changes in policy and differences across countries will make money.

The second opportunity is in taking advantage of distressed market participants. As the market crash indicated, these fairly new instruments have been used on a limited basis only, and it is taking firms some time to learn how to fully utilise the benefits of the instruments. These instruments are primarily used for compliance purposes. With the uncertainty about whether instruments will be a lasting element of the regulatory backdrop beyond 2012, many companies are choosing not to reorganise their internal structure to exploit the cost-savings benefits these instruments can offer. Therefore, many of these firms can be classified as one-off buyers, needing to purchase emission allowances for compliance purposes, or distressed sellers needing to solve problems such as satisfying cash constraints. For example, the recent market collapse has left some utility companies whose carbon permits were only used to satisfy compliance issues with millions of tons of carbon credits whose value is severely diminished. The utility companies could have made money if they had successfully hedged their exposure. These compliance and liquidity issues are creating ample short-term opportunities for alternative asset managers to step in and exploit the distressed prices that exist. Managers can do this with their ability to provide liquidity, conduct high quality research, and their expertise in hedging with complex products associated with these instruments, such as derivatives.

The third opportunity comes from a thorough understanding of the regional disparities that are a result of different regulations and market structures. As these markets grow globally, it is perfectly feasible for a manager with a fair amount of capital and a good understanding of the global markets to play the market by buying credits cheap from countries that are under their emission requirements and selling credits at a premium to countries that are over their requirements.

Currently, the EU has the only comprehensive trading system. However, large emitting countries such as Canada, Japan and New Zealand are all considering putting similar emission trading systems in place. In addition, the ChicagoClimate Exchange (CCX), which owns the ECX, is a voluntary, legally binding rules-based greenhouse gas emission reduction and trading system located in Chicago. Many members of the CCX are trading CO2 emissions simultaneously in the EU to offset their CO2 emission exposure in the States. There is an emerging emission market in the US. The emissions in these developed areas are enormous. Just recently Canada reported that its emissions of GHG are now 35% above the level in its Kyoto agreement, and its Environment Minister said that the country would have to ground every train, plane and car to meet its target. Emission markets are global and a team must be global to take full advantage.

A fourth opportunity arises because carbon credits in the developed world are going to be in high demand in the future, and the brick and mortar emerging markets will have the supply chain to fill this hunger. The current financing of CDM and JI projects will offer managers the ability to bring CERs and ERUs to market, and as a result the facility to own part of the future supply chain of carbon credits. Alternative asset managers are the right people to do this because they can hedge their short-term exposure over the longer term time frame necessary to develop these projects. This is by far the most lucrative strategy.

Of the two projects available, CDM projects have the greatest potential. As I stated above, 2005 CDM activity saw 392 Mt of contracts created which had a maturity date beyond 2008. This 392 Mt overshadowed the 362 Mt traded on the EU ETS. China supplied 300 Mt of these credits. Clearly, as regulations tighten substantially in phase two of the EU ETS, credits are going to come from CERs created by CDM projects in emerging markets such as India and China. Industrial Production (IP) arguably correlates best with commodity consumption. The amount of emerging markets growth in IP far overshadows the growth that is taking place in the developed world. These markets are building out the infrastructure to support this booming growth and consequently creating a large number of CDM projects to choose. The key will be to target these projects on the cheap and manage the process it takes to bring the credits to market. This requires experience that few people have.

Not only are geographic disparities a source of opportunity in the short term, so too is the way emissions relate to volatile energy prices. This is our fifth area of opportunity. Even though a focus on these fuel prices led to the recent market collapse, once effective caps are placed on emissions, the ability to play these markets will lead to opportunities. As demonstrated, the political, market and natural environmental forces that create volatility in the price of energy will also create a corresponding effect on the price of emission permits. As the EU ETS develops and places caps on more emission outputs, volatility is likely to be quite high. Eventually, there will be fully developed option markets and other derivatives to trade.

Potential risks

Arguably the largest risk is government intervention. This risk will not go away in the environmental markets especially with the price of energy at record levels. One of the best examples of governments intervening and creating risks for investors through policy change, can be seen in the US with its bio-fuel ethanol import tax. For those of you who may have missed this, let me give you a brief recap of the eventstaking place.

Ethanol, which is primarily derived from corn in the US and increasingly other cost-effective plant matter, is being phased in as a component in reformulated gasoline sold in large US cities. The US and Brazil are the largest producers of ethanol. In the US, ethanol is produced primarily in the Midwest and shipped to the coasts by barge or rail car. It can't be shipped in petroleum pipelines because it binds with water and as a result ruins gasoline.

As recently as six months ago, the US government was pushing energy independence through promoting domestic based ethanol initiatives. However, as the summer driving season heats up and oil prices skyrocket due to political tension in Iran, the US government has reversed its stance saying that it wants to lift a 26 year-old tariff imposed on the imports of ethanol. Its idea is that by destroying the tax it will increase imports and provide more ethanol to the coastlines, which have the highest demand. What it is ignoring is that imports are likely to be a total of 260 million gallons this year, which is twice as much as 2005.

The tariff has not been a barrier to entry and enough ethanol is expected to be available for this summer. Current US ethanol refiners produced around 400 billion gallons in 2005. Large investments were made in the US ethanol sector recently and capacity is expanding by almost 500 million gallons a year. Most importantly, making ethanol from corn is the most expensive way to produce the bio-fuel. It is cheaper to produce it from sugar. By destroying the import tax, cheap ethanol produced from sugar in the tropical regions is sure to flood the US market sending the price of ethanol plummeting. An investment in the US ethanol sector six months ago looked like it was a sure thing, now it has more risk because of this potential change in policy stirred up by politicians trying to do something about rising oil prices. This ridiculous change is unlikely to pass but shows how a seemingly intelligent government can do stupid things in the span of six months (I can hear the outcry of people saying this is not a seemingly intelligent government).

Another risk that may occur is a temporarily flat market. A surplus of credits means the price might reflect only the administrative costs of the scheme. Point Carbon found very little evidence of actual fuel-switching or internal abatement taking place thus far, and the recent crash is signaling that the market may not be working as originally planned. However, with the EU focused on curbing global warming, if the tradable market-based instruments are not working, the EUC is sure to place an ever more stringent cap on industries when the EU ETS enters its second phase in 2008.

There is no legally binding obligation past the 2012 date, and if the market is not working by then, there might be an incentive to give up. Thus, the time window for alternative managers to exploit this market is in the next four to five years. For CDM projects however, there is no time limit, and a bullish stance on continued action and the extension of emission trading makes this area of investment very attractive. It is also unclear whether the United States, the largest emitter of greenhouse gases, will ratify the Kyoto Protocol. The current administration, while not critical of the overall mission of Kyoto, has expressed concern over the strain it may place on the US economy. It is likely that the US government will have to do something to satisfy political pressures.

Wolf's opportunity

As I mentioned in the beginning, with allowance prices plunging, and some funds suffering substantial pain, I think the near future is the best time for a carbon fund. We are long term bullish on emission prices and feel there is a winning strategy in capturing a margin between long positions in CERs and ERUs (the emission credits from CDM and JI projects) and short positions in EUAs (the allowances currently traded on the EU ETS). With the large amount of power infrastructure being built out in some of the emerging market economies, CDM projects are plentiful, and the opportunity to invest in these projects and own part of the long term supply chain of emission credits is what needs to be targeted. In addition, we feel some strategic positions in JI projects will provide exposure to some supply across the more industrialised nations. The difficult part will be in the ability to pick the CDM and JI projects and prove the necessary "additionality" requirements while staying hedged in the short term until the credits are brought to the market.

In order to do this successfully we located an experienced team. There are not a lot of people out there who fully understand these markets so we went out and found the people who helped create them in the first place. We compiled a team that has the field knowledge and ability to pick the best CDM and JI projects on the cheap and add value by helping developers bring their CERs and EUAs to the market. We are helping this team launch so we can focus our investments in the right area.

I did not begin to scratch the surface on how difficult and complex the process for CDM and JI projects can be, and there is a huge demand for people who can not only select the projects with the highest return potential, but also have the legal knowledge, network and ability to manage and trade the CERs and ERUs that these projects produce.

There are some risks, but our team has a detailed understanding of intricate hedging strategies to minimise these risks. I believe they have the aptitude to remain as close to 100% hedged as possible removing basic exposure to the price volatility of the EU ETS market. This is not a "buy and hold" strategy we are talking about. It is one which uses all of the sophisticated hedging practices that alternative asset managers have the talent of employing.


While the dust has yet to settle on the EU ETS and carbon prices, the indication is that with Germany signaling it has a surplus of 14 Mts, there is going to be a surplus causing EU emission allowances to be cheap until 2008 when the number of industries that are capped moves from 45% to 100% and the EU members get a better idea of what effective caps they should place on their industries. However, even if the 2005 information that is released on 15 May drives allowance prices back to €30, the €40 per ton phase one penalty and a €100 phase two penalty leads us to believe that a €30 allowance is still cheap in the long term. An increasingly crowded European allowance market makes us consider CDM and JI investments outside of Europe one of the most attractive investments. Hence, we can still buy up emissions credits through CDM and JI, thus owning part of the supply chain and remain hedged by being short the European emission market.