Dóra FAZEKAS1 HUNGARIAN EXPERIENCES WITH THE EU ETS Carbon Market Implications for the new EU Member States Abstract This paper assesses the trial phase of the European Union Emissions Trading Scheme (EU ETS) from the point of view of the new Member States. Countries of Central and Eastern Europe are thought to lack the market-based economy necessary for the successful operation of such a system. Although the study provides an evidence-based description in the context of allowance trading in Hungary, the conclusion is general enough to inform the further development of the EU ETS. The findings of this study are based on interviews at installations responsible for two thirds of the Hungarian ETS emissions. This paper finds that no reductions were achieved clearly attributable to the introduction of the EU ETS due to the loose target and the overall long position of the market. Hungarian operators acted as regulatory cost-minimizers, focusing on compliance, rather than benefit maximizers seeking to profit from the scheme. Nonetheless the export share of the Hungarian allowance surplus was quite high in the pilot phase. On one hand some long installations kept their allowances until the end of the pilot phase when it was already worthless, hence not worth selling. On the other hand some operators made fortunes by selling early. The EU ETS in Hungary has been effective in inducing firms to build their capability to respond to a carbon price signal, but has not led to significant emissions abatement during the first phase. Key terms: emissions trading, Hungary, market functioning Acknowledgement I am indebted to the APREC2 team for the opportunity to engage in their research activities – special thanks to Raphael Trotignon for providing the CITL data necessary for my findings. I am grateful to Mariann Csikesz without whom the interviews, which give the basis for the findings of this study, would not have been possible. I also wish to thank Denny Ellerman for his careful reading and constructive criticism. 1 PhD Candidate at the Department of Environmental Management and Technology, Corvinus University of Budapest, Hungary 2 APREC has been implemented by an international research team composed of experts at the Center for Energy and Environmental Policy Research (CEEPR) at the Massachusetts Institute of Technology (MIT), the University College Dublin (UCD), and the Mission Climat of Caîsse des Dépôts, in collaboration with the Université ParisDauphine, the International Energy Agency (IEA), the Öko-Institut in Berlin and the Centre International de Recherche sur l'Environnement et le Développement (CIRED) in Paris. Table of contents Introduction and Methodology........................................................................................................... 3 History and development of the EU ETS in Hungary........................................................................ 4 Legal and regulatory environment ..................................................................................................... 6 Allocation of allowances and effects.................................................................................................. 7 Auctioning .......................................................................................................................................... 8 Development of the EUA market..................................................................................................... 10 Emissions and abatement ................................................................................................................. 13 Impacts on Hungarian EU ETS sectors............................................................................................ 14 Joint Implementation projects .......................................................................................................... 16 Green Investment Scheme and trading with hot air ......................................................................... 16 Conclusions and outlook .................................................................................................................. 17 Annex I. – Hungarian NAP I............................................................................................................ 18 Annex II. - Firms interviewed receive the bulk of allowances ........................................................ 20 Annex III. – Auctions in the pilot phase .......................................................................................... 21 Annex IV. – Accounting Aspects of Emissions Allowances ........................................................... 22 Annex V. – Transactions based on data of the Hungarian Registry................................................. 23 Annex VI. – Hungarian JI projects................................................................................................... 24 Annex VII. – GIS framework and the potential hot air in Hungaryó............................................... 26 References ........................................................................................................................................ 27 List of figures Figure 1. Hungary has very low per capita emissions level ................................................................ 5 Figure 2. Prices on the day of the first auction .................................................................................... 9 Figure 3. Long and short positions of Hungarian ETS sectors .......................................................... 13 List of tables Table 1. Comparing clearing and market prices .................................................................................. 9 Table 2. Net flows from/to Hungary.................................................................................................. 11 Table 3. EUA transfers within Hungary between April 11, 2006 and April 30, 2008. ..................... 12 Table 4. Sectoral distribution of NAPI .............................................................................................. 14 2 Introduction and Methodology This paper aims at providing a theoretically sound and empirically validated understanding of carbon trading in the new Member States3 of the European Union (EU), with a special focus on Hungary. The European Union Emissions Trading Scheme (EU ETS) is one of the obligations which came with the accession to the EU, although Hungary, and all the other accession countries signed the Kyoto Protocol, they are not part of the EU’s burden sharing agreement. The EU12 received the carbon reduction obligation with the EU membership. The new EU countries differ significantly with regard to size, state of reforms, economy and environmental challenges. However, they share several similarities due to their common post-socialist history (Ürge-Vorsatz et al, 2006). The rather limited experiences of Bulgaria and Romania that only joined the EU ETS in 2007 has proved that one year for preparation for the Kyoto phase was insufficient while the three years for the other countries was more or less enough to implement the scheme, set up the institutional background and set the carbon price as a new factor in corporate decision-making. As part of the international research program, the Association for Promoting Research on Carbon Economy (APREC), this paper provides an ex-post evaluation of the Eastern European CO2 market, with a focus on Hungary. The findings are based on Community Independent Transaction Log (CITL) and Hungarian Registry data and interviews conducted by the author together with Mariann Csikesz, the Communication Manager of Hungarian based Vertis Environmental Finance Zrt. We interviewed the operators of installations responsible for two thirds of the Hungarian ETS emissions (see Annex II.), two industry associations: cement, and iron and steel and two international auditor firms. During the trial phase the system’s legal basis has been laid down, the institutional framework has been set up, the trading has been introduced, and non-compliance has not occurred. On the other hand the system was introduced in a rush, all Eastern Member States, except Slovenia, were overallocated, and free allocation led to windfall profits for almost all sectors. Based on the interviews this paper finds that in the short run, the impact of EU ETS on operations was minimal, the effect if any has been non significant at best, and positive for the sectors in some cases. Despite the theory (Montgomery, 1972) stating that the efficiency of the scheme is independent of the initial permit allocation this study finds that most of the operators agreed that lobbying for more generous allocation was the optimal solution for the Hungarian ETS sectors. Although in theory the choice between free allocation and auctioning is not supposed to modify the conditions of competition at the margin (Reinaud and Philibert, 2007), we have found that it had important implications on corporate balance sheets and market behavior. Volumes and frequency of national and international transfers prove that Hungary was actively involved in the allowance market. This reflects that Hungary at the country level as well as at the corporate level effectively exercised the opportunity to access the European carbon market. The paper first presents the history and development of the EU ETS in Hungary, its legal and regulatory environment, then describes the allocation process with a focus on auctioning. The development of the carbon market in Hungary is then presented, followed by a discussion on whether decreasing emissions are due to abatement activity. Based on the interviews the paper reveals the impacts of the EU ETS on the main Hungarian sectors: combustion, iron and steel, oil refinery and cement production. Finally an overview on Joint Implementation projects and Green Investment Scheme in the context of hot air trading is given. 3 The new Member States of the EU referred to as EU12 are: Czech Republic, Estonia, Hungary, Latvia, Lithuania, Poland, Slovakia, and Slovenia, which joined in 2004 and Bulgaria and Romania which joined in 2007. Cyprus and Malta also joined in 2004 but are not addressed because they do not have a target under the Kyoto Protocol. History and development of the EU ETS in Hungary As all new Member States of the EU Hungary is a „country that is undergoing the process of transition to a market economy” according to the UNFCCC and shares most of their characteristics with respect to climate policy. (Bart, 2007) Hungary signed the UNFCCC on June 13, 1992, the Parliament passed a resolution and the ratification was announced to the public by Law LXXXII of 1995. Hungary ratified the Kyoto Protocol on August 21. 2002, joined the European Union on May 1. 2004 and reached Kyoto eligibility at the end of 2007. Hungary barely has twenty years of experience with market-based economy, hence it was rather challenging to introduce and nevertheless successfully introduce the market-based environmental policy tool of the EU ETS into the policy space in Hungary. Hungary traditionally devotes only scanty resources to environmental issues plus environmental problems and their solution were not in focus prior to EU accession. Hungary is a small country in every aspect, regarding population, area, and economic performance, influenced by its neighbors. According to Szlávik et al. (2000) Hungary does not develop a significantly different environmental policy from the policy of the neighboring countries and especially the EU, Hungary follows the Western European trends. Ürge-Vorsatz warns (ÜrgeVorsatz et al. 2005, 2006) that this “copy and paste” policy may not work for every Member State with different circumstances and conditions. Hungarian opinion about EU ETS was rather ambiguous prior to its introduction. On one hand Eastern Europeans felt that new Member States’ interest were not taken into account. On the other hand due to the loose reduction target the trading sector was expected to be in gain and the scheme was seen as a potential foreign direct investment into the country. In 2003 Hungary and other candidate countries, have expressed their concerns over the EU ETS. "The scheme was designed without keeping in mind the needs of new member states", officials voiced their worry (ENDS Europe DAILY, 2003). It is true that while the scheme was vital for the EU15 to reach its Kyoto commitments, the situation was different for accession countries. Another article from 2003 (Figyelő) states that accession countries will be the losers of the European climate regulation due to the fact that Western countries will buy up their hot air allowances below their value, hence Eastern Member States will waste their allowances, which will set back their economic growth and development. I agree with Lesi and Pál (2004) who argue that this attitude is mistaken and for Hungary not to participate in the first phase of the EU ETS, especially for the firms in sectors covered by the scheme, would be disadvantageous. The majority of Hungarian installations have a high abatement potential and with receiving allowances for free, they will benefit from the system. (Lesi and Pál, 2004) By ratifying the Kyoto Protocol, Hungary committed to cut its greenhouse gas (GHG) emissions by 6% under 1990 levels from 2008 through 2012. The latest data, which exclude sinks such as forestry, shows the country is 32% under 1990 levels. With forests, agricultural lands, and meadows removing carbon dioxide from the atmosphere taken into account, Hungary's emissions are around 36% under the target. (EEA, 2008) Hungary, like all new Member States, has seen a decline in its plan-based carbon-intensive economy during the 1990s, and despite of the increasing economic activity, emissions are still well below their base year4 level. None of the Eastern Member States need any further measures to meet their Kyoto targets, nevertheless a stronger than expected growth in emissions could bring current Hungarian emissions close to the target. (IEA, 2005) Per capita CO2 emissions level is very low in Hungary (see figure 1. below), only Latvia and Lithuania have lower levels in the European Union. The low per capita emissions level is due to three factors. First, the state owned Paks nuclear power station covers 40% of national electricity demand. Second, the share of natural gas in primary energy supply is very high: 40%. Third, the number of cars per capita in Hungary is growing but still very low.5 Figure 1. Hungary has very low per capita emissions level Source: Author’s graphs based on OECD data, 2005 In Hungary, 254 installations received CO2 allowances. These are responsible for almost 40% of the Hungarian CO2 emissions. Hungary’s trading sectors CO2 emissions are relatively small compared to its size. Total quantity of allowances issued is about half of the trading sector emissions of Belgium, a country with almost equal number of habitants. Though only half as populous as Hungary, Slovakia’s trading sector emissions are almost equal to Hungary’s. (Bart, 2007) The relatively small emissions are attributable to the relatively small heavy industry and an exceptionally high share of gas in the country’s total primary energy supply. Significantly, unlike in most other new Member States, electricity generation and distribution has been almost fully privatized, and is now owned mostly by multinationals E.ON, RWE and EDF. The state owns and operates the national electricity grid and the Paks nuclear power station. 4 For most countries 1990 is their base year but because of their special situation, the EU12 was granted a degree of flexibility for choosing the target. Bulgaria (1988), Hungary (average of 1985-87), Poland (1988), and Romania (1989) have chosen a base year other than 1990. 5 Based on personal communication with dr. Prof. Sándor Kerekes, vice rector of Corvinus University 5 Legal and regulatory environment In Hungary emissions trading issues are not only regulated and managed by the Ministry for Environment and Water but also by the Ministry of Economy and Transport, moreover auctions were implemented by the Ministry of Finance. The cooperation of the three Ministries, each having a different goal and a different conception was not the ideal situation for the EU ETS in Hungary this contradiction was present during the whole pilot phase. Hungary lacked the infrastructure, the institutions to back the scheme, also the staff working with climate issues was hardly a team of two people before the introduction of the scheme. After the pilot phase a Climate Change and Energy Unit is operating in the Ministry for Environment and Water with a team of five people. Besides the three ministries the National Inspectorate for Environment, Nature and Water appears on the regulatory scene, with five people, operating the Registry with the software licensed from DEFRA. EU accession has changed the environmental outlook in Hungary. The transposition of the Acquis Communautaire and the unification of Hungarian markets with EU markets, including conformity with the relevant EU directives, were the main drivers for environmental policy. (IEA, 2005) The Hungarian EU accession has led to the adoption of the EU directives. Hungary has liberalised partially both the electricity (January 1, 2003) and natural gas markets (January 1, 2004). From July 1, 2008 100% market opening is achieved, the electricity generation and distribution has been almost fully privatized, is now owned mostly by multinationals E.ON, RWE and EDF. The issue of climate change and the term cap-and-trade is becoming common knowledge. Environmental awareness in Hungary has grown considerably. A small Member State, like Hungary, cannot afford to spend too many resources on climate change issues, and it faces a greater pressure to introduce rules tailored for large installations with large bargaining power (Bart, 2007). The treatment of industries with only one or two operators is rather challenging – for instance oil refinery and the steel industry both have only one participant in Hungary, also the large power generation sector is responsible for two-thirds of all ETS emissions. Based on the interviews it may be concluded that Hungarian operators lack confidence in regulators due to serious delays, confusions, lack of their technical knowledge6 and postponing decisions. Operators feel authorities are not consequent, some minor mistakes received excessive attention while some major drawbacks go through the system. Lobbying power of some companies and sectors were the main drivers in the public consultation processes, as it will be discussed in the next chapter. 6 For instance one interviewee mentioned that Regulators could not define the difference between the CHP: combined heat and power and CCGT: combined cycle gas turbine technologies. Hence rules were confusing and contradictory. 6 Allocation of allowances and effects The lack of harmonized rules and the absence of restrictive Kyoto Protocol targets describe the allocation process in most new Member States. Three countries, Lithuania, Hungary and the Czech Republic used top-down macroeconomic analysis to forecast total expected emissions of the ETS trading sectors which was the input for the total amount of allowances to be created. The primary allocation method was that each installation's share of total emissions of its sector during the base period was the percentage used to distribute. On the other hand, Poland, Slovakia, Estonia and Latvia used microeconomic forecasting, a bottomup approach based on installations’ production forecasts. The latter countries have received more allowances than they were expected to emit. According to Bart (2007) Hungarians were disappointed when their National Allocation Plan (NAP) was approved after the approval of the more generous NAPs of Slovakia and the three Baltic Member States. Bart (2007) compares the proposed and approved NAPs and their relationship with the Kyoto targets and finds that almost all new Member States tried to allow for a significant growth in the trading sector’s emissions. Although similar attempts of old Member States were restricted by the Commission, new Member States justified the difference by their strong economic growth and by their need to benefit from the EU ETS. In the allocation process Hungary proposed a total amount that was 3.8% more than its emissions in 2002. The proposal was accepted in December 2004 by the Commission. Slovenia and Hungary were the only Member States that did not have to reduce their proposed allocation before the Commission’s approval. During the public consultation process of the NAP the powerful industry representatives were arguing for increased amounts. As mentioned earlier in smaller countries operators have a significant level of access to authorities responsible for allowance allocation, in consequence of lobbying the NAP already submitted was withdrawn, and a new version with higher quantity was submitted, 1.7% increase in allowances was exclusively allocated to large power generators. This was not only due to the government’s weakness in face of industry pressure but also the Directive was unclear about the rules for setting the total quantities. Allocation was a rather complex process, on one hand, the Ministry for Environment was responsible for setting the cap, and their goal was to keep the total amount of allowances low. On the other hand, the Ministry of Economy and Transport, which was responsible for distributing allowances among sectors, supported industry representatives claiming for more allowances. They supported the power generation industry and the miners' labor union that threatened mass lay-offs of miners if power plants had to close down due to lack of allowances. Finally the Ministry of Economy and Transport aimed at reaching the fairest solution by minimizing the number of disadvantaged and prevent participants from receiving windfall allowances. The first Hungarian NAP had a cap of 94.98 Mt for the pilot period with 2% new entrants reserve (NER), and 2.5% auction reserve (see Annex I). In the Hungarian NAP 55.6% of the total quantity allocated for free was delivered to the electricity sector represented by 18 installations. So a few dozen installations account for the bulk of emissions. During the process data collection was more difficult than previously thought. “Soft data”, i.e data not gathered for the purpose of emissions trading, was used due on one hand to the lack of time, pressing regulation and on the other hand to the fact that data gathered on the basis of previous legislation turned out to be less useful. 7 Three interesting features of the Hungarian NAP are worth mentioning: (1) „Free-riding technique“: the Hungarian NAP was among the last ones to be published and approved, so the drafters built on the structure and contents of other NAPs previously submitted. (2) Early action reserve: operators who can prove that there was a reduction in their emissions per unit of production may apply to the reserve for allowances. The early action allowances are distributed on the basis of applications, in proportion to the size of reductions achieved and above all to power plants which have switched to biomass. However during our interviews we were told that receiving the allowances from the reserve took so long that some operators received the allowance after 2008 when those were already worthless. (3) New entrants’ reserve: divided into progressively decreasing tranches across the three years of the trial period. Requests were collected during the year in order to prevent operators rushing for allowances and to distribute the risk of NER being too small. The NER for the whole period was 1.875.960 tCO2 (2005: 937.980 tCO2, 2006: 625.320 tCO2, 2007: 312.660 tCO2). It was not totally used in any of the three years. Nonetheless every installation received the requested amount, for some operators the amount was transferred only in April 2008 when they had already surrendered their allowances. Auctioning Only four countries chose to auction allowances among the twenty-five Member States. Three, Hungary, Ireland and Lithuania used sealed-bid uniform-price auctions. The auctions were open to anyone with an interest in the market, from installations needing to cover shortfalls in allowances to financial players. Denmark had a different experience, after assessing their possibilities they chose not to have an auction after all, their EPA organized direct sales through an agent instead. In the Hungarian National Allocation Plan, the Hungarian government set aside 2.5% of the total allocation, 790,000 tonnes for auctioning. On November 27, 2006 the Hungarian government announced the sale of European Union Allowances (EUA) in accordance with the Government decree 109/2006 (V.5.). Hungary sold a total of 2.4 million emission allowances at two auctions; the first one in December 2006 and the second in March 2007. The sources for the additional allowances were unclaimed NER allowances and those from closures. Auctions were implemented by the Ministry of Finance, revenue generated flew into the central budget. The situation was stressful due to the conflict of interests between Ministries, while the Environmental Department urged the Finance Department to have the auctions as soon as possible, the Finance Department was not in a rush, they could have generated more profit if selling early. The first auction took place on December 11, 2006 and sold a total of 1,197,000 EUAs for a price of € 7.42 per tonne. (see figure 2.) Bids for 3.42 million allowances were received. On 26 March 2007 a total of 1,177,500 emission allowances were on offer. Buyers have been bidding a volume of 2.4 million EUAs and the total volume offered for sale was sold, for a price of € 0.88 per tonne. The auction was a uniform-price auction where the single price was set by the lowest bid accepted by the auctioneer. The clearing price could not be lower than the minimum price determined by the auctioneer. The minimum price for the first auction was set at the Point Carbon 2007 EUA closing price index of the day before the auction minus 90 cents. Taking time value into account, this was around 60 cents less than the spot market price. (vertisfinance.com) In the second auction the 8 minimum price for the allowances for each round was 85% of the closing December 2007 forward price for the day before the particular auction round, rounded off to 2 decimals. Figure 2. Prices on the day of the first auction Source: Kaderjak (2007) The electronic auction was implemented on the euets.com CO2 trading platform. All entities or individuals holding an account at an emissions trading registry of any of the EU member states were able to participate in the auction through one of the Climex Alliance partners. Participants submitted bids for any quantity of emissions allowances up to the limit of the total number of allowances offered for sale. The electronic auction would have comprised a maximum of two sessions; if the whole amount of allowances were not sold during the first session; but at both auctions one was sufficient to sell all offered EUAs. Bidders had to place their bids in the given time period and could not withdraw them after the termination of the bidding phase. The bids were not visible to other bidders, which is known as a blind auction. The bidders needed to deposit their collateral with the clearing house of euets.com, APX B.V. or that of the Climex Alliance two working days before the date of the auction. The clearing and settlement of the transaction entered into during the auction was completed in two business days following the auction. Successful bidders could request the transfer of the purchased allowances by the clearing house to their holding accounts one business day after clearing. Bidders could request the refund of any unused collateral one business day after clearing. (€ per tonne) Clearing price Daily market price December 11, 2006 7.42 7.10 March 27, 2007 0.88 0.98 Table 1. Comparing clearing and market prices Source: Fazekas (2008), Daily prices from Vertis Environmental Finance. It is interesting to compare clearing prices to daily market prices. Table 2. and also figure 2. show that on the day of the first action the auction clearing price was higher than the daily market price. Based on economic theory this contradicts the rational market behavior. Explaining this particularity is however out of the focus of this paper. 9 Development of the EUA market Overall, the Hungarian carbon market is maturing, the system works with some issues left to resolve. Almost all support mechanisms are working, also the ITL-CITL connection has been set up by the time of writing this paper, it started in July, 2008. Nonetheless legal, tax, and accounting issues are not fully developed at companies. Financial services relating to CO2 emissions allowances were available through investment service providers - banks and brokers - as in the case of securities and commodities transactions. Hungarian operators could not sell their surpluses when the EUA price was still around 30 € s due to the long approval process of the NAP and delays of the Registry. The Hungarian Registry started operation on April 11, 2006 slightly before the publication of 2005 emissions data, when the carbon price collapsed. At that time the Dec 2006 EUA price was 29.43 € s. The Hungarian trading platform operated by Vertis Environmental Finance started spot trading on the euets.com CO2 stock exchange7 on April 20, 2006, until then only forward transactions were available. The euets.com is the first internet-based CO2 stock exchange in Central and Eastern Europe, a company may join the trading platform in case it has an operator’s account in the Transaction Log of any EU Member State or has a permit from the financial supervisory body of any EU Member State. Hungarian companies mostly traded via brokers, few companies joined exchanges and some did not appear on the market, while subsidiaries of multinational firms used the central trading desk, and Hungarian departments received extra allowances in case needed and had to surrender their surpluses, mostly independently from the carbon price on the market. Players on the Hungarian carbon market are Vertis Environmental Finance Zrt, Carbon Capital Markets (CCM), Evomarket, STX Services and multinational’s trading desks (EDF, EON). Based on our interviews those operators traded early who were confident, completely sure about their surplus. For example a Hungarian operator sold its surpluses for more than €8 millions in 16 transactions, with an average price of €15. Another operator tested the system by pilot sales; a good price was achieved then. Nonetheless later trying to sell the entire surplus, at a lower price, the income hardly covered administrative expenses. Most Hungarian players appeared on the market just after their yearly compliance became clear, moreover some installations waited to sell even until April 30, 2008. Based on data from CITL and the Hungarian Registry it may be concluded that Hungary both imported and exported allowances from and to other EU Member States, parallel to domestic transfers. This reflects that Hungary at the country level as well as at the corporate level effectively exercised the opportunity to access the European carbon market. Based on the CITL data, which builds upon surrender information, the net quantity of allowances transferred by Hungary equaled to 9.75Mt, the equivalent of 10.75% of distributed allowances. The gross Hungarian export was more than 10Mt CO2 allowances, representing a value transfer of €35 millions into the country. Table 4. reveals net flows, exported minus imported allowances. Positive numbers indicate transfers from Hungary, EUAs originating in Hungary, then surrendered in other countries. Negative numbers indicate transfers to Hungary, foreign EUAs surrendered in Hungary. Interestingly, despite the abundance of allowances in Hungary 323 thousand allowances were imported, mostly in 2007, hence the price paid by Hungarians did not reach €400 thousands. Values are calculated in accordance with the methodology of the APREC team, we used average prices for each compliance year: €20,6, €16,6 and €0,6 respectively. International transfers represented an income of €52,164,937 during the pilot phase, equivalent to 0.05% of the Hungarian GDP. 7 Source: www.vertisfinance.com and www.euets.com internet portals. 10 Net Flows (Export - Import) t CO2e 2005 2006 Austria Belgium 2007 Value associated to transfers to Hungary (€) 2005-2007 34 703 34 703 20 000 1 458 070 1 478 070 332 505 332 505 2005 2006 332 000 2007 2005-2007 20 822 20 822 874 842 1 206 842 199 503 199 503 Cyprus Czech Republic Denmark 58 827 Estonia 58 827 1 211 836 -5 908 -32 784 -38 692 19 460 19 460 -108 057 -114 160 457 172 2 042 476 2 499 648 Finland France -6 103 Germany Greece 1 211 836 -98 073 -19 670 -117 743 11 676 11 676 -64 834 -166 144 7 589 055 1 225 486 8 814 541 -101 310 2 500 10 000 12 500 41 500 741 742 338 931 1 080 673 12 312 917 224 224 11 317 23 183 34 500 5 524 357 503 363 027 -159 261 1 111 Romania 245 873 Slovakia -11 494 6 000 47 500 Ireland Italy Latvia Lithuania 203 359 12 516 276 134 134 187 862 13 910 201 772 91 698 214 502 306 200 -159 261 14 807 -95 557 -80 749 -163 -21 148 667 -20 481 245 873 147 524 147 524 -11 494 -6 896 -6 896 Luxembourg Malta Netherlands Poland Portugal -1 274 Slovenia Spain Sweden 15 358 521 590 4 100 4 100 570 962 1 107 910 14 14 United Kingdom 1 054 610 1 743 307 Total 74 185 2 801 170 6 870 826 316 375 8 658 394 2 460 2 460 342 577 9 317 346 8 8 2 797 917 17 506 526 1 045 984 18 552 510 9 746 181 1 528 211 46 514 228 4 122 497 52 164 937 Table 2. Net flows from/to Hungary Source: Author’s calculations based on CITL data from APREC Besides external trading, based on data from the Hungarian Registry (see also Annex V.), internal trading in Hungary amounted to almost 5 million EUAs during the first phase, starting from the opening of the Registry on April 11, 2006 until April 30, 2008 (see table 5. below). Hungarian operators traded more than 4.5 million EUAs among themselves and more than 400 thousands allowances were transferred to personal accounts. Calculating with the average prices above domestic transfers represent a value transfer of €73.5 millions during the pilot phase, equivalent to 0.07% of the Hungarian GDP. Comparing the extent of domestic transfers to foreign transfers, our finding that most of the transfers took place with parties in other Member States is not surprising since short installations in Hungary were uncommon. The cumulative short position of Hungarian installations was in the order of 4 million EUAs (see also figure 3.), this deficit could easily be covered by domestic transactions of 4.5 million plus imports of 323 thousand EUAs. 11 2006 EUA Transfers between Hungarian operators Transfers from Hungarian operators to Hungarian personal accounts Transfers between Hungarian accounts (Total) 2007 No. of transaction 2008 No. of transaction EUA EUA 2006-2008 No. of transaction EUA No. of transaction 1 846 804 38 1 737 049 30 922 407 57 4 506 260 125 131 035 6 200 000 1 81 461 6 412 496 13 1 977 839 44 1 937 049 31 1 003 868 63 4 918 756 138 Table 3. EUA transfers within Hungary between April 11, 2006 and April 30, 2008. Source: Hungarian Registry, personal e-mail communication (2008) As presented on the tables above there was a considerable amount of movement among market players, both internationally and within Hungary. Comparing the extent of exports to the overall long position of the Hungarian EUA market we must state that less allowances left the country than the potential supply. The allocation for the entire pilot phase was 90,708,498 EUAs, verified emissions were 78,843,048, thus the Hungarian carbon market was long by 11,865,450 EUAs. Based on the CITL data the net flow of Hungarian exported EUAs was more than 9.5 million EUAs, based on the Hungarian Registry it was around 9 million EUAs8. Both are more than 2 million EUAs less than the potential supply of Hungarian operators, which were neither transferred to another Member State, nor surrendered in Hungary. Thus the first period surplus was on the order of 12 million EUAs and Hungarian operators managed to transfer or sell more than 9 million to accounts in other Member States. Despite that Hungary did not appear on the market with all its over-allocation, we may conclude that 75% to 80% is a rather high degree to which the surplus was in fact sold.9 Comparing CITL data to that of the Hungarian Registry reveals an interesting feature, the timing of the transfers. On one hand, the Hungarian Registry registered two-thirds of transfers from Hungary abroad in 2006 (see Annex V.) On the other hand, more than 70% of the surrenders of Hungarian EUAs in other MS's occurred in 2007 (see table 2). This timing suggests that Hungarian operators realized the revenue generating potential of selling their surpluses on the European carbon market. Unfortunately due to limited data availability we may only conclude that Hungarian operators sold at a higher price than suggested by the surrender data. 8 The cause of the inconsistency is not yet revealed, but it is most probably due to the different datasets of the systems. Information on international transfers was constructed based on surrender information from the CITL. On the contrary the Registry builds on actual transactions from and to the country. 9 Based on personal communication with Denny Ellerman. 12 Emissions and abatement CO2 abatement as an indicator to measure the level of investment in technologies or capacities can only be measured in longer term than the three years of the Phase I of the EU ETS. Short term emissions abatement measures, such as switching to less carbon-intensive fuels or increasing energy efficiency, occurred without doubt in Hungary as well, albeit Hungarian sectors were overall long, meaning that more allowances were allocated in Hungary than were needed by installations. Significant net long positions occurred in Hungary (14%) accounting for 12 Mt CO2 during the three years. While the overall Hungarian market was long (see figure 3. below), some installations, mainly in the combustion sector, were short on allowances. Figure 3. Long and short positions of Hungarian ETS sectors Source: Author’s calculations based on CITL data from APREC An important issue for the new Member States regarding the EU ETS was the lack of reliable baseline data for CO2 emissions. For most installations, no historical data had ever been collected at all, it was very important to assess the mass balance measurement process and thoroughly examine all possible sources of emissions. Our interviews confirmed the widespread belief that baseline emissions were often inflated (Ellerman and Buchner, 2006). Hungary's greenhouse gas emissions in 2006 totaled 78.6 million tonnes of carbon dioxide equivalent (CO2e), 2 per cent down on the previous year, according to data released by the National Meteorological Service. The setback is mainly due to the milder winter that curbed energy demand for heating, the authority said, although long-term emission trends show a stagnation of Hungarian emissions since 1992 due to the collapse of heavy industry. At 40% of Hungarian installations emissions increased, and decreased at 60% during the pilot phase. Based on our interviews nothing tangible can be measured in aggregate data so as to the impact of EU ETS on Hungary during the first phase of the scheme. The effect if any has been non significant at best, and positive for the sectors in some cases. No reductions were achieved clearly attributable to the introduction of the EU ETS due to the loose target and the overall long position of the market. According to interviewees the system was not motivating, operators perceived the scheme as an administrative burden to comply with. This study’s main conclusion is that EU ETS has been effective in inducing firms to build their capability to respond to a carbon price signal, but has not led to significant emissions abatement in the pilot phase. 13 Impacts on Hungarian EU ETS sectors The pilot phase was a learning phase for the Hungarian economy, for decision-makers and also for operators, it raised awareness, and most importantly, carbon price appeared in their decisionmaking processes. Hungarian installations did not have to struggle for EUAs during the pilot phase as most installations in most sectors were overallocated. Operators did not have to worry about compliance, although they voiced their concerns over the stricter allocation for the Kyoto compliance period. For every Hungarian company the first phase of the EU ETS was rather neutral due to the over-allocation. According to operators, lobbying for loose and generous allocation was the optimal attitude in order to comply. The second phase allocation was expected to be based on the first one, so receiving more allowances in the pilot phase seemed to secure compliance for the Kyoto phase as well. Interestingly, the economic rationale of selling the surplus and thus generating profit was not mentioned by any of the interviewees as a reason to lobby for more allocation. In theory, free allocation amounts to compensating companies for the introduction of a cost on carbon (Grubb and Neuhoff, 2006). Allowances given free represent a rent transfer, in the form of a financial asset that can be sold on the carbon market. Free allowances thus have an opportunity cost, it is the cost of emitting an additional tonne of CO2, which means that one less freely allocated allowance can be sold on the market (Ellerman, 2005, p.130). Since most Hungarian installations were in a long position, the ETS was not a real constraint, they could emit as they would without a CO2 price and simply surrender the equivalent number of allowances. This however does not mean operators were not recognizing the opportunity cost of carbon allowances. This study presents two specific cases where the opportunity cost of freely allocated allowances were clearly recognized but we must state that most operators were apparently not doing so. Some long installations did not realize the potential for revenue generation and kept their allowances until the end of the pilot phase when it was already worthless. Nonetheless some operators made fortunes by selling early. This study presents ETS implications of four sectors receiving the bulk of Hungarian allocation. Table 4. Sectoral distribution of NAPI Combustion Cement Iron and steel Refineries Ceramics Metal ore Glass Coke ovens Paper and board Total Allocation 65,522,637 72.23% 8,564,688 9.44% 6,583,995 7.26% 4,149,510 4.57% 2,596,341 2.86% 1,003,191 1.11% 886,260 0.98% 792,699 0.87% 609,177 0.67% 90,708,498 100.00% Power generation Although the EU ETS was overall neutral to the power generation sector due to over-allocation, effects differ for coal, gas, lignite, and biomass fired power plants. Fuel-switch from coal to biomass represents the most common abatement possibility revealed by interviewees. One power plant manager revealed that after the price collapse of carbon allowances they switched back to coal, which clearly indicates the appreciation of the value of allowances relative to the cost of abatement. It may be concluded that the system could have had an impact, were the prices reasonable on the market. Two features worth mentioning are (1) the debate about BAT references 14 for cogeneration between industrials and the authorities, and (2) the growing interest for carbon capture and storage (CCS) by multinationals and their Hungarian subsidiaries. Cement production According to the head of the association of cement industry the entire Hungarian cement sector was long in the first period. That is the rationale behind the fact that industrials were not concerned with the allocation but rather with rising energy prices, strong competition on the market and the substantial delays of public investments. The bulk of allowance sales from the cement industry were done through the central trading desk of HOLCIM Heidelberg company. Iron and steel The strategic-technical director of the most significant Hungarian steel maker pointed out that carbon emissions in the iron and steel sector are due to technology hence cutting CO2 emissions is only achievable by reducing production. In his opinion, the only abatement possibility is relocating production e.g. to Ukraine, where EU ETS has not been introduced. This is the so called leakage. Oil refinery Interviews revealed that a Hungarian owned company had successfully internalized carbon price by managing the firm's allowances centrally and introducing carbon pricing into the profit and management evaluation criteria. Their linear programming models used to maximize plant profitability were modified by adding new constraints representing the cost of every tonne of CO2 emitted as a result of operational decisions. The carbon constraint amounts to €25/t presently and will increase to €40/t from 2012. It is built into each business unit’s performance assessment by focusing on EBITDA corrected with CO2 emissions indicators. The opinion expressed by the chief economist in the refinery sector we met overlaps with the findings of Lacombe (2008) that risks of leakage are of concern to them in the long run through capacity relocation. He concluded a very limited pass-through potential. Although cost of carbon in the pilot phase was too low to create strong incentives for actors to change their operations, it has compounded with the recent increase in energy prices and led companies to become much more serious about energy efficiency investments. Operators need time to learn that carbon allowances are assets that are subject to trading and also that banking and/or borrowing, and later selling them on the market represent an option to generate profit instead of normal production where carbon allowances are used. A question for the interviewees was to know whether they cut production down because of the carbon price. Such an outcome was irrelevant for the entire Hungarian ETS sector, it had at best a marginal impact on production choices and emission outcomes. In the short run, the impact of EU ETS on operations was minimal. All interviewees in all sectors agreed that the system is unreliable and unpredictable due to tremendous delays. Even half a year after the start of the second period Hungarian installations do not know their Phase II allocations. Interviewees only guess that their position is going to be short, which renders business planning even more difficult. We must conclude that such a system will undoubtedly have negative effects on all players if the rules of the game are set late and the circumstances are uncertain. 15 Joint Implementation projects Since Hungary meets the eligibility requirements, track one JI procedure is pursued, meaning that Hungary as the host party of JI projects wishes to apply its own national rules and procedures to the selection of JI projects and the estimation of emission reductions from them. In order to facilitate the implementation of JI projects, the Ministry for Environment and Water has developed the procedure for evaluating and approving JI projects. It created and maintains a web site with the relevant, updated information on the application procedure and general information on JI projects. It developed a manual that defines the additionality criteria for Hungarian JI projects and it regularly publishes the list of already submitted project initiatives and their status. In early 2002, US energy group AES`s power plant in Kazincbarcika was considering a pioneering fuel switch from coal-firing to biomass-firing. This was the first ever JI project in Hungary, the Ministry for Environment had never before issued approvals for Kyoto Protocol transactions. AES sold the Emission Reduction Units (ERU) to the Dutch government raising over €3 million of funding, 25% of the project cost. In 2004, Hungarian fertilizer manufacturer Nitrogénművek began planning a new nitric acid plant to replace its old plant in Pétfürdő in Western Hungary. A private bank acquired the ERUs from the project which reduced N2O emissions by over 2 million tonnes of CO2 equivalent. The project will ultimately raise between €12 and €20 million for the client, covering a substantial portion of the funding for the new nitric acid plant. There has already been a significant amount of JI projects in Hungary, regarding the number of projects approved most of them focus on wind energy and biomass utilization. Green Investment Scheme and trading with hot air Along with Joint Implementation Hungary intends to use International Emission Trading (art. 17 of the Kyoto Protocol) with guaranteed “hard greening” of the revenues from these activities. The Hungarian Ministry for Environment and Water has set up a Green Investment Scheme (GIS) for which the Hungarian cabinet adopted the last legal provisions on December 5, 2007. The framework aiming to lend environmental integrity to governmental carbon credits under the Kyoto Protocol demands that all activities supported by the scheme result in reductions of GHG emissions, so that buyers of the credits can be sure that the money they pay will be invested in climate friendly activities. Activities will focus on energy efficiency, energy saving and renewable energy (FeilerRabai, 2007). Availability of Assigned Amount Units (AAU) for the use of flexible mechanisms is determined by the total quantity of AAUs available for the country, the size of the commitment period reserve, likely emission trends till the end of Kyoto commitment period and the amount of AAUs necessary to be set aside for the generation of ERUs for Joint Implementation projects. (Feiler-Rabai, 2007) For Hungary the approved assigned amount is 542,366,600, and the commitment period reserve is 394,987,486 AAUs. According to emission trends for the commitment period by the Fourth National Communication of Hungary 432-443 million AAUs are needed to be set aside to cover domestic emissions. For the already approved JI projects a reserve of 10 million AAU is likely to be sufficient and no major new JI projects are foreseen. Considering these factors Hungary owns some 89 million AAUs, which can be used for sale in international emission trading or for banking for the post-Kyoto period. Hungary’s strategy is to sell 10 million AAUs in an initial phase, to test its GIS. If successful, the country plans to sell another 30-40 million AAUs over the Kyoto commitment period. No sales were organized during the pilot phase, but it is worth mentioning that on December 18, 2007 Hungary signed its first basic agreement with Japan to sell AAUs. 16 Conclusions and outlook During the pilot phase of the EU ETS Hungary has learned considerably about using emissions trading, using the market in order to reduce GHGs. The infrastructure, the institutional background has been set up, although with considerable delays but we might say it was due to the time pressure, which was the same even for the EU15. The Registry is up and running, the spot market has developed. The major part of Central and Eastern Europe uses the Hungarian trading platform. By January 1, 2008 only three countries had received UN approval to trade within the flexible mechanisms, Hungary among them, with Japan and New Zealand. In February 2008, Hungary adopted its National Climate Change Strategy in order to meet its obligations. The strategy will be financed from the government's environment and energy operational program and from sales of Kyoto carbon credits through the Green Investment Scheme, first to be up and running in the region. Hungary is one of only a handful of states to have used provisions in the ETS Directive allowing governments to auction allowances. The Hungarian experience serves as evidence that a new market economy has the institutional capacity and technical expertise to carry out auctioning. This confirms that Hungary at the state level realized the revenue generating opportunity behind emissions trading. There was a considerable amount of movement among market players, both internationally and within Hungary. Volumes and frequency of domestic and foreign transfers prove that Hungary was actively involved in the allowance market. The timing of transfers and surrenders suggests that Hungary, also on the corporate level, realized the revenue generating potential of selling surpluses on the European carbon market. Hungarian installations did not have to struggle for allowances, operators did not have to worry about compliance during the pilot phase. Based on the interviews the impact of the EU ETS on operations was minimal, the effect if any has been non significant at best, and positive for the sectors in some cases. This study finds evidence that some operators are recognizing the opportunity cost of freely allocated allowances, although some long installations kept their allowances and their surplus did not appear on the market. Our interviews revealed two examples of economically rationale behavior: one power plant switched back to coal from biomass when the allowance price dropped, and one firm introduced carbon pricing into their profit and management evaluation criteria. We must conclude that these two instances are both attributable to those two persons in their positions. The main conclusion of this study is that Hungary both at the country level and at the corporate level effectively exercised the opportunity to access the European carbon market. It will be interesting to look at the Kyoto phase for which a short position is foreseen even in Eastern EU. Whether operators have learned their lesson and whether they will forfeit the Kyoto period remains the subject of a possible next paper. 17 Annex I. – Hungarian NAP I Emissions allowances to be allocated to existing installations free of charge I/a-I/b. I/b. I/c. Quantity of emissions allowances (CO2 tonnes/year) 16,927,857 2,267,091 2,100,160 Electricity generation* District heating Combustion for internal purposes (except for sugar industry) I/d. Sugar industry 431,479 II. Mineral oil processing 1,383,170 III. Coking 264,233 IV-V. Roasting and concentration of metal ores; iron and steel 2,643,354 production* VI/a. Cement production 2,390,321 VI/b. Lime production 464,575 VII. Glass production 295,420 VIII. The production of roof tiles, bricks, fire-resistant bricks, 865,447 wall tiles, stone products and china IX-X. The production of cellulose, paper and cardboard 203,059 1. Total for existing installations 30,236,166 2. New entrants’ reserve 633,218 TOTAL FREE OF CHARGE (1+2) 30,869,384 3. Quantity to be allocated for compensation 791,523 TOTAL FOR SECTORS (1+2+3) 31,660,907 * Including the quantity to be transferred by the sector later under point 15 of the Allocation Plan. Source: Hungarian Ministry for Environment and Water 18 Breakdown of the number of installations by Annex I activity Mineral Iron Pulp Combustion oil Coke Metal and Cement Ceramic and Optinstallations refineries ovens ore steel clinker Glass products paper in Total 151 1 1 2 8 7 9 50 6 0 235 Combustion installations with a rated thermal input between 20 and 50 MW Installations Emissions Share of national Share of total installations national % Number t CO2 eq emissions % 71 30 1,103,424 4.2 Breakdown of installations by emission categories — number of installations Emissions in kt CO2/year < 500 500 to 50,000 50,000 to 500,000 > 500,000 Total Number 5 177 40 12 234 Breakdown of installations by emission categories — emissions < 500 500 to 50,000 50,000 to 500,000 > 500,000 kt CO2 per year 0.3 2,843 5,859 17,325 % 0.0% 10.9% 22.5% 66.6% 19 Total 26,028 100% Annex II. - Firms interviewed receive the bulk of allowances Installation Percentage of Cumulative Allowances allowances percentage Sector Mátrai Ltd. Visontai Power Plant 1-Combustion 20 382 318 22,47% 22,47% Dunamenti Power Plant 1-Combustion 7930539 8,74% 31,21% Dunaferr Company Group 5-Iron and steel 5 769 828 6,36% 37,57% Oroszlányi Power Plant 1-Combustion 5 185 509 5,72% 43,29% AES Tisza Power Plant 1-Combustion 4 307 580 4,75% 48,04% MOL Duna Oil Refinery 2-Refineries 4 149 510 4,57% 52,61% Csepel II. Power Plant 1-Combustion 2 432 598 2,68% 55,30% Vértesi Ltd. 20 Annex III. – Auctions in the pilot phase Allowances set aside for auctioning EUAs EU25 Denmark Ireland Hungary Lithuania Phase 1 7,499,201 5,025,000 502,201 1,420,000 552,000 % 5% 0.75% 2.5% 1.5% Allowances actually auctioned EUAs 2005 EU25 Denmark Ireland 0 0 250,000 2006 2,410,000 2,762,500 + 963,000 2007 5,029,500 1,618,500 0 Phase 1 7,439,500 4,381,000 1,213,000 % 4.35% 1.81% 0 Hungary Lithuania 0 0 1,197,000 1,177,500 2,374,500 4.18% Source: Fazekas (2008) 21 0 552,000 552,000 1.5% Annex IV. – Accounting Aspects of Emissions Allowances Entered as intangible assets Reducing profits Increasing profits Recognition Free allocation Entered as goods Reducing profits Increasing profits As extraordinary revenue Accrual of extraordinary revenues (as a delayed revenue) Other typical recognition Assessment Market price Unplanned below the book depreciation as value other expense Market price above the book value As extraordinary revenue Accrual of extraordinary revenues (as a delayed revenue) The proportionate resolution of the accrual upon the accounting of the allowance as a cost or expense No effect on profits nor losses Depreciation as other expense The reversal of unplanned depreciation as other revenue (Value correction against the assessment reserve – effect on the capital) Provision The creation of a As other expense provision on the balance sheet day The resolution of the provision by April, 30 Derecognition Usage As other expense Sale Book value as other expense The proportionate resolution of the accrual upon the accounting of the allowance as a cost or expense The reversal of depreciation as other revenue As other expense As other revenue Sale price as other revenue Fees, penalties Supervisory fee As expense for Administrative fee other service Account holding fee Penalties As other expense Interest on arrears As other revenue As other expense Book value as purchase value of sold goods As expense for other service As other expense Source: Fazekas – Andor (2008) 22 Sale price as net price revenue Annex V. – Transactions based on data of the Hungarian Registry 2006 No. of transaction EUA Transfers from other MS to Hungarian operators Transfers from other MS personal accounts to Hungary Transfers from other MS to Hungary (Total) 2008 No. of transaction EUA Phase I No. of transaction EUA No. of transaction EUA 18 688 1 96 200 4 451 1 115 339 6 611 322 20 452 832 18 343 554 13 1 407 708 51 630 010 21 549 032 22 344 005 14 1 523 047 57 192 2 605 788 62 1 311 356 25 10 260 616 279 6 200 000 1 67 344 198 2 805 788 63 1 378 700 Transfers from Hungarian operators to other MS 6 343 472 Transfers from Hungarian personal accounts to other MS 131 035 Transfers from Hungary to other MS (Total) 6 474 507 Transfers between Hungarian operators Transfers from Hungarian operators to Hungarian personal accounts Transfers from Hungarian personal accounts to Hungarian operators Transfers between Hungarian accounts (Total) 2007 2 27 398 379 9 10 658 995 288 1 846 804 38 1 737 049 30 922 407 57 4 506 260 125 131 035 6 200 000 1 81 461 6 412 496 13 0 0 0 0 0 0 0 0 1 977 839 44 1 937 049 31 1 003 868 63 4 918 756 138 Source: personal e-mail communication with the Hungarian Registry (2008) 23 Annex VI. – Hungarian JI projects This table presents an overview of the Hungarian JI projects under approval. LoE stands for Letters of Endorsement, LoA means Letters of Approval. The first five projects have already been implemented as of April 2008. Project supplier AES Borsodi Power Plant Bakonyi Power Plant PANNONPOWER Co. Project owner ERUPT (Netherlands) Senter Novem (Netherlands) PCF (World Bank) IBRD Status Type of project Location LoA biomass conversion Kazincbarcika LoA biomass conversion Ajka LoA methane utilization from landfill methane utilization from abandoned landfill methane, biogas utilization geothermal methane utilization energy efficiency improvement Nyíregyháza Exim-Invest Biogas Ltd. CCCCT Sarl (Luxemburg) LoA Pálhalmai Agrospeciál Ltd. JI/CDM tender (Austria) LoE BÁTORTRADE Ltd. CDC IXIS Bank LoA ENVIROINVEST Ltd. Mitsubishi C. (Japan) LoA Mitsubishi C. (Japan) LoA biomass conversion Pécs LoA conversion coal-to-gas Tatabánya LoA biogas utilization Pálhalma General Electrics LoA CHP from biomass Balatonfüzfő ERUPT (Netherlands) LoA PCF (World Bank) LoA ERUPT (Netherlands) LoA wind energy generation Osttffyasszonyfa LoA biomass Dél-Nyírség LoA acid prod. - N2O emission reduction Pétfürdő LoA suspended methane utilization Nagykanizsa, Orosháza, Baja LoE biogas utilization Sajóbábony LoE co-generation (gas) Salgótarján LoE co-generation Szeged LoE methane from landfill Gyöngyös, Göd, Salgótarján MÁV Hungarian Railways Co. GREEN PARTNERS, BGP Engineers BV Framex Bioenergia Ltd. Independent Energy Production Ltd. SZEGEDI Hőszolg. Ltd. – Démász/BKZ Szombathely District Heating Ltd. Vértesi Power Plant Co. ERUPT (Netherlands) ERUPT (Netherlands) Euroinvest Co. – Füzitő GM Ltd. EETEK Ltd. Alberirsai Wind Power Park Ltd. Eurowind Hungary Ltd. Hungarowind Wind Power Plant Füzfői Power Plant Ltd. Debreceni Hydropower Co. ERUPT (Netherlands) ERUPT (Netherlands) ERUPT (Netherlands) JI/CDM tender (Austria) ERUPT (Netherlands) ERUPT (Hollandia) 24 wind energy generation wind energy generation Debrecen Nyírbátor 34 locations 81 locations Rácalmás Kimle Project supplier Callis CRt. Kaptár "B" Energetika Ltd. Project owner JI/CDM tender (Austria) JI/CDM tender (Austria) E.ON Hungária Co. Pannon Wind Ltd. Liget Bioenergy Works Ltd. Callis Co. Nitrogénművek Co. Status LoE LoE LoE JI/CDM tender (Austria) Tohoku Electric Power Co. Inc. (Japan) JI/CDM tender (Austria) many project owners (Austria...) LoE Type of project wind energy generation wind energy park wind energy generation wind energy generation wind energy generation Location Albertirsa - Ceglédberc Pusztaszabolcs Sopronkövesd Tét Kimle Károlyháza Kisigmánd LoE gases recovered from spas 26 locations LoE acid prod. - N2O emission reduction Pétfürdő LoE forest colonization 10 locations Source: Hungarian Ministry for Environment and Water, personal e-mail communication (2008) Source: Hungarian Ministry for Environment and Water (2007) 25 Annex VII. – GIS framework and the potential hot air in Hungary Source: Feiler-Rabai (2007) Source: Fogarassy, Cs. - Lukács, A. - Nagy, H. (2008) 26 References Bart, I. (2007): Hungary. In. Ellerman, A. D. - Buchner, B. K. - Carraro, C. (ed.) Allocation in the European Emissions Trading Scheme: Rights, Rents and Fairness. Cambridge University Press Ellerman, A. D (2005): A Note on Tradeable Permits, Environmental & Resource Economics 31 pp. 123–131. Ellerman, A. D. - Buchner, B. K. 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