Dóra Fazekas Carbon Market Implications for new EU - UniCredit ...

eact efficiently to regulations. The division and sharing of labor in this way is necessitated by the
complexity of the data and the information involved: emissions data are recorded in one location,
whereas the accounting of allowances is done elsewhere by a different unit, and a third department
may be responsible for the trading of allowances. Most important, naturally, is the flow of
information, and this is not something one single individual can be responsible for; but the
coordination of different organizational units is critical to the success of the scheme.
Most companies, the author found, chose the member of the staff for these tasks who had already
collected experience with the system previously – through the JI project, for instance. In many
cases, it was difficult for the author to find just who the individual tasked with these duties is. In
many cases, the individual listed in the Allocation Plan did not even know that they had been
provided as the point of contact. The positions held by the individuals responsible for the system
also varied greatly: the author met Fuel Managers, Consultants, Senior Engineers, Group Trading
Directors, Managing Directors, Energy Traders, Deputy CEOs in charge of strategic and technical
issues, Environmental Managers, Deputy Department Heads, Chief Economists, Energy Directors
and Trade Officers – all of whom were responsible at their particular company for EU ETS issues.
There were companies where oversight of the system belongs under the purview of an
environmental protection office, while a separate CO2 accounting office also exists; in some cases,
an Environmental, Health and Safety office is responsible for the scheme. And in some cases, the
trading office is responsible for the EU ETS. Finally, there was also a company where an internal
consultant was tasked with all administrative matters related to the scheme.
Generally, Hungarian companies included EU ETS issues in their regular decision-making
processes; in most cases, however, investments aimed at the abatement of emissions, as well as
decisions related to the purchase or sale of allowances, required approval from the senior leadership
of the company. In the author’s opinion, it is not necessarily prudent to separate decision-making
responsibilities in this way, as doing so may, in some cases, lead to results which are ultimately at
odds with the company’s interests. For instance, if a lengthy approval process is required to sell or
purchase allowances, that makes it difficult to do so, and to do so quickly, and react to changing
market prices. Or, also, if monitoring emissions and allowance trading is not done by the same unit
or the same individual, the company may not necessarily receive an appropriate number of
allowances.
Nonetheless, the EU ETS pilot phase introduced, without a doubt, real changes to the way
companies do business. Above all, they had to establish a monitoring system, set up a registry for
monitoring CO2 emissions, and had to procure the software and measurement devices necessary.
Hungarian companies, for the most part, did not wish to take risks; in most cases, they prepared an
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