1. National Carbon Registry
A Proposal for Turkey
Amit Bando
Ankara, Turkey
March 23, 2010
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ambando@gmail.com

2. Agenda
The Current Situation in Turkey
Essential Features of a Carbon Registry
The Proposed Turkish Carbon Registry
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3. The Current Situation in Turkey
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The Turkish private sector is an active participant in Voluntary Carbon
Markets (VCMs)
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100% of Turkey’s carbon projects are designed for VCMs
VCMs account for less than 1% of Global Carbon Markets
63% of all VCM wind projects are of Turkish origin
Strong renewable energy potential - currently, out of 64 projects, there are
34 wind, 22 hydro, 2 geothermal and 2 landfill gas projects
Estimated emissions reductions of 22.6 MtCO2e by 2012
Projects worth US$ 220 million by 2012 (Ecosystem Market Place, 2008)
VCMs are defined by a lack of regulatory drivers
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Operate alongside their regulated market cousins
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Heavily influenced by them
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4. The Current Situation in Turkey (continued)
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Most Turkish VCM projects have used the Gold Standard
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High level of market credibility ensures high value for the verifiable emissions
reductions (VER) certificates
Very similar to the Clean Development Mechanism (CDM) standards
Turkey is an Annex-1 (non Annex-B) country under the UNFCCC
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Faces no legally binding emissions reduction targets
Cannot participate in the largest global compliance carbon markets
Cannot use the Kyoto “Flexibility Mechanisms” that include:
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Emissions trading, Joint Implementation (JI), and the Clean Development Mechanism
(CDM)
Turkey is negotiating for EU accession
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Not ready to curb economic targets to voluntarily cut GHG emissions
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Likely starting point for all negotiations with the EU
Will shape Turkey’s general strategy in her accession negotiations and in
negotiations for post-2012 climate regime
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5. The Current Situation in Turkey (continued)
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Turkey’s private sector has evolved in the VCMs through” learning by
doing”
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Ministry of Environment and Forestry (MoEF) is key agency involved in
carbon markets
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Lack of government rules and regulations
Lack of institutional support mechanisms
Lack of information on carbon markets at the government level
Also the focal point for the European Environmental Agency
Responsible for harmonizing national environmental laws with EU norms
Several departments in charge of sectoral emissions control, EIAs, etc.
National Coordination Board on Climate Change (NCBCC) is
responsible for overall climate change policies
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Established in 2001 and revamped in 2004 (through Prime Minister’s
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6. The Current Situation in Turkey (continued)
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Some key concerns exist
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The average reported value of US$ 9.4/tCO2e for Turkey’s VCM credits is
about one quarter to one half of the potential value in compliance market
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Turkey is an Annex 1 country poised for EU accession – both paths
potentially lead towards a future emissions commitment
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Undervaluation of carbon assets places nation at a long-term disadvantage
because it is selling off its carbon assets at low prices
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Especially true for projects that could have strategically delayed carbon
reductions to maximize life cycle value (e.g., efficiency enhancement
projects with a time frame of 30-50 years)
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7. The Current Situation, Though in a Flux,
Provides Immense Opportunities
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As part of a National Carbon Management Authority, a
Carbon Registry can help
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Increase the value of Turkey’s carbon assets
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Build on momentum provided by private sector participation in the
VCMs
Provide an institutional base on which to build a compliance based
carbon regime in the future
Turkey is poised to “seize the day”
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8. Agenda
The Current Situation in Turkey
Essential Features of a Carbon Registry
The Proposed Turkish Carbon Registry
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9. Carbon Project Registries: Tracking the Trades
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Registries provide a host of market services
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Tracking credit sales and ownership
Increasing market efficiency through information sharing
Protecting against “double counting.”
Registries are typically classified into two categories
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Emissions tracking registries
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Track buyer entities’ emissions and reductions
Establish baselines and account for emission reductions
Critical tool for cap-and-trade systems
Carbon credit accounting registries
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Report on transactions of credits, allowances, and offsets
Create a “substantial new commoditized, fungible asset class”
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10. Carbon Project Registries: The Architecture
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Most registries
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Are public or semi-public databases and transparent
Depend on third party standards to screen and classify credits
Impose some level of legal liability on registrants
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Third party verification is not required - but 87% of all credits in the
voluntary OTC market are third party verified
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Several standards are popular
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VCS -- used by 24% of organizations
Gold Standard -- used by 18%
VER+ -- used by 10%
CCSB -- Used by 10%
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11. Carbon Project Registries: The Cost
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The cost of listing credits on an OTC registry varies widely
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Environmental Resources Trust (ERT)’s GHG Registry charges
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$2,000 - $6,000 for opening an account
annual renewal fee of $1,500 to $5,000
$.035/ tCO2e administrative transaction and software system fee.
New Zealand-based Registry Company (known as “Regi”)
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Difficult to pin down - registries bundle their services differently.
account registration for buyers/sellers is free
per-project verification costs are $149
transaction fees around $0.23 per credit transferred
$0.04 for each credit retired (fixed cost of $1.12 for each transfer)
ERT services can include third party verification, whereas Regi only accepts
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credits that have already passed inspection by a certification service.

12. Carbon Project Registries: Usage Data
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Several registries are being used
 CCX -- 12%
 Blue Registry -- 13%
 CDM/JI -- 18%
 Gold Standard Registry -- 4%
 Environmental Resources Trust (ERT) -- 5%
 US Department of Energy -- 4%
 California Climate Accounting Registry (CCAR) -- 2%
 New South Wales -- 2%
 Bank of NY -- 0.08%
 Other --14%
 Retailers’ own specific registry -- 26%
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13. Exchange, Standard, Verifier and Supplier
Registries: Examples
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The Chicago Climate Exchange (CCX) Registry
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An accounting system for the CCX’s cap- and-trade scheme
Suppliers seeking to include their credits in the registry must be members
Offsets need approval of CCX Committee on Offsets
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Assigns serial numbers to ensuing third party-verified credits
Registry is both an emissions reductions tracking program and a carbon
credit accounting system
Somewhat transparent, providing publicly-available information regarding
the offset provider/aggregator, project type and location, as well as
transaction volume.
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14. Newer Registries: Example
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Gold Standard Registry for VERs - 2008
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Gold Standard Foundation and APX created registry
Creates, tracks, and enables the transfer of Gold Standard certified VERs,
ERUs, and CERs
Low-cost and transparent electronic database
Registered users can access information on the status of credits (such as
whether they are re-sellable or retired)
Serialization of each Gold Standard VER credit
Double-entry accounting framework
Full ownership and transaction tracking for VERs, ERUs, and CERs
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15. Agenda
The Current Situation in Turkey
Essential Features of a Carbon Registry
The Proposed Turkish Carbon Registry
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16. Investments through VERs are viable options for Turkey
under the UNFCC
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To promote economic development goals, the nation
needs to attract additional foreign direct investment (FDI)
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The VER market is growing rapidly with active VER
registries in Europe, Australia and the US -- market
expected to grow rapidly
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The VER market analysis suggests that Turkey should
focus on certain key sectors to develop attractive projects
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17. Proposed Carbon Market Registry will Enhance Investments
through VERs
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Initially, Turkey’s Carbon Market Registry should serve as a project registry
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The Registry should keep the costs of registration low to encourage
universal project registration
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The Registry should use internationally accepted standards to screen
credits
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For example, Turkey has had considerable success using the Gold Standard
Allows for compatibility with the CDM and potential fungibility between VERs
and CERs
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18. Proposed Carbon Market Registry will Enhance Investments
through VERs (continued)
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The Carbon Market Registry should keep its data partially public
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This will enhance the credibility of the system at the outset
Increase investor confidence in the system
Overtime, database could be opened up for public scrutiny and greater
transparency
Eventually, in anticipation of a future compliance regime, the Registry could
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Develop its own monitoring, reporting, and verification procedures patterned after
EU and other internally acceptable guidelines
Be prepared to ensure compliance through the deduction of allowances from
accounts in the registry equal to verified emissions reported for each installation
Be prepared to specify compliance penalties
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19. Proposed Carbon Market Registry - Physical Infrastructure
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Initially, the Registry could be a three-person unit within
the MoEF
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The Head of the Carbon Registry could be “seconded” by the
MoEF
A mid-level technical specialist should also be assigned to the
Registry
An administrative staff-member should complete the unit
This structure is likely to ensure support for the fledgling
Registry
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20. Proposed Carbon Market Registry - Physical Infrastructure
(continued)
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MoEF line-item budget allocations should finance the Registry for at
least two years
Registry is expected to operate with considerable autonomy with
regards to registering carbon projects
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Will need to leverage existing government, private sector and academic resources.
Should establish a physical and on-line presence with active legal, financial and
institutional support
Over time, the Registry will improve its own capacity as well as that of
MoEF, other government agencies and project developers to support
the nation’s participation in the VCMs
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Many of its services could be rendered on a “fee for service” basis
This will ensure that Registry is able to generate revenue streams in
addition to the project-registration fees
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21. Proposed Carbon Market Registry - Online System Features
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At the outset, the Carbon Registry should invite uniform membership
for the sole purpose of registering Turkey’s carbon projects
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Carbon Registry members should be able to register online via a
secure portal
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Manage accounts in the secure environment and navigate through the
Registry’s website
All applications, reviews and approvals should be handled electronically
Approved projects should be listed online
The website should be user-friendly and informative
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The online services should include information and guidance documents
for potential project developers and the general public
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22. Proposed Carbon Market Registry - Online System Features
(continued)
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Eventually, in anticipation of a compliance regime (e.g., as part of EU
accession) the Registry should aim for three levels of membership
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Full Members who are entities with significant direct greenhouse gas (GHG)
emissions who have committed to reducing their emissions a certain percent per
year from a baseline determined by their average emissions over a specified
period of time
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Associate Members who are entities with negligible direct GHG emissions, such
as office- based institutions, businesses, and service organizations. Associate
Members should commit to report and fully offset 100% of their indirect emissions
associated with energy purchases and business travel from year of entry through
a certain date in the future
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Participant Members who are project developers, offset providers, offset
aggregators, and liquidity providers
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