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    <p align="left"><font face="Arial"><strong><small>About The Author:<br>
	<br>
	</small></strong><span lang="X-NONE" style="color: black"><font size="2">
	ROGER FELDMAN, Co-Chair of Andrews Kurth LLP Climate Change and Carbon 
	Markets Group has practiced law related to the finance of environmental and 
	energy projects and companies for 40 years.&nbsp; In particular, he has analyzed 
	and executed a wide variety and substantial value of project financings.&nbsp; He 
	chairs the American Bar Association&#8217;s Committee on Carbon Trading and 
	Finance, serves on the Board of the American Council for Renewable Energy, 
	and has been a senior official in the Federal Energy Administration.&nbsp; He is 
	a graduate of Brown University, Yale Law School and Harvard Business School.</font></span></font></p>
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    <img src="../images/feldman.gif" alt="Washington Viewpoint by Roger Feldman" border="0" width="375" height="75"><p><b><u><br>
      May 2006</u></b></p>
    <p align="center"><font size="6"><b>Carbon Wildcatting</b></font></p>
    <p><strong>by Roger Feldman&nbsp; -- &nbsp; Bingham, Dana L.L.P.<br>
    </strong><font face="Arial" size="2">(<em>originally published by PMA OnLine 
    Magazine: 2</em>006/10/27)<br>
    </font><span style="font-size: 10.0pt; font-family: Palatino; color: black">
    &nbsp;</span></p>
    <font FACE="Times New Roman" SIZE="1"><i></i></font>
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    </font>
    <i></i>
    <p ALIGN="JUSTIFY">Where will the new energy merchants come from? Can they 
    learn anything from prior merchant history?</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">There have always been two very different types of 
    drivers of entrepreneurial planning in the merchant energy space: Long run 
    strategic embrace of &quot;big picture&quot; trends and concepts, and &quot;right now&quot; 
    exploration of governmental incentives and trading arbitrage opportunities. 
    Each approach began with a reasonable idea; extended into creative merchant 
    status and then more or less expired of excesses. Pontification on return to 
    basics followed. So it has been in the &quot;big picture&quot; cases of the 
    diversified multi-functional utility; the deregulated functionalized utility 
    (&quot;genco, transco, disco&quot;), of late blessed &quot;right now,&quot; the &quot;virtual&quot; (if 
    not virtuous) utility. So it has been for &quot;right now&quot; models like PURPA 
    machines; tax driven renewable deals, and hot trading floors exploiting fuel 
    and market price discrepancies. </p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">The most successful merchant strategies in the past 
    actually took advantage of these ideas in their prime. There is now another 
    chance to do so and revisit the relevance of some of these &quot;big picture&quot; and 
    &quot;right now&quot; strategies in the context of carbon-related developments.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">In terms of &quot;big picture&quot; long-term trends, we are at a 
    new juncture of course, in the entrepreneurial energy marketplace. Floor 
    prices for fuel seem to have bolted upward for the foreseeable future. 
    Consumer tolerance for the true prices and therefore operation of 
    deregulated markets seems to be a thing of the past. The barriers to 
    consolidation across energy service territory and international lines are 
    significantly reduced. The push for the utilization of non-imported fuels 
    that are price-competitive is &quot;pumped up&quot; with the passing of every day. 
    And, without direct reference to these developments, the public has moved 
    into acute awareness of a somewhat nebulous but nevertheless emotionally 
    heartfelt, desire to end &quot;global warming&quot; particularly through reduction of 
    the amount of CO2 in the air, by reduction of carbon sources, both 
    stationary and mobile. This is not your grandfather&#8217;s Kyoto, to paraphrase 
    an old &quot;gas guzzler&quot; ad. The confluence of these trends is a challenge to 
    nimble (read: merchant entrepreneur) inactivity, whether based in large or 
    small entities.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">Their attention is turning from every direction to what 
    may seem an unlikely beacon: carbon. With the consciousness growing that 
    there ultimately will be meaningful US governmental action trailing in the 
    wake of state initiatives, more merchants are checking the angles than ever 
    before. Utilities are, for the most part, simply doffing their caps to the 
    issue by setting emission target caps off in the middle distance; planning 
    ahead with announcements of major new efficient coal plants, built right in 
    the heart of the crowded Atlantic Coast; or issuing solemn &quot;sustainability&quot; 
    reports. But some larger players as well as smaller innovators are doing 
    more.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">First, and most visibly, they are becoming advocates of 
    the regional programs for carbon emissions control and trading and for 
    sustainability through efficiency programs. They are suggesting that the 
    renewables&#8217; initiative in support of REC&#8217;s trading might be expanded and 
    oriented toward the larger goal of rewarding those technologies which foster 
    carbon displacement and sustainability.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">Second, entrepreneurs are seeking to foster greater 
    awareness &#8212; already quite clear in Europe &#8212; of the high return interplay 
    between energy efficiency measures and carbon savings. The US ESCO &quot;shared 
    savings&quot; market seems to be contracting; the world market for reduced 
    reliance on all fossil fuels seems to be growing. Efficiency Technology 
    improvements and recycling sectors are beginning to find their rationale on 
    the CO2 front. Even the greenest of new fuels, ethanol, now has its 
    proponents of technology producing carbon savings improvements in its 
    manufacturing process.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">Third, the electricity renewables sector has begun to 
    emphasize better policy recognition and measurement of its 
    carbon-displacement value. This is particularly true, as it relates to calls 
    for improved recognition of the carbon air quality offset contribution which 
    renewables can make. The appeal of methane gas projects, for example, never 
    has been greater from that standpoint.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">Fourth, funds and developers who not so long ago once 
    pursued &quot;distressed power assets&quot; now seek out old coal plant sites which 
    present the possibility of IGCC and possibly even CTL. Optionally, value has 
    been added by the hunt for carbon displacement opportunities.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">Fifth, the pursuit of eligible carbon reducing projects 
    for CDM and JI projects has become far more than a hypothetical cottage 
    industry. Substantial commodity trading entities have become involved in the 
    field, and pools of capital which once pursued merchant combined cycle 
    plants now have refocused their sights as well.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">Sixth, the forces impelling overseas investment in 
    carbon-displacement energy investments are picking up capital investment 
    reinforcement as the possibilities for trading come into clearer focus. 
    There has been a significant decline in emerging market country power 
    investments over the past few years. The new emphasis on expedition of CDM 
    measurement has begun to somewhat reverse the trend. Many types of projects 
    now have an additional attractiveness, which their economics might not by 
    themselves have provided in the past.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p ALIGN="JUSTIFY">And finally, apart from the legally-created value of 
    carbon-reduction technologies as a result of emerging trading regimens there 
    has been the emerging value driven by impetus toward technology for using 
    CO2 outputs from power, gasification and even prototype hydrogen production 
    from petroleum coke fueled facilities to support enhanced oil recovery. 
    Direct CO2 utilization now has been conjoined with radio frequency 
    technology in proposed oil shale extraction technologies as well. In effect, 
    the pursuit of black gold is leading the way to the pursuit of black-derived 
    gold.</p>
    <font FACE="Palatino" SIZE="2">
    <p ALIGN="JUSTIFY"></p>
    </font>
    <p>So perhaps the prior &quot;big picture&quot; models for merchant energy can be 
    applied again in the pursuit of &quot;right now&quot; projects related to exploitation 
    of potential sustainability enhancing projects. Carbon wildcatting may be 
    the key to new types of energy entrepreneurs. And perhaps the players to do 
    so are the real successors to the merchants (by whomever owned) of prior 
    years. Public policy makers should be as alert to be helpful to them as they 
    were, for awhile, to merchant power development.</p>
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text-align:left"><font face="Arial" size="2">
	<span lang="X-NONE" style="color: black">ROGER FELDMAN, Co-Chair of Andrews 
	Kurth LLP Climate Change and Carbon Markets Group has practiced law related 
	to the finance of environmental and energy projects and companies for 40 
	years.&nbsp; In particular, he has analyzed and executed a wide variety and 
	substantial value of project financings.&nbsp; He chairs the American Bar 
	Association&#8217;s Committee on Carbon Trading and Finance, serves on the Board 
	of the American Council for Renewable Energy, and has been a senior official 
	in the Federal Energy Administration.&nbsp; He is a graduate of Brown University, 
	Yale Law School and Harvard Business School.</span></font></p>

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