EMISSIONS RISK TRANSFER SYSTEM AND METHOD

This invention relates to the field of risk transfer systems and methods, in particular, to an emissions insurance system and method.

Negative environmental and health effects, such as global warming, smog, and respiratory problems in humans caused by the emission of harmful pollutants such as carbon dioxide (CO ₂ ), have resulted in countries, states, and territories throughout the world regulating the amount of emissions permitted by businesses and industries. Other harmful emissions that may be regulated according to state, territory, or country regulations, include but are not limited to, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF6), methane (CH ₄ ), nitrous oxide (N ₂ O), carbon monoxide (CO), nitrogen oxides (NOx), and non-methane volatile organic compounds (NMVOCs). The source of these and other emission pollutants can come from a myriad of industries, including: 1) energy industries, such as public electricity and heat production, petroleum refining, and the manufacturing of solid fuels; 2) manufacturing and processing industries, such as the iron, steel, non-ferrous metal, chemical, pulp and paper, printing, food, beverage, and tobacco industries; and 3) agricultural, forestry, and fishery industries.

In many cases, individual activities, processes, and pieces of equipment within an installation, such as an oil refinery for example, each have an individual permitted emission amount, often expressed in terms of tons or cubic meters. For example, Refining Facility X, having individual processes or activities A, B, and C, may have a NOx emission permit level of 120,000 tons per year for activity A, a CO ₂ emission permit level of 200,000 tons per year for activity B, and a CO (carbon monoxide) emission permit level of 170,000 tons per year for activity C. Although in many cases emission permit levels may be combined for the same pollutant at a given location or installation, such as a power generation plant, significant risks that a company may exceed their permitted amounts still exist.

Exceeding permitted emission levels can carry significant fines or costs. Businesses have had to incur the costs associated with exceeding permitted levels, even if the cause of exceeding the permitted levels was beyond a company's control (e.g. damage caused by weather related storms, and equipment malfunction or failure). Heretofore, businesses have been unable to transfer any risks associated with exceeding permitted emissions regulations. The only options available to companies for emission risk management have been to install additional controls, invest in emission credit activities, purchase emission credits in the

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market, or reduce production. Implementing any of the foregoing options generally results in significant costs, and reducing production is typically not a viable economic alternative.

The present invention generally relates to a system or method for quantifying, transferring, managing, underwriting, or insuring the risk associated with manufacturing, operating a facility, or engaging in an activity that emits, produces, or potentially emits or produces permitted or regulated emissions. As described herein, one general embodiment of the invention typically involves a unique combination of qualitative and quantitative functions combined in an novel fashion to develop a risk transfer system or method associated with insuring emission releases due to equipment malfunction, operator error, acts of terrorism, or force majeure events. In another embodiment of the invention, an insurer, trustee, or other entity accumulates each of its insured' s emission credits in a bank or pooling system, wherein the insurer can use the bank of emission credits to pay claims, and/or trade emission credits in the market based on forecast data derived from emission calculation worksheets, real-time activity or installation data, or any other suitable source.

BRIEF DESCRIPTION OF THE SEVERAL VIEWS OF THE DRAWINGS

Fig. 1 illustrates a block diagram of one embodiment of an Emission Risk Transfer System and Method

Fig. 2 is an illustrative table of an embodiment of the invention.

Fig. 3 is an illustrative table of an embodiment of the invention.

Fig. 4 is an illustrative table of an embodiment of the invention.

Fig. 5 is an illustrative table of an embodiment of the invention.

DETAILED DESCRIPTION OF EMBODIMENTS OF THE INVENTION

As shown in Figure 1, an emissions risk transfer system and method according to one embodiment of the present invention is shown. As illustrated, an emissions regulatory agency issues an emissions permit for an installation 100 (Figure 1), such as an oil refining facility. Typically, the emissions permit is an annual operating permit, which prescribes the maximum amount of allotted emissions for a particular installation, and its associated activities, processes, or pieces of equipment. Each regulated emission, such as CO ₂ , hydrofluorocarbons (HFCs), perfiuorocarbons (PFCs), sulphur hexafluoride (SF6), methane

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(CH ₄ ), nitrous oxide (N ₂ O), carbon monoxide (CO), nitrogen oxides (NOx), and non-methane volatile organic compounds (NMVOCs), can have an individual permitted amount. The permitted amounts are typically expressed in terms of tons or cubic meters of regulated material. In some cases, a given country or territory has an overall maximum emissions amount for a pollutant, such as CO ₂ , and provides permits for installations to industries, individual activities, or businesses based on the historical emission rates for the particular industry, activity, or business. It should be noted that for ease of describing various embodiments of the invention, as used throughout the specification, reference will be made to CO ₂ as being the regulated pollutant. However, the embodiments of the invention described herein are applicable to a variety of emission regulated or potentially emission regulated pollutants, including but not limited to CO ₂ , hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluori.de (SF6), methane (CH ₄ ), nitrous oxide (N ₂ O), carbon monoxide (CO), nitrogen oxides (NOx), and non-methane volatile organic compounds (NMVOCs).

Although the regulatory agency may issue a CO ₂ emissions permit for an installation 100 based in part on the installation's historical data, typically the emissions permit while documenting the projected CO ₂ emissions from all activities in an installation covered under the applicable law, will routinely result in the tons of CO ₂ allotted to the installation being less than the projected CO ₂ emissions. As shown in Figure 1, a business or installation operator will calculate, measure, or determine the emissions forecast for an installation 102. This emissions forecast can be computed by any entity capable of computing the forecast, including but not limited to the regulatory agency, as previously described herein, the installation operator or business, a third party, an underwriter, and the insurer. The emissions forecast can be determined by many methods. In the Commission of the European Communities' Decision of 29/01/2004 ("Commission Decision"), in regard to the Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003, herein incorporated by reference in its entirety, describes various methods of calculating and measuring emissions forecast. Referring by way of illustration to the Commission Decision, detailed calculation, measurement, and error data for determining CO ₂ emissions in a variety of industries, using a variety of measurement devices is disclosed. For example, calculation OfCO ₂ emissions include the formula:

CO ₂ - emissions = activity data * emission factor * oxidation factor

As illustrated in the Commission Decision, several tables are provided for documenting installation information, calculation and measurement data. For example, such

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reports include the identification of the installation plant, the type of activity performed at the plant, emissions' information, such as CO ₂ , combustion and process emissions (Figures 2-5).

In one embodiment of the invention, the insurer evaluates the installation and compares the permitted CO ₂ emissions amount to the forecast amount 104. The insurer can obtain this information from a variety of sources. For example, in some European Communities, the permitted emission amounts for installations are publicly available via the internet. Additionally, although as shown in Figure 1, this embodiment refers to the insurer evaluating the installation 104, this evaluation and comparison can be accomplished by a third party, an independent body, the insured, or any suitable entity. The evaluating and comparing function 104 referenced in Figure 1 can also include an assessment, evaluation or review of the installation's regulatory-permitted-emissions calculations and data, previous operating years and forecast years emission data, previous operating and forecast installation unit production data, previous and planned modifications to the installation, safety reviews, activity/process hazard analyses, and failure mode effect analyses for the installation and the myriad of sequence of events within an installation's activities. Evaluating this type of data and information aides the insurer in performing a thorough evaluation of the probable maximum loss (PML) and maximum foreseeable loss (MFL) associated with emissions insurance for an installation. Thereby, providing a thorough basis for the emission insurance's deductible, policy, and premium limits.

Because of the myriad of factors affecting the potential profitability to an insurer providing any of the embodiments of the invention, those of ordinary skill in the art will recognize the need for insurer based or affiliated engineering activities associated with the risk management of emission exposures. Technical information, technical experience, and analyses are applied to provide underwriters the risk evaluation data required to conduct risk quantification, risk acceptance, and pricing analyses. Not only are these engineering skills provided prior to underwriting an emission insurance policy, the same skills are also applied after a loss for loss control and claims administration.

In another aspect of an embodiment of the invention, part of the documentation for the emission insurance, includes the calculations performed to compute the forecasted emissions over the policy period, such as the worksheets and reports referenced in the Commission Decision (Figures 2-5). Additionally, if forecasted emissions exceed the permitted emissions, the evaluation and comparison function 104 can also include a determination of the amount of energy credits, or other emission allowance producing

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investments/projects the insured can acquire and use to offset any excess forecast emissions. For example, if an insurer's evaluation of activities within an installation reveals that the insurer's calculated forecast emissions exceed the permitted emissions, and/or exceeds the insured' s calculated forecast, the insurer can require the insured purchase emission credits or engage in other emission allowance producing investments/projects so that the permitted emissions exceed the forecast emissions. If needed, the insured can purchase emission credits from the marketplace, the insurer, or another entity. The emission credits are generally based on for example, tons of CO ₂ . Additionally, emission allowance projects, such as "Joint Implementation," JI, or "Clean Development Mechanism," CDM, projects are applied as debits to the insured' s overall emissions and may be required to yield net emissions levels below the specified allowances. As incorporated by reference herein is the 24 February 2004 "Opinion of the Committee on Industry, External Trade, Research and Energy for the Committee on the Environment, Public Health and Consumer Policy on the proposal for a European Parliament and Council directive amending the Directive establishing a scheme for greenhouse gas emission allowance trading within the Community, in respect of the Kyoto Protocol's project mechanisms," which discusses allowing credits from the JI and CDM project-based activities under the Kyoto protocol to be converted in to emission allowances. Also, incorporated by reference herein and in its entirety is the "Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 96/6 I/EC." Also, incorporated by reference in its entirety is Document ID 52003DC0830, "Communication from the Commission on guidance to assist Member States in the implementation of the criteria listed in Annex III to Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC, and on the circumstances under which fore majeure is demonstrated."

The evaluation and comparison function 104, which includes review of any associated documentation, including the reports and worksheets illustrated in the Commission Decision as illustrated in Figures 2-5, constitute a part of the engineering role in the emission insurance. The evaluation and comparison 104 will verify the insured's calculations for accuracy, analyze the deterministic projections for practical realism, and run standardized risk models to test the sensitivity in results. The evaluation and data review functions 104 require engineers knowledgeable in the industry, region, and activity involved. For example, in power generation, the engineer must understand the generation technology, fuel types, and

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heat rates in comparison to the projected amounts expected to be consumed in that region, in order to thoroughly determine an emission forecast.

In yet another embodiment, because the energy conversion factors, calculation formats, and formulas for the covered activities' emission calculations are typically specified by or on behalf of the regulatory authority (e.g. the European Union's Commission Decision), this provides some standardization for these determinations in that the forms submitted to the regulatory agency, can also be provided to the insurer as part of the submission data. Once the emissions forecast is verified by the insurer, the information can be cross checked with any property insurance policy and site inspection data, if available, as another check on the installation composition and risk quality. Since the emissions coverage can be dependent on property perils (e.g. fire, lightning, windstorms, etc.) the property risk evaluations serve an additional purpose as providing insights on the risk quality for emission releases.

Additionally, as part of the evaluation function 104, based on risk models developed for the activities covered by the regulatory agency's emission limits, the engineer can develop a range of sensitivity estimates, estimating the likelihood that the insured will achieve emissions levels above the installations or group of installations covered in the policy allowances. The insured may also include in the submitted documentation, certified emission reduction units produced from projects, such as JI or CDM projects, that are linked to their overall emission levels and are applied as debits to the insured' s overall emissions and may be required to yield net emissions levels below the specified allowances.

As an additional aspect of the evaluation and comparison function 104, either based on a risk model computed score, engineering judgment, or both, some installations can be identified for on-site inspections. The on-site inspection can review property risk evaluation data, but also can examine the events or sequence of events that determine the installation- level and policy-level PML and MFL. This work will require analysis of installation operational inter-dependencies of the covered locations. For example, suppose an insured had four power generation installations covered by the emission policy. An equipment breakdown loss at one facility may suspend operations locally for several months. Although the annual emissions at that non-operating installation are much lower, because the other facilities have to increase output to make up for the non-operating installation's loss, the aggregate emissions can possibly be in excess of the maximum permitted allowance and any applied emission deductible. These types of regional interdependency factors, external to a single installation can play an important role and be an important part of the policy's value to

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the insured. This inter-dependency risk is a key underwriting issue, and requires a detailed analysis by the insurer in the evaluation and comparison function of an embodiment of the inventive system and method described herein.

As also shown in Figure 1, taking into consideration the evaluation and comparison functions 104 described previously, an emissions insurance policy 106 is created. In addition to policy premium amounts, an exemplary emissions insurance policy according to one embodiment of the invention can also contain information (or have such information as an attachment or appendage) on the installations or activities within an installation covered by the policy. Such information can include the activities' production capacity, and average, lowest, or highest CO ₂ emissions within a certain time period. The policy can also include details of the coverage. For example, the policy can specify that the coverage is applicable only to emission occurrences caused by equipment failure, acts of terrorism, or force majeure events; and that the coverage extends only to those emission sources documented in any attached worksheets or schedules, which worksheets or schedules are those associated with permitted emissions, such as those described in the Commission Decision at pages 38 - 41. The policy may also provide for coverage of expenses incurred by the insured as a result of the covered emission occurrence, such as expenses expended by the insured to reduce the loss (e.g. the leasing of equipment to replace failed or damage equipment that caused the emission occurrence) and expenses incurred by the insured for professional services that are necessary and reasonable in order to certify the details of a claim.

In one embodiment, the insured' s limits of liability (e.g. deductibles) can be based on a combined-emission-incident-aggregate limit for the policy period, be based on an each- emission-incident limit, or any other suitable insured-liability-limiting scenario. In still another embodiment, the policy can have various deductible methods, including for example, a monetary deductible amount, or a deductible in the form of tons or m ³ of CO ₂ .

In addition to coverage details, in one embodiment, the policy includes details of exclusions, conditions, and/or subrogation of coverage. Exclusions can include for example, emission excursions based on war and the failure of the insured to follow maintenance or operating procedures for an activity or piece of equipment. Conditions can include for example, a requirement that the insured notify the insurer within a certain time period of knowledge of an occurrence, such as a twenty-four hour notification period.

For example, as illustrated in Figure 1, in one embodiment the insurer has access to the insured's activity data 112 via communication link 114. This communication link 114

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can be via any suitable and preferably secure means, including through internet or intranet connections combined with the use of a computer operating system. In many activities, CO ₂ emissions, in some amount, are a daily and inherent part of the normal operation of an activity. Because there may be a direct correlation between CO ₂ emissions and unit output or fuel consumption for example, activity instrumentation that measures these variables can be an important gauge in determining CO ₂ emissions. Additionally, instrumentation may be used to directly measure CO ₂ emissions, or the activity control system (e.g. a distributed control system) may be configured to calculate CO ₂ emissions based on activity variables, such as temperature, pressure, fuel consumption, or flow of product output. In this embodiment, the communication link 114 represents the ability of the insurer to access the insured's pertinent activity data, such as CO ₂ emissions and other activity data that can be used to calculate or forecast CO ₂ emissions. This aspect provides the insurer with the ability to not only monitor the activity 110 for previous emission occurrences and potential emission claims (e.g. excess CO ₂ emissions) on some periodic basis, including continuous monitoring, but it also provides the insurer with a real-time status of CO ₂ emissions by an insured, or all insureds when this system is used with all CO ₂ emissions policy holders of an insurer. As will become evident in the succeeding portion of this detailed description, this unique system gives insurers the ability to forecast the overall need for emission credits on a going forward basis, as well as allowing the insurer to sell anticipated excess emission credits on the market at a premium, when the insurer acts on behalf of the insureds in an emission pooling, banking or trustee relationship.

Additionally, a real-time communications link, such as link 114, also provides the insurer with the ability to monitor the activities 110 and update risk models and scenarios previously or contemporaneously developed for the activities covered by the regulatory agency's emission limits. This communications link 114 also gives the insurer or insured the ability to update scenarios, models, and sequence of events identified in safety reviews, activity/process hazard analyses, and failure mode effect analyses for the activities. Thereby providing the insurer or insured with an updated emission probability based on real-time operational data.

The embodiment shown in Figure 1 also shows the insured monitoring its activities 108 and notifying the insurer of any CO ₂ excursions, modifications, and claims. In addition to notifying the insurer of any emission occurrences, the policy can provide that the insurer has the right to inspect the installation and associated activities and examine the risk. Also, another condition could include that prior to making any material change that would affect

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the emissions risk for a covered activity; the insured must notify and receive confirmation of continuance of coverage from the insurer. In addition to activity modifications, in one embodiment of the invention, emission insurance coverage is Limited to a specific production output rate, wherein emission insurance coverage is lost if the activity exceeds either instantaneous or cumulative production rates.

In another embodiment, in the event of an emission occurrence, the insured should immediately notify the insurer, via the method(s) described in the emission insurance policy such as phone or e-mail. Once the insurer receives notification of an emission occurrence, the insurer can make a determination of whether or not to send a control specialist to the site, in an attempt to access any potential claim and attempt to reduce the emission claim potential. Additionally, as previously illustrated in Figure 1 and described herein, if the insurer has a communications link 114 with the insured' s activity data 112, and has the several potential incident or risk scenarios modeled within a system, the insurer could use the appropriate models to determine the potential extent of an emission occurrence, as well as determine if there is a need to have an engineering representative visit the site.

The magnitude of the identified emissions should be computed as quickly as possible. In some cases, using a communications link 114 to the insured' s activity data 112 will allow for a real-time calculation or determination of an emission's magnitude. Consequently the insured, the insurer, or other professional service can determine or forecast the increased emissions from the covered peril. Based on these results the insurer may take additional proactive actions at one or more of the covered installations to reduce the forecasted emissions and possible claim severity. For example, the insurer or its representative may commission installation, at the insurer's expense, scrubbers to reduce the emissions if the insurer believes the installation benefits underwriting by eliminating a claim or lowering any reserve emission credits. Additionally, upon notification and evaluation of the emission occurrence, the insurer can react by purchasing additional emission credits in the market to compensate for any projected emission claims.

In another embodiment of the invention, several methods and combinations of methods are available for emission claims valuation and loss adjustment. For example, one method for computing a claim valuation can include the determination of total exceeded emissions by determining the actual CO ₂ emissions and subtracting the allowed or permitted CO ₂ emissions. Additionally, if for example, as described previously the insurer was required to purchase additional emission allowances or credits (e.g. based on a determination that the

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forecast emissions for the policy period exceeded the permitted or allowance emissions), the claims valuation could would include an additional subtraction from the total exceeded emissions by any purchased emission allowances or credits. The credits could also include those attributed to the insured because of emission credit projects, such as the JI and CDM projects previously described.

Still other claims valuation can include utilizing insured deductibles. As previously mentioned, the insured' s limit of liability can be based on an aggregate amount, per incident amount, or any other suitable limit of liability. The insured' s deductible can be based on a dollar amount or can be based in the form of tons or m ³ of CO ₂ . When the deductible is based on a dollar amount, this amount can be subtracted from any "dollar loss amount" as described below in reference to payment of claims. When the deductible is based on tons or m ³ of CO ₂ , the deductible can be subtracted from any determination of total exceeded emissions ("TEE"), in order to give an total exceed emissions prime (TEE'). Similarly, for determination of a "dollar loss amount" of the TEE or TEE', the TEE or TEE' can be multiplied by the cost of an emission credit, which can be determined by market rates at the time of the emission occurrence, or market rates at the time of reporting and payment, as described below in reference to payment of claims. Although these represent only a few emission claims valuation, it should be realized that any suitable method for claims valuation in conjunction with emissions insurance is considered to be within the scope of an embodiment of the invention.

Emission insurance claims should be identified before the end of the policy period. Since emissions are typically computed from fuel consumed and production volumes, quantifying exceedance amounts should be relatively straightforward. Also, since the insured normally must report these values to the regulatory authority, the calculations will most likely follow a standardized procedure.

Payment of claims can be in multiple forms. In one embodiment, payment is made in the form of the dollars required to purchase emission credits ("dollar loss amount"), or by the insurer supplying the credits directly. For example, the insurer could supply the emission credits from an emission credit bank, controlled by the insurer. Still in another embodiment, the insurer can go into the market to purchase the needed emission credits. In some cases reporting emissions and the subsequent payment of fees for exceeding permitted amounts, or using emission credits to apply towards exceedance amounts, does not occur until the end of a permitted period. When paying claims in the form of dollars required to purchase emission

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credits, one embodiment of the invention includes paying claims in the form of payment at the average trading market price during the period of the emission release event. Still, other scenarios for claim payments can include payment at market rates, at the time of reporting and payment to the appropriate regulatory agency.

In another embodiment of the invention, when an insured provides a report of its yearly emissions data to the regulatory authority, the insured may be asked for verification of its emissions data by an independent third party, to be paid for by the insured. As an added feature of the emissions insurance, the insurer may have provisions in the policy that allow for endorsements to the policy by the insured, wherein the insurer can provide appropriate professionals to quantify emission losses for covered perils, if expertise does not exist in- house.

Still another aspect of an embodiment of this invention is the development of an emissions credit bank by the insurer. In this embodiment, the insurer arranges to have all or some of the emission credits, allowances, or project credits for all or some of its insureds assigned, transferred, or provided to the insurer, an entity affiliated with the insurer, or a trustee. In another aspect of an embodiment of this invention, the insurer provides investments in approved energy and emission reduction projects (e.g. emission reduction projects in specified countries) and acquires additional emission credits for its investments. Some or all of the credits assigned, transferred, or provided to the insurer from its insureds and any additional emission credits acquired by the insurer through emission reduction projects, or purchased in the market for example, form an emission credit bank or pool. The insurer can use this emission credit bank as a primary source for paying claims of its insureds. Additionally, using the risk modeling techniques previously mentioned, the insurer can also forecast the need for emission credits, and projected price for emission credits in order to establish trading operations of emission credits.

In other embodiments of the invention, the insurer engages in forecasting the cost effectiveness of making emission reduction engineering or design changes in covered activities. In this aspect, the insurer determines if the engineering or design change would result in excess emission credits, which if sold in the marketplace could yield a higher return for the insurer based on the difference between the cost to implement the emission reduction engineering or design changes and the projected revenue from the sale of the excess emission credits at market rates. In another embodiment of the invention, the insurer provides reduced

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emission insurance premiums based on the insureds using equipment or a vendor listed on recommended equipment or vendors lists.

In still another embodiment, an Engineering entity, which can be associated or affiliated with the insurer, provides engineering design and/or installation services to business for new, modified, or re-designed activities within an existing or new installation. The Engineering entity provides the business with engineering services that provide the activity will function or operate at or below an emission level. This Engineering entity can implement the evaluating, comparison, monitoring, pooling, and equipment/vendor recommendation functions previously described herein, in order to modify or design an emission-efficient activity. Additionally, the Engineering entity can provide engineering design and/or installation services and forecasts for emission-reducing projects to the insurer and/or insured. In another aspect of this embodiment, the insurer can provide insureds with reduced rates for coverage and policy premiums based on the insureds use of the Engineering entity in any modification, design, or installation of a covered or potentially covered activity.

While the invention has been shown and described with reference to the preferred embodiment thereof, it will be understood by those skilled in the art that various changes in form and detail may be made therein without departing from the spirit and scope of the invention.

Payment of claims can be in multiple forms. In one embodiment, payment is made in the form of the dollars required to purchase emission credits ("dollar loss amount"), or by the insurer supplying the credits directly. For example, the insurer could supply the emission credits from an emission credit bank, controlled by the insurer. Still in another embodiment, the insurer can go into the market to purchase the needed emission credits. In some cases reporting emissions and the subsequent payment of fees for exceeding permitted amounts, or using emission credits to apply towards exceedance amounts, does not occur until the end of a permitted period. When paying claims in the form of dollars required to purchase emission credits, one embodiment of the invention includes paying claims in the form of payment at the average trading market price during the period of the emission release event. Still, other scenarios for claim payments can include payment at market rates, at the time of reporting and payment to the appropriate regulatory agency.

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