Registry Operation - Emissions Annex Provision
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EU Emissions Allowance Transaction Annex to the 2005 ISDA Commodity Definitions
Section Registry Operation in a Nutshell™ Use at your own risk, campers!
Full text of Section Registry Operation
Comparison See our natty emissions comparison table between the IETA, EFET and ISDA versions of emissions trading docs
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Content and comparisons
The definition of Registry Operation is more or less the same in all three emissions trading documentation regimes. Compare:
ISDA: Registry Operation
IETA: Registry Operation
EFET: Registry Operation
Summary
One of those definitions that appears to make little sense when viewed in isolation. The unhappy news is it doesn’t make a great deal more sense — at least as a piece of elegant draftspersonship — when you zoom out and view it in context. Parables of farmers and sheep come to mind.
What on earth could “Other than by reason of an Administrator Event” mean? typically, an Administrator Event would lead to a Registry non operation, you would think. As it turns out the definition “Registry Operation” is only used once, as an example of a Suspension Event, where it is used in the negative:
“(i) absence of Registry Operation; or”
Which then makes you think there is a curious, nested double negative: i.e., a Suspension Event is the absence of the Relevant Registry, EUTL or the link between them unless that was caused by an Administrator Event. Why would you exclude those, you wonder? Well, if you follow the rabbithole long enough, you get to a satisfactory answer — you don’t — because any Administrator Event, whether causing an absence of Registry Operation or not, is independently listed as a Suspension Event.
Seeing that “Administrator Event” itself (which is only used in the same context) is concerned with “the suspension of some or all of the processes of a Relevant Registry” you would like to think all of this could have been tidied up quite a bit.
In other words, this epically rubbish drafting from one of the carbon squads, which the other Carbons Squads have blindly adopted wholesale, which makes you glad to be alive.