Report on operations



The Helen Group is a commercial entity, which consists of the parent company Helen Ltd and its subsidiaries Helen Electricity Network Ltd, Oy Mankala Ab, Suomen Energia-Urakointi Oy and Helsingin Energiatunnelit Oy. The associated companies included in the financial statements of Helen Ltd are Liikennevirta Oy, Voimapiha Oy and Suomen Merituuli Oy.

Helen Ltd offers its customers electricity, district heating and district cooling, along with a wide range of services for small-scale energy production and the customers' own energy use and improving its efficiency. Helen Ltd produces energy at its power stations and other production plants located in Helsinki, as well as through its power assets. Helen Ltd is owned by the City of Helsinki.

Helen Electricity Network Ltd (100%) concentrates on electricity network operations in compliance with the Electricity Market Act and provides transmission and distribution services to its customers in almost the entire City of Helsinki. The net sales of Helen Electricity Network Ltd account for approx. 13% of the Helen Group's net sales.

Oy Mankala Ab (100%) is a hydropower company that owns the Mankala, Ahvenkoski, Klåsarö and Ediskoski hydropower plants by the Kymijoki River. Oy Mankala Ab's holding in Teollisuuden Voima Oy is 8.1%, in Suomen Hyötytuuli Oy 12.5% and in Suomen Merituuli Oy 50%.

Helsingin Energiatunnelit Oy (90%) serves the energy, water supply and telecommunication networks. The City of Helsinki's holding in Helsingin Energiatunnelit Oy is 10%.

Suomen Energia-Urakointi Oy (60%) is a service company specialised in electronic urban technology, providing design, installation, operation and data transmission services for networks and equipment related to electricity transmission, distribution and use. The other owners are Vantaa Energy Ltd and Lahti Energia Oy.

Financial year 2018

The results of the fiscal year 2018 were realised extremely well for Helen. The market price of Nordic electricity was at a high level throughout the year and rose sharply in the second half of the year as a result of the dry end of the year and the increased fuel and emission allowance costs. The volume of electricity production increased clearly from normal levels.

Strong growth in the district heating and cooling markets continued, and the volume of district cooling was record-breaking thanks to the warm summer. The need for cooling during the July heatwave doubled on the corresponding period in 2017. The Katri Vala and Esplanade Heating and Cooling Plants and the Salmisaari power plant were operating at full capacity to produce district cooling. Helen’s underground cooling reservoirs were also utilised.

Competition in the electricity retail market has continued to be tough. In spite of this, we were able to increase the number of electricity retail customers.

Progress was made in the concept development of new products and services, but introducing the products on the market was slower than expected.

Helen's own operations were further developed and their efficiency was increased. We adopted new operating models, production and maintenance, we were able to reduce costs and improve Helen's competitiveness by developing our operations.

The availability of power plants continued to be high, the security of electricity supply in Helsinki decreased slightly from the target level. The main reason for this was a lengthy, about12-hour interruption in the district of Katajanokka in July.

The overall water supply situation was considerably worse than in a normal year, and the power plants of Oy Mankala Ab are undergoing the largest investment project for decades.

Group’s profit trend

The Group’s results improved from the year 2017. The contributing factors to the increase in the net sales were the cost-based changes in the price of district heat and an increase in the electricity market price.  Helen Ltd was able to take advantage of the electricity market situation and increase the operating profit with successful measures in the electricity wholesale market. The net sales and profitability of Helen Electricity Network Ltd also showed an upward trend.

The net sales for 2018 stood at EUR  930 million (EUR 805 in 2017), and the operating profit amounted to EUR 131 million (EUR 81 million in 2017). At 6,578 GWh, the electricity sales volume grew by 7%. At 6,702 GWh, the district heat sales increased by 1% on the previous year. The district cooling energy sales grew by 32% i.e. to 188 GWh. At 4,414 GWh, the electricity distribution in Helsinki remained at the previous year’s level.

Group and parent company: Key figures 2018

  Group   Parent company  
  2018 2017 2018 2017
Net sales, EUR mill. 930 805 792 681
Operating profit, EUR mill. 131 81 88 51
Operating profit, % of net sales 14 10 11 7
Profit before appropriations, EUR mill. 112 60 106 66
Investments, EUR mill. 65 95 35 49
Equity ratio 73 72 77 76
Return on equity (ROE), % 5 3 5 4
Employees as of 31 December 1,080 1,144 838 888
Total equity and liabilities,
Balanse sheet, EUR. mill
2,758 2,732 2,629 2,584

Equity ratio % = 100 * own funds / balance sheet total
Own funds = shareholders' equity + untaxed reserves + depreciation difference deducted by tax liability
Return on capital invested % = 100 * (profit before appropriations + financing costs + tax) / average capital invested
Capital invested = shareholders' equity + interest-bearing debt


Helen is making investments in increasing the use of renewable energy in district heat production, recycling of energy with heat pumps and improving the security of supply in energy networks in particular.

Helen Group's investments totalled EUR 65 million. The investments in the parent company’s production structure amounted to EUR 32 million, of which the share of district heating and district cooling networks was EUR 15 million. Investments in the electricity network totalled EUR 26 million and those in the tunnel network EUR 2 million. The rest of Helen’s investments were targeted at new services and hydro power plants.


In accordance with its financial policy, Helen Ltd manages the financing of its subsidiaries in a centralised way. The Group's equity ratio was 73%, and the amount of interest-bearing debts EUR 569 million at the close of the financial year.

The interest-bearing debts of Helen Ltd consist of the subordinated loan of EUR 157 million taken out from the owner, a so-called senior debt of EUR 252 million taken out from the owner, and loans of EUR 62 million taken out from financial institutions.

Helen Electricity Network Ltd has loans of EUR 34.5 million from outside the Group. The loan of Oy Mankala Ab taken out from the State Nuclear Management Fund stood at EUR 84 million at the end of the financial year.

Helen Ltd has a new commercial paper programme of EUR 100 million, which has not yet been used.


The registered and fully paid hare capital of Helen Ltd is EUR 600 million. The total number of shares is 1,000. The City of Helsinki owns all the shares.

Key events during the financial period

  • The pellet-fired heating plant in Salmisaari was inaugurated. The use of coal is replaced with wood pellets in Helen’s district heat production. The pellet boiler of the heating plant is Finland’s largest (92 MW), and it generates renewable district heat for the needs of 25,000 one-bedroom apartments.
  • Helen decided to build Finland’s largest heat storage facility in the old oil caverns in Mustikkamaa.for the storage of district heat. The volume of the heat storage facility is 260,000 m3, and it will increase energy efficiency and allow reduction in the use of fossil fuels. The heat storage facility will be completed for production use in 2021.
  • Helen and Skanska presented their plan to implement the world’s first seasonal energy storage facility of its kind in the old oil caverns in the Kruunuvuorenranta district of Helsinki. In the planned energy solution planned by Helen, sea water warmed by the sun and recycled heat from residential buildings are utilised in a new way.
  • Helen launched an IoT development project on heat demand response to be implemented in cooperation with Helsingin kaupungin asunnot Oy (Heka). Helen will provide a new service for the metering and reporting of indoor temperatures and humidity in Heka homes. The service will enable improved energy efficiency in residential apartment blocks in a cost-efficient and easy way.
  • Helen’s underground heating and cooling plant located under the Esplanade park at the depth of some 50 metres was completed. The large heat pumps produce both district heat and district cooling. They recover a significant amount of excess heat from properties for utilisation in heat production. The Esplanade heat pumps replace some of the fossil fuels used in Helen's energy production and reduce carbon dioxide emissions by more than 20,000 tonnes a year.
  • Helen made a decision to invest in a new heat pump to complement the heating and cooling plant located under the Katri Vala Sörnäinen. Due to the new heat pump, the plant’s production volume will increase by almost 30%. At the same time, the thermal load of the Baltic Sea will be reduced considerably as the heat of purified waste water will be recovered even more efficiently than before.
  • Helen was the first company in Finland to introduce on the market solar panels and an electricity storage system as a tailored package for domestic customers. Microgenerators will gain greater benefits from their solar panels with the aid of an electricity storage system and, at the same time, be an active part of Helen’s virtual power plant and the smart electricity market of the future.
  • A new solar wall consisting of 84 panels was installed at the Suvilahti substation in Helsinki to test the yield of wall panels. The solar wall was integrated directly in the substation building so that the solar panels form new wall surface.
  • Helen is exploring various options of building new bioenergy heating plants in Helsinki. The environmental impact assessment (EIA) of the bioenergy heating plant planned for the Tattarisuo area continues in accordance with the statement made by Uusimaa ELY Centre so that a new site option on the southern side of the Tattarisuo industrial area is included in the EIA report.
  • Helen was again the most sustainable brand among energy companies. For the second year running, Helen was ranked first among Finnish energy companies.  The Sustainable Brand Index™ is most extensive brand survey on sustainability in the Nordic countries.
  • Helen was also awarded as one of the best energy brands in the world in the international CHARGE brand competition. The selection of the awarded brands was based on the results of an expert panel, a customer survey and an independent analysis. Helen competed in the category for established brands.
  • Helen won the title of Secure Organisation of the Year and Helen’s Mats Fagerström the title of Security Director of the Year at the Finnish Security Awards 2018 event.
  • The district heating network in Helsinki saw a record-high capacity increase in 2018. The new connections totalled 80 megawatts, which is twice as much as the connected load of the district heating system of the town of Mäntsälä. The last time when the connected load of the district heating network in a single year has increased more than in 2018 was in the 1970s.
  • Helen and German E.ON became majority owners of Liikennevirta when E.ON joined the operations of Liikennevirta. Helen’s associated company Liikennevirta Oy (Virta) is rapidly expanding its operations also in the overseas markets. The ownership base of Virta was developed through directed share issues and share transactions so that Helen and E.ON are now majority shareholders of the company.
  • Helen is launching a new district heating service on the market: a smart heat distribution centre saves energy and reduces heating costs for residents. Helen is offering a new service concept to housing companies, including the replacement of the heat distribution centre, equipment maintenance and repairs, and optimisation of the indoor conditions in the building.
  • Helen introduced on the market an open district heat service, which increases the diversity of energy procurement and promotes the circular economy as well as climate-neutral energy production. In the first stage, two-way heat trade is meant for properties, companies and residential buildings, which use Helen’s district heat and the operation of which generate heat that is suitable as such for use in the district heating network.
  • Helen and the Messukeskus Expo and Convention Centre agreed on building a large solar power plant on the roof of Messukeskus building. The solar power plant will have more than 2,000 solar panels to be harnessed as Helen’s rented designated panels.
  • Helen and MobilePay agreed to join forces in making mobile payments an option for Helen’s electricity bills in 2019. Helen is the first company in Finland to adopt mobile payment as a billing choice.
  • Helen Electricity Network Ltd signed a partnership agreement with Fingrid Oyj and the City of Helsinki to conduct a study on an electricity distribution network solution for the Helsinki region. The key idea is that it would be possible to reduce the volume of cabling in Helen Electricity Network’s 110-kV network and cut the costs to the City of Helsinki of moving the power lines, especially in the area affected by the Vihdintie boulevard project, by bringing forward the project of expanding Fingrid’s national grid to Helsinki.


Helen Ltd had 838 (888) employees at the end of the year. The number of permanent employees was 816 (852), and the number of fixed-term employees 22 (36). The average number of employees was 870 (962). The average age of the employees was 47.0 (46.7) years, and the average length of employment was 16.9 (16.6) years. A total of EUR 47.3 million (EUR 49.3 million) was paid as wages and salaries in 2018.

Helen Electricity Network Ltd had 98 (108) employees at the end of the year. The number of permanent employees was 96 (105) and the number of fixed-term employees 2 (3). The average number of employees was 105 (106). The average age of the employees was 44.9 (44.5) years, and the average length of employment was 13.9 (14.2) years. Wages and salaries amounted to EUR 6.6 million (EUR 6.6 million) in 2018.

Suomen Energia-Urakointi Oy had 144 (148) employees at the end of the year. The number of permanent employees was 142 (142) and the number of fixed-term employees 2 (6). The average number of employees was 145 (155). The average age of the employees was 46.2 (46.8) years, and the average length of employment was 11.8 (12.0) years. A total of EUR 6.5 million (EUR 6.3 million) was paid as wages and salaries in 2018.

The other subsidiaries, Oy Mankala Ab and Helsingin Energiatunnelit Oy had no employees at the end of 2018.

Research and development

The Finnish Government has decided to prepare legislation to prohibit the use of coal in energy production as from 2029: the legislative proposal was under review by Parliament at the turn of the year. Solutions to replace current production at Hanasaari and Salmisaari are examined as a whole. Preparations are under way for the planning decision for the bioenergy heating plant, which is a partial solution to replace Hanasaari, with a view to a decision by Helen's Board of Directors in winter 2019. The options include the Vuosaari wood chip heating plant, the Tattarisuo wood chip heating plant and/or the Patola pellet-fired heating plant. In addition to the bioenergy heating plants, investments in heat pumps and energy storage facilities have been made or are under preparation. Solutions to replace the heat production of Salmisaari are currently investigated. These include fuel conversions, new production plants, and non-combustion based solutions (e.g. various heat pump solutions from different heat sources, geothermal energy, utilisation of industrial waste heat, and modular nuclear reactors).

R&D activities consist of the development of various technologies, services, cooperation models and concepts. The research operations have focused on research projects for diverse utilisation of circular economy fractions into more valuable end products (liquid biofuels, raw materials) and heat.

Concepts for future energy systems, where renewable energy forms such as solar and wind energy play a more significant role in total electricity production, are developed in the EU-funded FLEXCHX project (Flexible combined production of power, heat and transport fuels from renewable energy sources) coordinated by VTT. The project seeks the best operating models to balance seasonal fluctuations in electricity and heat production. For example, during periods of low-cost electricity, it is possible to produce, e.g. renewable transport fuels from electricity with the Power-to-X method.

Helen is also taking part in the VaBiSys (Value-optimised use of biomass in a flexible energy infrastructure) research project coordinated by VTT as part of the ERA-NET projects in the EU Horizon 2020 programme. In the project, future technological development and solutions are modelled especially from the viewpoint of biomass use, taking account of the sustainability criteria of biomass, as well as developing technologies also in other bioeconomy sectors.

Helen published an IoT development project on heat demand response, which is implemented together with Helsingin kaupungin asunnot Oy (Heka). Demand response is analysed with various service partners in Heka’s properties by implementing heat controls during the heating season of 2018-2019. The objective is to investigate the feasibility of heat demand response in properties and the impacts on living conditions and to assess the significance of demand response as part of the overall district heating system.

Helen is involved in the EU-SysFlex project together with Helen Electricity Network Ltd and VTT. Helen’s goal in the project is to develop and demonstrate new market-driven flexibility technologies and products for the needs of the transmission grid and the distribution system. As part of the project, Helen and Liikennevirta developed an aggregation platform for flexibility in electric vehicle charging points. Moreover, the predictability of electric vehicle charging events and its flexibility potential have also been analysed in the project.

Helen continued cooperation with the transmission system operator Fingrid Oyj in the aggregation pilot project for the balancing energy markets. The objective of aggregation is to combine small-scale sites capable of balancing their electricity consumption or production, thus gaining financial benefits from taking part in the maintenance of the power balance in the electricity system. The pilot aims to gain practical experiences, e.g. from submitting aggregated bids, registering the sales and handling balance corrections, as well as information exchange between various parties in the balancing power market.

Helen is engaged in the EU project mySMARTLife to test new solutions for climate change mitigation in cities. The objective is that the solutions tested in Helsinki can be utilised in other towns in Finland and in other countries at a later date. An interface for heat demand response, which was piloted in Merihaka, was implemented within the project in 2018. The temperature levels experienced by the residents were also studied at the site with the activation of demand flexibilities. As part of the project, Helen and VTT have built a simulation model with a purpose of studying the impact of reducing the supply water in the district heating network in the Tali district. Moreover, e.g. five solar panel benches and one charging station for e-bikes were implemented in Helsinki within the project.

Helen took part in Kasvupolku (Energy Growth Track), a joint growth programme for energy companies seeking new innovations, ideas and business models. Participation in Kasvupolku is part of Helen’s cooperation with growth companies aiming to identify new, promising partner enterprises, to increase common sales and to act as a facilitator of growth also through ownership arrangements.

Internal control and risk management 

The aim of our risk management measures is to ensure the security of energy supply and safeguard and increase the value of the Helen Group in the long term. Within the company, risk management means a systematic and proactive way of identifying, analysing and managing uncertainties related to operations. Comprehensive risk management is a business-oriented, systematic and standardised procedure that steers decision-making and operations throughout the organisation.

It is the responsibility of Helen's management to ensure that the company has efficient risk management and internal control practices with regard to the extent and content of its economy and business operations. With regard to the extent and structure of its operations, the company has extensively assessed the most significant risks and uncertainty factors, as well as other factors affecting operational development.

Internal control and risk management have been organised by including risk-management thinking in all activities of the company. Operating principles and a risk management handbook have been drawn up for energy trading. The energy trading principles and associated risk management practices outlined in the risk management handbook have been approved by Helen's Board of Directors.

The comprehensive development programme for risk management includes, e.g., a risk maturity model and year clock. The maturity model assesses the present level of risk management and sets a target level for it. Improvement of risk management is based on measures that help to achieve the target level. The Management Group of Helen Ltd assesses the level of risk management annually.

Strategic risks

The key uncertainty in the long-term development of business operations is the operating environment, where the steering mechanisms, objectives and schedules are constantly changing due to political decision-making. In such a situation, it is challenging to plan long-term planning of investments in climate-neutral energy production.

Financial risks

The essential business risks are mainly associated with the high volatility and the increasing unpredictability of the electricity market. Competition in the electricity retail market is also becoming tougher.

Fluctuations of the electricity exchange price result in business risks in sales to wholesale customers and end customers, as well as in electricity procurement. The Group is prepared for risks by using derivatives to hedge procurement and sales. He most significant risks in fuel procurement are the volume risk and price risk. These risks are managed, e.g, by concluding procurement and derivative contracts.

Operational risks

Significant operational risks could result in faults in production plants or networks and production outages.  This could result in extra costs for energy procurement and possibly also disruptions to energy supply. The production plants’ operational risks are managed through proactive maintenance and condition monitoring of equipment and networks, as well as personnel training.

Earnings-related pension insurances and a group life insurance were taken out at Keva. The rest of insurances are divided between four insurance companies. The insurance protection covers damages to property, damage due to business interruptions, damage to third-parties, personal injuries and vehicle damage. It has been ensured that the coverage and excess levels of the insurances correspond to the insurance companies' risk-bearing capacity.


Helen’s long-term target is climate neutrality. Climate change mitigation has a key impact on our planning of future energy solutions and our forthcoming investments. We make progressive investments in reducing emissions and increasing renewable energy in order to take full advantage of new technologies. New energy production solutions are also developed together with customers. All energy production of Helen Ltd is covered by the EU emissions trading scheme.

The impacts of local emissions from energy production on the air quality in the Helsinki metropolitan area are monitored as part of the air quality monitoring carried out by the Helsinki Region Environmental Services Authority HSY. According to this monitoring, energy production has very low impacts on the air quality in Helsinki.

In addition to the climate and environment, Helen’s operations also have an impact on people. We aim to communicate about our activities openly with our stakeholders and to know their views and expectations. In 2018, we carried out a survey on our stakeholders’ views on Helen’s responsibility work via an online dialogue. More than 70 per cent of the representatives of our external stakeholders who took part in the survey regarded Helen as a responsible actor. The most important responsibility themes raised in the survey were security of supply, reducing the use of fossil energy, increasing the use of renewable energy sources, and reducing emissions.

The topics that attracted the most debate among Helen's stakeholders in the course of the year were the ban on the energy use of coal, sustainability of bioenergy, and the impacts of the planned bioenergy heating plant in Tattarisuo on the environment and society. During the year, open discussion meetings were held with regard to Helen's bioenergy plans, future energy systems and the heat market renewal. We held three public meetings concerning the ongoing environmental impact assessment of Tattarisuo.

Helen’s electricity generation and the production and distribution of heating and cooling are certified in accordance with the ISO 14001 environmental management system standard. Helen Electricity Network Ltd uses an integrated operating system that complies with the standards ISO 9001, ISO 14001 and OHSAS 18001. Helen Electricity Network Ltd is in the process of adopting an operating system complying with the ISO 55000 asset management standard with respect to the ISO 9001 and ISO 14001 systems. The operating system will continue to be certified with the OHSAS 18001 occupational health and safety management system as before. The environmental impacts of our offices are managed with the Green Office environmental programme.

Annual General Meeting

The Annual General Meeting of Helen Ltd (1/2018) was held on 23 March 2018. KPMG Oy Ab was selected as the company's auditor. The auditor with the main responsibility was Kaija Pakkanen, Authorised Public Accountant.

On 14 May 2018, the owner made a decision in compliance with chapter 5, section 1, subsection 2 of the Limited Liability Companies Act on amending articles 2-10 of the Articles of Association. The amendment affected, i.a., section 10 of the Articles of Association, according to which the number of issues to be discussed in an Annual General Meeting is lower than before. For example, the Board members of Helen’s subsidiaries are no longer selected in Helen’s Annual General Meetings.  A mention of responsibility and operations complying with the principles of sustainable development has also been added to the article defining the field of operation. The mention of granting of procuration has been removed, the term of office of the auditor has been changed into two years, the notice period for an extraordinary general meeting has been extended into three weeks, and a mention of the selection of the Chairperson of the Board of Directors has been added to the article defining the representation right.

Board of Directors

On 23 March 2018, the Annual General Meeting selected a Board of Directors for the new term of office.  Osmo Soininvaara acted as Chairman and Wille Rydman as Vice Chirman of Helen’s Board.The other members of the company’s Board of Directors were Hanna-Maria Heikkinen, Kaisa Hernberg, Marko Karvnen, Hillevi Mannonen, Timo Piekkari, Sirpa Puhakka and Daniel Sazonov.

In 2018, the Board of Directors convened 13 times. One of the meetings was an email meeting. The attendance percentage of the Board members in Board meetings was 92%.

The Board committees

The Board committees are the Audit Committee and the Personnel and Rewards Committee. The committees help the Board in carrying out its duties.

The members of the Audit Committee are Hillevi Mannonen as Chairman, and Hanna-Maria Heikkinen and Sirpa Puhakka as members. The committee meetings were regularly attended by the chief Financial Officer and the vice President, General Counsel, as the secretary of the committee, as well as by the auditor and any other experts that the committee had invited at any given time. The Audit Committee convened seven times in 2018.

The members of the Personnel and Rewards Committee were Osmo Soininvaara as Chairman and Wille Rydman and Timo Piekkari as members. The committee meetings were regularly attended by the CEO. The Human Resources Manager acted as the secretary of the committee. The Personnel and Rewards Committee convened two times in 2018.

President and CEO

Pekka Manninen, M.Sc. (Tech.) has acted as President and CEO of Helen Ltd. During the financial period, a total of EUR 550,195 (EUR 552,023) was paid as salaries, fees and bonuses to the members of the company's Board of Directors and to the President and CEO and his deputy.

The Board of Directors' proposal for the distribution of dividends

The distributable equity of the parent company Helen Ltd stands at EUR 1,339,141,544.01, of which the profits from the previous financial years amount to EUR 45,583,175.42 and the profit from the financial year to EUR 42,385,975.14. The Board of Directors proposes to the Annual General Meeting that the company should pay a dividend of EUR 51,000.00/share, totalling EUR 51,000,000.00, and that EUR 36,969,150.56 should be held as retained earnings. The Board of Directors proposes that the distribution of dividends should take place on 30 April 2019. The liquidity of the company is good, and the Board of Directors takes the view that the profit distribution will not jeopardise the company's liquidity.


The price fluctuations in the electricity wholesale market are expected to remain high and increase in the coming years as variable production increases. In district heating, competition is constantly intensifying in relation to other heating methods and operators as active new, prominent operators and technologies are entering the market.  New district cooling customers are sought through active sales and marketing.

Consensus on the rules of implementing the Paris Agreement is an important waypoint in international cooperation. Helen strives for climate-neutral energy production, and Helen is investing a lot of determined effort to reach this goal. Helen’s near-future target is to reduce emissions by 40% by 2025.  Investments will be made in the extensive utilisation of waste heat by means of heat pumps, and we will continue our projects on het storage at the same time.  With a long-term outlook, we are investigating several emission-free technologies, such as geothermal heat, utilisation of sea water and small modular nuclear power reactors.

The Finnish Government’s legislative proposal to ban the use of coal in energy production is currently under review by Parliament. Helen has the tools to replace coal. What kind of tools will be used will depend on the schedule. If implemented, the coal act would determine the schedule and also the solutions available. The process of building an energy production plant in the Helsinki conditions, with its permit procedures, could take as long as ten years, Therefore, the projects on solutions concerning the year 2029 should be launched within the next few years.

If the coal act is implemented, it will be important to ensure that a provision on the cancelation of emission released allowances is issued, so that the carbon dioxide emissions are really reduced.