Transcript Slide 1
Roundtable: Opportunities with climate policy development in China Theory & lessons learned from the EU ETS in practice Roundtable organised by the Ministry of Infrastructure and Environment, The Hague, 25 June 2012 Vianney Schyns, Utility Support Group www.usg.sitech-services.nl 1 Contents 1. Chinese ETS – questions about support 2. Theory: absolute or relative or “hybrid” 3. The EU ETS regulatory framework 4. What were the purposes of free allocation? 5. What about these purposes – needed changes 6. Some references 2 1. Chinese ETS – questions about support (1) • USG (for a.o. DSM, SABIC, OCI) finds the emergence of a successful Chinese ETS of high importance – level playing field – sustainability EU ETS long-term • – China is the biggest emitter, with high growth – No BRIC ETS was the argument for inaction in USA (Canada) – Chinese ETS may be the key for a successful COP-21 result Some USG action – Contacts (high level) about EU ETS experiences, about the theories of a robust and effective ETS (studies discussed, send to Beijing) – USG is invited to speak on BIT's 1st Annual World Congress of Greentech, Guangzhou, 19-21 October 2012 3 1. Chinese ETS – questions about support (2) • Dutch support is important – We have (with Flanders) most experience with benchmarks, played important role in making EU ETS benchmarks, leading role of Ecofys – • • Other important issues in China: • MRV (can we support here, NEa above average level) • Market liberalisation, especially for electricity Support for the best possible theoretical ETS framework – Difficulty: agreement of experts unlikely within short notice – So: let the Chinese decide based on argumentation But, let us not forget India, Brazil, etc. 4 2. Theory: absolute or relative or “hybrid” (1) • Most difficult subject, try to analyse via “elimination” • Level 1: absolute gives certainty of environmental outcome, relative does not; expressed often, by e.g. – Koutstaal c.s. (CATEP, 2002), EU Commission e.g. Decision (2003) on Dutch NOx ETS, EU ETS Directive demands “absolute” for linking (but: position is softening) – – However “absolute” is no guarantee, some targets “can’t be done”: • Who could have foreseen the immense Chinese growth 10 years ago? • If absolute would be guarantee: why not set -85% for 2020, or for 2025? Canada (2007): “World Resources Institute noted in a 2006 report, ‘for environmental performance, what matters overall is that targets are set at reasonably stringent levels and subsequently are met. This may be achieved with absolute or intensity targets.’” 5 2. Theory: absolute or relative or “hybrid” (2) • Level 1: absolute gives no certainty of outcome – Illusion: supply-demand balance predictable for e.g. 10 years ahead – Will Europe recover from the crisis? Or remain depressed for 10 years? (like Japan, for a long time and may be still) 6 2. Theory: absolute or relative or “hybrid” (3) • Level 2: carbon price signal – carbon leakage – windfalls – Climate Strategies / Carbon Trust, Öko-Institut and others incl. Koutstaal and RUG: actual production is solution to avoid carbon leakage, but not acceptable because of loss of carbon price signal (meant: product carbon price signal), “with relative caps product prices are inefficient” (Koutstaal) – price elasticity of demand – However: avoidance of carbon leakage and avoidance of possibility of windfall profits (ref. CE Delft) and maintenance of product carbon price signal are conflicting objectives • Leakage >> elasticity profit (Carbon Trust) • Leakage is anyway inefficient and total loss for the environment 7 2. Theory: absolute or relative or “hybrid” (4) • Level 3: combining absolute with relative, one ‘hybrid” – Not studied very much, but by Carolyn Fischer (Resources of the Future), Philippe Quirion (CIRED a.o.), Loske / Schyns – “Ex-post” with guarantee of total cap is easy in present EU ETS: • New entrants’ reserve (NER) can absorb growth, allowances to flow back if production is lower than assumed • • NER to be refilled from action volume, if depleted • However, EU ETS cap > 2020 is problem in case of no global ETS by 2020 Level 3: another “hybrid”, with “Carbon Bank(s)” – Waxman-Markey idea: large strategic reserve, with price collar – Addresses long-term supply-demand uncertainty, avoids lock-ins 8 2. Theory: absolute or relative or “hybrid” (5) • Summary problems with EU ETS ex-ante allocation – Possibility of windfall profits – Over-supply during crisis (EU ETS only commodity market without supply response) – set-aside is questionable & no structural solution – Incentive for production carbon leakage (49%, partial cessation rules) – Under-allocation: major barriers and risks for growth, likelihood of investment carbon leakage • Wide agreement on ideal system long-term – Auctioning, but then also global rules: what (not) to do with revenues – Probably also: some supply response – e.g. with carbon banks – Global cap – same ETS coverage – one single carbon price 9 3. The EU ETS regulatory framework • EU ETS Directive of 2003 – • Commission Decision on Benchmarks and Allocation Rules – • Revised, 23 April 2009 (OJ 5 June 2009), legally binding Comitology, adopted 27 April 2011, legally binding (the “CIMs” *) Guidance Documents on Benchmarks and Allocation Rules – Adopted 14 April 2011 and later, not legally binding – (1) General guidance, (2) allocation methodologies, (3) data collection, (4) verification NIMs baseline data reports, (5) carbon leakage, (6) cross boundary heat flows, (7) new entrants / closure rules, (8) waste gases, (9) sector specific guidance, PLUS guidance methodology report + Q&As (together 500+ pages) *) CIMs: Community-wide and fully-harmonised Implementation Measures 10 4. What were the purposes of free allocation? • Globally – – • Avoid carbon leakage (e.g. recital 24, statement Barroso, EP, Council) • Production leakage (lower production, import product & unemployment) • Investment leakage Protect competitiveness as good as possible (recital 25, Tajani) Europe (EU-27 plus Norway etc.): avoid distortions – “Harmonised ETS is imperative to avoid distortions in the internal market” (recital 8) through “Community-wide and fully-harmonised implementing measures” (Art. 10a(1)) – Environmental effectiveness (recital 20 old, Art. 1, Art. 10a, etc.), away from historical grandfathering 11 4. What about these purposes – needed changes • Avoid carbon leakage, protect competitiveness, support Europe 2020 Strategy for growth and jobs • Ex-ante incentive to 49% lower production; should move to ex-post, eliminates barriers & risks for growth, creates recession-proof system • NER limited (sufficient for 1.2% annual growth), should move to refill from auction volume if depleted and be defined also for after 2020 • Unstable, unpredictable financial compensation, should move to indirect allocation, complementary to direct allocation • Stringent top 10% immediately in 2013, should move to top 10% for 2025 or 2030 (‘sliding path’ allocation) • Carbon Leakage List: assessments each 5 years, should move to: industry “exposed” by default (comparison EU ETS with ETSs outside EU) • Abandon correction factors on allocation (“LRF”, “CSF”, “CLEF”) • Abandon Guidance Docs, move to legally binding rules, simplify rules 12 5. Some References • “Climate change challenges and the search for a sustainable policy”, Schyns (2005), a.o. about absolute or relative targets • “The IFIEC method for the allocation of CO2 allowances in the EU Emissions Trading Scheme”, by Ecofys (2008) • Trilogy Study: “The benefits and feasibility of an ETS based on benchmarks and actual production”, Loske / Schyns (2008), about ensuring the cap in an intensity based scheme & about carbon leakage, possible windfall profits and the product- and the production carbon price signal • “A reality check of the EU Emissions Trading Scheme; Does it allow growth – the major objective of the EU industry policy?”, Brouwers / Stalmans / Schyns (2012), a detailed analysis of CIMs & Guidance Documents: major barriers & risks for growth 13