Archive for September, 2012

In search of a new home for CERs

Two recent publications highlight the challenges ahead in the multilateral process that continues to seek an equitable global approach to the issue of growing CO2 emissions. But comparing and contrasting them illustrates the contradictions that exist as negotiators attempt to maintain existing structures and work within the spirit of the Durban agreements.

Two weeks ago, a major report issued by the High Level Panel on the CDM Policy Dialogue recommended a very broad range of actions for stabilizing and reversing the ongoing price collapse in the CER market (Certified Emission Reduction, the carbon unit within the CDM), with a view of re-establishing the CDM as the cornerstone of the global carbon market and thereby kicking off a further round of emissions mitigation action.

This week, the Harvard Project on Climate Agreements issued a policy brief  which outlines the shape of the new paradigm that the UNFCCC process has hopefully entered following the creation of the Durban Platform for Enhanced Action at COP 17 last December. Their ambitious interpretation of the agreement sees the Berlin Mandate effectively consigned to history (which enshrined the notion that emission reduction was effectively the responsibility of developed countries and which led to the 95-0 vote on the Byrd-Hagel Resolution in the United States Senate) and a new order emerging which results in all countries acting to manage emissions. There is no doubt that the latter interpretation is the only one that makes sense, but only time will tell if this represents the new reality. The Harvard think piece ends with the challenge;

Having broken the old mold, a new one must be formed. A mandate for change exists. Governments around the world now need fresh, outside-of-the-box ideas, and they need those ideas over the next two to three years. This is a time for fundamentally new proposals for future international climate-policy architecture, not for incremental adjustments to the old pathway.  We trust that this call will be heard by a diverse set of universities, think tanks, and advocacy and interest groups around the world.

Rescuing the CDM as recommended by the Policy Dialogue is a laudable ambition, but perhaps falls into the category of “incremental adjustments to the old pathway” rather than “outside of the box ideas”. Conversely, the Policy Dialogue proposal is attempting to stave off the collapse of the very idea of “carbon markets” by rescuing the one global example of their application. While “out of the box” thinking is certainly welcome, it is also hard to argue that we are done with carbon pricing/markets and now need something new. In fact, carbon pricing remains core to the solution.

As such, we end up with the dichotomy of needing new ideas but not wanting to see the structures of the past slip through our fingers; but should we mind that they institutionalize some of the ideas within the Berlin Mandate?

The CDM was a bold idea when conceptualized in the Kyoto Protocol, starting with the simple phrase;

A clean development mechanism is hereby defined.

But has it reached its use-by date and should it be consigned to the dustbin along with the Berlin Mandate? Unfortunately the answer is both “yes” and “no”. It does represent an era of action and financing being the responsibility of developed countries only, which is no longer a tenable paradigm within which to operate. It was designed to help developed countries meet their mitigation goals and to channel funding from developed to developing countries for the purpose of sustainable development. Yet it did demonstrate a mechanism which allowed a broader range of actors to get involved in the carbon market than those immediately impacted by the cap on allowances. This has become a design feature of more recent cap-and -trade systems, albeit with home grown offset systems.

The solution for the CDM, both to rescue the market today and to prepare it for the “out of the box” solution of tomorrow, must be to disentangle it from the Kyoto Protocol and make it available as a general offset resource under the UNFCCC, perhaps even one that any nation could use when it wants to involve part of its economy in the market without actually applying a cap to it (such as the farming sector in Australia).

Considerable resource is required to establish an offset mechanism, both in design and operation. Reinventing this multiple times around the world hardly seems like the best use of government resources, but that is what is happening. Unshackling the CDM wasn’t discussed in the Policy Dialogue report, perhaps because it then enters into the complex realm of Kyoto Protocol politics. The closest it got to this was a proposal to broaden the use of CERs.

To unlock the full potential of the CDM, all countries should be enabled to use CERs, not only those with mitigation targets under the Kyoto Protocol.

But the Kyoto Protocol represents the Berlin Mandate and, according to the Harvard Project, the new paradigm is a world without such a legacy. It also makes little sense under the accounting rules of the Kyoto Protocol to have other parties dipping into that market when their compliance obligation may be governed by another system. This leaves only the more radical approach of decoupling the CDM from the Kyoto Protocol, but then following the recommendations of the Policy Dialogue to broaden its scope and expand its use.

This also takes the CDM into the world of another discussion, that of the New Market Mechanism. Under such an approach, the CDM could migrate to become the NMM, but for all nations to use within the design of their emission trading systems.

Is the CDM now increasing emissions?

Late last week Point Carbon reported that the Executive Board of the UNFCCC’s Clean Development Mechanism has (re)agreed to allow energy efficient coal fired power plants to be included under the mechanism. Point Carbon said:

The governing body of the U.N’s Clean Development Mechanism (CDM) has agreed to allow the most energy efficient coal-fired power plants to earn carbon credits under the scheme, causing outcry from green groups who claim the carbon market could be overrun by millions of low-quality offsets. The CDM Executive Board’s decision to lift its ban that prevented coal plants from seeking credits could allow some 40 projects, mostly based in China and India, to earn Certified Emission Reductions (CERs).

The credits are awarded to projects that cut emissions of greenhouse gases and can be used by companies and governments to meet carbon reduction targets.

. . . . .

. . . . .

The Board approved six coal plants for CDM registration before agreeing in November 2011 to suspend and review the methodology that outlines how many credits the schemes could earn, effectively stopping new projects from earning credits.

While it is always good to use a resource more efficiently, this move has potentially negative consequences for the very issue it is setting out to address, a reduction in the total emissions of CO2 to the atmosphere.

In this instance the CDM is not acting as a carbon pricing mechanism, rather it is simply incentivizing energy efficiency. In a recent paper written by a colleague (featured in a July posting), the secondary impacts of energy efficiency policy as a climate change response are explored. This particular action by the CDM Executive Board falls right into one of the problem areas.

The paper presented the argument that energy efficiency action on its own could actually result in an increase in CO2 emissions. The diagram below explains this. On the vertical axis is the cost of providing an energy service, such as electricity. At the margin, this may be driven by non-fossil provision operating within the economy, such as a wind farm or the like. On the horizontal axis is a measure of the available carbon resource base. As the price of non-carbon alternative energy rises or falls, so too does the long term availability of the fossil alternative for a given technology set. At high alternative prices, more money is available to spend on expanding the fossil resource and vice versa. As the fossil resource expands, the cumulative number of tonnes of CO2 emitted will also grow, even if it takes longer for this to happen.

Assuming a given alternative cost of providing electricity (pnon-fossil), the more efficient the power stations that burn coal, the more the electricity provider can ultimately afford to pay for the coal that is used. As more coal is used and the price rises (all other things being equal), so the resource base expands (from UC1 to UC2 in the figure above) and so does cumulative CO2 in the atmosphere. Further, as the CO2 issue is basically an atmospheric stock problem, this then drives up long term warming, even if the rate at which CO2 is emitted happens to fall in the short term.

From a climate finance perspective the CDM has been a successful mechanism, albeit with some significant operational difficulties. It has paved the way for carbon pricing in many countries and has been an important catalyst for change in some areas (e.g. landfill methane). But subsidizing more energy efficient coal fired power plants, while well intentioned, may in fact have negative environmental consequences. The CDM needs to act in its purest sense, which is as a carbon price in the energy system of true developing economies.

N.B. Just prior to posting this, a colleague noted that the Executive Board may have only allowed the issuance of CERS against already approved projects to proceed, rather than allowing future projects to apply by releasing the current hold on the underlying methodology. Hopefully this is the case, but in any case the argument still stands.

A CCS project for Canada

I don’t normally use this blog to write about Shell, but last week saw an announcement that is very relevant and worthy of some further elaboration. Shell Canada, as operator of the Athabasca Oil Sands Project joint venture (with Chevron and Marathon), announced plans to proceed with a carbon capture and storage project (Quest) within the current oils sands project. This is a project that has been under discussion in one form or another since almost day one of production from the facilities, but the lack of a workable economic justification for the project has been the major impediment to progress.

In recent years the story has changed though. The Government of Alberta has developed a carbon pricing system which provides a level of underlying support for the project. The World Bank “State and Trend of the Carbon Market 2012” report describes the Alberta system (on page 89) as follows:

Alberta is Canada’s largest greenhouse gas (GHG) emitting province, accounting for 34% of the country’s total GHG emissions in 2010. This represents 235 MtCO2e, a 41% increase from 1990 levels, driven primarily by increased production activity in its oil and gas sector. On July 1, 2007, Alberta launched a mandatory GHG emission intensity-based mechanism, enacting the first GHG emissions legislation in Canada. Approximately 100 entities with annual emissions exceeding 100,000 tCO2e (ktCO2e), are required by the legislation to reduce their emission intensity by 12% from average 2003-2005 levels. Entities that do not meet reduction requirements on a given year may choose to meet these obligations by:

  • Trading “Emissions Performance Credits” (EPC) that are awarded to covered entities that reduce emissions below their set target;
  • Paying CN$15 (US$15.2) into a technology fund; and/or
  • Purchasing Alberta-based offsets issued by the Alberta Offsets Registry under an approved protocol.

N.B. The World Bank chart below shows the number of offsets retired annually through the system with an estimate for 2011 (not announced at the time the report was published). The price has remained very close to the technology fund alternative.

As such, this system provides an underlying base level of support of some CAN$15 per tonne of CO2 for the CCS project. In addition, in 2011 the Alberta Government announced a further support mechanism for CCS though the system, which now grants a second bonus credit for CCS projects meeting certain criteria. The Canadian based Pembina Institute published the diagram below, challenging the environmental integrity of the approach, but it also gives a simple explanation of how the mechanism works. In a completely closed system the environmental integrity  argument would be correct, but in the open ended Alberta system with payment into a technology fund as a compliance option, the argument is hardly valid. 

A further, but much less quantifiable, price signal is that coming from the California Low Carbon Fuel Standard (LCFS) and to a much lesser extent the EU Fuel Quality Directive (FQD). These mechanisms place a carbon footprint target on the fuel in the transport sector with a starting baseline about equal to the carbon footprint of oil products processed through a conventional production and refining route and then declining by about 1% per annum. When oil sands products arrive in these markets, their higher carbon footprint generates a penalty on the use of the component in the fuel pool which manifests itself as a price on carbon emissions associated with the production and use of the product. Of course the product may be targeted at other markets, but even a small location constraint on a product can lead to a trading discount in some market circumstances. This is also a carbon price of sorts. In any case, the prevalence of LCFS type approaches could well increase over the years ahead, which could penalize oil sands relative to some other production routes.

The combination of Provincial and Federal grants, a Province based carbon pricing system and its bonus credits and consideration of the role played by fuel standards in export markets in the future has allowed the project to get the green light. This should be seen as good news. CCS is the critical technology for real long term reductions in emissions – I have argued in the past that it may well be the only technology, so supporting it now and getting at least some early projects up and running should be an essential policy goal. Support remains a dilemma for policy makers, particularly in challenging economic times. However, there is a valid role to play here in that almost every carbon roadmap to 2030 and beyond shows CCS being required, yet there is currently no carbon price signal strong enough in any jurisdiction to actually build one now and therefore begin the process of demonstration and commercialization.

The project itself is medium in scale, storing about one million tonnes per annum of CO2 coming from the Hydrogen Manufacturing Unit (HMU) linked to the oil sands bitumen upgrader. The HMU produces hydrogen by steam reforming of natural gas, with a nearly pure CO2 stream as a byproduct. At high temperatures (700–1100 °C), steam (H2O) reacts with methane (CH4) to yield syngas.

 CH4 + H2O → CO + 3 H2

 In a second stage, additional hydrogen is generated through the lower-temperature water gas shift reaction, performed at about 130 °C:

 CO + H2O → CO2 + H2

 Heat required to drive the process is supplied by burning some portion of the natural gas. A very simple overview of the process is shown below.

 

The capture plant is located in Fort Saskatchewan, approx 50 km N.E. of Edmonton, Alberta. The CO2 will be transported by 12 inch pipeline to storage, approximately 65 km north of the upgrader site. The CO2 will be stored in a saline aquifer formation called Basal Cambrian Sands (BCS). At 2,300 metres below the surface it is some of the deepest sandstone in the region, with multiple caprock and salt seal layers and no significant faulting visible from wells or seismic activity. The BCS is well below hydrocarbon bearing formations and potable water zones in the region. Relatively few wells have been drilled into the BCS and none within 10 km of the proposed storage site.

It’s been a long road from initial discussion, to early concept and finally the investment decision last week. But the end result is a real CCS project!!

As Australia struggled through the ill fated CPRS legislation and finally landed with its carbon pricing mechanism, I often thought that it would be much simpler if they just joined the EU ETS. Governments don’t tend to do simple practical things like that, perhaps it makes them feel they are giving away some portion of national sovereignty or that they aren’t doing the job they were elected for (i.e. “we must invent it here” syndrome). But despite all this and having gone the very long way around to get there, Australia has, in effect now joined the EU ETS (or perhaps the ETS has joined the Australian trading system).

Last week the Australian Government and the European Commission announced that their respective emission trading systems would link up progressively over Phase III of the EU system, but for Australian entities from the start of full carbon allowance trading in 2015. This is a bold move by both parties and quite possibly one that will make others with nascent trading systems sit up and think about where they want to go. For Australia, provided the changes can be implemented by a parliament that isn’t exactly friendly towards carbon pricing (but a wafer thin majority currently is), the move cements the system into place even further, in that undoing it would likely cause some embarrassment on the international stage. For the EU, it puts the ETS back in the frame and maybe introduces some additional demand at a time of allowance oversupply, depressed prices and a consequent lack of confidence in the system. Let’s hope this move helps both sides to deliver confidence and stability in their respective systems.

A full two-way link between the two cap and trade systems will start no later than 1 July 2018. Under this arrangement businesses will be able to use carbon units from the Australian emissions trading scheme or the EU Emissions Trading System (EU ETS) for compliance under either system. To facilitate linking, the Australian government will make two changes to the design of the Australian carbon price:

  • The price floor will not be implemented;
  • A new sub-limit will apply to the use of eligible Kyoto units. While liable entities in Australia will still be able to meet up to 50% of their liabilities through purchasing eligible international units, only 12.5% of their liabilities will be able to be met by Kyoto units.

In recognition of these changes and while formal negotiations proceed towards a full two-way link, an interim link will be established enabling Australian businesses to use EU allowances to help meet liabilities under the Australian emissions trading scheme from 1 July 2015 until the full link is established.

Various Australian, EU and other websites cover all the details, so I won’t repeat them here. Rather, let me spend some time on a key issue that this move raises, namely the future design of any international framework via the UNFCCC (or other process). Both Australia and the EU have stressed that this is a bilateral linkage, to the extent that the allowance transactions will not be processed through the International Transaction Log (ITL), but CER transactions will be. However, there will still be a Kyoto AAU balancing at various times to ensure compliance in that system (although there remains considerable uncertainty with regards the issuance of Kyoto Second Period AAUs as there has been no firm agreement on the full nature of that period).

Despite this apparent distancing from the Kyoto based ITL, it must still be the case that the overarching Kyoto framework has helped this linkage – I might even go a step further here and say “allowed this linkage to happen”. Thanks to the UNFCCC architecture, these two systems grew up with enough harmony to make a linkage possible.  They “count” the same way, “track” the same way and “comply” the same way.  Both the systems have common offset arrangements through CERs under the Kyoto Clean Development Mechanism and the units created under the Australian Carbon Farming Initiative are also Kyoto compliant. This means we have the makings of a linked system with global reach.

This could be the primary goal of a new international framework, i.e. to provide sufficient tools, rules and mechanisms which countries can use in developing their carbon trading systems, thus facilitating linkage at a convenient time for those interested in doing so. Such a linkage framework could deliver the global market that we need, as shown in my illustration below (which by the way has been around for about 5-6 years now, so for me it is great to see that one of my linkage lines has finally been filled in!!).

The opportunity to devise such a framework now exists under the Durban Platform for Enhanced Action, which aims to see a new international agreement in place by 2015, for commencement not later than 2020. The agreement between Australia and the EU should be seen as a catalyst for the thinking behind what is to come.

Finally, as something of an aside, one of the major complaints by Australian companies has been that the current $23 fixed price and the future market floor price put the Australian price of carbon “out of line with the international price”. I challenged this notion in a recent post, but irrespective those who called for such alignment have pretty much got what they wanted, although obviously not in the very short term. There may be eventual irony in this, should the EU system go through something of a recovery in its fortunes. While every indicator today points to a continued depressed price through to Phase IV, stranger things have happened in commodity markets.

P.S. I still think that the simplest approach for Canada, which has been putting off economy wide carbon pricing legislation for years, would be to join the EU ETS.