To cap or not to cap?

In the early days of the development of the EU Emissions Trading System (EU-ETS) a number of industry groups, particularly in the energy intensive sector (e.g. cement, metals) put forward an alternative design known as “baseline-and-credit”. This was widely discussed and strongly advocated by some, but never gained traction with the EU Commission and was ultimately rejected as a viable way forward.

Baseline-and-credit is fundamentally different to cap-and-trade, in that no cap exists within the system. Rather, individual facilities are assigned a benchmark CO2 per unit of production (or it could be against some other specific production related metric) and must either buy credits in the market if the facility is short for the compliance period or are awarded credits by the government if the facility exceeds the benchmark. Offset project credits may also form part of the mix as they often do in traditional cap-and-trade approaches.

Since then, baseline-and-credit has been applied in a limited way in Alberta, Canada and did actually run for a few years in the United Kingdom in some sectors. Otherwise, the focus has been on cap-and-trade. But baseline-and-credit keeps rearing its head and has done so again in Australia very recently as the debate over the CPRS (Carbon Pollution Reduction Scheme) continues.

This then raises the question, yet again, as to whether such an approach can be the basis of a workable emissions trading system. Whilst baseline-and-credit seems to have all the components necessary for a viable market, (i.e. a tradable unit, supply, demand), the reality of trying to build such a system is very different. A number of obstacles present themselves:

• Of primary importance is that there is no overall cap on emissions. This is what really drives demand and creates the necessary scarcity to see a price develop. Whilst individual facilities may have a benchmark target, actual emissions from the system remain unknown until the level of production is known. If production is high, total emissions from the covered sector may even rise, even though the intention of the government is to drive emissions down. This means that delivering a specific environmental outcome cannot be guaranteed.
• A linked issue to the lack of a cap is that the government probably has one, perhaps in the form of a pledged reduction target for the nation as a whole. If production is high and emissions rise, the government will be forced to rachet down the benchmark, creating uncertainty for the scheme participants. Alternatively, the performance risk for the nation as a whole could rest with the government, which might then have to step in and buy international allowances to meet a cap such as that pledged under the Kyoto Protocol.
• The approach is built on the assumption that benchmarks are available and easy to establish. Whilst this may be true for some sectors, it is far from true for others. Chemicals is a good example, where one site may be comprised of many different processes and as such unlike any other single chemicals site. A related issue comes from attempting to find equality between sectors – i.e. how do I know that my benchmark for the cement sector is equivalent in difficulty to achieve as my benchmark for the steel sector?
• The world is progressing towards absolute numbers and developed countries are taking the lead in this respect. This means that national obligations must all eventually be in the form of absolute numbers and developed countries today are now targeting between 15 and 20% reductions in absolute emissions by 2020 from 2005. As discussed above, governments would rather not have to manage compliance, so they will cascade the obligation down into the economy as much as possible. This means that many nations will use cap-and-trade and will seek to link these with other cap-and-trade systems to increase flexibility and lower overall compliance costs. But a baseline-and-credit system cannot fully link with a cap-and-trade system given that one has an overall cap and the other doesn’t. The UK tried to link two such systems some years back and had to implement a complex gateway. Whilst the baseline-and-credit system can always buy from the cap-and-trade system, the reverse is not the case. A supply of credits from a baseline-and-credit system that has overall emissions rising due to increased production may undermine the environmental objective of the cap-and-trade system it is linked to (hence the UK gateway).
• A cap-and-trade system works its way progressively along the abatement curve, always implementing the next best reduction opportunity. This may be an efficiency measure, a CCS project or possibly a reduction in demand for a given product as a cheaper alternative (lower carbon footprint) is found. By contrast, the baseline-and-credit system may distort this progression along the abatement curve, driving up the overall cost of compliance for the economy as a whole. Whilst the system favours production and encourages efficiency measures, the hard truth may be that the most effective way to reduce emissions is through demand destruction and replacement of certain products and not through improved efficiency of existing production capacity.
• Lastly and perhaps most importantly, a trading system must deliver a liquid market. The ensures efficient price discovery, sufficient depth to execute large trades and the development of a forward curve – all important criteria to support investment. But the development of a liquid carbon market is hampered by the very design of baseline-and-credit. This has been seen in practice in systems that have come and gone, where trade was negligible and the price feeble at best. Up front allocation of allowances delivers a tradable commodity into the market early on, allowing future prices to develop – a critical component of overall trade in the energy sector. By contrast, baseline-and-credit delays crediting until after the event, which limits future trade. Many companies will simply not even entertain the notion of trading something they don’t yet have.

Cap-and-trade is the proven performer. It has delivered successfully in the US Acid Rain Program and has created a robust and growing carbon market in the EU. We need to create more systems of this design if we want to reduce emissions at lowest overall cost to the economy and have any chance of a global market in the years to come.