63270 state and trends of the Washington DC, June 2011 ₂₀₁₁ state and trends of the ₂₀₁₁ Environment Department This report was prepared by a World Bank team comprising of Nicholas Linacre, Alexandre Kossoy and Philippe Ambrosi, with important contributions from Manelle Aït Sahlia, Veronique Bishop, Benoît Bosquet, Christophe de Gouvello, Taisei Matsuki and Monali Ranade. 2 | State and Trends of the Carbon Market 2010 New Approach for the 2011 Report With the goal of providing a comprehensive discus- sion of the issues that most affected the carbon mar- ket in 2010, the authors of last year’s report have re- structured State and Trends of the Carbon Market for 2011. The report still provides an overview of the size and reach of the carbon markets, as well as the evolu- tion of the Kyoto flexibility mechanisms, and offers potential supply/demand scenarios for coming years. However, it no longer includes a detailed breakdown of carbon transactions, as in previous years. Instead, the report provides a more in-depth analytical dis- cussion of the regulation and policy issues that will guide future carbon market development. The findings and opinions expressed in this report are the sole responsibility of the authors and should not be cited without permission. They do not necessarily reflect the views of the World Bank Group, its Executive Directors, the countries they represent or of any of the participants in the carbon funds or facilities man- aged by the World Bank. The World Bank does not guarantee the accuracy of the data included in this work. This report is not intended to form the basis of an investment decision. The bound- aries, colors, denominations, and other information shown in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. Section 1 photo credit: Jan Golinski / UNFCCC Section 2 photo credit: Veer Incorporated Section 3 photo credit: Veer Incorporated Section 4 photo credit: Dreamstime LLC Section 2 photo credit: Veer Incorporated Design: Studio Grafik Printing: Westland Printers State and Trends of the Carbon Market 2010 | 3 Acknowledgements The report benefitted greatly from colleagues in the Akiko Nishimae, John O’Brien, Klaus Oppermann, carbon market who provided their written contribu- Molly Peters-Stanley, Vicky Pollard, Leila Pourarkin, tions and perspectives: Olga Christyakova, Martin Neeraj Prasad, Brice J. M. Quesnel, David Rapin, Lawless, and Damien Meadows. Heike Reichelt, Renaud Scardina, Kai-Uwe Barani Schmidt, Guido Schmidt-Traub, Chandra We wish to extend our gratitude to those who offered Shekhar Sinha, Trevor Sikorski, Milo Sjardin, Yvon their cooperation and insights during the elaboration Slingenberg, Sara Stahl, Andy Stone, Aurelien Tignol, of this report: Edwin Aalders, Schwan Badirou Gafari, Sarah Underwood, Laurent Valiergue, John Virgoe, Ellysar Baroudy, Jean-Jacques Barberis, François Alessandro Vitelli, George Waldburg, Xueman Wang, Beaurain, Luca Bertali, Agnès Biscaglia, Martina Vikram Widge, Yevgen Yesyrkenov, Peter Zapfel, Ivan Bosi, Ana Bucher, Marcos Castro, Lance Coogan, Zelenko, Elizabeth Zelljadt. Isabelle Curien, Keith Davis, Karen Degouve de Nuncques, Eduardo Dopazo, Jason Dunn, Saša We would also like to thank all of those who took Eichberger, Emmanuel Fages, Laura Fidao, Greger time to respond to the market survey. Without your Flodin, James Foster, Javier Freire Coloma, Martin responses the report would be less than it is. Finally, French, Pranab Ghosh, Matthew Gray, Pierre we want to thank the many market participants strug- Guigon, Isabel Hagbrink, Katherine Hamilton, gling to make a difference on a critical global issue. Henrik Hasselknippe, Carina Heimdal, Andrew Howard, Robert M. Hunt, Daigo Koga, Werner The State and Trends of the Carbon Market 2011 re- Kornexl, Ganna Korniyenko, Benoît Leguet, Gautier ceived financial support from the CF-Assist Program, Le Maux, Mark Lewis, Zijun Li, Peter Lloyd, Thomas managed by the World Bank Institute (WBI). Marcello, Allison McManus, Rachel Mountain, 4 | State and Trends of the Carbon Market 2010 List of Abbreviations and Acronyms AAU Assigned Amount Unit EUA European Union Allowance AAUPA AAU Purchase Agreement EU ETS European Union Emissions Trading Scheme AB 32 Global Warming Solutions Act of 2006 EURIBOR Euro Interbank Offered Rate Assembly Bill 32 FSB Financial Stability Board ACR American Carbon Registry GDP Gross Domestic Product ADB Asian Development Bank GGAS New South Wales Greenhouse Gas AfDB African Development Bank Reduction Scheme AMF Autorité des Marchés Financiers GHG Greenhouse Gas AWG-KP Ad Hoc Working Group on Further GIS Green Investment Scheme Commitments for Annex I Parties under HFC Hydrochlorofluorocarbon the Kyoto Protocol IFC International Finance Corporation AWG-LCA Ad Hoc Working Group on Long-term IEA International Energy Agency Collaborative Action IFI International Financial Institution CAPEX Capital Expenditures IFRS International Financial Reporting Standard CARB California Air Resources Board IMF International Monetary Fund CAR Climate Action Reserve IRR Internal Rate of Return CCP central counterparties J-VETS Japan-Voluntary Emissions Trading Scheme CCS Carbon Capture and Storage JI Joint Implementation CCX Chicago Climate Exchange JISC Joint Implementation Supervisory CDM Clean Development Mechanism Committee CER Certified Emission Reduction KM Kyoto Mechanism CFL Compact Fluorescent Lamp LBFR Law on Banking and Financial Regulation CFTC Commodities Future Trading Commission LDC Least Developed Country CH4 Methane LEDS Low Emission Development Strategies CMM Coal Mine Methane lCER Long-term Certified Emission Reduction CMP Conference of the Parties serving as the LFG Landfill Gas Meeting of the Parties to the Kyoto Protocol LoA Letter of Approval CPF Carbon Partnership Facility LRET Large-scale Renewable Energy Target CO2 Carbon Dioxide LULUCF Land Use, Land Use Change and Forestry CO2e Carbon Dioxide Equivalent MAD Market Abuse Directive COP Conference of the Parties MCCF Multilateral Carbon Credit Fund CPA CDM Programme Activity MDB Multilateral Development Bank CPRS Carbon Pollution Reduction Scheme MiFiD Markets in Financial Instruments Directive CP-1 First Commitment Period under the Kyoto MOP Meeting of the Parties Protocol MRET Mandatory Renewable Energy Target CRE Commission de régulation de l’énergie MRV Measurement, Reporting and Verification CRT Climate Reserve Tonne NAMA Nationally Appropriate Mitigation Action DNA Designated National Authority NCCP National Climate Change Policy DOE Designated Operational Entity NDRC National Development and Reform EB Executive Board of the CDM Commission EBRD European Bank for Reconstruction and N2O Nitrous Oxide Development NAP National Allocation Plan EC European Commission NPV Net Present Value ECX European Climate Exchange NZ ETS New Zealand Emissions Trading Scheme EE Energy Efficiency NZU New Zealand Unit EIT Economy in Transition OECD Organization for Economic Co-operation EITE Emission-intensive, Trade-exposed and Development ER Emission Reduction OTC Over-the-Counter ERPA Emission Reduction Purchase Agreement pCER Primary Certified Emission Reduction ERU Emission Reduction Unit PDD Project Design Document ESC Energy Savings Certificate PFC Perfluorocarbon ESS Energy Savings Scheme PIN Project Idea Note ETS Emissions Trading Scheme PMR Partnership for Market Readiness EU European Union PoA CDM Programme of Activities State and Trends of the Carbon Market 2010 | 5 POI Proof of Identity SF6 Sulfur Hexafluoride PP Project Participant SME Small and Medium-size Enterprise R&D Research and Development SRES Small-scale Renewable Energy Scheme RE Renewable Energy tCO2 Ton of Carbon Dioxide REC Renewable Energy Certificate tCO2e Ton of Carbon Dioxide Equivalent REDD Reducing Emissions from Deforestation and tCER Temporary Certified Emission Reduction Forest Degradation UN United Nations REDD+ Extends REDD by including sustainable UNEP United Nations Environment Programme forest management, conservation of forests, UNFCCC United Nations Framework Convention on and enhancement of carbon sinks. Climate Change REMIT Regulation on Energy Markets Integrity and VAT Value-added Tax Transparency VCS Voluntary Carbon Standard RET Renewable Energy Target VCU Verified Carbon Units RGGI Regional Greenhouse Gas Initiative VER Verified Emission Reduction RMU Removal Unit WB World Bank sCER Secondary Certified Emission Reduction WCI Western Climate Initiative SCF Strategic Climate Fund WTI West Texas Intermediate SEI Sustainable Energy Initiative WTO World Trade Organization 6 | |State and Trends of the Carbon Market 2010 State and Trends of the Carbon Market 2010 State and Trends of the Carbon Market 2010 | 7 Contents Acknowledgements 3 Overview 9 Introduction 11 1. International Developments—Cancun Conference and the Post-2012 Environment 13 1.1 Improvements to the Clean Development Mechanism and Continuing Support for Market Mechanisms 14 1.2 Climate Finance and the Establishment of the Green Climate Fund 16 1.3 Recognition of Developing Country Contributions to Mitigation and a Better Representation of Forestry-related Activities 16 1.4 Beyond Cancun—Market Perceptions 17 1.5 Conclusions 18 2. Domestic Policy Developments—A Story of Fragmentation 21 2.1 Annex I Countries 22 2.2 Non-Annex I Countries 33 2.3 Linking Emissions Trading Schemes 36 2.4 Conclusions 37 3. How Market Participants Transact—Risk and Regulation 39 3.1 The Changing Regulatory Landscape—The Impact of Financial Market Reforms 39 3.2 Over-the-counter Market—Regulation is Coming Down the Pike 42 3.3 Primary Issuance Market—Emission Allowance Auctions 42 3.4 Secondary Markets—Controlling Risk and Ensuring Transparency and Accountability 43 3.5 Conclusions 45 4. Carbon and Climate Finance 47 4.1 Kyoto Market—A post-2012 Facing Low Demand and Low Supply 47 4.1.1 CERs—What Did or Did Not Happen in 2010? 48 4.1.2 ERUs—What Lies Ahead? 51 4.1.3 AAUs—Responding to the Lack of Demand 52 4.2 Voluntary Markets 53 4.3 Mobilizing Low-carbon Investment—Beyond Carbon Revenue Streams 55 4.4 New Asset Classes Coming to the Market 57 4.4.1 REDD and REDD+ 57 4.4.2 Sustainable Land Management—Agricultural Soil Carbon 59 4.5 Conclusions 59 5. Outlook - Demand and Supply Balance 61 5.1 Demand and Supply Balance Through to 2012 61 5.1.1 Sovereign Demand 61 5.1.2 Private Sector Demand 63 5.1.3 Supply Through to 2012 64 5.1.4 Residual Demand—136 MtCO2e 64 5.2 Will there be Enough Emission Reductions Generated in Developing Countries After 2012? 65 5.3 Conclusions 68 Methodology 70 Appendix 1. Assumptions for Estimates of Potential Demand for Offsets from non-Annex I Countries 71 Glossary 73 8 | State and Trends of the Carbon Market 2010 Boxes Box 1. The European Union’s Approach to International Credits 15 Box 2. North American Offset Prices 31 Box 3. Brief History of Carbon Market Fraud in the EU ETS 40 Box 4. A Point of View on the EU ETS 41 Box 5. Voluntary Markets 54 Figures Figure 1. Carbon Market at a Glance, Market Values, 2004–10 9 Figure 2. Respondents Views on a Future Multilateral Framework 18 Figure 3. RGGI Forecast Emissions 33 Tables Table 1. Carbon Market at a Glance, Market Values, 2004–10 9 Table 2. Current State Climate Change Policies in Australia 23 Table 3. Current Province Climate Change Policies in Canada 23 Table 4. EU ETS Phase II Auctions 25 Table 5. Aviation Directive Summary 27 Table 6. Some Examples of U.K. Complementary Measures 28 Table 7. Current Climate Change Policies in Japan 29 Table 8. Offset Supply and Demand Forecast for California’s Cap-and-trade 31 Table 9. Current U.S. State and Regional Climate Change Policy in North America 32 Table 10. Current Trading Platforms in China 35 Table 11. Voluntary Market Prices and Volumes 54 Table 12. Supply and Demand in Perspective–Kyoto Market Balance, 2008–12 62 Table 13. Potential Demand, Contracted Supply, and Residual Demand, 2008–12 65 Table 14. Scenarios of Potential Demand for Offsets Generated in non-Annex I Countries 2013–20 (MtCO2e). 66 Table 15. Estimates of Potential Supply Under the CDM and JI up to 2020 (MtCO2e) 67 State and Trends of the Carbon Market 2010 | 9 Overview HOW LONG CAN A MARKET BE IN TRANSITION? After five consecutive years of robust growth, the Figure 1. Carbon Market at a total value of the global carbon market stalled at Glance, Market $142 billion (see Figure 1).1,2 Suffering from the Carbon Market Evolution ($ billion) Values, 2004–10 lack of post-2012 regulatory clarity, the value of the primary Clean Development Mechanism (CDM) market fell by double-digits for the third year in a row, ending lower than it was in 2005, the first year of the Kyoto Protocol. The Assigned Amount Unit (AAU) market, which grew in 2009 with strong sov- ereign support, shrank as well in 2010. Finally, the market that had grown most in 2009—allowances under the U.S. Regional Greenhouse Gas Initiative (RGGI)—saw that year’s gains erased in 2010. As these segments declined, the dominance of the European Union Allowances (EUAs) market became more pronounced than ever. EUAs accounted for 84 EU ETS Allowances Other Offsets percent of global carbon market value in 2010. With Other Allowances Secondary CDM the value of the secondary CDM transactions taken into account, the share of the carbon market primar- Primary CDM ily driven by the EU Emissions Trading Scheme (EU ETS) rose to 97 percent, dwarfing the remaining Sources: World Bank, Thomson Reuters Point Carbon, Bloomberg New Energy Finance, and Ecosystem Marketplace segments of the market (see Table 1). Carbon Market Evolution, values ($ billion), 2004–10 Table 1. Carbon Market at a Glance, EU ETS Other Primary CDM Secondary Other Offsets Total Market Values, Allowances Allowances CDM 2004–10 2005 7.9 0.1 2.6 0.2 0.3 11.0 2006 24.4 0.3 5.8 0.4 0.3 31.2 2007 49.1 0.3 7.4 5.5 0.8 63.0 2008 100.5 1.0 6.5 26.3 0.8 135.1 2009 118.5 4.3 2.7 17.5 0.7 143.7 2010 119.8 1.1 1.5 18.3 1.2 141.9 Sources: World Bank, Thomson Reuters Point Carbon, Bloomberg New Energy Finance and Ecosystem Marketplace Note: Numbers may not add up due to rounding. 1. For details on the methodology refer to the Methodology Section at the end of the report. 2. Still, carbon volumes traded contracted by over 10 percent during the same period as prices declined in some markets. 10 | State and Trends of the Carbon Market 2010 The global carbon market stagnated even as the global Some of the most notable events in 2010 and early economy stabilized and began a tentative recovery in 2011 were unfortunately related to framework loop- 2010. The carbon market growth halted at a particu- holes and criminal activities directed against the larly inopportune time: 2010 proved to be the hottest EU ETS. In addition to the “carousel” value-added on record,3 while emission levels continued their seem- tax (VAT) fraud that surfaced in 2009,5 the last 18 ingly inexorable rise.4 In the end, however, the year may months witnessed the sale of recycled CERs, phish- be remembered most for the political opportunities ing attempts on Germany’s national registries and a that arose, yet were ultimately failed to materialize. series of subsequent cyber-thefts that undermined the European market,6 highlighting security short- In the United States, there was not enough sup- comings and increasing the urgency of stakeholders’ port to pass federal cap-and-trade legislation. The pleas to strengthen infrastructure. Japanese Basic Act on Global Warming, which passed in the Diet’s lower house, was halted when Nevertheless, there were a few reasons for guarded the government lost control of the upper house a optimism in 2010. Europe started to craft its road- few months later. Australia’s Senate failed to pass the map for moving toward a competitive low-carbon Carbon Pollution Reduction Scheme and Australia’s economy in 2050. Also, while the Copenhagen cli- government subsequently chose to freeze its plans mate summit in 2009 failed to meet expectations, for a domestic cap-and-trade scheme. Even the year’s progress was achieved during the Conference of the rare good news, namely the Republic of Korea’s Parties in Cancun last December. Such progress was adoption of the Framework Act on Low Carbon welcomed by the market and helped to restore some Green Growth, turned sour when the government, confidence in UN negotiations on climate change. facing internal opposition, decided in early 2011 Still, as Parties continue their deliberations,7 much to delay the implementation of its cap-and-trade remains to be done. Differences among major emit- scheme until 2015. ters regarding domestic priorities, approaches and ambition will need to be resolved before a robust At the global regulatory level, in mid-2010 the CDM and sustainable international agreement can emerge. Executive Board temporarily halted issuance of Certified Emission Reductions (CERs) from hydro- While the international regulatory environment re- fluorocarbon (HFC-23) projects over baseline con- mains uncertain, national and local initiatives have cerns. As concerns revealed not to be substantiated, noticeably picked up and may offer the potential to issuance resumed at the end of the year. Nonetheless, collectively overcome the international regulatory gap. the European Commission soon thereafter proposed The most prominent of these initiatives is California’s qualitative restriction in the EU ETS of carbon off- cap-and-trade scheme, which is expected to begin op- sets related to CDM industrial gas projects. The pro- erating in 2012. Other low-carbon initiatives, includ- posal was adopted by the European Member States, ing domestic emission reduction targets, clean energy which in January 2011 confirmed the ban of CERs certificate programs, voluntary and pre-compliance do- from HFC and nitrous oxide (N2O) adipic acid mestic offset trading programs, and carbon exchanges, projects starting, in 2013. have gained increasing traction in developing econo- mies such as Brazil, China, India, and Mexico. These initiatives signal that, one way or another, solutions that address the climate challenge will emerge. 3. 2010 ranked as the warmest year on record, together with 2005 and 1998, World Meteorological Organization (WMO) (http://www. wmo.int/pages/mediacentre/press_releases/pr_906_en.html). 2010 tied with 2005 as the warmest year of the global surface temperature record, beginning in 1880, The U.S. National Oceanic and Atmospheric Administration (NOAA) (http://www.noaanews.noaa.gov/sto- ries2011/20110112_globalstats.html). 4. 2010 ended with CO2 emission concentrations of 389.68 ppm, NOAA, January 7, 2011. 5. Some of the issues evidenced in 2009 were explained in detail in the State and Trends 2010 report: http://siteresources.worldbank.org/ INTCARBONFINANCE/Resources/State_and_Trends_of_the_Carbon_Market_2010_low_res.pdf Access date 15 April 2011. 6. Over 3 million European Union [emission] allowances (EUAs) were reported stolen from at least 5 European national registries from No- vember 2010 until January 2011. As a consequence, the transfer of allowances has been temporarily suspended in the European registries and the spot-trade of carbon assets was frozen for several days early 2011 (http://ec.europa.eu/clima/news/index_en.htm). 7. Under the Ad Hoc Working Group on Further Commitments for Annex I Parties under the Kyoto Protocol and the Ad Hoc Working Group on Long-term Cooperative Action under the Convention. State and Trends of the Carbon Market 2010 | 11 Introduction This report covers many of the issues facing the participants of the emergence of a fragmented but carbon market today. The Overview provides high- workable carbon market that could further evolve lights from the report and information on the size through linking and acceptance of similar levels of of the carbon market. The body of the report covers ambition. international developments (Section 1), domestic policies (Section 2), risk and regulation of markets An issue related to domestic and regional mitiga- (Section 3), carbon and climate finance (Section 4), tion policies is the considerable activity currently and market outlook (Section 5). surrounding carbon market risk and regulatory de- velopment. This section provides details on many is- The international developments section briefly dis- sues faced by policy makers, regulators, and market cusses the positive outcomes for carbon markets participants. Considerable change occurred during and climate finance resulting from the Cancun 2010 and is expected to continue over 2011. There Conference. International developments have im- is convergence on regulatory approaches as more portant implications for market confidence and European countries move toward robust and trans- hence vital private capital investment. The report parent regulation of the carbon market to ensure includes the results from a market sentiment sur- market and public confidence. This includes a re- vey conducted by the World Bank’s Carbon Finance evaluation of such long-held principles as universal Unit. The results show that, despite well-document- participation. ed short-term uncertainty surrounding the carbon market, respondents to are optimistic about the pos- While Sections 1–3 summarize the geopolitical and sibility of a binding agreement in the longer term. regulatory environment affecting the carbon market, This section of the report also establishes the broad Section 4 on carbon and climate finance provides a parameters used in the projection scenarios devel- more detailed analysis of the impacts of these factors oped in the market outlook. on current Kyoto primary market prices, volumes, and market behavior. This part of the report also The report provides a summary of some national briefly discusses climate finance and new emerging and regional mitigation measures being implement- asset classes such as REDD plus. Finally, in Section ed, including important Nationally Appropriate 5, the report brings all this information together in Mitigation Actions (NAMAs) from some major the market outlook, which discusses the supply and emitters. The information in this section supports demand balance going forward. the increasingly common perspective among market 12 | State and Trends of the Carbon Market 2010 SECTION 1 State and Trends of the Carbon Market 2010 | 13 International Developments—Cancun Conference and the Post-2012 Environment THE DISAPPOINTMENT resulting from the United Nations Climate Change Conference in Copenhagen in 2009 was replaced by the renewed optimism of the Cancun Conference in 2010, which restored some market confidence in the United Nations Framework Convention on Climate Change (UNFCCC) process. At the Cancun Conference, countries agreed to keep average global temperature warming below 2˚C in comparison to preindustrial levels. They also agreed to review the adequacy of this com- mitment with the possibility of moving to a 1.5˚C target as new scientific evidence on impacts becomes available.8 The Cancun Conference resulted in a number of oth- than 2˚C in comparison to preindustrial levels.10 er positive outcomes for carbon markets and climate The International Energy Agency (IEA 2010) also finance:9 the decision to establish the Green Climate estimates that the 2˚C goal will only be achievable Fund; the continuation of the Kyoto mechanisms, with a dramatic scaling-up effort,11 particularly from including important improvements and reforms to major emitters. the Clean Development Mechanism (CDM); the inclusion of reduced deforestation through REDD and REDD plus (REDD+); and the formal recogni- tion of developing countries’ pledges of Nationally Appropriate Mitigation Actions, which are aimed at “ Developed and developing country pledges are 60 percent of what is achieving a deviation in their GHG emissions com- pared to business-as-usual trends by 2020. needed by 2020 to place the world onto a trajectory that will keep global The best case analysis from the 2010 United Nations Environment Programme (UNEP) Emissions Gap Report estimates that developed and devel- oping country pledges are 60 percent of what is temperature rises to less than 2˚C ” needed by 2020 to place the world onto a trajec- This section focuses on key elements of the Cancun tory that will keep global temperature rises to less Agreements and current market sentiment. 8. http://unfccc.int/files/meetings/cop_16/application/pdf/cop16_kp.pdf Access date 28 Feb 2011. 9. The United Nations Climate Change Conference took place in Cancun, Mexico, from 29 November to 10 December 2010. It encom- passed the sixteenth Conference of the Parties (COP) and the sixth Conference of the Parties serving as the Meeting of the Parties to the Kyoto Protocol (CMP). 10. UNEP 2010. Emissions Gap Report. “Are the Copenhagen Accord Pledges Sufficient to Limit Global Warming to 2˚C or 1.5˚C? A Preliminary Assessment.” http://www.unep.org/publications/ebooks/emissionsgapreport/ Access date 9 March 2011. 11. IEA 2010. World Energy Outlook. http://www.worldenergyoutlook.org/ Access date 29 March 2011. 14 | State and Trends of the Carbon Market 2010 “ Emissions trading and the project-based mechanisms under the Kyoto Protocol will continue to be available to Annex I Parties as means to meet their quantified emission limitation and reduction objectives, but the future of the Kyoto Protocol itself remains unresolved. ” 1.1 IMPROVEMENTS TO THE CLEAN Emissions trading and the project-based mechanisms DEVELOPMENT MECHANISM AND under the Kyoto Protocol will continue to be avail- CONTINUING SUPPORT FOR MARKET able to Annex I Parties as means to meet their quan- MECHANISMS tified emission limitation and reduction objectives,13 but the future of the Kyoto Protocol itself remains The major area of improvement and reform of the unresolved. Additionally the Cancun Conference CDM is arguably the introduction of standardized under the Ad Hoc Working Group on Long-term baselines and monitoring methodologies. These deci- Cooperative Action under the Convention (AWG- sions are aimed at maintaining environmental integ- LCA) negotiation track agreed to consider the estab- rity, but reducing transaction costs, enhancing trans- lishment of one or more market-based mechanisms parency and predictability, and facilitating access to to enhance the cost-effectiveness of mitigation ac- underrepresented project types and regions.12 tions by Parties.14 Such decisions that seek to improve the access of These changes are not yet providing the regulatory under-represented regions in the CDM are particu- predictability the market is seeking. Clarity is still larly important in the face of the EU’s decision to urgently needed on the post-2012 international cli- restrict CERs from CDM projects registered after mate change regime and on countries’ plans to use December 31, 2012 to those generated by projects market-based mechanisms to meet domestic GHG located in least developed countries (LDCs). A sig- objectives. As highlighted in Box 1, the European nificant change is needed in order to be able to scale Union is seeking to provide such clarity. up the virtual absence of LDC projects from the CDM pipeline (for further details see Section 4.1). 12. COP 16. Decision -/CMP.6. “ Further guidance relating to the clean development mechanism.” http://unfccc.int/files/meetings/cop_16/ conference_documents/application/pdf/20101204_cop16_cmp_guidance_cdm.pdf Access date 4 Feb 2011. 13. Outcome of the work of the Ad Hoc Working Group on Further Commitments for Annex I Parties under the Kyoto Protocol at its fifteenth session http://unfccc.int/files/meetings/cop_16/application/pdf/cop16_kp.pdf Access date 28 Feb 2011. 14. http://unfccc.int/resource/docs/2010/cop16/eng/07a01.pdf#page=2 Access date 29 April 2011. State and Trends of the Carbon Market 2010 | 15 BOX 1. The European Union’s Approach to International Credits The strategic importance of a broad and deep Sectoral mechanisms and the CDM could co-exist but international carbon market the CDM should increasingly focus on less developed countries, where it should continue to target low cost The EU is by far the biggest buyer of emission re- options for saving emissions. For the major emerging duction credits15 from third countries, providing for economies in the developing world, the CDM should continued financial flows and technology transfer to gradually be replaced by new sectoral mechanisms. developing countries, also after 2012 even in the ab- sence of the certainty that should come from a new Provisions in the climate and energy package international agreement to effectively tackle climate change. If designed properly and underpinned by ro- Several provisions of the EU’s domestic climate leg- bust targets, the international carbon market can play islation provide the tools to incentivise a move away a major role in global abatement efforts, and create from the CDM and towards sectoral mechanisms. increasing financial flows to support mitigation activi- The EU ETS and Effort Sharing Decision foresee that ties in developing countries. after 2012, even without an international agreement, these instruments can provide a market for CERs Design limitations of the CDM from new projects in Least Developed Countries. In addition, CERs from existing projects in other coun- To make this happen, we need to improve our existing tries can continue to be used. The EU’s standards tools and create new, advanced and scaled-up mar- on HFC-23 and adipic N2O credits, which have been ket mechanisms. Despite its successes, as a project- discussed extensively and will apply from 2013, cre- based system—and one that in practice covers so far ate more space for other CDM credits and can pro- a limited number of project types—the CDM is simply mote a shift to credits from bilateral or multilateral not designed to drive the structural transformation of agreements. The EU is interested in engaging with industry in developing countries that the transition to our partners to set up such pilots so that the experi- a low-carbon economy requires. By definition, offset ence gained can inform the international negotiations. mechanisms such as the CDM cannot reduce global Participation in the initiatives such as the Partnership emissions in net terms—yet this is what is needed if for Market Readiness can facilitate the designing of we are to keep global warming below 2°C. robust pilots and finding interested partners. Need for a move to sectoral crediting EU’s vision for the international carbon market mechanisms Europe’s vision for the international carbon market That is why the EU and other Parties are advocat- remains to link up the EU ETS with other compat- ing the creation of new and more ambitious sec- ible emission trading systems around the world and toral mechanisms that make it possible to tap into to develop robust sectoral mechanisms. We see an far greater emissions-saving potentials and provide eventual network of links between cap and trade sys- more revenue for financing reductions in developing tems as forming the backbone of an expanded and countries. Because only actions that go beyond a strengthened international carbon market. In this per- previously defined threshold or target are credited, spective, sectoral crediting is a necessary step be- this would ensure net benefits to the atmosphere. yond the CDM’s project-based approach. Kindly provided by Damien Meadows, Head of Unit, International Carbon Market, Aviation and Maritime, DG Climate Action European Commission. 15. Project-based emission reductions are commonly referred to as credits, offset credits or offsets. 16 | State and Trends of the Carbon Market 2010 1.2 CLIMATE FINANCE AND THE developed country Parties and 25 members from de- ESTABLISHMENT OF THE GREEN veloping country Parties, with members having the CLIMATE FUND necessary experience and skills, notably in the area of finance and climate change.18 The Cancun Agreements formalized the commit- ment made by developed countries in Copenhagen to mobilize $100 billion a year by 2020 to address 1.3 RECOGNITION OF DEVELOPING the mitigation and adaptation needs of developing COUNTRY CONTRIBUTIONS countries. Importantly, the Cancun Conference de- TO MITIGATION AND A BETTER cided to establish a “Green Climate Fund.” It is envi- REPRESENTATION OF FORESTRY- sioned that the Fund will manage a portion of these RELATED ACTIVITIES additional resources. The Cancun Conference formally recognized devel- The sources of funding are not yet clear. It is ex- oping countries’ Nationally Appropriate Mitigation pected, however, that a portion of the $100 billion Actions (NAMAs), which were pledged after the will come from private sources, which may be mo- Copenhagen Conference. In the context of sustain- bilized through carbon markets.16 Carbon finance able development, developing countries agreed to and other financial instruments will be important undertake NAMAs aimed at reducing emissions rela- for leveraging these funds to scale up the financing tive to business-as-usual emissions in 2020—contin- of mitigation and adaptation activities. Policy mak- gent upon the provision of finance, technology, and ers will need to ensure that market-based capacity is capacity building provided by developed countries.19 maintained in both the public and private sectors to A registry is to be established under the UNFCCC ensure mobilization of the pledged climate finance. to record NAMAs seeking international support and to facilitate matching of finance, technology, and The Fund will be governed by the Green Climate capacity-building support to these actions.20 Board, comprising 24 members as well as alternate members, with an equal number of members from At the time of writing, 45 countries have regis- developing and developed country Parties. The World tered a wide range of mitigation actions with the Bank will serve as the interim trustee of the Green UNFCCC. These actions range from broad enunci- Climate Fund, subject to a review three years after ated targets with varying form—absolute reductions operationalization of the Fund. An independent sec- on business-as-usual (BAU) or intensity limits— retariat will support the operations of the Fund.17 with varying base years21,22 to detailed programs of activities with and without quantified GHG emis- The Green Climate Fund will be designed by a sion reductions.23,24 Transitional Committee in accordance with the terms of reference. The Transitional Committee The particularity of NAMAs, especially those seek- comprises 40 members, with 15 members from ing support from international sources, is a need for 16. Final Report of the UN High-Level Advisory Group on Climate Change Financing. 2010. http://www.un.org/wcm/content/site/climat- echange/pages/financeadvisorygroup/pid/13300 Access date 29 March 2009. 17. http://unfccc.int/cancun_agreements/green_climate_fund/items/5869.php Access date 29 April 2011. 18. http://unfccc.int/files/na/application/pdf/07a01-1.pdf Access date 29 April 2011. 19. List of Nationally Appropriate Mitigation Actions of Developing Country Parties. http://unfccc.int/meetings/cop_15/copenhagen_ac- cord/items/5265.php Access date 8 April 2011. 20. COP 16. 2010. Outcome of the work of the Ad Hoc Working Group on Long-term Cooperative Action under the Convention. http:// unfccc.int/files/meetings/cop_16/application/pdf/cop16_lca.pdf Access date 28 Feb 2011. 21. Mexico aims at reducing its GHG emissions up to 30 percent with respect to the business as usual scenario by 2020. http://unfccc. int/files/meetings/cop_15/copenhagen_accord/application/pdf/mexicocphaccord_app2.pdf Access date 8 April 2011. 22. India will endeavor to reduce the emissions intensity of its GDP by 20-25 percent by 2020 in comparison to the 2005 level. http:// unfccc.int/files/meetings/cop_15/copenhagen_accord/application/pdf/indiacphaccord_app2.pdf Access date 8 April 2011. 23. Brazil has a range of quantified emissions reductions from different activities. http://unfccc.int/files/meetings/cop_15/copenhagen_ac- cord/application/pdf/brazilcphaccord_app2.pdf Access date 07 April 2011. 24. Ethiopia quantifies many reduction actions in terms of power generation potential http://unfccc.int/files/meetings/cop_15/copenha- gen_accord/application/pdf/ethiopiacphaccord_app2.pdf Access date 08 April. State and Trends of the Carbon Market 2010 | 17 monitoring, reporting, and verification (MRV) ca- framework. The scenarios include the following: (1) pacity. Clear boundaries and tracking will be neces- a continuation of the current multilateral framework sary to avoid overlapping and double counting sup- with legally binding limits on emissions; (2) a non- port for NAMAs. binding multilateral accord; and (3) no multilateral framework in the short-term.28 The Cancun Conference recognized the much broader contribution of forest-related activities in As scenario development is important for market efforts to limit climate change. Specific recogni- participants, the World Bank’s Carbon Finance Unit tion was given to the reduction of deforestation and surveyed them on five questions regarding the suc- degradation through such initiatives as REDD and cess of an international agreement post-2012: REDD+. This means that forests will be included in any future agreement with the possibility of generat- 1. How confident are you that there will be a new le- ing international credits from these activities.25 gally binding multilateral framework, similar to the current Kyoto Protocol, with legally binding com- Measurement of forest carbon will occur at the na- mitments to reduce emissions, underpinned by tional level, thus enabling programmatic approach- relatively strong multilateral rules and institutions? es. This measure is expected to encourage greater 2. How confident are you that there will be a new geographic diversification (for further details see political multilateral accord, building on the Section 4.4). Copenhagen Accord and Cancun Agreements, un- der which countries make voluntary political com- mitments, supported by at least some multilateral 1.4 BEYOND CANCUN rules and institutions, but without legal force? —MARKET PERCEPTIONS 3. How likely do you think it is that there will be no multilateral framework or accord in the near Developing countries are united in their support for term? Countries continue to negotiate, but in a second commitment period of the Kyoto Protocol, the interim, action is mainly driven at a national as a critical element of the international community’s level or through other international links. fight against climate change. Among the developed 4. Do you think a comprehensive agreement under countries, the European Union continues to support the auspices of the UNFCCC is fundamental for the multilateral framework through the UNFCCC26 countries to address the climate change agenda? and the Kyoto Protocol, but some countries have 5. Are there other scenarios, apart from those listed expressed opposition to the extension of the Kyoto above, which should be considered? Protocol in which only some countries are obligated to reduce emissions.27 The uncertain future of the Survey respondents were not optimistic that a bind- international negotiations affects market percep- ing international agreement could be achieved in the tions. Participants partly deal with this uncertainty short term. However, they were optimistic about the through scenario analysis. possibility of a binding agreement in the longer term (see Figure 2). Respondents believed that a nonbinding The New Zealand government, as part of the cur- multilateral accord is more likely in the short term.29 rent review of the New Zealand Emissions Trading Scheme (NZ ETS), has identified three broad sce- The majority of respondents also believed that there narios for the evolving near-term international will be a short-term hiatus in the international 25. COP 16. 2010. Outcome of the work of the Ad Hoc Working Group on Long-term Cooperative Action under the Convention. http:// unfccc.int/files/meetings/cop_16/application/pdf/cop16_lca.pdf Access date 4 Feb 2011. 26. EC Communication. 2010. “International climate policy post-Copenhagen: Acting now to reinvigorate global action on climate change.” http://ec.europa.eu/clima/documentation/finance/docs/com_2010_86.pdf Access date 19 March 2011. 27. For example, Japan. See Ministry of Foreign Affairs of Japan. “Japan’s Basic Position at COP16 as well as on the Kyoto Protocol.” http:// www.mofa.go.jp/announce/media/2010/12/1203.html Access date 19 March 2011. 28. New Zealand Emissions Trading Scheme Review 2011. http://www.climatechange.govt.nz/emissions-trading-scheme/ets-review-2011/ issues-statement.pdf Access date 19 March 2011. 29. The survey did not test respondents’ views on the relative likelihood of a binding agreement compared to the multilateral accord. 18 | State and Trends of the Carbon Market 2010 Figure 2. How confident are you that there will be a new framework, with countries continuing to negoti- Respondents legally-binding multilateral framework, similar to the ate, and that the absence of international frame- Views on current Kyoto Protocol, with legally-binding commit- work should not impede countries from continuing a Future ments to reduce emissions, underpinned by relatively strong multilateral rules and institutions? to act. Several respondents suggested that bilateral Multilateral Framework mechanisms may provide an alternative model. “ Market-based instruments can play a vital role in helping meet ambitious GHG emission reduction objectives by incentivizing the deployment of private capital. ” 1.5 CONCLUSIONS The international situation remains complex and the direction for the international negotiations may Pessimistic [ < 30%] both surprise and disappoint as the world continues Slightly Pessimistic [30% to 50%] the arduous process of moving forward on an inter- Slightly Optimistic [50% to 75%] national framework for combating climate change. Optimistic [> 75%] As highlighted in the report by the High-Level Advisory Group on Climate Change Financing established by the UN Secretary-General, market- based instruments can play a vital role in helping meet ambitious GHG objectives by incentivizing the deployment of private capital, but countries need to provide the market with regulatory confi- dence in the post-2012 environment.30 30. Final Report of the UN High-Level Advisory Group on Climate Change Financing. 2010. http://www.un.org/wcm/content/site/climat- echange/pages/financeadvisorygroup/pid/13300 Access date 29 March 2011. State and Trends of the Carbon Market 2010 | 19 20 | State and Trends of the Carbon Market 2010 2 SECTION State and Trends of the Carbon Market 2010 | 21 2 Domestic Policy Developments —A Story of Fragmentation THIS SECTION SUMMARIZES SOME OF THE POLICY INITIATIVES around the world, with an in-depth examination of the EU ETS, which is the international driving force of carbon markets. The information in this section supports the increasingly common perspective among market participants of the emergence of a fragmented but workable international carbon market that could further evolve through linking and acceptance of similar levels of ambition. The list of countries is not exhaustive. It illustrates the diversity of approaches and measures being either considered or implemented in several countries. To drive emission reductions, countries are adopt- For example, the current discussion in the EU on ing a range of domestic policies that fall under one the set-aside of EUAs results from the interaction of the following categories: cap-and-trade schemes, of energy efficiency measures and the EU ETS. The baseline and credit mechanism, renewable energy introduction in the United Kingdom of a Carbon and energy efficiency certificates, carbon taxes, sub- Price Floor31 provides another example were some sidies, and emission standards. In many cases, mul- market analysts argue that the price floor may of- tiple policy approaches are being used that may be fer limited benefits due to interactions with the EU complementary and sometimes contradictory, and ETS.32 The interaction between individual voluntary which often have different costs and benefits accru- actions and Australia’s now shelved Carbon Pollution ing at different times and geographical scales. It is Reduction Scheme (CPRS) also shows the need for important in the overall design of mitigation policies careful design.33 Finally, some academic work argues that policy makers consider the interaction between that multiple policies such as cap-and-trade and re- similar and different—market and non-market— newable energy policies will not necessarily create policy measures at different jurisdictional levels. additional environmental benefits.34 31. As announced in the U.K. 2011 Budget from April 1, 2013, the United Kingdom will introduce a carbon price floor for the power sector. The floor, which in reality constitutes a tax floor rather than a price floor, will start at around £16 per ton of carbon dioxide (tCO2) and follow a linear path to target £30/tCO2 in 2020 (both in 2009 prices). The carbon price support rates in 2013–14 will be equivalent to £4.94/tCO2. Indicative rates for 2014–15 and 2015–16 are £7.28/tCO2 and £9.86/tCO2 respectively. http://www.hm-treasury.gov.uk/ consult_carbon_price_support.htm Access date 4 April 2011. 32. Point Carbon. Carbon Market Daily March 25. “UK carbon floor could distort EUA price.” 33. The shelved Australian CPRS provides an example of voluntary action interacting with a cap-and-trade scheme. http://www.climat- echange.gov.au/government/initiatives/cprs/cprs-progress/voluntary-action.aspx Access date 27 April 2011. The situation is more compli- cated when AAUs are considered, as the countries initial assigned amount must also be reduced to preserve the effects of the voluntary action on global reductions. 34. See Fischer C., and L. Preonas. 2010. “Combining Policies for Renewable Energy,” Resources for the Future. Fischer and Preonas ar- gue that in the presence of a binding emissions cap, additional renewable policies do not affect emissions. Their effects on the ETS should be recognized. Policies that expand renewables make it easier to meet the cap, driving down allowance prices to the benefit of the relatively dirty sources and to the detriment of the relatively clean nonrenewable sources. http://www.rff.org/documents/RFF-DP-10-19.pdf Access date 2 April 2011. 22 | State and Trends of the Carbon Market 2010 2.1 ANNEX I COUNTRIES Splitting the RET scheme was in response to indus- try pressure to reform the scheme after a collapse Australia—Preparing to Price Carbon in prices of certificates resulting from a flood of Renewable Energy Certificates (RECs) from small- During 2010, the Australian government an- scale projects. It is reported that the generation of nounced plans for a carbon price mechanism with RECs was partly due to the interaction of state and a three-to-five-year annually increasing fixed-price federal renewable energy incentives and the RET period that will transition into an emissions trading scheme.39,40 scheme. The government will start pricing carbon on July 1, 2012, subject to negotiating an agreement The Australian government also closed several emis- with a majority in both houses of Parliament and sion reduction programs in 2010, including the passing legislation this year.35 Home Insulation Program, which was terminated because of safety concerns,41 and the Green Loans With support from the Greens and Independents, program.42 the government should be able to pass the legisla- tion in both houses of Parliament as a result of the At the state level, various initiatives are in place, incoming senate in July 2011. The legislation would including the New South Wales Greenhouse Gas need to pass during the spring Parliamentary sittings Reduction Scheme (GGAS), which commenced (August–November 2011) to avoid being delayed on January 1, 2003. It is one of the first manda- until the autumn Parliamentary sittings (February– tory greenhouse gas emissions trading schemes in March 2012). the world. GGAS aims to reduce greenhouse gas emissions associated with the production and use Australia is also developing a domestic offsets scheme of electricity. It achieves this by using project-based known as the Carbon Farming Initiative (CFI),36 activities to offset the production of greenhouse gas which aims to provide new economic opportunities emissions (see Table 2 for further details on state cli- to farmers, forest growers, and landholders and to mate change policies in Australia). help the environment by reducing carbon pollution. Some offsets may be allowed during the fixed-price Canada—Provinces Forging Ahead period.37 At the federal level, Canada is taking a sectoral ap- At the national level, the Renewable Energy Target proach to GHG emissions, largely focusing on ob- (RET) scheme remains the main market-based taining reductions from the transport sector. Canada mechanism in use to achieve emission reductions. has aligned its international commitment with that made by the United States and plans to reduce to- During 2010, the Australian Parliament passed tal greenhouse gas emissions by 17 percent from legislation to separate the RET into two parts, 2005 levels by 2020. The target is inscribed in the with the new scheme commencing on January 1, Copenhagen Accord. 2011. The RET was separated into the Large-scale Renewable Energy Target (LRET) and the Small- scale Renewable Energy Scheme (SRES).38 35. http://www.pm.gov.au/press-office/climate-change-framework-announced Access date 24 Feb 2011. 36. http://www.climatechange.gov.au/government/initiatives/carbon-farming-initative.aspx Access date 21 February 2011. 37. http://www.garnautreview.org.au/update-2011/update-papers/up6-carbon-pricing-and-reducing-australias-emissions.pdf Access date 22 March 2011. 38. http://www.climatechange.gov.au/government/initiatives/renewable-target.aspx Access date 07 April 2011. 39. “Price Hit Put Wind Power Projects in Limbo.” Herald Sun. http://www.heraldsun.com.au/ipad/price-hit-puts-wind-projects-in-limbo/ story-fn6bfmgc-1225976910971 Access date 29 April 2011. 40. “Renewable Energy Target Needs a Rethink.” The Australian. http://www.theaustralian.com.au/business/industry-sectors/renewable- energy-target-needs-a-rethink/story-e6frg976-1225785558866 Access date 29 April 2011. 41. http://www.climatechange.gov.au/government/programs-and-rebates/hisp.aspx Access date 03 February 2011. 42. http://www.climatechange.gov.au/government/programs-and-rebates/green-loans.aspx Access date 03 February 2011. State and Trends of the Carbon Market 2010 | 23 Policy Jurisdiction Comment Table 2. Current State Climate Solar Feed-in Tariffs Victoria, South Australia, Queensland, State-based incentives for small-scale solar. Change Policies Australian Capital Territory, New South in Australia Wales, Northern Territory, Western Australia Greenhouse Gas New South Wales One of the first mandatory greenhouse gas emis- Reduction Scheme sions trading schemes in the world. GGAS43 Greenhouse Gas Australian Capital Territory The ACT Government introduced a Greenhouse Reduction Scheme Gas Reduction Scheme that commenced GGAS44 on January 1, 2005. It mirrors the NSW Greenhouse Gas Reduction Scheme (GGAS). State Energy Victoria, South Australia, New South Wales Multiple schemes with similar objectives. Efficiency Schemes. Policy Jurisdiction Details Table 3. Current Province Climate Greenhouse Gas Reduction (Cap British British Columbia is the first province in Canada to introduce Change Policies and Trade) Act 200845 Columbia an act allowing a cap-and-trade scheme. The proposed in Canada scheme enables British Columbia to link to the emissions trad- ing schemes being developed with other jurisdictions. Greenhouse Gas Reduction (Cap Ontario The amendment enables Ontario to have a cap-and-trade and Trade) Act 200846 emissions trading scheme, and to link to the emissions trading schemes being developed with other jurisdictions. Cap-and-Trade Consultation (March Manitoba Manitoba plans to move forward with legislation enabling the 2011)47 creation of a cap-and-trade scheme to reduce greenhouse gas emissions, subject to public consultations. Act to amend the Environment Quebec The amendment enables Quebec to have a cap-and-trade Quality Act and other legislative provi- emissions trading scheme, and to link to the emissions trading sions in relation to climate change48 schemes being developed with other jurisdictions. Climate Change and Emissions Alberta Covers facilities with GHG emissions greater than 100,000 Management Act49 tons. Requires emissions intensity reductions of 12 percent. Management and Reduction of Saskatchewan Covers facilities with GHG emissions greater than 50,000 Greenhouse Gases Act50 tons. Requires emission reductions from a baseline by 2 percent per year from 2010 to 2019. On September 1, 2010, Canada released final tough new regulations on coal-fired electricity gen- Renewable Fuel Regulations that requires an aver- eration that will have a significant impact on reduc- age renewable fuel content of 5 percent in gasoline, ing emissions from the electricity sector.51 which will come into effect starting December 15, 2010. On June 23, 2010, the government of Canada Various initiatives are in place at the Canadian prov- announced that it is committed to introducing ince level. For further details see Table 3. 43. http://www.greenhousegas.nsw.gov.au/ Access date 03 February 2011. 44. http://www.greenhousegas.nsw.gov.au/act_scheme.asp Access date 07 April 2011. 45. http://www.leg.bc.ca/38th4th/3rd_read/gov18-3.htm Access date 16 March 2011. 46. http://www.e-laws.gov.on.ca/html/regs/english/elaws_regs_090452_e.htm Access date 17 March 2011. 47. http://www.gov.mb.ca/conservation/climate/capandtradeconsultation.html Access date 17 March 2011. 48. http://www2.publicationsduquebec.gouv.qc.ca/dynamicSearch/telecharge.php?type=5&file=2009C33A.PDF Access date 17 March 2011. 49. http://www.qp.alberta.ca/570.cfm?frm_isbn=9780779740956&search_by=link Access date 17 March 2011. 50. http://www.environment.gov.sk.ca/Default.aspx?DN=9192fbe8-23fe-4077-ac7d-30b7b269bdbf Access date 17 March 2011. 51. http://www.climatechange.gc.ca/default.asp?lang=En&n=4FE85A4C-1 Access date 17 March 2011. 24 | State and Trends of the Carbon Market 2010 Europe—A Year of Consolidation and a Roadmap for 2050 at 2,039,152,882 allowances, that is just under 2.04 billion allowances.56 This is not the final During 2010, the EU ETS continued to be the world’s 2013 cap.57 most important market mechanism for reducing GHG emissions. The EU ETS operates in 30 countries (the least 50 percent of allowances will be auctioned 27 EU Member States plus Iceland, Liechtenstein, from 2013, compared to about 3 percent in and Norway) and is expected to reduce total emissions Phase II. This will improve the economic ef- by 21 percent in 2020 compared to 2005 levels. The ficiency of the EU ETS. In most EU Member year-on-year declines in GHG emissions experienced States, there will be 100 percent auctioning for by installations in 2008 and 2009 now appear to be the power sector. over, with GHG emissions rising by 3.3 percent—a rebound due to the end of the economic downturn in from outside the EU will be limited to no more 2010. When accounting for new entrants, the overall than 50 percent of the reductions required in the year-on-year increase is 3.5 percent.52,53 EU ETS. This is a reduction from Phase II. It means a much larger share of emission reduc- Europe continues the task of transitioning to a low- tions will happen within the EU borders. carbon society by 2050. The European Commission (EC) is looking beyond the 2020 objectives and is will be redistributed to Member States with low- establishing a plan to meet the long-term target of er gross domestic product (GDP) in the interests reducing domestic emissions by 80 to 95 percent by of solidarity. These are mostly the newer eastern mid-century—Europe’s Roadmap for 2050. During Member States. the year, there was speculation that Europe would move to reduce GHG emissions by 30 percent by of the revenues from auctioning to tackle cli- 2020 compared to 1990 levels. The EC has since mate change both in the EU and in developing reaffirmed that the EU ambition is to achieve a 20 countries. percent reduction by 2020 on 1990 levels.54 - age concerns, industrial sectors will be allocat- From 2013, the revised EU ETS Directive provides ed allowances for free on the basis of product for:55 benchmarks. The benchmarks will be set on the basis of the average of the top 10 percent most - greenhouse gas–efficient installations in the EU. ances, which will reduce each year by 1.74 percent Sectors deemed at significant risk of relocating of the average annual level of the Phase II cap. The production outside of the EU because of the cap will deliver an overall reduction of 21 percent carbon price—carbon leakage—will receive 100 below 2005 verified emissions by 2020. percent of the benchmarked allocation for free. Sectors not deemed at significant risk of carbon 52. On April 5, 2011, the EC published updated data for a perimeter corresponding to 94.4 percent of 2009 volumes: the 10,500 plants reporting in both years (out of 12,802 listed in CITL, 82 percent) emitted 1,833 Mt in 2010 compared to 1,775 Mt in 2009, resulting in a 3.3 percent increase in emissions. Source: SG orbeo Carbon Specials, April 7, 2011, Société Générale. 53. http://ec.europa.eu/clima/documentation/ets/registries_en.htm Access date 4 April 2011. 54. http://ec.europa.eu/clima/documentation/roadmap/docs/com_2011_112_en.pdf Access date 24 March 2011. 55. EU ETS Phase III (2013-20) http://www.decc.gov.uk/eu_ets/phase_iii/phase_iii.aspx Access date 07 April 2011. 56. The EU ETS cap is the total amount of emission allowances to be issued for a given year under the EU Emissions Trading System (EU ETS). The total number of allowances, that is, the “cap,” determines the maximum amount of emissions possible under the EU ETS. The cap will decrease each year by 1.74 percent of the average annual total quantity of allowances issued by the Member States in 2008–12. This annual reduction will continue beyond 2020, but it may be subject to revision not later than 2025. http://ec.europa.eu/clima/policies/ets/ cap_en.htm Access date 07 April 2011. 57. The 2013 cap that has been released so far is not the final 2013 cap. It is the Phase II scope provisional cap and does not account for the cap for aviation and new sectors and gases entering the ETS from 2013. Deutsche Bank estimates that the 2013 cap for the Phase II scope should be worth 1,966 Mt. Counting the 1.3 Mt cap for opt-ins and the 106.9 Mt 2013 cap for new sectors and gases, Deutsche Bank estimates the 2013 cap should be worth 2,074 Mt, not accounting for aviation. From Curien I., and M. C. Lewis. 2011. “May You Live in Interesting Times ...” Market Update from Deutsche Bank. State and Trends of the Carbon Market 2010 | 25 Member Average Annual Quantity Comments Table 4. EU State to Be Auctioned ETS Phase II Auctions58 Germany 40 million (about 9 percent) Auctions from January 2010 are held weekly—spot auctions on Tuesday and futures auctions on Wednesday—at the European Energy Exchange (EEX).59 During 2008 and 2009 a banking group, on behalf of the German government, sold allowances at the market price at the relevant exchanges. United 17 million (7 percent) An auction schedule with dates and volumes for future auctions, up to Kingdom November 2011, is available on the U.K. Debt Management Office.60 As of January 2010, a noncompetitive bidding facility has also been put in place.61 Netherlands 3.2 million (3.7 percent) The first auction of 4 million allowances was carried out by the Dutch State Treasury Agency and took place on April 15, 2010.62 On October 27 and November 18, 2010, two further auctions of 2 million allow- ances each were held by Climex.63 The Dutch authorities have not yet decided the details of the auctioning of the remaining allowances (some 8 million). Austria 400,000 (1.3 percent) For 2009–12, two auctions per year are foreseen.64 Ireland 557,065 (0.5 percent) Ireland sold 185,000 allowances in January 2009, and the same number again in February 2010. The remainder for the 2008–12 period is also likely to be sold instead of auctioned. Hungary 2.7 million (2 percent) Frequency and scope are not yet decided. leakage will receive 80 percent of their bench- Kingdom auctioning allowances. Access to Kyoto marked allocation for free in 2013, declining to Protocol project offsets (namely CDM and JI) were 30 percent in 2020 and 0 percent in 2027. further limited with constraints on project types (see Section 4.1).65 The EU ETS continued to be plagued entrants’ reserve of the EU ETS will be used to by market irregularities—the EU has addressed support the demonstration of carbon capture these issues through a series of directives and pro- and storage (CCS) and innovative renewable posed measures (see Section 3.4).66 Further activity technologies. occurred on coverage with airlines expected to join the EU ETS in 2012.67 Member States continued hospitals so as to reduce regulatory burden. to develop complementary measures to comply with the “Effort Sharing Decision” that places an annual During 2010 and early 2011, the allowance auction binding GHG emission targets on sectors not cov- (primary issuance) market (see Section 3.3) con- ered by the EU ETS for the period 2013–20.68 tinued to develop, with Germany and the United 58. Auction details for EU ETS Phase II. http://ec.europa.eu/clima/policies/ets/auctioning_second_en.htm Access date 07 April 2011. 59. European Energy Exchange (EEX). http://www.eex.com/en/EEX/Products%20%26%20Fees/Emission_Rights/EUA%20Primary%20 Market%20Auction Access date 07 April 2011. 60. U.K. Debt Management Office EU Emissions Trading Scheme Web site. http://www.dmo.gov.uk/index.aspx?page=ETS/AuctionInfo Access date 07 April 2011. 61. http://www.decc.gov.uk/en/content/cms/what_we_do/change_energy/tackling_clima/emissions/eu_ets/euets_phase_ii/auctioning/ noncompbidding/noncompbidding.aspx Access date 07 April 2011. 62. http://www.dsta.nl/english/Subjects/Carbon_auctions Access date 07 April 2011. 63. http://www.climex.com/government-auctions.aspx Access date 07 April 2011. 64. Austrian National Registry. http://www.emissionshandelsregister.at/emission_trading/auction/index.html Access date 07 April 2011. 65. In taking this action, the EC identified the high proportion of CDM credits generated by the small number of industrial gas projects that, the EC argues, favor a limited number of advanced developing countries and do not encourage geographic diversification. http://europa.eu/ rapid/pressReleasesAction.do?reference=IP/11/56 Access date 4 Feb 2011. 66. The details are discussed in the section on “How Market Participants Transact—Risk and Regulation.” 67. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:008:0003:0021:EN:PDF Access date 22 March 2011. 68. http://ec.europa.eu/clima/policies/effort/framework_en.htm Access date 22 March 2011. 26 | State and Trends of the Carbon Market 2010 Auctioning Aviation Table 4 illustrates the auctioning of some EU allow- Direct emissions from aviation account for about ances. During Phase II (2008–12) the majority of al- 3 percent of the EU’s total GHG emissions, with lowances continued to be allocated for free. However, the majority of these emissions from international when Phase III starts in 2013, about half of the allow- flights, for example, flights between two Member ances are expected to be auctioned. On November 11, States or between a Member State and a non-EU 2010, the EU Commission formally adopted the EU country.71 Aviation emissions are growing rapidly, Auctioning Regulation. This is an EU-wide regulation however, so the EU plans to cover emissions from all that determines how some 1 billion allowances will be domestic and international flights that arrive at or auctioned each year during Phase III. depart from an EU airport. The regulation provides for a common platform that The expansion of coverage will translate into approx- all Member States can use, but Member States may imately 200 million of additional allowances annu- also opt out from the common platform. To host ally. Of this number, 82 percent of the allowances their own platforms, Member States had to submit will be freely allocated to aircraft operators and 15 a notification to the Commission by February 18, percent will be auctioned. The remaining 3 percent 2011, which would then be proposed to and voted will be allocated to a special new entrant’s reserve on by the Climate Change Committee.69 (see Table 5 for a summary).72 The European Commission proposes to auction 120 The move to include aviation in the EU ETS is not million allowances in 2012, ahead of the start of without controversy with airlines in both China Phase III. The volume of early auctions is to be de- and the United States opposing the inclusion of termined by means of an amendment to the EU ETS their emissions in the EU ETS. The Air Transport Auctioning Regulation. It is expected that almost 60 Association of America (ATA)—acting on behalf percent of the total allowances auctioned in Phase III of American Airlines, Continental, and United will enter the market via the common platform. Airlines—is challenging the EU directive in the courts.73 News reports also suggest that the China The procurement of both the common auction plat- Air Transport Association (Cata) has threatened re- form and the single auction monitor that will over- taliatory measures if Chinese airlines are required to see auctions on all auction platforms is ongoing.70 participate in the EU ETS, with Cata—acting on Germany, Poland, and the United Kingdom have in- behalf of three Chinese airlines—joining the ATA’s formed the Commission that they intend to opt out of existing legal challenge to the EU directive.74 the planned common platform for auctioning emission allowances for Phase III of the EU ETS. Each will in- The EC Directive on Aviation has provisions for ex- stead appoint its own auction platform. empting non-EU based airlines from the EU ETS where similar measures are in place.75 69. U.K. Department of Energy and Climate Change. The EU Emissions Trading System: Preparing for Phase III (and implementation of Phase II). http://www.decc.gov.uk/assets/decc/what%20we%20do/global%20climate%20change%20and%20energy/tackling%20cli- mate%20change/emissions%20trading/eu_ets/phase%20iii/1016-euets-preparing-phase-III.pdf Access date 07 April 2011. 70. The first auctions of EUAs will take place at the latest in 2013. No firm date is fixed yet, as the volume of any “early auctions” before 2013 remains to be decided. The first auctions of European Union Aviation Allowances (EUAAs) will take place in 2012, which is the year when aircraft operators come under the EU ETS. http://ec.europa.eu/clima/faq/ets/auctioning_third_en.htm Access date 07 April 2011. 71. http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/11/139 Access date 24 March 2011. 72. http://www.decc.gov.uk/en/content/cms/what_we_do/change_energy/tackling_clima/emissions/eu_ets/aviation/aviation.aspx Access date 23 March 2011. 73. http://www.airlines.org/News/Releases/Pages/news_5-27-10.aspx Access date 22 March 2011. 74. http://www.pointcarbon.com/news/1.1522877 Access date 31 March 2011. 75. DIRECTIVE 2008/101/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 19 November 2008 amending Directive 2003/87/EC so as to include aviation activities in the scheme for greenhouse gas emission allowance trading within the Community. Where a third country adopts measures for reducing the climate change impact of flights departing from that country which land in the Community, the Commission, after consulting with that third country, and with Member States shall consider options available in order to provide for optimal interaction between the Community scheme and that country’s measures. Where necessary, the Commission may adopt amend- ments to provide for flights arriving from the third country concerned to be excluded from the aviation activities in the EU ETS. http://eur-lex. europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:008:0003:0021:EN:PDF Access date 07 April 2011. State and Trends of the Carbon Market 2010 | 27 Issue Comment Table 5. Aviation Timing 2012: Inclusion of all flights arriving at and departing from EU airports Directive Level of emissions cap 2012: 97 percent of average 2004–06 emissions Summary 2013: 95 percent of 2004–06 emissions Auctioning 2012: 15 percent auctioning 2013: The volume to be auctioned over 2013–20 is already set to 15 percent per year, but may be revised. Free allocation criteria Great circle distance plus 95 km (fixed). Operators may choose to apply (i) actual weight, (ii) standard weight, or (iii) default passenger weight of 100 kg. Special reserve Creation of a reserve for new entrants and fast-growing airlines from within the cap. Three percent of the total capped allowances for that phase. Allocated to new operators and those whose activity data shows an increase of more than 18 percent per annum. A new type of allowances not Open trading scheme, but with the removal of the clause that allows convertibility backed anymore with AAUs will between Assigned Amounts Units (AAUs) and EU Allowance Units (EUAs)76 be created in 2012 to be al- 2012: 15 percent access to CERs and ERUs located/auctioned to airline opera- 2012+: to be confirmed as part of ETS review negotiations tors. Access to Certified Emission Reductions (CERs) and Emission Reduction Units (ERUs) Notable exemptions. Weight – certified 5.7t maximum take-off mass threshold A full list is available on the Heads of State exemption restricted to non-EU European Commission Web site Exemption for Public Service Obligations where they are either on specific routes between outermost regions or where capacity offered does not exceed 30,000 seats per year Activity threshold exemption for commercial air operators who operate at a frequency lower than 243 flights per period into, out of, or within the EU for three consecutive four-month periods, or with an emissions threshold of less than 10,000 tCO2 a year Effort Sharing The level of effort varies between EU Member States depending on their relative wealth (GDP/capita). The “Effort Sharing Decision” establishes annual At the EU level, this will deliver an approximate 10 binding GHG emission targets for Member States percent reduction of emissions from the uncovered for emissions not included in the EU ETS for the sectors in 2020 compared with 2005 levels. The ef- 2013–20 period. It is the responsibility of Member fort-sharing targets vary by EU Member State, with States to define and implement policies and mea- the greatest decreases being required for Denmark, sures to limit emissions of non-EU ETS covered Ireland, and Luxembourg, and with the greatest in- sectors under the Effort Sharing Decision. As a result creases allowed in Bulgaria, Latvia, and Romania.78 EU Member States are likely to implement comple- Cost-control measures include allowing Member mentary measures in such areas as transport, build- States to transfer part of their annual emission alloca- ings, agriculture, and waste (see Table 6).77 tion to other EU Member States as well as the use of credits from Joint Implementation (JI) and CDM. 76. Pers Comm. cdc climat. EUAs can be used for compliance by airline operators, whereas allowances from the Aviation Trading Scheme (ATS) cannot be used for compliance in the EU ETS. 77. DECISION No 406/2009/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 April 2009 on the effort of Mem- ber States to reduce their greenhouse gas emissions to meet the Community’s greenhouse gas emission reduction commitments up to 2020. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0136:0148:EN:PDF Access date 23 March 2011. 78. http://ec.europa.eu/clima/documentation/effort/docs/targets2020.pdf Access date 4 April 2011. 28 | State and Trends of the Carbon Market 2010 Table 6. Some Measure Comment Examples of U.K. Complementary Vehicle Emissions Tax79 Vehicle tax based on emissions measured in grams per kilometer (g/km) driven. Measures Climate Change Levy80 The levy is chargeable on the industrial and commercial supply of taxable commodi- ties for lighting, heating and power by consumers in the following sectors of busi- ness: industry, commerce, agriculture, public administration, and other services. Renewable Energy Feed-in Tariffs81 Incentivizes small-scale (less than 5 MW), low-carbon electricity generation. 82 Renewable Heat Incentive Incentivizes generation of heat from renewable sources at all scales (expected launch June 2011). Member States that have to reduce their non-ETS The government of Japan considers the ETS com- emissions, or are allowed to increase them by up to ponent an important policy measure for Japan to 5 percent of 2005 emissions, may use an additional achieve its announced target of reducing GHG 1 percent of CDM and JI credits. These credits can emissions by 25 percent by 2020 compared to 1990 come only from CDM projects in least developed levels. This reduction is premised on the establish- countries and small-island developing states; they ment of a fair and effective international agreement are nonbankable and nontransferable, and they are covering all major economies. available only to Member States meeting at least one of the following four conditions:83 In the absence of such an agreement, it appears unlikely that Japan will make a unilateral 25 percent cut. As a consequence of these factors, the Diet has deferred dis- concerned is higher than or equal to 0.7 percent of cussion of the ETS component of the Basic Act. The GDP according to the EC’s impact assessment. current state of policy is summarized in Table 7. - cording to the EC’s impact assessment, as a result Despite the deferral of the ETS, other components of setting targets on the basis of the GDP per of the Basic Act (introducing a carbon tax and estab- capita instead of the basis of cost-efficiency. lishing a feed-in tariff for all renewable energy sourc- es) may pass in 2011. These measures are expected to emissions covered by the Effort Sharing Decision be needed for Japan to meet its yet undecided unilat- are transport-related. eral emission reduction goal. excess of 30 percent. The passage of these measures through the Diet is also supported by Japan’s energy plan. The measures Further details on the EU ETS can be found in introduce an anti-global warming tax on oil, coal, Sections 3, 4, and 5. and natural gas, as well as a feed-in tariff that sup- ports the goal of increasing domestic energy genera- Japan—Reviewing the Target tion from renewable sources of up to 10 percent of total primary energy supply by 2020. In March 2010, the government of Japan introduced the “Basic Act on Global Warming Countermeasures.” The Japanese government also views access to in- The ETS component of the Basic Act has met with ternational offsets as an important contribution to strong opposition, which has strengthened with rising Japanese emission reduction efforts. As an agreement concerns about costs to the economy and a lack of on the post-2012 regime has yet to be achieved, it is extensive consultations with industry groups. currently unclear how Japan will access offset markets; 79. http://www.vcacarfueldata.org.uk/ Access date 03 February 2011. 80. An introduction to the U.K.’s Climate Change Levy (CCL). http://customs.hmrc.gov.uk/ Access date 4 February 2011. 81. http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/renewable/feedin_tariff/feedin_tariff.aspx Access date 4 February 2011. 82. A summary of the U.K.’s Renewable Heat Incentive (RHI) Scheme. http://www.decc.gov.uk/renewable_heat/incentive.aspx Access 4 Feb 2011. 83. From Questions and Answers on the Effort Sharing Decision. http://ec.europa.eu/clima/faq/effort/index_en.htm Access date 4 April 2011. State and Trends of the Carbon Market 2010 | 29 Policy Jurisdiction Details Table 7. Current Climate Change Emissions Trading Japan On March 12, 2010, the government of Japan proposed the “Basic Act on Policies in Japan Scheme (deferred) Global Warming Countermeasures,” an overall climate change policy frame- work that includes introducing an ETS. Feed-in Tariffs Japan Feed-in tariff for all renewable energy sources with the goal of increasing domestic energy generation from renewable sources to 10 percent of total primary energy supply by 2020. Anti-global Warming Japan Anti-global warming tax is proposed as add-on to existing taxes covering Measure Tax wide range of fuels, of which rates are proportional to CO2 emission. Voluntary 715 715 organizations had applied to participate, of which 521 supplied targets Experimental organizations (as of July 2009).The trial scheme aims to bring together several existing Integrated ETS initiatives, such as the Keidanren Voluntary Action Plan, plans for a domes- tic offsets scheme, and the Japan-Voluntary Emissions Trading Scheme (J-VETS), which targets smaller emitters. Tokyo Emissions Tokyo The Tokyo metropolitan area launched its own mandatory cap-and-trade Trading Scheme scheme on April 1, 2010, which targets office and commercial buildings (in- (Cap-and-Trade) cluding universities) and factories. The scheme covers approximately 1,400 installations and 1 percent of the country’s emissions. Saitama Prefecture Saitama Starting April 1, 2011, Saitama, the fifth largest prefecture in Japan, will be- Trading Scheme Prefecture come the second Japanese prefecture to implement a mandatory emissions (Cap-and-Trade) trading scheme. Saitama and Tokyo signed a pact to link their cap-and-trade schemes in the future. it may develop a bilateral offset scheme.84 The recent whether the ETS is functioning efficiently and effec- earthquake and tsunami and associated nuclear safety tively. Recommendations from the review process will concerns may cause the Japanese government to re- be forwarded to the Minister for Climate Change by consider its energy plans and climate change policies September 2011.The scope of the review includes the (for more details see Section 5.1.1). following: coverage of agriculture, allocation mecha- nisms for New Zealand Units (NZUs), whether or New Zealand—Under Review not to keep the fixed-price cap of NZ$25 and the one-for-two obligation for emitters, and whether In November 2002, the New Zealand Parliament synthetic greenhouse gases should be included in the passed the Climate Change Reponses Act 2002.85 The ETS. The review also examines the impact of the ETS act was subsequently amended in September 2008, on investment and operational decisions.87 introducing the greenhouse gas Emissions Trading Scheme (NZ ETS), which retrospectively covers forest- Over the past year, the New Zealand market for ry from January 2008. In November 2008, the newly NZUs has remained relatively flat. The market has elected government suspended, except for forestry op- traded between NZ$17 (€9.34) and NZ$22 (€12.1) erations, the NZ ETS, and launched a review of the and tends to follow the CER price at around a 10 country’s climate change policy. A further amended to 15 percent discount, which reflects the fact that scheme came into existence in November 2009.86 NZUs are subject to a price cap of NZ$25 and cannot be sold to companies participating in the EU ETS. During 2010, the NZ ETS was expanded to cover fuels and industry. In early 2011, a review of the NZ Demand in the NZ ETS mainly stems from local ETS commenced, as required by Climate Change utilities, local industry, and fuel companies, with a Response Act 2002. The review seeks to highlight few transactions from government buyers. In terms 84. “Japan confirms bilateral offsets support.” Point Carbon http://www.pointcarbon.com/news/1.1466069 Access date 15 April 2011. 85. http://www.legislation.govt.nz/act/public/2002/0040/latest/DLM158584.html Access date 17 March 2011. 86. http://www.legislation.govt.nz/act/public/2009/0057/latest/DLM2381636.html Access date 15 April 2011. 87. http://www.climatechange.govt.nz/emissions-trading-scheme/ets-review-2011/issues-statement.pdf Access date 19 March 2011. 30 | State and Trends of the Carbon Market 2010 of supply, however, it appears that a large percentage (see Table 9 for a summary of state and regional cli- of the allocations of NZUs are not coming to mar- mate change policies). ket as fast as envisioned, thus increasing the market price. An expected surplus of supply for NZUs has California so far failed to materialize.88 California continues to champion market-based mea- Russian Federation—The Bear Awakes sures in the United States through the Global Warming Solutions Act of 2006 Assembly Bill 32 (AB 32). AB Russia, as part of the Copenhagen accord, has com- 32 requires California to cut greenhouse gas emissions mitted to reductions of between 15 and 25 percent on to 1990 levels by 2020. It also identifies a cap-and- 1990 levels by 2020. These reductions are predicated trade program as one of the strategies the state will em- on the inclusion of forestry in Russia’s efforts to meet ploy to reduce GHG emissions. As part of the public its anthropogenic emission reductions and its success consultation process on the proposed cap-and-trade in imposing binding obligations on major emitters.89 plan, the California Air Resources Board (CARB) Russia also continues to be active in the JI market held a rule-making meeting in December 2010 and through the generation of Emission Reduction Units approved resolution 10–24 outlining elements of the (ERUs). For further details see Section 4.1.2. program. The regulation is not expected to be finalized until fall 2011 (September–November). United States and North America —It is all about California As a cost-control measure, AB 32 allows entities cov- ered by the scheme to purchase and use offsets for com- Uncertainty in U.S. climate policy continues as new pliance purposes, but volumes are limited to 8 percent legislators and administrators at the U.S. state and fed- of annual emissions. Offsets will come from a domestic eral levels reevaluate previous climate policy positions, offsets program with the possibility of importing inter- affecting market sentiment and investment decisions. national forest offsets (see Section 4.4.1.1).93 California There appears to be bipartisan congressional support for also has a strong renewable energy mandate and a re- a two-year suspension of the EPA’s authority to regulate quirement that the carbon content of the state’s vehicle GHG emissions under the Clean Air Act (CAA).90 fuels be cut by 10 percent by 2020.94 In the President’s address on the State of the Union During 2010, opponents of AB 32 supported 2011, a Federal Clean Energy Standard was made Proposition 23 with the aim of suspending AB 32. The an aspiration for the new Congress. Early reports Proposition 23 was defeated, but a related California suggest possible Senate support for a Clean Energy ballot, Proposition 26, was passed. Proposition 26 re- Standard that includes coal carbon capture and stor- quires certain state and local fees be approved by a age (CCS), natural gas, nuclear energy, and renew- two-thirds vote. Fees include those that address ad- able energy sources such as wind, geothermal, and verse impacts on society or the environment caused solar.91 At this time, House support is unclear.92 by the fee-payer’s business. Proposition 26 expands the definition of a tax under California law and some This means that approaches centered on California legal opinion speculates that it may affect the imple- will drive the carbon market landscape in the United mentation of AB 32.95 Nonetheless, advice from the States and North America for the foreseeable future State Attorney General’s office argues that Proposition 88. This section benefited from a Pers. Comm., with John O’Brien, Carbon Market Solution. 89. http://unfccc.int/files/meetings/cop_15/copenhagen_accord/application/pdf/russiacphaccord_app1engl.pdf Access date 10 April 2011. 90. There is a House bill to amend the Clean Air Act to prohibit the Administrator of the Environmental Protection Agency from promulgating any regulation concerning, taking action relating to, or taking into consideration the emission of a greenhouse gas to address climate change, and for other purposes. http://www.gpo.gov/fdsys/pkg/BILLS-112hr910rfs/pdf/BILLS-112hr910rfs.pdf Access date 15 April 2011. 91. http://www.reuters.com/article/2011/01/31/us-usa-bingaman-nuclear-idUSTRE70U64Z20110131 Access date 17 March 2011. 92. http://upton.house.gov/News/DocumentSingle.aspx?DocumentID=229488 Access date 17 March 2011. 93. http://www.arb.ca.gov/newsrel/newsrelease.php?id=170 Access date 11 March 2011. 94. http://www.arb.ca.gov/cc/ab32/ab32.htm Access date 4 Feb 2011. 95. http://cdn.law.ucla.edu/SiteCollectionDocuments/EnvironmentalLaw/PayingforPollution.pdf Access date 11 Feb 2011. State and Trends of the Carbon Market 2010 | 31 BOX 2. North American Offset Prices North American Offset Prices: 2010–11 As Proposition 23 was voted down in November and the market gained confidence in the California cap- In 2010, the expectations of the North American and-trade scheme, the price for CRTs from U.S. forest- carbon market refocused from federal legislation to ry, livestock methane, and ODS projects converged California’s cap-and-trade. Between January and into one “CARB eligible CRT” price at an average of July, prices for offset credits in the United States $7.00/t, jumping approximately 40% by January to an were driven by the signals from federal legislation average of $9.75/t. In February and March 2011, on of whether the credit was likely to be eligible for an the back of the court case of “Association of Irritated anticipated federal cap-and-trade program. Between Residents v CARB” and market’s concern with the August and October, the market was mostly illiquid, invalidation of CRT prices were once again down by but in November it was reawakened by the release of approximately 17% to average of $8.10/t. CARB eli- California’s cap-and-trade regulation. gible CRT prices are expected to stay at this level until further developments in the court case. The Climate Reserve Tonnes (CRTs) issued by the Climate Action Reserve (CAR) were the first choice Will there be enough supply for for sourcing early action credits in the federal bills California’s cap-and-trade? that came through the 111th Congress, including the Waxman-Markey climate bill that passed the House In December 2010, CARB approved four U.S. based of Representatives in the summer of 2010. Average project types—urban forestry, forestry, livestock meth- prices lingered from January 2010 to July 2010 at ane, and ODS—to generate offsets for California’s cap- $5.90/t for national forestry vintage 2009 CRTs, at and-trade system. In order to ensure supply of offsets $3.50/t for landfill gas vintage 2009 CRTs, and at at the start of the program in 2012, the legislation al- $4.20/t for V11-12 CRT forwards from ozone deplet- lows early supply of CRTs from the above listed project ing substance (ODS) projects. types with vintages 2005–14, as long as the project started prior to 2012. Offsets from jurisdictions under However, CRTs from forestry projects located in the Western Climate Initiative may also be accepted, California went for an average of $6.90/t and held but Certified Emission Reductions (CERs) from the steady throughout the year to be knocked down to Clean Development Mechanism (CDM) are not eligible. an average of $5.50/t for a brief time in October on the back of fears that Proposition 23 could have pre- CARB’s regulations suggest a cumulative demand of vented the California cap-and-trade program from 233 million tonnes of offsets from 2012 to 2020, or moving forward. The California forestry CRTs carried 8.7% of the total cap. To forecast supply, Thomson a premium over other project types as those were Reuters Point Carbon included projections from four thought to be most likely to be eligible in a then loom- project types CARB has approved. The projections also ing California cap-and-trade scheme. included REDD supply from Acre, Brazil and Chiapas, Mexico, and from U.S. based agricultural sequestra- Various iterations of federal legislation did not give the tion (cropland management and nutrient management), Verified Carbon Units (VCUs) from the Verified Carbon protocols for which CARB is likely to consider next for Standard (VCS) as much hope for early action accep- inclusion. The supply estimates show that there will not tance as for CRTs. As a result, the average VCU price be enough offsets to meet the maximum theoretical de- was at $2.40/t from January through July, dropping to mand in any of the scheme’s 3 phases, resulting in a cu- an average of $1.50/t for the remainder of the year as mulative offset shortage of 68Mt, as shown in Table 8. the market lost confidence in federal legislation. Table 8. Offset Years Supply (Mt) Demand (Mt) Shortage (Mt) Supply and 2012–14 38 42 (4) Demand 2015–17 52 100 (48) Forecast for California’s 2018–20 75 91 (16) Cap-and-trade Source: Thomson Reuter’s Point Carbon’s Carbon Market Analyst, A price forecast for California: Gauging Uncertainty, February 2011. Kindly provided by Olga N. Chistyakova, Senior Analyst, Point Carbon 32 | State and Trends of the Carbon Market 2010 Table 9. Current Policy Jurisdiction Details U.S. State and Regional AB 32 Cap-and-Trade96 California Cap-and-trade scheme to start in 2012. Climate Change AB 32 Renewable California Regulation requiring a 33 percent renewable energy target by 2020. Policy in North Electricity Standard97 America Renewable Portfolio Various U.S. states A renewable portfolio standard is a state policy that requires elec- Standards98 tricity providers to obtain a minimum percentage of their power from renewable energy resources by a certain date. Midwestern Six midwestern states MGGRA appears no longer functional with cap-and-trade off the Greenhouse Gas and one Canadian agenda. The Midwestern Governors Association is now primary fo- Reduction Accord99 province cused on energy efficiency, renewable electricity, and advanced coal (MGGRA) with carbon capture, as well as on bioeconomy and transportation. Regional Greenhouse 10 northeastern and mid- Cap-and-trade program reducing CO2 (only) emissions from the Gas Initiative (RGGI)100 Atlantic states power sector 10 percent by 2018. Western Climate Western and midwestern Currently it appears that California, British Columbia, Quebec, Initiative (WCI)101 U.S. states, and some and Ontario may be ready for trading in the WCI from 2012. Canadian provinces 26 is not applicable to AB 32.102 Some market ana- appears to be restricted to the West Coast of the lysts consulted by the authors share the same view. United States and several Canadian provinces. At the time of writing, a long-standing legal action On June 30, 2010, Arizona withdrew from the brought by the Association of Irritated Residents WCI’s planned January 2012 implementation of a against the CARB has been successful. The Superior regional cap-and-trade emissions trading scheme, Court of California ruled that CARB failed to prop- citing the economic downturn.106 Continued par- erly consider alternatives to the cap-and-trade pro- ticipation by Utah is also uncertain; its legislature gram contained in AB 32.103 Media reports suggest passed a resolution to withdraw from the WCI.107 that this ruling has the potential to delay the start Some news reports suggest that Montana is also hav- date of the cap-and-trade program.104 ing trouble with cap-and-trade and may be unlikely to have legislation in place before WCI’s proposed Western Climate Initiative start in January 2012.108 Cap-and-trade also appears in doubt in New Mexico, with the state executive California is the leading member of the Western terminating the employment of all members of the Climate Initiative (WCI), which aims to reduce re- Environmental Improvement Board that passed cap- gional GHG emissions to 15 percent below 2005 and-trade regulations.109 levels by 2020.105 However, the future of WCI 96. http://www.arb.ca.gov/cc/capandtrade/capandtrade.htm Access date 07 February 2011. 97. http://www.arb.ca.gov/energy/res/res.htm Access date 07 February 2011. 98. http://apps1.eere.energy.gov/states/maps/renewable_portfolio_states.cfm Access date 07 February 2011. 99. http://www.midwesterngovernors.org/Energy.htm Access date 08 February 2011. 100. http://www.rggi.org/home Access date 07 February 2011. 101. http://www.westernclimateinitiative.org/ Access date 07 February 2011. 102. Response from California Air Resources Board Chairman to a floor question at the IETA Carbon Forum, 14-15 March 2011, Washington, DC. http://www.ietacarbonforum.com/2011/. 103. http://webaccess.sftc.org/Scripts/Magic94/mgrqispi94.dll?APPNAME=IJS&PRGNAME=ROA22&ARGUMENTS=- ACPF09509562 Access date 24 March. 104. http://www.pointcarbon.com/research/marketsoverview/1.1520265 Access date 29 March 2011. 105. http://www.westernclimateinitiative.org/ Access date 12 March 2011. 106. http://www.azsos.gov/aar/2010/31/governor.pdf Access date 11 March 2011. 107. http://le.utah.gov/~2010/bills/hbillenr/HJR021.pdf Access date 12 Feb 2011. 108. http://billingsgazette.com/news/state-and-regional/montana/articled2433252-9c10-11df-958a-001cc4c002e0.html Access date 12 March 2011. 109. http://www.governor.state.nm.us/uploads/FileLinks/20e5f2e740f34a2297a940e2bacdfcce/010411_02.pdf Access date 18 March 2011. State and Trends of the Carbon Market 2010 | 33 Washington and Oregon are expected to join Figure 3. RGGI annual emissions vs. cap (MtCO2e) California in emissions trading through the WCI, RGGI but they will not be ready for trading in 2012.110 Forecast Emissions At the level of Canadian provinces, British Columbia, Ontario, and Quebec have passed cap-and-trade legislation; they are positioned to join California in early regional emissions trad- ing through the WCI. Manitoba does not yet have the legislative authority it needs to join in emissions trading through the WCI. Alberta and Saskatchewan are both taking individual actions— outside the WCI—to limit GHG emissions. Regional Greenhouse Gas Initiative Emissions forecast Cap The other major regional initiative operating in the Source: Thomson Reuters Point Carbon United States is the Regional Greenhouse Gas Initiative (RGGI). It is a mandatory cap-and-trade CO2-only- reduction program covering ten northeastern and mid-Atlantic states that aims to reduce CO2 emis- success of Bill 519 will cause other states to consider sions from the power sector by 10 percent by 2018.111 withdrawing from RGGI and possibly delay any re- RGGI continues to have overallocation problems. The view of the cap.115 cap exceeded emissions by about 50 percent in 2009. Although at lower levels (about 15 percent), overal- location is expected until 2018 (see Figure 3).112 In 2.2 NON-ANNEX I COUNTRIES addition, the lack of momentum at federal level fully offset in 2010 the growth of this market segment in the Brazil—Making Commitments previous year, which had strongly benefited from the expectation of an imminent federal legislation. On December 29, 2009, the Brazilian Parliament ad- opted Law 12.187. The law establishes the National The future of RGGI is unclear. The New Hampshire Climate Change Policy (NCCP) of Brazil and sets a legislature recently passed House Bill 519, which voluntary national greenhouse gas reduction target of repeals the state’s participation in RGGI.113 Media between 36.1 and 38.9 percent of projected emissions analysis suggests that the New Hampshire legislature by 2020. On October 26, 2010, the government pub- has enough votes to enact the bill into law should lished an executive summary of the sectoral mitigation the governor veto it.114 There is speculation that the plans to implement its voluntary commitment.116 110. http://www.pointcarbon.com/polopoly_fs/1.1512601!Carbon%202011_web.pdf Access date 17 March 2011. 111. http://www.rggi.org/home Access date 12 March 2011. 112. http://www.pointcarbon.com/research/northamerica/rggi/ Access date 17 March 2011. 113. http://www.gencourt.state.nh.us/bill_Status/results.aspx?lsr=475&sortoption=&txtsessionyear=2011&txtbillnumber=hb519 Access date 17 March 2011. 114. http://www.boston.com/news/local/new_hampshire/articles/2010/11/03/nh_gop_tally_5_sen_almost_300_house_seats/ Access date 17 March 2011. 115. RGGI market view - http://www.pointcarbon.com/research/northamerica/rggi/ Access date 17 March 2011. 116. Beyond official and voluntary commitments, a number of studies have investigated the potential of emissions reductions in Brazil in coming decades: levels and would require an average incremental investment of $18.5 billion per year and an average volume of incentive of $21billion per year to turn the low-carbon options attractive. de Gouvello et al., World Bank, 2010 http://go.worldbank. org/53EVFQYOG0 Access date 6 April 2011. than 18,000 potential low-carbon investment to implement systematically 61 different kinds of technologies, corresponding to cumulative emissions reduction potential of 455 MtCO2e per year. 34 | State and Trends of the Carbon Market 2010 Among other instruments, the NCCP law considers in These policy choices are driven by China’s need to article 9 the creation of a Brazilian Emission Reductions reduce emissions to avoid the negative impacts of cli- Market (BERM) to achieve the voluntary emission re- mate change on its population, to promote energy se- duction target. It will be operationalized by Brazilian curity, and to reduce emissions of health-threatening stock exchanges and the Securities Commission. pollutants such as sulfur dioxide (SO2), nitrous oxides (NOX), and particulates. As part of the 12th Five-Year As a signatory of the Copenhagen Accord, Brazil Plan China will increase forest cover by 12.5 million detailed this voluntary commitment in an offi- hectares by 2015, improve GHG emissions and ener- cial communication on NAMAs to the UNFCCC gy monitoring systems, promote energy efficiency in Secretariat as follows: industrial plants and buildings, support the expansion of public rail transport infrastructure, and continue the development of nonfossil fuel energy sources.120 Region and the Cerrado (minus 668 MtCO2e/ year in 2020); degraded pastures recovery (minus China continues to support emissions trading and 83 to 104 MtCO2e/year in 2020); reduction of Kyoto Protocol flexibility mechanisms, and has es- livestock emissions (minus 22 MtCO2e/year in tablished a number of environment and energy 2020); zero tillage (minus 20 MtCO2e/year in exchanges to provide infrastructure for trading in 2020); biological fixing of N2 (minus 16 to 22 CERs and Voluntary Emission Reductions (VERs). MtCO2e/year in 2020). As of December 2010 the National Development and Reform Commission (NDRC) had approved ap- 15 MtCO2e/year in 2020); use of bio-fuels (mi- proximately 2,850 Clean Development Mechanism nus 28 to 60 MtCO2e/year in 2020); increase (CDM) projects. of hydropower generation (minus 79 to 99 MtCO2e/year in 2020). Of these projects more than 1,000 have been success- - fully registered at the CDM Executive Board. China coal by planted forest–based charcoal in the steel has contributed 42 percent of the overall number industry (minus 12 to 15 MtCO2e/year in 2020). of globally registered CDM projects, with expected annual certified emission reductions of about 240 China—Going Green MtCO2e, or 62 percent of total global emission re- ductions from the CDM. Table 10 outlines the cur- In recognition of its changing economic and geopo- rent trading market and products covered. litical role, China released in March 2011 its 12th Five-Year Plan of National Economic and Social China may introduce an emissions trading scheme Development. It sets a carbon-intensity reduction tar- in six regions in 2013 and this may be expanded to a get (CO2 emissions per unit GDP) of 17 percent and national scheme by 2015.121 aims to cut energy intensity117 by 16 percent by 2015. These targets are consistent with the 40 to 45 percent India—Setting Itself a Target reduction in carbon intensity from 2005 levels that was first announced at the Copenhagen Conference India’s per capita CO2 emissions are expected to and reaffirmed at the Cancun Conference.118,119 grow from 1.1 ton in 2001 to 3–5 tons in 2030.122 In 2008, India launched the National Action Plan on Climate Change, which involves the establishment 117. CO2 emissions per unit of GDP. 118. http://www.theclimategroup.org/_assets/files/China-Five-Year-Plan-EXECUTIVE-SUMMARY.pdf Access date 17 March 2011. 119. http://www.wri.org/stories/2011/03/how-does-chinas-12th-five-year-plan-address-energy-and-environment Access date 18 March 2011. 120. http://pdf.wri.org/testimony/seligsohn_testimony_energy_and_commerce_2011-04-04.pdf Access date 10 April 2011. 121. The Panda Standard is a quality standard for Chinese voluntary emission reduction projects within agriculture and forestry. The standard is being developed by the China Beijing Environmental Exchange (CBEEX) and Paris-based carbon exchange Bluenext. The first deal of Panda Standard credit—China’s pilot domestic carbon standard—was announced on March 29, 2011. A major market participant purchased 16,800 t at $9.14 per ton. The project is the Bamboo reforestation developed under the AFD-FFEM Yunnan Rural Project. 122. India’s GHG Emissions Profile: Results of Five Climate Modeling Studies, Ministry of Environment & Forest. State and Trends of the Carbon Market 2010 | 35 China Beijing Environment Tianjin Climate Exchange Shanghai Environment Table 10. Exchange Energy Exchange Current Trading Platforms in (CBEEX) (TCX) (SEEE) China123 Web site http://www.cbeex.com.cn http://www.chinatcx.com.cn http://www.cneeex.com Location Beijing Tianjin Shanghai Date of 08/05/2008 09/25/2008 08/05/2008 Establishment Shareholders -China Beijing Equity Exchange -National Petroleum Corporation Sole owner: Shanghai (CBEX, 40 percent) Assets Management Co. United Assets and Equity -CNOOC New Energy (CNPCAM, 53 percent), Exchange (SUAEE) Investment Co., Ltd. (20 percent) -Tianjin Property Rights Exchange -China Guodian Corp. (20 percent) (TPRE, 22 percent), -China Everbright Investment -Chicago Climate Exchange (CCX, Management Corp. (20 percent) 25 percent). Common Information and service center for CDM projects Functions Environmental property rights trading, mainly SO2 and COD Energy Management/Performance contract and green technologies transfers Domestic VERs transactions Key Focus Panda Standard: China’s pilot Chinese companies joint action of Voluntary emission reduc- Activities domestic carbon standard—first voluntary emission reduction tion platform for the World project announced in Cancun124 Expo China Carbon Neutral Alliance Pilot intensity-cap trading scheme China voluntary reduction on heat suppliers of residential standard (still nothing as of buildings (no further announce- March 2011) ment as of March 2011) of eight programs—known as missions—on solar energy-intensive large industries and facilities. The technology, energy efficiency, sustainable habitat, energy saving certificates generated can be traded. water, Himalayan ecosystem, green India, agricul- ture, and strategic knowledge. Approved in 2010, the mission on sustainable habi- tats aims to make cities sustainable by improving en- The solar mission, approved in 2009, is expected to ergy efficiency in buildings and solid waste manage- enable setting up of 200 MW of off-grid solar power ment, and encouraging a shift to public transport. and cover 7 million square meters with solar collec- tors in its first phase from 2010–13. It has set a vol- In 2011, India submitted its voluntary emission re- untary target of 20,000 MW by 2022. duction objective under the Copenhagen Accord, a voluntary target of reducing emissions intensity of The energy efficiency mission, approved in 2010, its GDP by 20–25 percent by 2020 in comparison is expected to achieve total avoided capacity addi- to the 2005 level. tion of 19,598 MW, representing fuel savings of around 23 million tons per year and greenhouse Mexico—Looking for Options gas emission reductions of 98.55 million tons per year, over the next four years. This mission in- Mexico has submitted three National cludes a market-based mechanism—the Perform Communications to the UNFCCC. The First Achieve and Trade—to enhance cost effectiveness National Communication (1997) established the of meeting energy efficiency improvement targets in national greenhouse gas inventory and reported 123. Personal communication from Bluenext. http://www.bluenext.eu/. 124. Point Carbon, based on comment from the NRDC, reports that China wants to launch markets in Beijing, Chongqing, Guangdong, Hubei, Shanghai, and Tianjin in 2013, National Development and Reform Commission (NDRC). Carbon Market Daily. 11 April 2011. 36 | State and Trends of the Carbon Market 2010 the first studies on Mexico’s vulnerability to climate cap GHG emissions for 1,564 sites that collectively change. Mexico is currently preparing its Fourth emit more than 442 MtCO2e a year.129 National Communication. Recognizing the mul- tisectoral challenges posed by climate change, South Africa—Committed to Reducing in April 2005 Mexico established the Comisión Emissions Intersecretarial de Cambio Climático (CICC) (Intersecretarial Commission on Climate Change). South Africa, as part of the Copenhagen accord, has The CICC’s key mandates include formulating and made a non-binding commitment to reduce GHG coordinating national climate change strategies and emission by 34 percent below its business-as-usual incorporating them into sectoral programs. The emissions trajectory by 2020. South Africa further CICC contains several working groups, including plans to reduce emissions by 42 percent below its groups on mitigation and adaptation. Associated business-as-usual emissions trajectory by 2025. This with the CICC is an advisory board on climate commitment is contingent on financing, technol- change, which creates a link between the CICC, ogy, and capacity-building support.130 the scientific community, and civil society.125 It has been reported that South Africa is contem- A voluntary program for GHG accounting and re- plating the introduction of a carbon tax as a policy porting (Program GEI) covered 98 companies in measure to support its emission reduction target, 2009 accounting for 21 percent of national emis- rather than a cap-and-trade scheme. South Africa’s sions. In the next two years the coverage will be ex- actions toward low-carbon growth will become more panded to 80 percent of national emissions. Sectoral visible in 2011, as the country will host the next crediting is expected to complement CDM. Conference of the Parties of the Kyoto Protocol, to be held in Durban in December 2011. Republic of Korea—Two Steps Forward One Step Back 2.3 LINKING EMISSIONS TRADING During 2010, the Republic of Korea enacted its SCHEMES Framework Act on Low Carbon, Green Growth.126 This act establishes a legal framework for setting GHG Linking emissions trading schemes is a complex is- and energy reduction targets and provides for GHG sue that has attracted attention because of the po- emissions reporting. It also establishes the right to tential for reducing costs and enhancing market li- implement a cap-and-trade scheme for the purposes quidity.131 Different forms of linking are available, of reducing GHG emissions and sets up fuel use and including the following: GHG emission standards for automobiles. The act has met resistance from industry groups concerned about - the cost implications of cap-and-trade policies.127 tion of allowances in each emissions trading scheme being linked and would involve trading allowances Consequently, the implementation of the cap-and- between the schemes (import and export). trade scheme originally planned for commence- ment in 2013 has been postponed until 2015.128 mutually recognized standard unit. Most trading Regardless, the Republic of Korea is continuing with schemes indirectly link though CERs. its GHG Target Management System, which will require companies to meet energy-saving and green- Linking issues typically cover compatibility in the house gas reduction targets. The system is believed to level of effort or ambition; use of offsets; monitoring, 125. World Bank, Low-Carbon Development for Mexico. 2010. 126. http://www.moleg.go.kr/english/korLawEng;jsessionid=2XVAoj0GR5al5jBzbf231tBLR5sfblXWqUKrdjsnkPDpRoPPZWg4k7g10127 dywk?pstSeq=52136 Access date 22 March 2011. 127. http://af.reuters.com/article/metalsNews/idAFL3E7CO0CK20110124 Access date 22 March 2011. 128. http://www.pointcarbon.com/news/1.1519474 Access date 22 March 2011. 129. http://af.reuters.com/article/metalsNews/idAFL3E7CO0CK20110124 Access date 22 March 2011. 130. http://unfccc.int/files/meetings/cop_15/copenhagen_accord/application/pdf/southafricacphaccord_app2.pdf Access date 26 April 2011. 131. http://www.oecd-ilibrary.org/environment/towards-global-carbon-pricing_5km975t0cfr8-en Access date 22 March 2011. State and Trends of the Carbon Market 2010 | 37 reporting and verification (MRV) standards;132 and 2.4 CONCLUSIONS price caps. For example, the proposed U.S. Waxman- Markey bill (H.R. 2454: Sec 728)133 outlines provi- The national and regional mitigation measures sions for linking between the U.S. and foreign climate discussed in the preceding section support the in- change schemes run by national or supra-national creasingly common perspective among market par- governments. The criteria include the following: ticipants of the emergence of a fragmented carbon market.136 Some participants expressed the belief - that having several regulatory systems could be a lute tonnage limit on greenhouse gas emissions positive feature of fragmented markets, citing the (that is, cap-and-trade) benefits of fast (and flexible) local approval pro- cesses, high-degree of adaptability to specific needs, in the United States (that is, equivalent effort) and potentially, large local acceptability and in- creased level of engagement. The sentiment survey compliance, and enforcement (that is, similar presented in Section 1.4 supports the perspective MRV standards) that market participants view this as a workable sit- uation while the carbon market further evolves and and restrictions on the use of offsets matures through linking and acceptance of similar levels of ambition. The now shelved Australian Carbon Pollution Reduction Scheme (CPRS) contained price cap provi- The rate at which this will occur will depend on sions and allowance export limitations, which were im- many factors. In particular, it will depend on each posed partially because of the price cap. The rationale country’s willingness to work on and accept the fun- was if the international price moved above Australia’s gibility of allowances from other national or supra- price cap, Australian allowances would be exported and national schemes, which will be a consequence of entities with compliance obligations would access the compatibility in effort or ambition; use of offsets; price cap.134 This has two impacts: (1) abatement will monitoring, reporting and verification (MRV) stan- be less than otherwise would have occurred without the dards; and absence of price caps. Without fungible price cap, and (2) auction revenues will be lower than assets and open schemes, the fragmentation of the otherwise would have occurred without the price cap. carbon market will persist and the hoped for long- term carbon pricing signal—desired by some market Indirect linking through an offset scheme, such as participants—will not be achieved. the CDM, can provide an important cost contain- ment mechanism for developed countries with high Countries continue to adopt a range of policy measures cost abatement and offset import potential. The cre- to drive emission reductions. It is important in the ation of low-cost offsets through a scheme, such as overall design of mitigation policies for policy makers REDD+, offers import countries considerable op- to consider the interaction between different—market portunities for cost-effective abatement. The cost- and non-market—policy measures. A great deal can be containment opportunities justify the considerable learned from countries that have direct experience of work needed to develop offset schemes.135 these potentially complex interactions. 132. Linking separate schemes requires robust and transparent monitoring, reporting and verification (MRV) to ensure the environmental integrity of the different schemes and to build the trust needed among participants. Ideally uniform or at least compatible standards for MRV should be collectively adopted. 133. http://thomas.loc.gov/cgi-bin/query/z?c111:H.R.2454: Access date 23 March 2011. 134. http://www.climatechange.gov.au/publications/cprs/white-paper/~/media/publications/white-paper/V1011Chapter-pdf.ashx Access date 23 March 2011. 135. The cost-saving potential for developed countries of well-functioning crediting mechanisms appears to be very large. Even limited use of offsets would nearly halve mitigation costs; cost savings would be largest for carbon-intensive economies. However, one open issue is whether these gains can be fully reaped in reality, given that direct linking and the use of crediting mechanisms both raise complex system design and implementation issues. The analysis shows, however, that the potential gains to be reaped are so large that substantial efforts in this domain are warranted. http://www.oecd-ilibrary.org/environment/towards-global-carbon-pricing_5km975t0cfr8-en Access date 12 April 2011. 136. “Costs and financing of climate change policies: Negotiating a post-Kyoto regime requires the redefinition of the financial engagement of the different actors.” http://www.cdcclimat.com/IMG/pdf/16_Climat_Sphere_EN_Copenhagen_last_stop.pdf Access date 29 April 2011. 38 | State and Trends of the Carbon Market 2010 3 SECTION State and Trends of the Carbon Market 2010 | 39 3 How Market Participants Transact —Risk and Regulation THE ECONOMIC MALAISE resulting from the global financial crisis and the per- ceived excess risk taking in global financial centers have led many to question the effec- tiveness of market mechanisms. Yet, carbon markets can be one of the most important policy tools for cost-effectively reducing GHG emissions. However, obtaining politi- cal support from a skeptical public for market-based solutions in a period of economic slowdown is becoming ever more difficult. Robust and transparent regulations of these markets are vital for ensuring market and public confidence, which in turn supports the market’s ability to deliver cost-effective emission reductions. This section discusses the changing regulatory landscape, important regulatory approaches being used to control risk, and future regulatory developments. 3.1 THE CHANGING REGULATORY LANDSCAPE—THE IMPACT OF FINANCIAL MARKET REFORMS “ Robust and transparent regulations of these markets are vital for ensuring The recent and extensive turmoil in global finan- market and public confidence, which in cial markets has resulted in financial market regu- turn supports the market’s ability to deliver latory reforms. At the international level, the G20 have promoted financial market regulatory reform through the Financial Stability Board (FSB)137 and the Basel Committee.138 cost-effective emission reductions. ” At the domestic level, countries have initiated ma- background, the U.S. Commodities Future Trading jor financial market regulatory reforms; some ex- Commission (CFTC) released a report on carbon amples include the United States’ Dodd–Frank Wall market oversight.142 And after recent carbon market Street Reform and Consumer Protection Act,139 the irregularities in the European Union (see Box 3), the British government’s reforms to financial regula- European Commission has taken steps to improve the tion,140 and the French government’s Law on Banking functioning of the EU Emissions Trading Scheme. and Financial Regulation (LBFR).141 Against this 137. http://www.financialstabilityboard.org/index.htm Access date 25 Feb 2011. 138. http://www.bis.org/bcbs/ Access date 25 Feb 2011. 139. http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=111_cong_bills&docid=f:h4173enr.txt.pdf Access date 22 Feb 2011. 140. http://www.hm-treasury.gov.uk/consult_financial_regulation.htm Access date 22 Feb 2011. 141. http://www.legifrance.gouv.fr/rechTexte.do?reprise=true&page=1 Access date 22 Feb 2011. 142. http://www.cftc.gov/ucm/groups/public/@swaps/documents/file/dfstudy_carbon_011811.pdf Access date 15 March 2011. 40 | State and Trends of the Carbon Market 2010 BOX 3. Brief History of Carbon Market Fraud in addition, some EU Member States, most notably the EU ETS France, have implemented or are considering do- mestic carbon market regulatory reforms. The new French LBFR is important because it of- million worth of EU allowances leads to the closure of fers a carbon market regulatory reform model for national carbon registries, the suspension of spot trade, both other EU Member States and countries out- and the implementation of an EU-wide upgrade of registry side the EU who may be considering establishing security. emissions trading schemes. The LBFR, based on recommendations in the Prada review,145 provides ETS registry accounts in Romania results in the theft of 1.6 for oversight of the carbon market and its opera- million EUAs. tors through two regulators, Autorité des Marchés Financiers (AMF) and Commission de régulation virus Nimkey. de l’énergie (CRE).146 AMF and CRE have signed a memorandum of understanding on the exchange of been surrendered to it under the EU’s emissions trading information, control, and supervision of markets in scheme. In response, the EU amends the registry regula- greenhouse gas emission allowances, electricity, nat- tions to prevent CER recycling. ural gas, and their derivatives.147 The memorandum - of understanding is one of the LBRF’s applications sures for a consistent response to deal with VAT or carou- and it defines cooperation between AMF and CRE. sel fraud detected in the market in 2009–10. Under the memorandum of understanding, AMF is of EU ETS registries prompts the EU to revise Internet responsible for overseeing the operation of the mar- security guidelines. ket in allowances and their derivatives and CRE is responsible for supervision of transactions carried out in allowances by energy market participants. CRE is also responsible for analyzing the behavior of allowances in relation to the economic and technical factors underpinning energy markets. The memo- randum of understanding anticipates provisions in the draft European Regulation on Energy Markets Integrity and Transparency (REMIT).148 The EU Commission reform initiatives include a communication on carbon market oversight, which An additional factor behind France’s carbon market aims to ensure that the EU Emissions Trading Scheme regulatory reforms appears to be the EU Auctioning (ETS) is sufficiently protected from insider dealing Regulation, which requires that any auction platform and market manipulation.143 The ETS operations must be a regulated market.149 At the time of writing, will be centralized into a single European Union Bluenext150—the major spot market—was in the pro- registry, which will be operated by the Commission. cess of becoming a regulated market for the purposes of It will replace all EU ETS registries currently hosted participating in auctions. To date, most allowance auc- in Member States. The Commission proposed using tion markets have appointed independent observers, as a consistent reverse charge mechanism for VAT as the markets have not been regulated. The EC continues a response to carousel fraud in certain sectors.144 In this practice in the EU Auctioning Regulation. 143. http://ec.europa.eu/clima/news/docs/communication_en.pdf Access date 22 Feb 2011. 144. http://ec.europa.eu/taxation_customs/resources/documents/common/legislation/proposals/taxation/com(2009)511_en.pdf Access date 22 Feb 2011. 145. http://www.minefe.gouv.fr/services/rap10/100419rap-prada.pdf Access date 22 Feb 2011. 146. http://www.amf-france.org/documents/general/9794_1.pdf Access date 22 Feb 2011. 147. http://www.amf-france.org/documents/general/9767_1.pdf Access date 22 Feb 2011. 148. http://ec.europa.eu/energy/gas_electricity/markets/doc/com_2010_0726_en.pdf Access date 22 Feb 2011. 149. http://ec.europa.eu/clima/documentation/ets/auctioning_third_en.htm Access date 22 Feb 2011. 150. Jointly controlled by CDC Climat–a subsidiary of French long-term investor Caisse des Dépôts–and NYSE Blue State and Trends of the Carbon Market 2010 | 41 BOX 4. A Point of View on the EU ETS The Carbon Market in Crisis?—Recognition, Yet there is no clamour to abandon free market mech- Resolve and Optimism. anisms in finance and commerce. Rather, a gritty resolve from regulators and market participants to For many, 2010 has been a year of considerable dis- continue improving these markets. Indeed, free mar- ruption and controversy in the carbon markets. ket principles are increasingly widely embraced. So it should be with the carbon markets, whose pres- The CDM continues to suffer from registration and ent challenges are small by comparison. Whilst not issuance delays due to complex procedures and ca- the only tool in the fight against climate change - and pacity constraints. JI continues to be challenged by every available tool should be deployed - the carbon inefficient domestic bureaucracy and varying politi- markets continue to be the most efficient available cal support. There have been sovereign suspensions mechanism for wholesale delivery of penalties for under the Kyoto Protocol and alleged misappropria- emissions and rewards for reductions. tion of AAU sale revenues. The EU-ETS has suf- fered from alleged VAT fraud, money laundering and Despite the flaws in the carbon markets, many of which theft leading to registry suspensions and a dramatic are being resolved, there have been real achieve- loss of confidence and liquidity in the spot markets. ments. The CDM & JI have reduced over 600MtCO2e International negotiations are stalled on the critical of emissions and may achieve 3.3 billion tCO2e by end issue of binding commitments. 2020. The EU-ETS is demonstrably encouraging coal- to-gas switching, renewable energy investment and However, the carbon markets are far from unique in industrial energy efficiency. Phase 3 auction revenues their troubles. In the 1990’s several emerging econ- will help finance CCS. Regional schemes are being omies suffered serious setbacks with stock market implemented in New Zealand and California with fur- losses and currency devaluations. Many have since ther schemes under discussion in Australia, South recovered. The recent “credit crunch” led to the near Korea, Japan and China. The importance of REDD is paralysis of EU and US money markets requiring gaining widespread international support. significant injections of government liquidity. Major fi- nancial institutions failed and stock markets suffered Most importantly, there is now an established interna- significant losses, though some recovery has since tional market that penalises emissions and rewards occurred. The credit markets remain challenged by reductions via prices that respond in real time to a economic difficulties in Greece, Ireland and Portugal. changing world. The credit crunch exposed the $50bil+ Madoff fraud. Thus recognition of flaws in the carbon markets Theft, fraud and money laundering are serious concerns should be balanced by resolve to improve and ex- in all markets. Regulators and market participants are pand these markets - and outweighed by optimism in perpetually challenged to develop safeguards ahead the potential of the carbon markets to deliver signifi- of criminal activity. Advancing technology creates its cant emissions reductions and to drive the transition own issues. In 2010 the Dow Jones temporarily lost to a global low carbon economy. $1trillion in a “flash crash” driven by high speed auto- Kindly provided by Martin Lawless, Managing Director and Global mated trading. “Fat fingers” have led to disruptions in Head of Deutsche Bank’s carbon markets business. numerous electronically traded markets. 42 | State and Trends of the Carbon Market 2010 The suite of regulatory reforms at the EU and over the ability to embed optionality in standardized Member State levels will over time lead to a more contracts and the impact standardization will have robust, transparent, and fair market. Many of the on developing the tailored OTC derivatives market. challenges encountered in the continuing develop- ment of the EU ETS offer invaluable lessons for other countries considering emissions trading. 3.3 PRIMARY ISSUANCE MARKET— EMISSION ALLOWANCE AUCTIONS 3.2 OVER-THE-COUNTER MARKET— The move away from administrative allocations to REGULATION IS COMING DOWN THE PIKE competitive auctions for emissions allowances is a significant policy change affecting carbon markets. The theft of EUAs and lack of clarity over legal owner- Auctioning provides a mechanism that both efficient- ship across the Member States of the EU is leading to ly allocates allowances and raises revenue. Starting in renewed interest in over-the-counter (OTC) spot mar- 2013, the EU ETS will enter Phase III of its imple- kets. Depending on the jurisdiction, stolen allowances mentation (currently it is in Phase II), stimulating purchased in good faith from a trusted source may not further development of the primary issuance market. confer ownership and, hence, usability.151 Some mar- The market is expected to grow from around 3 percent ket participants view OTC transactions with known of allowances auctioned during Phase II to at least 50 counterparties as an effective way to manage counter- percent of allowances auctioned during Phase III. party credit risk. VAT fraud has also encouraged mar- ket participants into the OTC spot market as a way to Many EU Member States will auction 100 percent avoid being inadvertently implicated in carousel fraud. of allowances for the power sector in Phase III of the EU ETS. As Germany, Poland, and the United Some market participants argued for a harmonization Kingdom intend to opt out of the planned common of rules for dealing with ownership of stolen allowanc- auction platform,154 there will be four separate pri- es, favoring the approaches taken in certain Member mary markets for emissions allowances that may of- States. Given the urgency of the situation harmoniza- fer arbitrage opportunities. tion may not be practical, but a solution is needed to restore confidence in the exchange-traded market. In Although the move to auctioning is theoretically the absence of a practical solution, more participants sound, there are practical considerations. Measures are likely to look toward OTC spot markets as a way need be in place to prevent carbon leakage for sec- to control this type of counterparty risk. tors that are assessed at significant risk.155 Permit auc- tions also raise the possibility of including transport As interest has increased in the OTC spot market, in the EU ETS without any loss of revenue. This was there is pressure to move away from the use of the the approach taken in the shelved Australian Carbon noncleared OTC derivatives market. Transactions Pollution Reduction Scheme (CPRS) where the fuel in the OTC derivatives market represent approxi- excise tax was to reduce under the scheme. mately 15 percent of derivatives transactions. The European Commission has proposed that standard In the current financial environment, concern focuses OTC derivative contracts be cleared through cen- on the ability of liable entities to obtain financing for tral counterparties (CCPs).152 The aim is to reduce allowances or to purchase allowances out of working counterparty credit risk153 and improve transpar- capital. Governments have attempted to address these ency. Some market participants expressed concerns issues with a range of policy initiatives, including the 151. http://www.ieta.org/assets/PositionPapers/ietaletter_registrysuspension20012011final.pdf Access date 23 Feb 2011. 152. http://ec.europa.eu/internal_market/financial-markets/derivatives/index_en.htm Access date 23 Feb 2011. 153. The risk that one party to the contract defaults. 154. http://www.decc.gov.uk/en/content/cms/what_we_do/change_energy/tackling_clima/emissions/eu_ets/phase_iii/phase_iii.aspx Ac- cess date 13 March 2011. 155. It may be argued even in the absence of auctioning that compensation should be made to sectors at risk of carbon leakage. The EU sectors at significant risk will receive 100 percent of the benchmarked allocation for free and, depending on where the facility is located, may receive further assistance for increased electricity costs. State and Trends of the Carbon Market 2010 | 43 auctioning of futures contracts and deferred payment contributed to the VAT fraud that occurred in the EU arrangements.156 These approaches are not ideal, as ETS. For example, Denmark moved to restrict regis- they reduce liquidity in allowance futures markets. try access to permanent residents in October 2010 to The move to auctioning has also encouraged work on combat VAT fraud and other crimes.159 emissions auction design and many approaches are be- ing proposed or are in operation across the globe. The Tightening of POI regimes may have implications for predominant current approach is the single-round, individuals or corporations from developing coun- sealed-bid, uniform price auction.157 Other significant tries wishing to participate in existing carbon mar- issues include limits on who can participate and the kets. The problem is complex, but not new. How does collateral needed to participate in auctions. an agency in a particular country verify the bona fide credentials of another country’s citizens or corpora- tions? The authors believe that the goal of ensuring 3.4 SECONDARY MARKETS— access can be achieved without compromising market CONTROLLING RISK AND ENSURING integrity. Multilateral development banks and other TRANSPARENCY AND ACCOUNTABILITY international institutions could potentially play a role in developing the market infrastructure that can both From a policy perspective, the desire to encourage support access and control risk. broad market participation and facilitate easy access to the carbon market must be balanced by the need 3.4.2 Operational Risk to control such risks as the potential for tax eva- Management—Registries sion and money laundering. The issue of managing the risks associated with components of the carbon The January 2011 theft of approximately 3.1 million market infrastructure is broad. It encompasses the EUAs from national registries in Europe has reignited operations of the registry, liability reporting system, controversy around the carbon market’s effectiveness auction platform, settlement system, and secondary as a policy tool for emission reductions and led to the market integration. Management of risk is critical temporary suspension of spot markets. As with other for maintaining market integrity.158 Web-based financial systems, EU ETS registries are vulnerable to phishing attacks and other malicious ac- 3.4.1 Proof of Identity tivities, such as hacking and denial of service attacks. In response to the theft, the EU took decisive action Given the potential for market abuses in the carbon and closed EU ETS registries pending the implemen- market, various law enforcement agencies have tak- tation of minimum-security arrangements. However, en an active interest in the development of the mar- the resulting market disruption underscores the need ket. Governments and corporate entities use proof of for a comprehensive approach to the issue. identity (POI) to control risk. Proof of identity aims to ensure that you know with whom you are dealing. The proposed European Commission solution— centralizing the ETS operations into a single Adequate proof of identity is a prerequisite for partici- European Union registry—has much merit. The pation in primary and secondary markets and for es- European Commission will operate the single tablishing registry accounts. Variations have occurred European Union registry, which will replace all in POI requirements across the EU ETS, with coun- EU ETS registries currently hosted in EU Member tries implementing a variety of regimes. It is thought States.160 The European Commission will take on that weak POI regimes in some countries may have the registry operational risks from Member States, 156. http://www.climatechange.gov.au/publications/cprs/white-paper/~/media/publications/white-paper/V1009Chapter-pdf.ashx Access date 02/11/2011. 157. In this type of auction, the auctioneer announces the number of allowances to be sold and bidders submit sealed bids that indicated the number of allowances desired at each price. Allowances are allocated to bidders based on the price paid by the lowest successful bid- der and only the auctioneer has information about the demand curves from auction participants. 158. 159. http://www.pointcarbon.com/news/1.1493597 160. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0063:0087:en:PDF Access date 22 Feb 2011. 44 | State and Trends of the Carbon Market 2010 but the Member States will remain in control of the This speculation is based on the ease of transfer of administration of the POI regime. allowances between registry accounts held in differ- ent countries, while avoiding mandatory reporting This situation creates an opportunity for developing a requirements, because no threshold reporting limits consistent POI regime across EU Member States as a are triggered. However, at the time of writing the au- way to minimize the risk of continued jurisdictional thors are unaware of any substantiated cases of money shopping by criminals. This does not imply that the laundering. The EC plans to address money launder- same POI regime will occur in each EU Member ing and other issues as part of a wide-ranging review State, but that an equivalently robust POI regime will of the market oversight framework of the EU ETS.164 exist in each Member State. It may make sense for registry participation rules to be consistent with auc- The EU’s existing Market Abuse Directive165 (MAD) tion participation rules, and there is some speculation applies to emission allowance derivatives and cov- from market participants that this will be the case.161 ers insider dealing and market manipulation. MAD does not currently apply to the spot allowance mar- An associated issue is access controls over govern- ket in the majority of EU Member States because ment holdings of Assigned Amount Units (AAUs) allowances are not defined as financial instruments. and Certified Emission Reductions (CERs). It seems likely that these access rights will remain under the According to the Prada review, many EU Member control of the respective Member States. In this situ- States have not resolved the legal status of allowanc- ation, the move to the single European Union reg- es. However, the Markets in Financial Instruments istry is an opportunity to bring access controls in Directive (MiFID) has harmonized the part of the line with current banking practices by strengthening allowance derivatives market regarded as financial in- account access, audit, and notification processes. struments.166 The EC review of the market oversight framework will examine the need to better protect the 3.4.3 Market Oversight Issues scheme from insider dealing and market manipulation. This section covers market oversight issues such as The EU has proposed a reverse charge mechanism money laundering, insider dealings, and fraud pre- to deal with VAT fraud167 and, at the time of writ- vention. Much work has been undertaken in the EC ing, several EU Member States have adopted the to ensure the integrity of the carbon market. mechanism or an equivalent to address the problem. However, market participants continue to express Money laundering refers to transactions that are concern that VAT fraud exists in the market as not undertaken to hide the true sources of the money. all EU Member States have adopted the proposed Usually the money involved is earned from illegal reverse charge mechanism or an equivalent. sources and is laundered to give the appearance of coming from a legitimate source.162 The detection of Continued VAT fraud is problematic for many mar- laundering and enforcement of the law normally in- ket participants wishing to protect their organiza- volves several agencies, including tax authorities, po- tion’s brands and reputation. It is likely that VAT lice, and surveillance apparatus. A speculation and fraud will be removed from the EU emissions trad- concern of carbon market participants is that money ing scheme when all EU Member States adopt the laundering exists in the market.163 proposed reverse charge or equivalent mechanism. 161. The EC auction regulations will ensure the integrity of the auctions by establishing minimum requirements for adequate customers through diligence checks. Eligibility to apply for admission to the auctions will be given to easily identifiable, well-defined categories of par- ticipants, notably operators of stationary installations and aircraft operators covered by the emissions trading scheme, as well as regulated financial entities, such as investment firms and credit institutions. 162. http://www.irs.gov/compliance/enforcement/article/0,,id=112999,00.html 163. 164. http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/10/697&format=HTML Access date 25 Feb 2011. 165. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2003:096:0016:0025:EN:PDF Access date 25 Feb 2011. 166. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2004L0039:20060428:EN:PDF Access date 25 Feb 2011. 167. http://ec.europa.eu/taxation_customs/resources/documents/common/legislation/proposals/taxation/com(2009)511_en.pdf Access date 22 Feb 2011. State and Trends of the Carbon Market 2010 | 45 It will be important to ensure harmonization of Some entities may continue to apply the withdrawn approaches and practices to prevent a recurrence International Financial Reporting Interpretations of VAT fraud as other countries outside the EU Committee (IFRIC) 3 standard as an accounting Emissions Trading Scheme start to participate in policy. The most common approach recognizes emissions trading. Currently nine operational regis- freely allocated allowances at zero value, with obliga- tries are outside the EU ETS,168 with more planned. tions/liabilities recognized at the carrying value of allowances already allocated (which may be zero) or 3.4.4 Taxation and Accounting Treatments purchased, with the balance, if applicable, valued at the prevailing market price.171 The taxation treatment of allowances varies by ju- risdiction. Allowances purchased for investment purposes will generally be treated differently from 3.5 CONCLUSIONS allowances purchased for EU ETS compliance pur- poses. For compliance purposes nine EU Member Universal participation—the idea that the market States treat allowances as commodities for taxation should be directly open to all who want to par- purposes and allow an immediate deduction of the ticipate—has promoted open access to the carbon purchase price. market. Yet, while universal participation encour- ages constituencies supportive of action on climate The remaining 18 countries treat allowances as in- change, few schemes come close to its ideal. The tangible assets with five countries allowing firms to principle does not readily fit with the practical reali- depreciate the assets over their expected lifetime.169 ty of building a robust, well-functioning market. An These approaches are equivalent when allowance are informal consensus appears to be developing among purchased and used for compliance purposes within regulators to limit participation to identifiable cat- the same tax year. When banking is involved, how- egories of participants, such as scheme participants ever, there may be some advantages in immediate and financial intermediaries. deductibility. Currently no International Financial Reporting Standard (IFRS) exists for accounting of allowance and permits.170 The accounting treatment is frag- mented across jurisdictions and between entities, and some entities treat free allowances as zero value and do not include them on their balance sheets. 168. http://unfccc.int/kyoto_protocol/registry_systems/registry_websites/items/4067.php Access Date 24 Feb 2011. 169. This section made use of a study by Copenhagen Economics for the European Union. The report is available at http://ec.europa.eu/ taxation_customs/common/publications/studies/index_en.htm Access Date 24 Feb 2011. 170. http://www.ifrs.org/Current+Projects/IASB+Projects/Emission+Trading+Schemes/Emissions+Trading+Schemes.htm Access Date 15 March 2011. 171. http://www.pwc.co.uk/eng/publications/trouble_entry_accounting_revisited.html Access Date 15 March 2011. 46 | State and Trends of the Carbon Market 2010 4 SECTION State and Trends of the Carbon Market 2010 | 47 4 Carbon and Climate Finance MITIGATING THE WORST IMPACTS OF CLIMATE CHANGE requires substantial investment.172 Much of the growth in both emissions and energy use will come from devel- oping countries. Mitigation costs in developing countries consistent with keeping average global temperature warming below 2˚C in comparison to preindustrial levels could reach $139–175 billion per year by 2030. Delaying action increases costs, as the world locks itself into high-carbon trajectories while stabilization options progressively disappear. The World Energy Outlook 2010 estimates that within one year the global cost of keeping average global temperature warming below 2˚C in compari- “ The current uncertainties surrounding a post-2012 international agreement son to preindustrial levels has increased by $1 trillion over 2010–30 (or $50 billion p.a.).173 The scale and have left Europe alone to absorb the the amounts of financing needed means that private supply of project-based CERs in the capital flows will be vital to the transition to a low- carbon future.174 Therefore, the global community must continue to support mechanisms that mobilize private capital in support of emission reductions in post-2012 environment. ” developing countries. considerations related to a possible gap between This section provides information on project-based the first and subsequent commitment periods.175 offsets mechanisms (Kyoto Markets), climate fi- Nevertheless, the current uncertainties surround- nance, and new asset classes. ing a post-2012 international agreement have left Europe alone to absorb the supply of project-based CERs in the post-2012 environment. 4.1 KYOTO MARKET—A POST-2012 FACING LOW DEMAND AND LOW SUPPLY Even within Europe, demand for CERs post-2012 will be restricted. The recovery of the European The Cancun Conference delivered positive deci- economy after 2009 has been slow. There is a broad sions to improve the CDM (see Section 1.1). In consensus among market participants that Phase II addition, the Ad Hoc Working Group on Further of the EU ETS will be considerably long (for ex- Commitments for Annex I Parties under the Kyoto ample, EU installations’ cap will be higher than Protocol (AWG-KP) has tried to clarify some of the their overall emissions), leading many installations 172. Stern Review on the Economics of Climate Change. Ch 9:232. The global cost of reducing total GHG emissions to three-quarters of current levels (consistent with 550ppm CO2e stabilization trajectory) is estimated at around $1 trillion in 2050 or 1 percent of GDP in that year, with a range of –1.0 percent to 3.5 percent depending on the assumptions made. http://webarchive.nationalarchives.gov.uk/+/http:// www.hm-treasury.gov.uk/independent_reviews/stern_review_economics_climate_change/stern_review_report.cfm Access date 6 April 2011. 173. IEA 2011. World Energy Outlook. http://www.worldenergyoutlook.org/ Access date 29 March 2011. 174. http://www.un.org/wcm/content/site/climatechange/pages/financeadvisorygroup/pid/13300 Access date 29 March 2011. 175. UNFCCC. Legal Considerations relating to a possible gap between the first and subsequent commitment periods, July 2010. 48 | State and Trends of the Carbon Market 2010 to “bank” surplus allowances and offsets to be used the 605 million CERs issued to date (67 percent). in Phase III. The surplus to be brought over from The problem is further compounded because it takes Phase II together with the new Phase III allowances on average about 670 days for project developers to will reduce the needs for additional CERs in the first get their projects registered178 yet there are only 631 years of Phase III (2013–20). days left until December 31, 2012.179 This strongly diminishes the hope that projects in the early stages of development will be able to get registered in time “ Unless additional non-EU demand emerges soon and the supply is and generate EU ETS-eligible credits. Unless additional non-EU demand emerges soon boosted by meaningful CDM reforms, and the supply is boosted by meaningful CDM re- forms, project developers will have very little, if any, project developers will have very little, if real incentive to continue investing in new CDM projects. This will eventually lead to the already an- any, real incentive to continue investing ticipated movement of resources—capital, capabili- in new CDM projects. ” ties, and personnel—to other markets. 4.1.1 CERs—What Did or As covered in the previous year’s report, new usage Did Not Happen in 2010? rules and qualitative restrictions will apply in the EU ETS. CERs will no longer be de facto compliance In 2010, the market volume and value of project- assets for Phase III of the EU ETS. Installations will based transactions fell by almost 50 percent from the have to swap them into EUAs to comply with their previous year, to reach a total value of approximately obligations, adding another layer of complexity to $1.5 billion. The two-digit annual decline in the size the process. In addition, only compliance entities of the market in the last three consecutive years (12 will be allowed to swap CERs into EUAs, leaving the percent in 2008, 59 percent in 2009, and 46 percent financial institutions out of the process and conse- in 2010) led the primary CER (pCER) market to quently reducing overall liquidity for those assets in its record low value since the entry into force of the the market. Kyoto Protocol in 2005. The supply will also be limited. Offsets issued from Primary CER transactions, which used to represent projects registered after 2012 will only be eligible to a significant portion of the global carbon market in be swapped if sourced from a least developed coun- previous years (up to 23 percent of the market in try (LDC). However, limited emissions and major 2005 and 19 percent in 2006), account for barely 1 investment barriers will constrain the supply of eligi- percent of the global market today. ble CERs from LDCs. To illustrate the level of mag- nitude of those constraints, the number of CERs 4.1.1.1 CER Supply and Demand Dynamics issued from LDCs is about 16,000,176 or 0.003 per- —A Smaller Market and a Buyer’s Market cent of the total 605 million CERs issued to date.177 Since 2009, sovereign buyers who still had some In addition, the ban of offsets from hydrofluo- residual emission reduction obligations, and have rocarbons (HFCs) and adipic acid N2O projects historically engaged in origination activities and from Phase III will limit even further the number promoted the project-based primary market, largely of CERs eligible for compliance in the EU ETS. A shifted their efforts toward the Assigned Amount large portion of the CERs currently being issued Units (AAUs) market. This market offers predict- are from these project types—407 million out of able volumes, making it a suitable instrument for 176. Projects in Tanzania, Lao PDR and Bhutan. 177. UNEP Risoe, CDM/JI Pipeline Analysis and Database, May 1, 2011. 178. World Bank, UNEP Risoe, CDM/JI Pipeline Analysis and Database. 179. As of May 1, 2011. State and Trends of the Carbon Market 2010 | 49 compliance buyers to match and fine-tune demand The pCER market is a buyer’s market with minimal to “land on the dime,” which represents their final residual demand until 2012. Uncertain eligibility Kyoto obligations. rules and the lack of traction for post-2012 have in- creased the bargaining power of active buyers. This In addition, during 2010 the primary market was imbalance has been reflected in Emission Reduction further negatively affected as some sovereign buyers Purchase Agreement (ERPA) terms and conditions. increased purchases in the secondary CER (sCER) market, taking advantage of fast transactions, relatively 4.1.1.2 Emission Reduction Purchase Agreements inexpensive and simple contractual processes, and pre- —Tailored to Buyers dictable volumes ensured through delivery guarantee. As reported last year, project registration prior to Demand from the private sector has also consider- December 31, 2012, and EU ETS eligibility became ably reduced, as lower overall GHG emissions led to standard clauses in the great majority of ERPAs. In a surplus of allowances and offsets in the EU ETS. A addition, last year buyers involved in both origina- large number of financial institutions (that is, nonfi- tion and secondary trade reportedly secured even nancially regulated traders and private banks), inter- more stringent conditionality and guarantee clauses mediaries, and aggregators preferred investing in ex- in their ERPAs. In the case assets prove not eligible isting—undervalued—portfolios rather than in new at delivery, ERPA prices are reduced to the prevail- projects, and froze their origination activities. Other ing prices for these assets in the voluntary market.182 buyers either exited the market or were acquired by other firms in the past two to three years, which sub- Option clauses also have become common in ERPAs. stantially reduced the primary market’s liquidity. If the offsets transacted are not eligible at time of delivery or at the buyer’s sole discretion, contractual Despite the overall decline in the pCER market and purchase obligations may be converted into call op- the exits of many participants, the market continues tions; in this case, the market liquidity is squeezed to limp along with mainly private sector buyers look- and no secondary trade occurs (that is, buyers can ing for cheap opportunities to purchase both pre- and terminate the contracts without penalties, thus pass- post-2012 CERs. The still active private sector buy- ing the entire delivery risk to the sellers). The results ers include mainly utilities and financials. Potential of the World Bank survey confirmed the trends. aviation compliance buyers have shown an increased More than 80 percent of respondents confirmed re- interest in precompliance, but this is yet to translate strictive clauses in their ERPAs, in addition to regis- into significant demand.180 In addition, some demand tration pre-2012 and eligibility under the EU ETS. has come from a few multilaterals and governmental agencies winding up funds close to full subscription. Some increase in the level of activity in the primary market was reported in early 2011. Some buyers, who Utilities continue buying CERs since they are cheap- had their origination activities dramatically reduced in er than EUAs for compliance purposes. Utilities and 2009 and frozen in 2010, resumed some investment nonfinancially regulated traders have a cost advan- and sought new projects, motivated by the internal tage over private banks because they do not have to pressure to justify the maintenance of the personnel comply with the stringent and potentially expensive infrastructure created. It is also interesting to note that, rules imposed by the Basel Accords.181 On the other at the same time that the overall uncertainty favors buy- hand, the large commercial banks have continued ers, the few sellers who hold the most desirable pCER to develop their portfolios of captive clients because assets (that is, clean energy projects in advanced stage of their strong reputations, attractive and flexible fi- of development and projects in LDCs) have obtained nancial packages, and creditworthiness. favorable ERPA conditions and premium prices. 180. The aviation sector is to be included in the EU ETS in 2012. Please refer to Section 2.1 for further details. 181. The Basel Accords set up global regulatory standards on bank capital adequacy and liquidity designed to ensure that banks holds capital reserves appropriate to face the risk exposure in their lending and investment practices, safeguarding their solvency and overall economic stability. http://www.bis.org/press/p101201a.htm Access date 07 April 2011. 182. Some buyers have reported favoring CDM projects with CERs that are also compliant with voluntary standards, such as Gold Standard. 50 | State and Trends of the Carbon Market 2010 Finally, the lack of demand has also led to further Sovereign buyers have also been accessing sCERs market segmentation and the rise of niche markets from industrial gas projects to be delivered after that accentuate technology and regional preferences, April 2013 (and before the end of the “true up” peri- reflect specific objectives of sellers and buyers, and od) at the same price range of AAUs, and thus, even favor commercial relationships built in previous cheaper than the prevailing price for EU ETS eligi- years. Under this scenario, ERPAs are being tailored ble pCERs for the same delivery dates. The negative to address specific preferences and objectives, sub- spread—sCERs being cheaper than pCERs—be- stantially increasing the lack of transparency of the tween the secondary and the primary market prices primary market—a market that now resembles the in those specific offsets should further encourage earlier days of the Kyoto Protocol, when the level of sovereign buyers to seek those sources. information was sparse and inconsistent. Post-2012 4.1.1.3 New Operational Dynamics —Prices and Behavior Post-2012 prices were reported to be in the €6–8 range, with €7–7.50 being the median prices—al- Pre-2013 most identical to those reported in 2009. Variable price formulas followed pre-2013 transactions, but Despite the recovery of sCER prices vis-à-vis the discounts on upside sharing were reported to be previous year (that is, consistent with other energy slightly higher—up to 20 percent of the spot CERs related commodities), pCER prices did not follow at delivery. The discount on the variable price com- the same pattern. With lower compliance needs, ponent increases relative to how high the fixed floor buyers were more selective and acquired safer assets. price is agreed upon (i.e., sellers’ access to upside For these assets prices remained at the same level as prices at delivery is reduced). the previous year (2009). These prices are consistent with other publicly avail- Fixed prices for pre-2013 pCERs averaged €8–10 able information184 and with the results of the World across most regions and sectors. In cases where vari- Bank survey. About 70 percent of the respondents able prices were negotiated, floor or fixed components confirmed either not buying post-2012 offsets or if were in the €7–8 range, while variable components— they were, prices were in the €6–8 range. If a fully defined in terms of shared upside between buyers and variable price were chosen, over 70 percent of re- sellers—commonly reached 90 percent of the spot spondents indicated prices would be between 60 to CER prices, to be determined based on the prevailing 80 percent of spot CERs prices. price on the largest exchanges at the time of delivery. In addition to the new contractual developments Respondents to the World Bank survey who indi- mentioned in Section 4.1.1.2, several players re- cated interest in buying CP-1 HFC-23 offsets to be ported further safety provisions and changes in their delivered after April 2013 reported prices lower than modus operandi. The origination arms of private €6. The information clearly indicates that, since sector financials reported very low incentives to in- those offsets will no longer be valid for EU instal- vest in post-2012 offsets because of concerns over lations, governments with obligations under Kyoto the possibility of financial losses. This risk reportedly become the sole buyers of those assets183 and value led shareholders to zero-value offsets to be delivered them in the same price range of AAUs, which are after 2012. In addition, capital reserve provisions equally acceptable Kyoto compliance assets. under the Basel rules substantially reduce the return on equity (RoE) in those deals. 183. Although those assets may eventually be eligible to other ETS outside Europe, it is very unlikely that a relevant demand will be created given the precedent provided by the EU. 184. IDEAcarbon’s pCER Index confirms our findings and shows that average post-2012 pCER prices varied within the narrow range 2010 and early 2011. State and Trends of the Carbon Market 2010 | 51 Other financials, concerned about reputational risks sellers favored variable prices, as they desired poten- and future liabilities, have reportedly removed carbon tial upside gains and did not perceive any downside assets and projects from their spectrum of investment risk. During 2006–08, buyers preferred fixed prices alternatives. Moreover, many froze carbon advisory to reduce their exposures to price spikes. The cur- services to both traditional and new clients seeking in- rent reversal of the 2006–08 trend indicates that the vestment diversification and environmentally friendly downside risk is perceived as higher now, given the investment alternatives. Similarly, some sovereign uncertainties in the post-2012 market. buyers have reported receiving clear instructions to refrain from any exposure to post-2012 offsets. However, the ERPA risk allocation between the parties may be more relevant than pricing. The eligibility and Finally, although specific limits in contractual obli- option clauses mentioned previously drain most of the gations (e.g., maximum prices, volume contracted, predictability and security of fixed-price contracts (i.e., length of contracts, and ERPA value) have been future flows of resources cannot be ensured until deliv- commonly used by buyers as a means to matching ery). As a result, in ERPAs incorporating those clauses, their budget allocations, corporate buyers reported front-loading mechanisms such as unsecured advance much more stringent limits for post-2012 transac- payments from buyers or commercial loans backed-up tions. The stringency of those limits increased in by future carbon revenues could not be found. On the ERPAs signed at fixed prices or in projects located in other hand, those clauses have also allowed ERPAs to the most industrialized developing countries. address both buyers’ and sellers’ concerns and objec- tives in either pricing approach chosen. Thus, both Although a few contracts up to 2020 were reported, fixed- and variable-price contracts were observed. buyers strongly preferred to sign ERPAs limited to the end of the project’s first crediting period (that is, 4.1.2 ERUs—What Lies Ahead? reducing the risks related to the obligatory renewal of the project’s additionality) and early 2015 (that Many of the issues surrounding the development of is, the expiration of the “true up” period for govern- the JI market are similar to the CDM and relate to the ments with obligations under the first commitment post-2012 uncertainties, but with additional complexi- period of the Kyoto Protocol), whichever comes first. ties. Unless Parties adopt a COP decision not to do so, JI country governments or legal entities authorized by Buyers—especially financials—strongly favored vari- them might still be able to continue determining proj- able prices in the ERPAs, capped at the sCER price ects and verifying Emission Reduction Units (ERUs) to limit their financial exposure. Some buyers have unilaterally beyond 2012 under Track 1. reported being allowed to sign fixed-price ERPAs in least developed countries only. In contrast, sellers indi- In fact, interested JI Parties may have no incentive to cated a preference for fixed-price contracts, at least for stop ERU issuance for post-2012 vintages. However, the initial years of their contracts. This practice allows it is less clear whether the Joint Implementation them to seek finance or, at least, to forecast the extent Supervisory Committee (JISC) has a mandate to of possible future revenue streams. This message was continue its activities under the Track 2 procedure also conveyed by sellers dealing with Programmes of after 2012. In that scenario, it is envisioned that Activities (PoAs), especially when the implementing buyers will require strong monitoring and auditing agency, commonly a financial institution or govern- processes in place to ensure environmental integrity. mental agency, plays the role of the financier or guar- antor of the projects undertaken by the program. It is also unclear whether ERUs can be issued for emission reductions that occur after the end of the The current buyers’ preference for variable prices and first commitment period and prior to another. The the sellers’ preference for fixed prices is the opposite of JISC raised these and other questions in its last an- what the market witnessed in 2006–08. In those days, nual report,185 providing recommendations and 185. Annual report of the Joint Implementation Supervisory Committee of the Parties serving as the meeting of the Parties to the Kyoto Protocol, November 16, 2010, UNFCCC. 52 | State and Trends of the Carbon Market 2010 indicating areas of improvements for the JI process which is justifiable based on the credit-enhancement and a possible reorientation of the JISC’s program. and (counterpart) risk-mitigation roles played by These recommendations include further improve- Sberbank in the process. ment of the verification procedure, increasing the number of accredited independent entities, and en- Deals have reportedly been signed at prices lower hancing the financial stability of the JISC. than the government’s recommended €10 and more consistent with the prevailing primary market price In terms of the JI market, JISC recommendations range. This has resulted in at least one legal dispute include consolidating the two tracks into one single between a buyer and seller,189 and has raised con- unified track for JI and allowing the issuance of the cerns among certain buyers regarding the effective- emission reductions for existing and new JI projects ness of their ERPAs.190 between January 1, 2013 and either the end of the “true-up” period or the entry into force of new com- To date, 199 of the 392 visible projects in the JI mitments, whichever is sooner, by converting AAUs pipeline are referenced as Track 2 projects (that is, 51 from the first commitment period.186 percent of the total) and 28 (14 percent) out of them have been determined. Under Track 1, all 193 vis- No significant changes were reported in the JI prices ible projects in the pipeline (49 percent of the total) in 2010. As ERUs became tradable on exchange have already been approved by their respective host platforms in late 2010,187 liquidity for those assets countries. Russia is currently responsible for 113 vis- increased and consequently, the traditional pricing ible projects, leaving the former leader, Ukraine, in discount over sCERs reported in previous year di- second place with 70 projects.191 minished in 2010. Still, the much lower volumes of ERUs available in the market (vis-à-vis CER) kept Although striking, the latest moves from Russia the JI market in the hands of few players. Whereas could not yet be reflected in the number of deter- some participants found JI a very attractive market mined projects or in the volume of issued ERUs. for offsets in 2010—specifically the possibility to Ukraine remains in the lead with 47 determined obtain retroactive offsets—other participants report- projects (versus 4 in Russia) and about 50 percent of ed an unwillingness to accept the counterparty risk the almost 30 million issued ERUs to date, followed involved in ERU deals. by Russia with about a 15 percent share. Sberbank, the State Savings Bank of Russia—the 4.1.3 AAUs—Responding to the Lack of entity designated as the authorized entity to man- Demand age the selection of potential JI projects in Russia— confirmed the officially recommended price of €10 AAU prices in 2010 were reported to have substan- for the Russian tenders handled in 2010.188 That tially dropped from the €8–10 seen in 2009 to the price is at the high end of primary market prices, €5–7 level as carbon buyers became less active. It was 186. “The JISC is of the view that the two-track approach to JI, as it is currently applied, is not sustainable and is hindering the success of the overall JI mechanism in a number of ways.” Paragraph 125, page 41 of the JISC Annual report cited above. 187. On November 8, 2010, the Intercontinental Exchange (ICE) ECX announced the first cleared trade of EURs. The ERUs were traded introduced ERUs in the list of assets tradable in their platform. 188. In July 2010, the Ministry of Economic Development (MED) of Russia approved the results of the first Russian JI tender, managed by Sberbank. In the tender, 15 JI projects, which could earn up to 30 million ERUs, have been approved. A second tender was announced few months later with a deadline for applications in October 2010. In the second tender, 18 projects generating up to 29 million tons were granted with LoA. Ten of 18 projects have applied for LoA for the second time. A third JI project tender was announced by the Russian gov- ernment and it is expected by mid-March 2011. Like the previous two, the third tender would likely be assigned a cap of 30 million ERUs. Source: Point Carbon communication to the authors. 189. The Arbitration Court of Perm turned down a claim from Halopolymer, which was seeking to breach a contract to sell ERUs to Carbon Market Daily, April 20, 2011. 190. In a government newsletter, the Danish Energy Agency said it was withdrawing from investing in Russian emission reduction projects give guarantees that the offset credits it was seeking would be issued. Source: Point Carbon, CDM&JI Monitor, April 13, 2011. 191. http://www.cdmpipeline.org/publications/JiPipeline.xlsx Access date 1 March 2011. State and Trends of the Carbon Market 2010 | 53 noticed that private Japanese carbon buyers, such as utility companies, have kept their focus on AAUs due to the predictability of those assets. However, instead of pursuing those though direct purchases as in previ- “ GIS operations could, therefore, serve as additional testing ground for ous years, they started bidding for AAUs via brokers, management, implementation, monitoring, such as Japanese trading houses. and verification procedures for mitigation The UNFCCC negotiation proposals spearheaded by programs, similar to the ones foreseen the European Commission to ban or limit banking first commitment period AAUs under any new inter- national agreement (or possibly as an arrangement in- ternal to the EU) provided an incentive for countries under the PoA rules and procedures. ” to try and sell more AAUs during the first commit- led the country to lose its position as leading seller ment period. This essentially turned the market into in 2010. Estonia, with about 50 percent of market a buyer’s market and suppressed AAU prices further. share, became the preferred source for AAU buyers in 2010, followed by Czech Republic and Poland. More AAU sellers have entered the market but their be- haviors have varied. For example, Latvia, which was one The last ten years have shown that the Kyoto flex- of the front-runners of the Green Investment Schemes ibility mechanisms are often cumbersome. As a re- (GIS), has opted to stop offering AAU sales because of sult, GIS operations typically bundle many subproj- the currently low AAU prices, while other countries, ects coordinated by a single management entity and such as Estonia, the Czech Republic, and Poland, have monitor and verify results on a sample basis. actively sought to sell their AAUs, mainly to Japanese private firms. Countries such as Lithuania, Bulgaria, These elements are similar to those that PoAs have to and those that had difficulties in the implementation address. Although it is too early to draw conclusions, of the GIS before, such as Ukraine and Slovakia, started GIS operations could, therefore, serve as additional preparations for new GIS transactions. testing ground for management, implementation, monitoring, and verification procedures for mitiga- Although the number of AAU purchase agreements tion programs, similar to the ones foreseen under the signed in 2010 grew compared to 2009, the vol- PoA rules and procedures. ume of AAUs sold dropped, having spiked in 2009 because of the large GIS transaction in the Czech In many cases, GIS operations also focus on prop- Republic and Ukraine. Seller countries have been re- er and transparent financial management of the quested to demonstrate the accountability and trans- program, which is also important to consider in parency of the AAU transaction via their GISs to at- PoAs. Similarly, some elements of the GIS could tract AAU buyers. It should be noted that Russia, be useful in planning and implementing Nationally potentially the largest seller of AAUs, has not been Appropriate Mitigation Actions (NAMAs) in devel- able to enter the market, as the regulatory frame- oping countries or provide insight into the develop- work could not be prepared. ment of new market-based instruments. Japan kept its absolute dominant position among AAU buyers, although with smaller amounts. As 4.2 VOLUNTARY MARKETS Annex 1 countries get close to fully complying with their Kyoto obligations, governments reduce the The voluntary markets remain a small, but important pace of their purchases, and trading opportunities component of the overall carbon market. Voluntary for private sector players decline in tandem. Still, the action by environmentally conscious individuals and rapid decline in AAU prices resulted in a large spread organizations continues to send an important mes- between those assets and more expensive CERs, sage on the need for action. This message has been opening profitable swap opportunities for private expressed through the rapid growth of the Voluntary sector Japanese firms. The reported issues regarding markets (see Box 5). the misuse of AAU proceeds from Ukraine may have 54 | State and Trends of the Carbon Market 2010 BOX 5. Voluntary Markets 2010 was a record year for activity in the voluntary and the destruction of ozone depleting substances carbon markets (VCM). While the volumes in the (ODS) under the Climate Action Reserve (CAR). VCM remain miniscule, less than 0.3 percent of the global carbon markets, overall transaction volumes A huge shift in the marketplace was the demise increased 28 percent between 2009 and 2010 (see of the CCX cap-and-trade program. Shortly af- Table 11). The global economic crisis that dampened ter acquiring CCX operator Climate Exchange, demand for voluntary climate action in 2009 gave IntercontinentalExchange (ICE) announced that way to market growth as buyers sought credits from CCX’s severely over-allocated voluntary cap-and-trade projects that reduce emissions from deforestation program would conclude at the end of the program’s and forest degradation (REDD). Phase II in December 2010. In lieu of exchange trad- ing, ICE will continue to operate the CCX program’s The meteoric rise of REDD’s market share (+500% project protocols and registry system in 2011–12. from 2009)* can be attributed to formal internation- al recognition for REDD and conservation-based Parallel to the collapse of exchange-traded volumes REDD+ as critical for climate change mitigation as and prices, however, sellers began trading CCX well as likely pre-compliance interest in the project type credits off-exchange (bilaterally) to obtain higher pric- under California’s emerging cap-and-trade program. es. One such bilateral trade rocked the voluntary mar- ket in 2010, transacting 59 MtCO2e at $0.02/tCO2e. At the same time, REDD gained market standing on Even excluding this trade, CCX ranked among the the platform of the first REDD project methodologies top third-party standards in 2010—with some retail- approved for use by the Verified Carbon Standard ers packaging the low-priced credits (average $0.2/ (VCS) and through forest-focused third-party stan- tCO2e) along with non-CO2 environmental assets to dards like Brasil Mata Viva (BMV). obtain higher retail prices. Not all project types witnessed such growth. The voluntary markets have always seen a mix of “pure Transactions of methane-based credits—which was the voluntary” offsetting and pre-compliance motivations. most popular project category in 2009—fell dramatically Last year, suppliers reported that the bulk of transac- in 2010 as hope for national pre-compliance credits’ tions, around 70 percent, were driven by purely vol- value waned with failed US federal climate legislation. untary intentions. A resurgence in value among purely voluntary standards like the Gold Standard (up 56% However, the US maintained a slight lead (<1 to $55 million) and continued interest in “act local” MtCO2e) over Latin America as the top project loca- project types like bike shares and composting illus- tion due to landfill methane and the growing popu- trate ways the market continues to adapt (and grow) larity of improved forest management (IFM) projects around its traditional customer base. Table 11. Average price ($/tCO2e) Volume (MtCO2e) Value (million $) Voluntary Market Prices and 2009 2010 2009 2010 2009 2010 Volumes Chicago Climate Exchange (CFIs) 1.2 0.1 41.4 1.6 49.8 0.2 Voluntary over-the-counter market 6.5 5.8 55.4 125 357.8 393.5 Of which VCS 4.7 5.2 16.4 26.1 76.8 134.8 Of which CAR 7 5.8 14.6 13.4 101.9 78.2 Of which Gold Standard 11.1 11.4 3.2 4.8 35.2 54.7 Of which CCX bilateral 0.8 0.2 5.5 61.4 4.3 1.4 Source: Ecosystem Marketplace and Bloomberg New Energy Finance NOTE: preliminary findings, dated April 2010 *Survey respondents transacted 16.7 MtCO2e REDD offset credits in 2010, up from 2.8 MtCO2e in 2009. Kindly provided by Hamilton et al from Ecosystem Market Place and Bloomberg New Energy Finance. State and Trends of the Carbon Market 2010 | 55 4.3 MOBILIZING LOW-CARBON the transformational impact of CDM. In many sectors, INVESTMENT—BEYOND CARBON revenues from carbon credits have simply not been able REVENUE STREAMS to overcome the sectoral and regional investment barri- ers faced by many underlying projects.193 The CDM has been an important catalyst of low- carbon investment in developing countries. By en- Lenders that had in earlier years been willing to ac- hancing the overall financial viability of low-carbon count for prospective CDM cash flows in debt siz- projects in low-income countries, it leveraged other ing are no longer willing to do so, given the fact that resources and catalyzed the shift of much larger buyers typically do not take CER eligibility risk any- amounts of (essentially private) financial and invest- more. Moreover, on the supply side, as the post-2012 ment flows toward climate-smart development. market refocuses towards LDCs, the potential proj- ects and sponsors are considered less strong and less However, as we approach 2012, the prospect of rev- creditworthy. As a result, some market participants enues from the CDM shrinks, and CDM currently report that their CDM origination efforts are winding makes little difference in accessing financing. Because down. On the bright side, some market participants of the deep uncertainty surrounding the regulatory report increasing interest in the forestry sector, with fi- frameworks for mitigating GHG emissions post- nancing potentially driven by voluntary carbon deals. 2012, and the continued evolution of methodologies and other crediting rules, banks are unwilling to con- The relative decline in the importance of CDM has sider future flows from CERs in debt sizing.192 refocused attention on the value of additional revenues from carbon finance that enhances the overall financial It is well known that developing countries face large viability of low-carbon projects. As performance-based investment barriers—the lower income countries payments, these revenues create a positive incentive for in particular. Mobilizing low-carbon investment in good management and operational practices that will emerging markets can be challenging. Investors in sustain emission reductions over time.194 these countries typically face small-market size, weak business environments, high levels of perceived risk, As the global credit crisis eased during 2010, low-car- relatively low competitiveness, and incomplete capital bon finance and investment recovered, growing by 30 markets, so that sponsors are unable to secure debt percent to $243 billion.195 Clean energy investment in with sufficient maturities to cover the higher up-front the Asian region increased 33 percent to $82.8 billon. cost of low-carbon investment. These constraints are This is partly because of the rapid growth of private in- especially relevant in LDCs where European carbon vestment in China’s clean energy sector, which increased markets are now looking to source post-2012 CERs. by 39 percent to $54.4 billion. Many other developing countries fared less well: Brazil only achieved $7.6 bil- This situation is further complicated by the fact that lion and India $4.0 billion. Argentina ($743 million) carbon offsets are normally paid upon delivery, only and Mexico ($2.3 billion) were the fastest-growing after the underlying project has been built and has be- markets, at 568 percent and 273 percent, respectively. come operational. This reduces the capacity of carbon offsets to meet capital investment needs. In addition, Climate financing is a priority area for the six ma- the very low incremental revenue streams provided by jor multilateral development banks (MDBs),196 carbon offsets in many clean energy technologies— which are increasingly integrating climate into their particularly in renewable energy projects—have limited support to client countries. The MDBs’ country 192. UNEP 2009. Catalysing low-carbon growth in developing economies. http://www.unep.org/PDF/PressReleases/Public_financ- ing_mechanisms_report.pdf Access date 08 April 2011. 193. Kossoy, A. 2010. “Managing Expectations,” Trading Carbon, February 2010, Thomson Reuters Point Carbon. 194. Bosi, M. et al. 2010. “10 Years of Experience in Carbon Finance.” Carbon Finance Unit, World Bank. http://siteresources.worldbank. org/INTCARBONFINANCE/Resources/10YearsofExperienceinCF_Exec_Summary.pdf Access date 29 April 2011. 195. The Pew Charitable Trusts. 2011. “Who’s Winning the Global Clean Energy Race.” http://www.pewenvironment.org/news-room/ press-releases/global-clean-energy-investment-reached-record-243-billion-in-2010-329326 Access date 02 April 2011. 196. This discussion focuses on the five major MDBs collaborating on the CIFs: African Development Bank (AfDB), Asian Development Bank (ADB), European Bank for Reconstruction and Development (EBRD), European Investment Bank (EIB), Inter-American Development Bank (IADB), and the World Bank Group (WBG). 56 | State and Trends of the Carbon Market 2010 assistance strategies—jointly developed with cli- ent governments and other key stakeholders—in- Program199 creasingly address climate issues.MDB support has historically taken the form of investment funding, Development (EBRD) Sustainable Energy risk mitigation, and technical assistance (providing Initiative (SEI),200 EBRD Post-2012 Fund, capacity-building and other policy, regulatory and and EBRD Multilateral Carbon Credit Fund institutional advice). In the past decade the MDBs (MCCF)201 have increasingly tailored specific instruments aimed at reducing barriers to low-carbon investment, in- Carbon Credit Fund202 cluding climate-specific funding instruments, risk mitigation instruments, and carbon funds and facili- Sustainable Energy and Climate Change ties.MDB funding for mitigation activities has risen Initiative (SECCI)203 from $5.4 billion in 2006 to $17 billion in 2009. This growth trend is expected to continue, with in- 2012 Carbon Facility204 dicative financing of $20 billion in 2012.197 205 An important driver of the growth in MDB climate Grant support has historically been channeled financing has been the Climate Investment Funds through donor-financed facilities, notably the (CIF), which provide new and additional financing Global Environment Facility (GEF), a range of bi- through the MDBs to support mitigation and ad- lateral funds, and the MDBs’ own budgets. aptation at a significant scale. To date, donors have pledged $6.4 billion to the CIF, which is piloting Responding to growing interest from fixed-income efforts in 45 client countries. The CIF comprises investors looking to support climate activities with two funds: the Clean Technology Fund (CTF) and their investments, MDBs have issued “green bonds,” the Strategic Climate Fund (SCF).198 Further, sev- which raise funding earmarked to low-carbon ac- eral of the MDBs have developed specific initiatives tivities in client countries.206 This builds on earlier targeting sustainable energy, which enables them to experience with climate-themed bonds, such as the combine carbon finance—notably, purchasing post- CER-linked “COOL” bonds207 (a total of $31.5 2012 CERs—with underlying project finance: million was raised through two bonds with coupons 197. United Nations High-Level Advisory Group on Climate Change Financing. Work Stream 4: Contributions from International Financial Institutions. http://www.un.org/wcm/content/site/climatechange/pages/financeadvisorygroup/pid/13300 Access date 08 April 2011. 198. Under the SCF, there are three targeted programs with total pledges of $1.8 billion in funding. The Forest Investment Program (FIP) is supporting REDD+ activities in eight pilot countries). The Scaling Up Renewable Energy Program in Low Income Countries (SREP) is supporting grid- and off-grid electricity, including renewable generation and the transmission and distribution grids needed to connect them, as well as household energy. A third SCF program, the Pilot Program for Climate Resilience (PPCR), is developing strategic investment programs supporting climate resilience. http://www.climateinvestmentfunds.org/cif/ Access date 08 April 2011. 199. The Asian Development Bank (ADB) carbon market program supports CDM projects through two carbon funds (the Asia Pacific Car- bon Fund and Future Carbon Fund), a technical support facility, and a credit marketing facility. http://www.adb.org/Clean-Energy/CEFPF. asp Access date 5 April 2011. 200. http://www.ebrd.com/pages/homepage.shtml Access date 08 April 2011. 201. The Multilateral Carbon Credit Fund (MCCF) is a post-2012 fund jointly developed by the EBRD and EIB. http://www.ebrd.com/ pages/sector/energyefficiency/sei/carbon/markets.shtml Access date 5 April 2011. 202. The Post 2012 Carbon Credit Fund focuses exclusively on purchasing CERs and ERUs generated after 2012, potentially up to 2020, with funding from the European Investment Bank, Caisse des Dépôts, Instituto de Crédito Oficial, KfW Bankengruppe, and Nordic Investment Bank. http://www.eib.org/projects/publications/post-2012-carbon-credit-fund.htm Access date 5 April 2011. 203. http://www.iadb.org/en/topics/climate-change/secci,1449.html Access date 27 April 2011. 204. IFC launched a Post-2012 Carbon Facility in February 2011 to forward purchase CERs from projects either directly financed by IFC or by local banks financed by IFC. 205. http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/ENVIRONMENT/EXTCARBONFINANCE/0,,contentMDK:21871259~me nuPK:5216275~pagePK:64168445~piPK:64168309~theSitePK:4125853,00.html. 206. Since the inaugural issue issued in 2008, the World Bank has raised about $2.3 billion via 39 World Bank Green Bonds issued in 15 currencies. http://treasury.worldbank.org/cmd/htm/WorldBankGreenBonds.html. Other MDBs, such as IFC, have also issued similar green bonds in 2010. For example IFC’s four-year, fixed-rate bond raised $200 million. http://www.ifc.org/ifcext/media.nsf/Content/IFCGreen- Bond Access date 08 April 2011. 207. Cool Bonds are five-year AAA notes issued by the International Bank for Reconstruction and Development (IBRD) and linked to Certified Emission Reductions (CERs) set up under the Kyoto Protocol. http://siteresources.worldbank.org/CFPEXT/Resources/IF-for- Development-Solutions.pdf Access date 5 April 2011. State and Trends of the Carbon Market 2010 | 57 tied to CERs generated by specified GHG-reducing 4.4.1 REDD and REDD+ projects in China and Malaysia) and “Eco Notes”208 linked to special equity indices that support clean A significant development was achieved at the Cancun energy or other eco-friendly sectors (approximately Conference (COP 16). For the first time, the impor- $390 million was raised through three euro-de- tance of stemming the loss of tropical forests for miti- noinated transactions). However, funds raised with gating global climate change with financial support the “COOL” bonds and “Eco Notes” were not ear- from the industrialized world was enshrined in an marked for specific purposes. international agreement. The Kyoto Protocol’s Clean Development Mechanism has only allowed incentive The Green Climate Fund (see Section 1.2) and the payments to be made for afforestation and reforesta- expansion of green lending through international tion in developing countries, and only at the level of financial institutions are important developments projects. With COP 16 decision, entire jurisdictions that will provide additional financial support for de- (including countries themselves) could receive incen- veloping countries. tives, subject to verification that emissions have been reduced against a reference level.209 Looking forward, long-term carbon price signals are fundamental to deploy the currently not vi- All developing country activities referred to as able low-carbon technologies, as well as to develop “REDD+” are now eligible for financial support. new low-carbon technologies necessary to support They are as follows: the technological transformation to a low-carbon society. The low-carbon transition will be achieved through an appropriate mix of policy measures (such to diverge from the reference level by reducing as domestic/national budget allocations), conces- the conversion of forest to nonforest); sional finance, and overseas development assistance - (ODA). Nonetheless, private sector resources and verging from the reference level by reducing the investments will be needed at a much larger scale gradual loss of biomass because of activities un- than is available today in order to tackle the enor- der the canopy); mous infrastructure transformation that is required. forests); 4.4 NEW ASSET CLASSES emissions through harvesting activities with low- COMING TO THE MARKET er impact); and - Many of the emission reduction opportunities are hanced sequestration, for example, through beyond CDM, notably in the REDD+ space. They reforestation). do not have clear methodologies and are in sectors that may not be amenable to conventional financing. REDD+ activities will have to support and promote Organizing, financing, and implementing carbon safeguards. In particular, the knowledge and rights projects in such sectors as low-tillage agriculture and of indigenous peoples and local communities must sustainable land management will require developing be respected. Indigenous peoples and local com- new organizational and financing models. The follow- munities must be able to participate fully and ef- ing is a brief discussion of new developments in forest fectively. In addition, the national forest governance (REDD and REDD+), agriculture, and soils. structures must be transparent and effective, taking into account national legislation and sovereignty. REDD+ must not encourage the conversion of nat- ural forests to plantations. 208. http://treasury.worldbank.org/ Access date 08 April 2011. 209. Cancun Decision (Ad Hoc Working Group on Long-term Cooperative Action): http://unfccc.int/files/meetings/cop_16/application/ pdf/cop16_lca.pdf, Sections III.C, and Annexes I and II. Access date 09 April 2011. 58 | State and Trends of the Carbon Market 2010 Emissions from forests will now have to be ac- defined, but it is likely that preference will be given counted at the national level, possibly starting at the to offsets produced by states that have signed memo- subnational level as an interim measure. However, randa of understanding with California (so far, Acre the principles or objectives of the Cancun decision from Brazil and Chiapas from Mexico). will still need to be operationalized. The Subsidiary Body on Scientific and Technological Advice 4.4.1.2 Voluntary Forestry Offsets (SBSTA) is expected to develop modalities on the setting of Reference Emission Levels and the design In the voluntary markets, a number of smaller of measurement, reporting, and verification systems REDD+ projects are being developed by private and (MRV) and to propose guidance on the establish- public entities. Several standards are being applied, ment of information systems by developing coun- with the Verified Carbon Standard (VCS) becoming tries to report on safeguards. the main one. In Indonesia alone, more than 100 projects of different scales are under preparation. Even though the magnitude of finances required for REDD+ calls for the involvement of the private sector, In February 2011, the Kasigau Corridor REDD the role of markets in mobilizing funding for REDD+ project in Kenya, developed by Wildlife Works, is- still needs to be discussed under the UNFCCC. It is sued the first REDD carbon offsets under the VCS. clearly agreed that Phase l (national strategies and ca- The project issued 1.16 million offsets for the ini- pacity building) and Phase ll (implementation of strat- tial six-year monitoring period of its 30-year project egies and investment in demonstration activities) will life, representing 80 percent of the total 1.45 million be financed through additional public bilateral or ex- tons of GHG emissions avoided during the period. isting multilateral assistance, such as under Norway’s The project deposited 290,066 “buffer credits”—or International Climate and Forest Initiative, the Forest 20 percent of the net GHG benefit—to the VCS Carbon Partnership Facility (FCPF), the REDD+ pooled buffer account, where they will be held to Partnership, or the UN-REDD Programme. What is insure against the potential loss of offsets across all left open is the type of support that should be provid- projects in the VCS AFOLU portfolio. ed for Phase lll (development of result-based activities that are fully measured, reported, and verified). The Prior to this issuance, Wildlife Works had success- Ad Hoc Working Group on Long-term Cooperative fully developed its own REDD+ methodology and Action (AWG-LCA) was mandated to explore options had it approved by the VCS Program. Pursuant to and will report to the Durban Conference (COP 17). a financing agreement between BNP Paribas and It is likely that multiple channels will be proposed, Wildlife Works, BNP Paribas has the option to pur- recognizing the role of the private sector, including chase 1.25 million tons of these emission reductions through carbon markets, in addition to government over five years. assistance. Going forward, a key challenge for the REDD+ proj- 4.4.1.1 California—REDD+ Offset Potential ects and subnational programs will be to integrate them into the emerging national systems (in particu- The UNFCCC is not the only potential source of lar MRV), reference emission levels, and strategies. market creation for REDD+. The most advanced The integration of this increasing number of projects regulatory framework that could create demand for will demand two things: (1) high management ca- REDD+ is California’s cap-and-trade system, which pacity on the part of national governments and (2) is expected to become operational on January 1, an open and transparent approach in the way data 2012. The system, which will be linked to other re- and payments are handled to ensure that the system gional schemes within the United States and Canada, is credible and guarantee that local actors, including will allow offsets equal to 8 percent of total volume. indigenous peoples and local communities, are ap- propriately involved. It is expected that the Carbon The most favored source of international offsets is Fund of the Forest Carbon Partnership Facility REDD+. The eligibility criteria for REDD+ offsets (FCPF) will produce useful experience in this area. to enter the California system (such as baseline, so- cial, and environmental safeguards) are still to be State and Trends of the Carbon Market 2010 | 59 4.4.2 Sustainable Land Management— Smallholders and small-scale business entrepre- Agricultural Soil Carbon neurs are trained in diverse cropland management techniques, including cover crops, crop rotation, With nearly two times as much carbon in soil than compost management, and agroforestry. The farm- in the atmosphere, small changes in the level of car- ing practices both increase the yield of the land and bon in soils can drive large changes in atmospheric sequester carbon in the soil. carbon concentrations. Sustainable land manage- ment projects that increase the carbon content of The project is developing the Sustainable Agriculture soils represent a “triple win” for society: develop- Land Management Methodology under the VCS. ment, climate change resilience, and climate change The first validation was finalized in November 2010 mitigation. by Scientific Certification Systems. The project is currently undergoing the second validation. The Healthy and fertile croplands increase the productiv- BioCarbon Fund is leading the methodological ity of farms and the incomes of farming communi- work, together with Vi Agroforestry. It will purchase ties. In addition, cropland management techniques 150,000 emission reductions up to 2016. promote resilience to variations in climate, encour- aging stability and food security. Finally, the seques- tration of carbon in soils is a viable and quantifiable 4.5 CONCLUSIONS way to reduce atmospheric carbon. The sequestra- tion of carbon in soils is currently a neglected part of Long-term carbon price signals are fundamental for the climate solution, yet it is important for mitiga- the deployment of the currently not viable low-car- tion, adaptation, and rural communities. bon technologies, as well as for the development of new low-carbon technologies necessary to support In 2010, a groundbreaking project in Kenya brought transformation at scale. Well-developed policies and the potential for carbon sequestration in soils to the regulations, concessional finance, and ODA fund- forefront of carbon finance. The Kenya Agricultural ing are all necessary in the overall climate finance Carbon Project is the first project in Africa that sells package. However, harnessing private sector capital carbon offsets from a sustainable land management is vital for the transformation to a low-carbon soci- project, improving the livelihoods of rural commu- ety. Despite all uncertainties in the future market, nities while tackling climate change. the development of assets, including new categories, continues, thus confirming the belief that market in- Implemented by the Swedish NGO Vi Agroforestry, struments are still considered as an efficient way to the project is located on over 40,000 hectares in the mobilize private capital for financing climate action. Nyanza Province and Western Province of Kenya. 60 | State and Trends of the Carbon Market 2010 5 SECTION State and Trends of the Carbon Market 2010 | 61 5 Outlook - Demand and Supply Balance DESPITE SIGNS OF ECONOMIC RECOVERY and rising emissions the demand outlook remains slim in the period to 2012. It is anticipated that buyers will mostly meet their needs through purchases of Assigned Amount Units (AAUs) and secondary Certified Emission Reductions (sCERs) (further details in Section 5.1). Beyond 2012 the outlook for the carbon market is complex and depends on the likely commitment of major emitters and the mechanisms adopted at the domestic and international levels to achieve these commitments. Therefore, the scenarios used in Section 5.2 have been developed from the market sentiment (Section 1.4) and specific country and regional initiatives (Section 2). There is a great deal of uncertainty associated with forecasting demand, as much depends on uncertain future frameworks for emission reductions. 5.1 DEMAND AND SUPPLY BALANCE THROUGH TO 2012 The following sections investigate demand for “ Beyond 2012 the outlook for the carbon market is complex Kyoto assets, including demand from governments and depends on the likely and private sector entities,210 as well as supply under the three Kyoto Mechanisms. Residual demand for commitment of major emitters Kyoto assets continues to shrink, currently estimated and the mechanisms adopted at at 136 MtCO2e, virtually all from European govern- ments. This is a 41 percent decrease from last year’s the domestic and international estimate. levels to achieve these 5.1.1 Sovereign Demand Demand estimates for Kyoto assets from Annex B commitments. ” governments remain virtually unchanged over 2010. Sovereign gross demand for Kyoto assets is currently estimated at around 437 MtCO2e through 2012, with EU-15 accounting for 72 percent of the total, Japan 23 percent of the total, and all other Annex B governments 5 percent (Table 12). 210. Those are entities covered by existing or anticipated domestic climate regulation, like the EU ETS or the NZ ETS, or participants to sectoral agreements, like the Keidanren Voluntary Action Plan in Japan. For the vast majority, they belong to the private sector; however, some public installations (like hospitals under the EU ETS) are also regulated. 62 | State and Trends of the Carbon Market 2010 Table 12. Supply Potential Demand from Industrialized Potential Supplies (MtCO2e) and Demand in Countries (MtCO2e) Perspective–Kyoto Market Balance, Country or entity Kyoto assets demand Official target* 2008–12 EU 1,065 Potential GIS >1,500 Government (EU-15) 315 Ukraine 500–700 Private sector (EU ETS) 750 Russian Federation 200 Czech Republic 120 Other EU-10 600 Japan 300 Government of Japan 100 Japanese private sector 200 Rest of Annex B 27 CDM & JI 1,366 range: 1,238–1,487 Government 22 CDM 1,152 1,024–1,287 Private sector 5 JI 214 200–250 TOTAL 1,392 Government 437 Private Sector 955 *: These numbers correspond to the amounts of AAUs governments intend to sell. They are much lower than the whole amount of excess AAUs, now estimated at more than 10 billion tCO2e over the first commitment period, with Russia accounting for half, Ukraine one-quarter, and Poland one-fifth. Updated emissions projections that reflect the global accident at the Fukushima nuclear complex. This economic downturn and recovery show that the natural disaster may lead Japan to use more carbon- EU-15, and the EU as a whole, continue to expect intensive fossil fuels to compensate for the loss of to collectively meet and overachieve their collec- nuclear capacity. As a result, it is expected that car- tive Kyoto target with current policies and mea- bon- and energy-intensive reconstruction activities sures in place.211 However, it cannot be assumed will increase the carbon-intensity of output in Japan, that overachievement of the collective target will though this increase will likely be offset by subdued allow certain Member States to cover shortfalls economic growth over the coming months. from other Member States. Therefore some EU-15 members plan to use the Kyoto Protocol Flexibility Safety concerns around the globe may also result in Mechanisms to ensure that their individual Kyoto a substantial reduction in nuclear power generation, targets are met. As a result, demand for Kyoto as- increasing carbon emissions in other countries212and sets could fall in the range of 300–330 MtCO2e, leaving analysts still to agree on the long-term con- compared to the 465 MtCO2e initially estimated. So sequences on the carbon markets from Japan’s di- far about 270 million CERs and ERUs (nominal) as sasters. In this context, gross demand for Kyoto as- well as 54 million AAUs have been purchased. sets from the government of Japan is maintained at 100 MtCO2e, its initial public procurement goal. Carbon markets are struggling to understand the Over 2010, Japan purchased 4 MtCO2e of AAUs, implications of the deadly earthquake and tsunami bringing total acquisitions to 97.8 MtCO2e since the that struck Japan’s northeast, followed by the nuclear commencement of the buying program in 2006.213 211. “[W]ith the current policies and measures in place, average EU-15 GHG emissions over the full commitment period 2008–12 could reach a level of 10.4 percent below base-year levels.” See European Environment Agency (2010). Tracking progress towards Kyoto and 2020 targets in Europe, p. 31. 212. On March 15, 2011, Germany decided to temporarily shut down 7 of its 17 nuclear power plants while a safety review is conducted. Their permanent phase-out could increase ETS emissions in the country by at least 250 Mt over 2011–20. The complete shutdown of all reactors could push emissions by 370Mt over the same period. Source: Deutsche Bank. “German Nuclear Policy: Debate Wide Open Again.” Carbon Emissions, March 15, 2011. 213. As per http://www.meti.go.jp/english/press/2011/0401_06.html Access date 18 April 2011. State and Trends of the Carbon Market 2010 | 63 Gross demand from other Annex B governments could market during the transition from Phase II to Phase III. amount to 22 MtCO2e, mainly through Norway and Changes in the generation mix, brought by shifts in Switzerland acquisition programs, of which a sub- Germany’s nuclear energy policy or overheating in stantial part has been completed to date, possibly global energy prices for instance, could further push 25 MtCO2e for Norway (Nominal)214 and nearing compliance demand from power sector installations. the 12 MtCO2e purchasing target for Switzerland Airlines will face auctioning in their first year un- (Nominal).215 Australia and New Zealand continue to der the EU ETS, leading to an expected shortfall of expect to meet their Kyoto obligations through do- about 50 MtCO2e against free allowances in 2012, mestic policy measures and carbon sinks.216 to be filled by CERs and ERUs (up to 32 MtCO2e), or Aviation EU Allowances (See Section 2.1). 5.1.2 Private Sector Demand So far EU ETS participants have contracted approxi- Gross demand from private entities has been revised up mately 1.6 billion CERs and ERUs (nominal) with 28 percent from last year, to 955 MtCO2e, with de- CERs from HFC and adipic acid projects amount- mand in the EU ETS accounting for 79 percent of the ing to about 25 percent of volumes. Due to the ban total. The main reason for this increase is the preferen- of CERs from HFC and adipic acid projects in Phase tial surrender of CERs and ERUs (instead of EUAs) by III, installations are likely to surrender offsets over and EU ETS operators in response to the EC’s qualitative above their compliance shortfall and bank surplus al- restrictions on the eligibility of offsets in Phase III. lowances instead. In this context, estimates of CDM and JI use over Phase II average 750 MtCO2e, of which Analysts expect the EU ETS to be long over Phase II, compliance needs may represent only a fraction. with an overall surplus of about 1,280 MtCO2e to be banked, in the form of allowances, including remain- Private sector companies in Japan have report- ing reserves and set-asides, and unused offsets.217 It is edly contracted more than 400 MtCO2e in CERs, also expected that some installations—primarily utili- ERUs, and AAUs that can be surrendered under the ties and airlines, which enter the scheme in 2012— Keidanren Voluntary Action Plan, which should will be short. The power sector shows the largest amply cover their estimated needs of 200 MtCO2e. compliance shortfall of all ETS-covered sectors, being There are estimates that the prolonged outage of short against free allowances by approximately 500 nuclear capacity in Japan could create an additional MtCO2e cumulative since 2008.218 demand of 60–70 MtCO2e.219 It remains to be seen, given the circumstances, to what extent private com- Additional demand could come from generators panies would be required to cover the gap or wheth- that start to hedge their future exposure in Phase III er force majeure would be invoked. as a result of tighter caps and increased auctioning. Depending on the schedule of anticipated sales or auc- Exploratory demand from installations covered un- tions of Phase III allowances, this hedging behavior der the NZ ETS,220 the Swiss ETS and other ini- is expected to induce some volatility in the EU ETS tiatives under development such as California or 214. Norway is likely to meet its Kyoto target (+1 percent) solely through domestic policy and measures. The demand for KMs stems from its long-term commitment to carbon neutrality, including an overachievement of its Kyoto target by 10 percent. 215. This includes an extra 2 MtCO2e to account for delivery risk. All in all, around 7 million CERs and ERUs only (from 10 initially planned) could be required to bridge the Kyoto gap in Switzerland, factoring in policies and measures as well as carbon sinks. 216. See Department of Climate Change and Energy Efficiency (2010). Australia’s emissions projections, and New Zealand’s net position under the Kyoto Protocol (updated March 17, 2011) at http://www.mfe.govt.nz/issues/climate/greenhouse-gas-emissions/net-position/ index.html Access date 18 April 2011. 217. Barclays Capital. Monthly Carbon Standard, April 11, 2011: long position over Phase II: 470 MtCO2e, use of CERs and ERUs over Phase II: 700–900 MtCO2e; Société Générale. Carbon Specials, April 7, 2011: long position over Phase II: 520 MtCO2e, use of CERs and ERUs over Phase II: 780 MtCO2e. 218. Based on verified emissions data for 2008 and 2009 and preliminary emissions data for 2010. 219. Barclays Capital. Monthly Carbon Standard, April 11, 2011: 60 MtCO2e; Deutsche Bank. “Japan’s Quake & The Implications for Commodities.” Commodities Special Report, March 14, 2011: 70 MtCO2e. 220. Though a significant number of participants expect to be short under the NZ-ETS (41 percent following Point Carbon (2011). Carbon 2011), being in compliance should not be that much of an issue given the transitionary measures and the expected abundant supply of New Zealand Units, likely to be nearly double the domestic demand for units between 2008 and 2012. See New Zealand Emissions Trading Scheme Review 2011, op. cit., p. 17. 64 | State and Trends of the Carbon Market 2010 Australia, might be in excess of 5 MtCO2e depend- ing on price levels and rules beyond 2012. 5.1.3 Supply Through to 2012 “ Estimated residual demand of 136 MtCO2e of Kyoto assets over the next two years, virtually all from European About 1,150 million CERs are expected be issued pre-2013,221 of which slightly more than half should be issued to HFC and adipic acid projects. Supply projections are up 12 percent on average since last governments. ” Sustained activity in the AAU market continues to year, reflecting both improved timelines for regis- encourage countries to market their GIS. For exam- tration (most notably through Cancun’s decision ple, Slovakia is proactively trying to sell 27 million on start of the crediting period) as well as uninter- AAUs during 2011. Countries have announced in- rupted growth in the pipeline of CDM projects. At tentions to sell over 1.5 billion AAUs (see Table 12). the same time, lead time to issuance continues to Some of these AAUs may come from existing Green be a significant risk to pre-2013 supply. Potential Investment Schemes. This supply is far larger than bottlenecks and delays are possible as project devel- the anticipated demand. Uncertainties regarding the opers rush to have verification processed on time for bankability of AAUs, which could play a decisive delivery of CERs valid for compliance with EU ETS role in determining the commitment ambition of Phase II obligations. Parties under a future international climate change agreement, are likely to further reinforce the imbal- First, the COP/MOP decision in Cancun to move ance and affect market dynamics negatively. forward the starting date of the crediting period222 has the potential to add three to six months worth 5.1.4 Residual Demand—136 MtCO2e of CERs (or the average time from request of reg- istration to effective registration) to a project ex- Expected gross use of Kyoto assets now stands at pected deliveries. Second, over the past 15 months 1.39 billion tCO2e over 2008–12 (up 14 percent (Jan. 10–Mar. 11), the inflow of projects entering from last year), with approximately 70 percent of the CDM pipeline averaged 112 new projects per demand coming from the private sector. The three month, the highest rate ever—perhaps reflecting the Kyoto Flexibility Mechanisms will be required to fact that project developers are rushing to get proj- meet the demand for Kyoto assets, which could in- ects registered before 2013 in light of EU eligibility crease if deliveries from CDM and JI are lower than restrictions for Phase III. anticipated, if the performance of domestic policies and measures disappoints, if carbon sinks have been Market analysts’ project around 215 million ERUs overestimated, or if economic recovery is stronger should to be issued through 2012. This is an in- than expected. Adjusting the approximate 2.4 bil- crease over last year’s estimate and is largely a result of lion CERs and ERUs contracted (nominal) for risk Russian efforts to increase supply. Russia is projected of underdelivery and accounting for AAU transac- to account for approximately 50 percent of ERUs is- tions as well as some secondary transactions by gov- sued through 2012 (see Section 4.1 for more details). ernments lead to an estimated residual demand of 136 MtCO2e of Kyoto assets over the next two years, virtually all from European governments (Table 13). 221. Barclays Capital. Monthly Carbon Standard, April 11, 2011: 1.14 billion CERs and 250 million ERUs over 2008–12; CDC Climat Research (2011). Assessment of supply-demand balance for Kyoto offsets (CERs and ERUs) up to 2020. Climate Brief #5: 1.12 billion CERs and 205 million ERUs over 2008–12 (Conservative estimate that does not account for new projects possibly entering the CDM pipeline after March 2011); Deutsche Bank: Personal communication: 1.29 billion CERs and 200 million ERUs over 2008–12 (Secured supply from the first crediting period of projects registered as of January 2011); Point Carbon, Carbon Program Manager (accessed April 14, 2011): 1.19 billion CERs and 202 million ERUs over 2008–12; Société Générale. Carbon Drivers, April 11, 2011: 1.02 billion CERs and 214 million ERUs over 2008–12. 222. The CDM Executive Board was requested to revise the procedures for registration to allow the effective registration date/start of crediting period “to be the date on which a complete request of registration has been submitted by the designated operational entity where the project activity has been registered automatically.” State and Trends of the Carbon Market 2010 | 65 Potential demand Contracted CERs and ERUs AAUs Residual demand Table 13. Potential nominal adjusted for performance Demand, (MtCO2e) (MtCO2e) (MtCO2e) (MtCO2e) (MtCO2e) Contracted Supply, and EU 1,065 1,868 883 54 129 Residual Government (EU-15) 315 270 132 54 129 Demand, Private sector (EU ETS) 750 1,598 751 0 0 (-1) 2008–12 Japan 300 372 180 191 3 Government of Japan 100 34 21 76 3 Japanese private sector 200 338 159 115 0 (-74) Rest of Annex B 27 40 22 1 5 Government 22 37 21 1 1 Private sector 5 3 1 0 4 Total 1,392 2,280 1,085 245 136 Government 437 341 174 130 133 Private sector 955 1,939 911 115 4 Note: Numbers may not add up due to rounding. A portion of the purchases attributed to the European private sector relates to portfolios of intermediaries that are available for secondary transactions. In addition to the volumes reported above, about 173 million tons (nominal) are contracted but not attributed, and are very likely in the hands of intermediaries. They could represent about 83 million tons also available for secondary transactions, with public or private entities. CDM projects contracted in the next few months are not yet fully specified, with uncertainties as to the will be unlikely to deliver large volumes before 2013, amount of credits that could be used to meet compli- and thus governments may have to purchase AAUs ance obligations, eligible mechanisms or standards, to cover their residual Kyoto shortfalls and underde- and further qualitative restrictions (for example, on livery of CDM and JI. Governments may also wish country of origin or technology). To deal with these to secure some volumes through secondary transac- uncertainties about the supply-demand balance in the tions, with the advantage of being able to choose the carbon market over 2013–20, projections of supply types of projects generating the CERs, as is already are compared with estimates of demand for emission the case under a number of procurement programs. reductions derived from three scenarios, reflecting Approximately 300 million CERs are in the hands more or less ambitious collective action. of intermediaries and could be available. The price and quality of assets will likely determine sovereign The three scenarios (detailed in Table 14) encom- compliance strategy. pass: (1) enacted and proposed initiatives aligned with unconditional pledges under the Copenhagen Accord, (2) the full implementation of enacted and 5.2 WILL THERE BE ENOUGH EMISSION proposed initiatives aligned with higher pledges un- REDUCTIONS GENERATED IN der the Copenhagen Accord, and (3) the introduc- DEVELOPING COUNTRIES AFTER 2012? tion of domestic cap-and-trade schemes in most of Annex I countries to deliver on pledges at the higher Estimating the future demand for emission reduc- end of commitments under the Copenhagen Accord. tions generated in developing countries remains a delicate and heroic exercise as many initiatives look- These scenarios only look at the EU and other ing beyond 2012 are still at the proposal stage and will current OECD Annex B countries223 and omit likely be influenced by the outcome of the ongoing some Annex I countries, such as Belarus, Croatia, negotiations. Key features of many of these proposals Kazakhstan, Monaco, Russia, Turkey, and Ukraine. 223. To the exception of Cyprus and Malta, as well as Liechtenstein, as they join the EU effort. 66 | State and Trends of the Carbon Market 2010 Some of the omitted countries have pledges under the percent of total demand for scenarios 1 and 2, the Copenhagen Accord.224 There are also some non-An- EU Climate and Energy Package represents thus far nex I countries—such as Brazil, Chile, China, and the the only substantial source of demand for offsets Republic of Korea—that are contemplating new mar- from non-Annex I countries beyond 2012. Other ket mechanisms, including emissions trading, which potential sources remain speculative at this stage. may, at some point, generate possible demand for (do- mestic) offsets. This demand is not considered here. Importantly, these estimates of demand correspond to the maximum theoretical demand, given expected Depending on ambition of collective action, demand shortfall and rules governing the use of offsets (quali- for emission reductions generated in developing tative and quantitative restrictions). In other words, countries could easily surpass 2 billion tCO2e over they are not estimates of the actual use of offsets, 2013–20 (or twice as much as demand for KMs over which depends on availability and price (relative to 2008–12), possibly ramping up to 3 billion tCO2e other options, for example, AAUs or their successor, or more (see Table 14). Accounting for around 60 allowances from other schemes, price caps, and so on). Table 14. Country Scenario 1: Enacted and Scenario 2: Enacted and Scenario 3: ETS in major Annex Scenarios (group of) proposed initiatives, uncon- proposed initiatives, higher I countries, higher end of of Potential ditional pledges pledges Copenhagen Accord pledges* Demand for Offsets Description Potential Description Potential Potential demand in 2020 Generated in demand demand (MtCO2e) non-Annex I (MtCO2e) (MtCO2e) Countries 2013– EU, as well 20 percent below 1,750† 30 percent below 2,550† 20 (MtCO2e)225 as Iceland, 1990, with differen- 1990, with differen- Liechtenstein tiation EU ETS and tiation EU ETS and and Norway effort sharing effort sharing New Zealand NZ ETS: 10 percent 77 NZ ETS: 20 percent 106 below 1990 below 1990 Australia CPRS (2015): 5 516 CPRS (2015): 15 637 All countries deliver on percent below 2000 percent below 2000 Copenhagen Pledges resulting in aggregate reductions in Annex I GHG emissions of 17 percent below 1990 levels) Japan Between 25 and 539 25 percent below 539 zero percent below 1990 1990 Switzerland 20 percent below 28 30 percent below 55 1990, with ETS and 1990, with ETS and other measures other measures United States No U.S. federal 12 No U.S. federal ETS, 24 & Canada ETS, California and with full WCI (incl. limited WCI, RGGI‡ California), RGGI‡ TOTAL 2,922 3,911 1,500–2,000 *: Demand under Scenario 3 is only for year 2020, thus not comparable with the first two scenarios. †: Already accounts for an inflow in the EU ETS of 750 million CERs and ERUs during Phase II. ‡: No significant demand is expected to come from RGGI. 224. No demand for carbon assets is expected from Russia and Ukraine (the two largest emitters from the countries listed above), as their pledges are above their baseline projection. See den Elzen, M. G. J. et al. 2010. Evaluation of the Copenhagen Accord: Chances and risks for the 2°C climate goal. Netherlands Environmental Assessment Agency (PBL), The Netherlands, and Ecofys, Germany. 225. For detailed assumptions see Appendix 1. State and Trends of the Carbon Market 2010 | 67 Also, this theoretical demand is not to be met systemat- and agree upon a common set of rules and modalities, ically through CDM and JI, as there is political support including baseline setting and MRV requirements. in all major developed countries for the Cancun de- cision to establish new market mechanisms under the In this context, a streamlined, cost-effective, and effi- UNFCCC to “enhance the cost effectiveness of, and cient CDM will still likely play a lasting role on the sup- to promote, mitigation actions.” For instance, Japan is ply side (hence our focus). It could serve as a platform preparing a bilateral offsetting mechanism with 15 pi- for those countries willing to transition toward new lot projects in nine countries that could co-exist along mechanisms, drawing on experience, achievements, current Kyoto Mechanisms; EU is supporting sectoral and capacity built under the CDM. Alternatively, it approaches that could represent an increasing share of could remain a central project-based mechanism, serv- its demand for emission reductions; California may be ing the low-carbon development priorities of those open to international offsets from sectors and regions, countries preferring not to transition to new mecha- including from REDD activities, which so far are out- nisms in the near future. After all, programmatic ap- side the scope of the CDM. proaches such as the CDM Programme of Activities (PoA) are already helping scale up mitigation efforts. Estimates of supply (Table 15) are forecasts for CDM and JI only. None of these projections assumes con- About 2.5 billion offsets could be generated over 2013– tinuation of JI beyond CP-1. They do not include sup- 20, or twice as much as expected supply from CDM ply under new approaches or mechanisms, still under and JI pre-2013. For the most part (50–70 percent), negotiation. While there appears to be keen interest by this supply is expected from projects registered before several developing countries to participate in such new 2013, highlighting the strain of the lack of a predictable mechanisms, it will take some time to discuss, elaborate, and scaled-up demand on new origination. HFC and pre-2013 post-2012 Cumulative (up to 2020) Table 15. Estimates of Point Carbon Potential Supply CDM-EU ETS eligible 1,186 1,875 3,061 Under the CDM CDM-other 6 409 415 and JI up to 2020 ERU 202 202 (MtCO2e) TOTAL 1,394 2,285 3,679 Barclays CDM-EU ETS eligible 1,140 1,741 2,881 CDM-other 1,043 1,043 ERU 250 250 TOTAL 1,390 2,784 4,174 CDC Climat Research † CDM-EU ETS eligible 1,115 2,534 3,649 CDM-other 373 373 ERU 205 205 TOTAL 1,320 2,907 4,227 Deutsche Bank* CDM-EU ETS eligible 1,287 939 2,226 CDM-other 2 437 439 ERU 200 200 TOTAL 1,489 1,376 2,865 † Conservative estimate that does not account for new projects possibly entering the CDM pipeline after March 2011, nor for possible renewal of crediting period for already registered projects. *Secured supply from the first crediting period of projects registered as of January 2011. 68 | State and Trends of the Carbon Market 2010 N2O credits to be banned from the EU ETS represent participation. For the latter to materialize, it is nec- about one-third of 2013–20 supply. Given investment essary to simplify the procedures for project approval barriers, the share of supply from projects registered in and credit issuance (including for programmatic ap- LDCs post-2012 is likely to remain extremely limited, proaches to enable reaching micro-scale activities) between 10 and 75 MtCO2e (depending on sources) and increase the eligibility of land-based agriculture or systematically less than 5 percent. Also important to (including remedy the current temporary crediting note, two downward risks to these supply estimates are approach which penalizes forestry projects). the possible rejection of application for crediting period renewal and the revision of baselines. 5.3 CONCLUSIONS Available supply of EU ETS eligible offsets over 2013–20 may reach about 2 billion tCO2e, compris- Beyond 2012, the main constraint to the carbon mar- ing approximately 200 million tCO2e remaining from ket is perhaps a lack of demand beyond current initia- pre-2013 and 1.8 billion tCO2e generated post-2012 tives, with no further encouragement to build up a sub- (almost entirely from projects registered before 2013). stantial and credible supply. For both developed and In addition, at least 500 MtCO2e of non-EU ETS eli- developing countries, this could be a missed opportu- gible offsets (potentially up to 1 billion tCO2e) could nity to benefit from market instruments to mobilize re- come online over 2013–20.226 This could be sufficient sources and engage private sector in climate action. The to cover specific demand from EU ETS operators use of market mechanisms can contribute to lower the as well as demand from governments under the EU cost of achieving sustainable goals, result in additional Climate and Energy Package (even under a tighter resources, and send a price signal to encourage less car- cap, in line with an EU 30 percent target). bon-intensive lifestyles and investment decisions. The availability of a substantial and credible offset Financing needs for green growth and implementing supply could increase the likelihood of cost-effectively low-emission development strategies are huge, in the achieving more ambitious emission reduction targets. hundreds of billions annually for developing countries Under full implementation of Scenario 1 (let alone alone. Mobilizing sufficient resources in a predictable Scenario 2 or 3), potential demand for international and sustainable manner requires a combination of offsets over 2013–20 exceeds potential supplies, which sources-both existing and innovative ones, both pub- have been so far heavily constrained. This could imply lic and private. The Secretary-General’s High-Level that price of offsets beyond 2012 could be sustained, Advisory Group on Climate Change Financing (AGF) with hopes that higher prices will stimulate supply concluded that carbon markets can play a valuable role and encourage financial innovation to turn future in the mobilization of $100 billion per year from 2020, carbon revenues into upfront financing. in conformity with the pledges under the Copenhagen Accord. With predictable, long-term, and ambitious These preliminary estimates also underscore the targets, financial flows through improved market need to scale up supply to avoid future imbalances mechanisms to developing countries could reach $30– in the carbon market. Supply can be scaled up by 50 billion a year by 2020, further committing an equiv- (i) strengthening capacity and making mechanisms alent amount of foreign private investment to climate more predictable and efficient; (ii) broadening the action. Predictability and ambition, ingenuity and scope of the carbon market, looking at underserved reforms, capacity—all are needed to scale up carbon sectors and project-types; and (iii) facilitating LDCs markets and maximize their transformational impact. 226. Some of these credits could become eligible, should the EU enter into bilateral agreements with non-LDC countries. So far no such bilateral agreement has been signed. State and Trends of the Carbon Market 2010 | 69 70 | State and Trends of the Carbon Market 2010 Methodology The data used in this report was collected from a The size of the global carbon market in 2010 has combination of sources, including a survey of mar- been derived from the growth rate between 2009 ket participants conducted by the World Bank’s and 2010 of each market segment (for example, Carbon Finance Unit between March 21 to April 1, primary CER, other project-based markets, AAUs, 2011; semi-structured interviews of selected market EUAs, and other allowance markets) drawing on participants, policy makers, and regulators; and a information obtained primarily from Thomson desk study of major carbon-industry publications,227 Reuters Point Carbon and Bloomberg New Energy legislation, regulations, and media reports. The re- Finance. The value of the voluntary transactions port has written contributions kindly provided by was obtained from data provided by Ecosystem Ecosystem Marketplace and Bloomberg New Energy Marketplace. Since the original information from Finance (voluntary and pre-compliance activi- Thomson Reuters Point Carbon and Bloomberg ties), Thomson Reuters Point Carbon (California), New Energy Finance was provided in euros, the European Commission (international markets), and impact of the $/euro exchange rate in the same pe- Deutsche Bank (international markets). riod was eliminated and the US$-based results were applied to the values of each market segment, as The survey addressed selected market participants calculated by the World Bank in 2009. When ap- involved in several activities and representing the plicable, the unweighted average from the sources various sectors of the carbon market. The survey was used, although some adjustments were made as contained 26 questions and covered market senti- deemed appropriate. ment and Kyoto Protocol flexibility mechanisms. The results of the survey were used to augment and Prices and values are primarily expressed in nomi- corroborate information collected from the desk nal $ per tCO2e, unless indicated otherwise. An av- study and semi-structured interviews. Some of the erage annual exchange of €1 = $1.328 for 2010 was results of the survey are provided in this report, in applied. The cutoff date for information is April the appropriate sections. 15, 2011. A ton (abbreviated as “t”) refers to a met- ric ton (1,000 kg). Unless said otherwise, the symbol $ implies U.S. dollars. 227. Including online sources such as Carbon Finance (www.carbon-financeonline.com), Joint Implementation Quarterly (www.jiqweb.org), PointCarbon (www.pointcarbon.com), as well as Carbon Positive (www.carbonpositive.net), CDC Climat Research (www.cdcclimat.com), the Climate_L list (www.iisd.ca), IDEAcarbon (www.ideacarbon.com), Ecosystem Marketplace (www.ecosystemmarketplace.com), the CDM and JI pipeline databases and analyses maintained by UNEP Risoe and IGES, and Web sites of market players (DNAs, DOEs, proj- ect developers and aggregators, exchanges and trading platforms, financial institutions and brokers, regulators, carbon purchasing funds and facilities, public procurement programs, and companies facing compliance obligations). One should also mention other resources, such as reports prepared by financial institutions, such as analyses by Barclays Capital, Deutsche Bank, and Société Générale, that have been made kindly available to the authors. State and Trends of the Carbon Market 2010 | 71 Appendix 1. Assumptions for Estimates of Potential Demand for Offsets from non-Annex I Countries EU: Under the EU Climate and Energy Package, the For non-ETS covered sectors, the Climate and Energy EU commits to cut its GHG emissions by 20 percent Package translates into cuts of 10 percent (or more) be- below 1990 levels, possibly tightening to 30 percent low 2005 levels by 2020. Offsets can be used to cover depending on developments in climate negotiations. about one-third of the effort in the 20 percent sce- For the EU ETS, this translates into further tighten- nario, estimated to represent about 800 MtCO2e over ing of the cap from an average 6 percent below 2005 2013–20. In the 30 percent scenario, offsets can in levels over 2008–20 to 21 percent by 2020 (or more principle be used to cover half of the additional effort, in the 30 percent scenario), with a corresponding leading to a total demand of about 1,100 MtCO2e. shortfall of about 2,500 MtCO2e over 2013–20 in No restriction applies so far to the use of offsets. the 20 percent scenario (resp. 3,500 MtCO2e in the 30 percent scenario).228 New Zealand: The NZ ETS continues to expand its coverage, with synthetic gases and waste joining in The total amount of offsets that can be used over 2013 and agriculture in 2015. The cap of the scheme 2008–20 is estimated at 1,700 MtCO2e in the 20 is set in line with the country international commit- percent scenario (2,200 MtCO2e in the 30 percent ment—to reduce emissions by 10 percent below 1990 scenario). On aggregate, the amount of offsets that levels by 2020 or, if a comprehensive global agreement can be surrendered during Phase III corresponds to is reached, by 20 percent. This could translate into a the difference between the overall amount allowed shortfall of 75 to 105 million tons over 2013–20, ac- over Phases II and III jointly minus what has been counting for a limited uptake of forestry.229 already surrendered during Phase II. The following qualitative restrictions apply with regard to the use Australia: Following announcements earlier in 2011, of CERs/ERUs against Phase III obligations: Australia implements economy-wide carbon pricing for a period of three years, starting 2013, with a view - to transitioning to an emissions trading scheme, sim- struction of HFC-23 and N2O from adipic acid ilar in its design to the Carbon Pollution Reduction production are banned from the EU ETS. CP-1 Scheme (CPRS). The cap is set in line with Australia’s offsets will still be allowed until the end of April pledges under the Copenhagen Accord: 5 percent to 2013 against Phase II obligations. 15 percent below 2000 levels by 2020, depending on climate negotiations. One assumes that 75–80 project types can be banked and surrendered. percent of the country’s emissions are capped (that is, forestry and agriculture are excluded) and that from a project registered before end of 2012 or unlimited use of offsets is allowed. Following recent from a project based in an LDC if registered projections by Australia, this could represent a cu- after 2013. mulative shortfall over 2015–20 ranging from 520 to 640 MtCO2e, depending on ambition.230 228. This includes also aviation. Source: Barclays Capital. Monthly Carbon Standard, April 11, 2011 229. Source: own calculation based on New Zealand Fifth National Communication. 230. Own calculation based on Department of Climate Change and Energy Efficiency (2010). Australia’s emissions projections. 72 | State and Trends of the Carbon Market 2010 Japan: As plans for a mandatory ETS in Japan are Northern America: Demand of offsets under delayed, one simply assumes here that offsets could California’s cap-and-trade scheme could total 233 be used up to 50 percent to fill the gap to the -25 MtCO2e over 2012–20 (see Section 2.1). Estimates percent conditional pledge. Accounting for sinks, of use for offsets from the full WCI are hardly slightly this could correspond to a cumulative demand for higher, at 235 MtCO2e.233 Importantly, however un- offsets of 540 MtCO2e over 2013–20.231 certain such estimates are, it is unclear which share of demand could be sourced internationally. For this ex- Switzerland: As its main additional climate policies ercise, it is set at 10 percent. Given abundant overallo- and measures, Switzerland implements an ETS simi- cation in RGGI, no demand for international offsets lar in design to the EU ETS. This could result in a is expected over the decade from the scheme. cumulative demand for offsets from covered entities over 2013–20 of 2.3 MtCO2e in the 20 percent sce- Higher end of Copenhagen Accord pledges: nario, reaching 4 MtCO2e in the 30 percent scenar- Estimates here are obtained from the Report of the io. Another large source of demand for offsets stems Secretary-General’s High-Level Advisory Group on from the obligation for producers and importers of Climate Change Financing (AGF). They correspond fossil fuels to offset 25–30 percent of CO2 emissions to the medium price scenario, based on the higher in the 20 percent scenario (gearing up to 40-45 per- end of Accord pledges, which assumes that most cent in the 30 percent scenario). It is estimated that Annex 1 countries introduce domestic cap-and- this measure could generate a demand of 25 to 50 trade schemes and that government-to-government MtCO2e of international offsets.232 AAU trade occurs. Based on these assumptions, the potential demand for offsets in this scenario ranges between 1,500 and 2,000 MtCO2e in 2020.234 231. Assuming Japan’s emissions grow in line with projections by the U.S. DoE Energy Information Administration’s International Energy Outlook 2010 (High oil price case). Carbon sinks are maintained at 20 MtCO2e (that is, their planned use under the Kyoto Protocol), though they could decrease as indicated by http://unfccc.int/files/kyoto_protocol/application/pdf/awgkplulucfdatajapan051109.pdf. 232. Own calculation based on Switzerland Fifth National Communication. 233. Western Climate Initiative (2010). Updated Economic Analysis of the WCI Regional Cap-and-Trade Program 234. As per http://www.un.org/wcm/webdav/site/climatechange/shared/Documents/AGF_reports/Work_Stream_8_%20Carbon%20 markets.pdf. State and Trends of the Carbon Market 2010 | 73 Glossary Accredited Independent Entity (AIE): Accredited represents the right to emit one metric ton of carbon independent entities (AIEs) are independent audi- dioxide equivalent. tors that assess whether a potential project meets all the eligibility requirements of the JI (determination) Banking or carry over: Compliance units under the and whether the project has achieved greenhouse gas various schemes to manage GHG emissions in ex- emission reductions (verification). istence may or may not be carried over from one commitment period to the next. Banking may en- Additionality: A project activity is additional if an- courage early action by mandated entities depend- thropogenic GHG emissions are lower than those ing on their current situation and their anticipations that would have occurred in the absence of the proj- of future carbon constraints. In addition banking ect activity. brings market continuity. Banking between Phase I and Phase II of the EU ETS is not allowed but is al- Afforestation: The process of establishing and grow- lowed between Phase II and further Phases. Some re- ing forests on bare or cultivated land, which has not strictions on the amount of units that can be carried been forested in recent history. over may apply: for instance, EUAs may be banked with no restriction while the amount of CERs that Annex I (Parties): The industrialized countries listed can be carried over by a Kyoto Party is limited to 2.5 in Annex I to the UNFCCC were committed to re- percent of the assigned amount of each Party. turn their greenhouse gas emissions to 1990 levels by 2000. They currently include Australia, Austria, Baseline: The emission of greenhouse gases that Belarus, Belgium, Bulgaria, Canada, Croatia, Czech would occur without the policy intervention or proj- Republic, Denmark, Estonia, Finland, France, ect activity under consideration. Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Liechtenstein, Lithuania, Luxembourg, Biomass Fuel: Combustible fuel composed of a Monaco, the Netherlands, New Zealand, Norway, biological material, for example, wood or wood by- Poland, Portugal, Romania, Russian Federation, products, rice husks, or cow dung. Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, Ukraine, the United Kingdom, and the California Global Warming Solution Act AB32 United States, as well as the European Economic (AB32): The passage of Assembly Bill 32 (California Community. All but Turkey are listed in Annex B. Global Warming Solution Act AB32) in August 2006 sets economy-wide GHG emissions targets Annex B (Parties): The 39 industrialized countries as follows: Bring down emissions to 1990 levels by (including the European Economic Community) 2020 (considered to be at least a 25 percent reduc- listed in Annex B to the Kyoto Protocol have com- tion below business-as-usual) and to 80 percent of mitted to country-specific targets that collectively 1990 levels by 2050. Covering about 85 percent of reduce their GHG emissions by at least 5.2 percent GHG emissions, a cap and trade scheme (still under below 1990 levels on average over 2008–12. design) would be a major instrument, along with renewable energy standards, energy efficiency stan- Assigned Amount Unit (AAU): Annex I Parties dards for buildings and appliances as well as vehicle are issued AAUs up to the level of their assigned emissions standards. amount, corresponding to the quantity of green- house gases they can release in accordance with the Cap and trade: Cap-and-trade schemes set a desired Kyoto Protocol (Art. 3), during the first commit- maximum ceiling for emissions (or cap) and let the ment period of that protocol (2008–12). One AAU market determine the price for keeping emissions 74 | State and Trends of the Carbon Market 2010 within that cap. To comply with their emission tar- Clean Development Mechanism (CDM): The gets at least cost, regulated entities can either opt for mechanism provided by Article 12 of the Kyoto internal abatement measures or acquire allowances Protocol, designed to assist developing countries or emission reductions in the carbon market, de- in achieving sustainable development by allowing pending on the relative costs of these options. entities from Annex I Parties to participate in low- carbon projects and obtain CERs in return. Carbon Asset: The potential of greenhouse gas emission reductions that a project is able to generate and sell. Climate Action Reserve (CAR): The Climate Action Reserve is a U.S.-based offsets program that estab- Carbon Finance: Resources provided to activities lishes regulatory-quality standards for the develop- generating (or expected to generate) greenhouse gas ment, quantification and verification of greenhouse (or carbon) emission reductions through the trans- gas (GHG) emission reduction projects in North action of such emission reductions. America; issues carbon offset credits known as Climate Reserve Tonnes (CRT) generated from such Carbon Dioxide Equivalent (CO2e): The univer- projects; and tracks the transaction of credits over sal unit of measurement used to indicate the global time in a transparent, publicly accessible system. warming potential of each of the six greenhouse gases regulated under the Kyoto Protocol. Carbon Community Independent Transaction Log (CITL): dioxide—a naturally occurring gas that is a by-prod- The Community Independent Transaction Log uct of burning fossil fuels and biomass, land-use (CITL) conducts “supplementary checks” to those by changes, and other industrial processes—is the refer- the ITL for transactions involving registries of at least ence gas against which the other greenhouse gases one EU Member State, such as the issuance, transfer, are measured, using their global warming potential. cancellation, retirement and banking of EUAs. Certified Emission Reductions (CERs): A unit of Conference of Parties (COP): The supreme body of greenhouse gas emission reductions issued pursuant the Convention. It currently meets once a year to to the Clean Development Mechanism of the Kyoto review the Convention’s progress. The word “con- Protocol, and measured in metric tons of carbon di- ference” is not used here in the sense of “meeting” oxide equivalent. One CER represents a reduction but rather of “association,” which explains the seem- in greenhouse gas emissions of one metric ton of ingly redundant expression “fourth session of the carbon dioxide equivalent. Conference of the Parties.” Chicago Climate Exchange (CCX): Members to Conference of the Parties serving as the Meeting the Chicago Climate Exchange make a voluntary of the Parties (CMP): The Convention’s supreme but legally binding commitment to reduce GHG body is the COP, which serves as the meeting of the emissions. By the end of Phase I (December 2006), Parties to the Kyoto Protocol. The sessions of the all Members will have reduced direct emissions COP and the CMP are held during the same period 4 percent below a baseline period of 1998-2001. to reduce costs and improve coordination between Phase II, which extends the CCX reduction pro- the Convention and the Protocol. gram through 2010, will require all Members to ultimately reduce GHG emissions 6 percent below Crediting period: The crediting period is the dura- baseline. Among the members are companies from tion of time during which a registered, determined North America as well as municipalities or U.S. or approved project can generate emission reduc- states or universities. As new regional initiatives tions. For CDM projects, the crediting period can began to take shape in the U.S., membership of be of either seven years (renewable twice) or ten the CCX grew from 127 members in January 2006 years (non-renewable). to 237 members by the end of the year while new participants expressed their interest in familiarizing Designated Focal Point (DFP): Parties participating themselves with emissions trading. in the Joint Implementation (JI) mechanism are re- quired to nominate a Designated Focal Point (DFP) for approving projects. State and Trends of the Carbon Market 2010 | 75 Designated National Authority (DNA): An of- Emission Reduction Units (ERUs): A unit of fice, ministry, or other official entity appointed by emission reductions issued pursuant to Joint a Party to the Kyoto Protocol to review and give na- Implementation. One ERU represents the right to tional approval to projects proposed under the Clean emit one metric ton of carbon dioxide equivalent. Development Mechanism. Emissions Trading Scheme (ETS): See cap and trade. Designated Operational Entities (DOEs): Designated operational entities are independent au- EU-10: Bulgaria, Czech Republic, Estonia, Hungary, ditors that assess whether a potential project meets all Latvia, Lithuania, Poland, Romania, Slovakia, and the eligibility requirements of the CDM (validation) Slovenia. and whether the project has achieved greenhouse gas emission reductions (verification and certification). EU-15: Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, Determination: Determination is the process of Netherlands, Portugal, Spain, Sweden, United Kingdom. evaluation by an independent entity accredited by the host country (JI Track 1) or by the Joint European Union Allowances (EUAs): The allowanc- Implementation Supervisory Committee (JI Track es in use under the EU ETS. An EUA unit is equal 2) of whether a project and the ensuing reductions to one metric ton of carbon dioxide equivalent. of anthropogenic emissions by sources or enhance- ments of anthropogenic removals by sinks meet all European Union Emission Trading Scheme (EU applicable requirements of Article 6 of the Kyoto ETS): The EU ETS was launched on January 1, Protocol and the JI guidelines. 2005, as a cornerstone of EU climate policy toward its Kyoto commitment and beyond. Through the Eligibility Requirements: There are six Eligibility EU ETS, Member States allocate part of the efforts Requirements for Participating in Emissions Trading toward their Kyoto targets to domestic emission (Art. 17) for Annex I Parties. Those are: (i) being a sources (mostly utilities). Over 2008–12, emissions Party to the Kyoto Protocol, (ii) having calculated from mandated installations (about 40 percent of and recorded one’s Assigned Amount, (iii) having in EU emissions) are capped on average at 6 percent place a national system for inventory, (iv) having in below 2005 levels. Participants can internally reduce place a national registry, (v) having submitted an an- emissions, purchase EUAs or acquire CERs and nual inventory and (vi) submit supplementary infor- ERUs (within a 13.4 percent average limit of their mation on assigned amount. An Annex I party will allocation over 2008–12). The EU ETS will con- automatically become eligible after 16 months have tinue beyond 2012, with further cuts in emissions elapsed since the submission of its report on calcula- (by 21 percent below 2005 levels in 2020 or more, tion of its assigned amount. Then, this Party and any depending on progress in reaching an ambitious in- entity having opened an account in the registry can ternational agreement on climate change). participate in Emissions Trading. However, a Party First Commitment Period: The five-year period, could lose its eligibility if the Enforcement Branch of from 2008 to 2012, during which industrialized the Compliance Committee has determined the Party country have committed to collectively reduce their is non-compliant with the eligibility requirements. greenhouse gas (or “carbon”) emissions by an average of 5.2 percent compared with 1990 emissions under Emission Reductions (ERs): The measurable re- the Kyoto Protocol. duction of release of greenhouse gases into the at- mosphere from a specified activity, and a specified Green Investment Scheme (GIS): A GIS is a volun- period of time. tary mechanism through which proceeds from AAU transactions will contribute to contractually agreed Emission Reductions Purchase Agreement (ERPA): environment- and climate-friendly projects and pro- Agreement which governs the transaction of emis- grams both by 2012 and beyond. sion reductions. 76 | State and Trends of the Carbon Market 2010 Greenhouse Gases (GHGs): Both natural and an- Joint Implementation (JI): Mechanism provided thropogenic, greenhouse gases trap heat in the Earth’s by Article 6 of the Kyoto Protocol, whereby entities atmosphere, causing the greenhouse effect. Water from Annex I Parties may participate in low-carbon vapor (H2O), carbon dioxide (CO2), nitrous oxide projects in hosted in Annex I countries and obtain (N2O), methane (CH4), and ozone (O3) are the pri- Emission Reduction Units in return. mary greenhouse gases. The emission of greenhouse gases through human activities (such as fossil fuel Kyoto Mechanisms (KMs): the three flexibility combustion or deforestation) and their accumula- mechanisms that may be used by Annex I Parties tion in the atmosphere is responsible for an addi- to the Kyoto Protocol to fulfill their commitments. tional forcing, contributing to climate change. The Those are the Joint Implementation (JI, Art. 6), Kyoto Protocol regulates six GHGs: carbon dioxide Clean Development Mechanism (CDM, Art. 12), (CO2), methane (CH4), and nitrous oxide (N20), as and International Emissions Trading (Art. 17). well as hydrofluorocarbons (HFCs), perfluorocar- bons (PFCs), and sulfur hexafluoride (SF6). Kyoto Protocol: Adopted at the Third Conference of the Parties to the United Nations Convention on Global Warming Potential (GWP): An index rep- Climate Change held in Kyoto, Japan in December resenting the combined effect of the differing times 1997, the Kyoto Protocol commits industrial- greenhouse gases remain in the atmosphere and their ized country signatories to collectively reduce their relative effectiveness in absorbing outgoing infrared greenhouse gas emissions by at least 5.2 percent radiation. below 1990 levels on average over 2008–12 while developing countries can take no regret actions and Internal rate of return: The annual return that participate voluntarily in emission reductions and would make the present value of future cash flows removal activities through the CDM. The Kyoto from an investment (including its residual market Protocol entered into force in February 2005. value) equal the current market price of the invest- ment. In other words, the discount rate at which an Monitoring Plan: A set of requirements for monitor- investment has zero net present value. ing and verification of emission reductions achieved by a project. International Transaction Log (ITL): The ITL links together the national registries and the CDM regis- Nationally Appropriate Mitigation Actions (NAMAs): try and is in charge of verifying the validity of trans- Refers to a set of mitigation policies and/or actions a actions (issuance, transfer and acquisition between developing country undertakes aiming at reducing its registries, cancellation, expiration and replacement, GHG emissions and reports to UNFCCC on a volun- retirement and carry-over). It is the central piece of tary basis. The concept of NAMAs emerged in 2007 the emissions trading under the Kyoto Protocol. under the UNFCCC Bali Action Plan, which called for “[the implementation of] Nationally Appropriate Japan-Voluntary Emissions Trading Scheme (J-VETS): Mitigation Actions by developing country Parties in Under the J-VETS, companies receive subsidies to the context of sustainable development, supported and implement mitigation activities in line with voluntary enabled by technology, financing and capacity build- commitments and can resort to emissions trading ing, in a measurable, reportable and verifiable man- (incl. offsets) to meet their commitments with more ner.” Through international negotiations within the flexibility. Though growing, impact remains limited: UNFCCC, NAMAs have been steadily refined. The over the first three years of the scheme, participants Cancun Agreement of last December achieved signifi- (288 companies) have reduced their emissions by cant progress in the concept of NAMAs and, inter alia, about one million tCO2e. The J-VETS has contrib- set milestones for the development of a central registry uted to the development of MRV system, third-party of NAMAs (including NAMAs seeking international verification system, and the registry system. The funding support) and guidelines for measuring, report- J-VETS has been incorporated to the Experimental ing and verification (MRV). Definitions on these ele- Integrated ETS as one of participating options. ments are expected by the end of this year. State and Trends of the Carbon Market 2010 | 77 National Allocation Plans (NAPs): The documents, Project Idea Note (PIN): A note prepared by a proj- established by each Member State and reviewed by ect proponent presenting briefly the project activity the European Commission, that specify the list of (for example, sector, location, financials, estimated installations under the EU ETS and their absolute amount of ERs, and so on). emissions caps, the amount of CERs and ERUs that may be used by these installations as well as other REDD plus (REDD+): All activities that reduce emis- features such as the size of the new entrants reserve sions from deforestation and forest degradation, and and the treatment of exiting installations or the pro- contribute to conservation, sustainable management of cess of allocation (free allocation or auctioning). forests, and enhancement of forest carbon stocks. New South Wales Greenhouse Gas Reduction Regional Greenhouse Gas Initiative (RGGI): Under Scheme (NSW GGAS): Operational since January RGGI, 10 Northeast and Mid-Atlantic states aim to 1, 2003 (to last at least until 2012), the NSW reduce power sector CO2 emissions by 10 percent be- Greenhouse Gas Abatement Scheme aims at reduc- low 2009 levels in 2019. Within this ten-year phase, ing GHG emissions from the power sector. NSW and there are three shorter compliance periods. During ACT (since January 1, 2005) retailers and large elec- the first and second compliance periods (2009–11 tricity customers have thus to comply with manda- and 2012–14) the cap on about 225 installations is tory (intensity) targets for reducing or offsetting the set at 171 MtCO2e (or 188 M short ton CO2e). This emissions of GHG arise from the production of elec- is followed by a 2.5 percent per year decrease in cap tricity they supply or use. They can meet their targets during the third compliance period (2015–18). meet their targets by purchasing certificates (NSW Greenhouse Abatement Certificates or NGACs) that Reforestation: This process increases the capacity are generated through project activities. of the land to sequester carbon by replanting forest biomass in areas where forests have been previously New Zealand Emissions Trading Scheme (NZ harvested. ETS): The NZ ETS will progressively regulate emis- sions of the six Kyoto gases in all sectors of the econ- Registration: The formal acceptance by the CDM omy by 2015. Forestry is covered since 2008 and Executive Board of a validated project as a CDM by July 1, 2010, stationary energy, industrial process project activity. and liquid fossil fuel will be phased-in. The govern- ment recently announced, however, that full imple- Removal Unit (RMU): RMUs are issued by Parties mentation could be delayed if adequate progress is to the Kyoto Protocol in respect of net removals by not made in establishing similar regulations in other sinks from activities covered by Article 3(3) and developed countries. Article 3(4) of the Kyoto Protocol. Offsets: Offsets designate the emission reductions Secondary transaction: A transaction where the seller from project-based activities that can be used to is not the original owner (or issuer) of the carbon asset. meet compliance—or corporate citizenship—objec- tives vis-à-vis greenhouse gas mitigation. Supplementarity: Following the Marrakesh Accords, the use of the Kyoto mechanisms shall be supplemen- Primary transaction: A transaction between the origi- tal to domestic action, which shall thus constitute a nal owner (or issuer) of the carbon asset and a buyer. significant element of the effort made by each Party to meet its commitment under the Kyoto Protocol. Project Design Document (PDD): A central docu- However there is no quantitative limit to the utiliza- ment of project-based mechanisms, the PDD nota- tion of such mechanisms. While assessing the NAPs, bly describes the project activity (including environ- the European Commission considered that the use of mental impacts and stakeholders consultations), the CDM and JI offsets could not exceeded 50 percent of baseline methodology and how the project is addi- the effort by each Member State to achieve its com- tional as well as the monitoring plan. mitment. Supplementarity limits may thus affect de- mand for some categories of offsets. 78 | State and Trends of the Carbon Market 2010 United Nations Framework Convention on Verification: Verification is the review and ex post Climate Change (UNFCCC): The international determination by an independent third party of the legal framework adopted in June 1992 at the Rio monitored reductions in emissions generated by a Earth Summit to address climate change. It commits registered CDM project, a determined JI project (or the Parties to the UNFCCC to stabilize human in- a project approved under another standard) during duced greenhouse gas emissions at levels that would the verification period. prevent dangerous manmade interference with the climate system, following “common but differentiat- Voluntary market: The voluntary market caters for ed responsibilities” based on “respective capabilities.” the needs of those entities that voluntarily decide to reduce their carbon footprint using offsets. The Validation: Validation is the process of indepen- regulatory vacuum in some countries and the antici- dent evaluation of a project activity by a Designated pation of imminent legislation on GHG emissions Operational Entity (DOE) against the requirements also motivates some pre-compliance activity. of the CDM. The CDM requirements include the CDM modalities and procedures and subsequent Western Climate Initiative (WCI): The WCI cov- decisions by the CMP and documents released by ers a group of seven U.S. states (Arizona, California, the CDM Executive Board. Montana, New Mexico, Oregon, Utah, and Washington) and four Canadian provinces (British Verified Emission Reductions (VERs): A unit of Columbia, Manitoba, Ontario, and Quebec), with greenhouse gas emission reductions that has been an aggregate emissions target of 15 percent below verified by an independent auditor. Most often, this 2005 levels by 2020. Other U.S. and Mexican states designates emission reductions units that are traded and Canadian provinces have joined as observers. on the voluntary market. NOTES NOTES 1818 H STREET, NW FSC Logo WASHINGTON, DC 20433 USA