Showing posts with label emissions intensity. Show all posts
Showing posts with label emissions intensity. Show all posts

Wednesday, March 14, 2007

Liberals eying absolute targets for large emitters?

Tiny story in today's online National Post - the Liberals are supposedly considering absolute targets for large final emitters as part of their election plan, as opposed to the intensity-based targets that the Conservatives (and previous Liberal governments) have been working on.

National Post story

My Comments: I'm very glad to see absolute targets being discussed for emissions trading, and I hope this is a bit more long lasting than Stephane Dion's brief endorsement of a carbon tax. I don't know if this is an issue that can grab the public's attention politically, and who knows at this point if the Liberals will make it back into power, but I am certain that absolute targets, even if extremely generous ones initially, are a better choice for Canada. They would provide more certainty in terms of our reductions achievements, and will make it much easier for our system to become integrated with the European Emissions Trading System and other eventual tradeable permit systems based on absolute targets.

Friday, March 9, 2007

Alberta announces regulations for LIEs based on emissions-intensity

Alberta announced its new (proposed) Specified Gas Emitters Regulation (SGER) yesterday, part of Bill 3, a proposed amendment to the Climate Change and Emissions Management Act. SGER requires facilities that emit more than 100 000 tonnes of GHGs (CO2e?)/year to reduce their emissions intensity by 12% starting July 1 2007, or else
  • buy Alberta-based offsets
  • buy "emissions performance credits" from other emitters (who receive these credits in exchange for having achieved a lower intensity than their target)
  • contribute to an Albertan technology fund at $15.00/tonne over their target
The Pembina Institute is quoted as saying that the proposal is "an absolute joke", while the Canadian Association of Petroleum Producers (CAPP) is saying that few if any of the 100 facilities covered will be able to achieve the reductions, meaning that they will have to pay hundreds of millions of dollars into the technology fund.
Some more details about SGER
  • lower targets for new facilities: facilities opened in the last 8 years have lower targets initially - 10% if you are 8 years old, 8% if you are 6, down to 2% for facilities in operation four years or less
  • Offsets may be open to double-counting: details on qualification, methodology, etc. aren't in place, but the only requirement in the proposed regulation that covers additionality is a condition that the emissions reduction used as an offset not have been required by law. This leaves open the possibility that reductions funded by other provincial or federal initiatives could be used as an offset within the SGER system.
  • Baseline intensity will be an average of 2003, 2004 and 2005 emissions, except for new facilities, which will use their third year of operations
  • No longer-term targets - the Minister can change targets and the legislation expires in 2014, but no schedule of targets is set out in the SGER legislation.
Alberta Ministry of the Environment press release
National Post coverage
Pembina news release

My comments: I have to agree with Pembina here - intensity targets, especially such low targets applied to an industry that has such huge growth, are barely going to slow down our GHG increases. (Pembina calculates that the SGER will allow a doubling of tar sands emissions by 2010 relative to 2003). Meanwhile, I'm wondering why Alberta has come out with this, especially so soon before the federal announcement. I assume its meant more as a bargaining chip/preemptive strike than a real system - Alberta's 100 emitters are too few to make for a liquid emissions trading market, and I don't think this system as it stands could be easily linked to larger carbon markets, if at all. I also don't think that the Albertan system could meet "equivalency" requirements for soon-to-be-announced federal system. The Federal Conservative strategy is likely to recycle the Liberal LFE system, with slightly more stringent targets, so we should expect 15% or higher intensity targets at the federal level. And the national system will also give access to offsets from across Canada and (maybe just maybe) international credits. So is this just an attempt to stake some ground, with an eventual goal of forcing reductions/exemptions from the feds? Or will Alberta make this a big issue to stand its ground on? Anyone with a better sense of Albertan politics (or devious political maneuvering in general), feel free to enlighten me.

Wednesday, February 28, 2007

Pembina and CAN-RAC proposal for Large Final Emitters

Matthew Bramley of the Pembina Institute testified to the Clean Air Act Legislative Committee last week on behalf of Pembina and the Climate Action Network (CAN-RAC). They've published their briefing note on both websites. In a nutshell, it proposes that the forthcoming emissions trading system for big industry use absolute rather than intensity-based targets; set targets at 1990 -6% levels; keep a price cap but raise it to $30/tonne; include long term, gradually tightening targets; and move gradually from 100% free allocation to auctioning of permits. The overall 1990-5% target translates to 127 Mt for industry, roughly half of Canada's "Kyoto Gap", rather than the 45-55 Mt hoped for under the Liberal LFE system and the much anticipated Clean Air Industrial Regulatory Acronym (sorry, Agenda). Pembina and CAN-RAC say that costs will be reasonable - increases of less than 1.5 cents/kWh for coal-generated electricity and $1.50/barrel of oil sands oil at the worst.

Link to the briefing note

My comments: Great stuff. Another thorough, well-researched proposal from these folks. It turns the LFE system into something much closer to an ideal emissions trading system while still leaving industry room to breathe via the price cap and competitiveness allowances (forgot to mention this - their breakdown of industry into three sectors gives manufacturing much lower targets, reflecting their lower emissions growth since 1990. This reduces impacts on the LFEs with the most vulnerability to international competition).

Clean Air Act Legislative Committee on Target Setting

The transcripts are now available for meetings 7 through 10 of the legislative committee on Bill C-30. Here's a summary of meeting 7, which focused on target setting, with much additional discussion on policy. The committee heard from Greenpeace, the Canadian Chamber of Commerce (CCC), the National Round Table on the Environment and the Economy (NRTEE), and Dr. Marc Jaccard of SFU. Political sparring between the committee members was remarkably low.

Greenhouse Gas Emissions Targets: Greenpeace reiterated the long term CANet targets of 25% below 1990 by 2020 and 80% below 1990 by 2050. No one else advocated a specific target. NRTEE presented on its work on achieving a 60% reduction by 2050, and the CCC emphasized the need to respect investment cycles and Canada's energy-intense economy. Dr Jaccard made the point that setting targets is irrelevant if you don't have the policies in place to achieve them. Everyone agreed with a key NRTEE point - that long-term targets are needed ASAP, and that short-term targets have to be developed within a long-term plan.

Achieving Canadian Kyoto targets: Greenpeace says its achievable, but when pressed didn't have a detailed analysis of how. The CCC says it is impossible without doing very serious damage to the economy. Dr. Jaccard says at this point it isn't doable - domestically it is impossible and international credits will be in short supply, potentially causing price spikes. He also talked about his work in 98-99 for the feds, where it looked like the only way to achieve Kyoto domestically would have been the equivalent of a $120-150$/tonne carbon tax starting in 2000.

Emissions intensity targets: Lots of discussion on this. Greenpeace says its a bad idea and often gets used to mask lack of absolute reductions. They cited Canada's 1990-2004 intensity gain of 14% while absolute emissions rose 27%. The CCC supports the intensity approach because it doesn't penalize emitter growth. Dr. Jaccard says that intensity targets can work but you will need the capacity to increase them if growth exceeds predictions.

Emissions trading: Some discussion of the large final emitters system (now of course the "Clean Air Industrial Regulatory Framework"...who comes up with these zingy names? so catchy!) Greenpeace advocates absolute targets, no permit price cap, and having industry cover 50% of our reductions (this would make for a much more ambitious target than the 45-55 Mt aimed at right now). Dr Jaccard points out that the LFE/CAIRF system will be compulsory and so will probably achieve some reductions, but that still leaves the other half of the economy.

Policy effectiveness: Dr Jaccard focused on this issue. He cited a few big trends based on global experience to date with climate change policy:
  • voluntary policies don't work - we can't depend on subsidies, information campaigns and moral suasion
  • we can't count on energy efficiency - its more expensive to implement than thought, and there is evidence that the energy saved just gets used up by new energy-using devices
So:
  • we need compulsory policies - his biggest point - be it cap and trade, a carbon tax, or standards, policy needs to have teeth
  • focus on emissions rather than efficiency.
  • the likely winners - he sees them as a mix of zero-emissions fossil fuels, renewables, nuclear, and some efficiency. ( I should point out that he's well-known and somewhat controversial for his writing on clean coal and other fossil fuels technology)

Link to all transcripts.

My comments: The most interesting thing for me here was Jaccard's comments on policy effectiveness, especially the key point that we need to focus on compulsory policies. I found his point on energy efficiency interesting; its also been made by George Monbiot in his book Heat. I haven't had a chance to look at energy efficiency in depth so I won't comment on it further. Re our Kyoto targets, I'm pretty much convinced by the mountain of respected Canadian environmental analysts chiming in to say its just not possible at this point. What I'd like to see now, though, are some proposals for achievable domestic reductions. How close to Kyoto can we get?

Tuesday, February 27, 2007

the Clean Air Industrial Regulatory Agenda

The Globe and Mail has been analyzing leaked documents describing the Conservative plan for an emissions trading system for big industry. Basically, it looks like the Liberals' old Large Final Emitters (LFE) system, with slightly tougher targets and of course a brand new name. Unfortunately, this means that most of the flaws of the old LFE system could still be present:
  • intensity targets - the biggest flaw - no guarantee that absolute emissions will decline. It also makes for a more complex system to set up (you need to set targets for all kinds of industrial products), and leaves a lot of room for industries to negotiate relatively soft targets without the general public noticing.
  • free permits - the emitters in the system will (I am assuming here) once again get their permits free. Given international experience so far with emissions trading, this is a big transfer of wealth to industry, and will likely give many emitters a windfall profit, without necessarily rewarding good work.
  • an offset system - again, I'm assuming the Conservative model will reflect the Liberal original, here. The LFE system included a complementary offset system, where farmers, landfill operators, etc. could sell credits to the big emitters based on carbon sequestration or methane capture. An offset system can in theory be a great market-based tool, but is very complex to set up and administer (lots of project evaluation methodologies) and creates opportunities for double-counting reductions and diluting the emissions trading system itself.
  • a price cap on emissions - the Liberals promised industry that they would sell unlimited permits at 15$/tonne if the price rose that high. This amounted to a fairly low-set safety valve and would have eliminated a lot of emissions reductions from the market. If Canada's market had ever been linked to international carbon markets, then it could have also led to arbitrage (traders buying Canadian permits as a hedge against market volatility, etc.)
On top of these problems, the Conservative system won't go into effect until 2010. Back in 2004 when the LFE system was nearing completion, industry was already ready for a 2008 roll-out, so this seems like an unnecessary delay.

One plus of the draft Conservative system: long term, gradually tightening targets - it sets out targets for not only 201-2015, but stricter targets for 2015-2020. This gives predictability to industry, particularly for capital investment decisions.

So what would the ideal Canadian emissions trading system look like? Here are some key points:
  • an absolute target - forget the intensity targets and replace them with an overall, absolute cap on emissions, to guarantee real reductions.
  • auctioned permits - auctioning permits is more economically efficient, a lot simpler to set up and administer, and removes most opportunities to hide favouritism towards particular industries. It also creates revenue that can be used to run the program AND create a double dividend (see my post) by using it to reduce income taxes or what have you.
  • simplicity and clarity - a simple system makes for more liquid markets, more participant confidence, and more transparency. Using an absolute target and permit auctioning would get rid of a lot of the unnecessary complexity of the LFE system. Eliminating the offset system would also help, but this would also remove a big incentive for offset-type reductions - the compromise solution would be to design as simple an offset system as possible.
  • no/higher caps on permit price - the 15$/tonne permit price cap was too low and will stifle innovation if its reinstated. Either remove the cap altogether, or announce a much higher cap - 80-125$/tonne (I use these figures since they've been cited as approximating the true costs of CO2e emissions)
  • long term, gradually tightening targets
  • roll-out as soon as possible - 2008 if possible.
Link to Globe article
Link to further Globe coverage
Link to a US EPA Guide to desigining and operating a cap and trade program - a great resource covering all of the topics discussed above.

Wednesday, February 14, 2007

Clean Air Act Committee Meetings - Targets, Carbon Taxes and Emissions Trading

Just read over testimony from the February 6th meeting of the Clean Air Act Committee. The Committee heard from Bill Erasmus (Assembly of First Nations), Claude Villeneuve (Université du Québec À Chicoutimi prof), David R. Boyd (BC prof, author), and Mathieu Castonguay (Association québecoise de la lutte contre la pollution atmosphérique). There was a great deal of discussion on overall Canadian targets, the possibility of achieving our Kyoto targets, and the use of carbon taxes and emissions trading. In four sentences:
  • Canada can't achieve our Kyoto targets even with international credits, nonetheless we can still work within the Kyoto protocol, and we need to set ourselves a binding target of 80% below 1990 levels by 2050.
  • Carbon taxes are one of the most effective tools available, we need to use them, and they won't do us any harm; emissions trading can also be used but it is vulnerable to cheating by emitters.
  • Emissions-intensity targets are a fraudulent approach, a trap to be avoided.
  • The Clean Air Act is an unnecessary and risky piece of legislation.
Here is a more detailed summary. Remember that this is based on an unofficial transcript. If you would like a copy, email CC30 at parl.gc.ca

The Clean Air Act
The experts agreed, when asked, that the Clean Air Act achieved very little if anything from a climate change perspective and was unnecessary for addressing greenhouse gas emissions.

Achieving Kyoto Targets
Most of the discussion was from David Boyd. He pointed out that domestically, we would have to cut emissions by 7% a year for 5 years, which is too dramatic. He supports using verified international credits under the Clean Development Mechanism (CDM) but says that due to the long lead time on CDM there will never be enough projects available to cover our emissions. His diagnosis (supported by Villeneuve and others) - we will have to do our best and accept the penalties under Kyoto. Villeneuve proposed that an initial target of stabilizing emissions at 2003 levels for the 2008-2012 period would be feasible.

Emissions Intensity Targets

Both Boyd and Villeneuve criticized intensity targets extensively because they allow total emissions to increase. Boyd pointed out that, from an intensity perspective, Canada did quite well in the last 17 years: intensity was improved by 43% as measured by greenhouse gas emissions/GDP. Given our atrocious performance in terms of actual emissions, this underscores the weakness of using intensity targets.

Carbon Taxes
Again, a lot of discussion with Boyd and Villeneuve; carbon taxes were also supported by Castonguay. Boyd strongly advocated carbon taxes and pointed out that some of the most competitive countries in the world (the top four rated by the Davos World Economic Forum, for example) have carbon taxes. Advantages cited by Boyd and Villeneuve:
  • comprehensive
  • cover the entire economy
  • widely regarded as the most efficient policy approach
  • transparent
  • administratively simple
  • shows political will
  • low government investment
  • funds can be revenue neutral (tax shifting) and/or used for further reductions, R&D
  • less likely to cause energy price volatility than a cap and trade
  • proven track record in Europe
Why haven't carbon taxes been adopted? Pure political acceptability. Boyd recommends a revenue-neutral tax pushed by all parties together to mitigate this.

Emissions Trading

Again input from Boyd, Villeneuve. The main point was that despite some successes (US Acid Rain program), they are open to cheating. The recent European Union Emissions Trading System (EU ETS) price collapse demonstrates this. According to Boyd, emitters convinced governments that they needed more permits than they actually did. Since permits were given out freely, this led to many emitters making windfill profits as they sold extra permits, and then a price collapse.
According to Boyd, the Large Final Emitters emissions trading system the previous government was developing was on the brink of creating the same problem.

My comments:
Great to see this testimony. If only these experts and their arguments, particularly those on which they agreed, were listened to, we might be able to put something effective into place. Meanwhile, I'm (naively?) hopeful that the melee leading up to the 2007 election may lead one the opposition parties to start pushing a revenue-neutral carbon tax.

A side note: David Boyd was the expert cited by Minister Baird as comparing the emissions cuts needed to achieve Kyoto with the collapse of the Russian economy. Too bad Baird didn't go on to quote Boyd's bigger points that we need to continue to work within Kyoto, ditch intensity targets, and create a carbon tax...

Saturday, February 10, 2007

More details re Conservative position on emissions trading

I've been looking over the unofficial transcripts of Environment Minister John Baird's presentation to the committee on the Clean Air Act (available by request from the Committee secretary - write to CC30@parl.gc.ca). There were a bit more information on the Conservative's plans for GHG emissions trading than was reported in the natonal media. Here's a summary - note that the transcript is unofficial, so the quotes are conceivably inaccurate.

emissions-intensity versus an absolute cap

on the one hand, Minister Baird says: "
With respect to hard emission caps and with respect to pollution we've indicated in the notice of intent our desire to have hard emissions caps to deal with pollution"
but on the other hand, he goes on to say (in yet another partisan exchange between him and a Liberal committee member) "
I can quote Mr. Godfrey again, if you like, talking about how intensity-based are good, because I agree with him"

Using the clean development mechanism
John Godfrey pressed Minister Baird in some detail on whether or not he would use the CDM. Basically, he appears to reject it: "My problem with the clean development mechanisms, for taxpayers' dollars I would rather take the money, spend it in Canada, and also make our air cleaner. I use the example of the coal-fired generating station. We could take money and spend it abroad and then we'd get no benefit for clean air. But if we make the investment here in Canada, we get the twin benefit of clean air."

Domestic Emissions Trading
Bernard Bigras of the Parti Quebecois, among others, asked Baird about emissions trading - would it happen. He wouldn't make any commitment on it but spoke very positively about the idea of creating a domestic emissions trading market.

My comments
I got a bit excited to see him talking a hard cap on emissions for industry - basically, my biggest hope is that the Liberals and Conseravatives one-up each other right into some kind of significant cap and trade system - but it looks like intensity-targets are here to stay. I was also disappointed by his comments on CDM - hopefully he is just ill-informed. If not, in my opinion Canada will be missing a fantastic opportunity to meet Kyoto cheaply while boosting our international development funding and supporting Canadian technology exports.


Saturday, February 3, 2007

Alberta also talking emissions-intensity

From today's National Post. The good news - Alberta says it will set mandatory greenhouse gas emissions targets. The bad news - they will be emissions intensity targets, not absolute targets. As I mentioned earlier today, emissions intensity targets don't guarantee absolute limits to our emissions, just less emissions per unit of GDP/barrel of oil/what have you. The second problem here is the issue of redundant targets. There is no need for Alberta to have its own targets, unless they want to be more or less stringent than the feds. Given the Alberta government track record, I'm guessing this move is meant to ensure lower targets for Alberta industry. That, or its just a chance to claim credit for something the feds are putting in place anyway.

Link to NP story

Baird's industry targets

Looks like the Conservatives are poised to resurrect the large final emitters emissions trading scheme. Yesterday, Environment Minister John Baird told reporters that he is preparing to impose emissions intensity targets on industry, apparently "among the most aggressive in the world." The LFE scheme was also based on emissions intensity targets, which, as CANet noted, have a big weakness - they don't provide an absolute limit on industry emissions. If industry grows faster than anticipated, then emissions can grow with the industry, wiping out any absolute reductions.

The one possibly positive thing in this announcement- talk of aggressive targets. Hopefully the Conservatives will want to announce that they've gone beyond the targets previously set under the Liberals...given their political base, though, I suspect that this won't happen. More likely is that they will delay mentioning sectoral targets and hope that the public can't be bothered to figure out the details.

Link to Globe article.