Tag Archives: cap & trade

Et tu, EJ?

I’m not a cap & trade fan, but I find it rather bizarre that the most successful opposition to California’s AB32 legislation comes from the environmental justice (EJ) movement, on the grounds that cap & trade might make emissions go up in areas that are already disadvantaged, and that Air Resources failed to adequately consider alternatives like a carbon tax.

I think carbon taxes did get short shrift in the AB32 design. Taxes were a second-place favorite among economists in the early days, but ultimately the MAC analysis focused on cap & trade, because it provided environmental certainty needed to meet legal targets (oops), but also because it was political suicide to say “tax” out loud at the time.

While cap & trade has issues with dynamic stability, allocation wrangling and complexity, it’s hard to imagine any way that those drawbacks would change the fundamental relationship between the price signal’s effect on GHGs vs. criteria air pollutants. In fact, GHGs and other pollutant emissions are highly correlated, so it’s quite likely that cap & trade will have ancillary benefits from other pollutant reductions.

To get specific, think of large point sources like refineries and power plants. For the EJ argument to make sense, you’d have to think that emitters would somehow meet their greenhouse compliance obligations by increasing their emissions of nastier things, or at least concentrating them all at a few facilities in disadvantaged areas. (An analogy might be removing catalytic converters from cars to increase efficiency.) But this can’t really happen, because the air quality permitting process is not superseded by the cap & trade system. In the long run, it’s also inconceivable that it could occur, because there’s no way you could meet compliance obligations for deep cuts by increasing emissions. A California with 80% cuts by 2050 isn’t going to have 18 refineries, and therefore it’s not going to emit as much.

The ARB concludes as much in a supplement to the AB32 scoping plan, released yesterday. It considers alternatives to cap & trade. There’s some nifty stuff in the analysis, including a table of existing emissions taxes (page 89).

It seems that to some extent ARB has tilted the playing field a bit by evaluating a dumb tax, i.e. one that doesn’t adapt its price level to meet environmental objectives without legislative intervention, and heightening leakage concerns that strike me as equally applicable to cap & trade. But they do raise legitimate legal concerns – a tax is not a legal option for ARB without a vote of the legislature, which would likely fail because it requires a supermajority, and tax-equivalent fees are a dubious proposition.

If there’s no Plan B alternative to cap and trade, I wonder what the EJ opposition was after? Surely failure to address emissions is not compatible with a broad notion of justice.

The RGGI budget raid and cap & trade credibility

I haven’t been watching the Regional Greenhouse Gas Initiative very closely, but some questions from a colleague prompted me to do a little sniffing around. I happened to run across this item:

Warnings realized in RGGI budget raid

The Business and Industry Association of New Hampshire was not surprised that the Legislature on Wednesday took $3.1 million in Regional Greenhouse Gas Initiative funds to help balance the state budget.

“We warned everybody two years ago that this is a big pot of money that is ripe for the plucking, and that’s exactly what happened,” said David Juvet, the organization’s vice president.

Indeed, the raid happened without any real debate at all. In fact, the only other RGGI-related proposal – backed by Republicans – was to take even more money from the fund.

… New York state lawmakers grabbed $90 million in RGGI funds last December. Shortly afterwards, New Jersey followed suit taking $65 million in the last budget year. And “the governor left the door wide open for next year. They are taking it all,” said Matt Elliott of Environment New Jersey. …

This is a problem because it confirms the talking point of “cap & tax” opponents, that emissions revenue streams will be commandeered for government largesse. There is a simple solution, I think, which is to redistribute the proceeds transparently, so that it’s obvious that a raid on revenues is a raid on pocketbooks. The BC carbon tax did that initially, though it’s apparently falling off the wagon.

Strategic Excess? Breakthrough’s Nightmare?

Since it was the Breakthrough analysis that got me started on this topic, I took a quick look at it again. Their basic objection is:

Therein lies a Catch-22 of ACES: if the annual use of up to 2 billion tons of offsets permitted by the bill is limited due to a restricted supply of affordable offsets, the government will pick up the slack by selling reserve allowances, and “refill” the reserve pool with international forestry offset allowances later. [...]

The strategic allowance reserve would be established by taking a certain percentage of allowances originally reserved for the future — 1% of 2012-2019 allowances, 2% of 2020-2029 allowances, and 3% of 2030-2050 allowances — for a total size of 2.7 billion allowances. Every year throughout the cap and trade program, a certain portion of this reserve account would be available for purchase by polluters as a “safety valve” in case the price of emission allowances rises too high.

How much of the reserve account would be available for purchase, and for what price? The bill defines the reserve auction limit as 5 percent of total emissions allowances allocated for any given year between 2012-2016, and 10 percent thereafter, for a total of 12 billion cumulative allowances. For example, the bill specifies that 5.38 billion allowances are to be allocated in 2017 for “capped” sectors of the economy, which means 538 million reserve allowances could be auctioned in that year (10% of 5.38 billion). In other words, the emissions “cap” could be raised by 10% in any year after 2016.

First, it’s not clear to me that international offset supply for refilling the reserve is unlimited. Section 726 doesn’t say they’re unlimited, and a global limit of 1 to 1.5 GtCO2eq/yr applies elsewhere. Anyhow, given the current scale of the offset market, it’s likely that reserve refilling will be competing with market participants for a limited supply of allowances.

Second, even if offset refills do raise the de facto cap, that doesn’t raise global emissions, except to the extent that offsets aren’t real, additional and all that. With perfect offsets, global emissions would go down due to the 5:4 exchange ratio of offsets for allowances. If offsets are really rip-offsets, then W-M has bigger problems than the strategic reserve refill.

Third, and most importantly, the problem isn’t oversupply of allowances through the reserve. Instead, it’s hard to get allowances out of the reserve – they check in, and never check out. Simple math suggests, and simulations confirm, that it’s hard to generate a price trajectory yielding sustained auction release. Here’s a test with 3%/yr BAU emissions growth and 10% underlying demand volatility:


Even with these implausibly high drivers, it’s hard to get a price trajectory that triggers a sustained auction flow, and total allowance supply (green) and emissions hardly differ from from the no-reserve case.

My preliminary simulation experiments suggest that it’s very unlikely that Breakthrough’s nightmare, a 10% cap violation, could really occur. To make that happen overall, you’d need sustained price increases of over 20% per year – i.e., an allowance price of $56,000/TonCO2eq in 2050. However, there are lesser nightmares hidden in the convoluted language – a messy program to administer, that in the end fails to mitigate volatility.

Strategic Excess? Insights

Model in hand, I tried some experiments (actually I built the model iteratively, while experimenting, but it’s hard to write that way, so I’m retracing my steps).

First, the “general equilbrium equivalent” version: no volatility, no SR marginal cost penalty for surprise, and firms see the policy coming. Result: smooth price escalation, and the strategic reserve is never triggered. Allowances just pile up in the reserve:



Since allowances accumulate, the de facto cap is 1-3% lower (by the share of allowances allocated to the reserve).

If there’s noise (SD=4.4%, comparable to petroleum demand), imperfect foresight, and short run adjustment costs, the market is more volatile:


However, something strange happens. The stock of reserve allowances actually increases, even though some reserves are auctioned intermittently. That’s due to the refilling mechanism. An early auction, plus overreaction by firms, triggers a near-collapse in allowance prices (as happened in the ETS). Thus revenues generated in the reserve auction at high prices used to buy a lot of forestry offsets at very low prices:


Could this happen in reality? I’m not sure – it depends on timing, behavior, and details of the recycling implementation. I think it’s safe to say that the current design is not robust to such phenomena. Fortunately, the market impact over the long haul is not great, because the extra accumulated allowances don’t get used (they pile up, as in the smooth case).

So, what is the reserve really accomplishing? Not much, it seems. Here’s the same trajectory, with volatility but no strategic reserve system:


The mean price with the reserve (blue) is actually slightly higher, because the reserve mainly squirrels away allowances, without ever releasing them. Volatility is qualitatively the same, if not worse. That doesn’t seem like a good trade (unless you like the de facto emissions cut, which could be achieved more easily by lowering the cap and scrapping the reserve mechanism).

One reason the reserve fails to achieve its objectives is the recycling mechanism, which creates a perverse feedback loop that offsets the strategic reserve’s intended effect:


The intent of the reserve is to add a balancing feedback loop (B2, green) that stabilizes price. The problem is, the recycling mechanism (R2, red) consumes international forestry offsets that would otherwise be available for compliance, thus working against normal market operations (B2, blue). Thus the mechanism is only helpful to the extent that it exploits clever timing (doubtful), has access to offsets unavailable to the broad market (also doubtful), or doesn’t recycle revenue to refill the reserve. If you have a reserve, but don’t refill, you get some benefit:


Still, the reserve mechanism seems like a lot of complexity yielding little benefit. At best, it can iron out some wrinkles, but it does nothing about strong, sustained price excursions (due to picking an infeasible target, for example). Perhaps there is some other design that could perform better, by releasing and refilling the reserve in a more balanced fashion. That ideal starts to sound like “buy low, sell high” – which is what speculators in the market are supposed to do. So, again, why bother?

I suspect that a more likely candidate for stabilization, robust to uncertainty, involves some possible violation of the absolute cap (gasp!). Realistically, if there are sustained price excursions, congress will violate it for us, so perhaps its better to recognize that up front and codify some orderly process for adaptation. At the least, I think congress should scrap the current reserve, and write the legislation in such a way as to kick the design problem to EPA, subject to a few general goals. That way, at least there’d be time to think about the design properly.

Strategic Excess? The Model

It’s hard to get an intuitive grasp on the strategic reserve design, so I built a model (which I’m not posting because it’s still rather crude, but will describe in some detail). First, I’ll point out that the model has to be behavioral, dynamic, and stochastic. The whole point of the strategic reserve is to iron out problems that surface due to surprises or the cumulative effects of agent misperceptions of the allowance market. You’re not going to get a lot of insight about this kind of situation from a CGE or intertemporal optimization model – which is troubling because all the W-M analysis I’ve seen uses equilibrium tools. That means that the strategic reserve design is either intuitive or based on some well-hidden analysis.

Here’s one version of my sketch of market operations (click to enlarge):
Strategic reserve structure

It’s already complicated, but actually less complicated than the mechanism described in W-M. For one thing, I’ve made some process continuous (compliance on a rolling basis, rather than at intervals) that sound like they will be discrete in the real implementation.

The strategic reserve is basically a pool of allowances withheld from the market, until need arises, at which point they are auctioned and become part of the active allowance pool, usable for compliance:


Reserves auctioned are – to some extent – replaced by recycling of the auction revenue:


Refilling the strategic reserve consumes international forestry offsets, which may also be consumed by firms for compliance. Offsets are created by entrepreneurs, with supply dependent on market price.


Auctions are triggered when market prices exceed a threshold, set according to smoothed actual prices:


(Actually I should have labeled this Maximum, not Minimum, since it’s a ceiling, not a floor.)

The compliance market is a bit complicated. Basically, there’s an aggregate firm that emits, and consumes offsets or allowances to cover its compliance obligation for those emissions (non-compliance is also possible, but doesn’t occur in practice; presumably W-M specifies a penalty). The firm plans its emissions to conform to the expected supply of allowances. The market price emerges from the marginal cost of compliance, which has long run and short run components. The LR component is based on eyeballing the MAC curve in the EPA W-M analysis. The SR component is arbitrarily 10x that, i.e. short term compliance surprises are 10x as costly (or the SR elasticity is 10x lower). Unconstrained firms would emit at a BAU level which is driven by a trend plus pink noise (the latter presumably originating from the business cyle, seasonality, etc.).


So far, so good. Next up: experiments.

Strategic Excess? Simple Math

Before digging into a model, I pondered the reserve mechanism a bit. The idea of the reserve is to provide cost containment. The legislation sets a price trigger at 60% above a 36-month moving average of allowance trade prices. When the current allowance price hits the trigger level, allowances held in the reserve are sold quarterly, subject to an upper limit of 5% to 20% of current-year allowance issuance.

To hit the +60% trigger point, the current price would have to rise above the average through some combination of volatility and an underlying trend. If there’s no volatility, the the trigger point permits a very strong trend. If the moving average were a simple exponential smooth, the basis for the trigger would follow the market price with a 36-month lag. That means the trigger would be hit when 60% = (growth rate)*(3 years), i.e. the market price would have to grow 20% per year to trigger an auction. In fact, the moving average is a simple average over a window, which follows an exponential input more closely, so the effective lag is only 1.5 years, and thus the trigger mechanism would permit 40%/year price increases. If you accept that the appropriate time trajectory of prices is more like an increase at the interest rate, it seems that the strategic reserve is fairly useless for suppressing any strong underlying exponential signal.

That leaves volatility. If we suppose that the underlying rate of increase of prices is 10%/year, then the standard deviation of the market price would have to be (60%-(10%/yr*1.5yr))/2 = 22.5% in order to trigger the reserve. That’s not out of line with the volatility of many commodities, but it seems like a heck of a lot of volatility to tolerate when there’s no reason to. Climate damages are almost invariant to whether a ton gets emitted today or next month, so any departure from a smooth price trajectory imposes needless costs (but perhaps worthwhile if cap & trade is really the only way to get a climate policy in place).

The volatility of allowance prices can be translated to a volatility of allowance demand by assuming an elasticity of allowance demand. If elasticity is -0.1 (comparable to short run gasoline estimates), then the underlying demand volatility would be 2.25%. The actual volatility of weekly petroleum consumption around a 1 quarter average is just about twice that:

Weekly petroleum products supplied

So, theoretically the reserve might shave some of these peaks, but one would hope that the carbon market wouldn’t be transmitting this kind of noise in the first place.

Strategic Excess?

I’ve been reading the Breakthrough Institute’s Waxman Markey analysis, which is a bit spotty* but raises many interesting issues. One comment seemed too crazy to be true: that the W-M strategic reserve is “refilled” with forestry offsets. Sure enough, it is true:

726 (g) (2) INTERNATIONAL OFFSET CREDITS FOR REDUCED DEFORESTATION- The Administrator shall use the proceeds from each strategic reserve auction to purchase international offset credits issued for reduced deforestation activities pursuant to section 743(e). The Administrator shall retire those international offset credits and establish a number of emission allowances equal to 80 percent of the number of international offset credits so retired. Emission allowances established under this paragraph shall be in addition to those established under section 721(a).

This provision makes the reserve nearly self-perpetuating: at constant prices, 80% of allowances released from the reserve are replaced. If the reserve accomplishes its own goal of reducing prices, more than 80% get replaced (if replacement exceeds 100%, the excess is vintaged and assigned to future years). This got me wondering: does anyone understand how the reserve really works? Its market rules seem arbitrary. Thus I set out to simulate them.

First, I took a look at some data. What would happen if the reserve strategy were applied to other commodities? Here’s oil:

Oil prices & moving average cap

Red is the actual US weekly crude price, while purple shows the strategic reserve price trigger level: a 3-year moving average + 60%. With this trajectory, the reserve would be shaving a few peaks, but wouldn’t do anything about the long term runup in prices. Same goes for corn: Continue reading

Reactions to Waxman Markey

My take: It’s a noble effort, but flawed. The best thing about it is the broad, upstream coverage of >85% of emissions. However, there are too many extraneous pieces operating alongside the cap. Those create possible inefficiencies, where the price of carbon is nonuniform across the economy, and create a huge design task and administrative burden for EPA. It would be better to get a carbon price in place, then fiddle with RPS, LCFS, and other standards and programs as needed later. The deep cuts in emissions reflect what it takes to change the climate trajectory, but I’m concerned that the trajectory is too rigid to cope with uncertainty, even with the compliance period, banking, borrowing, and strategic reserve provisions. So-called environmental certainty isn’t helpful if it causes price volatility that leads to the undoing of the program. As always, I’d rather see a carbon tax, but I think we could work with this framework if we have to. Allowance allocation is, of course, the big wrestling match to come.

The WSJ has a quick look

Joe Romm gives it a B+

GreenPeace says it’s a good first step

USCAP likes it (they should, a lot of it is their ideas):

USCAP hails the discussion draft released by Chairmen Waxman and Markey as a strong starting point for enacting legislation to reduce greenhouse gas emissions. The discussion draft provides a solid foundation to create a climate strategy that both protects our economy and achieves the nation’s environmental goals. It recognizes that many of these issues are tightly linked and must be dealt with simultaneously. We appreciate the thoughtful approach reflected in the draft and the priority the Chairmen are placing on this important issue.

The draft addresses most of the core issues identified by USCAP in our Blueprint for Legislative Action and reflects many of our policy recommendations. Any climate program must promote private sector investment in vital low-carbon technologies that will create new jobs and provide a foundation for economic recovery. Legislation must also protect consumers, vulnerable communities and businesses while ensuring economic sustainability and environmental effectiveness.

The API hasn’t reacted, but the IPAA has coverage on its blog

CEI hates it.

Rush Limbaugh says it’ll finish us off,

RUSH: Henry Waxman’s just about finished his global warming energy bill, 648 pages, as the Democrats prepare to finish off what’s left of the United States. Folks, we have got to drive these people out of office. We have to start now. The Republicans in Congress need to start throwing every possible tactic in front of everything the Democrats are trying to do. This is getting absurd. Listen to this. Henry Waxman and Edward Markey are putting the finishing touches on a 648-page global warming and energy bill that will certainly finish this country off. They’re circulating the bill today. The text of the bill ought to be up soon at a website called globalwarming.org. The bill contains everything you’d expect from an Algore wish list. Reading this, I don’t know how this will not raise energy prices to crippling levels and finish off the auto industry as we know it. (More here)

Al Gore Armageddon

Time points out that the Senate could be a dealbreaker:

The effects of the already-intense lobbying around the issue were being felt across the Capitol, where the Senate the same afternoon passed by an overwhelming margin an amendment resolving that any energy legislation should not increase electricity or gas prices.

That’ll make it tough to get 60 votes.

Carbon Confusion

Lately I’ve noticed a lot of misconceptions about how various policy instruments for GHG control actually work. Take this one, from Richard Rood in the AMS climate policy blog:

The success of a market relies on liquidity of transactions, which requires availability of choices of emission controls and abatements. The control of the amount of pollution requires that the emission controls and abatement choices represent, quantifiably and verifiably, mass of pollutant. In the sulfur market, there are technology-based choices for abatement and a number of choices of fuel that have higher and lower sulfur content. Similar choices do not exist for carbon dioxide; therefore, the fundamental elements of the carbon dioxide market do not exist.

On the emission side, the cost of alternative sources of energy is high relative to the cost of energy provided by fossil fuels. Also sources of low-carbon dioxide energy are not adequate to replace the energy from fossil fuel combustion.

The development of technology requires directed, sustained government investment. This is best achieved by a tax (or fee) system that generates the needed flow of money. At the same time the tax should assign valuation to carbon dioxide emissions and encourage efficiency. Increased efficiency is the best near-term strategy to reduce carbon dioxide emissions.

I think this would make an economist cringe. Liquidity has to do with the ease of finding counterparties to transactions, not the existence of an elastic aggregate supply of abatement. What’s really bizarre, though, is to argue that somehow “technology-based choices for abatement and a number of choices of fuel that have higher and lower [GHG] content” don’t exist. Ever heard of gas and coal, Prius and Hummer, CFL and incandescent, biking and driving, … ? Your cup has to be really half empty to think that the price elasticity of GHGs is zero, absent government investment in technology, or you have to be tilting at a strawman (reducing carbon allowances in the market to some infeasible level, overnight). The fact that any one alternative (say, wind power) can’t do the job is not an argument against a market; in fact it’s a good argument for a market – to let a pervasive price signal find mitigation options throughout the economy.

There is an underlying risk with carbon trading, that setting the cap too tight will lead to short-term price volatility. Given proposals so far, there’s not much risk of that happening. If there were, there’s a simple solution, that has nothing to do with technology: switch to a carbon tax, or give the market a safety valve so that it behaves like one.

Continue reading

News Flash: There Is No “Environmental Certainty”

The principal benefit cited for cap & trade is “environmental certainty,” meaning that “a cap-and-trade system, coupled with adequate enforcement, assures that environmental goals actually would be achieved by a certain date.” Environmental certainty is a bit of a misnomer. I think of environmental certainty as ensuring a reasonable chance of avoiding serious climate impacts. What people mean when they’re talking about cap & trade is really “emissions certainty.” Unfortunately, emissions certainty doesn’t provide climate certainty:

Emissions trajectories yielding 2C temperature change

Even if we could determine a “safe” level of interference in the climate system, the sensitivity of global mean temperature to increasing atmospheric CO2 is known perhaps only to a factor of three or less. Here we show how a factor of three uncertainty in climate sensitivity introduces even greater uncertainty in allowable increases in atmospheric CO2 CO2 emissions. (Caldeira, Jain & Hoffert, Science)

The uncertainty about climate sensitivity (not to mention carbon cycle feedbacks and other tipping point phenomena) makes the emissions trajectory we need highly uncertain. That trajectory is also subject to other big uncertainties – technology, growth convergence, peak oil, etc. Together, those features make it silly to expend a lot of effort on detailed plans for 2050. We don’t need a ballistic trajectory; we need a guidance system. I’d like to see us agree to a price on GHGs everywhere now, along with a decision rule for adapting that price over time until we’re on a downward emissions trajectory. Then move on to the other legs of the stool: ensuring equitable opportunities for development, changing lifestyle, tackling institutional barriers to change, and investing in technology.

Unfortunately, cap & trade seems ill-suited to adaptive control. Emissions commitments and allowance allocations are set in multi-year intervals, announced in advance, with long lead times for design. Financial markets and industry players want that certainty, but the delay limits responsiveness. Decision makers don’t set the commitment by strictly environmental standards; they also ask themselves what allocation will result in an “acceptable” price. They’re risk averse, so they choose an allocation that’s very likely to lead to an acceptable price. That means that, more often than not, the system will be overallocated. On balance, their conservatism is probably a good thing; otherwise the whole system could unravel from a negative public reaction to volatile prices. Ironically, safety valves – one policy that could make cap & trade more robust, and thus enable better mean performance – are often opposed because they reduce emissions certainty.