10 April 2011

European Commission “Scaling up climate finance”: what does it actually mean?

The European Commission says $100 billion a year by 2020 for “climate funding” in developing countries is “challenging but feasible.” But read behind the press release, and what is actually being proposed shifts even further away from the idea that climate finance should form part of an obligation (or “debt”) incurred, alongside other industrialised nations, for playing a disproportionate role in causing climate change in the first place.

What follows are some notes on a new European Commission document prepared as a follow up on the UN High Level Panel on Climate Change Financing (AGF). The report was commissioned by ECOFIN (the Economic and Financial Affairs Council, which is the meeting of EU finance ministers) in December 2010.

Like most Staff Working Documents, its 46 pages are a dry and technical affair, but unlike most such documents it contains some interesting clues as to the direction of the Commission's thinking.

Carbon markets are central to the EU's approach, as are a broad range of other “private financial flows”. Public climate finance is defined in increasingly blurry ways, including promoting the EIB's role, double-counting aid flows, and blurring the boundary between public and private financing (eg. suggesting that more public sector equity be provided for private projects – in essence, because the banks aren't lending so much as a result of the economic crisis).

What are “private financial flows”?

* The general orientation of the document is that “Private financial flows will depend largely on developing countries' capability to create a general business environment which is attractive for domestic and international investment. ” (p.10) However, it is noted that the economic crisis has “severely limited access to private financing worldwide.” (p.45). It suggests, in this context, that MDBs and other IFIs act as “market maker” (p.45), in which the EU could be a partner through ”measures such as co-investments, risk sharing mechanisms, fee incentives, sanction mechanisms, etc. ”

* The boundary between public and private finance is becoming very blurred. For example, the document notes “The blending of grants and loans as well as equity and quasi-equity constitute innovative mechanisms to enhance support to EU external priorities and to multiply the impact of EU external assistance (p.43)

* A number of “innovative” instruments are proposed to enhance private financial flows. These include : “Instruments to improve the risk-return profile include the provision of guarantees, technical assistance or interest rate subsidies to support the issuance of debt for climate projects. Public-Private Partnerships (PPPs) can spread the costs and risks of financing of public goods over the lifetime of the asset which can considerably alleviate the short to medium-term pressure on public budgets. Using public funds to inject equity capital into companies or projects can be another mechanism to mobilise private investment. Public support for the use of market-based insurance schemes covering natural disasters can leverage sizeable amounts of private finance for adaptation. Other examples of innovative mechanisms that could raise private finance for climate actions are Advance Market Commitments (AMCs), tax discounts, access to finance, or standards of corporate social responsibility. ” (p.12) (see also p.39)

Public finance

* The document offers an “indicative table of financial contributions from Annex I states” (p.19) and suggests a central role (esp. in adaptation) could be played by the Green Climate Fund, which it sees as “likely to become bigger than the existing funds under the Financial Mechanism of the Convention ” (p.19)

* On adaptation, it is noted that“donor support for microfinance institutions (MFIs) could also be regarded as climate finance to some extent, ” (p.39)

Carbon markets

* The documents recommendations include the (predictable) suggestion that that the EU “work with other developed countries interested in setting up cap-and-trade systems, ... make progress on the reform of the Clean Development Mechanism, and ... promote a sectoral crediting mechanism; ”

* More interestingly, “Commission analysis shows that with current pledges, allowing the full banking of the Assigned Amount Unit surplus and choosing the Kyoto Protocol target as a starting level for the emission reduction paths for the period 2013-2020 would result in no demand for international credits additional to what has already been enabled.” (p.34) This begs a significant question as to what the use of the EU's proposed market mechanisms would be? In fact, it seems to signal a potential lack of demand that would undermine prices. As such, figures for the proposed “financial flows” that the EU attaches to such mechanisms should be treated with extreme caution, and may leave a large climate financing hole.

* For those with an interest in carbon markets, these projections are also useful to bear in mind (and offer one of the clearer projections relating to demand for sectors outside the EU ETS, ie. those covered by “effort sharing” Directive: “Current EU ETS legislation allows for carbon offsets of about 1.6- 1.7 Gt of CO2 in the period 2008-2020 (i.e. about 130 Mt of CO2 per year). Additional demand for credits will come from the sectors outside the EU ETS amounting up to approximately 700 Mt over the period of 2013-2020, i.e. roughly 88 Mt of CO2 per year until 2020. At the current price for CDM credits of some EUR 13 per tonne of CO2, the demand by the EU could generate roughly EUR 3 billion of financial flows to developing countries per year, not taking into account additional flows triggered by investments underlying CDM projects.” (p.35). Here as elsewhere (p.10 of the report), figures on CDM “investment” treat investment as the same thing as the cost of carbon credits sold (ie. these figures don't try to account for the large sums skimmed off by project developers, etc. ... and other financial transfers – eg. returns on equity borrowed to finance projects; intra-company financial flows from South to North).

MRV (measuring emissions)

* On MRV, it notes that “A new major challenge in the context of long-term climate finance will be the monitoring and accounting of private flows.” (p.20)

Double-counting aid flows

* Double-counting aid flows now seems to be normal Commission practice. Figures on existing climate finance are said to include allocations from the European Development Fund (EDF) (p.20), as well as a proportion of the EU's existing 2007-2013 budget that was allocated to the Instrument for Development Cooperation (DCI). (p.21), including subsidiary thematic programmes such as "Environment and sustainable management of natural resources including energy" (ENRTP) with a total amount of approximately EUR 1.1 billion.” The document notes that “The ENRTP covers the additional budget allocation granted for fast-start climate change funding and the allocation for the Global Climate Change Alliance (GCCA). ” The EU's climate finance figures also seem to include money from “the Neighbourhood Investment Facility (NIF) [which] has approved more than EUR 100 million of grants for climate related projects” since 2008. (p.43)

New EU carbon tax

* The EU is seriously considering new carbon taxes. “The Commission intends to come forward, during the second quarter of 2011, with a proposal for a revision of the Energy Taxation Directive (ETD) to bring it more closely in line with the EU's energy and climate change objectives. The proposal will aim at, on the one hand, integrating an explicitly CO2-related element into the energy taxation system which would be applicable outside the EU ETS and, on the other hand, putting the remaining part of energy taxation on a neutral basis by linking it to the energy content of the products subject to taxation. In doing so, it will ensure consistent treatment of energy sources within the ETD in order to provide a genuine level playing field between energy consumers independent of the energy source used. Moreover, it will provide an adapted framework for the taxation of renewable energies and provide a framework for the use of CO2 taxation to complement the carbon price signal established by the ETS while avoiding overlaps between the two instruments. ” (p.31) More on this is also reported here.

Privatising the commons

The document suggests that “ETS auctions of allowances for greenhouse gas emission sources in energy and industry could deliver revenues of more than EUR 20 billion per year by 2020. According to the ETS Directive, Member States should spend at least half of these amounts on activities related to climate change, energy and low-emission transport, including in developing countries ” (p.8). It should be noted that(1) these funds are not actually earmarked, and many EU Member States would resist such a move; (2) in putting a value on auctioned permits, the EU is creating property rights from pollution which are drawn from a global carbon space (that the EU has already over-used its share of).

07 April 2011

EU Emissions Trading System: phase III on course for failure

Emissions trading is the European Union’s flagship measure for tackling climate change, and it is failing badly. In theory it provides a cheap and efficient means to limit greenhouse gas reductions within an ever-tightening cap, but in practice it has rewarded major polluters with windfall profits, while undermining efforts to reduce pollution and achieve a more equitable and sustainable economy. The third phase of the scheme, beginning in 2013, is supposed to rectify the “teething problems” that have led to the failures to date.

I've written a new briefing which can be found here. It shows that:

- The EU Emissions Trading System (ETS) has failed to reduce emissions. Companies have consistently received generous allocations of permits to pollute, meaning they have no obligation to cut their carbon dioxide emissions. A surplus of around 970 million of these allowances from the second phase of the scheme (2008-2012), which can be used in the third phase, means that polluters need take no action domestically until 2017. Proposals to curtail this surplus were discussed in the context of the EU’s 2050 Roadmap, but have been watered down in response to lobbying from energy-intensive industries.

- Companies can use 1.6 billion offset credits in phases ll and lll, mostly derived from the UN's Clean Development Mechanism (CDM). Over 80 per coent of the offsets used to date come from industrial gas projects, which EU Climate Action Commissioner Connie Hedegaard admits have a "total lack of environmental integrity". The Commission delayed a ban in the use of these industrial gas offsets to April 2013 in response to lobbying from the International Emissions Trading Association (IETA) and others.

- The ETS is a subsidy scheme for polluters, with the allocation of permits to pollute more closely reflecting competition policy than environmental concerns. Power companies gained windfallprofits estimated at €19 billion in phase l, and look set to rake in up to €71 billion in phase ll. Subsidies to energy-intensive industry through the two phases could amount to a further €20 billion. This has mostly resulted in higher shareholder dividends, with very little of the windfall invested in transformational energy infrastructure.

- The third phase of the ETS will still see significant subsidies paid to industry, despite the auctioning of permits in the power sector. Industry lobbying has resulted in over three quarters of manufacturing receiving free permits, which could yield at least €7 billion in windfall revenues annually. Energy companies successfully lobbied for an estimated €4.8 billion in subsidies for carbon capture and storage (CCS), with a smaller amount for "clean" energy that includes agrofuels. In addition, the Commission is undertaking a review of its "state aid" rules which could see the granting of direct financial subsidies to companies claiming that the ETS damages their competitiveness.

- The allocation of permits according to performance “benchmarks” was supposed to encourage a fairer and more efficient division of responsibility for emissions reductions in energy-intensive sectors such as cement, steel, paper and glass. But industry has been allowed to influence the benchmarking. For example, CEMBUREAU (the cement industry lobby) was instrumental in choosing what to measure (“clinker” not cement) and how to measure it. The final agreement saw the adoption of a lax standard that was initially proposed by CEMBUREAU. This will result in a surplus of pollution permits for the cement sector, allocated in a way that rewards the continued use of dirty and outdated production methods.

-Aviation will be included in the scheme from 2012. The sector will receive 85 per cent of permits for free, and the projected carbon cost is far lower than the equivalent tax breaks for aviation fuel. Inclusion in the ETS applies only to CO2 emissions, which obscures the greater impact of contrails and other gases.

Put simply, the third phase of the ETS will continue the same basic pattern of subsidising polluters and helping them to avoid meaningful action to reduce greenhouse gas emissions.

Download EU Emissions Trading System: failing at the third attempt

01 April 2011

EU Emissions Trading 2010: analysis of newly released figures

Once again, the EU Emissions Trading Scheme has awarded massive subsidies to the steel sector and other energy-intensive industries. It has even given out permits to pollute to factories that are partially closed. This has nothing to do with addressing climate change. Emissions trading is being used as an industrial subsidy scheme for polluters....

A provisional analysis of EU greenhouse gas emissions data for industries covered by the Emissions Trading System (ETS) shows that emissions rose by over 3.5 per cent in 2010, compared to 2009 levels.1

For a fifth time out of the last six years, the “cap” that the ETS is supposed to imposed was set too high. Complete data is only available for 8,833 installations (77 per cent of the total), but this shows that the allocation of permits under the scheme was 3.2 per cent (57.36 MtCO2e) higher than the actual emissions measured from installations covered by it.

These figures make a mockery of the claim that emissions trading reduces emissions. Factories polluted more, and the scheme set no limit on this additional pollution.

The 10 plants with the largest surplus of permits are all from the steel sector, and account for a combined surplus of 54.7 million permits. These 10 plants alone have received a a windfall profit of around €650 million. 2

The plant with the third largest surplus (Teeside steelworks in the UK, which was sold by Tata to Sahaviriya Steel Industries, Thailand's largest producer, in February 2011) has been partially mothballed, yet still managed to accrue a surplus of 5.76 million permits. This amounts to a windfall profit of around €70 million.

The breakdown (in sequence) of the most significantly over-allocated plants is as follows:

Allocation Actual Surplus Owner
19622025 8695288 10926737 ThyssenKrupp Steelworks, Duisburg, Germany
11335573 4583475 6752098 ArcelorMittal Galati, Romania
6953226 1188865 5764361 Tata, Teeside, UK (since sold)
11557631 6227169 5330462 Tata, Ijmuiden, Netherlands
9276102 4011551 5264551 Glocke Salzgitter, Salzgitter, Germany
13255657 8606105 4649552 ILVA (Riva Group), Taranto, Italy
8918495 4386583 4531912 ArcelorMittal, Gent, Belgium
9323815 5291346 4032469 ArcelorMittal, Gijon and Aviles, Spain
8655981 4771369 3884612 Krupp Mannesmann, Duisburg, Germany
5832055 2245809 3586246 ArcelorMittal Bremen, Germany


1This is based on data from 9579 installations, which account for 83.9 per cent of the total. The rest are excluded because data is not available yet. It is based on a total of 11409 installations (a figure that excludes the “closed” accounts which are listed in the EU database).

2These figures for the steel sector assume a €13 per ton price of carbon permits (EUAs), and incorporate a 10 per cent downward adjustment to take account of permit transfers relating to waste gases.