Newsletter: Why Did Prices Crash at the California Carbon Auction?

 

Read our analysis of California’s last auction results
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Why Did Prices Crash at California’s Carbon Auction?
California carbon prices took a hit last week as the fourth auction cleared at $12.22 for V13 allowances and $11.10 for V16 allowances. 

CCA V13 contracts closed at $12.40 on ICE on Friday, a one dollar drop from the week before, and brokers reported a boost in activity as buyers sought to take advantage from the lower prices. In our view, the slowing demand for V13 allowances reflects the fact that many participants have already bought what they need for the year.

In contrast, demand for V16 allowances surged, signaling a boost in confidence in the programs’ long term prospects. Secondary market activity and prices for V15 and V16 allowances were also on the rise last week, with V15 closing at $12.05 and V16 at $12.55 on Friday. Read our post Weak Demand Sends Mixed Price Signals in California Carbon Auction for a detailed analysis of the auction results and participants.

The discussion is still ongoing regarding bill SB 605. In its July 3rd version, the bill restricted offset projects in the AB 32 cap-and-trade regulation to projects based in California. Such a restriction would cut available offset supply by 70 to 90 percent compared to current projections, worsening the expected shortage of credits available for use in the California carbon market, and escalating credit and allowance prices. These provision will probably be amended to include offset projects located in the US or in WCI partner jurisdictions. Whether international credits, REDD specifically, will make the cut is still uncertain – a change to that effect would wipe out a large potential source of supply for the California market, and would remove a source of much needed support for REDD globally.

That same SB 605 bill also mandates that funds in excess of the $500 million loaned to the General Fund be spent on programs and projects located within and benefiting disadvantaged communities, a popular provision that has drawn support from many social and environmental organization, and makes it likely to bill will be adopted on one form or other.

Is your Business At Risk from Climate Change?

Investors and stakeholders now routinely ask for climate risks and opportunities disclosure, and the bar is set to be raised as climate adaptation has been identified as a policy priority by President Obama. Four Twenty Seven has partnered with ISOS Group to provide a special session on climate risk disclosure as part of ISOS’s Sustainability Reporting Training course on September 4-5 in Mountain View, CA. Participants will learn about local and global climate impacts and most exposed sectors, tools to identify risks and opportunities across the value chain, and best practices for reporting climate risks.

Selling California Auctions

In case you missed it – read our primer on auctions: Selling California Auctions (Carbon Market Tracker, In Focus #20, May 2013), published jointly with Carbon Credit Capital LLC. The ten-page downloadable report provides a thorough description of the auction mechanics, participant dynamics, the role of utilities, and the use of auction revenues – a must-read for market participants!

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Sink or Swim in the Carbon Market

About Four Twenty Seven

Four Twenty Seven provides research and consulting services on carbon markets, climate policy and climate risk. Email or call if your organization needs help with its climate strategy!

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Upcoming Training Course

Registration is open for our next training course:

September 25-26, 2013,
San Francisco, CA

This two-day course provides an in-depth training on California cap-and-trade from an economic, regulatory, legal, and financial perspective. It will provide busy professional with a full update on all the recent rule changes and market developments, and delve into technical aspects of contracting and offset risk management. Click here for the detailed agenda.

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Roundtable: Industry Voices

How will the second period of cap-and-trade affect your sector, your organization, and your competitors? What are emitters doing to prepare for compliance? Join us for a roundtable discussion: 
California Cap-and-trade: Industry Voices, on September 12, 2013 in Los Angeles
featuring business representatives and market experts to discuss the best way to manage carbon risks in the second compliance period. Space is limited – register now!

427mt.com - The blog

About our blog

427mt.com is the reference blog on California cap-and-trade. Read us for our thoughtful analysis of key market developments, new regulations, and political trends affecting California’s carbon market. Email us with questions or to submit a guest post.

 

 

Weak Demand Sends Mixed Price Signals in California Carbon Auction

Results from California’s fourth carbon auction reflected slowing demand for V13 allowances as many participants have bought what they needed for the year. In contrast, demand for V16 allowances surged, signaling a boost in confidence in the programs’ long term prospects.

UDPATE (Aug 22): The number of participants and their classification for Auction 4 has been updated in the text and figure below.

V13 Clearing Price Falls

V13 allowances cleared at $12.22, below expectations and eight percent below secondary market prices – CCAs were trading at $13.35 a tonne on ICE yesterday. This drop will likely lead to a correction on the traded markets, and I expect prices will fall below $13 on the exchange within the next couple of days. The lower than expected clearing price was caused by weak demand from a smaller number of participants: 79 bidders, against 91 in February and 81 in May. Nine participants were new to the auction, with a noted entry of gas companies in the pool of bidders. Figure 1 below provides the breakdown by sector for each auction.

Financials Bored by Flat Market

Of particular interest, the number of financial participants dropped by a third, which translated as a smaller percentage of allowances purchased for speculative purposes: only four percent for each auction (current and future) against 10 and 14 percent respectively in May 2013. Flat prices and low liquidity in the secondary market have likely contributed to this lack of interest from financial players. Participation of industrials and governement entities also fell, which probably means that many of them have purchased what they need for 2013 already. If these trends are confirmed, we should expect weak demand in the last 2013 auction as well.

Figure 1. Who are the auction participants? (click to enlarge)

Auction participants Aug13

(See below for more explanations on the participant classification)

V16 Price On the Rise

The future auction created a bullish surprise – V16 allowances sold out, for the first time since the beginning of the program, and the clearing price was $11.10, 40 cents over the reserve price. This surge in interest in allowances for the second compliance period reflects the growing confidence of market participants in the viability and stability of the program. The increased demand for V16 allowances is also probably an effect of having better visibility on allocation in the second compliance period, one of the key elements ARB has been working on in its ongoing regulatory amendment process.

One Billion Dollars for Clean Energy

The auction raised a total of $138.5 million dollars for the state of California, up 18 percent from the May auction – thanks to the higher volume and price for V16 allowances, while IOUs saw the revenue from consigned allowances drop by 18 percent, from $151 million in May to $124 in August due to the lower V13 clearing price. Overall, since the first auction, the state of California has raised $395 million for the GHG Reduction Fund, while IOUs have received $626 million for the benefit of California electricity ratepayers, just over one billion dollars in total to be spent on emission reduction efforts and lower electricity bills.

 

Note on participant classification:
when counting and classifying auction participants, we distinguish between Investor-Owned Utilities (IOUs), Publicly-Owned Utilities (POUs or Munis), independent power plants, power merchants (who own more than one power plant), and power marketers. The distinction between power plants, power merchants and power marketers is important to get a better sense of how many bidders may also be buying for speculative purposes.

Indeed, power marketers and power merchants are entities that have a compliance obligation, either because they own one or several plants in California (merchants) or because they import electricity into California (marketers) or both. However, these companies are large financial or energy corporations like EDT Trading, Goldman Sachs, Morgan Stanley, Shell Energy and Citigroup Energy. They have sophisticated trading desks and it is quite possible, if not likely, that they also purchase allowances for speculation rather than purely for compliance. Because there is no way to know how much of the allowances they purchase could be over and beyond what they need for compliance, their purchase are all counted as ‘Compliance’ in ARB’s categorization – but these entities also contribute to market liquidity by acting as financial players.

Fourth Auction Preview

California is gearing up for its fourth auction in a context of bearish sentiment and regulatory uncertainty. Prices on the California market dropped below $14/ton late July for the first time in months, and CCAs have been trading on ICE between $ 13.70-13.80 a ton since then with low volumes. Friday’s auction will see 13.86 million V13 and 8.56 V16 allowances offered for sale.

The market’s bearish sentiment is likely driven by the regulatory changes proposed by the Air Resources Board on July 18, which could bring more free allocation to industry and natural gas emitters than previously expected. While the proposed regulatory changes don’t alter supply and demand fundamentals, they do signal that a number of large emitters – natural gas suppliers – may not need to participate actively to the traded market to be in compliance, lowering demand and liquidity.

Most immediately, this also means a number of potential buyers will abstain from participating to this upcoming auction since they might not need to buy allowances for their future compliance. The quiet summer and thin market could also discourage some financial players from investing in allowances as prospects for returns are limited with flat prices and low liquidity.

However, we don’t expect a price collapse at the auction – large buyers from the power and oil sector will continue to buy allowances, keeping prices from tumbling too low. We expect the V13 auction to be fully subscribed and clear around $13.5 a ton. The V16 (‘future’) auction, on the other hand, will likely suffer from the regulatory uncertainty and remain undersubscribed. We expect they will clear at the reserve price of $10.71.

Impact of SB 605 on the California Carbon Market

SB 605 as revised July 3rd, 2013 would restrict offset projects in the AB 32 cap-and-trade regulation to projects based in California. Such a restriction would cut available offset supply by 70 to 90 percent compared to current projections, worsening the expected shortage of credits available for use in the California carbon market, and escalating credit and allowance prices.

While offset protocols for U.S. projects approved and under consideration are forecasted to meet between 30 and 70 percent of total demand, supply from California-based projects would likely meet no more than 6 to 16 percent of cumulative demand for credits through 2020. The offset shortage makes it very likely (over 60 percent chance) that prices would reach the highest tier of the APCR in 2020, $82 a ton.

Yet higher prices in the carbon market are unlikely to incentivize a significant number of new offset projects in California due to institutional, regulatory and technical hurdles.

Download the full report Market Impact of SB 605.

Newsletter: Hot Summer Ahead for California

 

Hot summer ahead for California
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Hot Summer Ahead for California Carbon 

California is in the midst of a heat wave with two nuclear plants down. The Air Resources Board prepares major regulatory changes to the program rules. How long will CCA prices ignore the real world? 

California is experiencing today one of its worst heat waves in years, days after PG&E announced the unexpected temporary shut down of one of the two reactors at its San Diablo Nuclear plant, a 1,122 MW shortfall for Northern California power market. Since San Onofre’s nuclear plant won’t reopen at all, California is now struggling with meeting its peak demand under tough conditions – CA ISO issued yesterday a rare call for conservation across the state.

Meanwhile, Obama also turned on the heat on climate change, announcing a slew of federal regulations and incentives to reduce emissions and support climate adaptation across the country. The announcement bolsters California’s program, and will help keep prices low over the long term.

No rest for the weary – the Air Resources Board powers on with a number of regulatory reforms. Natural gas allocation was on the agenda early June, followed by the kickoff for the Scoping Plan Update. This high level review of California’s climate policy will be crucial in setting long term targets – 2030 and 2050, which will be a major driver of prices in the carbon market.

The latest ARB workshop focused on compliance timeline, transparency and price containment. The underlying question is: how much will it cost to meet California’s target – not so much the 2020 target, but the 2030 and beyond target – and is California willing to bear that cost? Our analysis weighs pros and cons of importing new credits and borrowing from the future.

The summer promises to bring more heat and more regulatory reforms, and maybe even the first official ARB offsets! CCA prices have safely stayed under $15/t so far – how long before the $150+ power prices push them past this resistance point?

Emilie Mazzacurati, Managing Director, Four Twenty Seven

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Selling California Auctions

In case you missed it – read our primer on auctions: Selling California Auctions (Carbon Market Tracker, In Focus #20, May 2013), published jointly with Carbon Credit Capital LLC. The ten-page downloadable report provides a thorough description of the auction mechanics, participant dynamics, the role of utilities, and the use of auction revenues – a must-read for market participants!

Copyright © 2018 Four Twenty Seven, All rights reserved.

Sink or Swim in the Carbon Market

About Four Twenty Seven

Four Twenty Seven provides research and consulting services on carbon markets, climate policy and climate adaptation. Email or call if your organization needs help with its climate strategy!

Picture of the SF Bay

Upcoming Training Course

Registration is open for our next training course:

September 25-26, 2013,
San Francisco, CA

This two-day course provides an in-depth training on California cap-and-trade from an economic, regulatory, legal, and financial perspective. It will provide busy professional with a full update on all the recent rule changes and market developments, and delve into technical aspects of contracting and offset risk management. Click here for the detailed agenda.

Picture of Los Angeles

Roundtable: Industry Voices

How will the second period of cap-and-trade affect your sector, your organization, and your competitors? What are emitters doing to prepare for compliance? Join us for a roundtable discussion: 
California Cap-and-trade: Industry Voices, on September 12, 2013 in Los Angeles
featuring business representatives and market experts to discuss the best way to manage carbon risks in the second compliance period. Space is limited – register now!

427mt.com - The blog

About our blog

427mt.com is the reference blog on California cap-and-trade. Read us for our thoughtful analysis of key market developments, new regulations, and political trends affecting California’s carbon market. Email us with questions or to submit a guest post.

 

 

Price Containment in California’s Carbon Market: a Difficult ARBitrage

On June 25, 2013, while the world was watching President Obama give a historical allocution on climate change, California emitters and regulators were absorbed in a nerdy and fascinating discussion on whether and how California’s cap-and-trade price ceiling mechanism should be amended. The Air Resources Board (ARB) brought some of the smartest minds in the country to discuss the proposal, which made for a very stimulating discussion on this altogether important issue of what is an acceptable cost to meeting the state’s reduction target, and what is the best way to keep costs under this acceptable level. This post largely draws on the arguments experts and industry participants laid out – for more details you might want to refer to their presentations as well.

Note that the same workshop also discussed two important topics that will likely see changes in the round of upcoming amendments in September: compliance timeline and data transparency. I’ll write about the implications of the compliance timeline when ARB stops moving dates around.

Why change the APCR

The Allowance Price Containment Reserve (APCR) is a mechanism by which a certain percentage of allowances are set aside from the main allowance budget in the California cap-and-trade program, and offered for sale on a quarterly basis at a prix fixe, starting at $40/$45/$50 in 2012 and rising to $65/74/82 in my estimates by 2020. The APCR is divided in three tiers, hence the three prices, and APCR allowances may only be purchased by compliance entities and cannot be resold – they go straight to an entity’s Compliance Account, which has a one-way revolving door for all compliance instruments.

The first concern with the APCR is that the pool of allowances (122 million total) could be exhausted  – modeling from the Energy Institute at Haas shows non-negligible odds of seeing all the APCR allowances sold out, after which prices could shoot up unchecked, possibly to three-digit numbers. Nobody likes the thought of that.

UC Berkeley's model shows a 3-22% chance that prices would get higher than the APCR.
UC Berkeley’s model shows a 3-22% chance that prices would get higher than the APCR.

The second concern is that, because nobody likes this idea, there is a widely shared expectation that policymakers would step in and try to prevent the APCR from getting depleted, either at the last minute or during a sudden high-price event. That’s also not a good idea – it’s very disruptive, potentially costly, and it undermines the credibility of the program. The intervention could come from the Legislature, from ARB itself, or even from the Governor, as provided in AB 32 section 38599. (a): “In the event of extraordinary circumstances, catastrophic events, or threat of significant economic harm, the Governor may adjust the applicable deadlines for individual regulations, or for the state in the aggregate, to the earliest feasible date after that deadline.” What is the point of writing 275 pages of regulations if regulated entities believe Superman Brown or his successor will step in and change the rules at the last minute?

The Emissions Market Assessment Committee, (EMAC), composed of economists from UC Berkeley, Davis, and Stanford, highlighted this issue in a presentation back in September 2012. Heeding the advice from EMAC, the Board mandated staff to bring to the Board, “by mid-2013, a proposal for incorporation into the cap-and-trade program one or more mechanisms that will achieve the policy objective of ensuring that allowance prices will not exceed the highest price tier of the Allowance Price Containment Reserve while minimizing the impact on existing allowances and maintaining the environmental objectives of the program” (ARB Board Resolution 12-51). Last week’s workshop was an opportunity for the ARB staff to discuss some of the ideas they’re looking at and gather feedback from experts and stakeholders.

What is the purpose of the APCR?

Cost containment is generally a very consensual idea – but it can mean different things to different people. In this case, the panel’s economists – Dallas Burtraw from RFF, Jim Bushnell from UC Davis, and Brian Murray from Duke University all agreed that the APCR was better suited to prevent short term price spikes and market manipulation than long term upward pressure driven by a large, sustained imbalance between supply and demand. Industry and market observers at large instead also seem to expect the APRC to be the backstop that guarantees that prices will stay in check even if supply and demand clearly cannot balance overtime under the top tier price of the APCR.

If the goal is to prevent upside price risk and volatility, the APCR is adapted and arguably only needs to be bolstered a bit, with a deeper reserve of compliance instruments, to act as a credible deterrent. But if the goal is to ensure that prices will never, ever go above the top tier price, and yet ensure that California will meet its target in any case, then ARB is really trying to square the circle – possibly in vain since a long term imbalance would in any case warrant a review of the program. In addition, panelists argued we’ll get plenty of notice before prices creep up to the reserve – if the first tier or two of the APCR get depleted over time, this will act as a warning sign and trigger scrutiny from a lot of players in any case. In my estimate, the earliest we might need APCR allowances to balance the market is the third compliance period, 2018-2020. That’s not to say a nasty combination of nuclear outages, wildfire-driven transmission breakdown and heat wave couldn’t push prices high this summer – but this kind of temporary price spike is precisely what the APCR should contain effectively.

What is a good cost-containment system?

Jim Bushnell outlined three important qualities for a good cost-containment system:

  • It should be ex-ante transparent, since a deterrent only works if market knows it exists
  • It should be credible, both in terms of price level and mechanism
  • It should be timely – it needs to kick in immediately when prices rise, not be dependent upon regulatory or political action

Bushnell and Murray both questioned the term “environmental objectives” of the program cited in Res. 12-51. Since we’re talking about greenhouse gas (GHG) emissions, a global problem in essence, one might want to consider emission reductions from a global standpoint as well, or at least not exclusively focused on California. Murray insisted on two dimensions to consider: the timing and the spatial location of GHG emission reductions. California’s program already provides flexibility on both accounts – reductions may take place at any facility in state, or in Quebec, or in other states for some offset projects, and the banking and APCR already provide some flexibility on time. When it comes to GHG emissions, argued Murray, timing matters a little bit (at least within such a short time period), and space doesn’t. Hence California would still be meeting its environmental objectives if it relied on emission reductions taking place in other geographic location – say, the EU or Australia for example…

ARB’s proposal

ARB staff laid out a wide range of options that were received with a mixed response:

  1. Do nothing. Received a thumb down from the panelists – if there is up to 22% chance that the APCR will run out, it’s not effective and needs to be strengthened. Moving on.
  2. Cancel (temporarily) the compliance obligation – also a losing proposition. It adds disruption, and potentially creates equity issues amongst compliance entities, a lot of whom have emissions that vary a lot from one season to another (e.g. power generators and food processors)
  3. Delay compliance obligation – called “staggering” by Dallas Burtraw, this would effectively create an overlap between compliance period, allowing emitters to use allowances from the new compliance period to meet their obligation from the previous compliance period. Yikes! The compliance timeline is complicated enough as it is – shall we really make things more complicated by changing the rules at the last minute? Tell me about disruption… That option was also shunned by the other panelists.
  4. Allowing compliance via the payment of a fee rather than by turning in compliance instruments. To me that’s just a rhetorical difference. If the fee revenue is used to purchase credits 1:1 from outside the program, you might as well require emitters to surrender said credits – skip to proposal 5. If the fee revenue is used for other purposes, such as long term R&D in energy technology, it’s akin to a “safety valve” as proposed in some federal cap-and-trade bills back in 2008-2009, where the supply of additional allowances is unlimited in order to guarantee prices – and therefore would likely fail to meet the environmental objectives of the program. Go straight to jail and don’t pass go.
  5. Replenish the APCR with additional credits, to provide a larger safety cushion and signal to the market that regulators are serious about keeping prices low and discouraging attempts at market manipulation by making it much more costly to try to create artificial scarcity on the market. By far the most discussed option, and in my view the best option by far, but of course the question is – how?

How to replenish the APCR?

Once again, ARB staff laid out a wide array of options – I’ll shoot down a few right away to focus on the ones that matter most from my standpoint.

  • Require additional reductions pre-2020 from sources not covered by the program. Uh, good luck with that. There’s a reason they’re not covered after all – emissions are difficult to measure and potentially costly to curb in the agricultural and forestry sector. Waste is already regulated. And all of them together make up a mere 13.5% of covered emissions – a tough ratio if we expect any meaningful number to come from such a small cumulative sector.
  • Redistribute allowances in the 2013-2020 period. I’m not sure I fully get it. Set more allowances aside to put it the APCR? That would not change the overall supply and demand balance, only make it more likely that we’re at the APCR price. There’s very little wiggle room in any case.
  • Require additional post-2020 emission reductions. We don’t know what emission reductions will be required post-2020 – how could we commit to more? It’s going to be a while before ARB sets a 2030 and beyond allowance budget (that’s part of the Scoping Plan Update, which then needs to be turned into actual regulations), so I’m not sure that would meet the “credible” criterion, since it would have to be drafted in very vague terms in the upcoming round of regulations.
  • Borrow from post-2020. I don’t really like that option either – for the reasons as just mentioned, and also because it seems to me that it’s making a silent assumption that we’re going to magically find a technology that will reduce emissions so much that we’ll meet our post-2020 target easily, so we can even borrow some of those future reductions to meet today’s target. I’m always a little weary of this faith in technology – it might be so, and then the world will be a better place and I can’t wait to see it. But it might not be so, and then we’ll be stuck with an even harder to reach target, and we won’t have made the right investments at the right time. It is worth mentioning, though, that panelists thought it most important and useful that ARB publish the allowance budget for post-2020 well in advance, as a long-term cost containment measure – it might push prices up in the short term, but it would ensure the necessary investments are made early on to meet the later cap.
  • Procure additional credits or allowances – my favorite option, but of course, the devil is in the details.

Shall we buy Made in California credits only?

This is where the crucial question of spatial flexibility arises. Should compliance instruments come from California only? From the rest of the U.S.? From the rest of the world? Could California buy allowances from other compliance programs as a way to replenish the APCR?

When it comes to California-based offsets, as discussed earlier, the potential is extremely limited since most sources of emissions are already covered in some form or fashion by the cap-and-trade program, or a regulation, or economic incentives. There is a large pool of offset credits in the U.S. outside of California, which would require ARB to consider offset protocols that are not currently eligible for compliance, such as industrial processes or land-use projects, which could provide large volumes and incentivize reductions in other states. This option has the benefit of reluing on well-known, trusted organizations – the current registries. But if those offsets are good enough for the APCR, should they allowed for compliance in general?

Outside of the U.S., California could consider selected credits from the Clean Development Mechanisms, following the new qualitative restrictions imposed by the EU ETS, whereby projects have to be located in Least Developed Country only. No more industrial gas from South Korea or “efficient” coal plants from China. California could also build on its existing political partnerships with Shenzhen or Mexico. Other options include EU Allowances themselves, or Australian allowances, or New Market Mechanisms under the UNFCCC. The options are many, and the hurdles not as insurmountable as one might think.

And then of course there is the Regional Greenhouse Gas Initiative (RGGI), long-time political partner of California, but long plagued by its overallocation. RGGI would be a natural place to look for out-of-state additional allowances, but only once the program’s fixes are implemented. And RGGI’s very low price ceiling might be an issue as well.

The panelists made two very important points on this issue. First, “every ETS has their warts,” said Bushnell. No point in pretending California has a perfect system and other markets are not worthy of its attention (really, who would think that?!…). The allowances are solid emission reductions in all of these programs, it’s only a matter of supply and demand – low prices don’t stand for low quality. Second, Burtraw suggested allowances from other ETS that are significantly cheaper could be converted through some kind of exchange rate or trading ratios – building on a recent paper he published at RFF. For example, California could buy five RGGI allowances at $10 each, sell one APCR allowance for $50 to a California emitter and retire the four others. In addition, Bushnell also insisted that the State of California buying allowances from other programs under strict conditions was nothing like a full linkage where private entities could buy allowances directly from their counterparts in other trading systems – an important precision since California is in no rush to establish such broad linkage with other markets.

Policy expectations and recommendations

The APCR debates touches to the very heart of California’s climate policy. The underlying question is: how much will it cost to meet California’s target – not so much the 2020 target, but the 2030 and beyond target, and is California willing to bear that cost? Does it make sense for California to try to go it (and pay for it) alone or should California rely on more emission reduction imports, just like it takes responsibility for emission imports?

I think it’s important to circle back to the distinction between short term and long term price containment. The APCR is made to prevent extreme volatility, short term spikes, it won’t do as a long term price ceiling. To meet its goal of preventing sudden, temporary price increases, I would largely prefer to see the APCR being replenished with allowances from other reputable trading systems, like RGGI and EU ETS, using a trading ratio that would ensure eager Californians get their money’s worth. As a nice collateral benefit, it would send a positive political signal at a time where the rest of the country is just starting to get its act together on emission reductions.

Yet I expect ARB might shy away from this solution, and will prefer the vague but reassuring option of borrowing from post-2020 – which is more a way to focus regulated entities on the big picture and pressure them into early reductions than real new supply for the APCR.

As much as I support the idea of expanding California’s cap-and-trade to additional offset protocols from the U.S. and abroad, including REDD and some carefully selected CDM project types and locations, I don’t think this is the right time or the right way to introduce such offsets into the program. ARB would be all too easily accused of letting through the back door credits that have been excluded from the current regulations. In a context where the California Senate just recently passed SB 605, a bill that requires ARB to “limit the use of offsets, to the maximum extent feasible, to those offsets originating and achieved within the state,” it probably wouldn’t go over very well. (The bill is now being amended in the Assembly.)

When it comes to long-term cost containment, I think it will be absolutely crucial for California to re-open the debate on international offsets and linkages down the road, but it should do so through the front door, using the same process it currently uses for examining new offset protocols, and not via the APCR. It may come to a point where California will have to recognize that it may not be able to solve this problem alone, and that relying more on its may will support its long term strategy and the global, joint goal of reducing GHG emissions.

Obama’s Climate Action Plan: Good News for AB32, Bearish Signal for California Carbon Prices

A little late to the game, but with renewed enthusiasm, President Obama laid out on June 25 a comprehensive climate action plan for the United States with greenhouse gas (GHG) regulations from the Environmental Protection Agenday (EPA) as the centerpiece. How will the regulations interact with California’s carbon market? Is federal action good news or bad news for California?

EPA regulations – a warm embrace for state action

EPA regulations have been years in the making – EPA’s authority to regulate GHG under the Clean Air Act was affirmed by the Supreme Court in 2007 by finding that GHG were, indeed, a harmful pollutant that fell under the authority of the Clean Air Act. The environmental agency has since been laying out all the pieces of the puzzle to prepare for comprehensive GHG regulations. EPA started with regulating “mobile sources” (cars and trucks) – and California played a key role in pushing, pulling and otherwise massaging its cutting-edge state GHG-intensity standard for transportation emissions into federal policy. Similarly, California and other states like New York and Massachusetts were prime movers in the newly announced standards by suing EPA, and they have been have been closely engaged with academic and advocacy groups since to think through how their cap-and-trade programs could fit snugly within the broader EPA regulations rather than be squashed by federal preemption.

It turns out the Clean Air Act (CAA) lends itself well to this exercise. The EPA will unroll its proposal under Section 111, which mandates the EPA to regulate harmful pollutants for new and existing “stationary” sources (power plants, industrial plants, boilers, etc). For existing sources, this section essentially follows the federalist model frequently used in the CAA. It directs EPA to set the standard – for example, how much GHGs power plants should be allowed to emit for each MWh they generate – and let states develop individual plans to implement and enforce this standard.

By many reports, a robust conversation has been taking place over the past years between California, RGGI states and other climate-friendly states, and the EPA, on whether and how the existing state cap-and-trade programs would be an acceptable way for those states to reach whatever standard the feds would eventually set. The answer is, in principle, yes, although much modeling and technical analysis will need to take place to support the states’ argument that they will reach at least an equivalent emission reductions from the pre-existing programs.

Implementing EPA regulations through state cap-and-trade

California and RGGI are grappling with different issues. The issue for California is that its cap-and-trade program covers more than just the power plants in California that EPA’s standard would cover. Instead, the cap-and-trade program covers plants that emit over 25,000 tonnes (instead of EPA’s threshold of 25 MW capacity). It also covers power imports and emissions from most industrial sectors and the transportation sector. It accepts offset credits from a diverse and growing list of altogether different sectors across the country and, potentially, internationally. Finally, the program is also linked to the province of Quebec, which means some of California’s emission reductions might take place out of the U.S. altogether. All these scope questions will need to be disentangled from the effect on California’s specific, regulated facilities. Yet California officials following Obama’s announcement were confident [LINK] that their program would qualify for some form of equivalency under the upcoming regulations.

RGGI has a different challenge ahead: unlike California, the northeastern carbon market covers only the power sector in participating states, and uses the same capacity threshold, but states will need to get the EPA to agree on one plan for all nine states. That’s the essence of emission trading, reductions take place in the most cost-effective location, not necessarily evenly split amongst states – but that might require tweaking to fit under the upcoming regulations.

This could have an unforeseen effect as other states that were hesitant but contemplated local cap-and-trade, like Washington, Hawaii or Illinois, might find that this is their preferred way to meet EPA’s future standards. And if states are allowed to bundle their target and emission reductions, they could even consider linking their program, making for a larger, multi-state carbon market. Many of the former WCI states have remained closely involved in the development of the cap-and-trade program until fairly recently, and could come back into the fold without too much trouble. Besides the politically liberal coastal states Washington and Oregon, heavy emitters with major electricity customers in California, like Utah and Arizona, could find that piggy-backing on California’s program is the cheapest option for their own residents and ratepayers.

Implications for California businesses and regulated entities

For California businesses, federal carbon regulations means going from a situation where California businesses might have faced higher production costs than their out-of-state competitors due to higher electricity and gas prices, to a situation where California companies may be more competitive than the other guys. Cap-and-trade is, in theory, the most efficient way to reach an emission reduction target, so that the cost will be lower than it otherwise might have been under plain regulations.

Moreover, California businesses have been following these rules for five years already. They mostly know what to expect, and can get on with business while their counterparts in other states are still getting up to speed and staffing up their compliance office. Many have made, or plan to make, significant investments in efficiency and other strategies to reduce their carbon costs. Potentially, California businesses that have been engaged with AB 32’s progress to date will have a leg up on companies struggling to follow and comply with new rules, and new uncertainty, in other states.

Market Implications: bearish signal for prices in California

These developments send conflicting price signals. In the short run, Obama’s commitment to climate policy sends a bullish signal for the market’s political viability and long-term support. It bolsters its foundations and makes it less likely to be turned over by a new Governor or struck down for legal reasons. Yet prices have remained flat since Obama’s announcement, possibly indicating that traders were not too worried about the program’s longevity.

A lot of the measures from the climate plan, however, will contribute to bringing emissions down in and out-of-state. In-state, Obama’s climate plan will bring new funding for energy efficiency and renewable projects, and set standards for buildings and appliances that will help meet and further California’s climate goals. In addition, by forcing all power plants to reduce their emissions in neighboring states, EPA regulations will lower emissions from imported power in California, which are covered under the cap. The combination of the two should lower the cost of compliance for market participants and therefore sends a bearish signal over the long term. The actual impact on emissions will only be quantifiable when the detailed regulations come out, along with details on grants, funding and new standards for the energy sector.

Scoping Plan Update: What to Expect

On June 13, 2013, the California Air Resources Board (ARB) held a day-long workshop to kick off the stakeholder process for the Scoping Plan update. Presenters from various California agencies discussed high level plans to reduce emissions further from the energy, transportation, agriculture, water, waste, and land use. The workshop confirmed that cap-and-trade would play a central role in California’s post-2020 climate policy, but the key question is: what will the cap look like after 2020?

AB 32 and the 2008 Scoping Plan

California Global Warming Solutions Act, AB 32, mandates the Air Resources Board to develop a “scoping plan for achieving the maximum technologically feasible and cost-effective reductions in greenhouse gas emissions” by 2020. The first version of the Scoping Plan was approved in December 2008 and was instrumental in establishing California’s overall climate strategy. Indeed, the 2008 Scoping Plan included a thorough cost-benefit analysis of various options to reach California’s 2020 target, and concluded that a combination of a cap-and-trade program with a wide array of complementary policies was best suited to the challenge ahead, which provided the foundation for California’s climate policy as we know it today.

The law also required ARB to update the scoping plan every five years, which brings us to the June 13 workshop. ARB is working in collaboration with other agencies to release a draft late August, with the goal of presenting a final version to the Board on November 21-22 this year.

What to expect from the Update?

The most interesting element of this Scoping Plan update is not so much the ongoing assessment of how the strategy outlined in 2008 is performing – the consensus is that California is well on track to meet its 2020 target of 427 Mt. The interesting part is that ARB is using this as an opportunity to lay the groundwork and start thinking about what happens after 2020.
California does not have a target set by law, but Gov. Schwarzenegger set by Executive Order a target for 2050 at 80 percent below 1990 levels, the recommendation from scientists from the United Nations International Panel on Climate Change (IPCC) to avoid the worst impacts of climate change. This 2050 goal was further reinforced by Gov. Brown as part of his zero-emission vehicle strategy.

Just to put things in perspective, 80 percent below 1990 level looks like this…

2050 Target

What Role for Cap-and-Trade Post-2020?

California’s cap-and-trade program is currently scheduled to last for three compliance periods: 2013-2014, 2015-2017 and 2018-2020. The regulation does not indicate what the cap might look like after 2020, or even if the program should continue at all. The June 13 workshop confirmed without any ambiguity that cap-and-trade would continue beyond 2020, and remain a centerpiece of California’s climate policy.

The Scoping Plan Update will not be the place for an extended evaluation and revision of the regulation, though. ARB is currently in the process of making final changes to the cap-and-trade regulation – both processes will run in parallel and the Scoping Plan will keep a bird’s eye view on all the GHG reduction policies rather than interfere with ongoing regulatory processes.

Now, if cap-and-trade does continue past 2020, the question is: how steeply the cap will decline after 2020? The scoping plan update will indeed address this issue, in particular by attempting to set intermediate target(s) between 2020 and 2050. How fast should emissions decline? How fast can emissions decline?

Reaching the 2050 target

How will California reach its 2050 target? Is it even feasible? ARB regulators acknowledged they didn’t have a crystal ball, and that it was the hardest issue they were grappling with. Two landmark reports have looked in depth at the technology that would be needed to meet the 80 percent below 1990 levels. The California Council on Science and Technology and the Lawrence Livermore National Laboratory found in their California’s Energy Future: the View to 2050 report that California could achieve roughly 60 percent below 1990 level with technology with “largely know about today” if those technologies are “rapidly deployed at rates that are aggressive but feasible.” Reaching the 80 percent target, however, would require “significant innovation and advancements in multiple technologies.” E3 and Lawrence Berkeley National Laboratory in a Science article entitled: The Technology Path to Deep GHG Emissions Cuts by 2050: the Pivotal Role of Electricity, also concluded that reaching this target would require technologies that are not yet commercialized to electrify the transportation sector.

Making the right choices today

Looking at the long-term target is a stern reminder on the importance of choices made today with regard to auction revenues and investments. Investing in R&D, in infrastructure development and deployment are going to be absolutely crucial to the transition to a low-carbon economy. In that regard, the idea of waiting another six to twelve months before deciding where the monies shall be used may after all be the right decision.
Meanwhile, it is safe – wise even – for market participants to assume that 2020 will bring a more stringent cap, declining rapidly over time and that cap-and-trade is here to stay.

California’s Third Auction Results Show Program’s Good Health

The third auction cleared at $14.00 for V13 allowances, in line with our expectation and with prices on the secondary market over the past months. Demand for current vintage was sustained, with a much narrower bidding price range (the maximum price was $16.67, while in the first auction it was over $90). Regulated entities remain the main buyers, with 90% of the permits purchased by compliance entities.

Demand for future vintage was stronger than in the first two auctions, with 80% of the allowances sold, showing increasing confidence into the design of phase 2 and the long term viability of the program generally. The clearing price for Vintage 16 allowances was the reserve price, $10.71.

81 in total participants joined for the auction, slightly less than at the last auction (91), but with a number of new players who had not bid in previous auctions. Municipal utilities in particular and smaller industrial players like food processors entered the primary market. This shows companies are getting better prepared and more confident in their ability to manage the program’s requirements.

The state raised a total of $117.6 million (V13 and V16 revenues combined), which brings total revenues from the three auctions so far at $256 million, in line with the Governor’s revenue projections for FY 2012-2013 and half way through the projects $500 million revenue for FY2012-2013 and FY2013-2014 currently under discussion in the budget.

Overall, the auction results show increased maturity from program participants and from the market and confirm the good health of the carbon market in California.

More detailed analysis of the auction results to come.

Newsletter: What to Expect from California’s Next Auction?

 

What to expect from California’s third carbon auction?
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What to Expect from California’s Next Auction? 

California’s third carbon allowance auction will take place on Thursday May 16. What is the outlook for clearing prices? How will the revenues be spent? 

Price Outlook: Still Waters Run Deep
I expect this coming auction’s results to be fairly similar to the last auction’s results back in February: healthy demand for current year permits with a clearing price between $13.50 and $14.00, and muted demand for future year’s vintage, which will likely clear at the price floor. Prices have been very stable since the last auction, staying consistently in the $14-$15 a ton range on the secondary market. But history is not guarantee of the future, and  the summer could bring more volatility on the market – read here why.

Auction Revenues: Follow the Money
Understanding California’s auction is no small feat – and yet being able to follow the complex flows of allowances and revenues between the California state government and market participants is essential to the underpinning of the state’s cap-and-trade program. How much money is at stake, and who will benefit from it? Explore our map to finally understand the ins and outs of auction dynamics and revenue allocation.

California to Link with Quebec
California is not alone anymore – the Golden State’s carbon market will officially be ‘linked’ with Quebec starting January 1st, 2014. Why Quebec, and what are the implications for the California market? Will California link with other markets? Read our analysis of what this means for California.

One market California is probably not going to link with any time soon is the EU ETS. Times are tough for climate policy in Europe, and the market has been getting a beating from lawmakers in Brussels. After the EU ETS crash – Is California headed the same way? Read more about the commonalities and differences between California and the EU ETS, and why California should avoid the main pitfalls EU regulators are now struggling with.

Emilie Mazzacurati, Managing Director, Four Twenty Seven

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