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US Carbon Emissions Trading Some Options That Include Downstream US CARBON EMISSIONS TRADING: SOME OPTIONS THAT INCLUDE DOWNSTREAM SOURCES Center for Clean Air Policy April 1998 Acknowledgments The primary author of this paper was David H. Festa, the Center’s Deputy Director. This paper was prepared under the direction of Ned Helme, Executive Director of the Center. This paper would not have been possible without the input of a number of people. In particular the author would like to thank the members of the Greenhouse Gas Emissions Trading Braintrust; Tim Hargrave of the Center for Clean Air Policy; and Jay Hakes and staff of the US Department of Energy’s Energy Information Administration, who provided their ideas and made themselves available for consultation. Alice LeBlanc was a driving force behind the transportation chapter. She contributed significantly to the formulation of the trading approach and the drafting of the transportation chapter. In addition, she improved the overall paper with her thoughtful commentary. Finally, the Center wishes to acknowledge the research and editing support provided by Jeff Fiedler. The Center for Clean Air Policy thanks the US Environmental Protection Agency’s Office of Policy, Planning and Evaluation for its support of the Greenhouse Gas Emissions Trading Braintrust project. The Center also extends it thanks to its Board of Directors whose dues provide some general support to the project. Cover photo: The main house at Airlie Center, the location of the Greenhouse Gas Emissions Trading Braintrust meetings. Photograph reproduced with the permission of Airlie Foundation. Additional papers in the Airlie series are available at the Center’s website, http://www.ccap.org. Printed copies can be ordered by contacting the Center for Clean Air Policy. phone: 202-408-9260, e-mail: [email protected] The Airlie Carbon Trading Papers The Airlie Carbon Trading Papers are intended to help lay the intellectual foundation for a US greenhouse gas emissions trading system, which is a leading policy option for realizing cost- effective reductions of greenhouse gas emissions. The papers are the product of a unique research, analysis and dialogue process directed by the Center for Clean Air Policy. Since November 1996, the Center has convened regular meetings of its “Greenhouse Gas Emissions Trading Braintrust”, a group of high-level representatives of industry, environmental organizations, state and federal government agencies and academe. The opinions expressed in these papers are those of the Center, though our views are informed by the extensive dialogue with Braintrust participants. Braintrust members and Center staff conduct research and analysis of key design and implementation questions, then bring their findings and proposals to the group for discussion. The purpose of this process is to investigate alternative design options in detail rather than to arrive at consensus on a preferred option. At the outset, the Braintrust identified a number of priority issues, including: definition of the instrument that would be traded, determination of who would be required to hold allowances, methods for allocating allowances, and the elements of the trading system compliance infrastructure. Braintrust members agreed to start with a focus on energy-related carbon dioxide emissions. Secondary issues identified by the Braintrust include the integration of additional greenhouse gases into the system, the incorporation of emissions reductions from forestry and land use activities and foreign countries, and the mitigation of any adverse impacts of carbon regulation on US industry. Why the “Airlie” Carbon Trading Papers? The Airlie Center serves as the backdrop for the Braintrust’s meetings. Situated outside the Washington, DC beltway in Warrenton, Virginia, Airlie provides an informal, congenial atmosphere that allows participants to leave their affiliations “at the door” and to build strong working relationships. These factors have been critical to the success of the Braintrust process. About the Center for Clean Air Policy Since its inception in 1985, the Center for Clean Air Policy has developed a strong record of designing and promoting market-based solutions to environmental problems. The Center’s dialogue on acid rain in the 1980s identified many of the elements of the SO2 control program that were adopted by the Bush Administration and eventually codified in the Clean Air Act Amendments of 1990. Since 1990, the Center has been active on the issue of global climate change. Center staff have participated in the Framework Convention on Climate Change negotiations and in domestic efforts to address greenhouse gases, analyzing and advocating market- based climate policies such as emissions trading and joint implementation. The Center brokered the world’s first energy sector joint implementation project. The Center is also active in the areas of air quality regulation, electricity industry restructuring, and transportation and land use. Table of Contents Executive Summary.....................................................................................................................1 1. Introduction .............................................................................................................................5 1.1.1 Familiar System..........................................................................................................6 1.1.2 Stimulus for Innovation...............................................................................................6 1.1.3 Non-Fossil Fuel Options .............................................................................................7 1.2 Challenges of a Downstream Approach ..............................................................................8 2. Electricity Generators ............................................................................................................12 2.1 Point of Regulation ..........................................................................................................12 2.2 Administrative Feasibility and Measurement Accuracy .....................................................13 2.3 Leakage...........................................................................................................................14 3. Industrial Sources ..................................................................................................................16 3.1 Point of Regulation ..........................................................................................................18 3.2 Measurement ...................................................................................................................21 3.3 Administrative Feasibility ................................................................................................23 3.3.1 Presence of Small Establishments..............................................................................23 3.3.2 Using the MECS for Regulatory and Enforcement Purposes ......................................24 3.3.3 Managing Changes over Time...................................................................................25 3.3.4 Coverage for the Non-Trading Establishments...........................................................25 3.3.5 Mechanism for Feedstocks and Offsets......................................................................27 3.4 Leakage...........................................................................................................................27 4. Commercial and Residential Sources ......................................................................................29 5. The Transportation Sector......................................................................................................30 5.1 Transportation Approaches ..............................................................................................32 5.1.1 Market Mechanisms in the Transportation Sector ......................................................32 5.1.2 Upstream Regulation ................................................................................................33 5.1.3 Downstream Regulation............................................................................................34 5.1.4 Integrating Upstream and Downstream Approaches..................................................36 5.2 Summary.........................................................................................................................37 6. Building a Downstream Program .........................................................................................37 Appendix 1: Research on the Impact of Changes in Gasoline Price and Increased Fuel Efficiency on Gasoline Consumption ...................................................................40 Appendix 2: Data Sources for Calculating Vehicle Manufacturer Greenhouse Gas Emissions ........................................................................................................43 Executive Summary A US greenhouse gas (GHG) emissions cap-and-trade system could be implemented either “upstream,” at the level of primary fuel producers, or “downstream,” at or near the point of emissions. While experiences with cap-and-trade programs have been good, a GHG program would be larger than existing programs. For that reason, design questions need careful evaluation. This paper accomplishes this for a downstream trading program that covers US carbon dioxide emissions. There are several reasons why a downstream system may be preferred over an upstream approach.
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