ACCOUNTING FOR EMISSION RIGHTS: AN ENVIRONMENTAL ETHICS APPROACH

Emma Zhang-Debreceny, whereby a central authority transforms GHG, Mary A Kaidonis, and of which „carbon‟ is one, into a new tradable Lee Moerman commodity (Andrew, 2008). It is assumed School of Accounting and Finance, that the value of carbon can be University of Wollongong, Wollongong, arrived at by trading emission rights that is, Australia. trading in the “right to emit pollutants” (IASB 2008a, para5). ABSTRACT Solomon and Lee (2000, p. 35) described We argue that the International Accounting ETS as a market means of “internalizing Standard Board‟s difficulty in arriving at a ”. Traditionally the cost of standard for accounting for emission rights, pollution is considered an and which is central to Emission Trading thus is excluded from production costs. By Schemes, is an opportunity to re-examine the giving carbon pollution a „price tag‟, it is issues from an environmental ethics assumed that entities would be given an approach. We critically evaluate the IASB economic incentive to reduce carbon approach which privileges profits, and views pollution in order to avoid the additional emission rights as tradeable entitlements to financial burden of having to purchase pollute. We consider social ecology, an emission rights to cover actual emissions. example of an environmental ethical perspective which holds that humans‟ In order that ETS succeed in reducing overall survival and the environment‟s emissions, there needs to be a limited supply are inextricably linked. We conclude that of emission rights, and as a scarce resource social ecology can inform accounting the market is meant to determine the most standard setters about the accounting efficient price of emission rights (Andrew, treatment of emissions rights. 2008). Price would influence whether it is more efficient for a firm to adopt carbon 1. INTRODUCTION friendly technology rather than keeping the Climate change presents challenges for all same polluting technology and buy emission stakeholders - individuals, policy makers, rights. Blass (2006) argued that by allowing industries, and the eco-system (IPCC 2008). participants of an ETS to buy or sell emission In 1997, the Kyoto Protocol was released as rights it would mean that the Kyoto target an international response to climate change, could be achieved by the most cost efficient whereby industrialised countries agreed to means. For entities that are unable to meet reduce Greenhouse Gas (GHG) emissions the emissions reduction target, they would “by 8% between 2008 and 2012, in relation have to purchase additional emission rights to 1990 levels” (Blass, 2006, p. 30). The from „cleaner‟ entities, and/or a central challenges and responses to climate change authority and/or a „greener‟ country in order also provide an opportunity to engage in to cover their actual emissions level. While a ethical approaches to the environment, not central authority sets the maximum allowable only by immediate stakeholders but by carbon emissions quantity, the market accounting standard setters. mechanism is used to trade in permits and The dominant response of industrialised therefore will drive the price of emissions countries to abate GHG has been to apply rights (Blass, 2006, Andrew, 2008). market mechanisms (Lohmann 2009, Despite the fact that ETS have been in MacKenzie 2009). operation for about 4 years, according to the Schemes (ETS) provide a market mechanism World Bank they were estimated to be worth

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around “£15billion in 2007” worldwide 2. BACKGROUND (PricewaterhouseCoopers, 2008, p.18). Global ETS participants continue to await Companies participating in ETS need to comprehensive and clear guidance from the reflect this impact in their financial reports. International Accounting Standards Board Accordingly, the international accounting (IASB). The IASB‟s efforts to develop. profession, through its standard setting comprehensive guidance on accounting for guidelines, is required to engage with this emission rights have already been extremely new mechanism for carbon abatement. While challenging. The IASB‟s International it is the notion of a „carbon pollution cap‟ Financial Reporting Interpretations that is expected to set the goal of emissions Committee (IFRIC) issued IFRIC 3 Emission reduction, it is the cost of emission rights that Rights as “an appropriate interpretation of is expected to change business behaviour in existing IFRSs for accounting for the EU order to deliver emissions reduction Scheme” (IASB 2005). Despite the (Andrew, 2008). The need to internalise costs subsequent withdrawal of IFRIC 3, the IASB of pollution or trade in emission permits, has continues to have accounting for ETS on its the effect of shifting what was traditionally board agenda (IASB, 2007; IASB 2008a; an external and costless concept into a costly IASB 2008b). According to IFRIC 3 and activity and, hence, is “at the heart of the consistent with the IASB Framework, challenge to standard setters” (Cook, 2009, p. emission rights are recognised as assets. The 457). The environmental crusader Gore question remains: can this recognition (2007) urged: adequately capture the „nature‟ of emissions a re-examination of accounting rights and still be consistent with the Kyoto systems and measurement protocols to protocol? include the environment in the routine, IFRIC 3 was withdrawn because it “creates everyday calculations by which our unsatisfactory measurement and reporting economy is governed. mismatches” (IASB 2005). Therefore, This paper re-examines accounting for companies were also concerned that the emissions rights in a way that is appropriate application of IFRIC 3 would force them to to address our ecological crisis. show a “distorted picture of their In this paper we will first demonstrate that performance” (Cook, 2009, p. 457). This efforts to recognise emission rights, so far, delay in implementing comprehensive and have been dominated by mainstream clear guidelines on accounting for emission accounting approaches. We critically rights from the IASB provides an opportunity evaluate the proposed mainstream accounting to reconsider the basis upon which earlier approach in order to open further discussion attempts to arrive at an accounting standard about accounting for emission rights. We rest. This paper focuses on the recognition highlight the implication of accounting for issue rather than the measurement issue in emission rights from an environmental ethics relation to emission rights. The IASB (2008) perspective. In particular we consider social has identified that, apart from the ecology as an example of an environmental measurement issue, there are other ethics approach and use this to re-examine fundamental issues that need to be the „nature‟ of emission rights. We conclude appropriately addressed first. For example, that a social ecology view, an approach of what is the nature of an emission right? Is an environment ethics, offers insights into why emission right an asset? How should an accounting for emissions rights as assets or emission right be recognised initially, liabilities would undermine efforts to reduce particularly if a reporting entity receives it GHG emissions. from a government as a grant or free of charge? Should a liability be recognised?

Without resolving the nature of emission

rights, accounting standard setters would not

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be able to decide what attributes of an consider them as inextricably linked to the emission right they are trying to represent ecological crisis. and ultimately to measure. In the next In bringing to the forefront the imperative to section, the notion of environmental ethics mitigate climate change we are then able to will be introduced to help shed light on how identify that there is a serious moral the „nature‟ or „essence‟ of emission rights dilemma, rather than a mere technical can be re-examined. challenge. Zimmerman (1994, p. 3) argued that: 3. MAINSTREAM APPROACHES, …ecological problems cannot be ENVIRONMENTAL ETHICS AND solved by simply tinkering with the SOCIAL ECOLOGY attitudes and practices that generated 3.1 Mainstream Approaches those problems. The importance of understanding emissions Environmental ethics offers another context rights in the context of the environment is not within which to consider accounting for merely a technical issue of recognition or emission rights. measurement. There are fundamental issues at stake which are reflected in the questions 3.2 Environmental Ethics Hopwood (2009, p. 435) raises, namely: Environmental ethics “examines how human …can the ethical considerations of beings should interact with the non-human environmentalists be transferred to the world around them” (Palmer, 1997, p. 6). As economic market place? Or will the a theoretical framework, environmental values of the market place overwhelm ethics “develops, suggests and analyses ways those of the environmental sphere, out of an environmental crisis” (Andrew, introducing a totally new set of 2000, p. 197). In this paper we argue that unanticipated consequences and social ecology, an approach of environmental actions which are likely to be to the ethics (Andrew, 2000) can be applicable to longer term detriment of the original the re-conceptualisation of emission rights. concerns? As defined by Light (1998), social ecology posits that there is a relationship between If emissions rights are seen as private society and the eco-system which can be property, then they possess the fundamental investigated. Inspired by Marx‟s work on characteristics of assets with economic social hierarchy and class domination in a benefits, controllability and tradability. capitalist society, proponents of social However, is the essential nature of emission ecology recognise the continuities between rights adequately reflected if they are the natural world and human society, and recognised as assets? The challenge to the their possible synthesis (Bookchin, 1980, IASB is not surprising considering that the Callicott and Frodeman, 2009). The IASB views the issue of emission rights as a ontological foundation of social ecology technical one. The body has proposed a recognises that the exploitation of nature not traditional, mainstream approach to provide only destroys the intrinsic value of eco- answers. Mainstream approaches have systems, but also the life line essential for considered ethical issues as non-technical human survival (Light 1998). Social and hence these have remained outside the ecologists see actions addressing ecology as IASB‟s domain. The IASB‟s approach is social (Light, 1998; Bookchin, 1989). most evident when accounting standard Accordingly, humans are deemed to have an setters see emission rights as something obligation to preserve nature as it is also a merely upon which the right „price tag‟ must part of the preservation and survival of be assigned. It is at this point that we can human-kind (Bookchin, 1980; 1989; 1990). pause to reconsider another way to The inextricable link between humans and conceptualise emission permits and to

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the environment was also stressed by Geno argued that accounting for ecology should (1995, p. 176): take into account environmental externalities …if human societies are to come to to ensure that economic growth does not go grips with their relationship to, and beyond the carrying capacity of an eco- interdependence on, in system. Social ecology adopts an open and the form of indispensable resources for inclusive approach and can enable the survival, institutions such as integration of the environment into the accounting and economics must face “social realm and not divorced” from it the moral as well as technical (Gallhofer and Haslam, 1997, p. 163). challenges in accounting for Consistent with social ecology, Eckersley sustainability. (1998, p.169) pointed out that individuals Social ecology is consistent with the view make choices by that human potentialities can shape the …developing new technologies, future, and need to be brought to the cultivating new social relations, forefront of humans‟ action (Bookchin, creating new legal relations, critically 1980). re-examining human consumption 3.3 Social Ecology patterns, needs, desires, and re- Social ecology challenges the mainstream evaluating and enlarging what passes notion of „rationality‟ by describing current for human virtues. society as “…a totally irrational society that Social ecology also includes “power, threatens to undermine the fundaments of life authority and democracy” (Light, 1998, p.86) on this planet” (Bookchin, 1980, p. 28). It is and thus accommodates the complexities that suggested that since it is logically possible inform and shape the social aspect of an for humans to achieve self-realisation ecological perspective. In this way, social without averting serious environmental and the ecological insights are given equal damage, it is a matter of developing an prominence and can inform each other. attitude that appreciates the intrinsic value of Social ecologists reject the notion of nature (Holbrook, 1997, Bookchin et al, „antihumanism‟ and „biocentrism‟, which put 1990). Consequently our ecological problems humanity against ecology. Instead, Bookchin can only be solved with a shift in mindset argued that nearly “all ecological problems (Holbrook, 1997, Bookchin et al, 1990). Such are social problems” (1989, p24) and that an attitude can assist us in making „sensible‟ radically separating social evolution from social action which has economic sense and natural evolution can only further alienate ecological sense in the long term. humanity from the natural world “in which it In reference to the notion of „land ethics‟ has always been rooted as a complex and Leopold, an environmental ethics pioneer, thinking life-form” (Bookchin, 1989, p. 23). suggested that the boundaries of community Social ecology is an approach to need to include nature (Nash, 1990). He environmental ethics that “does not seek to proposed that in a sustainable society humans destabilise anthropocentrism” (Andrew, and nature co-exist in a non-hierarchical 2000, p. 207). Social ecologists do not manner, and the idea of life community challenge the notion of environmental extends far beyond traditional definitions management; rather, it is the intention of (Leopold 1933, cited in Nash, 1990). environmental management that social Leopold approved the notion of responsible ecologists seek to challenge. Environmental “alteration, management and use” of natural management is seen by social ecologists as a resources, and pointed out that humans have way to “exercise the powerful and privileged the responsibility to take action to “prevent status humans enjoy in the natural the deterioration of the environment” (1933 community” (Schweitzer, 1935, cited in cited in Nash, 1990, p. 71). Birkin (1996) Nash, 1990, p. 61).

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A summary of the differences between According to mainstream approaches, the mainstream approaches and social ecology role of accounting in society is integral to the approaches to the environment is provided in requirements of capital markets. By contrast, Table 1. Briefly, social ecology explores the social ecology considers humans to be role humans can play in achieving long-term guardians of nature in order to protect the sustainability, where sustainability includes needs of future generations. Accordingly, the social, ecological and economic aspects. In role of accounting is to facilitate and reflect other words, social ecologists challenge the this custodial function. The focus of social existing mainstream dominant ideology of ecology of the economy must therefore be short-term, economic growth which is long-term. unsustainable and which has been achieved at the cost of nature (Geno, 1995; Andrew, 4. ACCOUNTING FOR EMISSIONS 2000). As seen in Table 1, the RIGHTS AND SOCIAL ECOLOGY anthropocentric view implicit in mainstream approaches is suspended by social ecology in 4.1 Emission rights as assets favour of a non-hierarchical relationship The reliance on market-mechanisms as between humans and the ecology. Therefore, providing an adequate response to GHG and social ecology considers human survival as their impact on climate change has raised implications for environmental accounting Table 1: Comparison of Mainstream and (Hopwood, 2009; MacKenzie, 2009). Social Ecology approaches to the Accounting does play an important role in environment (adapted from Andrew ecological crisis, however, whether or not 2000). accounting becomes part of the solution or Ethical Main- Social part of the problem (Lohmann, 2009) premises stream Ecology depends on how accounting standard setters Ontological Anthropo- Non- understand the „nature‟ of emission rights. foundation centric hierarchical The IASB‟s withdrawal of IFRIC 3 Nature Externality Human‟s “illustrates the problems faced by standard equal, setters as they explore the frontiers of essential to accounting” (Cook, 2009, p. 457). Based on survival mainstream accounting, standard setters have Role of Maximise Nature‟s struggled to establish a workable standard. human personal guardian to The suggested accounting treatment of utility protect emission rights, as an asset (IASB 2005), inter- however, appears to maintain the „business- generational as-usual‟ mindset rather than reflect any needs cognisance of the importance of Economy Short-term Long-term environmental ethics. focus focus In applying the environmental ethics of social Role of Integral to To represent ecology one can ask a new set of questions accounting capital nature which were not possible of a mainstream in society markets paradigm. Consistent with mainstream approaches, emission rights are essentially being inextricably linked to nature‟s survival. pollution rights that an entity can trade to This view challenges mainstream thinking allow GHG to be emitted. The monetary about nature as being an externality. benefits that an entity can generate from the Consistent with mainstream views, the role sale of emission rights lead to the treatment of humans is to maximize their personal of emissions rights as assets. However, a utility (Chua, 1986), and a short-term focus „right‟ is problematic in a wider social and of the economy is inevitable (see Table 1). environmental context. Table 2 provides a

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comparison between mainstream and social the responsibility of humans. Hayward ecology approaches to emissions rights. (2007, p. 434) noted that A mainstream approach would view …patenting the monetary value of the emissions rights as assets to be controlled by rights may not only take precedence the entity. The capacity to sell these in an over any concern about the ETS ascribes a „future economic benefit‟ to environment, but may also serve to the emission rights. Accordingly, the concept distract policy-makers from pursuing of having a right to emit carbon pollution is viable alternative approaches to incongruous with social ecology. Clark making the reduction. (2001, p. 435) pointed out that the idea that The focus on accounting for emissions rights humans can possess the right to pollute is as assets has demonstrated the saliency of the unacceptable and “absurd from an ecological profit imperative, rather than an effective point of view”. Schweitzer suggested, the action to reduce GHG emissions. powerful and privileged status humans take The intention of ETS is to „internalize‟ for granted, does not entail “a right to pollution costs and ultimately alter business exploit” but rather, “a responsibility to behaviour, that is “management strategy ... protect” (1935, cited in Nash, 1990, pp. 61- philosophies and practices” (Buhr, 2007 p. 62). 67) However, accounting for emission rights Table 2: Comparison of mainstream as assets may not result in entities changing approach and social ecology approach to their behaviour if it is not „efficient‟ for them emissions rights to do so. Therefore, the quest to reduce GHG Mainstream Social Ecology emissions to mitigate climate change may be Control: exclusive Responsibility: humans mere rhetoric to enable corporate profits to controlled by an maintain position as be generated from ETS. The self-interest- entity „environmental profit-maximisation imperative upheld by managers‟; nature mainstream approaches to climate change is guardianship evident in the following comments about Probable future Long-term ETS by Birley (2008) from the European economic benefits intergenerational Climate Exchange or sacrifice (short sustainability …this scheme is allowing those who term) change early to make money…you put Only measurable Non-monetary social technology on top. of your economic benefits and ecological benefits smokestacks that will stop. the carbon (gained and lost) from going into the atmosphere, you A result of past Co-existence can profit from it. transaction prioritised Yet, a firm does not have to be reducing GHG emissions to be able to profit from an The earlier discussion of social ecology as an ETS. While emission rights are seen as approach to environmental ethics argued that having future economic benefits and it is human responsibility to reduce GHG fulfilling the definition of an asset, polluters emissions. If a responsibility to reduce could purchase emission rights and sell them emissions is recognised from holding later when the price has been driven up by emission rights, would it not behove a the market. Therefore, recognising emission reporting entity to recognise an rights as assets could produce outcomes that environmental obligation? Hayward (2007) undermine efforts to abate carbon pollution. criticised ETS for focusing merely on the right to emit. He argued that in the debate 4.2 Emission rights as liabilities over climate change, people tend to lose sight If emission rights are not assets perhaps they of the fact that carbon emissions reduction is should be recognised as liabilities. A

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reporting entity could recognise a liability to maximising mindsets to prevail, and this, we fulfil an obligation to purchase rights in order argue will be at the expense of the to be able to emit. However, this would still environment. Focusing on the accounting for signal a suspension of any environmental emission rights, a construct of ETS, has not ethics in the accounting treatment of been resolved by the IASB so far. We have emission rights. Is it sufficient to recognise a seen this challenge as a reason to pause and financial monetary obligation to be able to recognise that emissions rights is an pollute? Gibson (1996) suggests that it would unprecedented issue which traditional views be more effective to control the source of of accounting are not well equipped to emissions, rather than charging for the address. Further, we argue that the claimed emissions when they are already in the air, an objectives of ETS to abate GHG emissions “end-of-pipe approach” (Gibson 1996 p. cannot be met if anthropocentric views 659). Unfortunately, recognising a liability persist. still upholds the self-maximising mindset of We have presented a social ecology view, an mainstream approaches since the monetary approach of environment ethics, which can obligation „entitles‟ the firm to emit offer insights into why accounting for pollution. emissions rights as assets or liabilities would A social ecology approach to emissions undermine efforts to reduce GHG emissions. rights provides a challenge to the mainstream Emissions rights when characterised as either approach to emissions rights accounting (see assets or liabilities, that is, seen as future Table 2). Emission rights whether viewed as economic benefits or sacrifices are still assets or liabilities, fall within the property constructs within the control of entities rights held by an entity and hence within participating in an ETS. Reduction of GHG their exclusive control. A social ecology emissions need not be achieved, since the approach suspends notions of control to incentive of an ETS is to make profits on adopt notions of responsibility by humans as trading. A social ecology approach is based environmental managers or guardians. on the long-term survival of humans and the Rather than emission rights providing future environment. Seeking monetary benefits is economic benefits or sacrifices, which viewed as short sighted. We have argued that emphasises the short-term, a social ecology the „nature‟ of emission rights can best be approach emphasises the imperative of a understood in the light of social ecology long-term view of intergenerational which keeps the environment and human sustainability. From a social and ecological survival at the forefront. Social ecology, as perspective future benefits are non-monetary. an environmental ethic, enables us, and A mainstream view relies on a capacity to importantly, accounting standard setters, to measure reliably the economic benefits of provide a foundation for re-examining the emission rights as a result of past „nature‟ of emission rights. transactions. The „nature of emissions rights from a social ecology approach, renders REFERENCES measurement an inconsequential issue. It is Andrew, B., (2008) “Market Failure, the co-existence of humans and the Government Failure and Externalities in environment which is significant. Climate Change Mitigation: The Case for a ”, Public Administration and 5. CONCLUSION Development, 28, 393-401. Efforts explicitly to cost pollution by the Andrew, J. (2000) The accounting craft and construction of emission rights have not the environmental crisis: reconsidering yielded acceptable results even to those environmental ethics, Accounting Forum, seeking to benefit from an ETS. While the 24(2), 197-222. intention of introducing an ETS is naive at Birkin, F. (1996) The ecological accountant: best, it still relies on self-interest-profit- from the cognito to thinking like a

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