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$23-Billion Carbon Loophole at Drax: CO2 Emissions Disclosure

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Pricing tomorrow’s cost of carbon today $23-billion Carbon Loophole at Drax: CO2 emissions disclosure requirements legitimately conceal the true cost of damage to the planet Drax Power Station - Carbon Value at Risk Case Study Executive Summary Edward Coe February 2018 About PAL PAL is the world’s only company to have scientifically determined the actual dollar cost of CO2 emissions. This carbon price is the foundation stone upon which PAL has developed and productised a comprehensive and sustainable solution for climate change. Published by PAL in June 2016, the book Predicting the Price of Carbon: How to tackle the climate change code for good1 by Richard Clarke, Director of Research at PAL, addresses the goals and strategies for tackling climate change and sets out the methodology of PAL’s carbon-pricing system. The underlying research and findings compare well with a recent, major, evidence-based study in the US by Hsiang et al2. This unique carbon-pricing system is embodied in PAL’s suite of complementary products and services. It covers every aspect of evaluating loss and damage caused by manmade climate change to provide dollar-costed Carbon Pricing, Enhanced Carbon Auditing plus the associated current and projected carbon liability across all sectors. Example applications include: Carbon Value-at-Risk Metrics: Using their analytically verifiable cost of CO2 emissions, PAL can put an accurate $ value on corporations current carbon footprint and their future carbon liability risk. The revolutionary technology behind PAL’s IP enables a huge range of unprecedented capabilities e.g.: • monetized carbon auditing of big-ticket projects such as nuclear power plants • measurement of carbon liability of, say, proven reserves of oil companies • assessment of carbon liability Value at Risk (VaR) for asset managers across all industry and energy types including renewables. Enhanced Carbon Auditing (ECA): PAL’s bespoke audits provide in-depth financial analysis of the real $/£/€ carbon costs impacting your enterprise. Effective carbon costing for Life Cycle Assessments (LCA) of projects involving all manner of major infrastructure or development planning can optimise decision-making and reduce costs. Carbon Pricing: PAL’s real-time carbon pricing data factors in the true cost of damage caused by CO2 emissions – past, present and future. A problem specific to carbon pricing is that a one-size-fits- all carbon price is too blunt an instrument for encouraging behavioural change. PAL’s spectrum of prices based on impact (PAL’s Carbon Intensity Weighting) is more effective as well as future-proof. Catastrophe Loss Modelling: PAL’s computing engine, PALgamma, provides algorithm-based forecasting of extreme weather-related disaster trends and loss events. It clearly identifies, in dollar terms, the financial impact of man-made climate change, as well as the most likely proximities and timelines of future loss events. For further information, please visit predictability.ltd.uk or email [email protected]. 1 https://predictability.ltd.uk/wp/publications/predicting-price-carbon/ 2 http://science.sciencemag.org/content/356/6345/1362 2 Do carbon accounting rules hide the true cost of damage to the planet? Whilst significant change is underway as companies prepare to transition to a lower-carbon economy, a long-term quantitative risk approach is required to effectively measure the preparedness of individual companies and the rate-of-transition of global markets as a whole. Value at Risk (VaR) is a measure of the worst expected loss that a portfolio or company can suffer over a given time horizon and for a given confidence level. PAL’s Carbon Value at Risk metric is used to determine the extent of carbon liability risk - the loss and damage attributable to carbon emission related anthropogenic (manmade) climate change. This report provides a long-term analysis of the carbon value at risk for Drax Power Station. Drax power station is a large coal-fired power station in North Yorkshire, England, capable of co-firing biomass and petcoke. It is situated on the River Ouse between Selby and Goole. Its generating capacity of 3,960 megawatts (MW) is the highest of any power station in the United Kingdom, providing about 7% of the United Kingdom's electricity supply. Key Findings § Drax’s carbon emissions disclosures appear to fall within the regulatory requirements and are therefore quite legitimate. Drax imports wood pellets from the US and burns these in place of coal. According to the EU ETS rules, this biomass combustion equates to zero emissions. However this legitimate loophole, allowed under the rules and as used by Drax, exposes Drax to the risk that if the rules change (and for the sake of the planet the rules certainly need to change) their Value at Risk (VaR) is a $23 billion ‘black hole’. This ‘black hole’ is the difference between the expected loss and damage caused by carbon dioxide emissions over the next 25 years ($33bn) and equivalent loss and damage where biomass emissions are excluded ($10bn). § Drax is the largest emitter of carbon dioxide from fuel combustion in the UK3 (see figure 3 below). Whilst Drax’s annual report4 shows an overall 53% emissions reduction in fossil fuel usage last year, down to 6.2 million tonnes of CO2, its average combined scope 1 (direct) and scope 2 (indirect) emissions remain high at 18 million tonnes (historical average 22.5 million tonnes) when biomass combustion is included. § The reported carbon intensity - the emissions per gigawatt hour (GWH) of electricity generated – of 297 tonnes of CO2 per GWH excludes biomass combustion. When biomass combustion is included in emissions figures, carbon intensity becomes 847 tonnes of CO2 per GWH, almost three times higher. § Shipping and manufacture (scope 3) emissions are implicitly reported as an average supply 5 6 chain GHG emissions of 33.9 g CO2 (e)/MJ (122 tCO2/GWh ) . This equates to biomass supply chain emissions of 2.5 million tonnes of CO2. Adding this to scope 1 and 2 emissions provides a carbon intensity of 968 tonnes of CO2 per GWH. 3 UK Company Analysis (PAL), https://predictability.ltd.uk/wp/resources-insights/carbon-risk-analytics/carbon-value-risk-operators-by-country/?m=GB 4 Drax annual report 2016, https://www.drax.com/wp-content/uploads/2017/03/Drax-Group-plc-annual-report-and-accounts-2016-Smart-Energy- Solutions.pdf 5 Drax annual report 2016 6 https://www.sciencedirect.com/science/article/pii/S0301421516307017 3 § The 25 year Carbon Value at Risk (VaR) including biomass combustion is $33 bn, over three times the $10bn VaR excluding biomass, both numbers using a 95% confidence level (the certainty that climate loss & damage arising from carbon emissions will be no worse than that VaR amount). At a much lower 50% confidence level, 25 year VaR is $16bn including biomass, almost four times the $4.6bn VaR excluding biomass. Figures 1 - Carbon Value at Risk ($M) excluding biomass combustion Carbon Value at Risk (VaR) excluding biomass combustion over 25 years. 4 Figures 2 - Carbon Value at Risk ($M) including biomass combustion Carbon Value at Risk (VaR) including biomass combustion over 25 years. Note that VaR is 3-4 times larger when biomass combustion is included. Carbon VaR measures the carbon liability risk that a company or portfolio can be exposed to over a given time horizon and for a given confidence level. Carbon liability is the measure of climate loss & damage arising from carbon emissions. Here we use a 25 year time horizon and 95%, 75%, 50%, 25% and 5% confidence levels. 95% confidence implies a 95% probability that losses will be no worse than $33bn over the next 25 years. 5% confidence implies a 95% probability that losses will be at least $8.6bn over the same period. 7 By comparison, applying the Carbon Price Support Mechanism levy (£18 per tonne CO2 currently ) to current year emission levels of 6.2 million tonnes would result in £2.8bn ($3.9bn) carbon tax over the next 25 years. Confidence level 95% 75% 50% 25% 25 Year VaR excluding biomass ($billion) 10.4 7.0 4.6 2.6 25 Year VaR including biomass ($billion) 33.1 21.2 16.1 13.0 25 Year Carbon Price Support Mechanism ($billion) 3.9 3.9 3.9 3.9 Source: PAL 7 http://researchbriefings.parliament.uk/ResearchBriefing/Summary/SN05927 5 Figure 3 – Carbon Value at Risk Rankings for UK combustion of fuel, excluding biomass Rank Installation Company Name 25Y 1Y Cost Scope 1 VaR ($M) Emissions ($M) (MtCO2e) 1 Drax Power Station Drax Power Ltd 10,557 125.7 6.26 2 Aberthaw Power Station RWE Generation UK Plc 12,032 119.3 5.94 3 Pembroke Power Station RWE Generation UK Plc 14,846 98.6 4.91 4 Staythorpe Power Station RWE Generation UK Plc 10,115 73.3 3.65 5 VPI Immingham VPI Immingham LLP 6,609 69.0 3.44 6 Saltend Cogeneration Company Saltend Cogeneration Company 4,738 59.9 2.98 Limited Limited 7 Ratcliffe on Soar power station Uniper UK Limited 4,849 53.7 2.67 8 Grain CCGT-CHP Station Uniper UK Limited 6,918 50.5 2.52 9 Valero Energy Ltd Valero Energy Ltd 3,742 47.3 2.36 10 Didcot B Power Station RWE Generation UK Plc 3,672 46.4 2.31 11 Stanlow Manufacturing Complex Essar Oil UK Ltd 3,632 45.9 2.29 12 AES Kilroot Power Ltd AES Kilroot Power Ltd 3,370 42.6 2.12 13 Eggborough Power Station Eggborough Power Ltd 4,364 42.1 2.10 14 West Burton B Power Station EDF Energy (West Burton Power) 6,463 40.8 2.03 Limited 15 Marchwood Power Station MARCHWOOD POWER LIMITED 4,953 39.7 1.98 16 Connahs Quay power station Uniper UK Limited 3,143 39.7 1.98 17 Fiddlers Ferry Power Station Keadby Generation Limited 4,150 39.4 1.96 18 Damhead Creek Power Station ScottishPower Generation Limited 3,243 38.8 1.93 19 Spalding Power Station Spalding Energy Co Ltd 2,843 35.9 1.79 20 Longannet Power Station ScottishPower Generation Limited 4,318 32.9 1.64 21 Seabank Power Limited Seabank Power Limited 2,595 32.8 1.63 22 Rocksavage Power Station Rocksavage Power Company Ltd 2,516 31.8 1.58 23 Cottam Power Station EDF Energy (Cottam Power) Limited 3,233 31.4 1.57 24 Severn Power Limited Severn Power Limited 3,442 28.7 1.43 25 Coryton Power Station Coryton Energy Company Ltd 2,231 28.2 1.40 Source: PAL, EU ETS.
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