Select Committee on European Union Thirty-Third Report


CHAPTER 7: External and domestic credits

The issue

154.  External credits raise a number of issues. One is the extent to which it is sensible for one country to pay for an emissions reduction in another country rather than reducing emissions in its own territory. Another is how the system of external credits should be monitored and verified.

BOX 10

External credits
The Kyoto Protocol (see Box 1) establishes a number of different types of environmental project-based mechanisms that provide credits which can be used to meet Kyoto targets. The underlying principle is that credits from projects that reduce emissions in other parts of the world can achieve the same environmental objective of reducing global emissions but at a lower cost.

The Clean Development Mechanism (CDM)[69]

The CDM allows emission reduction projects in developing countries (e.g. rural electrification projects using solar panels) to earn Certified Emissions Reduction credits (CERs), which can be traded and sold, and used by Annex I countries (37 industrialised countries listed in Annex I of the UNFCCC[70]) to count towards their own emission reduction obligations. The projects must be part-funded by an Annex I country. Any CDM project must be "additional" (See Box 11) and they must contribute to sustainable development. The administration of the mechanism is overseen by the CDM Executive Board, which is answerable to those countries that have ratified the Kyoto Protocol.

Joint Implementation (JI)[71]

JI allows Annex I countries to earn Emission Reduction Units (ERUs) from an emission reduction/removal project in another Annex I country. As with the CDM, JI projects must provide reductions that are additional to those that would otherwise have occurred.

Content of the proposal

155.  The Commission proposes that, until a future international agreement has entered into force, the use of ERUs and CERs over the period 2013-2020 should be restricted to unused credits from the period 2008-12. Explaining its proposal, the Commission noted[72] that a large number of credits could enter the EU ETS in Phase 2 but that, if full use were to be made of these by 2012, few domestic EU reductions would occur. Member States will, however, be permitted to allow operators to exchange CERs issued in respect of emission reductions made or planned before 2012 for allowances valid from 2013 onwards. It will also be possible to exchange unused Phase 2 CERs for allowances from new projects (not already planned) begun from 2013 onwards in Least Developed Countries[73] only.

156.  Should an international agreement meeting the EU's requirements be reached, EU ETS participants will be able to meet 50 per cent of the additional emissions reduction effort beyond the overall 20 per cent target with external credits.

157.  The proposal also allows for so-called "domestic off-setting". These are projects which mirror the concept of external credits, but are used within the home country to reduce emissions in sectors falling outside the scope of the ETS.

BOX 11

Additionality

CDM and JI projects must be "additional". Formally, this means that a project is additional if greenhouse gas emissions are reduced below those that would have occurred in the absence of the registered project activity[74]. Its precise interpretation is evolving and can include financial additionality, whereby a project should not be economically viable without the CDM or JI investment. In such cases, there is a double hurdle to clear: that the emissions reductions would not have been secured without the project, and that the project wouldn't have happened without the investment. In theory, however, these conditions could have perverse effects by deterring countries that expect to receive such investment from introducing their own emission reduction measures or funding relevant projects of their own.

The case for and against external credits

158.  A number of witnesses including the Aluminium Federation (AlFed), the British Cement Association (BCA), the British Lime Association (BLA), Euracoal and Lafarge Cement supported the use of external credits with no restrictions on the use of CDM-generated allowances. Those witnesses expressed the view that it was irrelevant where in the world emissions reductions were made as long as they were made at the point of lowest cost (AlFed Memorandum, para.9; BCA Memorandum, para. 15.2; BLA Memorandum, p.119; Euracoal Memorandum, p.162; Q 156).

159.  DEFRA took the view that through external credits, the EU ETS had thus far played a major role in supporting developing countries' efforts to address their greenhouse gas emissions (Q 105). Responding to concerns that the projects in developing countries would be happening anyway, officials emphasised that there was no evidence to support those claims and that the issue was "whether we are doing it in the best and most economically efficient way possible rather than whether or not we should have it" (Q 176).

160.  By contrast, the RSPB rejected the use of external credits unless the EU set a much higher overall emissions reduction target of around 40 per cent, in which case external credits at 5-10 per cent might be considered (Memorandum, para. 9.1). The Church of England adopted a similar approach, proposing that all of the EU's emission reduction efforts should be undertaken within the EU's borders and suggesting that instead, "the financial equivalent of an additional 15 per cent emissions reduction" should be invested in developing countries to assist them with their climate change adaptation and mitigation efforts (Memorandum, para. 29).

External credits in the draft Directive

161.  Explaining the Commission's position, Mr Meadows told us that the use of external credits needed to be restricted because, if there was no international agreement and emission reduction targets therefore remained relatively low, the use of more external credits would hamper efforts to reduce emissions in the EU and to reach the EU's renewable energy targets (Q 383).

162.  The International Chamber of Commerce UK (ICC UK) warned that the restrictions in the draft Directive would, if enacted, undermine the market in external credits, leading to a significant reduction in finance available for carbon projects in developing countries (Memorandum, para. 6). ICC UK therefore proposed that: the provisions of Article 11a(4) providing certainty on the permissibility of credits from projects in Least Developed Countries post-2012 be extended to all developing countries; and that a risk guarantee fund be established to compensate investors in projects for post-2012 emissions reductions in the case of failure of the international policy process (Memorandum, para. 7).

163.  The CBI expressed similar concerns about the provisions in the draft Directive regulating access to external credits (Position Paper, p.8). A CBI representative argued that restrictions on access to credits post-2012 should be relaxed but admitted that the CBI had not yet been able to come up with a specific volume of credits that would be appropriate (Q 156). He acknowledged that the EU might obtain useful bargaining leverage in international negotiations by threatening to restrict access to CDM credits in the event of no agreement at Copenhagen, but warned against intransigence on this point if no deal were to be reached.

164.  Ecosecurities' Head of European Regulatory Affairs, Miles Austin, pointed out that even in the event that an international agreement were to be reached, the proposals would only allow access to 72 million tonnes of CERs per year, as compared to 270 million tonnes during Phase 2 (Q 301). In relation to CDM projects, Mr Austin added that "it is very difficult to invest [in the market currently] because there is no clear signal as to what type of project to invest in". Indeed, he suggested, "there is no clear signal that there will be a market as such" (Q 307). Similarly, the European Federation of Energy Traders (EFET) feared a "scaling back of new investment into low carbon technology in developing countries" (Memorandum, p.164).

165.  Ms Anger (4cmr) pointed out that the Commission's proposal to allow "banking" of unused Phase 2 external credits for use during Phase 3 would be unfair to new entrants, including the aviation sector, which would come into the ETS at the very end of Phase 2 in 2012 (Q 271). Coralie Laurencin of Climate Change Capital and International Carbon Investors and Services, Mr Austin (Ecosecurities) and Mr Sam Fankhauser (IDEACarbon), on the other hand, all welcomed the proposal that unused external credits could be carried over from Phase 2 to Phase 3, which they anticipated would allow pricing to be smoother and less volatile because participants could choose to use their credits at the most appropriate time depending on market conditions (Q 314).

Monitoring, Reporting and Verification of external credits

166.  According to the Environment Agency, Monitoring, Reporting and Verification (MRV) standards for CDM and JI projects must be as good as those in the EU ETS (Memorandum, para. 3.7.2). WWF proposed that only external credits from CDM projects which met the Gold Standard[75] accreditation or equivalent quality should be allowed to enter ETS from 2013 (Memorandum, para.9).

167.  New Zealand officials noted that there was some scepticism in New Zealand about the integrity of CDM credits. New Zealand was accepting them, "but we do think it [the CDM] needs improving and we are putting in quite a lot of work in that area" (Q 355). The CBI argued that concerns about quality control of external credits should be addressed at the UN level if the aim was to build a global carbon market (Q 159).

168.  As regards the current system of monitoring the CDM, Ecosecurities explained that the Executive Board of the CDM was largely composed of negotiators who undertook scrutiny of nearly every project. In each case, this required analysis of a 150-200 page project design document. As the Executive Board met only six times a year for three or four days, "there is currently a huge backlog of projects" (Q 313)[76].

Domestic off-setting

169.  The Centre for European Policy Studies (CEPS) explained that there were two arguments in favour of domestic off-set projects. First, they "unquestionably" extended the price signal and thereby initiated a "market search" for abatement opportunities. Second, they arguably reduced the overall cost of reducing carbon emissions because they allowed otherwise unidentified low-cost abatement options to be considered. CEPS took the view, however, that this second argument was questionable because it meant that low-cost abatement options were removed from the menu of possible ways of meeting the emission reduction obligations in the non-ETS sectors, thus increasing the cost of cutting emissions outside the ETS (Memorandum, p.137).

170.  DEFRA suggested that the provision should be viewed mainly as an enabling clause (Q 194). Forestry was one sector where domestic off-setting might be considered, drawing on France's experience (Q 195). This was a view shared by Mr Fankhauser of IDEACarbon (Q 316).

171.  WWF and the RSPB rejected the idea of domestic off-setting. The RSPB expressed the view that the EU should not "invent its own credits on an ad hoc basis when there is a globally agreed system of crediting" (Memorandum, para. 5.1.). WWF explained that "the emphasis must be placed on reducing emissions from the ETS sectors rather than expanding their access to cheap emission credits from other sectors" (Memorandum, para.5). Dr Barker (4cmr) warned that domestic off-setting "is a really bad idea" that would weaken the overall cap (QQ 274-5).

172.  The British Cement Association (BCA) suggested that the provision might be strengthened so that the Commission could issue allowances in respect of projects involving companies and Member States that reduced GHG emissions outside the Community scheme (Memorandum, para. 12.2). The British Lime Association (BLA) was equally supportive of the principle on the basis that "emissions reductions should be made at the point of lowest cost" (Memorandum, p.118).

Conclusions and Recommendations

173.  External credits can play an important role in reducing global emissions cost-effectively as long as they do not crowd out developing countries' own efforts to cut emissions.

174.  Nonetheless, the EU cannot hope to set an example in the international arena without undertaking substantial emissions reductions within its own borders. It also cannot hope to secure a competitive advantage in low-carbon technologies if external credits are too freely available, as this will stifle domestic innovation and investment.

175.  On balance, we consider it appropriate as a negotiating tactic to restrict the level of external credits in Phase 3 to those available and unused under Phase 2 of the EU ETS, as proposed by the European Commission, until such time as an ambitious global climate change agreement has been concluded. This will be one of the few bargaining chips available to the EU in international negotiations: we urge the European Commission and the Member States to use it to press for an ambitious global emissions reduction target at Copenhagen in December 2009.

176.  In order to provide the carbon market with as much certainty as possible, it is imperative that a decision on the future level of credits is taken at the earliest opportunity in the event of an international agreement.

177.  The use of external credits must be properly audited, but this process should not lead to the development of standards separate to those stipulated by the Kyoto Protocol if the aim is to promote a liquid, truly global market. EU Member States might instead press for a review of the role of the CDM Executive Board by the Secretariat of the UNFCCC in order to assess whether it is functioning effectively.

178.  We are sceptical about the benefits that domestic off-setting might offer, on the basis that tapping cheap abatement opportunities in non-ETS sectors could push up the cost of meeting emissions reduction targets in those sectors.


69   http://cdm.unfccc.int/about/index.html  Back

70   United Nations Framework Convention on Climate Change Back

71   http://unfccc.int/kyoto_protocol/mechanisms/joint_implementation/items/1674.php  Back

72   COM(2008)16, p.10  Back

73   There is a UN-established list of 50 Least Developed Countries:
http://www.un.org/special-rep/ohrlls/ldc/list.htm  
Back

74   Article 43 of the 2001 Marrakesh Accords laying down the detailed rules on the implementation of the Kyoto Protocol.  Back

75   The "Gold Standard" Foundation offers a Quality label to CDM/JI and voluntary offset projects. Renewable energy and energy efficiency projects with sustainable development benefits are eligible. The Gold Standard is endorsed by over 49 non-governmental organisations worldwide. WWF was one of its founding members. Source: http://www.cdmgoldstandard.org/ Back

76   http://cdm.unfccc.int/Projects/index.html As of 6 November 2008, there were 108 requests for registration of CDM project activities, many of which might be reviewed by the Executive Board.  Back


 
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