پیامدهای محدودیت و تجارت کربن برای بازارهای داوطلبانه انرژی های تجدید پذیر آمریکا

Many consumers today are purchasing renewable energy in large part for the greenhouse gas (GHG) emissions benefits that they provide. Emerging carbon regulation in the US has the potential to affect existing markets for renewable energy. Carbon cap-and-trade programs are now under development in the Northeast under the Regional Greenhouse Gas Initiative (RGGI) and in early stages of development in the West and Midwest. There is increasing discussion about carbon regulation at the national level as well. While renewable energy will likely benefit from carbon cap-and-trade programs because compliance with the cap will increase the costs of fossil fuel generation, cap-and-trade programs can also impact the ability of renewable energy generation to affect overall CO2 emissions levels and obtain value for those emissions benefits. This paper summarizes key issues for renewable energy markets that are emerging with carbon regulation, such as the implications for emissions benefits claims and voluntary market demand and the use of renewable energy certificates (RECs) in multiple markets. It also explores policy options under consideration for designing carbon policies to enable carbon markets and renewable energy markets to work together.

Voluntary markets for renewable energy, or “green power markets,” provide an avenue for consumers to support the development of renewable energy sources by enabling them to choose cleaner electricity sources for their own energy consumption. This market is important in that it empowers consumers to affect the resources used to supply their own energy needs. While, initially, most green power products targeted residential consumers, recent growth in voluntary markets has been primarily fueled by large purchasers, including Fortune 500 companies and other businesses, universities, and government agencies, such as Intel, Pepsico, the US Airforce, and Wells Fargo.1 As a result of increased interest among the nonresidential sector, voluntary markets are growing rapidly. In recent years, sales of renewable energy in voluntary markets have increased by nearly 50% annually. At the end of 2006, voluntary consumer purchases of renewable energy totaled 12 million megawatt-hours (MWh) with a large fraction of the purchases by nonresidential customers (Bird et al., 2007). In comparison, state renewable energy standards, which are a primary policy driver for renewable energy development in the US, called for approximately 20 million MWh of new renewable energy generation in 2006, according to estimates from the Union of Concerned Scientists (Swezey et al., 2007). Thus, voluntary markets help to support a significant fraction of new renewable energy generation in the US alongside existing state policies. While there are a number of benefits of renewable energy sources, many consumers have been motivated, at least in part, to purchase renewable energy because of its greenhouse gas (GHG) benefits. Currently, purchasing green power is an accessible and relatively easy and transparent way in which customers can reduce their carbon footprints. Most utilities and independent marketers that offer green power options promote their products by touting the GHG benefits and, in fact, some marketers actually sell carbon reductions derived from renewable energy generation to enable consumers to “offset” the carbon dioxide (CO2) emissions associated with their electricity consumption, car and plane travel, and home heating energy use. Likewise, many purchasers point to the GHG benefits of their green power purchases in news releases and other promotional materials. Emerging carbon regulation in the US has the potential to substantially affect voluntary markets for renewable energy. Carbon regulation is now developing under the Regional Greenhouse Gas Initiative (RGGI, pronounced “Reggie”) in the Northeast, the Western Climate Initiative, and the Midwestern Greenhouse Gas Reduction Accord. There is increasing discussion about carbon regulation at the national level as well. To achieve GHG reductions, the regional initiatives plan to implement cap-and-trade programs, which would enable emitters to trade allowances to meet emissions targets. There is precedent for using cap and trade to control emissions, such as the successful national sulfur dioxide (SO2) cap-and-trade system developed under the Clean Air Act Amendments of 1990 to address acid rain. In general, renewable energy will benefit from carbon cap-and-trade programs because compliance with the cap will increase the costs of fossil fuel generation, which will improve the cost-effectiveness of renewables and may provide an incentive to capped entities to use renewable energy to meet future load growth. However, the level of the incentive provided for renewables will depend on the stringency of the cap; a loose emissions cap may provide little financial incentive for renewables. Cap-and-trade programs can also impact the ability of renewable energy generation to affect overall CO2 emissions levels, depending on the design of the program. If renewable generation sources are not accounted for under the cap (through the retirement of allowances or in setting the level of the cap), then they will not affect the overall level of CO2 emissions, and purchasers of renewable energy have no basis for claiming overall emission reductions. This is particularly problematic under a loose cap, where renewable energy markets could offer one avenue for further CO2 reductions. However, if these markets are not given the opportunity to do so (due to the design of the cap-and-trade programs) renewable markets could be comprised. Therefore, the implementation of carbon cap-and-trade programs has important implications for voluntary renewable energy markets. These same issues also pertain to other types of cap-and-trade programs, such as those for SO2 and NOx, but carbon cap-and-trade programs have more significant implications for renewable energy markets. This is true because renewable energy sources offer one of the few options for generating electricity without CO2 emissions and carbon capture and storage technologies are still under development. In addition, consumers may be more interested in achieving reductions in GHG emissions than emissions of specific air pollutants such as NOx and SOx. Furthermore, carbon regulation is beginning to emerge, while emissions trading markets have already been established for SO2 and NOx. This paper focuses primarily on the potential effects that emerging mandatory carbon markets will have on voluntary renewable energy markets. First, the paper examines the extent to which GHG benefits motivate consumers to make voluntary renewable energy purchases, and the claims that large commercial and institutional consumers currently make regarding their purchases. Next, the paper summarizes key issues emerging as a result of these overlapping markets, such as the implications for renewable energy marketing claims, the demand for and price of renewable energy certificates (RECs), and the use of RECs in multiple markets (disaggregation of attributes). Then, it describes carbon regulation programs under development in the US, with particular emphasis on the RGGI in the Northeast, and how such programs might affect renewable energy markets in these regions. Finally, the paper presents policy options for policymakers and regulators to consider in designing carbon policies to enable carbon markets and voluntary renewable energy markets to work together.

Voluntary markets for renewable energy have been growing rapidly in recent years, fueled partly by interest among businesses and consumers in reducing GHG emissions. Currently, these markets provide a convenient way in which consumers can support the development of renewable energy technologies and address the emissions associated with their own electricity consumption. In an era of carbon regulation, voluntary renewable energy markets can continue to play an important role because many consumers may be interested in supporting investment in renewable energy beyond what is required through mandates or other types of policy support. Some consumers may not be satisfied that emissions caps or other regulatory actions are sufficient to address the threats of global warming. In addition, many businesses and organizations may not be subject to carbon regulation, but may be interested in taking action to reduce the impacts of their own emissions footprints. Businesses and consumers may want to help support renewable energy today in order to help transform the technology to meet long-term emission-reduction goals. Voluntary markets for renewable energy may also be important because renewables provide advantages beyond no (or low) emissions, such as energy security and economic development benefits. The design of carbon regulations will have implications for the ability of consumers to affect emissions levels through their green power purchases, however. If cap-and-trade programs are designed and implemented so that renewable energy sources do not reduce CO2 levels below the level of the cap, then consumer purchases of renewable energy would not affect overall emissions levels, unless they purchased and retired an allowance separately. For residential consumers, in particular, this may be problematic, because they are unlikely to understand these complex market interaction issues and may believe that their purchases of green power from zero- or low-emitting renewable energy sources result in emission reductions. This could also reduce business and institutional interest in purchasing RECs to the extent that they are motivated by GHG benefits. REC marketers may still make claims that their product is “emissions-free”, however, this could be problematic under the NAAG Guidelines, as these claims might imply to consumers that by purchasing such energy, they are helping to reduce emissions. Under carbon cap and trade, both the methods for setting the emissions cap and for allocating allowances are important for emission-reduction claims. Allocating allowances to renewable energy generators (either through a set aside or output-based allocation) is one way to credit renewable generation with the emissions benefits they provide. A reduction in carbon emissions below the level of the cap can be achieved by retiring an allowance, ensuring that it is not sold to an emitter. A renewable energy marketer could convey an allowance with the sale of renewable energy or RECs, and the retirement of the allowance is a clear basis for making an emission-reduction claim. However, there is no guarantee that the allowances will remain bundled with the RECs, as generators will seek to maximize revenues in all available markets. Other approaches, such as reducing the cap or automatically retiring allowances to account for current and future renewable energy generation, would enable consumers to affect GHG emissions levels with their renewable energy purchases, but would not provide renewable energy generators the option of selling allowances in emissions markets. Thus, policy structures that are best suited for voluntary renewable energy markets are not necessarily the preferred policy options for renewable energy generators. In the absence of policies that would enable renewables to affect emissions levels, consumers could reduce emissions by purchasing a so-called “REC-plus” product in which an allowance would be purchased and retired on their behalf and bundled with renewable energy or RECs. Or a consumer could simply purchase carbon emission allowances without the renewable energy component. Either case would result in a clear, verifiable emission reduction and enable a strong claim. However, a REC-plus product would likely either increase the costs considerably to the end-use consumer, suppressing demand, or reduce the amount of revenue that would go to support renewable energy generation, which would reduce the ability of voluntary markets to support new renewable energy development. The latter approach of simply retiring an allowance would not necessarily lead to near-term support for renewable energy because efficiency improvements at fossil plants may dominate near-term compliance actions. Because of the substantial overlap in renewable energy and emissions markets, regulators and policymakers need to be cognizant of the policy-interaction issues and market implications of new and emerging policies. The voluntary renewable energy market is growing rapidly and provides a convenient and readily available mechanism for consumers to affect the impacts of their electricity consumption today. However, this market needs credibility, consistency, and the ability to articulate clear benefits in order to continue to provide consumers with a viable option for affecting change.