مقایسه سه طرح تجاری «کاهش تولید گازهای گلخانه ای » و مشوق هایی برای فن آوری های نوین به منظور کاهش گازهای گلخانه ای

A source-based market design is preferable for its simplicity, lower costs, faster implementation, more accurate tracking and verification, and greater incentives for the adoption of lower-emitting technologies.

The above discussion compares each cap-and-trade market design's capability to achieve the following important market objectives: • Clear market price signals. • Uniform and stable GHG allowance prices. • Verified environmental integrity. • Sufficient incentives for RD&D, purchase and use of improved technologies. • Minimized monitoring, administrative, transaction and overall costs of compliance. • Enhancement of environmental justice goals. • Simplicity of rules and ease of enforcement. • Acceptable magnitude and likelihood of unintended consequences. • Scalability in size, enabling a timely transition to a large regional or national market. Overall, the comparisons show that a well-executed, source-based market is more likely to achieve the above objectives than the other two cap-and-trade market designs. Essential technological innovation will be enhanced by the greater value that can be realized under source-based and first-seller/deliverer market designs. The comparisons also show that a load-based system would be more complex, costly, and inaccurate than either a source-based or a first-seller system. Indeed, trying to institute a regional load-based cap-and-trade system and failing to achieve these fundamental market objectives would set back public confidence in any carbon emissions reduction scheme. In summary, several reasons why a source-based market design should be preferred for the electric sector are: • A source-based market design is simpler. • A source-based market will have lower costs and lead to faster implementation. • Source-based emission reductions can be more accurately tracked and verified. In any case, the responsibility for monitoring and accurate reporting will be placed on emissions sources, even if a load-based market design is adopted. • The environmental integrity of emissions allowances will be higher in a source-based market than in a first-seller/deliverer market, which in turn, will be higher than in a load-based market. • Incentives to purchase and utilize improved, lower-emitting technologies will be greater under a source-based approach than under either the load-based or the first-seller deliverer approaches. • The transition to a national source-based cap-and-trade market will be easier, faster, and less costly, if states adopt compatible source-based approaches. Therefore, we strongly recommend that California and other states adopt an integrated, source-based cap-and-trade system with broad enough geographic coverage to include most of the power sources now serving electric loads in those states. As a second choice, which would incur unnecessary costs prior to the transition to a national cap-and-trade system or to a system of GHG emissions fees, we recommend that California and other states adopt a first-seller/deliverer market design with provisions to replace it with a regional or national source-based system, as soon as possible. 1 The United Kingdom applied a load-based approach to regulate GHG, which was replaced by the source-based European Union Emissions Trading Scheme. A former U.K. regulator compared the load-based and source-based approaches in a presentation: Olivia Hartridge, “Greenhouse Gas Cap and Trade Systems,” California Public Utilities Commission Symposium on Linking, April 19, 2007. 2 Similar conclusions were reached by members of the California Independent System Operator's Market Surveillance Committee: the chairman, Frank A. Wolak, and members James Bushnell and Benjamin F. Hobbs. Opinion on “Load-Based and Source-Based Trading of Carbon Dioxide in California, Market Surveillance Committee of the California ISO, Nov. 27, 2007. 3 In general, investments in improved and innovative technologies will most likely occur when the costs of GHG are clearly valued and internalized in the prices of the outputs or services provided by these technologies. Technologies suitable for global deployment will have greater opportunities for funding, demonstration, and ultimate success than technologies developed to meet only localized market needs. The worldwide deployment of technologies will be speeded up by allowing verified “offset” projects that utilize new technologies and help move them more rapidly along their developmental learning curves. 4 For those sectors with similar costs of control across the affected sources or where the burdens of regulation are prohibitive, a pre-combustion or upstream point of regulation may be preferable, such as imposing an emissions tax on gasoline at the refinery. 5 To achieve and maintain “environmental integrity,” GHG allowances must be tied to accurately measured, verifiable and enforceable tons of GHG emissions. The environmental integrity, equity, efficiency, and timing of allowance allocations, trading procedures, and compliance rules, such as banking or borrowing, are key design elements that will determine how well this future market functions. 6 While regional regulations created by the states are an important start, achieving the ultimate goal of global GHG reductions requires a U.S. national regulatory system that can reduce emissions at least cost. However, at the same time as a cap-and-trade market increases the demand for improved technologies to reduce GHG, additional incentives will be needed to develop and commercialize them because of the uncertainty of future GHG allowance prices and R&D market failures. 7 California Edison Company, Response of Southern California Edison Company (U 338-E) to Administrative Law Judge's Comments and Legal Briefs on Market Advisory Committee Report, CPUC Rulemaking 06-04-009, Aug. 6, 2007, at 16. 8 Even if allowances are awarded at no cost to regulated sources, the value or opportunity cost of an allowance of a particular vintage will set the market price of that vintage allowance at any given time. 9 Depending on competitive wholesale electricity prices, generators may not be able to incorporate all their GHG EA costs in their sales prices. 10 This and other characteristics of a load-based market design are discussed in Dallas Burtraw, “State Efforts to Cap the Commons: Regulating Sources or Consumers?” Resources for the Future, presented at Conference of Association for Public Policy and Management, Nov. 9, 2007. This paper concludes that “the load-based approach is not consistent with market reform and greater competition in the electricity sector.” It also warns that “a poorly designed market can lead to poor incentives and poor accountability that can bridge to other sectors and undermine confidence in climate policy” (at 12 and 17). 11 California Air Resources Board, Market Advisory Committee, Recommendations for Designing a Greenhouse Gas Cap-and-Trade System for California, Final Report, June 30, 2007, at 23. Available at http://www.climatechange.ca.gov/documents/2007-06-29_MAC_FINAL_REPORT.PDF. 12 Lonnie Rush and Kyle Hoffman, CAISO, presentation to CPUC Workshop on Reporting and Tracking for a Load-Based Cap for the Electricity Sector, April 12, 2007. 13 Only about 56 percent of emissions from imported electricity can be precisely identified, according to a 2007 CEC report: A. Alvarado and K. Griffin, Revised Methodology to Estimate the Generation Resource Mix of California Electricity Imports: Update to the May 2006 Staff Paper, California Energy Commission, Sacramento, CA, 2007. Such a situation does not satisfy the requirements for environmental integrity. 14 The magnitude of research, development, and demonstration funding needed to reach GHG reduction goals will require investment incentives well beyond those provided by an efficient market-based GHG regulatory scheme. The chosen regulatory scheme will primarily influence the purchase and utilization of technologies needed to achieve compliance and in so doing, it will also influence the investment and innovation needed to create improved technologies. 15 Some have argued that a load-based approach will encourage greater adoption of energy efficiency measures and renewable technologies. Since the CPUC in California currently mandates the adoption of energy efficiency measures and renewable generation technologies and can continue to do so, this is a debatable presumption. 16 Assembly Bill No. 32, California's Global Warming Solutions Act of 2006 (Sec. 38560). AB 32 requires the state Air Resources Board to adopt regulations for reporting and verification of statewide greenhouse gas emissions and to monitor and enforce compliance. The bill mandates a statewide greenhouse gas emissions limit equivalent to the statewide greenhouse gas emissions levels in 1990 to be achieved by 2020, and requires the state board to adopt rules and regulations in an open public process to achieve the maximum technologically feasible and cost-effective greenhouse gas emission reductions, as specified. The bill authorizes the state board to adopt market-based compliance mechanisms meeting specified requirements. The bill requires the state board to monitor compliance with and enforce any rule, regulation, order, emission limitation, emissions reduction measure, or market-based compliance mechanism adopted by the state board, pursuant to the specified provisions of existing law. The bill also gives the state board the authority to adopt a schedule of fees to be paid by regulated sources of greenhouse gas emissions. 17 While a low GHG emissions standard measured in maximum lbs./MMBtu or tonnes/MWh is unlikely to be achievable at older, inefficient power plants, such plants can provide relatively cheap GHG reductions, when measured on the basis of $ per ton GHG removed. Nevertheless, because older gas steam power plants operate infrequently and will be needed for load following, it may be that these older facilities will remain in service, despite their relatively high GHG emission rates. 18 In past years, low hydro conditions in California and the West have increased annual fossil-fired generation in California by as much as 25 percent above the amount occurring during an average hydro year. 19 See endnote 17.