Linking the CDM with domestic carbon markets

Certified emission reductions (CERs) from Clean Development Mechanism (CDM) projects have traditionally served as an indirect link between cap and trade systems around the world. However, since 2010, import restrictions have increased. Reasons for import limitations include the supplementarity principle, genuine concerns about the environmental integrity of CERs and social benefits of CDM projects, pressure from domestic emissions mitigation industries, concerns about competition in the industries in which reductions take place, as well as the attempt to pressure advanced developing countries to accept national emissions commitments under a future international climate policy regime. It is shown that import limitations lead to a decrease in CER prices and a race to generate CERs as quickly as possible. Such effects are visible in the CDM market after the EU announced its import limitations. The exclusion of CERs from specific project types will distort the CDM supply curve and increase the CER price unless the marginal abatement costs of the excluded project type are above the CER world market price. Similarly, exclusion of CERs from specific host countries will increase the price. Substantial differences are found in CER access to national carbon markets around the world.Policy relevanceCDM regulators could try to improve access of CERs to cap and trade schemes through improvements to additionality testing, standardizing baseline and monitoring methodologies and stakeholder consultation. However, regulators should be aware that standardization is no panacea, and controversies may resurface if standardized additionality determination (e.g. through benchmarks or positive lists) are applied for a certain period and found to be problematic. However, domestic policy concerns such as an unwillingness to send money abroad to buy credits, an inability to control market prices, and competitiveness impacts cannot be resolved by CDM reforms. If, despite such reforms of the CDM, blatant protectionism continues, a challenge before the World Trade Organisation (WTO) could be launched to stop discrimination of service exports from specific countries.     

A CER discounting scheme could save climate change regime after 2012

We can generate a net global GHG emission reduction from developing countries (in an UNFCCC term, non-Annex 1 Parties) without imposing targets on them, if we discount CERs generated from CDM projects. The CER discounting scheme means that a part or all of CDM credits, i.e., CERs, made by developing countries through unilateral CDM projects will be retired rather than sold to developed countries to increase their emissions. It is not feasible to impose certain forms of target (whether sectoral or intensity targets) on non-Annex 1 whose emission trend is hard to predict and whose industrial structure is undergoing a rapid change.

Instead of imposing targets (a command and control approach), we should apply market instruments in generating a net global emission reduction from non-Annex 1. Since April 2005 when the first unilateral CDM was approved by the CDM Executive Board, CDM has been functioning as a market mechanism to provide incentives for developing countries to initiate their own emission reduction projects. As CDM is the only market mechanism engaging developing countries in the Kyoto Protocol, we should try to re-design CDM so that it can generate net global emission reductions by introducing the idea of discounting CERs. But in order to produce meaningful GHG emission reductions by discounting CERs, the project scope of CDM has to be expanded by relaxing project additionality criteria while maintaining strict technical additionality criteria. Agreeing on the CERs Discounting Scheme will have a better political chance than agreeing on imposing emission reduction targets on developing countries.     

Future restrictions for sinks in the CDM How about a cap on supply?

Abstract

The first commitment period of the Kyoto Protocol is expected to result in only a small role for the Clean Development Mechanism (CDM), including afforestation and reforestation projects. Wide ranging concerns regarding sinks in the CDM have been reflected in the Marrakech Accords capping the total amount of emission offsets from sinks projects to be used by Annex I countries. Decisions about the second commitment period and beyond are likely to be of far greater importance for these projects.

This paper contributes to the discussion on how caps on sinks under the CDM could be used to obtain overall improved outcomes for developing countries. We examine two distinctive ways in which quantitative caps on sinks in the CDM can be implemented: one, restricting the use of sinks CERs to meet targets, as under the Marrakech Accords (a cap on demand); and two, restricting supply of sink CERs using a quota system. We argue in favour of a supply side cap, if Parties are to preserve the idea of limiting sinks in the CDM. Limiting the supply of credits could lead to better financial outcomes for developing countries as a whole, make higher-cost projects viable which may have better sustainability impacts, and provide an alternative to deal with equity concerns between developing countries.     

Tenders: an option for developing countries to support renewable energies under the CDM

Abstract

Renewable energy sources are generally considered as an important tool on the way towards sustainable development. However, if developing countries want to actively promote renewable energies, they may need to face the problem that current legislation conflicts with the clean development mechanism (CDM) rules, and especially with the additionality concept. Thus, CDM projects may become impossible to implement. This article presents an approach to overcoming these potential difficulties. One solution lies in offering a tender specifically for RE-CDM-projects.     

Standardization of baseline and additionality determination under the CDM

Clean Development Mechanism (CDM) project developers have long complained about the complexities of project-specific baseline setting and the vagaries of additionality determination. In response to this, the CDM Executive Board took bold steps towards the standardization of CDM methodologies, culminating in the approval of guidelines for the establishment of performance standards in November 2011. The guidelines specify a performance standard stringency level for both baseline and additionality of 80% for several priority sectors and 90% for all other sectors. However, an analysis of 14 large-scale CDM methodologies that use performance standard approaches challenges this top-down approach to the performance standard design. An appropriate performance standard stringency level strongly depends on sector and technology characteristics. A single stringency level for baseline and additionality determination is appropriate only for greenfield projects, but not for retrofit ones. Overly simple, highly aggregated performance standards are unlikely to ensure high environmental integrity, and difficult questions regarding stringency and updating frequency will eventually have to be addressed on a rather disaggregated level. A careful balance between data requirements and the practicability of performance standards is essential because the heavy data requirements of the existing performance standard methodologies have been the key barrier to their actual implementation.

Policy relevance

CDM regulators have been pushed by many stakeholders to standardize baseline setting and eliminate project-specific additionality determination. At first glance, performance standards seem to provide the perfect solution for both tasks. However, a one-size-fits-all political decision – e.g. the average of the top 20% performers as enshrined in the Marrakech Accords – is inappropriate. Substantial disaggregation of performance standards is required both technologically and geographically in order to limit over- and under-crediting and close loopholes for non-additional projects. As a lack of reliable and complete data has been and will be a key bottleneck for the development of performance standards, international support for data collection will be indispensable, but costly, and time-consuming. Empirically driven, techno-economic assessments of performance standard stringency levels must be the central task of the future work on standardized methodologies, and should not be sidelined by perceived needs of policy makers to take bold decisions under time pressures.     

Additionality revisited: guarding the integrity of market mechanisms under the Paris Agreement

ABSTRACT

The Paris Agreement requires mitigation contributions from all Parties. Therefore, the determination of additionality of activities under the market mechanisms of its Article 6 will need to be revisited. This paper provides recommendations on how to operationalize additionality under Article 6. We first review generic definitions of additionality and current approaches for testing of additionality before discussing under which conditions additionality testing of specific activities or policies is still necessary under the new context of the Paris Agreement, that is, in order to prevent increases of global emissions. We argue that the possibility of ‘hot air’ generation under nationally-determined contributions (NDCs) requires an independent check of the NDC’s ambition. If the NDC of the transferring country does contain ‘hot air’, or if the transferred emission reductions are not covered by the NDC, a dedicated additionality test should be required. While additionality tests of projects and programmes could continue to be done through investment analysis, for policy instruments new approaches are required. They should be differentiated according to type of policy instrument. For regulation, we suggest calculating the resulting pay-back period for technology users. If the regulation generates investments exceeding a payback period threshold, it could be deemed additional. Similarly, carbon pricing policies that generate a carbon price exceeding a threshold could qualify; for trading schemes an absence of over-allocation needs to be shown. The threshold should be differentiated according to country categories and rise over time.

Key policy insights

• Without additionality testing, market mechanisms under the Paris Agreements might lead to an international diffusion of ‘hot air’. To avoid this, an independent assessment of NDC ambition is in order. Otherwise, activities under the mechanisms need to undergo specific additionality tests.

• Additionality testing of projects and programmes should build on the experience developed under the Kyoto Protocol mechanisms.

• Bold approaches are needed for assessing additionality of policies. To avoid cumbersome assessment of all activities triggered by such policies, highly aggregated approaches are suggested, ranging from payback period thresholds for technologies mandated by regulation to minimum price levels triggered by carbon pricing policies. Over time, the stringency of threshold values should increase.

     

Experts talk the future Reflections on the Bonn Seminar of Governmental Experts, 16–17 May 2005: a view from Europe

Abstract

This article provides a first-cut estimate of the potential impacts of the clean development mechanism (CDM) on electricity generation and carbon emissions in the power sector of non-Annex 1 countries. We construct four illustrative CDM regimes that represent a range of approaches under consideration within the climate community. We examine the impact of these CDM regimes on investments in new generation, under illustrative carbon trading prices of US$ 10 and 100/t C. In the cases that are most conducive to CDM activity, roughly 94% of new generation investments remains identical to the without-CDM situation, with only 6% shifting from higher to lower carbon intensity technologies.We estimate that the CDM would bolster renewable energy generation by as little as 15% at US$ 10/t C, or as much as 300% at US$ 100/t C.

A striking finding comes from our examination of the potential magnitude of the “free-rider” problem, i.e. crediting of activities that will occur even in the absence of the CDM. The CDM is intended to be globally carbon-neutral—a project reduces emissions in the host country but generates credits that increase emissions in the investor country. However, to the extent that unwarranted credits are awarded to non-additional projects, the CDM would increase global carbon emissions above the without-CDM emissions level. Under two of the CDM regimes considered, cumulative free-riders credits total 250–600 MtC through the end of the first budget period in 2012. This represents 10–23% of the likely OECD emissions reduction requirement during the first budget period. Since such a magnitude of free-rider credits from non-additional CDM projects could threaten the environmental integrity of the Kyoto protocol, it is imperative that policy makers devise CDM rules that encourage legitimate projects, while effectively screening out non-additional activities.     

Future restrictions for sinks in the CDM: How about a cap on supply?

The first commitment period of the Kyoto Protocol is expected to result in only a small role for the Clean Development Mechanism (CDM), including afforestation and reforestation projects. Wide ranging concerns regarding sinks in the CDM have been reflected in the Marrakech Accords capping the total amount of emission offsets from sinks projects to be used by Annex I countries. Decisions about the second commitment period and beyond are likely to be of far greater importance for these projects.This paper contributes to the discussion on how caps on sinks under the CDM could be used to obtain overall improved outcomes for developing countries. We examine two distinctive ways in which quantitative caps on sinks in the CDM can be implemented: one, restricting the use of sinks CERs to meet targets, as under the Marrakech Accords (a cap on demand); and two, restricting supply of sink CERs using a quota system. We argue in favour of a supply side cap, if Parties are to preserve the idea of limiting sinks in the CDM. Limiting the supply of credits could lead to better financial outcomes for developing countries as a whole, make higher-cost projects viable which may have better sustainability impacts, and provide an alternative to deal with equity concerns between developing countries.     

Application of the Multiple Benchmark System (MBS) to selected case study projects

Abstract

Joint Implementation (JI) and the Clean Development Mechanism (CDM) have been established under the Kyoto Protocol as project-based instruments to mitigate greenhouse gases of the industrialized countries to the levels imposed by their Kyoto commitments. An unresolved issue associated with the implementation of these two flexibility mechanisms, concerns the choice of the appropriate baseline for calculating the emission reductions in JI or CDM projects. This article describes a computerized tool that constructs and compares different types of standardized baselines and benchmarks. The analysis focuses on the suitability of several different types of benchmarks for assessing the emission reductions of certain types of projects. The analysis is also expanded into a discussion of the extent to which benchmarks reduce the crediting of non-additional projects and limit the risk of missed additional investments. This tool has been applied to actual JI and CDM projects in the Russian Federation and Indonesia.     

Implications of early action for JI baselines

Abstract

This article discusses possible implications of early Joint Implementation (JI) action. Some projects which would otherwise be non-additional during the first commitment period, can become additional by implementing them before 2008 through early JI. For example, several environmental investments that will be mandatory under the European Union (EU) Acquis Communautaire as of, e.g. 2008 or 2010 could be carried out earlier than that with early JI action. As such, candidate countries could partly finance the accession process through JI credits and their environmental standards would earlier be in line with the Acquis. The theoretical risk that projects would have to follow a slow track if JI parties are not eligible for the fast track is not large for JI hosts that are candidate for EU membership.     

Estimating the CDM market under the Marrakech Accords

Abstract

The agreement on implementation of the Kyoto Protocol achieved at COP7 in Marrakech has important implications for investment in greenhouse gas emission reduction projects in developing countries through the Clean Development Mechanism (CDM). The required actual emission reductions for participating Annex B countries overall will be relatively small, as the United States do not intend to ratify the protocol and significant amounts of carbon sequestered in domestic sinks can be credited. In addition, the potential supply of surplus emission permits (hot air) from Russia and other economies in transition may be as high as total demand in the first commitment period. Thus, even under restraint of hot air sellers, CDM demand will be limited, and a low demand, low price carbon market scenario appears likely.

The magnitude of the CDM will be influenced by a host of factors both on the demand and the supply-side. We analyse these using a quantitative model of the global carbon market, based on marginal abatement cost curves. Implementation and transaction costs, as well as baseline and additionality rules affect the CDM's share in the carbon market. Demand for the CDM is sensitive to changes in business-as-usual emissions growth in participating Annex B countries, and also to crediting for additional sinks. Permit supply from Russia and other economies in transition is possibly the most crucial factor in the carbon market.     

Assessing the additionality of CDM projects: practical experiences and lessons learned

The Clean Development Mechanism (CDM) under the Kyoto Protocol allows industrialized countries to use credits from greenhouse gas (GHG) abatement projects in developing countries. A key requirement of the CDM is that the emission reductions be real, measurable and additional. This article evaluates how the additionality of CDM projects has been assessed in practice. The analysis is mainly based on a systematic evaluation of 93 registered CDM projects and comes to the conclusion that the current tools for demonstrating additionality are in need of substantial improvement. In particular, the application of the barrier analysis is highly subjective and difficult to validate in an objective and transparent manner. Key assumptions regarding additionality are often not substantiated with credible, documented evidence. In a considerable number of cases it is questionable whether the emission reductions are actually additional. Based on these findings, practical recommendations for improving the assessment of additionality are provided.     

Past as prologue: an innovation-diffusion approach to additionality

The ‘additionality’ criterion for the Clean Development Mechanism (CDM) (which is key to ensuring that CDM projects lead to real and additional emission reductions) has been a topic of much analysis and discussion. A number of different approaches, including those based on financial, barrier and market-penetration criteria, have been suggested as a test for additionality. A simple test for additionality is proposed that draws on the framework of the diffusion of innovations, especially the risk profile of adopters of new technologies or innovations. This approach has the potential to streamline the assessment for additionality, although it will require data on the rate of implementation of specific technologies or innovations.     

How to operationalize accounting under Article 6 market mechanisms of the Paris Agreement

The role of market mechanisms was far from certain in the lead up to the 2015 Paris Climate Conference. The use of ‘constructive ambiguity’ led to Article 6 of the Paris Agreement, with Article 6.2 specifying a mechanism with limited international oversight, and Article 6.4 establishing a ‘Sustainable Development Mechanism’ (SDM) subject to detailed rules. Clear operationalization of these mechanisms remains a challenge, especially regarding the critical accounting issue that could not be resolved at the 2018 Katowice Climate Conference (COP24) – how to apply corresponding adjustments, especially regarding sectors not covered by targets under nationally-determined contributions (NDCs). By using fictitious examples, we explain two possible approaches to using Internationally Transferred Mitigation Outcomes (ITMOs) under Article 6.2 for achieving NDCs: a ‘target-based’ one where the acquiring Party adds the ITMO amount to the target level of its NDC; and a ‘tally-based’ one where the acquiring Party removes the ITMO amount from the final tally of its NDC. We discuss how these approaches influence the way to make corresponding adjustments and to avoid ‘double counting’. The first one leads to ‘target/budget-based accounting’, the second one to ‘emission-based accounting’. For mitigation outside the scope of the host Party's NDC, we propose using a tally-based interpretation of ITMO use, as opposed to the target-based variety used in the 1997 Kyoto Protocol, and stress the need for additionality testing. This interpretation allows for mandatory corresponding adjustments for all ITMO usage, while the host Party NDC level remains unchanged. A buffer registry is created for corresponding non-NDC adjustments of the selling party.

Key policy insights

• Under the Paris Agreement, transfers of emissions units between two countries through the Article 6 mechanisms need a corresponding adjustment on both sides to prevent double counting.

• Corresponding adjustments can be applied either to emissions targets under NDCs or measured emissions levels.

• The transfer of emissions reduction credits generated outside an NDC should lead to a corresponding adjustment of a buffer registry of the selling country, but not its emissions level/NDC target. Such credits should only be generated if additionality of the reductions is shown.

     

Market penetration metrics: tools for additionality assessment?

Abstract

Project-based emission reduction or ‘offset’ programs are being implemented widely, from the CDM (Clean Development Mechanism) to corporate voluntary efforts and municipal and state-level activities. Additionality assessment remains a central and persistent challenge in all programs. Concerns have been raised with methods currently used, such as investment analysis, barrier analysis, and performance thresholds. They have been variously critiqued for high costs, resistance to standardization, weak environmental integrity, and susceptibility to gaming. Technology penetration rates provide another means to infer additionality, and could be a potentially useful complement to other methods. The notion is that emerging technologies with low but increasing penetration rates typically require some type of support, as might be provided through offsets markets, to compete effectively in the marketplace. For penetration rate analysis to provide a useful tool for additionality assessment, several fundamental questions need to be addressed. What do penetration rates represent and how can they be measured? How can additionality evaluation utilize penetration rates? For which sectors and project types are the use of penetration rates most promising? This article shows that penetration tests have a mixture of pluses and minuses, with greater relevance in certain market niches and regions. Reasonable ranges for penetration thresholds are discussed, along with partial crediting approaches to reduce ‘knife-edge’ effects.     

Proposal for a poverty-adaptation-mitigation window within the Green Climate Fund

The stakes for alleviating poverty and avoiding unbridled climate change are inextricably linked. Climate change impacts will slow down and may even reverse trends in poverty reduction. The pathways consistent with global warming of no more than 2?°C require strategies for poverty alleviation to make allowance for the constraint of low-carbon development. Existing climate funds have failed to target poverty alleviation as a high-priority strategy for adaptation or as a component of low-carbon development. This article proposes a funding window as part of the Green Climate Fund in order to foster synergies targeting greater satisfaction of basic needs, while making allowance for adaptation and mitigation. This financial mechanism is based on indicators of the satisfaction of basic needs and could respond to the claims of the developing countries, which see alleviating poverty as the first priority in climate negotiations. It defines a country continuum, given that there are poor people everywhere; all developing countries are therefore eligible with a mechanism of this sort.

Policy relevance

The Intergovernmental Panel on Climate Change (IPCC) calls for substantial emissions reductions and adaptation strategies over the next decades to reduce the high risks of severe impacts of climate change over the 21st century. Industrialized countries and developing countries alike recognize the need to mitigate climate change and to adapt to it. But they face many challenges that lead to an ‘emissions gap’ between an emissions level consistent with the 2?°C increase limit and the voluntary pledges that they have made thus far in the climate negotiations (United Nations Environment Programme. (2014). The Emissions Gap Report 2014. A UNEP synthesis report). In this arena, many developing countries underline that their first domestic priority is the satisfaction of basic needs. In the run-up to the next climate negotiations at the 21st Conference of the Parties (COP 21) in Paris, the proposed poverty-adaptation-mitigation funding window could contribute to alleviate the conflict between development and climate goals in developing countries. In this sense, it could spur developing countries to integrate more ambitious emissions limitations pledges into their Intended Nationally Determined Contributions. This could in turn entice industrialized countries to act similarly. In the end, it could pave the way to an ambitious climate agreement in Paris at COP 21.     

Baseline,leakage and measurement issues: how do forestry and energy projects compare?

Abstract

This paper examines three issues in quantifying project-level emissions reductions (ERs): baseline and additionality determination, leakage assessment, and measurement of net emissions. It finds no systematic differences between land use change and forestry (LUCF) and energy projects in addressing these issues. Rather, the ease of quantification depends on the following:

• ?The level and distribution of direct financial benefits that result from the project, since this is a key determinant of additionality.

• ?The degree to which the project is integrated with a broader physical and economic system, since this determines the amount of leakage.

• ?The internal homogeneity and geographic dispersion of the project components—a key determinant of measurement costs.

These dimensions cut across the energy versus LUCF distinction.     

Comparing developing countries under potential carbon allocation schemes

Abstract

To stabilise atmospheric greenhouse gas concentrations, all countries will eventually need to be included in the effort to limit climate change. This article explores what potential future greenhouse gas allocation schemes might mean for key developing countries. The need for development is widely acknowledged, but growth in non-Annex I country emissions means that such development may need to take a different path to business as usual. The national interests of developing countries in negotiating potential future commitments are shaped by basic characteristics, notably emissions (both annual and historical cumulative), economic growth and population. These factors in turn shape the acceptability of allocations based on ability to pay, emissions intensity, or emissions per capita.

Results for six major developing countries (China, India, Brazil, South Africa, Argentina and Nigeria) show that the implications for developing countries differ widely. For example, ability to pay does not favour Argentina; a reduction based on emissions intensity is not appropriate for Brazil; and per capita allocations would be problematic for South Africa. It is difficult to conceive of a single allocation scheme that would be appropriate for all developing countries. This points to the need for differentiation between developing countries in terms of any potential future commitments.     

Adaptation and poverty reduction in Mozambique: an opportunity for developing countries to lead§

Climate change disproportionately impacts the world’s poorest countries. A recent World Bank report highlighted that over 100 million people are at risk of falling into extreme poverty as a result of climate change. There is currently a lack of information about how to simultaneously address climate change and poverty. Climate change challenges provide an opportunity for those impacted most to come up with new and innovative technologies and solutions. This article uses an example from Mozambique where local and international partners are working side-by-side, to show how developing countries can simultaneously address climate change and poverty reduction using an ecosystem-based adaptation approach. Using ecosystem-based adaptation, a technique that uses the natural environment to help societies adapt to climate change, developing countries can lead the way to improve climate adaptation globally. This paradigm shift would help developing countries become leaders in ecosystem-based adaptation and green infrastructure techniques and has implications for climate policy worldwide.

POLICY RELEVANCE

The Paris Agreement resulting from the United Nations Framework Convention on Climate Change (UNFCCC) 21st Conference of Parties (COP 21) in December 2015 was rightly lauded for its global commitment to cut greenhouse gas emissions. However, COP 21 was also historic because of its call for non-party stakeholders to address climate change, inclusion of a global goal of ‘enhancing adaptive capacity, strengthening resilience and reducing vulnerability’, and the United States’ commitment of $800 million to adaptation funding. The combination of recognizing the need for new stakeholders to commit to climate change adaptation, the large impact climate change will have on the developing world, and providing access to funds for climate change adaptation creates a unique opportunity for developing countries to pave the way in adaptation policies in practices. Currently, developing countries are creating National Adaptation Plans (NAPs) for the UNFCCC. Through including a strong component of ecosystem-based adaptation in NAPs, developing countries can shape their countries’ policies, improve local institutions and governments, and facilitate a new generation of innovative leaders. Lessons learned in places like Mozambique can help lead the way in other regions facing similar climatic risks.     

Implications of early action for JI baselines

This article discusses possible implications of early Joint Implementation (JI) action. Some projects which would otherwise be non-additional during the first commitment period, can become additional by implementing them before 2008 through early JI. For example, several environmental investments that will be mandatory under the European Union (EU) Acquis Communautaire as of, e.g. 2008 or 2010 could be carried out earlier than that with early JI action. As such, candidate countries could partly finance the accession process through JI credits and their environmental standards would earlier be in line with the Acquis. The theoretical risk that projects would have to follow a slow track if JI parties are not eligible for the fast track is not large for JI hosts that are candidate for EU membership.