News Flash: There Is No "Environmental Certainty"

The principal benefit cited for cap & trade is “environmental certainty,” meaning that “a cap-and-trade system, coupled with adequate enforcement, assures that environmental goals actually would be achieved by a certain date.” Environmental certainty is a bit of a misnomer. I think of environmental certainty as ensuring a reasonable chance of avoiding serious climate impacts. What people mean when they’re talking about cap & trade is really “emissions certainty.” Unfortunately, emissions certainty doesn’t provide climate certainty:

Emissions trajectories yielding 2C temperature change

Even if we could determine a “safe” level of interference in the climate system, the sensitivity of global mean temperature to increasing atmospheric CO2 is known perhaps only to a factor of three or less. Here we show how a factor of three uncertainty in climate sensitivity introduces even greater uncertainty in allowable increases in atmospheric CO2 CO2 emissions. (Caldeira, Jain & Hoffert, Science)

The uncertainty about climate sensitivity (not to mention carbon cycle feedbacks and other tipping point phenomena) makes the emissions trajectory we need highly uncertain. That trajectory is also subject to other big uncertainties – technology, growth convergence, peak oil, etc. Together, those features make it silly to expend a lot of effort on detailed plans for 2050. We don’t need a ballistic trajectory; we need a guidance system. I’d like to see us agree to a price on GHGs everywhere now, along with a decision rule for adapting that price over time until we’re on a downward emissions trajectory. Then move on to the other legs of the stool: ensuring equitable opportunities for development, changing lifestyle, tackling institutional barriers to change, and investing in technology.

Unfortunately, cap & trade seems ill-suited to adaptive control. Emissions commitments and allowance allocations are set in multi-year intervals, announced in advance, with long lead times for design. Financial markets and industry players want that certainty, but the delay limits responsiveness. Decision makers don’t set the commitment by strictly environmental standards; they also ask themselves what allocation will result in an “acceptable” price. They’re risk averse, so they choose an allocation that’s very likely to lead to an acceptable price. That means that, more often than not, the system will be overallocated. On balance, their conservatism is probably a good thing; otherwise the whole system could unravel from a negative public reaction to volatile prices. Ironically, safety valves – one policy that could make cap & trade more robust, and thus enable better mean performance – are often opposed because they reduce emissions certainty.

Cap & Trade – How Soon?

I’m a strong advocate for a price on carbon, but I have serious reservations about cap & trade. I’m thrilled that climate policy is finally getting off the dime, but I wish enthusiasm were focused on a carbon tax instead. Consider this:

Jurisdiction Instrument Started Operational Status
EU Cap & Trade 2003 2005 Phase 1 overallocated & underpriced; still wrangling over loopholes for subsequent phases
British Columbia Tax Feb 2008 July 2008 Too low to do much yet, but working
Sweden Tax 1991 1991 Running, at $150/TonCO2; emissions down
RGGI Cap & Trade 2003 2008 Overallocated
Norway Tax 1990 1991 Works; not enough to lower emissions substantially
California Cap & Trade (part of AB32) 2007 Earliest 2012 Punted
WCI Cap & Trade 2007 Earliest 2012 Draft design

The pattern that stands out to me is timing – cap & trade systems are slow to get out of the gate compared to carbon taxes. They entail huge design challenges, which often restrict sectoral coverage. Price uncertainty makes it difficult to work out the implications of allowance allocation (unless you go to pure auction, in which case you lose the benefit of transitional grandfathering as a mechanism to buy carbon-intensive industry participation). I think we’ll be lucky to see an operational cap & trade system in the US, with meaningful prices and broad coverage, by the end of the first Obama administration.

Next Generation Climate Policy Models

Today I’m presenting a talk at an ECF workshop, Towards the next generation of climate policy models. The workshop’s in Berlin, but I’m staying in Montana, so my carbon footprint is minimal for this one (just wait until next month …). My slides are here: Towards Next Generation Climate Policy Models.

I created a set of links to supporting materials on del.icio.us.

Update Workshop materials are now on a web site here.

California Punting on Cap & Trade

Bloomberg reports that California’s cap and trade program may still be some way off:

[CARB chair] Nichols told venture capitalists and clean-energy executives last week in Mountain View, California, that she was “thinking of punting,” saying the specifics of the emissions-trading program may not be ready for 1-2 more years.

“I think the cap-and-trade system needs to be thought through and I don’t think that has been done yet,” said Jerry Hill, a member of the Air Resources Board. “It would be a good idea to take our time to be sure what we do create is successful.”

Greentech VCs aren’t thrilled, but I think this is wise, and applaud CARB for recognizing the scale of the design task rather than launching a half-baked program. Still, delay is costly, and design complexity contributes to delay. California has a lot of balls in the air, with a hybrid design involving a dozen or so sectoral initiatives, a low-carbon fuel standard, and cap & trade. As I said a while ago,

My fear is that the analysis of GHG initiatives will ultimately prove overconstrained and underpowered, and that as a result implementation will ultimately crumble when called upon to make real changes (like California’s ambitious executive order targeting 2050 emissions 80% below 1990 levels). California’s electric power market restructuring debacle jumps to mind. I think underpowered analysis is partly a function of history. Other programs, like emissions markets for SOx, energy efficiency programs, and local regulation of criteria air pollutants have all worked OK in the past. However, these activities have all been marginal, in the sense that they affect only a small fraction of energy costs and a tinier fraction of GDP. Thus they had limited potential to create noticeable unwanted side effects that might lead to damaging economic ripple effects or the undoing of the policy. Given that, it was feasible to proceed by cautious experimentation. Greenhouse gas regulation, if it is to meet ambitious goals, will not be marginal; it will be pervasive and obvious. Analysis budgets of a few million dollars (much less in most regions) seem out of proportion with the multibillion $/year scale of the problem.

One result of the omission of a true top-down design process is that there has been no serious comparison of proposed emissions trading schemes with carbon taxes, though there are many strong substantive arguments in favor of the latter. In California, for example, the CPUC Interim Opinion on Greenhouse Gas Regulatory Strategies states, ‘We did not seriously consider the carbon tax option in the course of this proceeding, due to the fact that, if such a policy were implemented, it would most likely be imposed on the economy as a whole by ARB.’ It’s hard for CARB to consider a tax, because legislation does not authorize it. It’s hard for legislators to enable a tax, because a supermajority is required and it’s generally considered poor form to say the word ‘tax’ out loud. Thus, for better or for worse, a major option is foreclosed at the outset.

At the risk of repeating myself,

The BC tax demonstrates a huge advantage of a carbon tax over cap & trade: it can be implemented quickly. The tax was introduced in the Feb. 19 budget, and switched on July 1st. By contrast, the WCI and California cap & trade systems have been underway much longer, and still are no where near going live.

My preferred approach to GHG regulation would be, in a nutshell: (a) get a price on emissions ASAP, in as simple and stable a way as possible; if you can’t have a tax, design cap & trade to look like a tax (b) get other regions to harmonize (c) then do all that other stuff: removing institutional barriers to change, R&D, efficiency and renewable incentives, in roughly that order (c) dispense with portfolio standards and other mandates unless (a) through (c) aren’t doing the job.

State Emissions Commitments

For the Pangaea model, colleagues have been compiling a useful table of international emissions commitments. That will let us test whether, if fulfilled, those commitments move the needle on global atmospheric GHG concentrations and temperatures (currently they don’t).

I’ve been looking for the equivalent for US states, and found it at Pew Climate. It’s hard to get a mental picture of the emissions trajectory implied by the various commitments in the table, so I combined them with emissions data from EPA (fossil fuel CO2 only) to reconcile all the variations in base years and growth patterns.

The history of emissions from 1990 to 2005, plus future commitments, looks like this:

State emissions commitments, vs. 1990, CO2 basis

Note that some states have committed to “long term” reductions, without a specific date, which are shown above just beyond 2050. There’s a remarkable amount of variation in 1990-2005 trends, ranging from Arizona (up 55%) to Massachusetts (nearly flat).

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Is the BC Carbon Tax Fair?

That’s the title of a post today at The Progressive Economics Forum, introducing a new report from the Canadian Centre for Policy Alternatives.

The bottom line:

In this study, we model the distribution of BC’s carbon tax and recycling measures. Our results conirm that BC’s carbon tax, in and of itself, is regressive. However, the overall carbon tax and recycling framework is modestly progressive in 2008/09 ’” that is, low-income families get back more in credits, on average, than they pay in carbon taxes. If the low-income credit is not expanded, however, the regime will shift to become regressive by 2010/11. It is important for policy makers to rectify this situation in the 2009 and future budgets by minimally ensuring that the credit grows in line with the carbon tax.

A related problem:

A second concern with the carbon tax regime is that tax cuts undermine a progressive outcome at the top of the income scale. In 2008/09, personal and corporate income tax cuts lead to an average net gain for the top 20% of households that is larger in dollar terms than for the bottom 40%.

I plotted the results in the report’s tables to show some of these effects. In 2009, the lowest income groups (quintiles 1-3) come out a little ahead, but the 4th quintile faces a net loss, while the top income group is overcompensated by the corporate tax cut:

BC carbon tax incidence and rebate distribution

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Risk Communication on Climate

John Sterman’s new Policy Forum in Science should be required reading. An excerpt:

The strong scientific consensus on the causes and risks of climate change stands in stark contrast to widespread confusion and complacency among the public. Why does this gulf exist, and why does it matter? Policies to manage complex natural and technical systems should be based on the best available scientific knowledge, and the Intergovernmental Panel on Climate Change (IPCC) provides rigorously vetted information to policy-makers. In democracies, however, the beliefs of the public, not only those of experts, affect government policy.

Effective risk communication is grounded in deep understanding of the mental models of policy-makers and citizens. What, then, are the principal mental models shaping people’s beliefs about climate change? Studies show an apparent contradiction: Majorities in the United States and other nations have heard of climate change and say they support action to address it, yet climate change ranks far behind the economy, war, and terrorism among people’s greatest concerns, and large majorities oppose policies that would cut greenhouse gas (GHG) emissions by raising fossil fuel prices.

More telling, a 2007 survey found a majority of U.S. respondents (54%) advocated a “wait-and-see” or “go slow” approach to emissions reductions. Larger majorities favored wait-and-see or go slow in Russia, China, and India. For most people, uncertainty about the risks of climate change means costly actions to reduce emissions should be deferred; if climate change begins to harm the economy, mitigation policies can then be implemented. However, long delays in the climate’s response to anthropogenic forcing mean such reasoning is erroneous.

Wait-and-see works well in simple systems with short lags. We can wait until the teakettle whistles before removing it from the flame because there is little lag between the boil, the whistle, and our response. Similarly, wait-and-see would be a prudent response to climate change if there were short delays in the response of the climate system to intervention. However, there are substantial delays in every link of a long causal chain stretching from the implementation of emissions abatement policies to emissions reductions to changes in atmospheric GHG concentrations to surface warming to changes in ice sheets, sea level, agricultural productivity, extinction rates, and other impacts. Mitigating the risks therefore requires emissions reductions long before additional harm is evident. Wait-and-see policies implicitly presume the climate is roughly a first-order linear system with a short time constant, rather than a complex dynamical system with long delays, multiple positive feedbacks, and nonlinearities that may cause abrupt, costly, and irreversible regime changes.

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