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.

     

Keeping the forest for the climate's sake: avoiding deforestation in developing countries under the UNFCCC

Abstract

A process for reducing emissions from deforestation in developing countries has been initiated under the UNFCCC. Efforts to agree on a legally binding instrument to halt deforestation have previously failed in other international fora. The magnitude of the social, economic, technical and political complexities underlying deforestation have led to negotiations being challenging. What policy instruments could provide incentives to reduce deforestation, and how could these instruments be framed, under the UNFCCC? This article analyses the advantages and disadvantages of the available alternatives within and outside of the Kyoto Protocol. Staying within the Kyoto framework means low institutional development costs, established but limited incentives for action, and low flexibility. Alternatives outside the Protocol provide higher institutional development costs, uncertainties with regard to the incentives, but greater flexibility. We argue that a separate protocol may be the most viable option, as it could offer the necessary flexibility and avoid some technical and political pitfalls that would be likely to beset new efforts under the Kyoto Protocol. The article also presents the concept of ‘committed forests’ as a means of defining geographically where the reduction of emissions from deforestation can take place.     

Operationalizing the Adaptation Fund: challenges in allocating funds to the vulnerable

The Adaptation Fund of the Kyoto Protocol marks a change in the international climate change financing architecture due to its independence from official development assistance, direct access and the majority of developing countries in governance. A major goal of the Adaptation Fund is to finance concrete adaptation projects and programmes in developing countries that are particularly vulnerable to the effects of climate change. The presented analysis considers the results of operationalization of the fund between 2008 and 2010, and the role vulnerability had in the allocation of funds. The definition of ‘vulnerability’ remains broad and currently does not allow for a prioritization in the allocation of funds. Criteria like ‘level of vulnerability’ or ‘adaptive capacity’ still need to be specified. The possibilities for the Adaptation Fund Board to implement a vulnerability-oriented funding approach are limited by the legal basis of the Kyoto Protocol and the principle of a country-driven approach. The effective support of vulnerable communities primarily depends on the institutional capacities and the institutional arrangement at the national level and the quality of analysis the adaptation projects and programmes are based on.     

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.     

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.     

Policy innovation in a changing climate: Sources,patterns and effects

States have been widely criticized for failing to advance the international climate regime. Many observers now believe that a “new” climate governance is emerging through transnational and/or local forms of action that will eventually plug the resulting governance gaps. Yet states, which remain oddly absent from most discussions of the “new” governance, will remain key players as governance becomes more polycentric. This paper introduces a special issue that explores the ability of states to rise to these interconnected challenges through the analytical prism of policy innovation. It reveals that policy innovation is much more multi-dimensional than is often thought; it encompasses three vital activities: invention (centering on the ‘source’ of new policy elements), diffusion (that produces different ‘patterns’ of policy adoption), and the evaluation of the ‘effects’ that such innovations create in reality. The papers, which range from qualitative case studies to large ‘n’ quantitative studies, offer new insights into the varied roles that states play in relation to all three.They show, for instance that: the policy activity of states has risen dramatically in the past decade; that state innovation is affected to similar degrees by internal and external factors; and that policies that offer flexibility to target groups on how to meet policy goals are most effective but that voluntary reporting requirements are ineffective. This paper draws upon these and many other insights to offer a much more nuanced reflection on the future of climate governance; one that deservedly puts states at the front and center of analysis.     

Implementing CDM for the Indian dairy sector: prospects and issues

What is the potential for developing small-scale CDM projects in India to reduce enteric methane emissions from cattle and buffaloes? The issue of baseline setting for prospective CDM projects is a complex one in the Indian context. The baselines constructed on the basis of aggregate emission rates at the national level are unlikely to be precise as methane emission rates are influenced by the livestock and feed characteristics, which vary widely across regions in an agro-climatically diverse country like India. This calls for establishing a project specific baseline underpinned with regional methane emission rates. The various aspects of sustainable development that merit consideration in formulating a CDM project in the Indian dairy sector include; increasing the productivity of animals, increasing the net income of producers, decreasing the cost of milk production and the transfer of safe technologies. The projects in the sector would be able to meet the ‘additionality’ conditions of the CDM. However, there are a number of constraints in implementing the enteric methane mitigation strategies through a CDM project at the field level. The article discusses these technical, financial, socio-cultural and institutional barriers along with possible responses to these constraints.     

From inadvertent to reluctant pioneer? Climate strategies and policy style in France

Abstract

To comply with the Kyoto Protocol, signatory nations have implemented a policy template of reducing greenhouse gas emissions mainly from the electricity generation and heavy industry sectors. This article shows how, in the case of France, a policy style based on ‘environmental meso-corporatism’ has largely exhausted this ‘standard recipe’. To consider how far France has developed fresh solutions, two phases of climate policy-making in the 2000s are analysed. Increased recourse to new environmental policy instruments is identified, but implemented through the institutional routines of ‘environmental meso-corporatism’. The article argues that although this policy style has proved relatively well adapted to regulating the technologies of production, it has little purchase on cultures of consumption within the residential and transport sectors. Faced with new challenges, policymakers have proved better equipped to reform policy content than policy style. But France shows some reluctance to resolve the problem of limited policy reach.     

Additionality reconsidered: lax criteria may not benefit developing countries

Abstract

International negotiation on the additionality issue of the CDM (Clean Development Mechanism) seems to be proceeding without sufficient information or understanding. Especially apparent is a lack of recognition that the non-additional CERs (certified emission reductions) generated by relaxing the additionality criteria may lead to economic losses for developing countries. This article quantitatively reconfirms the effects of non-additional CERs on the international community, while clarifying that the generation of non-additional CERs in excess of a certain number will eventually lead to negative consequences for developing countries, even if these countries were able to acquire all the non-additional CERs. Furthermore, the Discussion section demonstrates that future system design would significantly affect the benefits of developing countries as well as the overall environmental integrity of the Kyoto mechanisms.     

Forging alliance with Russia: the example of a Green Investment Scheme

Abstract

Russian Kyoto related interests are economic and after the US withdrawal the mission of Russian actors has been to find new demand for Russian credits and allowances. Kyoto related benefits to Russia will be significantly smaller than earlier expected, however, the revenues are now more likely to be focused on climate change mitigation purposes. Competition in the Kyoto market has established buyers’ market and Russia has to accommodate the interests of investors in order to gain benefits. The Russian initiative ‘Green Investment Scheme’ to recycle revenues from International Emissions Trading (IET) to further environmental activities would convene demand for Russian AAUs but experience the same problems than the previous initiatives: inadequate institutional arrangement, unclear division of responsibilities between domestic actors, prolonged ratification process and lack of eligibility strategy. These problems have prevented implementation of GIS so far. Therefore, these problems have to be addressed by high-level Russian policy-makers if serious benefits from Kyoto are sought. Actors building alliances with Russia should focus on assisting with solving these problems.     

New lessons for technology policy and climate change: investment for innovation

The direction of UK energy policy requires a renewed impetus if the goal of climate change stabilization is to be met. Cost is not the main issue: a transformation to a low-carbon energy system may be no more expensive than meeting future energy demands with fossil fuels. Institutional barriers are preventing the large-scale adoption of the necessary technologies. New institutions to promote low-carbon technologies have not yet led to investment on the necessary scale. Further changes to the operation of the UK electricity markets to create a ‘level playing field’ for small-scale and intermittent generation are necessary. UK policy can contribute to international agreements following on from the Kyoto Accord, which also need to address the institutional barriers to energy technology development and transfer.     

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.     

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.

     

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.     

Estimating the CDM market under the Marrakech Accords

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.     

Russia: climate policy formation and implementation during the 1990s

Russian climate policy initially developed slowly, mostly in response to the emerging international regime in the early 1990s. Developments accelerated by the end of the decade, under the influence of the UNFCCC, and especially, its Kyoto Protocol. Developments included creation of institutional framework for domestic implementation of its reporting and other UNFCCC commitments, formulation of mitigation and adaptation strategies and measures, GHG inventory compilation and reporting, crystallizing its major national positions towards international mechanisms, initiation of vertical subsidiarity of government authority in climate policy implementation, and channeling interactions between the government and business community. The Kyoto Protocol and its international mechanisms (particularly IET and JI), mark a turning point, with opportunities for Russia to benefit if the Kyoto Protocol enters into force; the apparent US withdrawal from Kyoto puts Russia in a central position. Besides external influences, national climate policy has been strongly influenced by the domestic reforms towards market economy and democracy: combining new opportunities with constraints characteristic of the transition period. The gap between climate policy goals and putting them in practice has been considerable, but is narrowing.     

Investing in low-carbon transitions: energy finance as an adaptive market

The amount of capital required to transition energy systems to low-carbon futures is very large, yet analysis of energy systems change has been curiously quiet on the role of capital markets in financing energy transitions. This is surprising given the huge role finance and investment must play in facilitating transformative change. We argue this has been due to a lack of suitable theory to supplant neoclassical notions of capital markets and innovation finance. This research draws on the notion from Planetary economics: Energy, climate change and the three domains of sustainable development, by Grubb and colleagues, that planetary economics is defined by three ‘domains’, which describe behavioural, neoclassical, and evolutionary aspects of energy and climate policy analysis. We identify first- and second-domain theories of finance that are well established, but argue that third-domain approaches, relating to evolutionary systems change, have lacked a compatible theory of capital markets. Based on an analysis of electricity market reform and renewable energy finance in the UK, the ‘adaptive market hypothesis' is presented as a suitable framework with which to analyse energy systems finance. Armed with an understanding of financial markets as adaptive, scholars and policy makers can ask new questions about the role of capital markets in energy systems transitions.

Policy relevance

This article explores the role of financial markets in capitalising low-carbon energy systems and long-term change. The authors demonstrate that much energy and climate policy assumes financial markets are efficient, meaning they will reliably capitalise low-carbon transitions if a rational return is created by subsidy regimes or other market mechanisms. The authors show that the market for renewable energy finance does not conform to the efficient markets hypothesis, and is more in line with an ‘adaptive’ markets understanding. Climate and energy policy makers that design policy, strategy, and regulation on the assumption of efficient financial markets will not pay attention to structural and behavioural constraints on investment; they risk falling short of the investment levels needed for long-term systems change. In short, by thinking of financial markets as adaptive, the range of policy responses to enable low-carbon investment can be much broader.     

Kyoto flexibility mechanisms in EU accession countries: will they make a difference?

What potential effect do flexible mechanisms under the Kyoto Protocol have on energy efficiency, fuel switching and the development of renewable energy sources for the eight post-communist EU Member States that accessed in 2004? These countries are chief candidates for hosting Joint Implementation (JI) projects and for participating in international emission trading, which may assist the implementation and financing of projects in these target areas. The potentials and barriers to Joint Implementation are reviewed, as well as the conditions under which international emission trading can influence the energy use of the selling country. Different strategies adopted by the host countries towards the application of these instruments, and their impact on sustainable energy development, are examined. The article concludes that the Kyoto flexibility mechanisms may play a positive, but rather limited, role in the sustainable energy development of the region, but the barriers to Joint Implementation may shift the emphasis towards transactions under the framework of international emission trading. If innovative mechanisms are tied to sustainable development goals, this may mobilize the energyefficiency potentials of these countries. An attractive opportunity exists to achieve energy efficiency and emission reductions, utilizing the revenues from allowance sales through ‘green investment’ schemes.     

Climate negotiations beyond Kyoto: developing countries concerns and interests

Five years down the road from Kyoto, the Protocol that bears that city’s name still awaits enough qualifying ratifications to come into force. While attention has been understandably focussed on the ratification process, it is time to begin thinking about the next steps for the global climate regime, particularly in terms of a deeper inclusion of developing countries’ concerns and interests. This paper begins doing so from the perspective of the developing countries. The principal argument is that we need to return to the basic principles outlined in the Framework Convention on Climate Change in searching for a north-south bargain on climate change. Such a bargain may be achievable if we can realign the policy architecture of the climate regime to its original stated goals of sustainable development.     

The political economy of carbon markets: The CDM and other stories

Despite ongoing faith in their ability to deliver meaningful reductions in GHG emissions as the Durban climate summit approaches in December 2011 and as the end of the first commitment period of the Kyoto Protocol in 2012 looms large, carbon markets have been adversely affected by low prices that are failing to drive necessary investment in low-carbon technology and a series of scandals about their integrity. Some Clean Development Mechanism (CDM) projects have nevertheless delivered reductions in GHG emissions and sustainable development benefits. However, these benefits are too few, and strong incentives still remain in place to go for ‘low-hanging fruit’ opportunities that bring few additional environmental and developmental gains. Although governance reforms have a part to play in addressing these issues, these are not teething problems that can be easily weeded out with further institutional learning and innovation. They touch on the deeper politics of carbon markets and the role politics play in responses to climate change that have to be addressed.