This post originally appeared on Robert Stavins’s blog, An Economic View of the Environment.
In my previous essay at this blog – The Importance of Getting it Right in California – I wrote about the precedents and lessons that California’s Global Warming Solutions Act (AB 32) and its greenhouse gas (GHG) cap-and-trade system will have for other jurisdictions around the world, including other states, provinces, countries, and regions. This is particularly important, given the failure of the U.S. Senate in 2009 to pass companion legislation to the Waxman-Markey bill, passed by the U.S. House of Representatives, highlighting the absence of a national, economy-wide carbon pricing policy.
In my previous essay, I focused on three pending design issues in the emerging rules for the AB-32 cap-and-trade system: (1) the GHG allowance reserve; (2) the role of offsets; and (3) proposals for allowance holding limits. I drew upon a presentation I made on “Offsets, Holding Limits, and Market Liquidity (and Other Factors Affecting Market Performance)” at the 2013 Summer Issues Seminar of the California Council for Environmental and Economic Balance.
At the same conference, I made another presentation, which was on “Allowance Value Distribution and Trade Exposure,” a topic that is of great importance both economically and politically, not only in the context of the design of California’s AB-32 cap-and-trade system, but for the design of any cap-and-trade instrument in any jurisdiction. It is to that topic that I turn today. (For a much more detailed discussion, please see a white paper I wrote with Dr. Todd Schatzki of Analysis Group, “Using the Value of Allowances from California’s GHG Cap-and-Trade System,” August, 2012).
Why Does Anyone Care About the Allowance Value Distribution?
A cap-and-trade policy creates a valuable new commodity – emissions allowances. In a well-functioning emissions trading market, the financial value of these allowances (per ton of emissions, for example) is approximately equivalent to their opportunity cost, which is the marginal cost of emissions reductions. This is because of the existence of the overall cap, which – if binding – fosters scarcity of available allowances, and hence generates their economic value.
It should not be surprising, then, that the initial allocation of these allowances can have important consequences both for environmental and for economic outcomes.
Environmental Consequences of the Initial Allowance Allocation
No matter how many times I meet with policy makers around the world to talk about alternative policy instruments (for climate change and other environmental problems), I never cease to be struck by the confusion that abounds regarding the environmental (and the economic) consequences of the initial allocation of allowances in a cap-and-trade system. As I have written many times in the past at this blog, the initial allocation does not directly affect environmental outcomes. Regardless of the allocation method used, aggregate emissions are limited by the emissions cap. This is true whether the allowances are sold (auctioned) or distributed without charge. Furthermore, which firms or sources receive the initial allocation of allowances has no effect on either aggregate emissions or the ultimate distribution of emissions reductions among sources.
This independence of a cap-and-trade system’s performance from the initial allowance allocation was established as far back as 1972 by David Montgomery in a path-breaking article in the Journal of Economic Theory (based upon his 1971 Harvard economics Ph.D. dissertation). It has been validated with empirical evidence repeatedly over the years. (More below about the initial allocation’s potential effects on economic performance.)
However, it is also true that the initial allocation method can indirectly affect emissions. In particular, emissions leakage can arise if economic activity shifts to unregulated sources – this risk is greatest with auctions or free fixed allocations. In contrast, an updating, output-based allocation (used in AB 32 for “industry assistance”) can reduce leakage risk by making the free allocation of allowances marginal, rather than infra-marginal (as is the case with a simple free allocation).
Economic Consequences of the Initial Allowance Allocation
A favorite topic of academic economists is that the allowance allocation method in a cap-and-trade system can affect the overall social cost of the policy if the allowances are auctioned (sold by government to compliance entities), and if the revenues are then used to reduce distortionary taxes (such as taxes on labor and investment), thereby eliminating some deadweight loss and cutting overall social cost. I discuss this a bit more below, but for now let’s recognize that the combination of two California propositions and subsequent court rulings means that the State is not permitted to use the auction proceeds to cut taxes (rather, any auction proceeds must be used to achieve the purposes of AB 32, that is, reducing GHG emissions).
So, within the set of feasible options, the initial allowance allocation will not directly affect the cost-effectiveness of actions taken by emission sources to reduce emissions. In other words, aggregate abatement costs will not be directly affected by the nature of the initial allocation.
I was careful to use the word, “directly,” because the initial allowance allocation can indirectly affect economic outcomes. In particular, the use of updating, output-based allocations can: (1) lower the costs seen by consumers, which can reduce incentives to conserve; (2) avoid reductions in economic activity within California, with associated distributional impacts; and (3) avoid potential shifts of production to less efficient, more distant producers.
Auction Revenue Use
Decisions about how auction revenues are used can have profound consequences for the potential benefits of auctioning. There are three basic options.
First, as I emphasized above, in theory, reducing distortionary taxes provides the greatest net economic benefit (by reducing the social cost of the policy). But California’s unique legal context takes this option off the table.
Second, funding programs to address other market failures that are not addressed by the price signals provided by the cap-and-trade system can be meritorious. For example, information spillovers can be addressed through financing of research and development activities, and the principal-agent problems that infect energy-efficiency adoption decisions in rental properties can be addressed — to some degree — through zoning and other local policies.
The third and final option, however, is highly problematic, if not completely without merit, and yet, ironically, there are strong incentives in place for policy makers to go this third route. This third option is to use auction revenues to fund programs to subsidize emission reductions. There is a strong incentive to do this, because of California’s legal constraint to employ any auction revenues in pursuit of the objectives of the statute, that is, reducing GHG emissions.
What’s the problem? The AB-32 cap-and-trade system will cover approximately 85% of the economy. In other words, the vast majority of sources are under the cap. As I have explained in detail in several previous essays at this blog, under the umbrella of a cap-and-trade mechanism, (successful) efforts to further reduce emissions of capped sources will have three consequences: (1) allowance prices will be supressed (take a look at the hand-wringing in Europe over allowance prices in its CO2 Emissions Trading System); (2) aggregate compliance costs will be increased (cost-effectiveness is reduced because marginal abatement costs are no longer equated among all sources); and (3) nothing is accomplished for the environment, in the sense that there are no additional CO2 emissions reductions (rather, the CO2 emissions reductions are simply relocated among sources under the cap).
Economics, Policy, and Politics
As I concluded in my previous essay, the California Air Resources Board has done an impressive job in its initial design of the rules for its GHG cap-and-trade system. Of course, there are flaws, and therefore there are areas for improvement. A major issue continues to be the mechanisms used for the initial allocation of allowances. Because of the economics and politics of this issue, it will not go away. But, going forward, it would be helpful if those debating this issue could demonstrate better understanding of the allowance allocation’s real – as opposed to fictitious – environmental and economic consequences.
