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Cap & Trade: An Outsourcing Extravaganza?
The quandary for capping and trading is straight out of Econ 101: As long as some countries restrict emissions and some don't, many firms will simply move their emissions rather than eliminate them, seriously compromising CO2 reduction targets.

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Written by Zach Arnold, Breakthrough Generation Fellow

Imagine it's 2010. The environmental lobby and its governmental allies have finally managed to implement a carbon cap-and-trade system. Under this plan, CO2 emissions are limited to those allowed by a set number of permits; companies who emit more than their allotment have to buy permits from those who don't, and as caps tighten over time, most everyone is required to lower their emissions.

Sounds good, right? An elegant scheme to be sure, and one that has borne fruit in the past - cap-and-trade policies are widely credited with America's drastic reductions in the pollutants that form acid rain. But can a rigorous American cap-and-trade system work similar wonders for CO2? I don't think so.

What Econ 101 has to say about cap-and-trade

When it comes to reducing emissions, an America-only cap-and-trade system will have little effect. To explain why, we need only resort to that most familiar of adages - "follow the money." CO2-emitting businesses will naturally "follow the money" around the world, migrating to wherever they can save the most - that is, wherever the cost of emitting is lowest.

This, of course, is not a peculiar trait of polluting businesses; the accelerating pace of economic globalization over the past few decades has been driven by this behavior. Manufacturers flit from American factories to Mexican maquiladoras to Chinese sweatshops in pursuit of cheap labor, and call-center operators transfer jobs from well-paid Americans to job-hungry (and English-speaking) Indians. You basically do the same thing when you drive an extra few blocks to a cheaper gas station, rather than pay a few extra pennies per gallon closer by.

Carbon emitters like factories, refineries, and power plants will follow the same logic. As cap-and-trade raises the price of emitting (by forcing companies to retool or to buy permits), they'll be increasingly tempted to move to countries where their emissions aren't taxed. In turn, carbon emissions may simply move, rather than disappear. Interestingly, as carbon caps become more rigorous, thus raising the price of emissions, the costs of staying stateside will increasingly outpace the hassle (financial and otherwise) of picking up shop. In this way, stronger climate policy might end up shooting itself in the foot.

 

Who pays the price?

Of course, fleeing cap-and-trade is more of a possibility in some industries than in others. It's hard to see, for example, how a CO2-spewing coal plant in Ohio can just move overseas, considering that its transmission lines and customers are stuck in Cleveland and Akron. (This helps explain why SO2 cap-and-trade was so effective - most SO2 comes from power plants, which can't move.)

Yet the alternative might not be any better for our atmosphere. For example, those electricity providers that can't skip town will face a higher cost of generation, which will then be passed on (at least partially) to their customers. Those industries and firms that purchase electricity will face the same dilemma as those who emit directly, and might just head over to China as a result - especially if this price pressure is piled on to the economic woes such firms are already facing - high labor costs, lagging demand, etc.

It's easy to see how this dynamic could create both an economic headache and a political catastrophe for American climate activists. Assume a cap-and-trade system passes in 2009. As the first few factories and server farms start moving, and the first few Southern utilities start building their new plants in Mexico rather than Texas, critics will (correctly) point the finger at environmentalists. The resulting spat could dwarf previous scuffles like the call center outsourcing crisis of a few years ago. And since the incentive to migrate is directly tied to the carbon price, it's unlikely that environmentalists and their backers, in the midst of a political firestorm, would be able to raise it incrementally (as many cap-and-trade plans entail).

 

Patching up the problem

The quandary is straight out of Econ 101: As long as some countries restrict emissions and some don't, many firms will simply move their emissions rather than eliminate them, seriously compromising CO2 reduction targets.

How to address this quandary? We might try to "patch up" our unilateral cap-and-trade system with measures aimed at preventing migration. One add-on might be a carbon import tariff, in which carbon-intensive imports are taxed for the emissions they "embody," so to speak. This would theoretically attach the price disincentive to emissions no matter where they happen (as long as the products are coming into the US, that is). But such a system would be nightmarishly complicated to administer - how do you audit the carbon content of every item you import? Moreover, a new tariff regime administered unilaterally would be seen as a flagrant violation of WTO laws and a slap in the face to our trade partners.

Another patch could be simply to throw cash at those businesses affected by carbon caps. This was the strategy of the ill-fated Lieberman-Warner bill, which provided hundreds of billions of dollars for industry "transition assistance" and the like. Indeed, recycling the proceeds of carbon taxation back to industry might well keep firms in the country - but only by offsetting the financial pain of emitting carbon, thereby eliminating the disincentive to emit and rendering the price for carbon toothless. If the money businesses pay for emitting carbon will just come back to them a bit down the road, why bother reducing emissions at all?

 

Looking forward

 
Patches like these won't solve the structural problem inherent in a single-state cap-and-trade regime. Really, there's only one good solution: a truly global carbon regime. A single, worldwide carbon price would level the international playing field, leaving no opportunity for firms to avoid the cost of carbon and spurring CO2 reductions rather than evasion.

It's perhaps with this in mind that many environmentalists have boosted cap-and-trade not so much for its actual effect on climate change as much as for its potential to enable America to broker a global carbon regime. Joe Romm exemplifies the trend: "If China won't alter its coal policy to make its environment livable today even with the Olympics coming, it will require very strong international leadership (led by an America with a moral climate policy of our own) to have any chance at making them alter it to preserve a livable climate in the future."

 But the developing world has already signaled its unwillingness to restrict emissions, no matter how hypocritically the U.S. may or may not be behaving. Besides, if we act first, then quite a few developing countries may find themselves with new industries, creating new interests against restrictions. For example: will Mexico be more or less likely to adopt cap-and-trade once they've begun to attract new factories and power plants, drawn in precisely by their lack of a carbon regime?

 In any case, with limited time on our hands, we should be wary of devoting our primary energies to the laborious implementation of an efficient carbon regime both in the U.S. and then globally. Put more simply, we may not have time to get cap-and-trade right first. What we need, fast, is a clean energy technology portfolio that's cheap worldwide - a set of technologies that make financial sense both to American utilities and Indian entrepreneurs, regardless of the policies in place in one country or another.

An American commitment to developing these cheap, clean energy sources will not only ensure America's success in cutting emissions, but will also enable developing nations to follow with their own emissions reductions as their economies expand. The marginal renewable energy sources of today - wind, solar, geothermal and the like - could well come to fulfill this role, but only if policymakers focus their attention on tech deployment and development, rather than obsessively pursuing America's emissions alone. Will cap-and-trade's proponents wake up in time?


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TrackBacks (0) 4 COMMENTS:

Zach, the problem of leakage is a concern but is not as intractable as you make it out to be. Consider Lieberman-Warner, because it actually dealt with this quite well (though it had plenty of other faults). The sectors covered are transportation, electric power, and industry. Transportation is covered by upstream allowance requirements on petroleum importers (or 'first seller' for domestic reserves I believe), so moving abroad does no good. Electric power is similarly not vulnerable because you can't ship kilowatts from China or India. Might a few power plants spring up on Canada/Mexico side of the borders? Sure, maybe, but its really minor considering the limited area they could serve compared to the vast rest of the country. So right off the bat you know this leakage issue applies to a particular corner of the economy - industry.

You mention Lieberman-Warner gave away credits to keep those plants in the US. Those credits were given away more as a bribe for political support than to achieve anything - since they're not tied to production levels a plant could seriously ramp down production (shifting new production overseas) and still keep collecting. But L-W did have quite a clever method of dealing with the risk of leakage. In short it was a carbon tariff designed to be WTO compliant.

Title VI (and Title XIII in Boxer substitute) creates an "International Reserve" of allowances. This reserve would be unlimited, but the price would be pegged to the price of a domestic allowance (by day to day closing price on the spot market). Foreign importers would have to purchase carbon allowances from this reserve just like domestic producers have to. Since its a different pot, there's no competition for limited permits driving up the price. And since it's pegged to the price of domestic permits, there's the equality of treatment between domestic and imported goods crucial for WTO compliance. They had lawyers working on this, and apparently pretty good ones.

So how do you decide how many allowances need to be submitted for which goods? The EPA has to create a list of emissions intensive (covered) goods from importing countries whose national emissions are above a de minimis threshold. It sounds like it would be a bureaucratic nightmare, but really it wouldn't. A lot of emissions are from chemical processes where amounts are known and pretty standard. A lot can be traced to the heat or electricity used in production, and in combination with the power or fuel portfolio of a country/region you can get a pretty good estimate. And they'd have until 2015 (it was 2020 in the original) before the International Reserve requirement goes into effect to put this together. Perfect or not it clearly is more than enough to eliminate the incentive to ship factories overseas, especially considering (though it wasn't specified in the bill, but could be in administrative rulemaking) an extra Carbon premium could be assessed for international shipping as well.

Remember everyone wants access to the American market, because we make a lot of money and we don't save much of it (i.e. we like to spend). So if moving abroad doesn't improve the ability to cater to the American market at lower costs, it won't happen. Would it be better to have a global system? Of course. But this inertia of US saying we want a global system and developing countries insisting the US lead first must be broken. Since there's no way China/India will be convinced to adopt hard targets without our leading (nor should they), that means the ball is in our court.

"One add-on might be a carbon import tariff, . . . But such a system would be nightmarishly complicated to administer - how do you audit the carbon content of every item you import?"

NOT so hard to administer- here is how it works. Take the # of each countries fossil fuel power plants, multiply by GHG, multiply by GHG price per ton (& tack on penalty for nukes). Each country is then required to drop that electric power GHG into a worldwide kitty which is then distributed back to the countries for ghg mitigation and sustainable power projects. Any country not putting its fair share in kitty has its power plants bombed, since bombing is what us does best, anyway, and it will stimulate us economy even more! Problem solved.

Anyhow, cap and trade, carbon import tax, sustainable investment, all go hand in hand, no need to get pissy about it.

Max -

Thanks for your thoughtful comment!

The Lieberman-Warner international reserve system is indeed clever, and does address the problem somewhat. However, I'm not as optimistic about its effectiveness as you are. First of all, establishing an EPA-authored list of imports and their respective carbon content seems like it could be a very large and complicated process indeed, especially if more and more industries migrate overseas given rising energy prices (due to a carbon cap affecting immobile electricity producers). "Emissions-intensive" is also a loaded term, one whose definition could bog the system down in disputes (even if the carbon impact of adding or dropping a product to the category is minimal).

More important, though, are the problems inherent in establishing where the "de minimis threshold" lies. Is it based on countries below a certain numerical level of emissions? (If so, per-capita or absolute?) Or on countries who have committed to certain reductions? And in either case, there are tricky procedural and moral questions involved in comparing other countries' emissions commitments to our own. For example, the Boxer addenda to Lieberman-Warner created an International Climate Change Commission, tasked with determining which countries have taken "comparable action" to the US in reducing CO2 emissions (and thus would be exempt from import tariffs). Aside from the fact that this commission could be affected as much by international and domestic political influence as by the numbers, how do we determine what "comparable action" would be for China or India? And is it right (or WTO-legal) to expect "comparable action" from them, given their largely impoverished populations? I'm not saying the answer is necessarily "no," only that the problem is complex, and could complicate or even halt the implementation process.

Finally, even if the system worked perfectly, it's important to maintain perspective - American emissions are only a piece of the whole puzzle, and although you and many others hope that "if America leads, China/India/etc. will follow," I feel that this idea, although alluring, is probably wrong. These developing nations have already made it clear that they are not likely to curb emissions (see here, for example), no matter what the US and EU are doing. So even if the US managed to cover its emissions perfectly under cap-and-trade (which, as the failure of Lieberman-Warner showed, is not close to happening), the prospect of leveraging our efforts into a global carbon regime (much less one with an adequate price level to stimulate significant innovation and emissions reductions) is a dim and distant one at best. In my opinion, we should probably focus on investment-based solutions that promise quicker and greater change.

Thanks again -Zach

Zach, I agree that it would be a bit of work, but I don't think it would be infeasible by any means. The requirement doesn't have to be perfect, it has to be a reasonable enough approximation that it doesn't undershoot and preserve the incentive to go overseas, or overshoot and be overly protectionist (and so open to WTO challenge). I'd start off by just saying that I think the main reason China/India flatly reject mandated emissions cuts is the same reason its political dynamite here - they're afraid its incompatible with economic growth. So if we were able to overcome that obstacle and achieve reductions and growth simultaneously, which I think is very achievable with a sensible cap/trade policy, I bank on that changing their willingness to come on board. Also, the international reserve requirement is a stick for their not signing onto comparable reductions (they get out of it if they do, as determined by the Climate Change Commission), but the bill also explicitly mandates negotiations to try to bring these countries on board. Presumably these negotiations would include less rigid targets, as well as 'carrots' like tech assistance. So all considering I'm fairly optimistic the world can be brought under this umbrella with strong American leadership; carrots and sticks and a demonstration that reductions do not necessarily interfere with growth.

I'll try and address some of the specific concerns you mentioned with implementing the international program.

You question a fair way of determining the "de minimis" percentage of emissions for foreign countries. The bill is pretty straightforward and I think its fair enough, though you can certainly still disagree:
A country would qualify if its "percentage of total global greenhouse gas emissions [is] not more than 0.5, as determined by the Commission” from most recent data.
--Also exempts: each foreign country identified by
the United Nations as among the least-developed developing countries, and of course, countries that have taken comparable action.
--------------
You wrote “this commission could be affected as much by international and domestic political influence as by the numbers.” And to clarify, this Climate Change Commission is the one that's making all the decisions we're talking about here. (I erred in referring to the EPA making these decisions before, although maybe that's how it was in the original bill, which I was more familiar with.)

The Commission members (nominated by the president and confirmed by the Senate) would be appointed for 12 years, and the Commission would be made up of 3 dems and 3 republicans. I get the feeling it would be more like the Fed in terms of independence than the EPA, where obviously the President can (and does with this administration) interfere politically.
------------------
You say "'Emissions-intensive' is also a loaded term" - what the Commission is supposed to consider is whether it is a "primary product" or "manufactured product," and whether a product:
"(B) generates, in the course of the manufacture of the good, a substantial quantity of
direct greenhouse gas emissions or indirect
greenhouse gas emissions [indirect = emissions from process heat or electricity used]; and
(C) is closely related to a good the cost of
production of which in the United States is affected by a requirement of this Act."

Now you can say "substantial" is a loaded word. But from most everything I've heard/read, you're really only dealing with a fairly limited set of primary products (food, pulp, paper, bulk chemicals, petroleum refining, glass, cement, steel, aluminum, iron, and industrial ceramics - combined from two lists that mostly overlapped, one from EIA analysis and one from the bill itself), and then the manufactured goods that use a lot of them as inputs (cars, turbines, etc). It still may sound like a lot, but its important to remember that there are a lot of institutions that already collect this sort of data, even if not quite so detailed to be broken down to glass vs. paper, etc. But OECD, EIA, IEA- I think you're underestimating the wealth of data that's out there. Not all the data needed for sure, but my point is just this project would not be totally from scratch.

The number of international reserve allowances required is to be calculated by multiplying:
"(A) the national greenhouse gas intensity
rate for each category of covered goods of each
covered foreign country for the compliance year,
as determined by the Administrator under paragraph (3);
(B) the allowance adjustment factor for
the industry sector of the covered foreign coun8
try that manufactured the covered goods entered into the United States, as determined by
the Administrator under paragraph (4); and
(C) the economic adjustment ratio for the
covered foreign country, as determined by the
Commission under paragraph (5)."

(A) is actually the per-unit GHG’s, found by dividing total [direct+indirect] emissions per category of goods by the units produced of that good [again, I think these numbers wouldn't be so hard to come by - number of goods produced is definitely already tracked for all the relevant goods. Emissions from the steel/glass/etc sector then would just have to be calculated, and you could do a pretty good approximation of this just by energy auditing a set of factories and multiplying by the emissions rate per fuel]
(B) Actually discounts the requirement for them to simulate how many allowances they would have gotten freely allocated if they were a US manufacturing company
(C) Is by default 1, except the commission can lower it to reflect progress on deploying clean technology, implementing regulatory programs to limit GHG’s etc.

This last part is significant, because it incentivizes foreign countries to take real action, even if they're not willing to take "comparable" action yet. Especially states like China and India, all of a sudden raising fuel standards, major investments in CCS, anything like this that they might otherwise not see economic benefit for - now if it could knock that adjustment factor from 1 to even just .95, that's tons and tons of revenue when you consider how much they export to us. So again, I think this framework is actually the best way going forward to incentivize foreign countries to get on board, to whatever extent they're willing, with a final major benefit at the end if they decide to sign onto an international treaty. I agree of course that there will certainly be heavy negotiating to determine how to target their emissions reductions - per GDP, per capita? It almost certainly won't be absolute, or if it is, it definitely will not be as stringent a target as ours. But its achievable, and-- I think at least-- this bill would help us get there.

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