An Essential Strategy
Author
Alan Biller - Consultant
Consultant
Current Issue
Issue
2
An Essential Strategy

Achieving an energy economy based entirely on renewables quickly enough to meet the Paris goal of 2ºC is a high-risk strategy. Removing carbon dioxide from emissions waste streams and burying it is necessary — as may be extraction of the gas from the atmosphere.

Alan MillerAlan Miller retired from the Climate Business Department at the International Finance Corporation in December 2013 and is now an independent consultant on climate finance and policy

An evaluation of current trends and country commitments by the United Nations Environment Program, the “Emissions Gap Report 2017” estimates that only about a third of the necessary reductions to realize the Paris Agreement’s temperature goals have been pledged. “The gap between the reductions needed and the national pledges made in Paris is alarmingly high,” the report concludes. Reductions must be achieved quickly due to the long atmospheric lifetime of carbon dioxide. Thus, “If the emissions gap is not closed by 2030, it is extremely unlikely that the goal of holding global warming to well below 2°C can still be reached.”

In response to this intimidating challenge, experts have devised many scenarios showing how the Paris goals might be achieved. While continued rapid growth in use of clean energy is central to all such analyses, it is insufficient without a concomitant, radical transition away from current technologies for burning of fossil fuels and particularly coal — which amount to about 40 percent of the world’s electricity and is a key source of energy for cement manufacturing, steel making, and other industrial processes. Yet dozens of new coal plants are currently under construction or planned around the world, and new coal mines have opened even in Germany. Enormous economic and political costs will be incurred if these plants are to be closed in the near future. So any realistic policy scenario must allow for the role of fossil fuels.

To offset this trend and ensure the Paris goals can be met, carbon removal and sequestration (or storage) will be essential. As the International Energy Agency stated in 2016, “There is no other technology solution that can significantly reduce emissions from the coal and gas power generation capacity that will remain a feature of the electricity mix for the foreseeable future.” Indeed, as you shall see we may need to go even beyond that.

A discussion of carbon dioxide removal encompasses a wide range of methods, some natural, some sophisticated, expensive technologies. A National Academy of Sciences review of the subject in 2015 provides several helpful definitions and associated acronyms: “Carbon Dioxide Removal (CDR) refers broadly to efforts to remove carbon dioxide from the atmosphere, including land management strategies . . . and direct air capture and sequestration (DACS). CDR techniques complement carbon capture and sequestration (CCS) methods that primarily focus on reducing CO2 emissions from point sources such as fossil fuel power plants.” Where combined with the use of the captured gas, systems are referred to as CCUS.

Thus, carbon removal can refer to natural, biological processes such as afforestation (planting trees) as well as engineering methods for removing carbon from flue gas or even directly from the air. However, only CCS (as defined by the NAS) attempts to reduce emissions from power plants and thus to address the problem created by the widespread use of coal at its source. While CDR and DACS may prove necessary in the long run, the near term policy focus needs to be on CCS.

Effective CCS requires effective storage as well as carbon capture; leakage into the atmosphere negates the benefits of reduced emissions and could create liability issues deterring investment. Currently, there is substantial opportunity for storage in depleted oil and gas fields. CO2 can also be used for enhanced coal bed methane, the generation of natural gas from deep, unminable coal seams. The effective reduction of CO2 emissions from such methods depends on site conditions and appropriate engineering but provides both some reduction in emissions as well as an economic incentive for the further development of carbon removal. How effective is this technology? An IEA assessment concluded that “the volume of the CO2 injected and stored can significantly outweigh the emissions from combusting the oil that is subsequently produced.” In countries like India and China with low quality coal but very little natural gas, the combination may even be marginally economical without carbon taxes or other incentives.

In the longer term, however, the quantities of carbon dioxide captured will require storage in much larger amounts. According to an IPCC review, “Captured CO2 could be deliberately injected into the ocean at great depth, where most of it would remain isolated from the atmosphere for centuries.” The first real test of such storage was put into operation in Norway more than 20 years ago, but the environmental implications of doing so on a large scale require much more study. As the IPCC review states, “CO2 effects on marine organisms will have ecosystem consequences; however, no controlled ecosystem experiments have been performed in the deep ocean. . . . It is expected that ecosystem consequences will increase with increasing CO2 concentration, but no environmental thresholds have been identified. It is also presently unclear, how species and ecosystems would adapt to sustained, elevated CO2 levels.”

There are several flavors of carbon capture and storage. The three most advanced and demonstrated technologies for power plants are post-combustion CO2 capture, currently used at NRG Energy’s Petra Nova plant in Texas; oxy-combustion, demonstrated at some large pilot plants; and pre-combustion CO2 capture in combination with coal gasification. The third category has received the bulk of support to date, with mixed results as discussed below.

Despite it’s potential for reducing the largest source of carbon dioxide emissions, CCS of any stripe has to date received limited support from Washington or other national capitals. Only 17 projects are in operation worldwide (nine in the United States) with four more under construction. Most of these are linked to industrial facilities with separation of the CO2 part of their process. The current global CO2-capture capacity is only about one tenth of one percent of emissions. Rather than growing, the pipeline of new CCS projects has been shrinking, from 77 in 2010 to around 38 today, and as of a November 2016, IEA report no projects have progressed to construction since 2014.

T he lack of enthusiasm for CCS despite growing evidence of the need is due to several factors. The coal industry has generally preferred to question climate science and the need to do anything. In the absence of carbon taxes or other climate policies, commercial interest in emissions capture has been largely limited to enhanced oil and gas production, in which CO2 is injected into rock formations to force out the fossil fuel. While coal-burning utilities are arguably second only to coal-mining companies in the need for technologies that could allow continued use of coal in energy production, they have had limited incentive to finance the costs of research and demonstration.

A few utilities have shown interest in the potential for combining CO2 capture with coal gasification, the third category above. The Kemper Project in Mississippi, undertaken by one of the country’s largest utilities, the Southern Company, was planned as a commercial-scale demonstration of the technology based on a very small pilot project. Construction was initiated in 2010, and after expenditures of over $7 billion (including a $133 million federal tax credit) the CCS features were abandoned, leaving only the possibility of operating as a natural gas plant. The project was effectively canceled last June by order of the state Public Service Commission, with assignment of financial responsibility still to be resolved.

Some environmentalists were quick to argue that Kemper’s failure illustrates why CCS “is a waste of our tax dollars and a false solution to the climate crisis,” as one put it. However, others pointed to mismanagement unrelated to the technology. This included equipment never tested at commercial scale; inadequate time spent on engineering; a rush to completion to avoid loss of tax credits; and the failure to learn from another gasification facility operating in Indiana. “The Kemper Project failure is not due to any problem with the equipment required to capture CO2,” argue NRDC lawyer David Hawkins and scientist George Peridas. “All of the problems are due to the system components upstream of the capture stage. . . . . The conclusion is not that CCS is a flop.”

Indeed, the case for CCS rests on a combination of arguments from different vantage points. The “Emissions Gap Report” points to the availability of clean energy and land use strategies for emissions reductions but also recognizes the reality that coal use is not going away soon. A headline in the New York Times last July makes the point: “As Beijing Joins Climate Fight, Chinese Companies Build Coal Plants.” Even in relatively green Germany, political and economic realities dictated the opening of new coal mines, partly to compensate for the closing of nuclear power plants. Consequently, the UNEP report acknowledges the potential need for carbon capture technologies of any and all flavors despite their limited development to date.

As the Kemper Project illustrates, much of the current image of CCS is associated with capital-intensive systems with large land requirements and long time requirements for construction. There has also been recent media focus on what might be termed “moon shot” ideas for removing CO2 directly from the atmosphere. A company owned in part by Bill Gates and based in Canada, Carbon Engineering, is attempting to commercialize a process for this feat, described as falling “somewhere between toxic-waste cleanup and alchemy” by the New Yorker writer Elizabeth Kolbert.

Much more attention needs to be given to the existence of the many other promising approaches for CCS, some in development for more than a decade by relatively small companies and entrepreneurs. These innovators are working on ways to capture and store carbon with the potential for low costs, a small footprint, and often additional economic and environmental benefits.

One example is Jupiter Oxygen, a company with more than a decade of experience with carbon capture and a process with multiple environmental benefits. The firm uses oxy-combustion (injecting oxygen in the combustion process to achieve high flame temperatures) in a process that allows very effective removal of CO2 and nitrogen as well as improving energy efficiency and incineration of most conventional pollutants. The company had technical support from the DOE National Energy Technology Laboratory a decade ago, has substantial operating experience, and is currently pursuing partnerships in China and India based on CCUS — enhanced coalbed methane and industrial applications of CO2.

Blue Planet, a company based on pioneering materials science by Stanford doctor and scientist Bret Costanza, uses water-based methods to capture CO2 from flue gas and makes cementitious building materials. The company has attracted impressive support, with an advisory board that includes former FDA Commissioner Donald Kennedy, former National Renewable Energy Lab Director Denis Hayes, and actor Leonardo di Caprio.

The Carbon X-Prize, a competition with a $20 million award for “breakthrough technologies that convert the most carbon dioxide emissions from natural gas and power plant facilities into products with the highest net value,” announced 27 semi-finalists in 2016. One of the most intriguing was originally conceived in a high school chemistry lab by a teenager. The young inventor is now working with a Yale professor and has secured funding to build a pilot plant that will use waste gas from a power plant or chemical factory and capture one metric ton of carbon emissions per day.

Given the magnitude of the effort required and the complexity of the technical challenges, continued support for these and other innovative smaller companies with CCS concepts should be a priority. As a recent “Economist Briefing” observed, “Progress will be needed on many fronts. All the more reason to test lots of technologies. For the time being even researchers with a horse in the race are unwilling to bet on a winner.”

Yet even as current research shows that climate change may be increasingly dangerous and unavoidable, support for CCS remains slow to develop. Perhaps the greatest source of resistance is the belief that alternative approaches are better — and achievable. The proposition that renewable energy can be the solution to climate change has been aggressively advocated and is credible as a mathematical proposition. The rapid rate of advancement in solar, wind, and battery and other energy storage technologies has indeed been, and continues to be, impressive. A recent end of year review by Bloomberg New Energy Finance cites plummeting emissions auction prices, the entry of significant new markets, and record corporate renewable power purchase agreements. On the other hand, the same source points to negative policy developments in several markets including the United States and South Africa — e.g., the recent decision by President Trump to increase tariffs on solar imports — as well as the risk of rising interest rates for renewable technologies with high capital costs.

Assuming the political support could be found for an all-out clean energy strategy and implemented in every large energy-consuming country, there are significant technical issues to be resolved before this could be done consistent with the existing electricity grid. Power from wind and solar energy are variable and not dispatchable consistent with the management and operation of centralized power grids. Reliance on natural gas plants as a backup is not consistent with the aggressive decarbonization required to stay below 2°C. Unless some other alternatives emerge, as clean energy advocate Dave Roberts has noted, CCS will be essential; without it “other dispatchable resources [would] have to dramatically scale up to compensate — we’d need a lot of new transmission, a lot of new storage, a lot of demand management, and a lot of new hydro, biogas, geothermal, and whatever else we can think of.” Thus, while it is theoretically possible the Paris goals can be met based almost entirely on clean energy, the majority of analyses advocate a combination including clean energy and CCS.

Many environmentalists advocate for carbon sequestration through natural means, primarily by planting trees. The CO2 uptake of existing forests is substantial — in the United States offsetting fossil fuel emissions by about 15 percent. Studies suggest about a third of current carbon emissions could be captured this way, potentially even more if conflicts with food production could be managed, with further reductions through environmentally beneficial measures to increase CO2 absorption and retention in soils. Using trees as fuel for power plants could even generate “negative emissions” if combined with CCS technologies — an approach the last IPCC report stated will be “critical in the context of the timing of emissions reductions,” and also dependent on effective technologies for CCS.

Unfortunately, the trend in forestry has been toward more deforestation and forest degradation, collectively estimated to account for 8 to 15 percent of the rise in global CO2 concentrations. While desirable for many environmental and social reasons, reversing this trend has so far proven to be a major challenge. And climate change may make this still more difficult, as reflected in the recent California wildfires, forest dieback due to pests in Colorado, and expectations of more severe drought in some currently forested regions. A recent article in Nature notes that efforts to raise biomass stocks have only been verifiable in temperate forests, where their potential is limited, whereas large uncertainties hinder verification in the tropical forest, where the largest potential is located. California is working on a Forest Carbon Plan, expected to be finalized this year, which could serve as a model.

Given the magnitude of the climate challenge, there is an increasing consensus that all options for mitigating emissions need to be deployed as soon as possible. For some, the situation is so bad that it is now necessary to consider options much more worrisome from an environmental perspective — climate intervention (also called geoengineering). This includes measures such as injection of sulfates in the atmosphere to reflect sunlight and cool the earth’s surface. An initial review by a committee of the National Academy of Sciences concluded in 2016 that such measures merit further research given they could be implemented at a relatively low cost despite “an array of environmental, social, legal, economic, ethical, and political risks.”

Given the seriousness of climate risks and the absence of any single fully effective solution, increasing support for CCS thus seems fully justified and increasingly urgent. In the United States, CCS may also have one additional benefit going for it: a surprising measure of bipartisan political support. Proposals for CCS have attracted backing from both coal state Republicans and liberal Democrats. The Western Governors Association, under the leadership of Wyoming’s Republican governor, Matt Mead, and Montana’s Democratic governor, Steve Bullock, convened a working group composed of 14 states to advocate policies that encourage CCS technologies. A broader coalition with similar interests, the National Enhanced Oil Recovery Initiative, includes fossil fuel companies, labor unions, and national environmental organizations.

Reflecting this diverse political support, last July a bipartisan group of 25 senators introduced the Future Act (for Furthering carbon capture, Utilization, Technology, Underground storage, and Reduced Emissions) to extend and expand a federal tax credit, known as Section 45Q, which incentivizes capturing carbon dioxide from power and industrial sources for enhanced oil recovery and other uses. Another bill with bipartisan support, the Carbon Capture Improvement Act, would authorize states to use tax-exempt private activity bonds to help finance carbon capture equipment. Allowance for such bonds was retained in the recent changes in tax law, a change originally contemplated in the version first passed by the House.

The two bills would be a substantial step toward encouraging increased interest and investment in CCS projects, although limited in key respects. First, insofar as the captured carbon is to be used primarily for enhanced oil recovery or enhanced methane production, fossil fuels are still being burned. Another concern is that the bill would provide limited support for innovative ideas from high-risk companies. Such early stage research support should be a federal responsibility and would seem to be consistent with administration support for coal. At a recent IEA summit, DOE Secretary Rick Perry stated, “While we come from different corners of the world, we can all agree that innovation, research, and development for [carbon capture and underground storage] technologies can help us achieve our common economic and environmental goals.” However, the administration has so far given little indication of formal support for CCS and even proposed significant cuts to the fossil fuel program.

Expanded tax credits for CCS for enhanced oil recovery in the United States also do not promote carbon capture where it is most needed, in China, India, and other rapidly growing developing nations with coal-dependent energy systems. China alone currently produces about four times as much coal as does the United States, and because of their populations and coal reserves the IEA projects that China and India will account for the lion’s share of global growth in coal consumption in coming decades. Whereas in the United States most CCS would be retrofits to existing coal plants, in China and India there will be opportunities for integrating systems with new plants and industrial facilities — particularly if combined with desperately needed control strategies for conventional pollutants like smog precursors, acid rain, and particulates.

There is an established international initiative with the relevant focus, the Carbon Sequestration Leadership Forum, founded in 2003, which now includes ministerial-level participation from 25 countries. There was also some hope for support with the establishment of Mission Innovation, a global initiative announced during the Paris COP21 climate negotiations to encourage clean energy innovation. Seven of the initial 20 sponsors included reference to CCS when the initiative was announced, but U.S. support is now uncertain. A more ambitious, coordinated, and well financed international effort to include all the world’s largest coal producers and consumers is needed. There are multiple institutions and international initiatives for clean energy, including the International Renewable Energy Agency, the Clean Energy Ministerial, and the Climate Technology Centers organized under the UN climate convention. Given the importance of financing, there also needs to be more of a role for the World Bank and other international financial institutions in a position to provide risk capital as well as technical assistance.

Bipartisan political support may be growing in the United States, but it still faces numerous challenges. In recent congressional testimony, a spokesman for the governor of Wyoming focused on the time required to do environmental reviews and permitting of pipelines as equal if not greater obstacles. Broader leadership for long-term CCS development in the United States also remains an issue, as the future of the DOE fossil energy program is in question and the states with the most progressive climate policies have not made it a priority.

Carbon capture and sequestration remains a necessary if less than ideal solution to the challenge of climate change. As time passes and other solutions appear to be inadequate, a growing body of analysis points to CCS as among the only remaining sources of hope for avoiding catastrophic climate change. As the IEA concluded in its 2016 report, “CCS is the potential ‘sleeping giant’ that needs to be awakened to respond to the increased ambition of the Paris Agreement.” TEF

LEAD FEATURE ❧ Achieving an energy economy based entirely on renewables quickly enough to meet the Paris goal of 2ºC is a high-risk strategy. Removing carbon dioxide from waste streams and burying it is necessary — as may be extraction of the gas from the atmosphere.

World’s Largest Carbon Market Is Scheduled for 2020 Launch in China
Author
Robert N. Stavins - Harvard Kennedy School
Harvard Kennedy School
Current Issue
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2
Robert N. Stavins

China is developing a nationwide carbon-trading scheme which, when launched, will be the world’s largest — twice the size of the EU’s Emissions Trading System and nearly nine times the size of California’s. The new system will help China meet its emissions and renewable energy targets that are part of its Nationally Determined Contribution pledge under the Paris Agreement.

The December announcement from Beijing was greeted in the United States with excited praise from climate activists and skepticism from conservatives. The most reasonable assessment lies between those two extremes.

China’s system will begin with the electric power sector only, but eventually will also include building materials, iron and steel manufacturing, non-ferrous metal processing, petroleum refining, chemicals, pulp and paper, and aviation. Importantly, the system will not be a cap-and-trade system per se (unlike the CO2 trading systems in Europe and California), because there will not be an administratively set mass-based cap of some quantity of emissions. Rather, the trading system will be rate-based, meaning that it will be in terms of emissions per unit of electricity output.

This is also called a tradable performance standard. The government sets a performance benchmark of emissions rate per unit of output, sources receive permits (or allowances) based on their electricity output and their benchmark, and sources are allowed to trade. By regulating the rate rather than the mass of emissions, the standard may help mitigate political concern about constraining economic growth, but it does so by rewarding higher levels of emissions through subsidies. Hence, this approach is inefficient compared with a mass-based cap-and-trade system.

The problems are exacerbated with China’s system because the performance standards are set not only by sector, but by sub-categories of electricity production within the sector. As some categories are, in effect, subsidized by other categories, the cost-effectiveness of the overall system declines. There is a lack of incentive for the carbon market to move energy consumption from coal to natural gas, for example, because of the multi-benchmark approach.

Finally, it appears that allowances will be allocated without charge, at least in the early stages of the program. This has been typical of emissions trading systems in other parts of the world, and may lessen political resistance, but it also will sacrifice potential efficiency gains associated with auctioning allowances and recycling revenues by cutting distortionary taxes.

Despite these limitations, the announcement marks a significant step along the long road of climate change policy developments. The new system will eventually be very important, because of its magnitude and because of the importance of China in global CO2 emissions and climate change policy.

More broadly, the announcement and the eventual launch of the system will have significant effects on other governments around the world — regional, national, and subnational. Some will be encouraged to launch or maintain their own carbon trading systems, and to increase the ambition of their systems.

A frequently stated fear of adopting climate policies, including carbon pricing, is the competitiveness effects of those policies, due to emission, economic, and employment leakage. Since the greatest fear in this realm is that domestic factories will relocate to China, that concern will be greatly reduced — or at least it should be — when and if China has put in place a serious climate policy, whether through carbon markets or otherwise.

So, the best assessment of this new policy lies somewhere between the extremes. The December announcement by Beijing was neither as exciting as some of the applause from climate activists might suggest, nor was the announcement as meaningless as conservatives have claimed.

Rather, cautious optimism seems to be in order. China is serious about climate change, and is thinking long-term. The country appears to be methodically working to develop a meaningful carbon-trading scheme. What is important now is developing a robust system that can be effective, expanded in scope, and gradually made more stringent.

Development of the system has begun, with the real launch of trading likely to take place in 2020, which is a key year for Chinese climate policy for other reasons, as well. In that year, China will release its next Five-Year Plan, and it will submit its updated Nationally Determined Contribution to the United Nations under the Paris Agreement.

World’s largest carbon market is scheduled for 2020 launch in China.

States Step Up Regional Climate Change Gas Mitigation Markets
Author
Linda K. Breggin - Environmental Law Institute
Environmental Law Institute
Current Issue
Issue
2

Despite an abdication of responsibility at the federal level, many states have ramped up efforts to mitigate climate change, including through collaborative initiatives such as the Regional Greenhouse Gas Initiative. RGGI, a bipartisan coalition of nine northeastern and mid-Atlantic states that participate in a voluntary cap and trade regulatory system for power sector CO2 emissions, recently lowered its regional cap by an additional 30 percent between 2020 and 2030. The new cap will be implemented through regulations, based on a RGGI model rule, in each of the participating states — Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont.

Climate change mitigation leadership is nothing new for RGGI, which estimates that since its start in 2005 the participating states have reduced power sector CO2 emissions by 45 percent. RGGI emphasizes that the nine-state region’s per capita gross domestic product grew during that period.

The regulatory scheme provides for the participating states to set an emissions budget and issue allowances consistent with the cap. Allowances, the majority of which are bought at quarterly auctions, allow regulated power plants to emit one short ton of CO2. To comply with the cap, power plants also can buy allowances from other emitters and participate in offset projects.

The auction proceeds are used by states for energy and consumer programs. For example, RGGI estimates that the 2015 proceeds that were invested in energy efficiency, clean and renewable energy, greenhouse gas abatement, and direct assistance for consumer bills yielded $2.3 billion in energy bill savings and avoided 9 million megawatt-hours of electricity use, 28 trillion BTUs of fossil fuel use, and 5.3 million short tons of CO2 emissions.

On the West Coast, the California legislature last year extended the state’s cap-and-trade program to 2030. The program, which is linked with systems in Canadian provinces, sets an ambitious goal of reducing greenhouse gas emissions to 40 percent below 1990 levels by 2030. In addition, the Oregon legislature is considering a trading program that would be linked with the California and Canadian systems.

Although trading systems are welcome during this period of federal inaction, only 20 states currently are pursuing climate mitigation policies that set quantified reduction targets, according to the Rocky Mountain Institute. And, those 20 states represent only 36 percent of U.S. carbon emissions. Similarly, the Congressional Research Service estimates that the RGGI states account for only 7 percent of national CO2 emissions from energy consumption.

Consequently, broadening current programs such as RGGI to include more stringent caps, additional states and regions, and other energy sectors, may be critical to the country’s success in reducing greenhouse gas emissions. Conservation Law Foundation President Bradley Campbell, who helped start RGGI in 2005 when he was New Jersey Department of Environmental Protection commissioner, is optimistic. He notes that RGGI “creates an infrastructure to demonstrate that we can decarbonize our energy system and save money for consumers — all with positive impacts on the economy.”

Furthermore, CLF and other non-governmental organizations support extending the model to other sectors. Campbell views transportation as the “most urgent sector for attention” and predicts that it will take two or three years to develop a sound model and conduct the necessary implementation work. He contends that “a powerful force” moving the process forward will be not only the need to reduce greenhouse emissions but to revamp the current transportation infrastructure finance system. Campbell explains that the current system, which relies on the gas tax, “Will fail as vehicles become more fuel efficient and electrification takes root.”

Membership in RGGI also is expanding. Virginia is poised to join and would be the first southern state to participate. In addition, New Jersey’s newly elected governor pledged during his campaign to rejoin RGGI. And, as a candidate, Pennsylvania’s governor stated his intent to join RGGI but reportedly has faced resistance from his legislature.

Nevertheless, Campbell recognizes that “first and foremost” the challenge is to “come up with a pathway” that can bring in states that are coal dependent or otherwise not interested in emissions reductions. He contends that economics may be the ultimate driver, noting that states that have been “hardliners against emissions reductions are now finding that their job base in fossil fuels is being dwarfed by their job base in renewables and energy innovation.”

Regardless of the motivation, it is critical at this juncture for states to step up efforts to address climate change, including expansion of existing trading systems.

It is critical for states to address climate change, including expansion of existing trading systems.

States step up regional climate change gas mitigation markets.

As Regulators Retreat, Is Corporate Sustainability Up to the Challenge?
Author
David P. Clark
Current Issue
Issue
2
David P. Clark

Under the Trump administration, the era of robust federal environmental programs may be over. EPA is pursuing an aggressively deregulatory agenda that may have spurred more than 700 agency officials to leave. Regulatory retreat is also the watchword at the Energy Department and throughout the executive branch.

With federal shrinkage, voluntary progress toward high environmental standards becomes more important than ever. For years, corporations and other entities have touted their sustainability pledges. But will they live up to their commitments in the absence of a federal prod? What difference will voluntary actions make?

Because humanity needs an all-hands-on-deck response to combat climate change, biodiversity loss, and other urgent environmental challenges, says John Dernbach, a Widener University environmental law professor and sustainability authority, if the federal hand isn’t visible, then state, local, and private forces become more important.

Reasons to be hopeful are numerous. In 2017, with leadership from the America’s Pledge movement, 2,300 governors, mayors, businesses, investors, and other organizations from across the United States responded to Trump’s withdrawing from the Paris climate agreement by signing a “we are still in” statement supporting the accord. At the same time, the Center for Climate and Energy Solutions (C2ES) worked with 25 global companies to take out full-page newspaper ads urging the administration not to withdraw. Sustainable Brands, which describes itself as a community of forward-thinking business professionals, claims a membership of 348,000 sustainability business leaders who are active on climate, recycling, and other issues.

Regarding corporate sustainability, Dernbach offers a historical perspective on business leadership today compared with 1997, the five-year anniversary of the Rio Earth Summit. In 1997 only a handful of corporate and municipal leaders could be found, and such standards as forestry certification, LEED for green buildings, the Global Reporting Initiative, and many others did not exist. But now they abound, Dernbach notes, and many large companies won’t locate in places where they cannot source materials and energy sustainably. Some business interests are still fighting back, but battles are occurring on a front that today is vastly expanded compared with 1997.

“The momentum is really there” for companies to go beyond compliance, says Janet Peace, the senior vice president for policy and business strategy at C2ES. For both economic performance and reputation reasons, large businesses now see sustainability as essential. But the bigger concern is that without a policy framework post-2020, there is a lot of uncertainty, and “companies don’t like uncertainty,” Peace adds.

Committed cities and major corporate energy users — such as Amazon, Walmart, and Google — can make significant progress in reducing greenhouse gas emissions, but it is difficult to completely fill the gap without strong federal leadership, Dernbach says. In his view, Trump’s climate policies aren’t fact-based and will ultimately have limited impact, whereas companies think internationally and are driven by facts pertaining to cost reduction, consumer demand, resource availability, and other issues that are driving them toward sustainability without regulatory drivers.

Corporate performance data will be critical. In 2016, the Securities and Exchange Commission issued a “concept release” seeking public comment on corporate disclosure requirements. In response, labor and citizens groups urged the SEC to require greater corporate disclosure on environmental, social, and governance issues. But in 2017 the Business Roundtable told the White House that a top regulatory concern was to have tighter SEC rules limiting the power of activist shareholders with small stakes in public companies from pursuing social agendas through shareholder proposals.

Concerns about shareholder activism have existed for decades, Peace notes. But, despite efforts to limit that activity, participation in the Carbon Disclosure Project has risen annually, with more than 6,000 companies now on board. Additionally, 237 companies with a combined $6.3 trillion market capitalization publicly committed to supporting the Task Force on Climate-related Financial Disclosures, which last June published recommendations on governance, strategy, risk management, and metrics and targets. The task force information will be useful to disclosers, advisers, and third parties, Peace says, adding that some 200 sustainability disclosure frameworks exist. Standards, such as ISO 14001 for environmental management systems, are helping companies achieve leadership roles, Peace adds.

Many corporate, state, and local hands are on deck, but with global middle class consumers doubling by 2030, will the coming storms be overwhelming?

As regulators retreat, is corporate sustainability up to the challenge?

The Drivers of Corporate Climate Mitigation
Author
Michael P. Vandenbergh - Vanderbilt University
Vanderbilt University
Current Issue
Issue
1
Parent Article

The private sector can generate a billion tons per year in greenhouse gas emissions reductions over the next decade, with corporations contributing half. This is not overly optimistic. If we start with the assumption that firms seek to maximize profit, then motivations to reduce carbon emissions arise from at least seven sources, supplemented by the moral norms of corporate managers.

The first is the cost savings that exist because of the gap between the energy efficiency steps that businesses could take with a positive return on investment and the steps they actually take. Economists and engineers differ about the size of the gap, but credible reports suggest that inefficiencies alone could account for half a billion tons of reductions. Inefficiencies exist because of market failures (split incentives, insufficient information, outdated pricing customs, etc.) and behavioral failures (steep discount rates, ingrained habits, contrary social norms, etc). Private-sector initiatives that target these market and behavioral failures have had great success.

The second source of motivation is reputation. Most of the book value of many of the largest firms in the world, including major high-tech firms, is corporate or brand reputation. Companies will do back flips to build and protect their reputation, and many recognize that most of their retail and corporate customers support climate mitigation. In fact, the public believes that corporations have the greatest responsibility to address climate change among society’s various actors. The political system can marginalize these concerns via gerrymandering, lobbying, and other strategies, but market pressure remains.

The third arises from supply chain pressure. A study of the 10 largest firms in each of eight sectors demonstrated that more than half impose environmental requirements on their suppliers. These include pressure to reduce carbon emissions. A company like Walmart, which has more than 10,000 suppliers in China alone, can have an enormous impact on global carbon emissions, and it just announced with several major NGOs that it would achieve a billion tons of emissions reductions from its supply chain by 2030.

The fourth and fifth arise from investors and lenders. Divestiture and socially responsible investment initiatives have received a great deal of attention and have applied pressure for emissions reductions. In addition, investors with more than $100 trillion in funds participate in the CDP (formerly the Carbon Disclosure Project). Similarly, lenders have acted individually and in groups to increase the pressure on fossil fuel investments and companies with large carbon footprints.

The sixth arises from the importance of employee morale and recruiting. Most of the population, including a disproportionate share of potential new employees in the highest skill areas, are concerned about climate change. Companies that cannot recruit and retain these employees are at a competitive disadvantage.

The seventh is the anticipation of government regulation. Although the federal government may not regulate carbon emissions for another four to eight years, utilities and other corporations often make strategic decisions and capital investments with a longer time horizon. Despite recent pullbacks by the Trump administration, government regulation of carbon emissions is still a substantial risk over the long haul, and many companies have incentives to reduce emissions in the interim to be well positioned when that happens.

Finally, even though self-interest can explain most of the opportunity for corporate emissions reductions, limited empirical evidence and everyday experience suggest that the values or norms of corporate managers and directors matter too. No smart manager is going to announce that he or she is sacrificing corporate profits to achieve personal norms, but the shift toward sustainability by many of the largest companies in the world has often begun with a transformational moment by top managers that arose when the importance of doing the right thing became clear, and the other seven motivations made the ability to do the right thing affordable, if not profitable. It may never be possible to establish the extent to which managers satisfice on profits to address climate problems, but this motivation should not be underestimated.

These reasons support the notion that corporations have self-interested and other motivations to reduce carbon emissions in the near term, but it is also important not to lose sight of a fundamental question: As compared to what other viable approach? No one solution will provide a silver bullet, and if we compare any one strategy to a perfect but unattainable government alternative we will miss the chance to buy time until the evidence of climate change becomes so undeniable that even our flawed political system will be forced to respond.

 

Michael P. Vandenbergh is David Daniels Allen Distinguished Professor of Law at Vanderbilt University.

Benefits and Difficulties of Policy Linkage Under the Paris Agreement
Author
Robert N. Stavins - Harvard Kennedy School
Harvard Kennedy School
Current Issue
Issue
1
Robert N. Stavins

The Paris Agreement achieved broad participation by countries — accounting for 97 percent of global greenhouse gas emissions. That stands in stark contrast with the 14 percent associated with the Kyoto Protocol. That is an important accomplishment, but a critical question is how to create incentives for countries to increase their ambition over time.

The ability to link different climate policies such that emission reductions undertaken in one jurisdiction can be counted toward the mitigation commitments of another jurisdiction may help parties to the agreement increase ambition over time. In new research, Michael Mehling of MIT, Gilbert Metcalf of Tufts University, and I explore options and challenges for facilitating such linkages in light of the heterogeneity that is likely to characterize regional, national, and subnational efforts to address climate change under the agreement.

Linkage is important, in part, because it can reduce the costs of achieving a given emissions-reduction objective. Lower costs, in turn, may make it politically feasible to embrace more ambitious objectives. In a world where the marginal cost of abatement — that is, the cost to reduce an additional ton of emissions — varies widely, linkage improves overall cost-effectiveness by allowing jurisdictions with relatively higher abatement costs to instead finance reductions from jurisdictions with relatively lower costs.

In effect, linkage drives participating jurisdictions toward a common cost of carbon, equalizing the marginal cost of abatement and producing a more cost-effective set of abatement activities. These benefits are potentially significant: The World Bank has estimated that international linkage could reduce the cost of achieving the emissions reductions specified in the initial set of Nationally Determined Contributions submitted under the Paris Agreement — 32 percent by 2030 and 54 percent by 2050.

Article 6 provides a foundation for linkage by recognizing that parties to the agreement may “choose to pursue voluntary cooperation in the implementation of their” NDCs through “the use of internationally transferred mitigation outcomes,” or ITMOs.

Linkage is relatively straightforward when the policies involved are similar. However, linkage is possible even when this is not the case: for example, when one jurisdiction is using a cap-and-trade system to reduce emissions while another jurisdiction is relying on carbon taxes.

There are several potential sources of heterogeneity. One is the type of policy instrument used (for example, taxes versus cap-and-trade versus a performance or technology standard). Another is the level of government jurisdiction involved (for example, regional, national, or subnational). There is also the jurisdiction’s status under the agreement (that is, whether or not it is a party, or within a party). The nature of the policy target is also important (for example, absolute mass-based emissions versus emissions intensity versus change relative to business-as-usual). Finally, there are the operational details of the country’s NDC (including type of mitigation target, choice of target and reference years, and sectors and GHGs covered).

Most forms of heterogeneity do not present insurmountable obstacles to linkage, but robust accounting methods will be needed to prevent double-counting of reductions, to ensure that the timing (vintage) of claimed reductions and of respective ITMO transfers are correctly accounted for, and to ensure that participating countries make appropriate adjustments for emissions or reductions covered by their NDCs when using ITMOs.

Broader questions that bear on the opportunities for linkage under Article 6 include the nature of NDC targets and whether these are to be treated as strict numerical targets that need to be precisely achieved; the nature and scope of ITMOs, which have yet to be defined, let alone fully described, under the agreement; and finally, whether transfers to or from non-parties (or subnational jurisdictions within nonparties) are possible, and if so, how they should be accounted for. Parties have differing views, however, on whether the guidance on Article 6 should extend to such issues.

Clear guidance for accounting of emissions transfers under Article 6 can contribute to greater predictability for parties engaged in voluntary cooperation, thereby facilitating expanded use of linkage. But too much guidance, particularly if it includes restrictive requirements, might impede linkage and dampen incentives for cooperation. So, parties should exercise caution when developing guidance that goes beyond key accounting issues. Concerns about ambition and environmental integrity need not be neglected, but the combination of common accounting rules and an absence of restrictive conditions can accelerate linkage and allow for broader and deeper policy cooperation.

Benefits and difficulties of policy linkage under the Paris Agreement.

Reports: Cities Need to Plan Now for Flooding From Sea-Level Rise
Author
Linda K. Breggin - Environmental Law Institute
Environmental Law Institute
Current Issue
Issue
1
Linda K. Breggin

In the aftermath of perhaps the worst flood in U.S. history, there has been ample debate about whether climate change caused or intensified Hurricane Harvey, which inundated Houston last summer. What appears certain, however, is that flooding of American cities will be increasingly commonplace, due to gradual sea-level rise caused by climate change.

A month before Hurricane Harvey hit Texas, the Union of Concerned Scientists published “When Rising Seas Hit Home,” which examines the timeline for and number of communities that are likely to be “chronically inundated” due to sealevel rise. Chronic inundation occurs when 10 percent or more of a community’s land (excluding wetlands and land protected by federal levees) is flooded at least 26 times per year. In these towns, gradual sea-level rise takes a serious toll that eventually “makes normal routines impossible,” according to the report. For example, homes may be flooded, commutes to work hindered, and properties devalued.

The report examines three scenarios — low, intermediate and high sea-level rise. The scenarios are dependent in part on the degree of global emission reductions, but the report nevertheless recognizes that “for many hundreds of communities increased flooding is inevitable and adaptation is now essential.”

Under the “moderate” sea-level rise scenario, UCS predicts that by 2035, about 170 communities will experience chronic inundation — double the number today. Most of these are in Louisiana and Maryland, where land subsidence is increasing the rate of rise. Within 45 years, more than 270 coastal communities could be chronically inundated, including many that to date rarely, if ever, are subject to flooding. By the close of the century, close to 490 communities — and 40 percent of all East and Gulf Coast oceanfront communities — are predicted to be chronically inundated.

The numbers are even more jarring under the “high” scenario. The report estimates that by the close of the century the number of chronically inundated communities could jump to 670 and the percent of East and Gulf oceanfront communities to 60 percent. In addition, a growing number of West Coast communities and more than 50 heavily populated areas, such as Oakland, Miami, and four of New York’s five boroughs, could face chronic inundation.

Another recent study by Buchanan and others published in Environmental Research Letters similarly found that flood frequency will “amplify” as a result of sea-level rise and is anticipated to be “one of the most economically damaging impacts of climate change for many coastal locations.” The researchers predict by 2050 “a median 40-fold increase . . . in the expected annual number of local 100-year floods at tide-gauge locations” along the American coast. The study notes that some locations will have a higher frequency of “historically precedented” floods, while others may have increases in lower frequency, “historically unprecedented” types of floods.

Both studies emphasize the critical importance of planning for increased flooding. Buchanan explains that coastal communities can plan for resiliency if they understand how flood levels will change. The UCS report authors put the options for coastal cities and towns in stark terms: defend, accommodate, or retreat.

Specifically, UCS asserts that coastal communities “from Maine to Washington State will be forced to make difficult choices about whether and how much to invest in flooded areas versus when to retreat from them.” For example, efforts to “defend” include measures to reduce erosion and storm surge, such as building gray and green infrastructure projects (e.g., sea walls and wetlands), whereas “accommodation” entails managing flood waters through measures such as elevated infrastructure and using large-scale pumps. In particular, cities should plan now for infrastructure projects that can take years to plan and construct, let alone finance.

Sea-level rise also will have notable effects on non-coastal communities, as populations retreat from the coasts and relocate. A recent study by Hauer, et al., in Nature Climate Change estimates that 13.1 million Americans eventually will relocate due to sea-level rise and that Atlanta, Houston, and Phoenix are top destinations. These and other cities, particularly those already challenged by population growth, will need to plan for the migration. And it is ironic, of course, that Houston, which last year experienced the worst flood in American history, is one of those primary destinations.

Simply put, now is the time for coastal and interior cities to prepare for the inevitable floods of water and affected populations that will result from rising sea levels.

Reports: cities need to plan now for flooding from sea-level rise.

Protecting the Poor
Author
Chad Stone - Center on Budget and Policy Priorities
Center on Budget and Policy Priorities
Current Issue
Issue
6
Protecting the Poor

COVER STORY ❧ Reducing greenhouse emissions by making it more expensive to burn fossil fuels and letting prices determine how businesses and households reduce their emissions is a cost-effective policy — provided mechanisms are put in place to offset added costs to those in poverty.