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Cap-and-trade: a sufficient or necessarycondition for emission reduction?

Michael Hanemann*

Abstract Influenced by the success of emission trading in the US for sulphur dioxide (SO2), some

economists have argued for an upstream, economy-wide cap-and-trade scheme as the primary tool forachieving the required reduction in greenhouse gas (GHG) emissions. This paper addresses that argument

and concludes that cap-and-trade will need to be accompanied by complementary regulatory measures. While

it is a necessary component in a climate mitigation programme, it is unlikely to be sufficient by itself to

accomplish the desired emission reductions. The paper reviews the evidence on how SO2 emissions were

reduced and the extent to which actual emission trading was responsible for the reduction as opposed to

other innovations. It also identifies differences between the past regulation of SO2 and other air pollutants

and the challenges presented by the regulation of GHG emissions. What actually happened in the US with

SO2 emission trading deviated in several significant respects from what would be predicted based on the

conventional theoretical analysis. While there was a dramatic reduction in SO2 emissions, it occurred

because of several factors, some of which are unlikely to apply for GHG emissions, and others of which

argue for an activist regulatory policy by the government as a complement to the functioning of an

emissions market for GHGs.

Keywords: climate change, emission trading, pollution controlJEL classification: H23, Q54, Q58

I. Introduction

The success of allowance trading for sulphur dioxide (SO2) in the US under the 1990

Amendments to the Clean Air Act (CAA) has been widely seen as creating a new para-

digm for government regulation of the environment.1 Instead of the heavily prescriptive

*University of California, Berkeley, e-mail: [email protected]

I am extremely grateful to Cameron Hepburn and Giles Atkinson for very helpful comments.1 As will become evident, this paper deals with domestic rather than international climate mitigation policy,

and its focus is the US and, to a lesser extent, the EU, but not developing countries.

doi: 10.1093/oxrep/grq015

The Author 2010. Published by Oxford University Press.

For permissions please e-mail: [email protected].

Oxford Review of Economic Policy, Volume 26, Number 2, 2010, pp. 225252


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command-and-control regulation that marked the first two decades of pollution control

regulation in the US, the new approach emphasizes the role of price signals as incentives

for changing polluter behaviour. One way to create such incentives is through emissions

taxes, such as the SO2 and carbon taxes introduced in the Scandinavian countries and

elsewhere. In the US context, however, the introduction of new taxes is seen as politicallyinfeasible. Hence, cap-and-trade (emission trading) has emerged as the preferred approach

in the US.2 Compared to the prior regulatory approach, this involves a more minimalist

role for the government. The government sets emission caps for individual polluters, dis-

tributes emission allowances according to those caps, creates a mechanism to monitor the

emissions, and establishes a procedure whereby polluters turn in allowances to cover their

emissions. Having thus established the parameters of a market, the government then sits

back and allows events to proceed on their own. Polluters reduce their emissions or buy

allowances. Private intermediaries come along. A market evolves. Emissions are reduced.

This is what happened in the US with SO2. Under Title IV of the 1990 Amendments to the

CAA, emission trading was instituted in two phases. Phase I, lasting from 1995 to 1999,

covered the largest and dirtiest generating units. Starting in 2000, Phase II extended thecoverage to virtually all fossil-fuel power plants in the US. The total SO2 emissions from

the generating units covered by Phase I had been 9.4 m tons in 1980 and 8.7 m tons in 1990.

In Phase I these units SO2 emissions were capped at 5.5 m tons; by 1999, their actual emis-

sions were 3.5 m tons, a reduction of almost 60 per cent compared to their 1990 emissions.

With Phase II, the total SO2 emissions from the units covered in that phase had been 17.3 m

tons in 1980 and 15.7 m tons in 1990. These units emissions were capped at a declining

rate, starting at 10 m tons in 2000 and declining to 8.95 m tons in 2010, remaining fixed at

that level thereafter. In 2008, these units emissions were capped at 9.5 m tons, but their

actual emissions were 7.6 m tons, a reduction of almost 52 per cent compared to their

1990 emissions.

The empirical success with SO2 reduction was not unexpected by economists. The eco-nomic explanation dates back to Crocker (1966), Dales (1968), and Montgomery (1972).

Several theoretical propositions about emission trading have been demonstrated. A cap-

and-trade system achieves the set reduction in aggregate emissions at a minimum total cost.

The economy-wide equilibrium is independent of the initial allocation of allowances. The

outcome of emissions trading is identical to the outcome with an emissions tax when the tax

rate is set equal to the clearing price in the emissions marketequilibrium prices are the

same economy-wide. Because the economy-wide equilibrium prices are independent of

the initial allocation of emission permits among individual producers, the point of regulation

makes no difference. Whether there is an upstream cap (e.g. the point of regulation is the

point of entry of fossil fuels into the economy) or a downstream cap (the point of regulation

is the end user of the fossil fuels, or the end user of energy derived from fossil fuels), theultimate economic outcome is the same.3

In this theoretical analysis, market prices are the drivers of behavioural change. When a

price is placed on a pollutant through a cap-and-trade system (or a tax), the prices of pol-

2 As Convery (2009) points out, the European Unions Emissions Trading Scheme for CO2 (EU ETS), intro-

duced in 2005, arose as the result of the European Commissions failure to introduce an effective EU-wide carbon

tax.3 The equivalence result assumes that there are no deviations from perfect competition along the supply chain.

It would not necessarily hold if, for example, the railroads which deliver low-sulphur coal have market power or the

rates charged by pipeline companies are regulated.

226 Michael Hanemann


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luting commodities rise, reducing the demand for those commodities and raising the demand

for non-polluting substitutes. In turn, this lowers input demands by producers of the pollut-

ing commodities, reducing those prices and passing the cost burden backward along the

supply chain. At the same time, there is increased demand for inputs that reduce the gener-

ation of emissions. The price changes radiate throughout the economy, inducing a suite ofprice-driven demand and supply responses in sectors both upstream and downstream of the

sectors that are capped. Once the government establishes the parameters of the market, price

signals take over and do their work.

Thus, both economic theory and the empirical experience of emission trading for SO2allowances appear to support the concept of a minimalist role for the government in the

regulation of pollution. However, in this paper I argue that what actually happened in the

US with SO2 emission trading deviated in several significant respects from what would be

predicted based on the theoretical analysis outlined above. While there was a dramatic re-

duction in SO2 emissions, it occurred because of several factors some of which are unlikely

to apply for greenhouse gas (GHG) emissions, and others of which argue for an activist

regulatory policy by the government as a complement to the functioning of an emissionsmarket for GHGs. Thus, emission trading is a necessary but not a sufficient condition for

an effective climate policy.

The remainder of the paper is organized as follows. Section II reviews the evidence on

how SO2 emissions were reduced from 1995 onwards and the extent to which actual emis-

sion trading was responsible for the reduction as opposed to other innovations. I argue that

other innovations played a major role, and these were due largely to the fact that the 1990

CAA Amendments functioned as a performance standard rather than the technology stand-

ard previously existing under the Clean Air Act. Section III examines the trading that did

occur under Title IV and notes the occurrence of significant over-compliance and banking of

emission reduction, non-arms length transactions, and non-participation in the permit mar-

ket. In light of this empirical evidence, section IV discusses the possibility that some firms

behaviour in reducing emissions may have been influenced not just by the price of permits in

the SO2 market but also by the cap set on their individual emissions. Section V examines the

differences between the past regulation of SO2 and other air pollutants and the challenges

presented by the regulation of GHG emissions. Given these differences, section VI examines

the evidence regarding whether emission trading will be effective in promoting the degree of

technological innovation that will be required for GHG abatement. Section VII makes the

case for governments to go beyond emission trading and become more engaged with GHG

abatement by adopting various complementary policy measures. Section VIII offers some

brief conclusions.

II. How SO2 emissions were reduced

The experience with SO2 trading has played a crucial role in the US debate on climate

change policy, both in individual states and at the national level. It is regularly cited by pro-

ponents of emission trading as an important reason for applying this to GHGs.4 It is useful,

therefore, to review exactly how SO2 emissions were reduced in the US and what was the

role of emission trading.

4 For example, Stavins (2007, 2008).

Cap-and-trade: a sufficient or necessary condition for emission reduction? 227


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Ellerman and Dubroeucq (2004) estimate that about 85 per cent of the reduction in SO2emissions between 1994 and 2002 was associated with a reduction of emissions at individual

generating units (i.e. cleaning up old plants) as opposed to switching generation from high-

to low-emitting units. In other words, firms responded to prices largely by reducing emis-

sions from their own plants, rather than trading allowances between firms. Burtraw (1996)called this response cost savings without emissions trading. Some of this reduction was

due to the retrofitting of scrubbers, but about half or more of the total reduction in SO 2emissions was due to two other factors: (i) a switch from high- to low-sulphur coal, and

(ii) a substantial reduction in capital and operating costs for both new and existing scrubbers.

Neither of these was expected prior to the introduction of trading.

Coal switching, in part, involved the introduction of western low-sulphur coal to power

plants in the Midwest. This was a consequence of railroad deregulation in 1976 and 1980,

which gave railroads greater operating freedom. In addition, there were what Ellerman

(2003) calls [o]ther cost-reducing changes that might be termed innovations in the other

major coal production regions. In the Midwest and Northern Appalachians, lower-sulphur

coal came to be mined as a result of newly opened mines, changes in mining practices, andincreased sulphur removal in coal preparation plants. There was also innovation with regard

to scrubbers. The price of new scrubbers dropped by nearly half between 1989 and 1994.

The operating efficiency increased, the average removal efficiency of new scrubbers rising

from about 85 per cent before 1992 to about 95 per cent by 1995. Also, there was an increase

in the utilization of the retrofitted scrubbers. As a result, there was a substantial reduction in

the cost of using scrubbers.

Another factor leading to cost savings without emissions trading was that the act of giv-

ing plant operators the freedom to choose between buying emission allowances, installing a

scrubber, changing the dispatch order, and switching fuels created an element of competition

among the suppliers of inputs to abatement that was not formerly present. By itself, the

enhanced competition contributed to a reduction in abatement costs.As Ellerman (2003) puts it, [w]hat emerges from the experience with Title IV is that

[abatement] costs are lower for reasons beyond the ability to trade emission reductions

among sources. The cost reductions were a form of induced innovation. This did not in-

volve the emergence of fundamentally new technologies but rather improvements in

operating practices and innovation in the application of existing technologies.

One should also note what didnothappen. Despite increased demand, the prices of inputs

used for the abatement of SO2 in electricity production did not risethey fell. And there was

virtually no discernible increase in the price of electricity as a result of allowance trading for

SO2. The total value of electricity sales in 2000 was $233 billion, while the total cost of

compliance with the Phase II programme that year is estimated to have been about $1.5

billion (i.e. about 0.6 per cent of sales). Moreover, the retail price of electricity fell continu-ously throughout this period from (in 2000$) 9.7 cents per kWh in 1982 to 8.05 cents in

1990, 7.66 cents in 1994, and 6.81 cents in 2000.5 Thus, although SO2 abatement may have

raised the cost of electricity production by about 0.6 per cent in 2000 compared to pre-Phase

I, the retail price of electricity fell by more than 10 per cent between 1994 and 2000.There

also was no obvious reduction in the production of electricitynet generation grew from

3,247 billion kWh in 1994 to 3,802 billion kWh in 2000 (an increase of 17 per cent).

5 There was a spike in electricity prices in 2001, but they then fell back to the range 6.916.99 cents in 20024.



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It also appears that the cap on SO2 emissions had virtually no effect in promoting either

energy conservation or the use of renewable sources of electricity. Net generation from re-

newables rose by only about 6 per cent from 337 billion kWh in 1994 to 357 billion kWh in

2000. One provision of Title IV created the Conservation and Renewable Energy Reserve,

under which bonus allowances worth 300,000 tons of SO2 were set aside to be allocated toutilities for energy efficiency and renewable energy development. However, little use was

made of these allowances; as of February 2002, only about 49,000 of these allowances

had been awarded (Vine, 2003).

Thus, the reduction in SO2 emissions was only partly the result of price changes radiating

from the electricity sector because the cap on emissions had raised the cost of producing

electricity. Induced innovation within the electricity sector itself and its immediate suppliers

played a more important role, whether in the form of market evolution associated with in-

creased competition, or operational innovations by coal producers, railroads, boiler

operators, and scrubber manufacturers and operators. Electricity generators and their suppli-

ers were motivated to find new ways of responding to the implicit price placed on SO2

emissions.This should not be seen as implying that the introduction of emission trading for SO2 was

unimportant or of little economic benefit. Even setting aside the substantial reduction in SO2emissions mandated, the manner in which the emission reduction was regulated was a sig-

nificant improvement compared to the prior regulatory regime established under the 1970

Clean Air Act and the 1977 CAA Amendments.6

Instead of mandating a particular abatement technology, Title IV established a perform-

ance standard for SO2. The emissions limit established under Phase II of the SO2 trading

programme was the same as the prior NSPS limit, but the allowance trading was vastly more

flexible. Installation of a scrubber was no longer required. A power plant operator became

free to use low-sulphur coal, vary the dispatch order, substitute emissions among facilities,

and/or purchase emission allowances in order to comply with the emissions limit. The re-duction in the costs of a scrubber has already been noted. One factor that may have

contributed is the flexibility provided by Title IV with regard to redundant scrubber capacity

(Burtraw, 1996). Before the 1990 CAA Amendments, scrubber systems usually included a

spare module to maintain low emission rates when any one module became inoperative. The

alternatives afforded by Title IV lessened the need to install a spare module, thereby redu-

cing the capital cost of a new scrubber.

A performance standard is inherently superior to a technology standard because it affords

firms the flexibility to attain their emission limit in whatever is the most cost-effective man-

ner for them. The existing discussion of the SO2 trading programme has focused largely on

differences in the marginal cost of SO2 abatement among different electricity generating

units, and the resulting cost savings if emission reduction can be shifted among plants. Thisis how the gains from emission trading have been modelled in the theoretical literature:

emission trading is efficient because it reallocates abatement from plants with high to low

marginal costs. This is essentially a static analysis. The marginal abatement cost curves are

6 Under the prior regime, power plants in existence when the regulations implementing the 1970 CAA became

effective in 1971 had to meet emission rate limits imposed by State Implementation Plans (SIPs), which the indi-

vidual states were required to develop to ensure compliance with National Ambient Air Quality Standards (NAAQS)

for six criteria air pollutants, including SO2. New power plants constructed after that date were regulated more

stringently. They were required to meet the New Source Performance Standard (NSPS) which, after 1977, required

the installation of a scrubber in new power plants, ruling out any reliance on low-sulphur coal alone.



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assumed to be fixed over time, and the focus is on annual emissions, the marginal cost of

annual abatement, and the cost-minimizing re-allocation of annual abatement. In effect, this

is a long-run analysis of where abatement should optimally occur.

But, there are several other ways in which costs could be lowered because of the flexibility

afforded by emission trading. One flexibility is the ability to reallocate emission reductionsover time, which is enhanced by the fact the unused SO2 emission allowances are bankable.

This gives companies the ability to control the timing of investments in new lumpy capital in

the most opportune manner. If interest rates are low, for example, a company can install new

abatement equipment before it is fully needed, and either bank or sell the excess emission

reduction; or, a company can postpone abatement investments until more favourable f inan-

cial circumstances arise, buying emission allowances in the interim.

There are also gains associated with short-run, cost-minimizing operating flexibility as

opposed to the long-run, cost-minimizing reallocation of emission reduction. One form of

operating flexibility is the ability to respond to short-run fluctuations in operating conditions

on, say, a weekly, daily, or hourly time scale by reallocating abatement among different

plants, either internally within a firm that operates multiple plants or externally via the emis-sions market.

A related source of operating flexibility concerns the firms ex ante uncertainty regarding

what its emissions will be during the relevant regulatory period. A power plant operator

cannot know what the demand for electricity will be next week, let alone for the rest of

the year, and he cannot be sure of future prices for fuels of different sulphur content. So,

how can he know what his emissions will be during the balance of the regulatory period?

However, SO2 and other emissions markets are designed so that emission generation and

compliance are asynchronous: emissions occur during a particular period (the calendar year,

for SO2.) while the emissions permits must be turned over at the endof the period, or shortly

thereafter. Thus, emissions permits have a convenience value (Burtraw, 1996) which phys-

ical abatement equipment lacks: if there is a shortfall on 31 December, say, it is possible toacquire additional permits at the last minute, but it is too late to lower the years emissions by

installing a scrubber.7

Short-run operating flexibility and long-run reallocation of emissions reduction are clearly

benefits arising from the existence of emission markets, but they are distinct phenomena and

they serve different purposes. Operating flexibility, while economically valuable, does not

necessarily lead to a long-run reallocation in emission reduction. For example, changing the

dispatch order is a short-run fix to reduce emissions, but with growth in power demand it is

not necessarily a substitute for the installation of new, low-emission generation capacity in

the long run.

Short-run flexibility and long-run reallocation of abatement are likely to lead to different

patterns of participation in the emissions market. If a firm decides on a long-run strategy ofabatement, one would expect to find it consistently selling permits in the market. If a firm

decides to rely on buying permits as a strategy because this is cheaper than abatement, one

would expect to find it consistently appearing as a buyer. However, if a firm varies between

buying and selling permits, that could be consistent with use of the emission market for

short-run flexibility rather than for long-run reallocation of abatement. At this point, it is

an open question as to how much of the participation in the SO 2 emission market was mo-

tivated by long-run versus short-run considerations. Nevertheless, the fact, noted above, that

7 In addition, the purchase of permits is reversible (the permits can be resold), while the installation of a scrub-

ber is irreversible; the difference in reversibility gives rise to an option value for permits (Chao and Wilson, 1993).



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85 per cent of the reduction in SO2 emissions between 1994 and 2002 was associated with a

reduction of emissions at individual generating units rather than with switching generation

from high-emitting to low-emitting units suggests a somewhat limited role for long-run re-

allocation of abatement via the SO2 emissions market.

III. The nature of SO2 trading

In Hanemann (2009), I review the literature on the functioning of the SO2 allowance market.

Three distinctive features stand out. The f irst feature is over-compliance in emission reduc-

tion and the banking of allowances. In Phase I, 30 per cent of all allowances distributed

during 19959 were banked; equivalently, the reduction in emissions was about twice what

was required to meet the Phase I cap (Ellerman and Montero, 2007). Between 2000 and

2005 the bank was drawn downalbeit at a fairly modest rateto cover emissions in excess

of the annual allotment of new allowances. In 2007 and 2008, there was again some over-compliance in emission reduction, and the allowance bank started to grow. In an analysis of

banking between 1995 and 2002, Ellerman and Montero (2007) concluded that, contrary to

the general impression of excessive banking, the amount of banking that occurred during

this period was actually quite efficient based on economic fundamentals. At the time, Eller-

man and Montero projected that an efficient bank would decline to about 3 m tons in 2008.

This is about half the amount actually banked in 2008.8 It would seem that one cannot rule

out the possibility of over-compliance in emission reduction beyond that called for by pure

economic efficiency.

The second feature is a significant degree of what Kreutzer (2006) calls autarky. This is

when firms do not comply with their cap by purchasing allowances in arms-length transac-

tions; they either reduce emissions to stay within the cap or, if there are excess emissions,

they draw on their own past banked allowances or on allowances available from other units

that they control. One measure of this is the extent to which, when firms submit allowances

to the Environmental Protection Agency (EPA) to cover their emissions, these are allowan-

ces that had originally been allocated to them, rather than allowances obtained from

someone else. Kreutzer (2006) finds that, between 1997 and 1999, about 70 per cent of

the allowances retired each year were redeemed by the same unit to which they had origin-

ally been allocated, and only about 30 per cent were originally allocated to another unit.9

Between 2000 and 2003, the proportion of allowances redeemed by the same unit to which

they had originally been allocated was lower, about 60 per cent, but still substantial.

Third, even when allowances are transferred, this may not be an arms-length transaction

since the same corporation may own multiple plants with multiple boilers, each with its own

allocation of allowances. In its annual summary of allowance transaction data, the EPA dis-tinguishes between what it calls economically significant transactions (i.e. between

8 Their analysis was conducted prior to the proposed tightening of emission limits under the Clean Air Inter-

state Rule in 2005, which strongly affected spot prices and could also have affected banking. The rule was set aside

in July 2008. Risk aversion, not included in their analysis, may also be a factor.9 In a personal communication with EPA staff, I have been told that, until 2006, account identity numbers

represented individual boilers. Therefore, the same unit here means the same boiler.



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economically unrelated parties), and transactions between related entities.10 In 2007, for

example, the EPA deducted 8.9 m allowances from sources accounts to cover their emissions

that year. In addition, nearly 4,700 private allowance transfers moving roughly 16.9 m al-

lowances of past, current and future vintages were recorded in the EPA allowance Tracking

System. About 9.1 m (54 per cent) were transferred in economically significant transac-tions. The other 46 per cent were transfers between related entities. The large proportion

of transfers between related parties has been a constant feature of the SO2 allowance market.

Finally, while there clearly were significant cost savings from allowance trading compared

to what would have happened under a command-and-control approach, the evidence sug-

gests that the allowance market was not perfectly efficient and that not all gains from

trade were successfully exploited. Carlson et al. (2000) find that, in the first years of Phase

I, there were some differences in marginal abatement costs among facilities, and absolute

compliance costs could have been reduced further with additional trades. Ellerman et al.

(2000) reach a similar conclusion. In addition, plant-level studies of production and abate-

ment efficiency by Coggin and Swinton (1996) and Swinton (2002, 2004) indicate that some

plant owners did not take full advantage of the allowance market; they controlled emissionswhen it would have been cheaper to purchase allowances.

IV. What caused the reduction in SO2 emissions?

The standard theoretical model on which most of the economic analysis of emission markets

is based (Montgomery, 1972), is a purely static model. A firm minimizes total cost, which

consists of abatement cost plus the cost of procuring emission permits (or minus the revenue

from selling permits). Production and abatement technology are given. There is no effective

distinction between capital and operating costs. To the extent that capital costs are involved,

there is implicitly an instantaneous adjustment of the capital stock, with no allowance for a

time lag associated with the turnover in capital. Whether there is a tax or a cap on emissions,

firms equate the marginal cost of abatement to the tax or the market price of emission per-

mits. The introduction of a tax or a cap on emissions causes the firms costs to rise. The price

increase is transmitted upstream and downstream from the polluting sector, inducing move-

ments along demand and supply curves throughout the economy. It is the price signal that

induces a reduction in emissions. The cap on the individual firms emissions has no econom-

ic significance per seonly the aggregate cap on emissions affects the outcome, because it

determines the equilibrium price in the market for emission permits.

As indicated above, what actually happened with SO2 does not exactly match these sty-

lized facts. No price signal was transmitted to electricity users downstream. All of the

emission reduction occurred as the result of actions taken by the railroads and the electricityproducers themselves. Rather than movements along demand and supply curves, the main

mechanism of adjustment was shifts in those curves induced by changes in railroad market

structure and unexpected operational innovations in electricity production. The indication is

that these innovations went beyond the ability to trade.

10 The EPA comments that transfers between economically unrelated parties are arms length transactions

and are considered a better indicator of an active, functioning market than transactions among the various facility

and general accounts associated with a given company (US EPA, 2008, p 12).



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Then, what motivated the innovations? The market price of SO2 emissions permits may

have had some influence but this can hardly be the entire explanation, given that many firms

did not resort to the permit market to meet their obligation to the EPA. As noted above, there

was a significant degree of autarky. Many firms kept their emissions within their cap and/or

relied on unused permits from previous years which they had previously banked. In addition,a substantial number of firms relied on internal transfers of permits rather than arms-length

market transactions. Moreover, the evidence of autarkic behaviour by firms is not limited to

the SO2 marketthere is similar evidence from other pollutant trading schemes. With the

US lead trading programme for gasoline, for example, Kerr and Mare (1998) found a sig-

nificant amount of non-arms length trading, in the form of internal transfers among different

refineries owned by the same company. In their data, 67 per cent of the quantity of lead

bought was bought within the same company, and 70 per cent of the lead sold was sold

within the same company. Two recent studies of firms confronting the EUs Greenhouse

Gas Emission Trading System (EU ETS) also provide evidence of some predisposition to

autarky. In a survey of the 500 largest companies worldwide conducted in 2004, 31 per cent

of the German firms, 38 per cent of the UK firms, and 61 per cent of the French firmsexpressed no interest in the EU ETS, due to begin in January 2005, or stated that they will

not participate at all (Pinkse, 2008). A survey of Swedish firms in 2006 found that 46 per

cent of firms thought they would handle a potential allowance deficit by reducing emissions

internally rather than purchasing allowances (Sandoff and Schaad, 2009). In a different con-

text, a recent experimental study of allowance trading by Goeree et al. (2009) f inds evidence

of a predisposition to autarky when allowances are grandfathered, although not when they

are auctioned.

Loss aversion is another possible factor that Kreutzer (2006) suggests might have come

into play and promoted autarky in the SO2 market. A firm that does not sell allowances

when it should do so forgoes a gain; a firm that sells allowances when it should not do

so, and then has to buy them back at a higher price, suffers a loss which may weigh moreheavily than a gain of the same magnitude.

If there is a preference for autarky, or more generally a wish not to bother with the com-

plexity of the market, then the caps on individual firms emissions would themselves drive

the reduction in those emissions. The individual caps have, in fact, been identified by some

commentators as a major reason for the reduction in SO2 emissions.11

The caps could also drive behaviour if managers have a preference for complying with the

law and simply choose to keep emissions within the limit set for them by the EPA. Evidence

of a compliance norm has been found in other contexts where firms responses to regulation

have been studied. Braithwaite and colleagues interviewed and observed firm managers in a

variety of industry sectors, including coal mining, nursing home operations, and pharma-

ceutical production.

12

In an analysis of those studies, Ayres and Braithwaite (1992)concluded that, in many cases, managers were motivated by social responsibility and sought

to comply with the law. Gunningham et al. (2003) found evidence of a compliance norm in

their investigation of pulp and paper mills response to environmental regulation in the US,

Canada, Australia, and New Zealand. They found that management style was a key explana-

tory variable, and they identified five styles which they characterized as laggards, reluctant

compliers, committed compliers, environmental strategists, and true believers.

11 For example, Malloy (2002, p. 549), citing US EPA (2001); also Driesen (1998, p. 318).12 Braithwaite (1984, 1985) and Braithwaite et al. (1990), cited by Malloy (2003, note 91).



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Are there any economic reasons why their individual caps would influence firms behav-

iour? The conventional economic model of emission trading based on cost minimization by

a polluting firm holds that the firms optimal emissions are independent of its cap (Mont-

gomery, 1972). However, this result follows directly from the assumption that the marginal

cost of obtaining permits through emission trading is constant; it does not hold when themarginal cost varies. Thus, if there are transactions costs that depend nonlinearly on the

number of emissions permits purchased, the optimal level of emissions will not be independ-

ent of the cap (Stavins, 1995). Nevertheless, transactions costs may not be a sufficiently

significant factor in the SO2 market. There are many brokers and other market intermedi-

aries who are active in that market and, in fact, trading costs are considered to be low

(Joskow et al., 1998).

If one introduces risk aversion into the conventional model of cost minimization, this

would cause optimal emissions to depend in part on the firms cap. For example, the cap

influences emissions if there is uncertainty regarding whether a permit transaction will be

approved which varies nonlinearly with the magnitude of the transaction (Montero, 1997).

There can also be uncertainties about future emissions, about future allowance prices, and/orabout future programme regulations which would make a firms optimal emissions depend

on its cap.

The conventional economic model of emission trading represents the firm as a single,

unitary decision-maker, with a single objective, namely profit maximization. This has been

characterized as the black-box model of the firm (Malloy, 2002). There is an alternative

view of the firm as an organization with a multiplicity of actors and certain distinctive in-

ternal features. In economics, this view goes back to Coase (1937) and was importantly

developed by Williamson (1975). This view also is the central focus of the organizational

behaviour literature, where it received a powerful stimulus from Cyert and March (1963).

Viewing the firm as an organization opens up additional explanations for why firms might

be influenced by the cap set on their emissions.It has been pointed out by von Malmborg (2008) that the decision to stay within ones

emissions cap or resort to purchasing emission permits from the market is isomorphic to the

make or buy decision discussed by Coase (1937) and analysed further by Williamson

(1975, 1981) using a transactions cost approach. In this approach, the question of when

firms choose to produce a good or service themselves as opposed to buying it on the market

is analysed in terms of three main factors: (i) the degree of uncertainty/complexity inherent

in the transaction, (ii) how frequently the transaction is to be made (the transaction dens-

ity), and (iii) the cost of transaction-specific investments. If a transaction is seen as complex

and is marked by uncertainty, which Williamson suggests is commonly the case, it is mainly

the other two factors that determine how the f irm proceeds. Applying Williamsons logic to

the circumstances of a firm enrolled in the EU ETS programme, von Malmborg concludesthat, if transaction density and transaction-specific costs are both seen as low, the firm will

choose to buy emission permits; if both are seen as high, the firm will engage in in-house

emission reduction (the hierarchical solution); if transaction density is seen as high while

transaction-specific costs are low, the firm will resort to a bilateral solution, which in this

case could be participating in a joint implementation (JI) or clean development mechanism

(CDM) project; and, if transaction density is seen as low while transaction-specific costs are

high, the firm will resort to a third-party solution, which in this case could be investment

in a fund such as the World Bank Prototype Carbon Fund. For electric utilities covered by

the SO2 trading programme, transaction density is likely to be seen as high. If transaction-

specific costs are high, this argues for the hierarchical solution of in-house emission reduction.



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If transaction-specific costs are low, in the absence of a JI or CDM alternative the best bilateral

solution might be emission reduction in another facility owned by the same company (trade

with a related entity). Thus Williamsons logic could provide an explanation for the observed

prevalence of autarkic behaviour in the SO2 market.

The behavioural view of the firm as a system for allocating and coordinating organizationalresources, such as capital, personnel, and information, can also lead to the conclusion that

the emissions cap may be more influential on firm decision-making than the market price of

emission permits. Within the firm, there are multiple actors and, quite possibly, multiple

objectives. In a typical manufacturing establishment, there is a manager responsible for

the purchase of energy services, a manager responsible for product design, and perhaps a

manager in charge of product pricing, as well as the CEO. These people have different re-

sponsibilities, they face different incentives, and consequently they may not all respond to a

given price signal in an identical manner. The consequence is that the firm as an entity may

fail to exploit some of the profitable opportunities that are available to it.13

By contrast, a downstream cap on GHG emissions could have more impact on the firms

decision-making. Compare an upstream cap versus a downstream cap on, say, the emissionsassociated with new model vehicles manufactured by Ford for sale in California.14 The up-

stream cap raises the price of gasoline, which affects both Ford as a consumer of fuel, and

also Fords customers. The downstream cap affects Ford more directly, because it limits what

new model vehicles Ford can sell. It is not necessarily the case that the same decision-ma-

kers within Ford are mobilized to deal with the consequences of the two emissions caps, or

that the same corporate response emerges. Because the downstream cap is more direct and

visible, it makes abatement more salient for senior managers and is likely to attract their

attention more strongly than the price signal triggered by an upstream cap.15 With senior

management more engaged, the downstream cap can have a larger, and more rapid, impact

on what cars Ford designs and on how it prices them than the upstream cap.

Malloy (2002, 2003) has argued that the behavioural view of the firm has important im-plications for the design of environmental regulatory policies, and casts doubt on some of

the conventional arguments for market-based price incentives. Theoretical studies of how

firms respond to regulatory incentives, he writes, typically fail to consider the role of at-

tention. Instead, they assume at the outset that all stimuli are created equal in terms of their

ability to garner firm attention. However, he argues that the capacity of any organization to

process information and to detect and respond to stimuli is necessarily limited: attention

13 There is robust empirical evidence in the organization learning literature and business strategy literature of

such failures. They have also been documented in the pollution context by a number of researchers, including De-

Canio (1998), King and Lenox (2002), Saele et al. (2005), and Muthulingam et al. (2009).14

This is how the Pavley Bill (AB 1493) functions. Enacted by California in 2002 and implemented by the AirResources Board in 2004, it requires a 30 per cent reduction by 2016 in the overall emissions of GHGs of the fleet of

new vehicles sold by each manufacturer in California. Implementation required a waiver of the CAA by the US EPA

which was withheld under President Bush. The waiver was granted in June 2009. In September 2009, the US EPA

and Department of Transportation announced a new national standard for GHG emissions from light- and medium-

duty vehicles very similar to Californias standard.15 Gillingham (2009) has also suggested that, because of considerations of salience, a downstream cap may

induce a larger behavioural response from firms than an upstream cap or a carbon tax. However, his argument is

slightly different: he suggests that the signal from the price of carbon in an emissions market with downstream caps

may be more salient for firms than the signal from an increase in the price of energy resulting from an upstream cap

or a tax. He attributes no influence on the firms emissions to the cap itself.



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itself is a scarce resource that is directed and allocated.16 In a case study of the regulation of

toxic emissions from dry-cleaning firms in Southern California, Malloy and Sinsheimer

(2004) present evidence that many of these firms appear relatively insensitive to modest

but non-trivial opportunities for increasing profit by adopting less costly and less polluting

production technologies. The reason, they suggest, is that the novel technology loses out tothe conventional technology in the competition for firm resources and managerial attention.

Consequently, they argue that direct regulatory intervention can be more effective than in-

centive-based approaches.

In summary, there are both economic and behavioural reasons why an emissions cap

could turn out to be a more visible and salient trigger of change in a firms emissions than

a price increase alone.

V. SO2 versus CO2

The obvious question is: could not emission trading work just as well for GHGs as it did for

SO2? At first glance, GHGs seem a better candidate for emission trading than SO2 because

there are no hot spots for GHGs: the environmental consequences of their emission in

terms of climate change depend just on the aggregate volume of emissions, regardless of

the location where the emissions occur.17 However, there are several other differences be-

tween SO2 and GHGs which make cap and trade unlikely to be as effective at accomplishing

a large emission reduction for GHGs as it was for SO2. In this section we enumerate the

differences. The implications for emission trading are discussed in the following two

sections.

First, the emission of GHGs, especially CO2, is more widely diffused throughout the

economy than for SO2. About 70 per cent of SO2 emissions in the US in 1995 came from

the burning of fossil fuel in electricity generation, but only 34 per cent of the GHG emis-

sions in the US today come from electricity generation.18 Nearly as many GHG emissions

(28 per cent) come from transportation.19 The reduction of SO2 emissions engaged a rela-

tively small number of decision-makersjust a few hundred power companies accounted for

the vast majority of SO2 emissions. However, narrowing the focus of CO2 reduction to the

electricity generation sector alone would leave the majority of US emissions untouched

hardly a satisfactory outcome. To accomplish a more extensive reduction in CO2 emissions

requires somehow engaging with emissions from other sectors, including transportation and

buildings, and also forestry and agriculture.20

16

Malloy (2002, p. 556). Saele et al. (2005) also identify lack of managerial attention as one of the factors preventing organizations from implementing profitable energy-saving measures.

17 The impact depends on the composition of GHGs emitted (with methane, for example, being more potent in

the short run than CO2), but not the location. The consensus in the literature is that hot spots do not so far appear to

have been a major problem with SO2 allowance trading (Swift, 2000; Burtraw et al, 2005).18 Electricitys share of CO2 emissions alone is 39 per cent (US EPA, 2009). CO2 accounts for about 85 per

cent of the 7.15 billion metric tons (tonnes) of CO2-equivalent GHG emissions in the United States in 2007; but

methane, nitrous oxides, and other gases also contributed. About 94 per cent of the CO2 comes from the combustion

of fossil fuels, with the rest from changes in land use (deforestation, etc.). The methane comes mainly from landfills

and cows.19 In California, by contrast, electricity (including electricity imported from out of state) accounts for 22 per

cent of the CO2 emissions, and transportation accounts for 40 per cent of the emissions.20 The discussion below addresses transportation and buildings, but not forestry or agriculture.



13/28

Second, unlike SO2, we cannot rely on existing technologies to achieve the requisite re-

duction in CO2 emissions. A 50 per cent reduction in SO2 emissions was accomplished

virtually overnight without any major technological breakthrough. The emission reduction

was accomplished through technologies with which power plants operators had long been

familiar. By 1995, scrubbers were a mature technology. Burning low-sulphur coal in boilersdesigned for high-sulphur coal was a challenge for boiler operators and constituted a signifi-

cant operational advance, but it was hardly a major technology breakthrough. By contrast, it

will be necessary to develop new technologies to achieve the needed reduction in CO2 emis-

sions from burning coal to generate electricity. There is no low- CO2 coal, and there is no

end-of-pipe device, like a scrubber, that can be retrofitted in an existing coal-fired power

plant. Carbon capture and storage (CCS) has not yet been practised at the scale of a com-

mercial coal-fired generating plant. A handful of small-scale CCS pilot projects and

demonstration projects are under way in the US and elsewhere. If all goes well, it is expected

that a commercial version of this technology may become available by 2020.21 Construction

of new plants would then take several years.

However, for existing coal-fired power plants it is believed that retrofitting CCS wouldnotbe economically feasible because it would cost virtually as much as building a brand new

plant (MIT, 2007).

Working with existing power plants, one can reduce CO2 emissions by changing the

dispatch order.22 CO2 can also be reduced by co-firing coal with biomass which, since it

is renewable, has effectively zero carbon intensity. Until recently it was thought this could

be done on a very limited scale (under 5 per cent of biomass). It is now believed this can be

done with up to 15 per cent of biomass.23 This may improve further with experience, as

happened with the use of low-sulphur coal. But still, it seems unlikely that co-firing with

biomass will be as much of a boon as low-sulphur coal was for SO2 reduction. Consequently,

unlike with SO2, the only way significantly to reduce CO2 emissions from existingcoal-fired

plants appears to be to operate them less.As noted earlier, renewable energy generation played no role in the reduction of SO 2

emissions. With CO2, by contrast, there is a significant potential for non-fossil fuel electri-

city generation based on nuclear power and renewables, but it will take some time to realize

this potential.

Nuclear power plants based on existing designs are extremely expensive and take a very

long time to construct, especially in the US. The capital cost is the most important factor

determining the competitiveness of nuclear energy. The smallest nuclear power plant that

can be built is typically larger than other power plants, making the nuclear option a much

larger commitment of funds. With the increase in commodity prices around 2008, the con-

struction cost of all power plants has greatly increased, but the increase has been

dramatically larger for nuclear than for coal-fired plants. MIT (2003) had estimated the con-struction costs for nuclear power, excluding interest (i.e. the overnight cost), at $2,000/kW

in 2002 dollars. Du and Parsons (2009) subsequently updated this estimate to $4,000/kW in

2007 dollars; other estimates are even higher.24 Moreover, the recent liberalization of the

21Wall Street Journal, The Long Road: Carbon Capture and Storage, 22 February 2010.

22 Electricity from natural gas has about half the CO2 emissions of coal, and electricity from oil is about half

way between natural gas and coal.23 I owe this observation to Dallas Burtraw.24 By contrast, Du and Parsons (2009) estimate the construction cost of a coal-fired plant at $2,300/kW in 2007

dollars.



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electricity markets in the US and some other countries means that the risks of construction

delays and cost overruns, and the risk of cheaper power becoming available from other

sources, are now borne by plant suppliers and operators rather than consumers. This has

made the economics of nuclear power less attractive for utilities. Efforts are under way to

develop less costly new designs for nuclear power plants using multiple smaller reactors, butthese technologies could take about a decade to be approved and put into operation.

In the past decade there have been significant improvements in the technologies for gen-

erating electricity from wind and solar power. The cost of wind energy at a good site is now

close to being competitive with the cost of electricity from coal and natural gas. Solar ther-

mal power (concentrated solar power) is still more expensive than coal or natural gas, but is

coming within range.25 However, wind and solar thermal face two difficulties in competing

with coal and natural gasintermittency and location. Wind and solar thermal generate

electricity only when the wind blows and the sun shines; both need some form of storage

to be fully effective. While it is an active area for research, the storage problem does not yet

have a definitive solution. Furthermore, many good wind and solar thermal sites are located

a great distance from where electric power is consumed, and therefore need transmission inorder to be effective. Construction of the needed transmission will take time and will be

expensive.26 While wind and solar thermal hold promise for the future, their market shares

are still very small. In the EU27, wind accounts for 5.5 per cent of electricity consumed, and

all solar (photovoltaic plus thermal) accounts for 0.8 per cent. In the US, wind accounts for

1.9 per cent of electricity consumed, and solar accounts for less than 0.1 per cent. All forms

of renewable electricity, including hydropower, geothermal, and biomass, as well as wind

and solar, account for about 9 per cent of the electricity consumed in EU27, and 10.4 per

cent in the US. The EU has adopted the target of a 20 per cent share for renewable energy by

2020, and there has been some discussion of a similar target for the US. Even with 20 per

cent of electricity generated from renewables in the US and Europe, this would still leave the

large majority of GHG emissions from electricity generation untouched.The above discussion highlights a third point of difference between SO2 and CO2the

need for replacement of capital stocks in order to accomplish the reduction in CO 2 emis-

sions. With SO2, emission reduction was accomplished for the most part with existing

capital assets: it was possible to retrofit existing power plants with scrubbers and/or to mod-

ify the combustion for low-sulphur coal. There was not a wholesale retirement of capital

assets well before the end of their useful lives. By contrast, before there can be a major

reduction in CO2 emissions from electricity generation, existing power plants will have to

be replaced by nuclear energy or renewable energy or by new coal-fired plants using state-

of-the-art technologies, such as supercritical combustion or integrated gasification com-

bined-cycle, and designed from the beginning to incorporate CCS.27 Similarly with

transportation, the other major source of emissions, existing vehicle fleets will have to be

25 For example, Heal (2009), gives the cost of electricity from coal and natural gas as between 6 and 7 cents/

kWh; that of wind (leaving aside transmission cost and intermittency) as between 6 and 10 cents/kWh; and that of

solar thermal as about 12 cents/kWh.26 A US Department of Energy (DOE) report estimates that wind could contribute 20 per cent of US energy by

2030; for this to occur it would be necessary to construct over 12,000 miles of new transmission lines at a cost of

approximately $20 billion (US DOE, 2008).27 The situation is different in developing countries. In China, for example, it is estimated that over two-thirds

of the electricity generating capacity in place by 2020 will have been built after 2005. But in the OECD, it is

estimated that almost two-thirds of todays generating capacity will still be in operation in 2030 (International En-

ergy Agency, 2003).



15/28

replaced before there can be a major reduction in CO2 emissions from transportation. The

problem is that today we have the wrong types of power plants, the wrong types of motor

vehicles (gas guzzlers rather than highly fuel-efficient smaller vehicles), and the wrong types

of urban development, with urban sprawl and limited public transit. It is unlikely that the

reduction in GHG emissions required by mid-century can be accomplished with existingcapital stocks left mostly unscathed.

The fourth difference concerns the role of energy conservation and energy efficiency. As

noted earlier, conservation by energy users played no role in the reduction of SO 2 emissions.

By contrast, conservation by end users and energy efficiency will have a central role in the

reduction of CO2 emissions, especially in the near term while we wait for new technologies

to be developed and deployed. It will be necessary to promote a degree of behavioural

change among energy users throughout a broad swathe of the economy, a far more daunting

challenge than was faced when dealing with SO2 emission reduction.

Given the differences between what occurred when SO2 emissions were reduced and what

will be required in order for CO2 emissions to be reduced, the question arises whether emis-

sion trading will be as effective with CO2 as it was for SO2. As explained below, there aresome reasons to doubt this.

VI. Emission trading and technological innovation

Since many of the technologies required for GHG reduction are still in their infancy, there is

general consensus on the need for some form of research and development (R&D) policy to

promote long-term technological change. Because information is a public good, there is an

impaired ability to appropriate all the rents from an innovation, and this weakens private

incentives to invest in R&D. Hence most economists agree on the need to address this mar-

ket failure through some government-sponsored climate-oriented R&D policy as a

complement to a carbon tax or an emission trading system.

Schumpeter famously identified three stages in the process of technological change: in-

vention, innovation, and diffusion. Invention is the first development of a scientifically or

technically new product or process, which may involve both basic and applied research.

Innovation is accomplished when the new product or process is commercialized, i.e. made

available on the market. Diffusion is when the product or process comes to be widely used

through adoption by many firms or individuals. In the case of climate change, invention and

innovation are the core issuesthe development and commercialization of technologies that

do not exist yet or, at best, are still experimental (e.g. CCS).

In the pollution control literature there is some limited empirical evidence that more strin-

gent environmental policies lead to invention, as reflected in increased patent activity.Lanjouw and Mody (1996) found a positive correlation between the stringency of environ-

mental policy, measured in terms of pollution abatement expenditures, and the number of

environmental patents granted in the US, Japan, and Germany. Using US manufacturing

data, Brunnermeier and Cohen (2003) also found a positive relation between pollution abate-

ment expenditures and counts of environment-related patents. In a more extensive

international comparison, De Vries and Withagen (2005) analysed patent counts relating

to SO2 abatement in the US and 13 European countries over the period 19702000 and

found some evidence that strict environmental policies lead to more inventions.



16/28

A less settled question is how the choice of policy instrument influences the rate of in-

vention. It is sometimes asserted that, by rewarding emission reductions however they are

accomplished, a carbon tax or an emission trading system would also provide broad incen-

tives for inventions that lower the cost of emission reduction.28

The actual experience of the promotion of technological change under emission tradingfor SO2 is more ambiguous. While scrubber operating efficiency increased and scrubbers

became cheaper, there does not appear to have been any fundamental change in scrubber

technology. The data on patent counts relating to post-combustion SO2 control technology

actually show a decline in the number of new patents starting around 1990, and steepening

after 2001.29 Moreover, there was no obvious boost to other low-emission technologies for

coal combustion, such as integrated gasification combined cycle (IGCC) which results in

lower emissions of SO2, particulates, and mercury as well as improved combustion efficiency

compared to conventional pulverized coal.30 Developments such as the burning of low-

sulphur coal in boilers designed for high-sulphur coal and the increased operating efficiency

of scrubbers were primarily refinements in operating practices rather than fundamentally new

technologies.31 As noted above, the increased use of low-sulphur coal and the improvementin scrubber operating efficiency can have been due to the fact that the cap functioned as a

performance standard rather than to the price signal created by emission trading.

Thus, emission trading for SO2 (and also lead) promoted the adoption of technologies that

were already available; in Schumpeters terminology, while there was diffusion, there was no

invention and no innovation.

With NOx, Popp (2006) examines patents over the period 19702000 and shows that, in

the US, the rate of patents for Nox-control technologies reached a peak in 1990. However,

this is evidence of the impact of regulatory stringency on invention, rather than of emission

trading per se. The 1990 Clean Air Act was the beginning of binding regulation for existing

stationary sources of NOx. The act significantly tightened limits for NOx emissions from

power plants and, unlike the previous legislation in 1970 and 1974, applied those limits toexisting as well as new power plants. But, emission trading for NOx came later. In addition

to acid rain, ozone was a second focus of concern with NOx in the CAA Amendments.

Seeing the need for a regional strategy for the Northeast Corridor to achieve compliance

with the ozone standard, the CAA Amendments created the Ozone Transport Commission

(OTC). In 1994, the states belonging to the OTC recognized that emission rate standards

alone would not be sufficient for ozone compliance and agreed to implement a summertime

28 For example, Stavins (2007, p. 32).29 By 2004, the annual number of new patents was less than half the annual average for the period 19751989

(Taylor, 2008). Popp (2003) shows that there is a correlation between the increase in scrubber operating efficiencyafter 1990 and the cumulative stock of new patents issued after 1990. But it is not clear whether the specific focus of

post-1990 patents related to operating efficiency, nor is it necessarily the case that the relationship found by Popp is

a causal one. His explanatory variable, the cumulative stock of new patents, may function as similar to a time trend,

in which case his regression shows merely that scrubber operating efficiency rose over time during the 1990s.30 There are currently only two IGCC plants generating power in the US, which started operating in 1995 and

1996; several new IGCC plants are expected to come online in the US around 2012 20.31 A similar conclusion applies to the US lead-refining programme which operated from 1982 to 1987. Kerr

and Newell (2003) examine a technology known as isomerization used by refineries to replace octane when lead is

restricted. The technology was introduced in the late 1960s. By 1980, the cost of isomerization had fallen by about

40 per cent. During the 1980s, the cost fell hardly at all. More than half the adoption of isomerization occurred after

1986, when the phase-out of lead trading had been set. In fact, the flexibility afforded by lead trading may have

permitted some refineries to postpone the installation of isomerization from, say, 1985 to 1987.



17/28

trading programme for large sources of NOx, including both power plants and certain in-

dustrial facilities. The trading programme commenced operation in 1999. There was a small

increase in the rate of patents for NOx control in 1994 (for NOx post-combustion patents)

and 1997 (for NOx combustion modification patents), but in each case this was followed by

a subsequent decline.Two papers have recently analysed inventions relating to climate change mitigation

technologies. Glachant et al. (2009) employ a global patent data set covering 13 classes

of technologies with significant potential for GHG emission reduction over the period

19782003. Between 1978 and 1997, patents relating to climate change grew at the same

pace as all patents generally. Between 1998 and 2003i.e. after the Kyoto Protocol

patents relating to climate change grew much faster than all patents generally. Moreover,

the increase in climate-related patents occurred in countries which ratified the Kyoto

Protocol but not in the US and Australia, which did not ratify the Protocol.32 One com-

mentator characterized this finding as climate policy does wonders for your green-tech

patent count.33 However, this again should be seen as evidence of the impact of regu-

latory stringency on invention, rather than of emission trading per se. The two categorieswith by far the largest annual number of patents between 1998 and 2003 were lighting

and fuel injection. These were followed respectively by waste (recovery of heat from

waste incineration, recovery of waste heat from exhaust gases, and production of energy

from waste or waste gases), solar, building efficiency, and wind. Solar and wind patents

may be related to investments by power companies that are regulated in Europe through

the EU ETS, which was established by a directive in October 2003 and went into effect

in January 2005. The other patent categories that experienced unusual growth between

1998 and 2003 are unlikely to be related to emission trading in the EU or elsewhere. It

is noteworthy that, between 1998 and 2003, CCS had the smallest annual number of

patents of all 13 categories.34

Johnstone et al. (2010) analyse a subset of the same data relating to renewable energytechnologies involving wind, solar, geothermal, ocean, and biomass/waste in 25 countries

over the period 19782003, Their focus is the effect on the rate of invention of alternative

types of policy instruments. Since the data end prior to the institution of EU-ETS, emission

trading per se is not one of the instruments considered, but the analysis does cover tradable

renewable energy certificates (RECs) in connection with renewable portfolio standards. The

econometric analysis shows that RECs induced inventions in wind power, while targeted

subsidies, such as feed-in tariffs, induced inventions in solar power. The authors explain this

by pointing out that a renewable portfolio standard is a performance standard which leaves

electric utilities free to choose any renewable technology; therefore it promotes innovation in

a technology such as wind that is close to competitive with fossil fuels. By contrast, solar is

more expensive than fossil fuels and therefore requires subsidies in order to promoteinnovation.

In short, the empirical evidence demonstrates that the pace of invention is influenced by

the stringency of environmental regulation and perhaps also whether the regulation involves

a performance standard, but not necessarily whether it involves emission trading per se.

32 Australia subsequently ratified it in December 2007.33 http://www.env-econ.net/2009/02/climate-policy-does-wonders-for-your-greentech-patent-count.html.34 According to Glachant et al. (2009), annual patents relating to CCS increased sharply in the late 1980s,

reaching a peak in 1992, but then fell for 5 years. Since 1997, the level of CCS patents has increased gradually,

but in 2005 it was still below the 1992 record high.



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Montgomery and Smith (2007) reach a similar conclusion. Commenting that climate policy

demands a policy prescription that is effective in stimulating future technology development

without imposing inefficiently high costs in the near-term stages of the policy, they con-

cluded that the ability of the cap-and-trade approach to perform in [this] manner has not

been demonstrated by any of its previous applications, nor has it been explored adequatelyin modeling or in theory.

There are at least two economic reasons why the price signal generated by emission trad-

ing might not be sufficiently powerful, by itself, to promote the type of technological

innovation required for the reduction of GHG emissions. One reason, emphasized by Mont-

gomery and Smith, is the problem of:

dynamic inconsistency between what governments will announce as a future policy

and what governments will subsequently be motivated to adopt as a policy. As a result

of this dynamic inconsistency, efforts to address climate change by imposing caps or

taxes in the near-term will fail to provide an adequate credible incentive for the R&D

necessary to lower the cost of long-term reductions. Additionally, even if the R&Dexternality is being effectively addressed, implementation today of a cap or tax that

will not become stringent until a later date will provide little or no supplemental bene-

fit in the form of an announcement effect.35

Second, much of the existing theoretical literature on R&D and pollution abatement as-

sumes that the firm which does the invention is the same as the firm which causes

pollution and invests in abatement. In fact, however, this is generally false: the vast major-

ity of the inventers are not the polluters but rather machinery suppliers and other outside

sources.36 The fact that different parties engage in invention, innovation, and pollution

abatement creates the possibility of what is known as a coordination problem (Rodrik,

1996); the coordination problem arises because each of the various actors does not knowthe others expectations and intentions. For an innovation to be successful, these expecta-

tions need to be coordinated, especially when the innovation is costly and capital intensive.

The polluting f irm must be reasonably confident it can recoup the investment if it invests in

an expensive new production process that lowers GHG emissions. The equipment supplier,

likewise, must be reasonably confident that there will be an industrial market before he

invests in commercializing this product. And the venture capitalist must be reasonably

confident that the product will be marketable if it is successfully commercialized before

he finances the R&D. Given the long time lags and high degree of technological uncer-

tainty, the coordination problem is likely to be especially severe for many GHG control

technologies. It is quite possible, therefore, that the price signal from an emission trading

programme by itself might not generate sufficient coordination; some additional policy in-struments may be required.

35 Montgomery and Smith (2007, p. 328). The findings of Glachant et al. (2009) may, however, be an indi-

cation of some degree of announcement effect associated with the adoption of the Kyoto Protocol.36 Lanjouw and Mody (1996) estimate that machinery suppliers were the source of about 80 per cent of the

patents for the control of industrial air pollution, water pollution, oil spills, and the exploitation of non-fossil-fuel

energy sources. Taylor (2008) shows that electric utilities and oil companies accounted for only about 18 per cent of

the patents for SO2 control, while 82 per cent of the patents are held by research institutions and, especially, other

entities.



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VII. The need for complementary measures

As noted earlier, not only was a reduction of more than 50 per cent in SO2 emissions ac-

complished virtually overnight, but the only policy action required of the federal government

was the minimalist one of establishing the allowance trading programme under Title IV. Thequestion arises whether the same will hold true for GHG emissionswill a minimalist pol-

icy of allowance trading alone secure the desired reduction in GHG emissions? For GHGs,

the European Union has adopted a more comprehensive approach including, in addition to

emission trading for CO2, measures to promote renewable energy; improvements in energy

efficiency in buildings, household appliances, and industry; emissions standards for new

passenger cars; and the reduction of methane emissions from landfills. Similarly, the

GHG legislation adopted by the US House of Representatives in 2009 (HR 2454, Wax-

manMarkey) has provisions relating to a federal renewable portfolio standard, energy

efficiency standards for buildings, lighting, appliances, and new motor vehicles, CCS, per-

formance standards for new coal-fired power plants, smart grid deployment, and R&D

support for electric vehicle development along with emission trading for CO2. Among theUS states, Californias programme to reduce GHG emissions, being copied by its five partner

states in the Western Climate Initiative (WCI), involves a suite of complementary measures

alongside emission trading, including efficiency standards for motor vehicles, appliances,

and buildings; renewable energy standards; a low-carbon standard for transportation fuels;

government procurement policies; and a performance standard for new long-term power

contracts.37

However, whether there should be complementary measures to deal with GHGs, or simply

emission trading alone, is a contested issue. In contrast to the WCI, the Regional Green-

house Gas Initiative (RGGI), formed by ten north-eastern and mid-Atlantic states, relies

solely on cap-and-trade covering power plants to limit CO2 emissions.38 While the

Kerry

Boxer bill currently before the US Senate adopts a broad approach similar to thatof HR 2454, the other bill before the Senate, the CantwellCollins bill, focuses more nar-

rowly on emission trading for CO2, without any complementary measures,39 and adopts an

upstream cap on fossil-fuel carbon as it enters the US economy. Also, many economists have

advocated a cap-and-trade system for CO2, or a carbon tax, unaccompanied by complemen-

tary measures other than an R&D policy.40

As noted above, the actual experience with emission trading for SO2 and lead deviated in

some significant respects from the standard economic model on which the economists re-

commendation relies. Moreover, as argued above, GHGs differ from SO2 and lead in several

important dimensions that make cap and trade alone unlikely to be as effective at accom-

plishing a large emission reduction for GHGs as it was for them.

The key fact about the past experiences with emission trading in the US is that all theemission reduction was accomplished by producers in the capped sector modifying their

37 For a description of the package of complementary measures adopted by California between 2002 and the

present, which created a template for the other members of WCI, see Farrell and Hanemann (2009). In addition to

the partner states, there are seven observer states, plus partner and observer provinces in Canada and observer

states in Mexico.38 At least 25 per cent of the allowances have to be auctioned, with auction revenues directed to strategic

energy investments.39 All of the allowances would be auctioned. Of the revenues generated by auctioning permits 25 per cent

would be allocated to a Clean Energy Reinvestment Trust which could f inance emission reduction activities.40 For example, Stavins (2007), Metcalf (2007).



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production process or reformulating the product, without any substantial increase in produc-

tion costs. The reduction in emissions was not due to price increases that choked back

demand for the product. The adjustments were on the supply side, not the demand side.

The same outcome is not likely to occur with GHGs.

With electricity generation, unlike SO2, there is limited scope for reducing GHG emis-sions from existing fossil-fuel power plants. Therefore, the main focus will have to be on

lowering the GHG emissions associated with new power plants. Renewable energy will not

assume a large share of the power sectors in the US or EU overnight. The share of nuclear

power in those countries will increase, but also not overnight. For political reasons, coal will

continue to account for a substantial share of new power plant construction, making the tim-

ing of CCS deployment and regulatory pressure for high thermal efficiency combustion

technologies important determinants of the pace of GHG reduction in the electricity sector.

Since power plants are capital-intensive and long-lived investments, it is doubtful whether

the price signal from an emissions market will, by itself, be sufficiently powerful to produce

a decisive shift in the selection of future generating capacity away from fossil fuels or, in the

case of fossil fuels, towards technologies embodying high thermal efficiency combustionand pre-equipped for CCS. Not only an R&D programme but also complementary measures,

whether performance standards for new coal-fired plants, feed-in tariffs, purchase commit-

ments, subsidies, or loan guarantees will surely be required.

Moreover, whereas demand-side management played no role in the reduction of SO2emissions, it seems clear that it will have to assume a significant role in order to attain

2020 GHG emission targets. Together, residential and commercial buildings account for

70 per cent of electricity consumption in the US. Approximately 38 per cent of the CO 2emissions in the US comes from the energy use associated with these buildings.41 The lar-

gest component of the CO2 emissions comes from the generation of the electricity used in

them (71 per cent), but emissions also arise from the direct combustion of natural gas and

petroleum, especially fuel oil. The major uses of this energy include space heating and cool-ing, lighting, and water heating.42 Thus, an effective strategy for GHG mitigation must

identify options for reducing these emissions, including both reducing emissions from the

current building stock and also tackling the buildings that will be constructed in the future.

Some of the options for reducing GHG emissions entail higher costs and investments; but

others, especially those focused on increased energy efficiency, could yield net savings.

Major opportunities for improvements in end-use efficiency include space heating (especial-

ly residential), air conditioning, lighting (especially in commercial buildings), and water

heating (especially in residences).

There are several reasons why it is doubtful whether the price signal from an emissions

market will, by itself, be sufficiently powerful to induce the improvements in end-use effi-

ciency and the reduction in CO2 emissions. One factor is the sheer fragmentation ofdecision-making, especially in the residential sector. While about 500 firms control the op-

eration of the electric power industry in the US, there are over 110 m occupied residential

41 Brown et al. (2005). Twenty-one per cent of the CO2 emissions result from residential buildings and 17 per

cent from commercial buildings. In addition, industrial buildings account for another 5 per cent of CO 2 emissions.42 In the residential sector, 30 per cent of the energy consumed is for space heating, 12 per cent is for water

heating, 12 per cent is for lighting, and 11 per cent is for air conditioning; the remainder goes for appliances,

electronics, and other purposes. In the commercial sector, the breakdown is 21 per cent for lighting, 12 per cent

for space heating, 9 per cent for air condition, and 8 per cent for office equipment; the rest goes for water heating,

refrigeration, and other purposes (Brown et al., 2005).



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housing units in the US. Of these, about 75 m are owner occupied and 35 m are renter oc-

cupied. In this context, the principalagent problem is a significant obstacle to investment in

energy-efficiency improvements. The problem arises whenever the energy user does not pay

for the cost of his energy use and/or does not choose the energy-using appliances. The latter

is not limited to rentersit can also apply to owner-occupiers.43 First, in an existing home,the building insulation, the windows, the space-heating equipment, and perhaps, to a lesser

extent, some other appliances are likely to be pre-determined and changeable only at sub-

stantial cost. Second, with the significant mobility of the US population, long-lived

investments in improving energy-efficiency may seem a risky proposition to home owners

who do not know how long they will continue to live in the home and are not sure that they

will recoup the investment if they sell it.44

In addition to the principalagent problem, there are behavioural impediments to invest-

ment by individual end-users in energy efficiency. One impediment is the high initial capital

costs of energy efficiency investments and the inability or unwillingness of consumers to

finance these, even though there is a subsequent stream of operating cost savings. Empirical

studies have demonstrated cases of high implicit individual discount rates,45 which couldreflect high rates of time preference or, alternatively, the influences of illiquidity or uncer-

tainty and risk aversion. Whatever the cause, this is not an instance of market failure. But, it

is a market opportunity. The situation could be remedied if a market intermediary were to

come forward who was satisfied with conventional rates of return, and was therefore willing

to finance the up-front capital costs of energy-efficiency investments in return for a guaran-

teed share of the future stream of energy cost savings. There is a missing actor who could

arbitrage the differential between the rate of return on energy efficiency investments and

homeowners high individual discount rates. To plug this gap, California and 15 other

states have now enacted legislation authorizing local governments to form Energy Finan-

cing Districts (EFDs) which use bond or other funds to finance residential or commercial

energy-efficiency investments and are then repaid over a set number of years through a spe-cial assessment on the property tax bills of those property owners who elect to participate

(Fulleret al., 2009).

Another behavioural impediment for individual end-users is the lack of information about

the potential opportunities for cost-saving energy-efficiency investments. Perhaps more im-

portant is their lack of attention to this potential, and its lack of salience for them. Salience is

defined in psychology as the property of a stimulus that causes it to stand out and attract

attention in its context (Fiske and Morling, 1996). This definition comprises three elements.

43 Davis (2009) compares appliance ownership patterns between homeowners and renters using US household

level data and finds that, controlling for household income and other household covariates, renters are significantly

less likely to have energy-efficient refrigerators, clothes washers, and dishwashers. In the US, leasing/rentals are alarger proportion of commercial than residential buildings, and principalagent problems arising from leasing/

renting are therefore likely to be more widespread for commercial property.44 The incomplete capitalization of energy-efficiency improvements in house values is noted by Dubin (1993).

It has been estimated that, in the US, the principalagent problem is a potential obstacle to energy efficiency affect-

ing up to 25 per cent of the energy usage associated with residential refrigerators, 47 per cent of the energy usage

associated with residential space heating, and 77 per cent of the energy usage associated with residential water usage

(ACEEE, 2007).45 For example, Hausman (1979) and Meier and Whittier (1983). It should be noted that the behavioural im-

pediments to the adoption of energy-efficiency investments are not limited to householdsthey are also found in

some businesses and other organizations. Muthulingam et al. (2009) find evidence that high up-front costs and a

short planning horizon (economic short-termism) lead managers to overlook profitable opportunities for energy

savings.



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The stimulus has to be vivid enough to be noticed by the recipient; it has to be important in

the light of her goals and interests; and whether it is vivid or important depends, in part, on

the particular context. There is a large literature in political science, mark

cap and trade hanemann

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