1 greenhouse gas emissions trading performance-based allocation for a faster, undistorted and...
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Greenhouse gas emissions trading
Performance-based allocation for a faster, undistorted and effective global carbon market
European Chemical Regions NetworkSeminar 13 February 2008
Brussels
Vianney SchynsManager Climate & Energy Efficiency
Utility Support GroupUtility provider for a.o. DSM and SABIC
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Faster realisation global carbon market
Benchmark:Specificenergy useor CO2
emission
2012 2017 2022 2027
Benchmark EU-Japan
Transition period (with 3 or more BMs for same product) avoids high cost in case of auctioning for regions with higher emissions per unit of product (vital: BMs without differentiation new/old plants)
2032
Incentive low carbon technologies the same in global trading scheme
2008
Benchmark USA-Canada
Benchmark China-India
Global benchmark
Model proposed by European Industry
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Faster realisation global carbon market
• This model is possible with global sectoral agreements• Clean Development Mechanism (CDM) –
improvements needed– Same type of project receives different quantity of credits
(“Certified Emission Reductions” – CERs) in different nations– From ambiguous baselines to benchmarks – growing list
• Globally linked markets essential – as fast as possible– Developed regions: with guarantee of total cap– Developing regions: transition, without guarantee of total capEU Emissions Trading Scheme (EU ETS) and other emerging
schemes must abandon demand of total cap for linkingRelatively few sectors cover >/= 50% of total GHG emissions, e.g.
electricity, steel, cement, refineries, paper and pulp, ceramics, glass, chemical industry
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Existing and emerging GHG trading schemes
• EU ETS 2013: 45% EU GHG emissions, broad coverage of electricity and industry
• USA– Western Climate Initiative (WCI): California + 6 US states & 2
Canadian provinces, broad coverage as well– Regional Greenhouse Gas Initiative (RGGI): New York + 9 US
states, covers only electricity– Midwestern Climate Pact (MCP): 6 US states & Manitoba
• Other emerging schemes: – Canada, Australia, New Zealand
• Japan so far reluctant for a mandatory scheme
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Cap & trade and allocation methods
• Definition of cap & trade– A cap & trade system is an emissions trading system where total
emissions are limited or “capped” (source: Point Carbon)
• Four main allocation methods
Method Cap per company Total cap
Historical grandfathering Yes Yes
Auctioning No Yes or no
Performance-based, with benchmarks
No No
Performance-based cap & trade (novel method)
No Yes
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Historical grandfathering – cap per company
• Lack of effectiveness & market distortions– Lower emissions = fewer allowances in next period (“updating”)– Distorts CO2-price signal– Distorts market share competition, winners must buy allowances– Efficient producers are to be encouraged to win market share– Unsolvable dilemmas for new entrants and closures– Closure rules enhance market concentration – esp. electricity – Economic rents for electricity producers – windfall profits
= Example EU ETS 2008-2012: at € 30/ton, € 54 billion/year calculated= At expense of citizen & EU industry
– “Leakage” of emissions, lowering production and importing product is encouraged – called “equally legitimate” !!!= Canadian J.H. Dales 1968: “Pollution in one region must never be
reduced by increasing pollution in another”= EU Commissioner Verheugen: we don’t want “export of pollution and
import of unemployment”
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Auctioning – ideal, but only if applied globally
• No problems with “updating”, market share competition, no distortion of CO2-price signal
• Problems are “leakage”, distortions and loss of competitiveness– Border Adjustments (obligation for importers to buy allowances)
not feasible (thousands of products of all value chains of steel, aluminium, chemicals, etc.) and opposed by EU Commissioner Mandelson (DG Trade), Germany, UK, USA, etc.
– With full auctioning for electricity as foreseen in EU 2013-2020 = Price effect at € 35/ton increases to € 82 billion/year
= Windfall profits remain for nuclear & large hydro: € 45 billion/year
= Logical in a global auctioning scheme, but with isolated auctioning loss of competitiveness industry, killer for aluminium, electrolysis, etc.
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Performance-based allocation - benchmarking
• No problems with “updating”, market share competition, no distortion of CO2-price signal, provided benchmarks (total CO2-emission per unit of product) are geared to product only, not to fuel, technology, age or size of production plants – then incentive same as auctioning– Fuel-specific benchmarks support the cheaper fueled coal-fired
power plants and not low carbon technologies– Allocation with one electricity benchmark for fossil-fueled
electricity related to actual production= Eliminates the windfall profits
= Encourages CHP (Combined Heat & Power) first and coal with CCS (Carbon Capture & Storage) medium term – the market decides
• Problems of “leakage”, loss of competitiveness only at very high CO2-prices, > € 125-150/ton
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Performance-based cap & trade
• Guarantee of total cap by adjusting the benchmark in the future when production was higher than forecasted– Benchmarks of a running year are always fixed ex-ante, they are
never adjusted afterwards (otherwise: unclear market)– Novel method, see appendix how this works
• Lower electricity price could create higher demand (the “production subsidy” argument), this is countered by a proper benchmark approach– In a product benchmark the efficiency of all energy carriers is
taken into account, i.e. CO2-emissions from fuel, heat (steam) and electricity
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Historical grandfathering Historical grandfathering historical mistake historical mistake• EU Commission came with a proposal for revised EU ETS Directive
in January 2008, then co-decision EU Parliament & Council – Takes 1.5-2 years, is no decision for single Member State
Allocation rules• Historical grandfathering was a historical mistake
– Finally admitted by EU Commission, March 2007
• Proposal for 3rd Trading period: auctioning for electricity & phase-in of auctioning for industry or benchmarking for industry “exposed” to global competition
• Benchmarking for allocation to companies– Ex-ante: based on historical production, announced latest 2006
2nd historical mistake– Ex-post: based on actual production, proposed by European
Industry
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New legal cases – historic production
• What means a historic cap?: import and export– More electricity import NL from Germany – is NL then doing well?– New CHP in Luxembourg – is Luxembourg doing badly?
• Nine new legal cases– What means a historic cap?: economy is strongly recovering
as we desire it to be (Lisbon strategy)– Forecast of growth in central Europe, 9 legal cases European
Court of Justice against EU Commission: Estonia, Latvia, Lithuania, Poland, Czech Republic, Slovakia (withdrew), Hungary, Rumania, Bulgaria and Malta
– Influence historic production on allocation is perverse
• Solution: benchmarks linked to actual production
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Trends in the trading schemes
• EU ETS– Abandonment of historical grandfathering– Tension between (phase-in of) auctioning and benchmarking,
threat it will be based on historical production
• RGGI with only electricity: partial or full auctioning• WCI, Australia, New Zealand
– No historical grandfathering, auctioning as vision for long term– Benchmarking in the mean time, with a total cap
• Canada: benchmarking without total cap• Japan: certainly no auctioning and no cap per company
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Conclusion – for a faster global carbon market
Method Cap per company
Total cap No total cap
Historical grandfathering
Yes, perverse incentives
Auctioning No Leakage & loss of competitiveness
Unlikely globally, regional efficiency differences
Performance-based allocation, regional benchmarks
No Main sectors of China, India, Brazil, etc.
Performance-based cap & trade, regional benchmarks
No Likely for EU, USA, Australia, New Zealand
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Let us foster innovation and global participation
Thanks for your attention !
Questions ?
References: <http://www.usgbv.nl/index.php?page_ID=7>
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AppendixEU Commission High Level Group
Competitiveness, Energy and the Environment
Clear advice HLG CEE
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HLG Competitiveness, Energy and the Environment
• High Level Group CEE members– Commissioners Verheugen, Kroes, Piebalgs and Dimas +
representatives industry, NGOs and others
• The HLG CEE advice for EU ETS on 2 June 2006– EU Commission & Member States to undertake (for
implementation in 2nd period, but this failed)= Stronger signal towards low carbon technologies= Competitiveness, reduce impact electricity windfall profits= Level playing field for new investments across EU= How can rules, notably for new entrants and closure, be more
harmonised, incl. the possibility of using a benchmarking approach
• HLG CEE 30 October 2006 confirmed statements above• HLG CEE: final conference 27 November 2007 “Towards
a global low carbon economy”
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AppendixPresent political situation
in the European Union
Historical grandfathering historical mistake
Lowering production, no benefit for environment
Industry wants benchmarks no (partial) auctioning
Leakage danger underestimated
Border Adjustments: not feasible in practice
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Historical grandfathering Historical grandfathering historical mistake historical mistake• EU Commission came with a proposal for revised EU ETS Directive
in January 2008, then co-decision EU Parliament & Council – Takes 1.5-2 years, is no decision for single Member State
Allocation rules• Historical grandfathering was a historical mistake
– Finally admitted by EU Commission, March 2007
• Proposal for 3rd Trading period: auctioning for electricity & phase-in of auctioning for industry or benchmarking for industry “exposed” to global competition
• Benchmarking for allocation to companies– Ex-ante: based on historical production, announced latest 2006
2nd historical mistake– Ex-post: based on actual production, proposed by European
Industry
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Lowering production …Lowering production …
• “Lowering Production is no Benefit for the Environment, says European Industry”Paper Alliance-Cefic-IFIEC, 21 May 2007
– EU Commission declared end 2006= Lowering production and selling freed allowances is equally legitimate than
investing in emissions reductions and selling freed allowances
– European Industry recalled founding father J.H. Dales (1968): = “Pollution in one region must never be reduced by increasing pollution in
another”
= Ex-ante allocation root cause of many distortions
= Call for link to actual production
= Italian representatives EU ETS review: “intra-period updates”
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Auctioning seems ideal facts tell different story
• 1st trading period, € 12/ton CO2
– Higher electricity cost: 2,750 mln MWh x € 5/MWh ~ € 14 billion/year– Cost of allowances: ~ zero (EU as a whole)– Economic rents electricity: ~ € 14 billion/year
• 2nd trading period, € 30/ton CO2, electricity typically 25% short– Higher electricity cost: 3,000 mln MWh x € 21/MWh ~ € 63 billion/year– Cost of allowances: 25% x 1,250 Mton x € 30/ton ~ € 9 billion/year– Economic rents electricity: ~ € 54 billion/year
• 3rd trading period, € 35/ton CO2, assume full auctioning– Higher electricity cost: 3,300 mln MWh x € 25/MWh ~ € 82 billion/year– Cost of allowances: 100% x 1,070 Mton x € 35/ton ~ € 37 billion/year– Economic rents electricity: ~ € 45 billion/year
• Auction revenues only 45% of total economic effect• Auctioning reduces economic rents with only 17%
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Benchmarks, no auctioning & solution “windfalls”Benchmarks, no auctioning & solution “windfalls”
• Industry is against auctioning 3rd trading period
– Auctioning electricity= Electricity prices remain high industry pays 40% of this bill / bad for
competitiveness / leakage
= Full auctioning 3rd period: windfalls still high (IFIEC paper 23 Nov 07)
– Auctioning industry= At stake € 27 billion/year at € 35/ton
= Bad for competitiveness, “leakage”: production & investment relocation
– Total loss of competitiveness European Industry ~ € 60 billion/year, which is ~ 50% of EU Budget
Alliance, Cefic, IFIEC, ECRN call for benchmarks and solution electricity windfall profits (letter European industry 16 Nov 07)
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Leakage danger underestimated
• Leakage analyses show serious flaws– Assumption low CO2-price, e.g. € 20/ton
– Assumption “only few sub-sectors” exposed to global competition most sectors affected
– Assumption electricity “not exposed” industry pays 40% of bill= Detrimental for especially aluminium, electrolysis, etc.
– Assumption (prosperous) recent added value no guarantee for the long period to 2020
– Assumption added value hardly relevant relevant is trade-off direct + indirect CO2-cost against transportation in Europe
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Border Adjustments: not feasible in practice
• Border adjustments– Border obligation for only most CO2-intensive part of each sector –
e.g. clinker for cement, blast furnace steel for steel, crackers for petrochemical industry no remedy for value chain optimisations
– Thousands of products affected, example chemicals and polymers until their application in final consumer goods (cars, electronic equipment, etc.)
– Import: buy allowances how much, how many products?– Export: refund of allowances how much, how many products?
Results– Hole in the total cap!– Huge bureaucracy, can never be effective
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AppendixAppendixBenchmarkingBenchmarking
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Key principle of benchmarkingKey principle of benchmarking What a CEO wants to know?
He wants to know – e.g. with cost-price: Where his plants stand?; then Why? + What can be done about it?
He refuses notions like “We are the best in the peer group of our [obsolete] technology, or in our [small] scale, or in our plant vintage” (many corrections make everyone equal)
Key principle: benchmarks relate The product … with the objective function – CO2 in the EU ETS Deviations shall be possible, but temporary and aimed to avoid
leakage outside EU (… objective function) Example: energy efficiency as objective function can avoid leakage by
switch to gas and shipping of carbon-rich fuels outside EU
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Benchmark with ex-post + guarantee total capBenchmark with ex-post + guarantee total cap
Benchmark with ex-post electricity Scenario with a higher production growth than forecasted
(without contingency reserve) Second trading period Third period2008 2009 2010 2011 2012 Total 2013 2014
FORECASTS Production fossil, TWh 2000 2034 2069 2104 2140 10346Start Benchmark, ton CO2/MWh 0,600 0,590 0,580 0,570 0,561
Total cap, Mton CO2 1200 1200 1200 1200 1200 6000Fixed Fixed
Ex-post Update production fossil, TWh 2030 2034 2090 2125 2155 10434 Update forecastover 2008 Ex-post, TWh 30
done in 2009 Ex-post, Mton 18to 2010 Allocation, Mton CO2 1200 1200 1194 1194 1194
Benchmark, ton CO2/MWh 0,600 0,590 0,571 0,562 0,554Total cap, Mton CO2 1200 1200 1212 1194 1194 6000
Fixed Fixed Fixed
Ex-post Update production fossil, TWh 2030 2045 2130 2140 2175 10520 2190 2230over 2012 Ex-post, TWh 30 11 40 25 5
done in 2013 Ex-post, Mton 18 6 23 14 3to 2014 Allocation, Mton CO2 1200 1200 1194 1191 1168 986 997
Benchmark, ton CO2/MWh 0,600 0,590 0,571 0,563 0,538 0,450 0,447Total cap, Mton CO2 1200 1200 1212 1197 1191 6000 1011 1002
Fixed Fixed Fixed Fixed Fixed Fixed Fixed
• Automatic adjustments within an ex-ante agreed total capAutomatic adjustments within an ex-ante agreed total cap• More stringent benchmarks work exactly like auctioning (& cap & trade)• System is self-adjusting; virtually no interest costs
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Benchmark takes account of all energy carriersBenchmark takes account of all energy carriers
Productionplant
Feeds
Steam
Natural gas ?Other fuel ?
Electricity
CO2 ?
Product(s)
Many energy functions can be done either with:• Steam, or• Electricity, or• Natural gas or other fuel
Benchmark takes this into account:Normalised calculation to (total)primary energy – or total CO2
Benchmark for only fuel – direct emissions – is meaningless
Examples: chemical plants, refineries, cement, paper plants, etc.
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Benchmark takes account of all energy carriersBenchmark takes account of all energy carriers
Furnaces withheat recovery
to steam
Feeds
Methane from feedstock
CO2
Separations withhigh power
compressors
Example steamcracker, simplified scheme
2/3 of the investment
Separation train can be:• Efficient, with net-export of steam of whole cracker• Inefficient, steam import• Both can be with the same direct emission of the cracker itself
(ethane,LPG,naphta,gas oil,etc.)
Power train can be:• Steam turbine driven• Electric motor driven• CombinationsHigh influence onelectricity & steam balance, direct emissions elsewhere
(ethylene, propylene, etc.)Products
Steam recovery
Electricity Steam
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Benchmark data of plants under the scheme (now EU)Benchmark between average & best performance, e.g.
Benchmark = WAE – CF x (WAE – BP)
= WAE = Weighted Average Efficiency= CF = Compliance Factor, to comply with total cap= BP = proven Best Practice, proven means actual measured operational
data (or rather BP Group, for extra stimulation of innovation)
Formula coincides with EU ETS Directive Annex III (3), average emissions and achievable progress for each activity
Industry opposes following alternative Related only to BP (BP + X%) – too short allocation, contra-incentive
to improve BP, effectiveness & innovation
Suitable benchmark formulaSuitable benchmark formula
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Benchmarks in a direct emissions schemeBenchmarks in a direct emissions scheme
Allocation = direct emission – emission {total plant – total BM}
Productionplant
Feeds
Steam
Natural gasOther fuels
Electricity
CO2
Product(s)
Site utilities have also benchmarks
Example 1:
• Net-import of secondary energy carriers:
70 – {120 – 100} = 50Plant worse than benchmark
Example 2:
70 – {90 – 100} = 80Plant better than benchmark
See formula in ANNEX
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Benchmarks in a direct emissions schemeBenchmarks in a direct emissions scheme
Easy inclusion in an ETS No conceptual problem in a direct scheme and no legal problem with
Directive, on the contrary
Allowances according to deviation with benchmark In formula:
A = RDE + RSE – Σ production x (REE/RCE – benchmark) x CCF= RDE = Realised Direct Emission (ton CO2)
= RSE = Realised Sequestered Emissions (ton CO2)
= REE/RCE = Realised Energy Efficiency (GJ/ton product) or Realised CO2
Efficiency (ton CO2/ton product)
= Benchmark = benchmark energy (or CO2) efficiency
= CCF = CO2 Conversion Factor (= 1.0 in case of CO2-benchmark)
Note: Process emission is in this view included in the Best Practice
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Recent legal case
• Germany against EU Commission (judged 7 Nov 2007)– Germany contested the prohibition of the EU Commission to apply ex-post
adjustments (also in 1st & 2nd guidance note)– Germany asserted that the whole Directive – also art. 10 and Annex III – does
not forbid ex-post, provided total cap ensured
– Court of First Instance fully confirmed German case– Findings of the Court a.o.:
= “…, neither the incentive for operators to reduce their emissions nor the certainty in respect of investments made for this purpose is affected by the ex-post adjustments, quite the reverse.” (para 128)
= “The Commission was wrong in asserting at the hearing that this recital [20] did no more than “record” a desirable future effect … only a “subordinate objective” … “whether the ex-post adjustments at issue are compatible with … recital 20 … the Directive “will encourage the use of more energy-efficient technologies … producing less emissions per unit of output.” (para 139)
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Quality of historic data for operatorsQuality of historic data for operators
Variations in annual load factors over five years, found in
UK by consultant NERAfor UK government
… with climate change instruments based on history?
Historic production tells nothing about the futureHistoric production tells nothing about the future
Link to actual production: Avoids distortions Avoids windfall profits Solves problems new entrants and closures
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New legal cases – historic production
• What means a historic cap?: import and export– More electricity import NL from Germany – is NL then doing well?– New CHP in Luxembourg – is Luxembourg doing badly?
• Nine new legal cases– What means a historic cap?: economy is strongly recovering
as we desire it to be (Lisbon strategy)– Forecast of growth in central Europe, 9 legal cases European
Court of Justice against EU Commission: Estonia, Latvia, Lithuania, Poland, Czech Republic, Slovakia (withdrew), Hungary, Rumania, Bulgaria and Malta
– Influence historic production on allocation is perverse
• Solution: benchmarks linked to actual production
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Benchmarks with ex-post
• Few benchmarks provide high coverage= E.g. electricity, cement, refineries, steamcrackers, etc.
• Real benchmarking is easier that often assumed= Output related, same BM for incumbents & new entrants
• Benchmarks with link to actual production, solution for:= Leakage, level playing field, no insecurity for new entrants, no
transfer rules, no windfall profits, free market without cartel problem
= Works as effective as auctioning
• European Industry at ETS Directive review meeting= How to ensure total cap= How it works in the electricity market
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Setting total cap 2013-2020 – effectivenessSetting total cap 2013-2020 – effectiveness
• Total cap may appear to be too stringent– Renewables behind target, higher economic growth than expected,
etc. very high CO2-price
• Total cap may appear to be too soft– Reverse of possible causes above very low CO2-price
Ex-ante frozen allocation not effective
• Solution– Contingency reserve if cap too stringent for example 100 Mton– No loser benchmarks if cap too soft– Can be done in any allocation systemTarget is to maintain a realistic CO2-price to ensure a robust and
predictable EU ETS for companies to reduce emissions
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Benchmarking same effectiveness as auctioning (1)Benchmarking same effectiveness as auctioning (1)
Incentive to reduce emissions is independent of the exact value of benchmark in a certain year
Incentive = avoided purchases + sales of allowances
Example:Investment to reduce emissions from 900 to 600 kg CO2 per unit of product (in old plant or new plant)
• Year 1, BM = 750: incentive = 150 + 150 = 300• Year n, BM = 700: incentive = 200 + 100 = 300
Predictability of investment climate
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Benchmarking same effectiveness as auctioning (2)Benchmarking same effectiveness as auctioning (2)
Same benchmarks for incumbents and new plants Recognised by EU Commission
Avoids= Distorting transfer rules
= Barriers to entry
= Enhanced market concentration
Ensures= Equal incentive for plant improvement & plant replacement
No “maximisation” or “minimisation” rules, see e.g. Matthes (NL 110% and 85% now)
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References: <http://www.usgbv.nl/index.php?page_ID=7> • “Climate change challenges and the search for a sustainable policy”, 21 June
2005, 8th International Conference on Carbon Dioxide Utilisation (ICCDU-VIII) 20-23 June 2005, Oslo, Norway.
• “Options and consequences for the allocation of allowances to electricity producers”, 21 December 2005, European Chemical Region Network (ECRN) presidium meeting 21-22 December 2005, Maastricht, the Netherlands.
• “Towards a simple, robust and predictable EU Emissions Trading Scheme – Benchmarks from concept to practice”, 21 March 2006, presented to the Dutch Ministry of Economic Affairs.
• “The EU ETS is urgently in need of: effectiveness, level playing field, competitiveness, fair & free competition”, 4th Congress of the ECRN, 10 November 2006, Tarragona, Spain, including:– “One single benchmark for fossil-fuelled electricity in an Emissions
Trading Scheme: does it work, does it hurt and what about alternatives?”.– “How to fit benchmarks with ex-post adjustments in the present EU
Emissions Trading Directive”.• “Auctioning for electricity seems ideal – but the facts tell a different story”, by
Annette Loske (VIK - Germany) and Vianney Schyns• “Interpretation outcome legal case Germany against EU Commission
concerning ex-post adjustments”, by Jan Berends (Royal DSM) and Vianney Schyns