International Emissions Trading Association

The International Emissions Trading Association (IETA) supports the objectives of the United Nations Framework on Climate Change. On its website, it states that it is dedicated to climate protection, “the establishment of effective market based trading systems for greenhouse gas emissions by businesses that are demonstrably fair, open, efficient, accountable and consistent across national boundaries, and maintaining societal equity and environmental integrity while establishing these systems.” . In its objectives it states that it aims to establish “The Clean Development Mechanism” and “Joint Implementation and emissions trading”. This is the development of a cross borders, global greenhouse gas market which involves flexible mechanisms and systems, supposedly ensuring effective business participation. It aims to be “the premier voice for the business community on emissions trading”. As part of its remit it hopes to provide the latest information on emissions trading, participate in the design of and implementation of international rules and guidelines, and promote the emissions trading system as a solution to climate change.

In order to achieve these objectives, the IETA states that it aims to focus on key areas. The first area is the development of the Greenhouse Gas market and trading systems. The second is to promote market mechanisms, and participation within those markets. Lastly they aim to develop of a Global Greenhouse Gas market.

In order to achieve these goals, the IETA has established a number of working groups, workshops and seminars. These have looked at topics such as trade agreements, taxation and accounting. It acknowledges the need to promote market mechanisms and trading, selling it as a viable solution to minimise social impact within sustainable development. In doing this, it fully cooperates with the World Business Council for Sustainable Development (WBCSD) and the World Economic Forum (WEF) .

IETA history and Background

The IETA emerged from the United Nations Conference on Trade and Development (UNCTAD) Policy Forums on greenhouse emissions trading in 1999. It’s birth was formed through cooperation of the UNCTAD and the World Business Council for Sustainable Development (WBCSD). It became a non profit organisation in 2000, and received United Nations Framework Convention on Climate Change (UNFCCC) NGO accreditation in late 2000. It currently has offices in Geneva, Switzerland, Brussels, Belgium, Ottawa, Canada and Washington DC, USA.

IETA Board members

IETA Chairman; Jack Cogen, President, Natsource; ETA Vice Chairmen; Paul Dawson, Head of Environmental and Regulatory Affairs, Citigroup, David Hone, Group Climate Change Adviser, Shell ; Directors; Bruce Braine, Vice President,Strategic Planning & Analysis,AEP Georgia Callahan, General Manager, Environment and Climate Change, Chevron, Karen Degouve, Head of the European Carbon Fund, Natixis, Steve Drummond, Managing Director, CantorCO2e, Andrei Marcu, Former IETA President & CEO Arne Mogren, Head of Public Affairs, Vattenfall Lasse Nord, Senior Vice President, Climate and Environment, Norsk Hydro, Wendy Poulton, General Manager, Corporate Sustainability, Eskom, Louis Redshaw, Head of Environmental Markets, Barclays Capital, Masayuki Sasanouchi, Project General Manager, Environmental Affairs Division, Toyota, Gudmundur Sigurthorsson, Senior Vice President, DNV, Lee Solsbery, Director, Global Energy and Environment, ERM,Marc Stuart, Director, Ecosecurities, Luis Trevino, Electricity Development Director, CEMEX, Patrick Verhagen, Senior Vice President, Environmental Relations, Holcim, John Wells, Vice President, Environment, BP..

Aims

The IETA aims to do the following things with regard to a future carbon market. It seeks to ensure that the system design, and its implementation, delivers a fit for purpose market. According to its own set of guiding principles, this includes. “(1) Transparency of design and operation. (2) Sufficient scale to operate and deliver emissions reduction. (3) No artificial barriers to access or participation. (4) Low transition costs and limited bureaucracy.(5) Delivery without intervention (ie no price caps or price floors, no artificial supply barriers such as limits on the use of reduction units from projects). (6) Adequate offset availability (7) A fair and equitable allowance allocation process that does not withdraw capital from the firms and industries covered by the scheme, nor grants windfall profits. (8) Recognition of the important link between the holder of allowances and the initiation of actions that create the reductions. (9) The need for trading systems to recognise all verifiable key abatement technologies, including Carbon Capture and Storage. (10) That the release of market data is well managed”. The IETA tries to fill the gap between business and government. This requires bringing together different people from different sectors, as well was information in order for it to interact with different institutions. In order to do this, the IETA has a number of working groups. “These working groups are chaired and co-chaired by representatives of the IETA members and report their findings to the IETA board and its members. This particular format has proven to be very successful and have established IETA as a credible source of knowledge for the different institutions such as UNFCCC, World Bank, European Commission, National Governments and the CDM Executive Board”.

The working groups are numerous and global, with the four geographical regions of the EU, US, Australia, and Canada each having their own working groups. Other working groups including the IETA CMD Executive board working group, the IETA Validation & verification working group, the IETA VCS working group, and the Aviation Working group. .

EU ETS Working group

This group, after the EU ETS started in 2005, have been reviewing EU directive 2003/87/EC, which established the cap and trade emissions market in the EU. This group meets regularly so that institutions and organisation involved in carbon trading can receive expert advice and new positions and ideas. This group deals with various issues and conveys certain messages. It’s main themes are; “ the lessons learned, the long term signals - lead times of business cycles, allocation methodologies (benchmarking, grandfathering and auctioning) . NAP (National Allocation Plans) developments and assessment process, member states implementation of linking the emissions trading directive JI and CDM. Defending the relevance of competition for industry, input to the commissions upcoming guidelines on the second round of NAP’s (2008-2012). Expansion of the scope of the directive, inclusion of other sectors and other gases. Unilateral inclusion by Member States of installations/ other gases. Thresholds for small plant, and single interpretation of installation” .

US Working Group

The irony of the whole issue of carbon trading comes to light with the situation in the United States. Even though ETS has essentially been a neoliberal agenda, the process of achieving a carbon market is much younger there. This group have been working with American business and government while congress and senate debated the Lieberman-Warner Bill. This is essence brings the US carbon market into being. This group have been heavily involved throughout the legislative process of bring the market into being. At all times it has focused on various aspects of the white papers presented to government. It has been involved in developing guide lines on what sources would be included, what type of emissions, what type of targets, what type of monitoring reporting and validation mechanisms can be utilised, registration provisions for American business, as well as what sort of penalties would be involved in the newly born market. As COP-15 approaches, this group has focused more on how the American market would best be tied in along other markets such as the EU ETS, and other markets such as China and India. .

IETA’s CDM Executive Board Working Group

The Clean Development Mechanism (CDM) was an integral part of the Kyoto Protocol. As a result, the IETA has a working group which works specifically on this area.

This is one of the largest working groups within the IETA. It brings together the members of IETA to respond to the actions of the CDM Executive Board. This group is presently working on the following areas of concern.” (1) Providing a platform of the members to get inside information on the meetings of the CDM Executive Board based on the IETA CDM Executive Board memo’s and verbal reports of the IETA secretariat (2) Coordinate and submit any call for public comments by the CDM Executive Board (3) Bring to the attention of the CDM Executive Board issues of concern of the IETA membership and (4) Liase with other Observers that are involved in the CDM Executive Board. This group has been heavily involved in negotiations surrounding CDM. For example , companies like B.P. Chevron and Statoil have financed the group to research the legalities and powers of the COP/MOP and Executive Board in respect to CDM.. This group is currently chaired by Wendy Poulton of ESKOM andDick Forrister of Natsource.

IETA’s Validation & Verification Working Group

This group works on accreditation, validation and verification with regard to compliance programs that are developing around the world. It seeks to develop audit protocols and methods, and a harmonised way of verification under the EU ETS. It also works on developing guidelines for GHG auditors and also their training. It looks to bring about a standardised validation process and verification and accreditation..

VCS Working Group

This group works on the design and implementation of the Voluntary Carbon Standard. This it is suggested is “to provide a credible but simple set of criteria that will provide integrity to the voluntary carbon market, and to provide the protocol and criteria to verification entities and emissions reduction project developers on creating, verifying, and registering Voluntary Carbon Units”.

Aviation Working Group

This group has been very busy in negotiation surrounding the work program on inclusion of the aviation sector in EU ETS and resolving the relevant monitoring reporting and verification and compliance issues surrounding EU directive 2008/101/EC of the European Parliament which amends Directive 2003/87/EC and thus brings the aviation industry within the EU ETS. ”. This group seeks to provide guidance for the aviation industry. It hopes to identify the steps needed so that the industry can implement changes in the most cost effective, efficient, and timely manner.

IETA on the road to COP-15

On the road toward COP-15, the IETA has focused its attention on expanding the EU ETS, and globalising carbon trading as a measure against climate change. It has taken a keen interest and an ever more important role in negotiations as to what will replace the EU ETS. In a letter dated 6th March 2007, from Andrei Marcu, President of the IETA, to Commissioner Stavros Dimas it states “In particular, IETA is encouraged by the recent progress in bringing Phase II allocation plans into line with Kyoto targets and with the upcoming review process. IETA is pleased to have received your invitation to the first meeting of the ECCP working group on emissions trading on the review of the ETS and will most certainly attend. Internal IETA discussions are ongoing in order to canvas a wide range of our members’ opinions and experiences so that we may present a rounded and well-informed point of view”.

The letter then continues to outline that the IETA’s position at the forthcoming meeting will be one in which it will reiterate the importance of transparency with regard to ETS. As well as this, the importance of increased harmonisation between member states and their adherence to current as well as future targets would be encouraged. An expansion of the current scheme, with the most efficient and effective way to include other sectors and gases would be considered. As well as the long term allocation and investment periods, a streamlining of verification processes would have to be recognised. The full and free use of Kyoto Credits, stronger world-wide emission reduction targets would also have to be considered. In earlier reviews of the implementation of the EU Emissions Trading process, the IETA when considering revision of Directive 2003/87/EC states “It is possible that the formal revision of the directive by co-decision procedures may not allow agreement in time for implementation before 2013. However, necessary improvements can be agreed by coordination, or by Member States and the Commission in the Climate Change Committee to allow modifications to be implemented during the 2008-2012 2nd period. As a general principle, IETA would not be in favour of any opening of the directive before the formal review, except for narrow, well-defined technical issues”.

The IETA has sought to gain influence throughout negotiations, as part of its response to COP-10 the IETA released a document regarding CDM entitled “Lessons learned in the Green Development Mechanism”, in this review of the ten years since Marrakech, the IETA emphasise the critical role that CDM has in the current architecture of Global emissions market. It also states how crucial CDM will be to any future regime that may emerge post 2012. The article then continues by stating that in order to safeguard the CDM implementation process a Business Advisory group be created within the CDM Executive Board, “which would include business representatives of high standing, and which would work with the existing structures”. Hence strengthening business influence in the overall process. ”.

The CDM has become central to the IETA’s agenda for a post 2012 agreement on Carbon Trading. Insisting on more international trading, the CDM is a seen as a way of encouraging this, as well as sustainable development in underdeveloped regions. The idea of CDM was taken on in order to lower the cost for participating countries as they try to meet their emission targets, as well as help developing nations develop sustainability through technological transfer. “The rules governing the CDM were finalised in 2003 and are contained in the “Modalities and procedures for a clean development mechanism (CDM M&P) in the Marrakech Accords, the decisions of the CDM Executive Board and subsequent decisions of the Conference of Parties (COP). They where consequently adopted during the first Meeting of Parties (COP/MOP) in Montreal 2005. The rules governing the CDM state that projects must meet requirements in order to qualify as CDM”.

These include compliance to the sustainable criteria and project approval process, project validation and monitoring, verification and certification, as per the rules of issuance of Certified Emissions Reductions (CER’s), the IETA sees expansion of the CDM as key to the success of a post 2012 agreement. As a result, the IETA have released on the build up to COP-15 two articles. The first one is entitled “Principle for a Post 2012 International Climate Change Agreement”, and the other is “New Emission Reduction Mechanisms: Filling in the Details and bringing in the Public sector”. These two articles are effectively designed to remind the world’s climate negotiators, including those who were in Bonn, as well as those who will be at Copenhagen, that the markets can put their enthusiasm, know-how and ingenuity to work in regard to emissions reduction. They call for the reform of the existing CDM, for its continuation, and expansion, for a fair and effective transitional regime where mechanisms are created. They call for careful planning of new financial mechanisms to ensure the private sector and the carbon market are given incentive. They warn against offsets or reducing the markets efficiency by unnecessary regulation. They urge the use of market led approaches to solving problems.

The IETA has continued to increase its influence and participation within the negotiations which have been taking place. Alongside this it has been running various workshops and conferences. As well as IETA workshops in Houston , it has had conferences in San Diego and Prague so far this year. Up coming events before COP-15 include co organisation of Carbon Expo 2009 in Barcelona and the African Carbon Forum in Nairobi in September.

About Emissions Trading

The system advocated by the IETA “restricts the aggregate allowable amount of pollutant and allows market forces to continually move the allowed emissions to the highest value uses” .

In this system of market transactions, the main driving force is the relative prices of emission reduction opportunities among participants. An example of this can be seen in a company having a low cost solution to reducing its own emissions, it will not use up its own emissions allocation, it can then sell the unnecessary allocation to another company, supposedly one which is struggling to meet its own allocation. As the IETA states, “Many different forms of trading have evolved. However, the underlying theme is to provide entities with the flexibility to determine the most economic means to reduce emissions. The diversity of trading markets is primarily a consequence of the products traded and the scope of the market” .

Here, Greenhouse gas reductions are seen as a commodity which can be traded. Reductions may refer to actual emission reduction, avoiding emissions, or creation of “carbon sinks” (eg sequestration). The IETA stresses that greenhouse gas reduction is NOT an emissions credit, and that no such system exists today. Greenhouse Gas trading is very similar to other trading markets, although the IETA admits that the rules governing what exactly constitutes an emission reduction are still in development. “Buyers of emission reductions are, in effect, making investments in existing or proposed projects and businesses that are expected to result emissions reductions, in the anticipation that these reductions will someday be eligible for credit by the appropriate international and/or domestic legislative bodies”. Transactions within the market range from simple purchases and sales, to more complicated structured transactions. These include Immediate settlement (straight forward sale or purchase with immediate payment), Forward settlement (reductions and payment deferred to a future date), and Options (this allows the buyer to lock the right to purchase reductions at a future date at a specified price, or the seller to lock in a set future price.. “The IETA’s membership is currently 181 companies out of which 51% represent project developers, intermediaries, financial institutions, brokers, verifiers, legal firms, and others engaged in new economic activity as a result of the GHG market. The balance of 49% represents industrial organisations”. In 2005, the European Union established the European Emissions Trading Scheme , based on EU directive 2003/87/EC, it is the largest multi-country, multi-sector Greenhouse Gas emission trading scheme world- wide, the scheme is mandatory for all EU member states.

Principles for a post 2012 International Climate Change Agreement

In a document with the above title , the IETA outlines its positions and views on a new agreement to replace the Kyoto protocol, which it will advocate during COP-15. “These positions explicate how the agreement could best draw in private sector participation and capitalise upon the strengths of the private sector in addressing climate change efficiently and effectively” .

In this document, the IETA outlines various issues, including its goals and targets, commitment to a period duration for the new agreement, new forms of commitment, flexible mechanisms, and Carbon Market Design. Here, the IETA states that it “believes that the parties should agree firm targets for the next commitment period; indicative medium term (~2030) targets that lay out a series of ‘rolling targets’ for subsequent commitment periods; and long term (~2050) global goals”. The IETA advocates the choice of commitment periods of eight years, this is so that long term investment is possible, it also advocates flexibility in order to tie in targets with scientific or political developments. It is also argued here, that any changes to differentiation among the parties (eg. new countries being included) MUST be guided by clear criteria made explicit in the new agreement, new forms of commitment such as ‘sectoral targets’ be agreed after careful consideration. Flexible mechanisms are argued for, with the IETA supporting continued operation, reform and expansion of the Kyoto Protocol’s flexible mechanisms, essentially emissions trading, the Clean Development Mechanism, and Joint Implementation. “The IETA supports the development of new flexible mechanisms to further encourage critical private sector investments in the areas of emission reduction, and technology development and deployment”. It is also suggested that the decisions made by the parties when replacing Kyoto MUST work alongside decisions made by national and regional governments, and that ambition levels and the extent and nature of regulation will prove critical to the success of the proposed market.