Energy and Climate Change
Reaction to the tiered approach to carbon leakage protection
The signatories (see below), energy-intensive industries express concerns regarding the so called “tiered approach” to carbon leakage protection under the EU ETS
The tiered approach1 would reserve free allowances for some sectors at the expense of others. It goes against the principle set in the October European Council Conclusions that best performing companies in ETS carbon leakage sectors should not bear further carbon costs. Indeed, it would ensure that even best performers in most sectors would bear significant carbon costs and expose them deliberately to carbon and investment leakage.
The proposed tiering has no environmental or economic justification and is based on flawed assumptions (“cost pass-through”) of in reality unpredictable market dynamics. Depriving sectors of carbon leakage provisions would not deliver decarbonisation through investment and innovation. Moreover, it could well prove to have been entirely unnecessary. All forecasts, including the Commission’s Impact Assessment, predict that there will be sufficient allowances available to ensure full free allocation to benchmark levels at least until 2025: and there are other proposals for ETS reform that would deliver full and effective carbon leakage protection without the need for arbitrary discrimination.
To that end, we continue to support an approach based on realistic benchmarks, allocation based on more recent production data and an adequate reserve that ensures full allocation to benchmark levels. The proposed share of allowances to be auctioned shall also be recalculated downwards, as analysis of the EC proposal shows, it does not properly include the number of allowances which were to be given out for free (i.a. unallocated and left-over NER allowances).
In the circumstances, the “tiered approach” would introduce an unnecessary and unfair discrimination between sectors. Fairness and solidity should become key principles of policy making. Jobs in one sector are neither more nor less important than those in other sectors. The signatories fully share and support the BusinessEurope views on tiered approach as expressed in a statement on April 14th.
We ask you to create a framework that gives all sectors an equal opportunity to compete and thrive in Europe, and not to pick certain sectors to stay in Europe. It would undermine our industry’s faith in, and support for, the ETS as a means of reducing carbon emissions.
For further information please contact Peter Botschek, Cefic Director Energy & HSSE, e-mail email@example.com
1 i.e. as presented in a Non-paper on a Tiered Carbon Leakage List in Phase IV of EU ETS (authored by France, the United Kingdom)
Global Forest Products Industry is Part of the Solution to Climate Change
São Paulo – The International Council of Forest and Paper Associations (ICFPA) and its members welcome the signing of the landmark United Nations agreement to tackle climate change, set to take place on April 22. The agreement urges countries to implement policies that would allow them to keep a global temperature rise below 2 degrees Celsius. The global forest products industry has a highly significant role to play in the implementation of these targets.
“The global forest products industry has made significant strides in reducing its carbon footprint, stocking carbon, and generating greenhouse gas removals – all helping to mitigate climate change”, said ICFPA President and Brazilian Tree Industry (Ibà) President Elizabeth de Carvalhaes. “This agreement is crucial to implementing some of the policies that consider biomass as carbon neutral when harvested from sustainably managed forests and to further recognize all positive contributions that forests and forest products provide in combating climate change.”
The inherently-renewable global forest products industry remains committed to mitigating climate change for the benefit of the green economy and society at large. ICFPA members have achieved an impressive 5% reduction in their greenhouse gas emissions intensity since 2010/2011 and 17% since the 2004-2005 baseline year (2015 ICFPA Sustainability Progress Report).
The European pulp and paper industry has been a global champion in mitigating greenhouse gas emissions. It has set itself in 2011 a clear vision of becoming carbon neutral by 2050 and since then, taken concrete steps to reach that goal,” said Jori Ringman, Acting Director General of Confederation of European Paper Industries (CEPI). “Thanks to responsible sourcing practices and sustainable forest management, the forest area is growing in Europe by an area of over 1,500 football pitches per day. CEPI is pleased to see development in the same direction globally”, he added.
The forest industry’s significant role in mitigating climate change was highlighted in the ICFPA-commissioned report Analysis of Forest Contributions to the INDCs by acclaimed researcher Paulo Canaveira. Having looked at the contributions of forests in the national targets of ICFPA member countries (INDCs) and global mitigation effort from 2020 onwards, the report concludes that many countries identify forests and the land-use sector as relevant to policies and measures implemented to meet their targets. Reducing emissions from deforestation, but also sustainable forest management, afforestation and reforestation are commonly mentioned as key mitigation practices. In some developing countries, they even constitute the country’s main contributions.
Other climate change mitigation efforts of the global forest products industry include supporting national and regional climate policies and programs; investing in technologies with low carbon footprints and ones that improve carbon sequestration; and developing bio-based technologies to find innovative ways to use wood fiber and substitutes for goods traditionally made from fossil fuels.
Note to the editor:
The ICFPA represents more than 30 national and regional forest and paper associations around the world. Together, ICFPA members represent over 90 percent of global paper production and more than half of global wood production.
For more information about the global forest and paper industry, visit icfpa.org.
Joint declaration by a group of industry associations “2016, time to deliver… an ambitious power market reform”
The signatories of this declaration gather leading associations and industry groups with a clear stake in Europe’s energy policy. We share the conviction that only a flexible and dynamic energy system, making the best use of innovative and distributed supply and demand options, can ensure a cost-efficient and sustainable transition towards a decarbonised energy system.
We strongly believe that a market-driven environment is the best means to provide long-term investment signals while meeting all system needs and accommodating the growing share of renewable energy in the energy mix. The completion of the Internal Energy Market will improve system adequacy and efficiency, increase security of supply, support the competitiveness of European industry, and help deliver the energy and climate goals stemming from the COP 21 agreement and EU’s post 2020 objectives on emissions reductions, energy efficiency and renewables.
However, we see many constraints persisting in the energy sector that affect investment decisions, in particular: 1) depressed wholesale market prices due to overcapacity; 2) fading EU-coordination of energy policies with a tendency towards renationalisation; and 3) an antiquated set of market rules.
Market rules have been tailored to centralised production within national boundaries for too long. Not only have they failed to adapt to developments in energy technologies and evolution of demand patterns both at industry and end-consumer level, but some of them hamper the deployment of renewables, storage and demand-side flexibility. These new technologies can today provide valuable services including balancing energy offering significant flexibility to the system.
The energy system is now more complex to plan, control and balance. It needs enhanced flexibility that could be provided by a mix of options, but this would require significant changes in the relevant legislation. In this respect, we consider the upcoming legislative package on market design as a unique chance to provide the energy sector with a predictable investment framework, fairer market conditions, and ultimately seize new opportunities arising from decentralised energy production and demand side participation.
In particular, we deem essential that any ambitious reform of the energy market addresses the following issues:
1. Providing adequate price signals and further integration of short-term markets across borders
2. Ensuring a balanced approach to system adequacy that fully takes into account the contribution from renewable energy supply and demand sources
3. Implementing a level playing field for all flexibility providers to foster the pan-European trading ofelectricity and grid support services.
1. Providing adequate price signals and further integration of short-markets across borders
In a well-functioning electricity market, unhindered price-formation drives operational choices and investment decisions. Transparent and undistorted market prices must be in place in all time horizons, and allowed to move freely without caps. Wholesale electricity prices reflecting scarcity would signal the need for investments in new capacity. Therefore, price spikes should be treated as a positive sign of an efficient and cost-effective energy system where market participants are free to choose the level of hedging they prefer to contract, revealing the true value of flexibility and energy at all times.
Market rules also need to be adapted so as to enhance clean and flexible energy providers to trade power over broader geographical areas and as close as possible to the time of delivery. In this context, the opening and cross-border integration of intraday market is essential, especially for energy producers whose output is variable. A as long as separate procurement of balancing capacity and energy is guaranteed, another important aspect is the possibility to negotiate the duration of contracts, e.g. for balancing contracts. This is crucial, as certain flexibility technologies may require considerable capital investment and, therefore, contracts with a longer duration.
2. Ensuring a balanced approach to system adequacy that fully takes into account the contribution from different energy sources
The main challenge for security of electricity supply is not the availability of capacity as such, but the availability of flexibility that is needed to support the system and provide for a constant balance between supply and demand.
In order to identify potential, locally constrained adequacy issues, system adequacy assessments should be carried out according to a common methodology and metrics transparently defined in EU legislation1. Such analysis should be performed at regional level and consider the potential of all flexibility options, from the various energy supply and demand sources. This would ensure a rigorously needs-based approach to the introduction of Capacity Remuneration Mechanisms (CRMs) when the market cannot not deliver the adequate flexibility.
If CRMs are deemed necessary, they should be designed in a way that minimises any negative impacts on price formation on energy markets. They should avoid contributing to continued overcapacity situation by keeping redundant and polluting power plants online, and prioritise clean flexibility options as foreseen in the energy state aid guidelines.
3. Implementing a level playing field for all flexibility providers2 to foster the pan-European trading of electricity and grid support services
In addition to the modernisation and further opening of the balancing market, a proper market for ancillary or grid support services needs to be fostered to provide additional non-discriminatory revenue streams to flexibility providers, as well as overall operating cost savings for the energy system. As of today, a number of services and solutions from decentralised generation and demand-side response are technically feasible, but current market conditions do not properly value their commercial provision.
The continued adaptation of balancing and ancillary services markets should foster liquidity and incorporate innovative and decentralised solutions. Prohibitive pre-qualification requirements and access conditions for independent aggregators, extended product-durations or minimum thresholds and symmetric bids are some of the aspects currently hampering an effective market. Moreover, contradictory regulatory signals, e.g. regarding network tariffs, the operation of industrial loads or co-generation should be addressed to ensure demand side flexibility further develops without impeding the achievement of robust energy efficiency targets.
1 Incl. a clear system adequacy target level for all control areas in the EU as many countries are lacking one
2 “A service provided by a network user to the energy system by changing its generation and/or consumption patterns in response to an external signal” (Task Force Smart Grids report, 2015)in
European Paper Industry continues to reduce its carbon emissions
Preliminary estimates based on today’s publication of the Verified Emissions and Compliance Data for the year 2015 show that carbon emissions in the pulp and paper industry in 2015 fell by at least 1% compared to 2014. Compared to 2005, the year the EU Emission Trading Scheme came into force, absolute emissions fell by 27%.
With production levels remaining substantially the same in 2015, emission reductions were primarily driven by market consolidation, investments in bioenergy, and the push from international competition to improve efficiency in production processes. And with energy being the second main component in the cost structure, reducing energy-related costs, such as CO2 emissions, is a priority to secure an internationally-competitive position.
"We have been early-movers in low-carbon investments and have further plans to grow our business in Europe, building synergies with Circular Economy as well as the Bioeconomy”, says Jori Ringman, CEPI Acting Director General. “The EU ETS should support such efforts which are completely in line with its overarching scope of transforming the industries. Therefore the EU ETS should continue to improve the predictability of the regulatory framework, by promoting and rewarding investments in low-carbon technologies”, he added.
The European Paper Industry currently receives 1.4% of the total allocations for manufacturing sectors, while employing over 6% of the manufacturing industries’ workforce and being responsible for over 5% share of investments in Europe.
For more information, please contact Annie Xystouris at firstname.lastname@example.org, mobile: +32 486 243 642.
EU ETS: Three reasons why the Tiered Approach is bad for the EU economy
The non-paper jointly drafted by the French and British government on tiered free allocation arbitrarily determines which sector has a future in Europe and which sector has a future outside Europe.
Specifically, the proposal has three major critical points:
1. It is unjustified from both an economic and a fairness perspective
The proposal pretends to adequately ensure protection against the risk of carbon leakage. However, it reduces the share of free credits to the vast majority of industrial sectors, without providing any evidence of the impact of additional costs on their competitiveness. The proposal particularly lacks of any cost comparison between a given European and a non-European sector.
The proposal reduces the amount of free credits to certain sectors, as a supposedly fair gesture towards some others who would otherwise receive too little protection. Yet, some other sectors would unjustifiably be excluded from such a “solidarity clause”. This is far from being a fair approach.
2. It penalises competitive industries investing in low-carbon technologies
Protection against the risk of carbon leakage should provide the regulatory certainty for industries in transition towards a low-carbon economy.
However the tiered approach rewards the most carbon intensive and least profitable sectors. This is intrinsic in the formula used, which rewards high carbon intensity combined with low value added (GVA).
On the contrary, the formula punishes a sector investing in carbon emission reductions by giving a lower protection against the risk of carbon leakage as a direct consequence of these investments.
3. It hampers innovation
The ETS is expected to ultimately promote the substitution of high-carbon with low-carbon production. In this respect, solutions may come from within a given sector or as a cross-fertilisation of ideas coming from other sectors. One example is the potential coming from the bioeconomy or circular economy to provide solutions to decarbonise other sectors.
However, the proposed tiered approach provides different carbon cost exposure to different sectors, with the paradox that the most carbon intensive will bear the least carbon costs. As a consequence, the investment signal from the ETS will be totally jeopardised.
Sectors which successfully invest in decarbonising their processes are systematically at risk of being pushed outside the EU.
Alternatives to the tiered approach
Discussions on tiered free allocation are triggered by the need to avoid the application of the Cross-Sectoral Correction Factor (CSCF). The timing and magnitude of the CSCF are far from being certain, as it depends on a combination of factors (production levels, changes in the market, technological developments, innovation, development of international carbon markets, etc.).
Rather than picking one scenario and fixing the rules for the next 15 years accordingly, the EU should:
1. Define a regulatory framework that stimulates and rewards investments in low-carbon technologies, as a way to reduce the demand for free credits;
2. Support programmes to accelerate the market-readiness of breakthrough technologies for industrial installations;
3. Secure a sufficient amount of free credits to allow for low-carbon economic growth in energy intensive industries exposed to international competition;
4. Set rules to predictably assess potential shortages in the supply of free credits and, when the case, explore all possible options to preserve industrial competitiveness.
For more information, please contact Nicola Rega at email@example.com mobile: +32(0)485403412.
Consultation on the Review of Directive 2012/27/EU on Energy Efficiency
This consultation was launched to collect views and suggestions from different stakeholders and citizens in view of the review of Directive 2012/27/EU on energy efficiency (Energy Efficiency Directive or EED), foreseen for the second half of 2016. The full consultation replies can be found here.
Here are some highlights:
In reviewing the EU energy efficiency target for 2030, the Commission should have in mind that energy efficiency has to be achieved by voluntary initiatives, rather than by mandatory requirements. An EU-wide binding energy saving target until 2030 would limit the scope for economic room to manoeuvre. A rigid objective as a binding cap on energy consumption would impede growth. Therefore, it is of vital importance that the Commission designs the target in such a way that recognises early measures and focuses on lowering the energy intensity, not the energy use as such. The European framework has to create ideal long-term conditions to realize energy efficiency measures covering all sectors. This is particularly important for the non-ETS sectors, where incentives to improve energy efficiency are often insufficient. Effective incentives are needed, especially for research and development as well as for the cost-efficient implementation of investments in energy efficiency measures.
In view of achieving the new EU energy efficiency target for 2030, we believe that energy efficiency work must be done locally and as close to the energy consuming unit as possible. The role of the EU should therefore only be limited to setting targets, creating the overall regulatory framework, monitor the process in terms of energy efficiency improvements and give non-binding advice to those countries that are not able to reach the given goals. But details on how to implement energy efficiency policies need to be formulated at national or even industry level.
The EU should also promote and finance research and innovation in the field of energy and process technology to enable breakthrough technologies.
Regarding the most appropriate financing mechanisms to significantly increase energy efficiency investments in view of the 2030 target, it is important to find a high efficient way of financing. To make sure that the highest possible potential is tapped with the available amount of money, it is important to prefer energy investment funding for measures with high returns on investment. One way would be to support investment in form of cheap call money from a revolving fund for efficiency measures that would otherwise not take place without support. Ensuring that the invested money always returns to the fund (e.g. oney is paid back to the fund in the same rate as the energy savings pay back), allows multiple use of the available budget and therefore enables highest efficiency.
Interest-free loans to finance investments are also a way to achieve energy efficiency measures.
Tax decrease/benefit could also be envisaged if companies are participating in energy efficiency programs and achieving results.
Income from auctioning of emission rights should also be used to finance energy efficiency measures.
CEPI's response to EU Commission's Preparation of a new Renewable Energy Directive for the period after 2020
In its Energy Union Framework Strategy, the Commission announced a new renewable energy package for the period after 2020, to include a new renewable energy directive (REDII) for the period 2020-2030 and an updated EU bioenergy sustainability policy. This consultation covered the REDII aspects. You can find the fully completed consultation here.
Here are some highlights:
CEPI believes that the RED has been successful in deploying large volumes of renewable energy sources. However, the costs directly and indirectly associated to such deployment in most Member States have been quite significant. The energy
prices gap with competing economies has widened, with policy-induced costs being particularly relevant in electricity prices. This has a negative impact on industrial competitiveness, as acknowledged by the 2014 Commission Guidelines on State aid for environmental protection and energy 2014-2020. Weather dependent renewable energy, solar and wind, is remarkable and growing challenge to secure availability of electricity.
The RED has also led to measures promoting the demand for bioenergy, not sufficiently taking into account the availability of wood for the wood processing industry, which is producing substitutes to fossil fuel based and more carbon intensive products. This negative impact on the competitiveness of the wood processing industry is hampering the uptake of the bio-economy and
its climate change mitigation potential. Support to bio-energy should rather focus on stimulating the supply of wood.
Member States have a responsibility to ensure that additional demand for bioenergy is met by supply of raw materials, taking into account local biomass availability. Therefore demand-side measures should be balanced with supply-side measures to mobilise existing additional potential of wood that can otherwise not be used for wood and fibre based products. Reference could be made to the biomass mobilisation brochure jointly developed by DG AGRI, Forest-Europe and the UNECE-FAO.
EU ETS: Six steps to ensure industry’s competitiveness
The EU ETS reform, published on 15 July, presents several positive elements that contribute to improving the predictability of the regulatory framework. However, these improvements are not yet sufficient in protecting the competitiveness of energy intensive industries, ensuring adequate regulatory stability and predictability, and in stimulating investments in low-carbon technologies.
From 2005 to 2014, our industry has reduced carbon emissions by 26%, resulting in 21% carbon-intensity reduction. We have been early-movers in low-carbon investments and have plans to grow our business in Europe, building synergies with circular economy and the bioeconomy.
To bring environmental protection in line with industry competitiveness, we ask to:
1. Remove artificial cap on free credits to industry.
Artificially capping access to free credits depresses future investments: it means acceptingdeindustrialisation as a legitimate way to reduce emissions in Europe, even if this wouldincrease Europe’s carbon footprint in the world.
The artificial cap will also lead, sooner or later, to the application of the cross-sectoralcorrection factor (CSCF). This is the most unfair among all instruments, as it cuts allocationirrespective of industry potentials, neutralises carbon leakage provisions, limits predictability,and punishes investments made by early movers.
2. Keep the proposed approach to benchmarks review, but improve key design aspects.
The benchmark review needs to predictably promote and reward investments in low-carbontechnologies, while finding the right balance between accuracy and administrative burden.Reducing benchmarks at achievable paces, with rules clearly stated upfront, will lowerregulatory risks and reward the installations who will invest in low-carbon technologies.
Looking at the administrative burden, the pulp and paper industry, with more than 700installations in the ETS – 60% of which below 25kt – emitted just 31.6 MtCO2 in 2014.Roughly 1.4% of total ETS emissions. Yet, it is the 2nd biggest sector for number ofbenchmarks (11), covering only about 50% of industry production – the rest being under theso-called fall-back approach. It is self-evident that opting for a full review of benchmark valuesinstead is disproportionately costly while only delivering marginal accuracy improvements.
This is why we look favourably at the approach proposed by the Commission. However, manyparameters need to be reviewed and/or clarified, starting with:
•Linearity of the reduction factor;
•Disruptive impact in moving from one reduction pattern to the other;
•Avoid/reduce administrative burden in data collection and verification;
•Fairly assess progresses for installations in fall-back approaches.
3. Grant to all energy-intensive industries equal protection against present and futurerisks of carbon leakage.
Industry is either exposed to global competition or not: there is no middle ground. In thiscontext, the Commission proposal seems reasonable. Moreover, it is worth noticing that therest of the world does not impose comparable costs on energy intensive industries, withcarbon leakage provisions appearing also in other non-EU countries.
4. Adopt binding EU rules for compensation of indirect carbon costs.
Indirect carbon costs affect industrial international competitiveness as much as direct carboncosts do. The principle of equal treatment in shielding industry from both carbon costs musteffectively and consistently apply in all Member States.
5. Stop penalising investments in industrial Combined Heat and Power (CHP).
In the pulp and paper industry CHP is considered as Best Available Technique. Installations are therefore expected to use this technology. Today however the EU ETS does not send the right investment signal to invest in industrial CHP: the EU ETS grants no free credits for electricity produced and no consistent and adequate compensation for indirect carbon costs is given across Europe either. Given the relevant co-benefits CHP delivers in moving Europe towards a low-carbon economy, corrective measures to provide the right investment signal are urgently needed.
6. Earmark innovation and modernisation funding to energy intensive industries.
The earmarked 450 million allowances is the largest industry innovation fund ever. To deliverits full potential it should be linked to the goal of 2050 sectoral roadmaps, and aimed at thedeployment of new technologies for each Annex I sectors. The modernisation fund should alsoprimarily support low-carbon technologies in industry.
For more information, please contact Nicola Rega, Climate Change and Energy Director, at firstname.lastname@example.org, mobile: +32 485 403 412
Global Forest and Paper Industry Releases Policy Statement on Climate Change
The International Council of Forest and Paper Associations (ICFPA) today released its statement on climate change ahead of the UN Framework Convention on Climate Change meeting (COP21) in Paris, France. The statement presents the contributions of forests and the forest products industry to the mitigation of global climate change and calls on governments to recognize these contributions. The full statement is available at: http://bit.ly/1MPD7ax.
The ICFPA will elaborate on the forest products industry’s efforts at a COP21 side-event – “Assessing transparency and ambition in the land use and forestry sector”, held at the EU Pavilion on December 1 at 2:30 pm. The side-event will be hosted by the ICFPA and the EU Joint Research Centre.
“Forests and the global forest products industry have a key role in helping to mitigate climate change. A low carbon economy has to consider the forest industry as a contributor to climate solutions”, said Marco Mensink, Director General of the Confederation of European Paper Industries (CEPI). “With this policy statement, we are encouraging national governments to recognize and foster all positive contributions that forests and forest products provide in combating climate change.”
The industry has made significant contributions to mitigate climate change. In addition to greenhouse gas (GHG) removals and stocking carbon in products, ICFPA members have achieved an impressive drop in their GHG emissions intensity: 5 percent since 2010/2011 and 17 percent since the 2004-2005 baseline year, as shown in the ICFPA 2015 Sustainability Progress Report (2013 data).
The statement calls on governments and the parties to the UN Framework Convention on Climate Change to recognize sustainable forest management and reforestation activities for their contribution to the global climate effort, as well as the recognition of the efforts and achievements of the forest products industry to mitigate climate change, including the carbon neutrality of biomass harvested from sustainably managed forests and the need to provide for market-based mechanisms capable of valuing mitigation actions to incentivize the industry’s potential contribution.
The ICFPA’s statement is the latest in a series of policy statements underwritten by its members associations. All ICFPA policy statements are available at icfpa.org/resource-centre/statements.
The ICFPA serves as a forum of global dialogue, co-ordination and co-operation. Together, ICFPA members represent over 90 percent of global paper production and more than half of global wood production. For more information, visit icfpa.org.
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ETS falls short of expectations
The Juncker Commission today launched the largest industrial policy decision it will take in its entire mandate, with the new proposal for the EU Emission Trading System. The proposal has a number of good elements but falls short in its protection of energy intensive industries. Member states hold the key to the solution.
In October 2014 the European Council recognised that measures to protect energy intensive industry from carbon leakage should be maintained when revising the EU ETS. The Council concluded the most efficient installations in sectors such as the pulp and paper industry should not face undue carbon costs that would impact their global competitiveness.
Member states however added expectations on the revenues they want from the EU ETS. Today’s proposal therefore fixes the share of auctioning vs. the share of free allocation. “The proposal shows the member states cannot have their cake and eat it. If policy makers in Brussels and the member states are serious on growths and jobs, the fixed share of free allocation should be changed to really protect industry as agreed by the Heads of State”, said Marco Mensink, CEPI Director General.
CEPI does appreciate the focus on low carbon investments and support for technology and innovation in the new proposal. The use of more accurate production data is good, even though the proposal could be more ambitious. CEPI also believes the linear reduction of the benchmarks used for free allocation is reasonable and improves predictability.
The proposal does however not solve the lack of free allocation for Combined Heat and Power Plants in Europe, which has been an additional factor in closing down very carbon efficient gas-fired energy plants in Europe. The pulp and paper industry is a leading CHP sector, producing over 50% of its electricity consumption by itself.
Finally, the proposal strengthens the focus of member states on compensation for higher electricity costs to industry, but does not lead to a harmonised EU approach, which is what the internal market requires. Member States have to align their compensation schemes, so industry is treated equal across Europe.
The European Pulp and Paper Industry is a globally competing sector, with over 700 installations covered by the EU ETS. Total sector fossil CO2 emissions were 31 Million tonnes in 2014, already reduced from 43 Million tonnes of CO2 in 2005. The sector has a clear focus on breakthrough technology programmes through its 2050 Low Carbon Roadmap for the Forest Fibre Sector. “Sufficient carbon leakage protection is essential, especially for sectors that want to invest in low carbon technologies in Europe. In order to reduce emissions, we need to be attractive for investments”, concluded Marco Mensink. CEPI calls upon the policy makers to rethink their approach.
For more information, please contact Marco Mensink at email@example.com, mobile +32475769388
Note to the Editor
CEPI aisbl - The Confederation of European Paper Industries
The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 505 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 920 paper mills. Together they represent 23% of world production.
The competitiveness of energy intensive industries is a pre-condition for EU growth
The competitiveness of energy intensive industries is a pre-condition for EU growth
Brussels 15 July 2015: Energy intensive industries are voicing concern about their capacity to remain competitive and attract investment in Europe following the publication of the Commission’s proposal for the reform of the EU Emissions Trading Scheme (ETS). We call on EU policy makers to ensure that the post-2020 carbon leakage provisions fully offset direct and indirect costs at the level of best performers with no cross sectoral correction factor.
The Alliance of Energy Intensive Industries supports the fight against climate change and the Commission’s ambition to transform the EU into a competitive, low-carbon economy. Our industries play an instrumental role in delivering the technologies and solutions to reach that common goal.
The ETS is an important tool to be used in achieving this common ambition. However, the initial assessment is that the Commission proposals’ contents are inadequate. They elicit severe concern for energy intensive industries as they undermine the EU’s own key priorities on investment, job creation and growth in Europe.
Energy intensive sectors are capital-intensive. A large part of their investments are geared towards energy efficiency, decarbonisation and emission reduction efforts, in full support of the Climate and Energy Package 2030. However, securing these investments and preventing them from leaking outside of the EU requires strong carbon leakage provisions.
The current Commission proposals fall short on this requirement. In particular, fixing the auction share means shrinking available free allocations for manufacturing industry. Under the proposed rules even Europe’s most carbon-efficient installations in exposed sectors would face significant direct and indirect carbon costs.
We call on the Council and the Parliament to reform the ETS system in such a way that the economy can resume growth and that the most carbon efficient undertakings are not incurring a carbon cost penalty.
Notes for Editors
The Alliance of Energy Intensive Industries represents over 30,000 European companies and four million jobs in the EU. Our industries are at the core of the EU economy and the starting point of multiple value chains, such as the car industry, fuels, buildings, energy production, including renewable energies, food and drinks, and pharmaceuticals.
For more information, please contact AEII’s members directly.
• European Chemical Industry Council (CEFIC): www.cefic.org/
• European Cement Association (CEMBUREAU): http://www.cembureau.be/
• Glass Alliance Europe: www.glassallianceeurope.eu/
• Confederation of European Paper Industries (CEPI): www.cepi.org/
• Chlor-alkali Industry in Europe (Euro Chlor): www.eurochlor.org/
• European Steel Association (EUROFER): www.eurofer.eu
• FuelsEurope: www.fuelseurope.eu
• International Federation of Industrial Energy Consumers (IFIEC Europe): www.ifieceurope.org/
• European Ceramic Industry Association (Cerame-Unie): www.cerameunie.eu/
• European Association of Metals (Eurometaux): http://www.eurometaux.be/
• European manufacturers of gypsum products (Eurogypsum): www.eurogypsum.org/
• Fertilizers Europe: www.fertilizerseurope.com
• European Lime Association (EuLA): http://www.eula.eu/
• European Expanded Clay Association (EXCA): http://www.exca.eu/
• Association of European ferro-Alloy producers (EUROALLIAGES): www.euroalliages.com/
Strategic choices for ETS Post-2020: Allow energy intensive industries to be competitive and grow in Europe
The Alliance of Energy Intensive Industries, representing over 30.000 European companies and 4 million jobs, wishes to be an active contributor in the upcoming revision of the EU ETS. This paper contains Alliance proposals on carbon leakage protection, free allocation principles and competitiveness under ETS Phase IV to ensure simple, fair, predictable and effective rules i.e.:
- Carbon leakage protection needs to be the first element of the ETS revision based on the same criteria and assumptions as under Phase III, as well as on technically and economically achievable benchmarks;
- An EU-wide harmonized system must be put in place, which fully off-sets direct and indirect costs at the level of the most efficient installations in all Member States; therefore, no cross-sectoral correction factor should be applied to free allocation;
- Allocation methodology must be closely aligned with real/recent production levels;
- Innovation support must be extended to industrial sectors;
These principles are fully compatible with the March and October 2014 European Council Conclusions and reflect the industry contribution to the Commission questionnaire, following the meeting with Commissioner Arias Cañete in February 2015. Those principles are further detailed below.
Best industrial performers must not be penalized by ETS allocation rules
The concept of declining free allocation for industry is in contrast to the need for full protection against carbon leakage and should not serve as a justification to reduce protection. The limit on the total issuance of allowances in ETS sectors defined by Heads of State and governments covers both free allocation and auctioning. They did not impose a decrease of free allocation as such. On the contrary carbon leakage provisions should be improved in order to encourage carbon-efficient production and growth in Europe, and allocation must be guaranteed at the level of realistic benchmarks. Only predictable and effective carbon leakage measures will enable companies to invest in innovative solutions in Europe.
Accordingly there should be no direct and indirect cost at the very least at the level of most efficient European installations in sectors at risk of carbon leakage.
The effect of the cross sectoral factor (CSCF) is that even the best performers cannot achieve these levels due to economic, technical or thermo-dynamical limits. Ignoring this turns the EU ETS into a penalty system rather than an incentivising system.
For that reason, all our sectors call for a deletion of the CSCF, in accordance with the European Council conclusions of 23-24 October 20141.
Current carbon leakage assessment methodology remains valid
The carbon leakage risk will not decrease and may well increase on the contrary:
- It can currently not be expected that there will be a large breakthrough in negotiations at international level that would lead to climate policies, imposing equivalent carbon costs for industries located in competing regions.
- Meanwhile, the GHG reduction target will be increased to 43% for EU ETS sectors compared to 2005 levels (meaning that the cap will be tightened)
- The Market Stability Reserve will result in rapid carbon price increases.
All Energy Intensive Industries should receive full protection at the level of the benchmark. Consequently, the quantitative and qualitative carbon leakage risk assessment criteria and assumptions as defined in 2008 remain fully valid and must remain unchanged. Energy Intensive Industries are characterised by long investment cycles. The carbon leakage list must only be updated at the beginning of each trading period.
Also, since the risk of carbon and investment leakage remains as acute as ever for EU industry, introducing differentiation in the level of protection will lead to unequal and incomplete protection for sectors at risk, and could have negative repercussions on EU industrial value/supply chains.
Establishing technically and economically achievable benchmarks
The benchmarks should be updated maximum once, ahead of each trading period to provide planning certainty for participants, decrease the administrative burdens and provide an appropriate reward for those that have invested in emissions efficiency.
The update of the benchmark values should be based on data collection from the EU companies. The process of establishing benchmarks must be as transparent as possible. If in a sector, no relevant changes in technology have taken place, such sector can request a simplified approach for data collection.
These benchmarks have to be representative for the sectors and based on representative technologies that have been adopted by the European market. Over-ambitious benchmarks artificially increase costs to industry overall and de facto undermine the effectiveness of the carbon leakage provisions. The current rules are already very stringent, as benchmarks are set according to the average of the top 10% most efficient installations in the sector; hence, even without the cross-sectoral correction factor, around 95% of the installations have to purchase allowances.
Indirect carbon costs need to be fully compensated throughout Europe
The current implementation of carbon leakage measures to deal with indirect carbon costs has resulted in a fragmented approach as eligible sectors exposed to electricity price increases due to carbon costs may only receive from few Member States a partial financial compensation. This creates an uneven playing field in the internal EU market, and creates a disadvantage for those installations that are not receiving any, or only partial, compensation, vis-à-vis extra-EU competitors.
While designing the new system, several measures/principles should apply:
- EU-wide harmonized system, which fully off-sets indirect costs (100% of the CO2 cost-pass through in electricity prices) at the level of the most efficient installations in all Member States and reflects most recent production levels. Sectors with a fall-back approach should also be properly treated.
- Cost compensation could be assured using different complementary mechanisms (free allocation and/or harmonised financial compensation).
- Mechanisms should ensure predictability over the entire trading period by being described in the revised directive. The current system is unpredictable, as it relies on a state aid compensation assessment, and is granted annually, digressive and uncertain for future years.
- The eligibility assessment for such an EU-wide scheme should be based on a consistent methodology that identifies qualified sectors on the basis of their exposure to indirect carbon costs or their total electro-intensity.
- As indirect costs arise from the price setting mechanism prevailing in the power sector (marginal price setting), an EU-wide compensation scheme should be in place without delay.
For the longer term, the Commission should also assess the possibility of redesigning the electricity market in a way that prevents carbon cost pass through in electricity prices to sectors at risk of carbon leakage.
System based on real/recent production must replace the ex-ante straightjacket approach
Moving to an allocation methodology closely aligned with real/recent production levels would provide the required allowances at the level of the benchmark to companies expanding or restarting production to avoid undue costs, help prevent over- or under-allocation, stop rewarding ETS participants for moving production overseas and ensure simplified and fairer rules as regards new entrants, capacity increases or decreases, plant rationalisation and partial cessation. For example, the reference period could be the rolling year n-2. The required production data are already available as verifiers have to ascertain the activity data needed for the allocation. The bureaucratic burden will be therefore minimal.
For installations covered by fall-back approaches as opposed to benchmarks, emission reductions resulting from efficiency measures should not result in a penalty.
Creating a reserve for growth
To ensure sufficient availability of allowances for free allocation for industry, a reserve for growth would be needed. This reserve for growth would act as a buffer to ensure predictable access to both free allocation and auctioned allowances.
There are several ways to operate this proposed reserve for growth:
- It can be filled with unused free allowances due to lower production in phase III, back-loaded allowances, un-allocated allowances from New Entrants Reserve. Then it can provide allowances for growth in case of higher production.
- In addition, the Market Stability Reserve could also be used as the source for granting such allowances, if it would be designed as a sink for unused allowances from which allowances could be released for said purpose.
Support to innovation
The extension of innovation support to industrial projects is welcome. However, it should not happen at the detriment of carbon leakage protection by reducing or limiting the amount of free allocation. Industry exposed to carbon leakage risk will struggle to invest or innovate without predictable efficient carbon leakage protection.
The revenues from auctioning should be reinvested for low carbon technology support, as foreseen in the ETS Directive, or energy efficiency, but more importantly they should be used by Member States to stimulate economic growth and relevant R&D investments. Innovation funding under EU ETS should be allocated to energy intensive sectors appointed in Annex I of the directive. The NER400 should be technology-neutral and refer instead to R&D and deployment of new technologies for those Annex I sectors.
In order to achieve a realistic policy and to allow for effective reduction of emissions, there is a need to identify the abatement possibilities in the industry (linked to technological, thermo-dynamic and physical/chemical limits that cannot be overcome due to feedstock, process emissions and lack of break-through technologies). Some sectors have already developed 2050 decarbonisation roadmaps, in which transformation technologies are mentioned. A dedicated fund taking into consideration these abatement possibilities will bring innovative technologies (e.g. industrial breakthrough technologies, including CCS and CCU for industry) forward and secure buy-in of industry sectors.
Industry needs an objective impact assessment for Phase IV ETS
In light of the better regulation policy of the new Commission, an objective impact assessment on the different European energy intensive industries is crucial, taking into account their ability to reduce emissions (low carbon roadmaps). Any flawed impact assessment could lead to wrong policy decisions for the energy intensive industries in Europe.
1 See legal opinion on article 2.9 by Luther of April 2015Download here
Consultation response on the revision of the EU Emission Trading System (EU ETS) Directive
Background: On 24 October 2014, the European Council agreed on the 2030 framework for climate and energy, including a binding domestic target for reducing greenhouse gas (GHG) emissions of at least 40% in 2030 as compared to 1990. To meet this target, the European Council agreed that the emissions in the EU Emission Trading System should be reduced, compared to 2005, by 43%. A reformed EU ETS remains the main instrument to achieve the emission reduction target. The cap will decline based on an annual linear reduction factor of 2.2% (instead of the current 1.74%) from 2021 onwards, to achieve the necessary emission reductions in the EU ETS. The European Council furthermore gave strategic guidance on several issues regarding the implementation of the emission reduction target, namely free allocation to industry, the establishment of a modernisation and an innovation fund, optional free allocation of allowances to modernise electricity generation in some Member States.
The strategic guidance given by European leaders on these elements will be translated into a legislative proposal to revise the EU ETS for the period post-2020. This constitutes an important part of the work on the achievement of a resilient Energy Union with a forward looking climate change policy, which has been identified as a key policy area in President Juncker's political guidelines for the new Commission.
The purpose of this stakeholder consultation was to gather stakeholders' views on these elements.
CEPI's Key messages :
- The ETS in general, and the benchmarks in particular, should reward installations and sectors reducing GHG emissions, without penalising early movers, new investment made, and low-carbon economic growth. Fiscal and legislative stability and predictability are needed to enable investments in low-carbon technologies.
- The pulp and paper industry cannot pass through carbon costs to its customers: the global market of export goods sets prices, not the production costs of the European industry. This can be easily verified by the lack of correlation between carbon prices and final product prices.
- For “direct carbon costs”, free allocation is a necessary condition but not sufficient to avoid carbon leakage: support mechanisms should be set up to help the EU industry improve its energy efficiency and reduce its GHG emissions.
- Concerning “indirect carbon costs”, it would be better for a mandatory and harmonised EU-wide compensation scheme to address the impact of rising electricity costs due to ETS in all Member States. Financing of compensation schemes should include also, but not be limited to, auctioning revenues from ETS.
- Support for innovation in industry should not come at the expenses of carbon leakage protection: funding for innovation will have to come on top of free allowances for industry. It should be directed to directly finance large-scale demo and pilot projects, as well projects close to commercialisation stage (TRL 6-8). These are high risk, high capital investments where the private sector would not be able to deliver without the backing of public financing.
- The role that European industry plays in the circular economy and in the bioeconomy is of strategic importance for Europe’s access to raw materials and reducing Europe’s carbon footprint. This should be acknowledged when reviewing the EU ETS, by addressing the ETS impact on prices and availability of raw material, such as wood.
Read the full reponse.Download here
CEPI applauds European Commission’s Energy Union Package
Last chance for energy markets - Member states’ support key to its success
The Confederation of European Paper Industries (CEPI) strongly welcomes the Energy Union Package published today by the European Commission. CEPI especially welcomes the emphasis put on delivering competitive energy prices, investing in the bioeconomy and establishing synergies between the energy efficiency, resource efficiency and circular economy policies.
“This package is the last chance to make energy markets in Europe work”, says Marco Mensink, CEPI Director General. The success of the Energy Union no longer depends on the Commission, but on member states’ willingness to “walk the talk”. CEPI expects national governments to urgently give their support to make the package a reality. A strong EU energy regulator is part of the solution. “In this case, ‘more Europe’ is the answer to the industry and consumers’ need for affordable and competitive energy,” he added.
The package not only recognises that energy costs for industry in Europe are uncompetitive, it also acknowledges that the root of the problem lies in the levies, taxes and additional costs energy consumers are charged for by the member states. If no measures are taken, the need for capacity payments will add yet another layer of costs, affecting all European energy consumers.
CEPI has great expectations for a number of key elements to be later defined in the package proposal. The Commission indicates renewable support schemes would need to be rationalised. The system of subsidies for burning wood for energy can no longer be sustained. Furthermore, establishing an EU biomass supply policy is urgently needed. In addition, energy recovery from waste should be limited to non-recyclable fractions, in line with the waste hierarchy and the requirements for separate collection.
Among the first proposed actions, the Emission Trading System reform offers the possibility to turn the ETS into a tool that rewards investments in low-carbon technologies, while ensuring industrial competitiveness. Engaging industry in this process is crucial. Moreover, the Energy Union should support industrial co-generation, recognising its role in delivering demand side flexibility. This should be part of the combined initiative on the internal energy market, together with the review of the Energy Efficiency Directive and the Guidelines on State Aid for Environmental Protection and Energy.
For more information, please contact Annie Xystouris at firstname.lastname@example.org, mobile: +32(0)486 243 642.
Note to the author:
European Commission: Energy Union: http://ec.europa.eu/priorities/energy-union/index_en.htmDownload here
Alliance of Energy Intensive Industries renews calls for ‘carbon leakage’ protection
The Alliance of Energy Intensive Industries (AEII) has published an open letter to the heads of State and Governments of the EU Member States, the European Parliament, the Council of the European Union and the European Commission on carbon leakage. CEPI is part of this alliance.
The 2030 climate and energy framework must guarantee predictability for industry by setting the principles for measures against carbon and investment leakage now.
The undersigned manufacturing industries are the foundation of Europe’s economic fabric, drivers of jobs and growth in Europe. We represent over 30 000 companies in the EU with more than 4 million direct jobs, and around 30 million jobs in our manufacturing value chains.
The EU should focus on promoting recovery and growth of industrial production in Europe, in line with the objective to reinstate industry’s share of EU GDP to 20% by 20201. European industries need a stable and long term legislative framework that effectively combines EU climate ambition with EU industrial competiveness.
Current carbon leakage provisions under the EU Emissions Trading Directive, if not revised rapidly, will result in a huge shortage in free allowances and increasing direct and indirect costs (the pass-through of carbon costs into power prices) for even the most efficient installations in Europe. In the period from 2021 to 2030, when the provisions against carbon leakage and free allocation would be phased out, our industries are expected to face hundreds of billions of Euros in direct costs and costs passed through in electricity prices.2 The impact on energy intensive industries will simply be overwhelming.
Knowing that the Commission will be looking at “an improved system of free allocation of allowances with a better focus” for 2021-2030 is not enough. Industry needs a clear outline of policy measures to effectively prevent the risk of carbon and investment leakage.
The Commission’s legislative proposals currently only cover EU ETS structural reforms, which increase both carbon prices as well as the unilateral burden on EU industry, and expose EU jobs and growth to aggravated carbon leakage risk. Unfortunately, the Commission intends to publish proposals to prevent carbon leakage only at a later stage.
This is contrary to the guidance resulting from the March 2014 European Council, instructing the Commission “to rapidly develop measures to prevent potential carbon leakage in order to ensure the competitiveness of Europe's energy-intensive industries”, and this to provide by October 2014 “the necessary stability and predictability for its economic operators”.
The European Parliament stressed in February 2014 “that the 2030 climate and energy policy targets must be technically and economically feasible for EU industries and that best performers should have no direct or indirect additional costs resulting from climate policies; [that] the provisions for carbon leakage should provide 100% free allocation of technically achievable benchmarks, with no reduction factor for carbon leakage sectors.” 3
We therefore urge the European Council to give guidance at its summit on 23/24 October confirming that carbon leakage measures will be continued after 2020, as well as outlining the principles for the level of protection in order to safeguard predictability, investment certainty, jobs and growth in Europe:
Until a global agreement on climate change provides for a level playing field for energy intensive sectors at risk of carbon and investment leakage, best performers should not be penalised by direct or indirect additional costs resulting from the framework. This implies:
- Truly 100% free allocation based on technically and economically achievable benchmarks (including heat and fuel based benchmarks), reflecting recent production, and without a correction factor.
- Harmonized off-setting of all CO2 costs passed through into electricity prices in all Member States.
The Market Stability Reserve must only be considered in conjunction with the above measures, instead of through piecemeal approach.
The undersigned energy intensive industries are all at risk of carbon and investment leakage and therefore must be safeguarded through the above measures.
These measures provide the essential signal towards industry for predictability and investment certainty, and secure an environmentally and economically sound EU ETS which does not distort the market. We strongly believe that these measures, together with strong innovation funds to support breakthrough innovation in industrial technologies and processes, will offer a win-win situation for the global climate and the European economy.4
1 European Commission Communication "For a European Industrial Renaissance", COM(2014) 14/2
2 The Commission expects a price of €40/tCO2 in 2030, modelling presented by Point Carbon expects ca. €48/tCO2 (source: www.ceps.eu/taskforce/review-eu-ets-issues); Climate Economics Chair calculates a price of up €70/tCO2 in a high scenario in its report EU ETS reform in the Climate-Energy Package 2030: First lessons from the ZEPHYR model, Paris 2014.
3 European Parliament resolution of 4 February 2014 on the Action Plan for a competitive and sustainable steel industry in Europe (2013/2177(INI))
4 The agreement on the reform of the EU ETS between the Dutch government, industry and NGOs proves that a compromise and a balanced solution between the pillars of EU sustainable policy – growth, jobs, and environmental protection – is possible by applying an allocation more closely linked to economic reality e.g. a dynamic emissions trading system.
Europe should support, not hamper EU industrial competitiveness
CEPI comments on the draft EU guidelines on environment and energy aid
It is unwise to raise costs for the industry to promote competition in the internal market, by doing so Europe will lose competitiveness in the global market.
CEPI therefore calls the European Commission to urgently modify the proposed draft guidelines on environment and energy aid for 2014-2020, in order to:
• allow 100% aid intensity for cogeneration;
• do not cap exemption from electricity price increases due to support for renewables;
• do not change definition for energy intensive industry.
The Guidelines on environment and energy aid for 2014-2020 will be an essential tool for reaching the ambitious 2020 energy and climate goals in a cost-effective manner. It is therefore important to promote low-carbon investments while preventing distortion of competition.
The European Commission should scrutinise the impact of proposed measures on the overall EU industrial competitiveness. Preventing intra-EU distortion of competition is important. But in a global competitive market, EU industry is faced with costs unmatched by other economies.
CEPI asks the European Commission to urgently correct three main issues.
First, allow 100% aid intensity for cogeneration.
The European Commission cannot adopt interpretative guidelines derogating from EU law. Art. 15 of the Council Directive 2003/96/EC (the so-called “Energy Taxation Directive”) specifically allows Member States “total or partial exemptions or reductions in the level of taxation” for energy used and electricity produced from combined heat and power generation (so-called “cogeneration” or “CHP”). However, the draft guidelines propose restricting investment and operating aid for cogeneration installations (from para. 17 onwards).
Such a restrictive interpretation is not only contrary to EU law, but also to the overarching 2020 energy-climate policies, where promotion of cogeneration is a key element of energy efficiency policies. It is arbitrary, inappropriate and acts as a disincentive for cogeneration, and the promotion of energy efficiency.
Second, do not cap exemption from electricity price increases due to support for renewables.
The draft state aid guidelines propose capping aid for industry at 85% for increased costs to support renewable energy sources (RES). This proposal in unacceptable for two main reasons:
1. From an environmental perspective, there is no link between the additional cost associated to RES promotion and the behavioural change expected by the beneficiary (industry) to achieve this environmental objective. Although RES contribute also – but not exclusively – to the environmental objective, the redistribution of costs within society is a social policy, where competency lies with the Member States;
2. The cost of promoting RES varies across Member States, even for the same technology. The cost depends on geographical conditions and on the way it fits into other cost components in the electricity bill, such as: national energy mix, network charges, other taxes and levies. Tackling just one component of the overall electricity price will not address intra-EU competition. On the contrary, an additional cost promoting RES set at EU level has the potential of further increasing market distortion.
Third, do not change definition for energy intensive industry.
The Energy Taxation Directive clearly defines “energy-intensive business” a business entity “where either the purchases of energy products and electricity amount to at least 3,0 % of the production value or the national energy tax payable amounts to at least 0,5 % of the added value” (Art. 17).
However, the draft state aid guidelines introduce a different definition of energy intensive industry, setting higher thresholds (10% trade intensity and 5% tax costs/gross value added). The new thresholds are based on carbon leakage criteria set in the EU Emission Trading System (ETS).
Such an interpretation is arbitrary and conceptually not correct. The carbon leakage criteria are meant to protect EU industry from unmatched costs from third countries. It looks at global competition. The state aid guidelines look at intra-EU competition. The basis for assessing distortion of competition cannot be the same.
The definition of energy intensive industry in the state aid guidelines needs to match the definition in the Energy Taxation Directive to avoid legal uncertainties distorting the internal market.
For more information, please contact Nicola Rega at (email@example.com)Download here
Focus is back on industry in EU policy, but will it work?
The fact that the 2030 Energy and Climate package includes an analysis of energy costs and was published together with the European Industrial Renaissance Communication is a landmark shift in EU policy. The Confederation of European Paper Industries (CEPI) interprets this as a signal showing the European Commission is starting to take industrial competitiveness seriously. However, there are still important steps to be taken.
In practice, this new package will not change the competitiveness of industry in the short run. The high pile of documents released by the Commission analyses and promises, but at the end it only proposes one legal act – the change of the EU ETS. In this regard, CEPI welcomes the Commission proposal to keep EU ETS unchanged up to 2020 to give the necessary stability for investments in EU industry. But is this enough?
The Commission finally acknowledged energy prices in Europe are uncompetitive, as electricity costs for industry are twice that of US competitors. It also rightfully recognised the way the EU supported renewable energy was unsustainable. It is now up to EU member states to change this. But more is needed. The gas market needs to be reformed. Energy interconnections between EU member states need to increase urgently.
The impact on European competitiveness of a 40% CO2 reduction target by 2030 for the entire EU economy cannot be underestimated either. The suggested changes by the Commission for industrial sectors will require emission reductions of 43% in 2030, 65% in 2040 and 87% in 2050. The European Council in March needs to assess the feasibility of this package in detail and develop tools that support the deployment of innovative low-carbon solutions in industry. This is especially needed, if no further global action is taken and the EU Economy does not improve.
Additionally, the cost of decarbonising the current power sector - a key challenge - is not addressed. This will most likely increase electricity bills, which the European Commission accepted as being too high already. The EU will have to explore new models of decarbonising the power sector, other than via the carbon price alone.
Specifically related to the European pulp and paper industry, CEPI applauds the long awaited recognition of the negative impact of subsidised bioenergy on EU wood markets. And CEPI welcomes the announcement in the 2030 Energy and Climate package to further explore funding tools for breakthrough technologies.
But the bottom line is: policy needs to be put into practice. “We appreciate the refocus on industrial policy. It is a good sign that the Commission recognises again our role in creating jobs and growth for Europe. However, the proposed measures for an effective industrial policy need to be translated into concrete actions as soon as possible”, said Teresa Presas, CEPI Director General.
For more information, please contact Daniela Haiduc at firstname.lastname@example.org, mobile: +32(0)473562936
Note to the Editor
2030 Energy and Climate Package from the European Commission:
Industrial renaissance Communication:
Regulatory and Market Aspects of Demand-Side Flexibility
Abstract from CEPI response to CEER public consultation
The Council of European Energy Regulators (CEER) has recently launched the public consultation “C13-PC-71: Regulatory and Market Aspects of Demand-Side Flexibility”.
Below an abstract from the CEPI response to main questions raised by CEER on:
1. main opportunities and benefits for demand-side flexibility;
2. main barriers to the emergence/functioning of demand-side flexibility;
3. most important 'preconditions' necessary for the emergence/functioning of demand-side flexibility
CEER Consultation Questions
1. What do you see as the main opportunities and benefits for demand-side flexibility in existing/future markets and network arrangements? How would you prioritise these?
1.1 Existing markets
The pulp and paper industry has already engaged, where possible, in demand-side programmes.
Mechanical pulping, an electro-intensive process, can be used for “peak shaving” programmes. It can react at reasonably short notice, like as short as 15 minutes and, depending on the frequency and schedule of interruptions, up to one hour. However, these are indicative figures, which need to be carefully assessed at mill level, as they will vary in function of the trade-offs between benefits from balancing the electricity system, the need to meet paper demand, and the overall economic impact that balancing the grid would have on the production process.
In some countries, paper production also participates in “valley filling” programmes: the whole industrial process is shifted to the night or to the weekends to optimise baseload electricity production. Example of this can be found, for instance, in Austria or Belgium. In Norway there are also provisions for flexibility markets where industry can participate. In this case, the transmission operator asks for bids.
The potentials for further exploring “peak shaving” or “valley filling” programmes are however limited. Beside auxiliary processes, the paper making process has little margins of flexibility when it comes to demand-reduction programmes. Moreover, most of the energy required from the sector (steam and electricity) are generated on-site, therefore mostly off the grid.
There is however quite some untapped potential if the market will develop flexible solutions for absorbing excess electricity supply at critical times (see next paragraph).
1.2 Future markets
One of the main criticalities of the electricity system is how to properly integrate electricity generated from “variable”, or “non-programmable” renewable energy sources (NP RES), like wind and solar, at a time of low or no demand. Curtailing these sources is particularly inefficient, as they produce at zero marginal prices. While most of R&D programmes are focussing on energy storage, the pulp and paper industry is in a rather unique position to potentially providing solutions to
- efficiently absorbing excess of electricity supply,
- while creating vale for the EU economy,
Most importantly, all this could be already delivered with current technologies.
To explain how this would be possible, few words on the pulp and paper industry are necessary.
CEPI represents 959 mills located in 18 European countries. According to our latest figures, in 2011 the European pulp and paper industry consumed 111 TWh of electricity, of which 57 TWh (52%) produced on-site via co-generation units. In 2011 the sector also consumed 557 TJ, or 155 TWh-equivalent, of heat, all on-site generated.
Combining the two figures for on-site generation, the sector generated and consumed about 212 TWh of energy in 2011. This is all energy sitting outside the energy system boundaries. To put these figures into context, it is worth noticing that in 2011 total European electricity production from wind and solar was about 223 TWh.
What would happen if, at a time of excess of electricity supply, the sector would ramp up electricity demand by ad-hoc moving form off to on the grid? It would absorb the peak of cheap electricity supply while maintaining the industrial output unchanged. Meaning more value per kWh, less primary energy consumption, less carbon emissions. In one word: a more competitive industry.
In most cases technology is already available and deployable. For instance, it would be sufficient to install an extra, highly-efficient electric boiler. With the support of additional RDI projects, more options could be envisaged in the near future, whereby electro-technologies could be used in the drying process.
The geographical distributions of mills in Europe allows for cost-effective absorption of excess electricity produced by decentralised energy sources, substantially reducing the need to costly investments in grid extensions.
Last but not least, this cost-effective measure will also reduce the need for additional costs to remunerate unused thermal capacity for electricity generation (so-called Capacity Remuneration Mechanisms – CRM), as the impact of NP RES on the running hours of conventional power plants will be largely mitigated.
Regulatory barriers are the main reason for not making this a reality. Without addressing this aspect first, it will be impossible for any mill operator to start any cost-benefit analysis to assess how to adapt a mill operation in a way that would deliver on-site financial benefits.
1.3 Existing network arrangements
In almost all CEPI countries, existing network arrangements act as a barrier against the absorption of excess supply of electricity.
The only exception is Norway. There, already since 1999, the government promoted the installation of electric boilers on industrial sites (although other incentives were already earlier in place). The rationale was to absorb seasonal excess of hydro electricity generated. The boilers are activated in remote by the network operators.
In exchange for this flexibility, industrial operators have a significant reduction in grid charges. While the usual tariff for the transmission grid (Statnett) is 170 NOK/kW (about 20 €/kW) in 2013, the tariff for flexibility load is 43 NOK/kW (about 5 €/kW). In addition there are distribution charge and taxes. Since 2010 the flexibility grid fee is open for all that can offers to decouple the load either by remote control or at 15 minutes or 2 hour notice.
For customers with remote control, the grid operator can move the load from day to night. The grid operators are very satisfied with this system. The possibility to decouple load has proven to save the grid from collapse. The use of flexible load in periods with excess of electricity stabilizes the grid.
We strongly encourage national regulators to urgently use the Norwegian example as a best practice case for promoting and valuing flexibility markets in their own countries.
2. What do you see as the main barriers to the emergence/functioning of demand-side flexibility? How would you prioritise these?
2.1 Legislative barriers/difficulties
In many cases, the industry is subject to stringent energy efficiency targets. In case of demand side flexibility, deliberately stopping CHP units would negatively impact the industry performance.
To promote energy efficiency programmes while incentivising demand side flexibility, it should be clearly stated in the legislation that importing electricity from the grid would be done in order to absorb
the load from NP RES, such as wind and solar. Therefore the electricity imported should be counted as 100% energy efficient.
2.2 Regulatory barriers/difficulties
This is the key barrier for demand-side flexibility in absorbing excess electricity supply from NP RES.
Currently, network tariffs and network charges (including levies and taxes) are set in a way that discourages industries from accessing the grid.
This approach is in principle correct, as it tends to promote stable and predictable demand from big energy users.
However, in this context, the network operator needs a service to balance the network. A service the industry is ready to provide. But here is the paradox: instead of being remunerated for such a service, industry would have to pay for offering it, to the benefit of the network operator.
In Germany, for instance, should a paper mill decide to import electricity from the grid, it would face additional costs up to more than 70 €/MWh.
Moreover, a mill has a very flat power consumption profile, like i.e. 7000 (or 7500 or 8000) full load hours a year. On this basis, it enjoys a reduced grid fee, i.e. in Germany it pays only 20% (or 15% or 10%) of the normal fee. Normal grid fee depends on local grid operator and might be between 5 to 11 €/MWh. When taking additional load from the grid, the profile will no longer be flat and the 7000 hours threshold might not be reached anymore. As a consequence, the mill would have to pay the remaining 80 to 90% of the grid fee.
A proper regulatory framework should incentivise both the “off-the-grid” baseload demand, and the flexibility to bring “on-the-grid” ad hoc electricity demand to help matching the excess of electricity generation from NP RES.
2.3 Market barriers/difficulties
It should be clear that RES balancing is not an industry prerogative. Industry can be part of the solution, and is willing to do so, provided there is a business case supporting it.
Industry lacks crucial information to build a proper business case. There should be some sort of guarantee on the minimum yearly number of hours one should reasonably expect to be called for balancing the market.
This minimum number of hours should be provided by the regulator and/or network operator and should be the founding element of any contractual agreement.
Moreover, commodity prices will have to be extremely low (or even negative) to compensate for the loss of revenues from CHP/green certificates or other support schemes. In fact, if commodity prices
would be on the level of the fuel used normally, it would just be equal costs for steam generation, but no compensation for lost electricity generation.
Energy supply contracts may need to be adapted to incorporate this additional flexibility.
3. For each of the barriers identified above, please describe the most important 'preconditions' necessary for the emergence/functioning of demand-side flexibility
To promote demand side flexibility in absorbing excess of NP RES supply, the following minimum preconditions would be required:
- Removal of regulatory barriers to create extra demand for electricity at a time of need: no extra costs (tariffs, levies, taxes) when participating in DSF programmes
- Maintain current incentives for on-site generation
- DSF to be compatible with energy efficiency targets: 100% energy efficiency for electricity taken from the grid when participating in DSF programmes
- Need for regulators/network operators to guarantee a minimum yearly amount of hours a paper mill should reasonably expect to be called when participating in DSF programmes.
Lastly, participation in DSF programmes would require significant changes in the way industry operates, both from a technological and industrial processes perspective. Support for Research, Development and Innovation would be needed.
For more information, please contact Nicola Rega at email@example.com
CEPI comments on the discussion document ‘Paper Vapour – the climate impact of paper consumption’ from the European Environmental Paper Network
The European Environmental Paper Network (EEPN) presented preliminary findings of their Paper Vapour report. The report aims to show that paper has a large climate impact and it questions the carbon neutrality of wood fibre. The Confederation of European Paper Industry (CEPI) analysed the report. CEPI advises a major reworking of the draft report before publishing final findings. There are several reasons for this:
I. The data do not match the sources referenced
The report concludes that pulp and paper industry emissions are 7 kg of vapour per kg produced leading to total emissions that are larger than those of waste and landfilling, chemicals, oil and gas, fuel and power, steel and aluminium and iron combined.
It uses data from the World Resource Institute (WRI). However, the report does not show the original WRI data for all sectors. In table 2 a new figures was inserted for the percentage of the pulp and paper sector. In the original WRI publication the emissions from pulp, paper and print are set to be 1.1% (http://www.wri.org/chart/world-greenhouse-gas-emissions-2005). Instead a number seven times higher than the original was included based on separate calculations. The report lists this fact only on page 11, which is misleading. Either WRI figures should be used entirely to be able to compare them correctly or all sector figures need to be re-calculated on an equal basis. At the moment the figures in table 2 do not add up to 100% any longer; they exceed that figure.
2. The underlying data are unlikely at best
The emissions of industry sectors are well documented by the International Energy Agency (IEA). The IEA publications on industrial efficiency and CO2 emissions show that 70% of industrial emissions are emitted by three sectors: iron and steel, non-metallic minerals (cement) and chemicals and petrochemicals. The direct emissions from the pulp, paper and print industry together add up to 189 Mtonnes in 2005 at global level, 2.8% the of industrial emissions (IEA Energy Technology Perspectives). These data are based on national country statistics. EU steel sector emissions in EU ETS published by the European Environment Agency (EEA) are around 140 Mtonnes in non-crisis years, four times that of the 35 Mt from the European pulp and paper industry according to EEA statistics.
The IEA data divided by the global production figures used in the report (328 Mt pulp and paper produced), lead to a direct emission of 189/328 = 0.58 t/t as a global average, compared to the 0.34 t/t for Europe. These are direct emissions only. When adding indirect emissions from electricity in line with European data (0.34 vs. 0.10, CEPI sustainability report based on EU ETS and energy consumption statistics), the number used for direct production emissions in the report is 100% higher than reality.
Vice versa, the weighted average of 1.51 t/t used in the EEPN report would lead to 546 Mt global emissions for the paper industry, compared to the realistic 189 Mt from the IEA statistics.
3. The combination of data leads to mistakes
In table 1, data from a multitude of sources are combined resulting in an altered total figure. Similarly, the combination of different data leads to mistakes. An example is ‘Debarking and Chipping’. US data from a single study are used in the report in this instance. The emissions (0.45 t/t) are higher than the overall EU average production emissions. Moreover, debarking and chipping for pulp production is included in pulp production statistics, because they are part of our production process.
Wood chipping in the US, meant for exports of bio-energy, is delivering wood to the power sector, not to the pulp and paper industry. Additionally, a Carbon mass balance credit is added without any further explanation. Again a number is used higher than the real and verified emissions from paper production today. The source is the author of the report himself. CEPI believes a clearer explanation is needed to understand how these figures have been calculated.
4. The key number is not explained
A crucial discussion is missing from the report, linking forest accounting with the number 6.83 t/t in the first section. This number doubles the emission calculation made in the report, without explanations on how it is derived. The source seems to be the grey picture on page 5, which is not referenced properly. It seems to relate to a virgin paper production cycle. It is also unclear to what the percentages in the picture refer to. Yet this picture seems to be the basis for the entire allocation of biomass emissions, without any further explanation. The conclusions of the report are very difficult to assess, as the calculations included are contrary to current standards in life cycle accounting, monitoring or reporting rules in legal frameworks and the UNFCCC accounting rules
Carbon neutrality is an issue in emission accounting, based on the UNFCCC accounting rules, including LULUCF. The emissions of carbon emitted when burning wood for energy are calculated in the national forestry (LULUCF) accounts, enabling a zero factor to be used for biomass.
The report quotes in many cases from an article in the Science magazine and the discussions in the USA. The so called accounting error in forest carbon accounting as referred to in the Science articel is an issue for non-Kyoto countries. However, it is clear that in Europe, having signed the Kyoto protocol and following the agreements reached in Durban, proper forest accounting is taking place. It is based on the LULUCF legislation and a zero emission factor from the EU Monitoring, reporting and verification guidelines. Around 80% of all wood used in the European industry is coming from EU forests and the pulp from known and established planted forests.
But the core of the matter remains, if the wood used is sourced from sustainably managed sources one cannot double count carbon stock, flow approaches and forest and biomass emissions, as seems to be the case in this study. In Europe forest carbon stock has been growing for years, and proper forest accounting is taking place.
5. The report compares apples and pears
The report makes comparisons between the pulp and paper sector and other sectors in society, to emphasise the size of emissions calculated. The comparisons are flawed for a number of reasons. Some were mentioned before, additionally, the constructed pulp and paper LCA style number in the report is compared to non LCA data of other sectors. The basis for the calculations are completely different. In addition, the word “direct” emissions is used incorrectly in several cases throughout the report, not in line with scope 1 and scope 2 emissions normally used in reporting on industrial emissions.
6. Old and US data are used for a European study
The paper was commissioned by the European paper network and is intended for the European discussion, but only two of the sources are European and no European data has been used. CEPI strongly feels the data should also be European and reflect the real situation in the European production and consumption of paper and board. The current discussion paper does not. To address imports of paper into Europe for consumption, a weighted average can be calculated. But the fact remains that the vast majority of paper used in Europe is produced in Europe from European raw materials.
7. Sources are unclear
Last but not least, the study should avoid quoting background studies made by the same author, without further references. This leaves figures untraceable. Nine out of the 11 data used are either (co)sourced to Jim Ford, Climate for Ideas or EPN. There are many more public studies and materials available that could have been used, providing additional data and references.
In a nutshell, verification of the conclusions made in the report based on the calculations, data and sources presented is not possible. The 7 kg of paper vapour is not backed by the material presented. CEPI recommends a complete overhaul of the report to be credible.
For more information, please contact Marco Mensink at firstname.lastname@example.org