Environmental Effectiveness
Little analysis of how emissions trading actually affects the environment
has been undertaken. But a study undertaken by Hahn and Hester (1989)
in the USA, the first of its kind, found that emissions trading
did not improve the environmental quality; instead, it saved money
for industry. This is hardly surprising, since one of the key motivations
for the development of marketable permit systems was the potential
for cost savings.
The benefits of economic instruments are far more theoretical than
real. The use of charges have not been shown to provide incentives
for innovation and pollution reduction measures and the use of tradeable
pollution rights, used widely only in the US, has not led to significant
environmental quality improvements. The most often cited success
case is the use of tradeable pollution rights for removing lead
from petrol between 1982 and 1987. Whilst proponents claim it saved
petrol refiners hundreds of millions of dollars those same proponents
admit it "appears to have had very little impact on environmental
quality... In Canada, lead in gasoline was eliminated by gradually
raising standards set out in traditional regulations." (Cassils
1991, 10).
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Economic Efficiency
One of the key motivations for the development of marketable permit
systems was the potential for cost savings to polluters. An OECD
report states that:
More consensus seems to exist regarding advantages of
emissions trading in terms of economic efficiency than with respect
to its environmental effectiveness. Substantial cost savings are
reported by many authors on this subject. An important advantage
of emissions trading over direct regulations is that it has facilitated
continuous economic growth in dirty areas. (OECD 1989, 118)
For example, the chemical company Du Pont has estimated that its
fifty-two plants achieved cost savings of over 86 per cent from
the use of regional bubbles (Senecca and Taussig 1984, 232).
But often cost savings arising from economic instruments result
directly from firms not having to make pollution reductions that
they otherwise would have. A study by economic instrument advocates
Hahn and Hester (1989, 129) found that emissions trading, although
it saved money for industry by enabling firms to "avoid making emissions
reductions that they otherwise would have been required to make"
did not improve environmental quality.
One of the problems with emissions trading is setting the level
of emissions that individual firms should have a right to attain
before trading can occur. If the baseline level is too low, there
will be few pollution rights for sale because few firms will be
able to reduce their pollution levels below the standards set. However,
if the baseline level is too high, there will be few buyers of pollution
rights because most firms will be able to meet the standards. In
either case, there will be too little trading.
A major question is whether the baseline levels should be set to
meet environmental goals or to ensure a high level of trading and
cost saving. Environmentalists have been opposed to emission trading
partly because they fear that environmental objectives have been
sacrificed for economic efficiency. Even proponents of trading admit
that there will inevitably be a conflict and an implicit trade-off
between the goals of reducing costs and improving environmental
quality. They argue that the US EPA's concern with improving environmental
quality has in fact hampered the effectiveness of trading and limited
markets.
A major problem with the new EPA policy is that it reinforces the
perception of a strong link between emissions trading and the achievement
of air quality standards. This is especially apparent in the requirement
for additional reductions for emissions trading in nonattainment
areas
Requiring large additional emission reductions from
firms using emissions trading simply creates another disincentive
for firms to use trading. (Hahn & Hester 1989, p. 147)
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Administrative Efficiency
An OECD report (1989)points out that administrative costs of trading
have been high. Other problems pointed out by Senecca and Taussig
(1984) include the fact that few firms have taken part, so the market
is made up of only a small number of buyers and sellers. In fact,
although the emissions trading program was introduced in the USA
in 1979, by 1989 far fewer firms than expected were banking credits
or trading them with other firms. With so few firms in the market,
it has been difficult for individual firms to get information about
prices and terms.
The baseline level is usually set in the USA by making it the same
as existing licence limits. Opponents of emissions trading point
out that these established licence limits have not enabled states
to meet air quality goals and that, while further reductions in
emissions are needed, surplus rights should not be traded. Proponents
argue that the problems lie with the licensing system, and that
these problems should not prevent cost savings being made through
the use of emissions trading.
Several states have set baseline levels on the basis of what a
firm has been discharging in the past. But if a firm's actual emissions
are overestimated, so that allowable emission rates are set higher
than actual emission rates to start with (which, it has been argued,
happens in many states in the USA), a firm may get credit for reductions
it has not actually made. This is also one reason why offsets have
not resulted in any noticeable improvement in air quality. 'Many
offsets are created by revising the permit of an existing source
to reflect an emission reduction that has already occurred' (Hahn
& Lester 1989, p. 122).
It is argued that these difficulties in working out baseline and
actual emission levels also add to the uncertainties faced by firms
in working out the credits to which they are entitled. The resulting
lack of clearly quantified property rights acts as a disincentive
for firms to create surplus-emission reductions and trade them.
There is also uncertainty surrounding the issue of enforceability
of emission ownership rights.
Another problem is that, if the established baseline level is found
not to be the ideal ultimate level, or if new information comes
to hand that means the regulator has to tighten the air quality
standards, this will mean that baseline levels will have to be reduced.
How does that affect a firm's 'banked' credits? Would the government
have to buy them back? Otherwise, according to Hahn & Lester
(1989, p. 117), 'reductions that were once surplus would then be
required, thereby effectively confiscating the property right held
by the firm'. This also adds to the uncertainty of firms that may
not be inclined to get involved for fear of having their banked
credits devalued.
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