A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report

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A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
Ariadne Report

A Fair and Solidarity-based
EU Emissions Trading System
for Buildings and Road
Transport
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
Authors

                     » Benjamin Görlach                             » Dr. Michael Jakob                                 » Katharina Umpfenbach
                        Ecologic Institut                              Ecologic Institut                                   Ecologic Institut

                     » Dr. Mirjam Kosch                             » Dr. Michael Pahle                                 » Dr.Théo Konc
                        Potsdam-Institut für                           Potsdam-Institut für                                Potsdam-Institut für
                        Klimafolgenforschung                           Klimafolgenforschung                                Klimafolgenforschung

                                                                    » Johannes Brehm                                     » Simon Feindt
                    » Dr. Nils aus dem Moore                           RWI - Leibniz-Institut für                            Mercator Research Institute on
                      RWI - Leibniz-Institut für                       Wirtschaftsforschung
                      Wirtschaftsforschung                                                                                   Global Commons and Climate
                                                                                                                             Change

                     » Fabian Pause
                        Stiftung Umweltenergierecht                 » Jana Nysten                                       » Dr. Jan Abrell
                                                                      Stiftung Umweltenergierecht                          ZEW - Leibniz-Zentrum für
                                                                                                                           Europäische Wirtschaftsforschung

Cite this paper:
Benjamin Görlach, Michael Jakob, Katharina Umpfenbach, Mirjam Kosch, Michael Pahle,
Théo Konc, Nils aus dem Moore, Johannes Brehm, Simon Feindt, Fabian Pause, Jana
Nysten, Jan Abrell (2022): A Fair and Solidarity-based EU Emissions Trading System for
Buildings and Road Transport. Kopernikus-Projekt Ariadne, Potsdam.

Corresponding Author: Dr. Michael Pahle, michael.pahle@pik-potsdam.de

This Ariadne analysis was prepared by the above-mentioned authors of the Ariadne
consortium. It does not necessarily reflect the opinion of the entire Ariadne consortium
or the funding agency. The content of the Ariadne publications is produced in the pro-
ject independently of the Federal Ministry of Education and Research.

Published by                                                                                        Photo Credits
Kopernikus-Projekt Ariadne                                                                          Titel: Antoine Schibler / Unsplash
Potsdam-Institut für Klimafolgen-
forschung (PIK)
Telegrafenberg A 31
14473 Potsdam

June 2022
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
TABLE OF CONTENTS

     Executive Summary                                                        1

     1. Introduction                                                         5

     2. Institutional options to ensure solidarity and social fairness:

       Social Climate Funds and alternatives                                  7

         Different paths to the same goal                                     7

         Description and analysis of different options                       8

         Step 1: Comparing Option I (“Cheque from Brussels”)
         with Option IV (“No EU interference”)                               8

         Step 2: Comparing Option II (Social Climate Fund)
         with Option III (Social Climate Mechanism)                          10

         Discussion and recommendations                                      11

     3. Distributional implications between member states (solidarity)       12

         Considering the interaction between the ETS2 and the ESR is
         essential for the robustness of the social compensation mechanism   12

         Scenario analysis to explore the effects of AEA trade and ETS2
         price levels                                                        13

                  Summary of results                                         14

                  Scenario 1: No AEA trade & low ETS2 price                  14

                  Scenario 2: High ETS2 price with AEA trade                 16

         Uncertainties might lead to an unstable system and need to
         be addressed                                                        16

     4. Distributional implications within member states (social fairness)   17

         One price, but very different financial burdens                     17

         Description and analysis of scenarios                               18

         Discussion and recommendations                                      20

     References                                                              22

     Appendix to Section 2                                                   23
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
EXECUTIVE SUMMARY

    1.     The new emissions trading system                                              and regulations at EU and member-
           for buildings and road transport –                                            state level. This study fills this gap
           the so-called ETS2 – proposed by                                              for three particularly important
           the European Commission in the Fit                                            choices that may have far-reaching
           for 55 package is key for decarboni-                                          consequences for the overall policy
           sing these two sectors. But a uni-                                            package:
           form EU-wide carbon price has im-
           portant distributional implications –                                 3.      The first design choice is the institu-
           both between EU member states                                                 tional structure and general gover-
           and within them. Managing these                                               nance level of the mechanism to
           implications in a way that ensures                                            manage the distributional implicati-
           solidarity and fairness is of utmost                                          ons. While the SCF seems generally
           importance to providing the ETS2                                              capable of performing its designa-
           and its price signal with the neces-                                          ted function, there are concerns sur-
           sary political robustness and endu-                                           rounding whether the SCF should
           ring credibility.                                                             be established at EU level or at the
                                                                                         member-state level. Against this
    2.     To that end, the Commission has                                               backdrop, this report compares the
           proposed the creation of a Social                                             SCF with three other design options
           Climate Fund (SCF).1 While this pro-                                          that differ in terms of how they are
           posal builds on evidence gathered                                             situated between national and su-
           by the Commission for related ana-                                            pranational levels.
           lysis2, no dedicated impact assess-
           ment has yet been conducted. Other                                    4.      The second design choice relates to
           studies have analysed some of the                                             the interaction between the ETS2
           design aspects – especially the dis-                                          and the Effort Sharing Regulation
           tributional effects of carbon pricing                                         (ESR). In general, the ETS2 can shift
           on households – but key design                                                the distribution of emissions reduc-
           choices have not yet been systema-                                            tions away from agreed-upon ESR
           tically explored. In particular there                                         targets, with consequent welfare ef-
           needs to be an understanding of:                                              fects.3 In order to maintain a fair ef-
           (1) the advantages and disadvanta-                                            fort-sharing between EU member
           ges of different design options, and                                          states, it is crucially important to
           (2) interactions with other policies                                          manage the distribution and flow of

     1 On 8 June 2022, the European Parliament voted on the SFC proposal as well as proposed amendments. The EP rejected the report on the revi-
    sion of the EU ETS and referred it back to the ENVI committee. The final vote on the SCF was adjourned until agreement on the ETS review has
    been achieved. See https://www.europarl.europa.eu/news/en/press-room/20220603IPR32130/fit-for-55-environment-committee-to-work-on-
    way-forward-on-carbon-pricing-laws
    2 See the section titled “Collection and use of expertise” in the SCF proposal (COM(2021) 568 final).
    3 The reason for this possible divergence between the ETS2 and the ESR is the interactive, and not yet fully specified, overlap of a bottom-up and
    a top-down system: In the “bottom-up” ETS2 system, companies throughout the EU trade allowances for the emission of CO2. The resulting allo-
    cation of ETS2 allowances is therefore an emergent market outcome, determined by company-specific abatement costs. In contrast, the “top-
    down” ESR specifies an allocation of abatement burdens between member states (defined via the “Annual Emission Allocation”, AEA) and provi-
1
    des for the trading of AEA allowances between the member states.
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
revenues resulting from the trade of           Figure ES1: Institutional design options for the social balancing of a new ETS2
     ESR certificates (annual emission al-
     locations, AEAs) and ETS2 certifi-
     cates. This report uses quantitative
     modelling to analyse how welfare
     would change if AEA trade was limi-
     ted, and/or the ETS2 price was rela-
     tively high.

5.   The third design choice concerns
     the financial volume of the SCF (or
     of an alternative social transfer me-
     chanism): how large does it need to
     be, in terms of the share of total
     auction revenues, to ensure fair                 (between member states) and the                                       9.      Based on eight guiding questions4,
     compensation for households                      idea of the welfare state (within                                             we describe the SCF proposal in
     across the EU, given varying criteria            each member state). Furthermore,                                              terms of its institutional characteri-
     for social fairness? This is important           the principle of subsidiarity deman-                                          stics and compare it with the three
     because there is a trade-off between             ds that the EU only acts if and inso-                                         alternative approaches depicted in
     using revenues for social compensa-              far as the objectives of the proposed                                         Figure ES1. For the two “corner so-
     tion on the one hand, or financing               action cannot be sufficiently achie-                                          lutions”, our analysis points to se-
     green investments and infrastruc-                ved by the member states.                                                     vere deficiencies, both conceptual
     ture on the other. Furthermore, dif-                                                                                           and practical, implying that they do
     ferent forms of compensation entail       8.     Given this tension, it is worth evalu-                                        not represent feasible solutions.
     different administrative require-                ating how the objective of "leaving                                           Looking at these options is nevert-
     ments and specific challenges. This              no one behind" of the current SCF                                             heless useful since proposals in the-
     report discusses these issues in                 proposal can be achieved best by                                              se directions are on the table. The
     light of the SCF spending criteria,              comparing four design options,                                                second step of the analysis then
     specifically with a view to possible             each of which situates governance                                             contrasts the Commission’s propo-
     adjustments that would make com-                 of the respective program at a diffe-                                         sal for a Social Climate Fund with
     pensation more targeted.                         rent stage along the cooperation -                                            an alternative option: a “Social Cli-
                                                      subsidiarity spectrum. Figure ES1 il-                                         mate Mechanism” (SCM). A central
DESIGN CHOICE 1: INSTITUTIONAL                        lustrates these four options, ran-                                            idea of the latter approach is that
STRUCTURE AND GOVERNANCE LEVEL                        ging from extreme cooperation                                                 the goal of social balancing can be
                                                      ("Cheque from Brussels") to extre-                                            achieved through clearly-defined ru-
6.   The SCF, as proposed by the Euro-                me subsidiarity ("No EU interfer-                                             les and procedures, but without re-
     pean Commission, is only one out of              ence"), with two moderate options                                             course to the EU budget – thus
     a number of different design opti-               in between.                                                                   avoiding some political, legal and
     ons for achieving the goal of a soci-                                                                                          administrative hurdles.
     ally balanced implementation of the
     ETS2 – and it may not be the best
     one. Alternatives are conceivable              Figure ES2: Overview of interactions between ESR and ETS2
     with regard to (1) who should be eli-          existing uncertainties in the regulation outcome, and possible impacts on cost
                                                    effectiveness and distributional implications of the Fit for 55 package.
     gible for compensation, (2) who
     should be responsible for compen-
     sation, and (3) who should control
     the spending.

7.   The SCF’s goal of preventing exces-
     sive burdens from the ETS2 is un-
     questionably appropriate and im-
     portant. Nevertheless, the proposal
     has sparked controversy because
     the distributional effects of climate
     change touches on very fundamen-
     tal and sensitive issues at the heart
     of the EU, i.e. the value of solidarity

                                                4 (1) Where do funds originate? (2) Which criteria govern the allocation of resources? (3) Is member-state co-funding required? (4) Where are the
                                               funds held? (5) Who decides on spending? (6) Are the criteria for spending set at the EU level? (7) How is spending controlled and governed?
2
                                               (8) How are funds disbursed?
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
10. A main result of our analysis is that         Figure ES4: High-intensity energy consumers in the EU by income decile
    the quality of implementation and
    the level of cooperation between the
    Commission and member states is
    crucial for the performance of both
    the SCF and the SCM. Assuming ide-
    al implementation and sincere co-
    operation between the Commission
    and member states, the SCF may be
    the better option since it achieves
    its targets more reliably. The alter-
    native proposal of an SCM is less
    ambitious in terms of precision and
    stability, but allows for a leaner
    structure and a higher degree of
    member-state ownership. It is ulti-
    mately a matter of policy preference
    that tilts the balance towards either
    the SCF or the SCM.

DESIGN CHOICE 2: ETS2 AND ESR IN-                    most all member states (left-hand       13. To increase the political stability of
TERACTION                                            panel of Figure ES3) and thus make          the Fit for 55 package, we propose
                                                     it more difficult to reach the EU’s         to (i) improve AEA trade and (ii) en-
11. The interaction between the ESR                  emissions target. Second, a higher          sure that the relative distribution of
    and ETS2 in the Fit for 55 proposal              ETS2 price is likely to have an im-         ETS2 revenues between member
    entails uncertainty in three dimensi-            pact on the cost distribution across        states is independent of the ETS2
    ons: AEA trade may remain limited;               member states that is at odds with          price, i.e. social transfer mecha-
    the ETS2 price is uncertain; and it is           the ESR (right-hand panel of Figure         nisms need to be scaled accordingly.
    unclear how revenue allocation bet-              ES3) if social transfer mechanisms
    ween member states will respond to               are not scaled accordingly. In this     DESIGN CHOICE 3: DISTRIBUTIONAL IM-
    changing ETS2 prices (Figure ES2).               case, (mostly) poorer member            PACTS & TRANSFER
                                                     states would suffer from higher wel-
12. If not properly accounted for in poli-           fare costs whereas (mostly) richer      14. At the EU level, the impact of the
    cy design, these uncertainties might             member states would benefit from            ETS2 would be slightly regressive.
    undermine the stability of EU clima-             lower welfare costs. Both potentially       That is, low-income households
    te policy architecture. Our analysis             undermine the political acceptability       would, on average, spend a higher
    brings two main risks to light: First,           of the EU’s climate ambition.               share of their disposable income to
    an absence of AEA trade will increa-                                                         keep up their energy consumption.
    se the costs of climate policy for al-                                                       However, using the revenues from
                                                                                                 auctioning permits can make the
                                                                                                 ETS2 progressive.

    Figure ES3: Changes in welfare per capita – compared to the base case with AEA           15. Using revenues from carbon pricing
    trade and a low ETS2 price. Note: For a short description of the model see Box be-
                                                                                                 in a way that benefits every EU citi-
    low; individual scenarios are described in the subsequent sections.
                                                                                                 zen in an identical manner (e.g. by
                                                                                                 direct transfers, tax reductions or
                                                                                                 infrastructure investments) could
                                                                                                 provide benefits to low-income hou-
                                                                                                 seholds that exceed their additional
                                                                                                 energy costs, so that they are better
                                                                                                 off with the ETS2.

                                                                                             16. While low-income households would
                                                                                                 gain on average, a carbon price
                                                                                                 would put high-intensity energy
                                                                                                 consumers, for whom energy expen-
                                                                                                 diture constitutes a large share of
                                                                                                 spending, at risk of energy poverty

3
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
(Figure ES4). Households in Bulga-        Figure ES5: Share of auction revenues required to compensate (a) all high-inten-
    ria, Hungary, Poland and Romania          sity consumers, and (b) all consumers, for their additional energy costs due to a
    would be at greatest risk of experi-      carbon price. Source: own elaboration.
    encing energy poverty.

17. Targeted measures can prevent
    energy poverty for low-income hou-
    seholds. Transfers amounting to
    slightly more than 10% of auction
    revenues would be sufficient to
    compensate all high-intensity ener-
    gy consumers in the lower half of
    the income distribution for their ad-
    ditional energy costs (Figure ES5).
    However, transfer payments to all
    households in this income segment
    would require more than 30% of
    carbon-pricing revenues.

18. Relieving households by lowering
    energy prices does not make sense
    because it also weakens the incenti-
    ve to reduce emissions. More sensi-
    ble are measures that especially
    enable vulnerable groups to adjust
    to higher energy prices, since these
    are effective from an environmental
    as well as social perspective. This in-
    cludes expansion of public transport
    or targeted support for heat pumps
    in low-income households. Starting
    to implement such measures before
    the ETS2 enters into force can help
    to cushion social hardships.

4
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
1. INTRODUCTION

                                               The new emissions trading system for                                       tion (i.e. a higher relative burden on low-
                                               buildings and road transport – the so-                                     income segments of society). Correspon-
                                               called ETS2 – proposed as part of the Fit                                  dingly, member states with a relatively
                                               for 55 package is key for decarbonising                                    high share of low-income households are
                                               these two sectors. It will oblige fuel sup-                                disproportionally affected by a uniform
                                               pliers to obtain emission allowances for                                   carbon price – especially if they do not
                                               the greenhouse gas (GHG) content of the                                    have the financial means or institutional
                                               fuels they supply to customers in those                                    capacity to compensate such households
                                               sectors. The ETS2 thus sets up a techno-                                   through social policy and transfers.
                                               logy-neutral carbon price that provides
                                               incentives to decarbonise operations and                                   This suggests the need for a mechanism
                                               foster investment and innovation to-                                       to balance the distributional effects of
                                               wards the EU goal of GHG neutrality by                                     the ETS2 in a way that ensures social
                                               2050.5                                                                     fairness within EU member states, and
                                                                                                                          solidarity between them. Such a mecha-
                                               However, a uniform EU-wide carbon                                          nism will make the ETS more acceptable
                                               price will have distributional implications                                upon its introduction, more robust in
                                               at the household level, both between                                       light of changing energy prices – and
                                               and within EU member states (see Figu-                                     thereby more likely to politically durable,
                                               re 1): Low-income households tend to                                       and deliver a stringent and credible car-
                                               spend a higher proportion of their dispo-                                  bon price. The use and (re)distribution of
                                               sable income on energy consumption.                                        revenues from auctioning ETS certifi-
                                               This raises the issue of social fairness                                   cates between and within member
                                               and how to avoid a regressive effect of                                    states will be key to achieving this. Cor-
                                               the carbon price on the income distribu-                                   respondingly, the rules for the distributi-

    Figure 1: Distributional effects of a carbon price between and within countries (without revenue redistribution)
    Source: Frederikkson & Zachmann (2021)

                                               5 Furthermore, the ETS2 would represent an important milestone on the road to a uniform CO2 price within Europe, which should foster interna-
5                                              tional cooperation in the form of a global carbon pricing regime (Edenhofer et al. 2021)
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
on of allowances between member                  state level. Against this backdrop, this
states, and the criteria for spending the        report compares the SCF with three
resulting revenues, are the central policy       other design options that differ in terms
levers for which design options are being        of how they are situated between natio-
discussed.                                       nal and supranational levels.

The Commission has proposed to institu-          The second design choice relates to the
tionalize these levers through the creati-       interaction between the ETS2 and the Ef-
on of a dedicated Social Climate Fund            fort Sharing Regulation (ESR), which
(SCF).6 Its core features are: (1) A total fi-   establishes binding annual emissions
nancial envelope for the 2025–2032 pe-           targets for EU member states related to
riod of 72.2 billion € in current prices –       i.a. emissions from road transport and
amounting to 25% of expected ETS reve-           buildings.8 If the ETS2 allowance price is
nues – to be financed through the EU’s           relatively high, member states with rela-
Multiannual Financial Framework (MFF).           tively unambitious ESR targets risk
This entails a “frontloading year” to en-        overshooting them. To maintain the dis-
sure a smooth transition to the ETS2. (2)        tribution of efforts as agreed upon in the
A formula for the maximum financial al-          ESR, it is crucial to manage the distribu-
location from the SCF to each member             tion and flow of revenues resulting from
state. (3) Social Climate Plans (SCPs), to       the trade of annual emission allocations
be assessed by the Commission, in which          (AEAs) (which determines the number
member states articulate the measures            and distribution of ESR certificates) and
to be financed through the SCF, their ex-        ETS2 certificates among member states.
pected costs, milestones and targets. If         This report therefore analyses how wel-
approved, the SCF can finance up to 50%          fare would change if – in contrast to the
of the total SCP costs, with the remain-         European Commission’s assessment as-
der coming from member states’ natio-            sumptions – AEA trade was limited, an-
nal budgets.                                     d/or the ETS2 price were relatively high.
                                                 On the basis of quantitative modelling
While the proposal builds on evidence            results, we discuss various options for
gathered by the Commission for related           how ETS2 allocation and market rules
analysis7, no dedicated impact assess-           could be adjusted to increase the robust-
ment of the SCF has yet been conducted.          ness of effort sharing between member
Other studies have analysed some de-             states in the face of an uncertain ETS2–
sign aspects – most notably the distribu-        ESR interaction.
tional effects of carbon pricing on house-
holds – but key design choices have yet          The third design choice concerns the is-
to be systematically explored. In particu-       sue of how large a share of total auction
lar there needs to be an understanding           revenues the SCF (or an alternative me-
of: (1) the advantages and disadvantages         chanism) needs to be to ensure adequa-
of different design options, and (2) in-         te compensation for households across
teractions with other policies and regula-       the EU, given varying criteria for social
tions at the EU and member-state level.          fairness. This is important because there
This study seeks to address three design         is a trade-off between using revenues for
choices which may have far-reaching              compensation on the one hand, or for fi-
consequences for the overall policy              nancing green investments and infra-
package:                                         structure on the other. Furthermore, al-
                                                 ternative forms of compensation entail
The first design choice concerns the insti-      different administrative requirements
tutional structure and general gover-            and specific challenges. This report dis-
nance level of the mechanism to manage           cusses these issues in light of the SCF
the distributional implications of ETS2.         spending criteria, specifically with a view
While the SCF seems generally capable            to possible adjustments that would
of performing this function, there are           make compensation more targeted.
concerns whether redistribution should
be handled at the EU level (as foreseen
in the SCF proposal) or at the member-

                                                 6 https://ec.europa.eu/clima/eu-action/european-green-deal/delivering-european-green-deal/social-climate-fund_en
                                                 7 See the section titled “Collection and use of expertise” in the SCF proposal (COM(2021) 568 final).
6                                                8 https://ec.europa.eu/clima/eu-action/effort-sharing-member-states-emission-targets_en
A Fair and Solidarity-based EU Emissions Trading System for Buildings and Road Transport - Ariadne Report
2. INSTITUTIONAL OPTIONS
                                                   TO ENSURE SOLIDARITY
                                                   AND SOCIAL FAIRNESS
                                                              SOCIAL CLIMATE FUND AND
                                                              ALTERNATIVES
                                                              Authors: N. aus dem Moore, B. Görlach, F. Pause, J. Nysten, J. Brehm

                                                The SCF, as proposed by the European                                     Different paths to the same goal
                                                Commission, is only one of several diffe-
                                                rent design options for achieving the                                    There is a broad consensus that climate
                                                goal of a socially balanced implementati-                                policy ought to be socially balanced; as
                                                on of the ETS2 – and it may not be the                                   Frans Timmermans observed, “either
                                                best one. This section describes the SCF                                 this will be a just transition – or there
                                                proposal in terms of its institutional cha-                              will be just no transition”9. But the con-
                                                racteristics and compares it to three al-                                crete decisions on who should be eligible
                                                ternative approaches. Two of these mark                                  for compensation, who should be re-
                                                the theoretical extremes along a spec-                                   sponsible for compensation and who
                                                trum of conceivable options. The third is                                should control the spending remain con-
                                                a proposed Social Climate Mechanism                                      troversial. With its proposal for an SCF,
                                                (SCM) – a moderate and viable alternati-                                 the EU Commission has tabled its idea
                                                ve to the SCF.                                                           for a governance structure dedicated to
                                                                                                                         this purpose. This proposal has attracted
                                                                                                                         both praise and criticism, as it touches
                                                                                                                         on a fundamental tension between basic
                                                                                                                         values and principles of the EU:

                                                                                                                         ▶      The EU relies on solidarity between
                                                                                                                                member states, as stipulated in Ar-
    Figure 2: Institutional design options for the social balancing of a new ETS2
                                                                                                                                ticle 2 of the Treaty on European
                                                                                                                                Union (TEU), and within each mem-
                                                                                                                                ber state, the idea of the welfare
                                                                                                                                state may encompass the promoti-
                                                                                                                                on of social protection and inclusion.
                                                                                                                         ▶      At the level of regulatory interventi-
                                                                                                                                on and implementation, Article 5 of
                                                                                                                                the TEU specifies the principle of
                                                                                                                                subsidiarity, stipulating that the EU
                                                                                                                                shall only act within its non-exclusi-
                                                                                                                                ve competences if and insofar as the

7                                               9 Remark by Executive Vice-President Frans Timmermans at the Informal Environment Council on Oct. 1, 2020.
objectives of the proposed action                      of the latter approach is that the                                        METHODOLOGY
        cannot be sufficiently achieved by                     goal of social balancing can be                                           The analysis compares institutions
        the Emember states. However, un-                       achieved through clearly defined ru-                                      based on considerations in law, poli-
        der Article 4 (3) of the TEU, the EU                   les and procedures without recourse                                       tical science and economics. To struc-
        and member states shall work to-                       to the EU budget – thus avoiding                                          ture the analysis and make it trans-
        gether in sincere cooperation to                       some political, legal and administra-                                     parent, a unified framework was
        achieve the goals of the Union.                        tive hurdles.                                                             constructed around the following
                                                                                                                                         eight guiding questions:
Depending on the desired balance bet-                  Step 1: Comparing Option I (“Cheque                                               1. Where do funds originate?
ween subsidiarity and cooperation, go-                 from Brussels”) with Option IV (“No EU                                            2. Which criteria govern the allocati-
vernance can be concentrated more at                   interference”)                                                                          on of resources?
the EU level or at the member-state le-                                                                                                  3. Is member-state co-funding requi-
vel. Correspondingly, Figure 2 illustrates             The two corner solutions mark the extre-                                                red?
four possible design options for the soci-             mes in terms of assigning responsibility                                          4. Where are the funds held?
al balancing of the new ETS2, ranging                  for compensation entirely to Brussels                                             5. Who decides on spending?
from extreme centralisation (“Cheque                   compared to keeping it entirely within                                            6. Are the criteria for spending set
from Brussels”) to extreme subsidiarity                the member states.11 In both cases, the                                                 at the EU level?
(“No EU interference”), with two modera-               revenue from ETS2 initially accrues at                                            7. How is spending controlled and
te options in between.                                 the member-state level; in Option I, the-                                               governed?
                                                       se revenues would then be entirely                                                8. How are funds disbursed?
Description and analysis of different                  transferred to the EU budget, while in
options                                                Option II they would remain entirely at
                                                       the national level. These two options ine-
The analysis of the four options followed              vitably imply further differences, for ex-                                     This option promises a number of advan-
eight guiding questions, presented in the              ample regarding the decision-making                                            tages: It could help avoid the common
“Methodology” Box.10 It was conducted                  authority for expenditures, the question                                       “blame game” in which national govern-
in two steps:                                          of binding criteria, and alternative moda-                                     ments credit themselves for success, but
                                                       lities of disbursement.                                                        blame unpopular elements on Brussels.
1.      The first step looks at the two “cor-                                                                                         It would instead create a more positive
        ner solutions”, i.e. the extreme posi-         The first option, “Cheque from Brussels”,                                      perception of the EU. Furthermore, it
        tions. For these, the analysis points          is based on the premise that if the EU                                         could reduce the risk of misspending wi-
        to severe (conceptual and practical)           places a new burden on European hou-                                           thin member states and reduce the
        deficiencies, implying that they do            seholds, the EU should grant compensa-                                         temptation for member states to use EU
        not represent feasible solutions.              tion. Compensation from the EU would                                           funds to crowd out domestic social assi-
        Looking at these options is nevert-            be analogous to solutions in other coun-                                       stance. Finally, by largely eliminating the
        heless useful since proposals in the-          tries and jurisdictions (e.g. British Colum-                                   member-state dimension in the distribu-
        se directions are on the table.                bia, Canada or Switzerland)12, where it is                                     tion of funding, it would enable the tar-
                                                       granted through a direct transfer pay-                                         geting of funds to the most vulnerable
2.      The second step zooms in on the                ment to households or even by a cheque                                         groups in Europe – irrespective of the
        two more balanced approaches – in              in the mail, with the aim of creating ma-                                      country in which they happen to live.
        a political, legal or administrative           ximum visibility for the compensation                                          There are, however, substantial disad-
        sense. This step contrasts the Com-            payment.                                                                       vantages and risks associated with this
        mission’s SCF proposal with our al-                                                                                           option:
        ternative SCM option. A central idea                                                                                          ▶ Compensation for carbon pricing
                                                                                                                                           becomes part of the EU budget and
                                                                                                                                           the MFF, hence any spending decisi-
                             I                    II                           III                        IV                               ons require unanimity. MFF negotia-
        Option         “Cheque from              SCF                                                   “No EU
                         Brussels”                                            SCM                   interference”                          tions are already extremely difficult
                                                                                                                                           and often result in delayed agree-
                      Compensation is    Commission pro-            Alternative pro-
                                         posal to compen-           posal without re-                                                      ments; it seems risky to further in-
                      handled entirely   sate for effects of        course to the EU              Compensation
    Description       at the EU level    the ETS2 through           budget, organi-               takes place en-                          crease the complexity of this pro-
                      (implementation,   a dedicated EU             zed instead via               tirely at mem-
                      administration                                                              ber-state level                          cess. Moreover, agreeing the criteria
                      and control)       fund                       member-state
                                                                    budgets                                                                for spending at the EU level would
                                                                                                                                           be subject to the same extensive
    Analysis          Step 1                                 Step 2                               Step 1                                   bargaining processes that currently

                                                       10 See tables A2.1, A2.2 and A2.3 in the appendix for a detailed overview of the respective design features.
                                                       11 Table A2.1 in the Appendix shows how these options play out in light of the eight guiding questions.
8                                                      12 See for instance Haug et al. (2018) and Santikarn et al. (2019).
characterize MFF deliberations, limi-     The other extreme option – “No EU inter-                                      This approach would also have conside-
    ting the flexibility of the use of        ference” – embodies the notion that so-                                       rable risks and downsides:
    funds.                                    cial policy should be the sole responsibi-                                    ▶ For some member states, at least,
▶   Distributing funds directly from the      lity of member states, without any input                                           loosely defined criteria for spending
    EU to its citizens would require a        from the EU.13 Since the ETS2 creates                                              would be ineffective for directing
    very substantial (and capable) Euro-      new distributional impacts, according to                                           spending to where it is most nee-
    pean bureaucracy for social policy,       this line of thought, these impacts can                                            ded. The greater room for manoeu-
    which does not yet exist. This pro-       and should be addressed by the member                                              vre at the national level could fa-
    blem is not trivial: even the authori-    states through existing national structu-                                          vour successful rent-seeking by
    ties within member states do not          res. All EU member states have develo-                                             influential interest groups, or ex-
    necessarily have all the relevant in-     ped social welfare arrangements and                                                acerbate existing corruption pro-
    formation pertaining to all of their      structures, but the degree of redistributi-                                        blems, especially if the Commission
    citizens (inter alia, current addres-     on and social security they achieve differ                                         adopts a loose mode of oversight of
    ses and bank accounts). Gathering         considerably. This is not necessarily a                                            national spending.
    this information would thus likely        problem, however; member states opt                                           ▶ Second, if ETS2 revenues flow to-
    involve 27 different approaches,          for the arrangements that best match                                               ward national compensation or wel-
    with complex implications for data        the preferences of their electorate, and                                           fare systems, there is a risk that re-
    protection and privacy. Building up       the EU has neither the mandate nor the                                             venues could crowd out national
    this bureaucracy at the EU level –        tools to change this.14                                                            funding: if member states lower
    apart from the substantial costs in-                                                                                         their own contribution in proportion
    volved – may also be problematic          Member states are presumed to know                                                 to the EU funding, the (expected) so-
    under the subsidiarity principle, sin-    how best to use the revenues for effecti-                                          cial imbalances resulting from the
    ce there is no obvious advantage in       ve compensation – including interactions                                           ETS2 would remain unaddressed.
    having the EU achieve the overall         with existing social programmes. They                                         ▶ Third, from a political–economic
    objective of the revenue distribution.    are also best positioned to identify vulne-                                        perspective, this arrangement
    Furthermore, the EU lacks access to       rable groups and know how they can be                                              would invite member states to con-
    the necessary instruments to effect       effectively supported. Where national                                              tinue the “blame game” described
    compensation by other measures,           funds for a just transition already exist,                                         above, shifting the blame for carbon
    for example by lowering taxes or          ETS2 revenue could be distributed                                                  pricing to the EU while claiming cre-
    fees.                                     through these channels: revenues from                                              dit for spending the revenues and
▶   Finally, the realization of this option   ETS2 allowance auctions would go di-                                               providing social support.
    requires some goodwill (or fantasy)       rectly to the member states that auctio-
    with regard to the political-econo-       ned them, and remain there, much like                                         In sum, these factors constitute a signifi-
    mic motivation of actors: It is an of-    existing arrangements for the current                                         cant risk of misspending (relative to the
    ten-described phenomenon that na-         EU ETS.                                                                       declared intentions), which could under-
    tional governments like to take                                                                                         mine the acceptance of carbon pricing as
    credit for positively perceived (soci-    However, it should be noted that even                                         an instrument.
    al) measures, but in return Brussels      under this option, member states’ use of
    is made the scapegoat for unpopu-         the revenues from the ETS2 would be                                           Taken together, therefore, Options I and
    lar developments. Against this back-      subject to certain guidelines: while there                                    IV represent outliers that could conceiva-
    drop, it is hard to imagine that nati-    would be no restrictions on linkage or                                        bly work if many improbable preconditi-
    onal governments would simply             co-financing through any additional nati-                                     ons were fulfilled, but which also carry
    concede the credit and the praise         onal measures, the target areas for ex-                                       significant risks – political, legal, admi-
    for the social balancing of the ETS2      penditure would at least be broadly defi-                                     nistrative and procedural. The next stage
    to the EU.                                ned.15 Nevertheless, such criteria would                                      of analysis focuses instead on the two
                                              allow member states wide-ranging dis-                                         middle-ground options: the proposed
                                              cretion in choosing what to fund, again                                       SCF and an alternative arrangement, the
                                              similar to the current ETS.16                                                 SCM.

                                              13 There are indeed those who argue against any EU-designed social compensation in the context of ETS2, calling for any engagement to be
                                              strictly optional and at the member-state level (cf. Schmidt & Frondel 2022).
                                              14 There is also a legal aspect to this option: While there is no mandate to provide harmonized welfare systems across the EU, the EU shares
                                              non-exclusive competences to support and complement the activities of the member states in the field of social policy (Art. 151, 153 of the Treaty
                                              on the Functioning of the European Union [TFEU]). However, where the purpose and focus of a measure is the protection of the climate, the EU’s
                                              non-exclusive environmental competence is primarily relevant. When the EU uses this competence and bases a measure on Art. 192 of the TFEU,
                                              the EU shall take into account social aspects when defining and implementing its policies and activities (compare also Art. 9 TFEU). Thus, when it
                                              comes to the EU’s environmental regulation, the EU shall consider the economic and social development of the Union as a whole and the balan-
                                              ced development of its regions (Art. 191 para. 3 of the TFEU).
                                              15 Note that under the current ETS directive, member states should use at least 50% of ETS revenues to tackle climate change, social dimension
                                              included (Art. 10(3); COM-Proposal revision ETS-Dir.).
                                              16 This means that no tightening of conditions, compared to the status quo, is compatible with Option IV, and the set of criteria formulated in
9
                                              the Commission’s SCF proposal must be rejected.
Step 2: Comparing Option II (Social                   lowing it to front-load the SCF. This addi-                                  levant member state and SCF funds
Climate Fund) with Option III (Social                 tional funding would facilitate spending                                     would be distributed to the member
Climate Mechanism)                                    on measures at the very start, or even in                                    state according to a pre-defined schedu-
                                                      advance, of implementing the ETS2. It                                        le, conditional upon achieving the mile-
The two options in the middle of Figure               would also protect funding against annu-                                     stones and targets set out in the SCP.21
2.1 – SCF and SCM – represent two mo-                 al fluctuations in ETS2 revenues. The al-                                    Ex post, each member state would be
derate approaches for strengthening the               location of the SCF’s resources, and                                         obliged to report to the Commission on
social aspect of EU climate policy.17                 hence their availability for member                                          the implementation of its plan as part of
                                                      states’ social programmes, would follow                                      its integrated national energy and clima-
Option “II is the SCF proposed by the Eu-             a calculation formula based on six mea-                                      te progress reports.
ropean Commission. It sees the distribu-              sures of social vulnerability and energy
tional effects of ETS2 compensated for                poverty.20                                                                   Option III, the proposed SCM, is an alter-
through a dedicated fund established at                                                                                            native design that could still achieve the
the EU level. Its specific objective would            Since the SCF would be located at the EU                                     same objective of balancing the distribu-
be to support vulnerable households, mi-              level and managed by the European                                            tional effects of the ETS2, but without re-
cro-enterprises and transport users                   Commission, the use of funding by mem-                                       course to the EU budget. It thereby em-
through temporary direct income sup-                  ber states would be subject to an explicit                                   phasizes the responsibility of member
port and through measures and invest-                 five-step approval procedure, providing                                      states for social policy and gives them
ments intended to increase the energy                 for strong Commission oversight: In the                                      more leeway to define and implement
efficiency of buildings, to decarbonise               first step, each member state would                                          concrete measures.
heating and cooling in buildings, to inte-            have to submit a Social Climate Plan
grate energy from renewable sources,                  (SCP) with “a coherent set of measures                                       One fundamental difference is that un-
and to improve access to zero– and low-               and investments”, together with an                                           der the SCM, no new fund would be crea-
emission mobility and transport.18                    updated version of its National Energy                                       ted at the EU level. Instead, ETS2 reve-
                                                      and Climate Plan. Once the SCP (or a re-                                     nues would remain entirely with member
In the future, member states would be                 vised version of it) has been assessed                                       states and frontloading and smoothing
obliged to pay 25% of the revenues from               and approved, the Commission would                                           would need to happen at the national le-
ETS1 and ETS2 into the EU budget,19 al-               conclude a legal agreement with the re-                                      vel, e.g. through existing funds.22 To
                                                                                                                                   achieve a distribution of financial re-
                                                                                                                                   sources between member states that re-
Table 1: Key characteristics — Social Climate Fund vs. Social Climate Mechanism                                                    flects social needs, the SCM would requi-
                                                                                                                                   re the allocation of ETS2 allowances to
                                                                                                                                   member states to include an element of
            Option                              SCF                                            SCM                                 solidarity.23 The allocation of allowances
                                                                                                                                   would not simply be based on historical
                                  Realizes a targeted allocation of                                                                emissions (as in the SCF proposal) but
                                  resources to member states on             Requires that a social compo-
                                  the basis of a calculation formu-         nent (e.g. the established al-                         would also have to be based on criteria
 Financial allocation across      la that takes social criteria like        location key of the ESR) be                            of fairness, and on exposure and vulne-
 member states                    social vulnerability and energy           taken into account in the al-
                                                                                                                                   rability to ETS2-induced price increases.
                                  poverty at the individual level           location of ETS2 allowances
                                  into account                              to member states                                       Using the established allocation rules of
                                                                                                                                   the ESR, rather than devising an entirely
                                                                            Establishes a higher degree                            new distribution key, could simplify the
                                  Provides for institutionalized ex         of ownership and responsibi-
 Scope and stringency of EU                                                                                                        implementation of the SCM and make it
                                  ante control by the Commission            lity on the part of the mem-
 oversight                                                                                                                         easier to agree on.24
                                  to ensure effective supervision           ber states, who can ultimate-
                                                                            ly implement their own ideas
                                                                                                                                   As member states hold the money under
                                  Coupling with MFF allows for              Whether frontloading and
                                  frontloading and, during an on-           smoothing are possible at the                          the SCM proposal, decision-making on
 Possibilities for frontloading
 & smoothing
                                  going budget period, funding is           national level depends on the                          spending is also leaner, with less super-
                                  independent of fluctuating ETS2           individual fiscal position of
                                                                                                                                   vision by the Commission. In contrast to
                                  revenues                                  member states
                                                                                                                                   the five-step approval procedure of the

                                                      17 Tables A2.1, A2.2 and A2.3 in the Appendix depict how these options map onto the eight guiding questions.
                                                      18 Art. 1 SCF-Reg.
                                                      19 As Table A2.2 in the Appendix documents, exceptions are possible until 2030 (derogation), including deviations from the principle of a uniform
                                                      transfer ratio of 25%.
                                                      20 See Art. 13 with Annexes I and II in the proposed SCF-Regulation.
                                                      21 See Table A2.3 in the Appendix for further institutional details, e.g. on the governance of spending.
                                                      22 In 2016, seven member states (Croatia, Germany, Hungary, Lithuania, Portugal, Slovenia and Slovakia) had dedicated national energy and/or
                                                      climate funds into which EU ETS revenues would flow. See Velten et al. (2016), p. 20.
                                                      23 See the detailed discussion of this point in Section 3.
                                                      24 See Table A2.2 in the Appendix for further details on the allocation of funds under the SCF and SCM proposals. Using the ESR allocation for-
                                                      mula would have the additional benefit of keeping the distribution of the combined revenues from ETS2 and AEA trading (largely) the same, irre-
10                                                    spective of how ETS2 and AEA prices evolve, i.e. irrespective of which share of total trading volume flows through which channel.
SCF, the SCM could entail a three-step         Discussion and recommendations                                               In summary, both the SCF and SCM offer
consultation process: Member states                                                                                         benefits and risks, and deciding which is
would inform the Commission ex ante in         From the broad range of options availa-                                      preferable depends on two specific ques-
writing of their planned programmes,           ble for mitigating the distributional im-                                    tions: First, are member states willing
and the related expenditure needs. The         pacts of extended EU emissions trading,                                      and able to provide adequate social com-
Commission would assess these propo-           this analysis isolated four ways of organi-                                  pensation on their own? Second, to what
sals and, if necessary, issue recommen-        zing the social component. It started                                        extent do the Commission and member
dations for adjustments based on their         with the two endpoints of the spectrum:                                      states share an understanding of “just”
assessment of whether the envisaged            one in which the processes are concen-                                       climate policy, which is a necessary con-
programmes are likely to meet the over-        trated to the maximum degree at the EU                                       dition for sincere cooperation?
arching social criteria; however, the final    level (and hence Brussels would be sen-
decision on the use of funds would rest        ding cheques to all eligible EU citizens),                                   If the capabilities of individual member
with member states. The only constraint        and one that reserves maximum discreti-                                      states, and their commitment to social
would be that a member state would             on for member states, in terms of both                                       balancing, are considered to be high,
have to declare its reasons, should it         decision-making and implementation. In                                       then the SCM appears to be the prefer-
choose to deviate from the Commis-             sum, these extreme solutions fail to con-                                    red option as it allows for a leaner struc-
sion’s recommendations.25                      vince: they could conceivably work if                                        ture and a higher degree of member-
                                               many preconditions were fulfilled, but                                       state ownership. However, if there is
As shown in Table 1, the SCF and SCM           they also carry significant risks – politi-                                  agreement on the interpretation of a just
differ mainly in terms of (i) the allocation   cal, legal, administrative and procedural.                                   transition combined with sincere coope-
of financial resources (SCF) or underlying     In addition, Option I is based on very op-                                   ration between the Commission and
allowances (SCM) across member states,         timistic assumptions about the EU’s ad-                                      member states, the SCF may be the su-
(ii) the scope and stringency of EU-level      ministrative capacities and the readiness                                    perior option: In principle, it allows for a
oversight, and (iii) the possibilities for     of member states to hand over responsi-                                      better achievement of the targets, espe-
frontloading spending and smoothing            bility to the EU, while Option IV is based                                   cially in member states that cannot
revenue flows. The juxtaposition illustra-     on flawed assumptions about the EU’s                                         frontload expenditures and smooth fluc-
tes that the SCF is characterised by a         lack of competence in the area of social                                     tuating ETS2 revenues via their national
high degree of financial stability: Coup-      policy – if indeed this competence is even                                   budgets.
ling with the MFF allows for frontloading      relevant in this case.
and, during an ongoing budget period,                                                                                       Another important factor is the Commis-
funding is therefore independent of fluc-      This leaves two alternatives: the Com-                                       sion’s and member states’ capacity for
tuating ETS2 revenues. Under the SCM, a        mission’s proposal for an SCF and an al-                                     rational policymaking. This is important
comparable level of financial security can     ternative option, namely the SCM. These                                      for judging whether a higher degree of
only be achieved in fiscally sound mem-        options can briefly be characterized as                                      ownership and responsibility at state le-
ber states whose budgets have the ne-          follows:                                                                     vel, as within the SCM framework, would
cessary scope and flexibility for frontloa-    ▶ The proposed SCF is characterized,                                         be advantageous. Yet, any doubt about
ding and revenue smoothing.                         on the one hand, by a high degree                                       the ability or will of member states to
                                                    of stability in terms of financial flows                                use funds appropriately would favour the
Through a higher degree of control on               and, through stricter oversight and                                     SCF, since it provides for effective super-
the part of the Commission (accompa-                more extensive planning, has a                                          vision by the Commission.26
nied by a greater administrative burden             lower risk of resource misspending.
on both the EU and individual member                On the other hand, it is more                                           Another consideration is the desirability
states) and a higher degree of collective           complex in terms of procedures and                                      of using funds uniformly across member
resource mobilization in the form of joint          carries a higher administrative bur-                                    states (pro SCF) or whether a higher de-
frontloading and smoothing, the SCF                 den.                                                                    gree of national fit is seen as more ad-
can achieve greater homogeneity of soci-       ▶ The SCM option, by contrast, has a                                         vantageous (pro SCM). It is ultimately a
al cushioning across member states                  comparatively light structure in                                        matter of the appraisal and weighting of
than the SCM. Because the SCM depends               terms of procedures and associated                                      these aspects, together with policy prio-
more on the resources and capabilities              administrative burdens, but also                                        rities, and that will determine the prefe-
of individual member states, it carries             entails a higher degree of uncertain-                                   rence for either the SCF or SCM.
the risk of widening the differences bet-           ty and volatility regarding financial
ween member states in terms of the                  flows. By giving more leeway to
speed and extent of social compensation.            member states, it provides for more
It is worth noting, however, that the fi-           room to experiment with different
nancial burdens to be offset (due to the            approaches, but also carries a hig-
ETS2) are quite limited in relation to the          her risk that the use of funds will be
size of national budgets.                           poorly aligned with EU objectives.

                                               25 See Table A2.3 in the Appendix for further details, e.g. on the governance of spending.
                                               26 In particular, the fact that disbursement is made in stages after verifying progress against agreed-upon milestones ensures intertemporal in-
11                                             centive compatibility: if a member state deviates from its SCP, it risks losing funding for the next stages of its plan.
3. DISTRIBUTIONAL IMPLICA-
        TIONS BETWEEN MEMBER
        STATES (SOLIDARITY)
                    Authors: M. Kosch, K. Umpfenbach, J. Abrell, M. Pahle

     Considering the interaction between                                        impose a uniform EU-wide carbon price
     the ETS2 and the ESR is essential for                                      on the buildings and road transport sec-
     the robustness of the social compensa-                                     tors. While the scopes of the ESR and
     tion mechanism                                                             ETS2 are not identical, they do overlap:
                                                                                the ETS2 will cover emissions from buil-
     The ESR is a main distributional element                                   dings and road transport, while the ESR
     of the EU’s climate policy architecture.                                   covers all emissions that are not subject
     Based on their GDP per capita and – to a                                   to the ETS1, and thus includes emissions
     lesser extent – their abatement potenti-                                   from land use, agriculture, waste, dome-
     al, some countries have more stringent                                     stic navigation and small industries, as
     targets than others; these range from                                      well as emissions from buildings and
     –50% for richer countries to –10% for                                      road transport covered in the ETS2 (Eu-
     poorer countries, relative to 2005 levels.                                 ropean Commission 2021b, p.2).27 In its
     For all member states to fulfil their re-                                  impact assessment for the revised ESR,
     spective targets, richer countries need to                                 the Commission states that “about half”
     undertake more mitigation and therefo-                                     of current ESR emissions would be sub-
     re spend more on abatement measures.                                       ject to the ETS2 (European Commission
                                                                                2021a, p. 8). While it may seem appe-
     The ESR also foresees several flexibility                                  aling to complement the efficiency of a
     options, including the option for coun-                                    second ETS with the distributional prin-
     tries that overshoot their annual targets                                  ciples of the ESR, the interaction bet-
     to sell their excess AEAs to countries                                     ween the two systems increases uncer-
     that miss their targets. The resulting re-                                 tainty in three dimensions:
     venues can be used to finance abate-
     ment measures or cushion the distributi-                                   (i) AEA trade will likely be limited
     onal impacts of climate policies.
                                                                                The impact assessment does not contain
     The current Commission proposal re-                                        a detailed analysis of AEA trade, but the
     tains ESR targets as a national compli-                                    Commission appears to assume that it
     ance mechanism, and extends the ETS to                                     will take place, since several member

     27 According to calculations by Fraunhofer ISI for the European Commission, based on EU emissions for 2017, 56 % of emissions covered by the
     ESR in this year would fall under the new ETS2 (European Commission 2021a, p. 367).
12
states are expected to generate a sub-        Other analyses (e.g. Abrell et al. 2022b;                                     and consequently less progressive ef-
stantial surplus of AEAs28 (European          Pietzker et al. 2021) suggest it might be                                     fects from revenue recycling.30
Commission 2021b, p. 59). This would re-      much higher. The ETS2 price is highly
sult in a financial transfer from (mostly)    uncertain and hard to predict because it                                      Scenario analysis to explore the effects
richer to (mostly) poorer member states.      depends on various factors such as the                                        of AEA trade and ETS2 price levels
However, in the compliance period to          marginal abatement costs in the buil-
2020, AEA trade has been extremely li-        dings and road transport sectors, price                                       AEA trade volumes and ETS2 price levels
mited; so far, the only example of such a     elasticities and the behaviour of financial                                   will affect the cost-effectiveness and
trade was when Malta used AEAs                actors. These are less well understood                                        equitable distribution of SCF funds. In
purchased from Bulgaria for compliance        than the abatement options and costs,                                         the following analysis, three scenarios
(European Commission 2021d, p. 8).            as well as the preferences of relevant                                        are explored using a static global Com-
                                              actors, in the energy, manufacturing and                                      putable General Equilibrium (CGE) mo-
In practice, AEA trade faces significant      aviation sectors covered by ETS1. Finally,                                    del (see “Model & Assumptions” Box be-
barriers: First, the limited number of        the price depends on the stringency and                                       low). The “base case” scenario is drawn
market participants, in combination with      effectiveness of national companion poli-                                     from the EUs own impact assessment
the penalty payments for non-complian-        cies targeting the ETS2 sectors and thus                                      and two additional scenarios (discussed
ce, will likely lead to monopoly rents,       interacts with the ESR, i.e., if more strin-                                  in detail below) are added to disentangle
where member states with excess AEAs          gent national policies are implemented                                        the impacts of AEA trade from ETS2
use their position to set excessively high    to fulfill individual ESR targets, the ETS2                                   price levels, as illustrated in Figure 3:
AEA price levels. Second, there is no         price will likely be lower.                                                   ▶ Base case (upper right quadrant):
transparent market with a price signal.                                                                                           We assume the coexistence of AEA
Member states thus have to find out the       (iii) Revenue allocation is volatile                                                trade and the ETS2. For the ETS2,
abatement costs of all firms and house-                                                                                           we assume a moderate price of 50
holds to derive the “fair” exchange price.    According to the Commission’s proposal,                                             €/tCO2 with 25% of revenues alloca-
Relatedly, in the absence of a liquid mar-    around 9 billion euros29 would be alloca-                                           ted to the SCF for distribution
ket, member states have high transacti-       ted to the SCF annually. For the assu-                                              among member states, according
on costs for negotiating bilateral con-       med price of 48 €/tCO2 (in the MIX sce-                                             to SCF criteria. The remaining 75%
tracts. Third, governments may prefer         nario), this corresponds to 25% of total                                            is distributed among member
national mitigation measures over AEA         ETS2 revenues. The SCF allocates these                                              states according to historic emissi-
trade, even if they come at a higher cost,    revenues to member states based on so-                                              ons from 2016–2018. We assume a
because domestic climate policy measu-        cioeconomic indicators such as energy                                               functioning AEA trade between
res are seen as having more domestic          and transport poverty levels and gross                                              member states, exploiting all possi-
benefits, especially job creation. Moreo-     national income per capita (European                                                ble efficiency gains from trade.
ver, a majority of member states’ natio-      Commission 2021c, Annex I). The remai-                                              Member states achieve their indivi-
nal climate targets are fixed in national     ning ETS2 revenues would be distributed                                             dual ESR targets through national
climate laws, which typically require         among member states based on their                                                  abatement measures and trade. In
emissions to be reduced domestically.         historic emissions in the period                                                    this case, the total AEA trade vo-
                                              2016–2018.                                                                          lume amounts to around 15% of to-
(ii) The ETS2 price is uncertain                                                                                                  tal ESR emissions.31
                                              Unfortunately, the proposal does not fo-                                      ▶ Scenario 1 (upper left quadrant): No
In its impact assessment, the Commissi-       resee an automatic adjustment of the re-                                            AEA trade.
on considered two main carbon pricing         venue allocation in response to changing                                      ▶ Scenario 2 (lower right quadrant): A
scenarios, both with relatively low ETS2      ETS2 prices. For the extreme case, where                                            higher ETS2 price of 150 €/tCO2.
prices. In the MIX scenario, the ETS2 car-    the SCF is fixed at around 9 billion € per
bon price reaches 48 €/tCO2 in 2030,          year, the SCF share of total funds availa-                                    All scenarios are geared towards the
and in the MIX-CP scenario with less am-      ble for redistribution between and within                                     2030 target of at least a 55% greenhou-
bitious companion policies (and hence a       member states decreases with an increa-                                       se gas reduction compared to 1990. For
stronger role for the carbon price), it in-   sing carbon price. This means less funds                                      2030, 64% of emissions are allocated to
creases to a maximum of 80 €/tCO2 (Eu-        to support low income and vulnerable                                          the ESR sectors, with the rest being allo-
ropean Commission 2021d, p. 121).             households relative to the carbon price,                                      cated to the sectors covered under ETS1.

                                              28 In the impact assessment for the ESR proposal, the Commission estimated that Bulgaria, Sweden, Luxemburg, Romania, Slovenia, Italy, Cze-
                                              chia, Spain, Slovakia, Poland, Portugal, Hungary, Croatia and Greece would generate surplus AEAs ranging from 1 %–29 % of their 2030 emissi-
                                              ons budget (presented in order of increasing surplus). A gap is expected for Lithuania, France, Latvia, Finland, Cyprus, Belgium, the Netherlands,
                                              Germany, Estonia, Austria, Denmark, Ireland and Malta, ranging from 3 %–55 % of the 2030 emissions budget. This distribution correlates – but
                                              does not completely match – with the GDP per capita distribution: Luxembourg and Sweden would generate a surplus despite being above-avera-
                                              ge income, while Estonia, Cyprus, Latvia, Lithuania and Malta are expected to face a gap despite being below the average for EU states (European
                                              Commission 2021b, p. 156).
                                              29 According to the proposal, the SCF would be fixed in size (Art 9): 23.7 billion euros for 2025–2027 and 48.5 billion euros for 2028–2032.
                                              30 In practice, it is likely that SCF revenues will be adjusted depending on the carbon price. However, under the current proposal, it cannot be ea-
                                              sily adjusted because it would be funded through the MFF which has already been set to 2028; any adjustments could only be made thereafter
                                              31 The highest demand for AEA trade comes from Germany (50 Mt) and France (27 Mt), whereas the highest supply comes from Poland (62 Mt)
13
                                              and Romania (32 Mt).
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