Claim VS Fact:

“The overall steel sector will be in shortage of allowances well before 2020. The EC impact assessments are flawed and structurally play down this huge impact.”

“If the EC can push through their wishes, by 2030 the steel sector will have a CO2 allowance shortage of around 50% with excessive CO2 and power prices. No steel plant can survive this, but most Eastern plants will be hit hardest.”

“For ArcelorMittal Europe, an introduction of MSR with freezing of backloaded allowances by 2017 could cost us around 1 Billion Euros only until 2021 (depending on the carbon price impact).”

“On average the carbon price increases by up to 40% of the wholesale power price for the period 2021-2024.”

1. Underestimating the scale of future surpluses: Eurofer’s estimations for the carbon price are outdated, with new evidence suggesting much larger surpluses and therefore much lower carbon prices in 2020. Eurofer’s price estimates seem to coincide with figures presented by PointCarbon during the Experts Meeting hosted by the Commission on June 25, 2014. At the time, the expectations for the surplus in 2020 were 2.6 billion tonnes, as suggested by the Commission. In the meanwhile, it has become clear that the 2020 surplus will probably be much larger. Preliminary evidence shows that 2014 emissions are far lower than had been widely anticipated, suggesting larger surplus estimates, as prepared by the UK government (3.1 billion) and by Sandbag (4.5 billion), are more likely. This in turn means carbon prices are likely to be lower than the values cited by Eurofer.
2. Ignoring the safety features built into the MSR: The MSR by its very design prevents the market from becoming too tight. This is because the MSR attempts to steer the surplus into a zone between 400 and 833 Mt, where the Commission deems that large-scale market players’ hedging needs for EUAs are satisfied. As long as this matter is safely taken care of, enough slack in the market is ensured for other players. This factor alone ensures that price spikes are defused. However, this buffer can only become more pronounced in the future, because hedging needs are set to decrease for a number of reasons:
   1. As more and more renewable electricity continues to be fed into grids at a priority, electricity generation in thermal power plants (the only ones requiring carbon hedging) diminishes progressively because of diminishing residual demand.
   2. An increased role of fluctuating output renewables in electricity generation means that it is no longer meaningful for utilities to hedge a year or more ahead. Instead, they require only much smaller hedging volumes for significantly shorter time horizons.
   3. New regulations introduced in response to the financial crises of the past years have increased credit requirements for derivatives trading, making taking out lengthy hedging positions more costly.

   All three of these factors indicate that hedging requirements are contracting. This frees up allowances for other market players and puts additional downward pressure on the carbon price, making fears of rapidly escalating prices overstated.

High emissions forecasts, and high hedging assumptions have driven up the price forecasts of many analysts, but these are steadily being revised downwards in light of new evidence in both areas. Point Carbon recently issued a media advisory anticipating that the average price of carbon would be €23 per tonne for 2021-2030 under the most ambitious version of the MSR looked at by Eurofer (2018 start with backload placed in the MSR). This price is down €4 from their forecast for the same scenario just six months earlier (€28/tonne), and is now much closer to the prices that were then forecast for the Commission’s much more modest proposal (€24/tonne with 2021 start date and backload released to market).

“An early introduction of Market Stability Reserve (MSR), with possible freezing of backloaded allowances, increases the steel sector’s costs even more, as it has much less carbon leakage protection against the higher CO2 and power price impacts […] politically it will be only possible to solve this current impact at the Post-2020 ETS Review”.

The current carbon leakage list covers 99.73% of manufacturing activities covered by the ETS and provides continued free allocation according to efficiency benchmarks until at least 2019. The recent 2030 Climate and Energy Package, agreed in October 2014, explicitly states that carbon leakage rules will be revised and improved to provide better protection in the future against the risk of competitiveness impacts. Carbon leakage provisions are not therefore being phased out, in fact they are likely to be improved making them more targeted – rewarding companies who invest in increased production (using better production threshold triggers) and looking again at the balance between allowance allocations to the power sector where emissions are rapidly declining, and industrial sectors where the transition to low carbon technologies is yet to get underway.
Instead of lobbying against the introduction of an effective MSR ArcelorMittal should be offering concrete proposals to improve the free allowance allocation process post 2020 and also suggesting policies such as the NER 400 which can form part of a policy package to incentivise investment in lower carbon technologies in industrial sectors including support for CCS.
On Wednesday, September 24, 2014, the EU’s current provisions for protecting sectors deemed at risk of carbon leakage were extended until 2019, despite an impact assessment from the Commission clearly indicating these protections were exaggerated. Manufacturers’ carbon leakage exposure has been assessed using a carbon price of €30/tCO2, but the real price of carbon today (January 21, 2015) is €7.41. A Commission Impact Assessment estimated that using this inflated price to calculate leakage exposure awarded additional carbon assets to industry worth €39 billion.
Sandbag calculates that a 99.73% of manufacturing activity has been defined as at risk of carbon leakage, indicating that effectively all manufacturers have been granted extra free allowances on this basis. The extension of an already exaggerated carbon leakage list, calibrated for a vastly inflated carbon price, hardly counts as a phasing out of protections or an attempt to increase costs for manufacturers – iron and steel or otherwise.
ArcelorMittal is right to say that carbon leakage rules will not be revisited until the post-2020 ETS review, but this is no excuse for delaying the implementation of the market stability reserve. The European Council and several parliamentary groups have expressed clear support for extending and improving the carbon leakage protections offered from 2021. However, the ETS remain first and foremost an instrument of climate policy, and the current discussion in the European Parliament is aimed at correcting a fundamental design flaw – that of an inflexible supply that leads to massive surpluses, which in their turn render the entire scheme ineffective. Arguing that repairing the EU ETS should be deferred until 2021, after the competitiveness concerns of already protected industry have reviewed, needlessly delays these urgent and essential reforms.