Recently a discussion group was asked for information on the area needed to make a Carbon Farming Initiative (CFI) methodology viable. I follows the answer is not as simple as it should be and part of the problem is the rules can change and even the responsible entity itself might change. This statement is not an example of a remote possibility, it is very much what is likely to happen.
First issue: The market.
Currently a Australian Carbon Credit Unit is reported as holding steady at approximately the Carbon Price Mechanism expectation of $23 (actually ACCU spot price is $22.60 at 4 April 2013). Compared to the trading prices of others. For example the Carbon + Market Daily (www.cedaily.com.au) shows European Union Allowances (EUA eligible on Australian Scheme from mid 2015 – June 2016: AUD $7.48 – no change) * Certified Emission Reductions (CER eligible on Australian Scheme from mid 2015 – June 2016: AUD $0.67 – up 6.4%) * New Zealand Units (NZU spot can’t be used to meet liabilities under the Australian scheme: NZD $1.97 – down 2.5%) * Australian Carbon Credit Units (ACCU spot Kyoto units issued under the CFI that can be used to help meet Australian scheme liabilities: AUD $22.60 – no change). They also report of conflicting market drivers, and this is in addition to the Coalition threats to dismantle the carbon price mechanism, that the European market is struggling to hold above EUR5 on moderate volumes. Problems include:
1) An increasing likelihood that backloading will be passed as more countries come out in support of the proposal; and
2) High auction volumes relative to emitter demand.
3) Increased selling in the New Zealand market as more participants’ look to switch out of their NZUs and into cheaper international units.
4) June 2016 prices for EUAs and CERs reflect the cost of these units to an entity liable under the Australian scheme’s floating price phase.
5) The EUA (December 2013 contract) is a focus as this drives price movements and is a key indicator of EU (European Union) market sentiment.
Conclusion – first issue: Transactions involving carbon give rise to substantial risk (including regulatory risk) and are not suitable for all investors. It is recommend that you seek your own independent legal or financial advice before proceeding with any investment decision
Second issue: Carbon Auction Rules.
The Clean Energy Regulator is likely to be required to offer 60 million carbon units in 2013-14 under draft carbon auction rules. The potential is the opening price is at 60% of the international market price. Follow the link of the
exposure draft of a carbon auction determination, and it will outlines arrangements for auctions that are set to begin next financial year.
If you are relying on an incoming Coalition Government to repeal the determination, you should note s113(9) of the Clean Energy Act allows the Regulator to hold auctions even without the determination. It might not be so simple as a statement to win votes – it is written in stone so to speak.
Conclusion – Second issue: Without control of the senate, or if the senate is hostile, a Coalition repeal instrument would be disallowable. This introduces additional risk, and additional to regulatory risk. As in the first issue it is recommended you seek your own independent and financial and legal advice.
Third Issue: ACCU methodology.
It costs up to $1M to develop a methodology acceptable under CFI. Once accepted the transaction cost to create the ACCU’s is said to be about $70,000. Although it is not a definite cost, it can be less but a reasonable guide and it requires you to look carefully at the potential yield of each project and whether you can smear the transaction cost across the entire project to determine the minimum size for it to be a worthwhile program.
One way to develop a methodology and reduce your cost base is to apply to the Methodology Development Program (MDP) for a grant to develop the methodology. The MDP is a $19.6 million for the development of methodologies for use in the Carbon Farming Initiative. The fund is administered by the Department of Climate Change and Energy Efficiency (DCCEE).
However, recently the Government has moved from 26 March 2013 that DCCEE be in transition to be part of a new super department called the Department of Industry, Innovation, Climate Change, Science, Research and Tertiary Education. It is reported as a move the Australian Government hopes will be seen as logical and a way to portray that climate change is taken seriously across all of government and across all portfolios. Details changes are yet to be fully announced, albeit it is known the Climate Change Adaptation Strategy has changed with 140 projects, 33 university programs and 100 researchers affected – source ABC.net.au.
Conclusion – Third issue: Before expending too much time on the methodology. The suggestion is you follow up on who would administer the program post transition to the super department, and the will to continue with the program. Any changes will have cost implications for your efforts.
If only we had certainty!