House of Commons - The EU Emissions Trading System

The EU Emissions Trading System - Energy and Climate Change Contents

2 Leading by example

13. The EU ETS was the first cap-and-trade system in the world and has provided an example for others of how to deliver emissions reductions at least cost.[18] By pursuing meaningful emissions abatement, the EU Member States demonstrate leadership and effort which underpins confidence in the diplomatic effort to reach the next international agreement to curb emissions.[19] However, in order for the EU to be a credible leader in international climate change mitigation and in the development of international emissions trading, it is necessary for the EU Emissions Trading Scheme (EU ETS) to be as robust a system as possible. In this chapter, we propose a number of ways in which the scheme could be improved: with the current carbon price crisis, a short-term fix may be necessary to rebalance supply and demand and mechanisms should be put in place to improve flexibility in the long-term.

Investment in decarbonisation

14. The EU ETS should deliver short-term economic efficiency and create an incentive for long-term investment in low-carbon technologies. Short-term efficiency depends on meeting the cap within a commitment period, but long-term efficiency depends on a stable and significant carbon price, which can give investors the confidence to choose low-carbon options.[20]

15. In essence, the carbon price is determined by the supply of allowances (the overall cap on emissions) and the demand for allowances (the level of industrial activity). Emissions trading systems are "political" markets in one sense because the balance of supply and demand is defined by the amount of allowances created. The overall number of allowances available gives certainty about the environmental effect of a scheme, while scarcity in the market (the difference between demand for allowances and supply) creates a price. It is this price that can affect investment decisions and promote low-carbon choices, as an extra carbon price can make carbon-heavy schemes less economically viable. Recently, the price of EU Allowances (EUAs) has fallen considerably, as the recession led to a dip in demand.[21]

16. It was clear from our evidence that the ETS was achieving short-term emissions reductions. However it appeared unlikely that current carbon prices would achieve the long-term investment needed to stimulate a shift to a low-carbon economy.[22] The 2011 International Emissions Trading Association annual survey of carbon markets participants found that the average price expected for a 2020 EUA was approximately €20. This was lower than the 2010 survey and significantly below the carbon price (of approximately €50) that respondents believed was necessary to achieve an emissions reduction of 80% by 2050, the goal adopted by the European Council.[23]

17. Some witnesses believed that providing long-term investment signals was not the function of the scheme or argued that controlling fluctuations in price would not be possible, concluding that the main function of the scheme was to keep emissions within the cap.[24] However, investment levels in low-carbon technology depend on the carbon price and the long term stability of cap-and-trade regulation. To attract the necessary investment, the ETS needs to maintain the certainty of regulation and the carbon price. Other witnesses suggested that market intervention, long-term targets, or a reserve price could deliver this stability.[25]

18. At the moment, under the Emissions Trading Directive, the overall EU ETS cap will be reduced by 1.74% each year. This would amount to emissions reductions of 25% by 2023; 30% by 2026; and 37% by 2030. Without sufficient investment this decade, such targets will be extremely costly and may even prove impossible to meet.[26]

OVERSUPPLY

19. In Phases I and II of the EU ETS, the amount of allowances available and access to offsets were determined by each Member State's estimates of its emissions in a National Allocation Plan. The National Allocation Plans were extremely generous, generating more EU Allowances than there were emissions. In Phase I this caused the price of EU Allowances to fall to almost €0. In Phase II, although the EU Commission forced almost all Member States to revise their allocations, a large surplus remained. Some estimates suggest that Phase II could end with an overall surplus of 1.0-1.7 Gt CO2e.[27]

20. From Phase III, the overall EU ETS cap is determined centrally, with no role for National Allocation Plans, reducing the risk of oversupply. However, the generous allocations already made do not end with Phase II because surplus allowances can be carried over ("banked") for use from 2013 onwards. This could mean that no domestic emissions reductions are necessary until 2018 as emitters have enough allowances to cover their emissions.[28] Oversupply, combined with a fall in industrial output brought about by the recession, has caused the price to fall to about €7 in December 2011, the lowest since 2009.[29] Deutsche Bank's price prediction for the first half of 2012 was €5-7/tCO₂. This compared with prices of around €30/t in mid-2008.

21. The emissions trading system will deliver short-term environmental goals, but if it is to drive long-term investment decisions a strong and stable carbon price signal is necessary. This can only be provided by a scarcity of EU Allowances. The EU ETS needs to be strengthened and issues resolved before Phase III starts in 2013.

22. The Committee has heard a number of proposals for maintaining a strong carbon price, including:

Increasing the emissions reduction target by lowering the overall cap;
Setting aside surplus allowances;
Establishing targets further into the future; and
Setting a reserve price for auctions of EU Allowances.

We will look at each of these in turn.

INCREASING THE TARGET (REDUCING THE CAP)

23. The most effective way to rebalance supply and demand would be to adjust the overall EU ETS cap. This option is complicated by the fact that the cap is set by the EU Emissions Trading Directive and so a revision would require EU-level negotiations to amend the Directive. A move to a 30% reduction target is already being pursued by DECC.[30] In May, Chris Huhne told the House that:

we are making progress with our aim to achieve a 30% reduction in carbon emissions by 2020. A number of other countries have joined us in the call for that, including, recently, Denmark, Sweden and Spain, and I am confident that we will make further progress among our partners in the months to come.[31]

24. Many witnesses advocated such a shift. For example, six major European utilities recently called for a 25% rather than 20% reduction in GHG emissions by 2020.[32] Others, such as National Grid and WWF, have called for a 30% reduction target.[33] Some witnesses suggested more specific adjustments in the cap. Sandbag—a climate change campaigning organisation—calculated that supply in Phase III should be reduced by 1.7Gt to generate real scarcity and suggested that the annual reduction factor of 1.74% should be increased to at least 2.4%, which would lead to a lower cap each year.[34]

25. In December 2011, the EU Parliament Environment Committee voted to increase the rate at which the cap was tightened from 1.74% to 2.25%, which would eliminate more than 8.5 billion EUAs by 2050.[35] This proposal would need to be approved by the European Parliament in plenary session and by the Council of Ministers in order to become law.

26. We welcome the decision of the EU Parliament's Environment, Public Health and Food Safety Committee to support an increase in the annual reduction rate for the EU ETS cap. The linear reduction of 1.74% per year must be adjusted to set out a long-term emissions trajectory that would deliver a 60%-80% reduction in greenhouse gas emissions by 2050. The Government should lobby for this adjustment to be approved in the European Parliament and by the Council of Ministers.

27. The overall EU ETS cap should also be revised to deliver more ambitious emissions reductions. A 30% emissions reduction target for 2020 would be appropriate and we support the Government's efforts to secure agreement for this target.

A SET ASIDE OF EU ALLOWANCES

28. A second option for rebalancing supply and demand would be to "set aside" a share of the allowances planned for auction. This would simply mean removing a number of EUAs from the number that would be auctioned by each Member State in Phase III. A set aside would increase demand for the remaining allowances and raise their price. These allowances could then be held in reserve until a later date, or cancelled altogether.

29. The possibility of a set aside has already been discussed at the EU level.[36] Although the European Parliament initially rejected proposals for a set aside, an amendment to the draft Energy Efficiency Directive is currently being considered which would mandate the set aside of 1.4 billion allowances.[37] The amendment is intended "to restore the price mechanism to levels envisaged in the impact assessment on which basis [the energy efficiency directive] was agreed".[38] Fifteen companies and lobby groups—including Dong Energy, Alstom, Vestas and Shell—wrote to the president of the EU Commission in support of the amendment.[39] EUA prices rose as much as by 32% when the EU Parliament's Environment Committee voted in favour of an additional amendment to "withhold a significant amount of allowances".[40] Like the amendment to the annual adjustment, the amendment would need to be agreed by the Parliament in plenary session, as well as by Member States, in order to become law.

30. The withdrawal of 1.4 billion EUAs would, according to Shell, push up the ETS carbon price to around €23/tCO₂.[41] Since it could also generate extra revenues for governments, which could be invested in low-carbon technology, the extra value created by the increase in price was expected to be more than the value of the allowances that would be set aside.[42] Shell argued that:

Reducing auctioning rights by some 15% over the whole period 2013-2020, representing some 1.4 billion allowances, could be sufficient. Projections suggest that auctioning revenue might increase by around a third, because carbon prices are expected to increase by more than the reduction of allowances auctioned.[43]

Shell believed that the most appropriate method to achieve a robust carbon price would be to set aside allowances from Phase III auctions.[44] This option could also require a revision of the EU ETS Directive. Without a revision of the ETS Directive before 2020, any allowances that had been set aside may have to be put back on the market under Article 10 of the ETS Directive.[45]

31. Some witnesses were concerned that artificial intervention and resulting price inflation would undermine market expectations. Short-term measures that interfered with an already agreed emissions cap could heighten perceptions of political risk, undermine confidence and damage long-term investment.[46] Others suggested that adjusting the cap to match demand during the recession would stifle recovery.[47] We acknowledge these concerns and agree that in future any market intervention must be made according to clearly defined rules. In this case, however, we believe that circumstances necessitate action.

32. In the early stages of EU ETS, a separate pot of EUAs was maintained as a New Entrants' Reserve (NER), which was intended to provide free allowances to new emitters. As the extent of over-allocation became clear, 300 million allowances from the NER were set aside under Article 10 (a) of the revised ETS Directive and converted into a financing instrument for low-carbon projects, known as the NER300.[48] These allowances would be sold to support innovative renewable energy technology and carbon capture and storage projects. A similar arrangement may be possible for further allowances set aside by the Commission.

33. The EU Parliament should vote to set aside a significant number of EU Allowances and Member States should support this move as a necessary short-term fix for the EU ETS.

34. In order to avoid creating uncertainty, any set aside of allowances would need to be carried out under transparent rules, based on an objective assessment of over-supply and reduction in demand caused by the recession. A set aside may be an appropriate short-term mechanism for dealing with the surplus of EU Allowances, but there should be a clear mechanism for retiring allowances or returning them to the market at a later date. A set aside could provide a useful pool of allowances to support low-carbon development, following the example of the New Entrants Reserve.

SETTING LONG-TERM TARGETS

35. A third way to improve prices in the short-term would be to set ambitious long-term emissions reduction targets. Increased certainty about the trajectory of emissions reductions could add value to allowances now, because it would give emitters confidence that allowances will become increasingly scarce and valuable in the future.

36. Investment in low-carbon technology is a long-term commitment. The life-cycle of some industrial or power projects can be up to 60 years.[49] Therefore developers need to be satisfied that a suitable cost of carbon will be maintained to support the projects. Long-term targets would help to create this certainty. They could also help to support the current market price for EU Allowances by showing that demand would be sustained through the life of an investment. With plans only running until 2020, firms are unable to tell if their investment will pay off.[50]

37. Targets could be set for commitment periods much further ahead, following the example of the UK Climate Change Act 2008, which sets a target for 2050. Witnesses suggested that long-term targets could do more to strengthen the CO₂ price level than short-term interventions such as auction set-asides.[51] The EU's 2050 Roadmap could give clarity to industry on the post-2020 abatement trajectory in the EU.[52]

38. Long-term targets would be an effective way to create certainty for investors in low-carbon technology and to give a clear picture of likely demand for EU Allowances over time, which would improve price predictability. Firm emissions reduction targets should be set for 2050, based on the 2050 Roadmap. Indicative targets should also be laid out for the intervening periods, with a mechanism for confirming precise targets in advance of each Phase of the EU ETS.

CARBON PRICE FLOOR

39. The most direct way to maintain a specific range of prices in the EU ETS would be to set a carbon price floor at EU level. In doing so the market basis of the scheme would be weakened and it would take on more "tax-like" features by creating more certainty about price at the expense of the some of the efficiency of a trading system. The UK has set a unilateral Carbon Price Floor, which we consider further in Chapter 3. For now, we will focus on EU-level price intervention.

40. A price floor could be achieved in a number of ways. For example, it would be possible for governments to buy back allowances when they fell below a certain price. Several witnesses believed that an auction reserve price would be the best way to give certainty about future carbon price trajectories and reduce volatility.[53]

41. A floor price would send a clearer, long term signal to investors about the price of carbon and should support more low carbon investment.[54] It may also limit the overall number of EUAs available, if some were to remain unsold. Shell considered that an auction reserve price should be set for Phase IV of the ETS, with the price set well in advance.[55] Setting an auction reserve price for Phase IV could also give new value to existing allowances because they could be banked into future phases and benefit from the known auction reserve price.[56] The price floor could be increased over time to ratchet up the incentives for reducing emissions.

42. However, the Commission believed that agreeing a reserve price would be difficult because of different levels of ambition among Member States. Commissioner Hedegaard told us that some Member States would prefer prices to be capped at the level proposed for a price floor.[57]

43. We agree that a common EU-wide auction reserve price would give long-term confidence to emitters. The auction reserve price should be announced well in advance, and ideally as soon as possible. Provided that it was set at a sufficient level a floor price would create long-term strength and predictability for the carbon price, giving a better signal for investors.

FLEXIBILITY

44. A major cause of the weakness and volatility in the carbon price has been the inability of the EU ETS to respond to changes in demand caused by factors outside the control of the System. The recession has caused a serious dip in demand for EU Allowances. New emissions reduction policies, such as the proposed Energy Efficiency Directive, could also bring about reductions in demand which were not anticipated when the cap was set. In combination with factors inside the system—such as over-allocation—this has led to a serious lack of demand with no mechanism for adjusting supply.[58]

45. Ideally, it would be possible to address each policy objective with a single economic instrument. However, in reality it is often necessary to adopt a number of approaches to a problem, especially one as complex as climate change mitigation. The EU ETS is designed to uncover and exploit low-cost emissions reduction opportunities, but other instruments may be needed to overcome other market failures. For example, the Renewable Energy Strategy Directive could drive innovation and bring new technologies to market, while the Energy Efficiency Directive could unlock cost reductions and energy saving measures that the ETS cannot access.[59]

46. Where new policies influence demand in the ETS, it may be necessary to compensate by adjusting the cap in order to maintain sufficient scarcity to support a credible price of carbon.[60] In its Roadmap for moving to a competitive low carbon economy in 2050 and the impact assessment in the proposal for a Directive on Energy Efficiency (EED), the European Commission has already recognised that overlapping policies will affect demand in the EU ETS.[61] The EU Commission's impact assessment estimated that the 2020 carbon price would fall to €14 or even €0 (down from forecasts of €25) if no adjustment was made to counteract the drop in demand caused by the implementation of extra energy efficiency measures.[62] If the carbon price drops while the cap on emissions under the ETS remains unchanged, facilities outside the scope of the EED could increase their emissions, resulting in no net environmental benefit. Shell suggested that there was a good opportunity to use the EED consideration process (which will be completed in 2013) to take steps to boost the carbon price and ensure the success of the ETS.[63]

47. Sandbag calculated that the full EU climate package would deliver a reduction of 4 Gt of domestic emissions by 2020 plus 1.6 Gt of offsetting, reducing Europe's total emissions by 5.6 Gt. This would be lower than the ETS cap and store up 2.1 Gt of allowances for use beyond 2020, equivalent to more than a year's worth of emissions from the traded sector.[64] Already, more than three-quarters of installations have surplus permits, which means they can delay taking action to reduce their greenhouse gas emissions.[65]

48. We heard that the fear of weakening the carbon price could even undermine other policy objectives, if policymakers feel constrained in their ability to aim for emissions reductions because of the effect it would have on the cost of EUAs. For example, the Integrated Pollution Prevention and Control (IPPC) Directive was modified to exclude CO2 emission limits for installations which are covered by the EU ETS because of the effect this would have on carbon prices.[66]

49. A mechanism by which the emissions cap can be adjusted in a transparent and timely manner to account for supply-side changes, such as the global recession and new policies, would strengthen confidence in the ETS by setting a minimum level of scarcity.[67]

50. Vattenfall—a major investor in EU energy markets—emphasised that any changes would need to be completely EU-wide and predictable from a regulatory point of view, which may be easier to achieve by setting out rules, rather than negotiating changes.[68] Several witnesses highlighted the importance of predictability and avoiding ad-hoc policy.[69] The disruption caused by adjusting the cap would be minimised if the ETS Directive did not need to be renegotiated. The ETS Directive already includes a framework for changes without amending the Directive in some areas. Member States are able to include new gases and industries in the ETS under certain conditions, or to allow the exclusion of some small installations.

51. A central institution, with clear terms of reference and objectives, could manage the supply of allowances within the EU ETS, in a manner that was independent of short term political concerns, while being required to pursue ambitious emissions reduction goals.[70] This would be similar to the role played by the European Central Bank on Eurobonds, and the Monetary Policy Committee on inflation. In this way, changes could be made in a way that increased confidence in the overall direction of the scheme, rather than reducing it.

52. Such a body could have a mandate to: set aside EUAs; release EUAs from a strategic reserve; cancel EUAs; or purchase EUAs, in order to maintain a predetermined level of stringency. This could guard against future recessions, non-compliance, or other unexpected events, so that the price of EU Allowances reflected actual abatement, rather than other factors. It could also adjust supply to implement new emissions agreements on the basis of international agreements or advancing scientific understanding.

53. The need to maintain a stable and effective carbon price should not be a reason for delaying other emissions reduction policies, but additional emissions reduction measures should not undermine the price of carbon. In order to avoid this situation, a flexibility mechanism should be adopted. A lack of flexibility in the EU ETS reduces investors' confidence in the System as a basis for a credible carbon price. The Directive should be amended to allow increased flexibility without the need to renegotiate the whole Directive each time certain modifications in policy are needed. An independent market oversight body is necessary to respond to changes in policy, science and the economic situation without increasing political risk. There are a number of international examples of similar bodies. The Government should work up proposals for a market oversight body to be established at the EU level and put them forward as soon as possible.

54. A supply-side mechanism for adjusting the cap in response to economic shocks or internal policy change is necessary to ensure that the whole EU remains on a reliably robust decarbonisation trajectory.

Influencing design

55. As the design of EU ETS is improved, the EU and its Member States have an opportunity to guide the design of emissions reduction policies in other countries. This will be important both to help ensure that the world develops effective policies for averting dangerous climate change and for encouraging ETS designs that would be compatible with EU ETS. Drawing on the experience of the EU could help others to reduce the time needed for design and implementation phases of new schemes.[71]

56. The Government already contributes to the development of international emissions trading in a number of ways:

a) The UK, along with other EU Member States, has pledged £7million to the World Bank Partnership for Market Readiness, which aims to build capacity for market-based instruments including cap-and-trade in developing countries. So far, eight countries are due to receive a preparation grant of $350,000.[72]

b) In collaboration with DFID and FCO, DECC has been helping the Government of India to design and implement a new energy efficiency trading scheme. According to DECC, the scheme is a "step towards the creation of a domestic carbon market".[73]

c) DECC has also been working with the Republic of South Korea to help draft emissions trading legislation, with a scheme due to start in 2015.[74]

More broadly, the EU has set up the International Carbon Action Partnership (ICAP), to promote the efficient use of mandatory cap-and-trade systems. It is intended that ICAP will facilitate linking of trading programmes.[75]

57. The EU and Member States should encourage and provide capacity building to other countries to develop market-based instruments and make available their expertise in technical subjects, such as monitoring, reporting and verification, allocation, benchmarking and trading infrastructure.

58. Because emissions trading systems create a kind of "common currency", in the form of emissions allowances and offsets which all represent a certain volume of greenhouse gas pollution, it is possible for separate schemes to be "linked". Linking allows emissions units from one scheme to be used in another. Linking can take place bilaterally (where units can flow both ways), or unilaterally (where one scheme recognizes units from another for compliance, but not vice-versa).

59. Linking schemes would increase liquidity and widen the available pool of low-cost emissions reduction opportunities. This could increase efficiency and price certainty.[76] DECC cited evidence that global carbon trading, through linking of ETSs and use of international credits, could reduce emission reduction costs by up to 70%. This would allow reduction of global emissions by an extra 40-50% at the same cost.[77] Linking between one or two schemes could also have efficiency benefits. However, so far, linking has only taken place on a limited basis. The countries of the European Economic Area (EEA) have linked with EU ETS and several schemes have linked unilaterally with the Clean Development Mechanism (CDM), the UN offset scheme.[78]

60. The EU should encourage other countries to develop robust emissions reduction policies by setting out its own criteria for linking with the EU ETS.[79] If other countries perceive a link with EU ETS as a way of reducing the cost of their own emissions reduction efforts, they may be more inclined to adopt a scheme that would be compatible with EU ETS. Linking could also reduce the impact of carbon leakage as carbon prices could equalise between the linked schemes. Professor Fankhauser suggested that linking emissions trading schemes was the simplest solution to leakage carbon mitigation efforts between countries.[80]

THE RISKS OF LINKING

61. A major challenge to linking systems would be in managing different prices of carbon around the world and different levels of ambition. Harmonisation is likely to be extremely difficult where countries are at different stages of economic development or economies are locked in to high carbon technologies. The design of other schemes would almost certainly have to cater to national priorities and particularities.[81] If these features were not coordinated there could be an unintended flow of allowances between systems, which would entail a transfer of funds from one country or region to another.[82]

62. The environmental integrity of a scheme could also be compromised if a linked scheme is not designed carefully. At present, the EU ETS excludes certain land-use and hydro-power offsets and will also exclude HFC and N₂O offset credits from April 2013; these offsets have become notorious for the perverse incentive they create to increase production in order to cash in on carbon credits. This kind of quality control would be impossible if the scheme were linked with others that did not share these exemptions.[83]

63. Linking will require serious attention to design harmonisation and should only involve thoroughly tried and tested schemes, so that any potential problems can be identified before linking is considered.[84] At least four design features need to be coordinated to link cap-and-trade schemes:

a) Monitoring, reporting and verification rules as well as compliance and enforcement mechanisms;

b) Limits on the use of international credits (offsets);

c) Banking and borrowing rules; and

d) Price interventions (e.g. price floors and ceilings).[85]

64. While the top down climate negotiation is moving very slowly, a process of linking emissions trading systems could help to ensure concerted international action on climate change.

65. Any schemes being considered for linking with EU ETS would need to demonstrate strong environmental integrity and be sufficiently mature to have a credible track record, so that any initial teething problems could be resolved before linking took place. In order to promote the adoption of compatible policy design, the EU should publish a set of minimum standards for the kinds of emissions trading system it would consider linking with.

POTENTIAL PARTNERS

66. DECC's intention is that by 2020 it should be possible to start linking with other compatible cap-and-trade schemes and to create a network of linked ETSs.[86] Although there are few no ETSs currently in a position to consider linking in the short term, schemes are emerging that may become suitable for linking. Damien Morris of Sandbag described 2015 as a "critical year", when several schemes could reach maturity.[87]

67. At the moment, at least twenty nations are considering cap-and-trade, either nationally or at a regional level, including South Korea, Australia, Japan, Taiwan, Brazil, India, United States and China. We heard that the EU was being consulted on all steps of implementation from monitoring, reporting and verification to the trading framework needed to have a liquid but well-regulated market.[88]

68. The influence of the EU ETS in policy-design may be particularly important in relation to China.[89] Not only is China the most prolific emitter in the world, there is also the likelihood that if China adopts emissions trading this will prompt other major emitters to follow. According to China's latest Five Year Plan, pilot emissions trading schemes will be developed before 2013, based on provincial energy consumption targets. The pilot schemes may be unified and scaled up to a national programme after a two-year test phase. However, no plans on the scope or design of such a scheme have as yet emerged.[90] These pilots could cover the emissions of many millions of people, so encouraging a robust design could have a significant effect on global emissions.

69. Sharing expertise with countries developing domestic trading schemes, particularly China, should be encouraged in order to ensure that these nations benefit from the experience gained in introducing the EU ETS. Partnership with key emitters such as China could act as a wake-up call to laggard states and improve the chances of an international deal. Together, the EU and China could reach a critical mass of key emitters involved in emissions trading. The EU should cooperate with China in the development of its own climate change mitigation policies and help to shape its nascent emissions trading schemes.

18 Ev 44 [DECC]; Ev w33 [National Grid]; Ev w61 [Drax Power] Back

19 Ev w41 [SSE]; Ev w100 [ScottishPower]; Ev w15 [Energy Services and Technology Association] Back

20 Ev w104 [Emissions Trading Group] Back

21 Pointcarbon.com Back

22 Ev w49 [Shell]; Ev w41 [SSE]; Ev 44 [DECC] Back

23 European Council Conclusions 29/30 October 2009; Ev w59 [Pricewaterhouse Coopers] Back

24 Ev w63 [Confederation of Paper Industries] Back

25 Ev w59 [Pricewaterhouse Coopers; Ev w92 [Carbon Capture and Storage Association]; Ev w92 [Carbon Capture and Storage Association] Back

26 Ev 52 [Barclay's Capital] Back

27 Ev w54 [Friends of the Earth]; Ev 77 [Sandbag]; Ev w74 [FERN]; Ev w17 [Civitas]; Ev w49 [Shell]; World Bank, State and Trends of the Carbon Market 2010, May 2010, p. 57 Back

28 Ev w54 [Friends of the Earth]; Ev 77 [Sandbag]; Ev w74 [FERN]; Ev w17 [Civitas]; Ev w49 [Shell]; World Bank, State and Trends of the Carbon Market 2010, May 2010, p. 57 Back

29 Pointcarbon.com; Ev w24 [Centrica] Back