Danny Cullenward Profile picture
May 30, 2020 28 tweets 10 min read Read on X
1. Check out my latest on California's cap-and-trade program:
2. At the quarterly auction last week, the state collected only $25M instead of the usual $600-800M. Why? lao.ca.gov/LAOEconTax/Art…
3. The answer is simple—the program has too many allowances.
4. A little background: it's an old problem, common to environmental markets around the world. This is the second time in four years California has had a revenue shortfall as a result of having too many allowances. Image
5. Legislation in 2017 extended the program to 2030 and put the auctions back on track. It also required the regulator, CARB, to "evaluate and address" the excess allowance problem. Guess what happened?
6. CARB put out some bad numbers to justify taking no action—demonstrably false and totally beneath the agency's hard-earned reputation. CalMatters' @julie_cart covered the exchange here: calmatters.org/environment/20…
7. So having kicked the can down the road, CARB ended up with a market design that looked, in every practical respect, like the oil industry's wish list (cc @RL_Miller). Way better than nothing, but far less than what's needed for the state's climate goals.
8. Take it from the great @drvox, who dug into all the glorious details: vox.com/energy-and-env…
9. In one fell move, big oil rolled back local air districts' climate authority, prevented new statewide regulations on the oil and gas industry, and locked in an oversupplied cap-and-trade program. ProPublica's @lisalsong has the whole story here: propublica.org/article/cap-an…
10. To be fair, compromise was always going to be necessary. Thanks to an industry-funded ballot initiative (Prop 26), market-based climate policies require a 2/3 vote in California. There's no path to 2/3 in any jurisdiction that doesn't give incumbent polluters a voice.
11. And along with the cap-and-trade bill came a companion effort, AB 617, to invest in local air quality improvements. The two bills were joined together to symbolize the commitment to climate and clean air.
12. But critically, the deal on both climate and air quality depended on stable revenue. An oversupplied market would sell climate policy short, but bring in enough money to keep California's environmental programs running. For some, that was enough. A down payment, perhaps.
13. Problem is, CARB's approach to keeping industry happy was to maintain an oversupplied market to keep prices artificially low. That approach worked … until it didn't.
14. In early March, the secondary market for allowances went haywire when investors dumped their holdings and crashed the secondary market price. That's bad news for the government's quarterly allowance auctions, which raise the state's climate and clean air funds.
15. Because the quarterly auctions have a minimum price—the market's "price floor"—secondary market price crashes tend to depress demand at auctions, leading to the revenue shortfalls we saw in 2016-17 and again this week.
16. Now—in the middle of a massive budget crisis—the state's climate funds are nowhere to be seen, and long-term market prices indicate the problem could come back again in the next quarterly auction in August.
17. A lot of people want to blame this outcome on COVID—i.e., "who could have known?!?" But GHG emissions aren't falling that much. Compared to the scale of market oversupply, the likely drop in 2020 emissions is tiny. See here for The Science: ghgpolicy.org/writing/2020/5…
18. The fact is that hedge fund margin calls and macroeconomic shocks wouldn't crash a market if it were well-designed. The EU ETS and RGGI learned the hard way about the importance of designing markets to anticipate and weather unexpected storms. But they did learn.
19. So far, CARB has been unwilling to admit its mistake. What's so frustrating is that the warning signs have been out there for years. Among the first to raise the alarm were @chrisbbusch and @JustinHGillis: nytimes.com/2017/12/12/opi…
20. Academics have been writing about these risks, too—notably @BorensteinS, Jim Bushnell, Frank Wolak, and Matthew Zaragoza-Watkins: aeaweb.org/articles?id=10…
21. Mike Mastrandrea, @masoninman, and I showed the extent of excess allowance accumulation exceeded regulator's worst-case scenario in 2018 and matched projections from @chrisbbusch, the Ontario Government, and @LAO_CA: iopscience.iop.org/article/10.108…
22. We also developed an open source model that shows these conditions could cause the program to be "long" on allowances all the way through 2030—even before COVID pushed emissions lower: tandfonline.com/doi/abs/10.108…
23. Anyway, there a bunch of ways to fix the problem. We all have an interest in seeing a better program—one that's more reliable for cutting climate pollution, generating revenues for public programs, and yes, even stabilizing compliance costs for industry.
24. But that all depends on CARB and the Newsom Administration wanting to make a change. Here's hoping they will.

* fin *
25. … adding, it takes a village to cover an issue this complicated, and I forgot to mention several key voices. @jacqules wrote a great summary of the situation in the @latimes in January: latimes.com/opinion/story/…
26. Last year, @RA_Becks had a great @CalMatters story on an excellent and brave @Next10 report warning about the slack pace of climate policy progress in recent years: calmatters.org/environment/20…
27. And last but not least, @KateAronoff was on this way back in the day, writing about the actual legislative horse-trading for @inthesetimesmag: inthesetimes.com/article/20331/…
28. A lot of people dismissed @KateAronoff for political bias on that story, but for my money, it's the single best example of California climate journalism in 2017. Kate makes no secret of her political views; #climatetwitter should make no secret of her prescience, either.

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More from @dcullenward

Oct 26, 2022
Oh hey look it's another senior policymaker from the California Air Resources Board who jumped careers to work for a lobbying firm with oil industry clients.

h/t @debra_kahn in Politico. politico.com/newsletters/th…
Richard Corey was CARB's executive officer from 2013-2022. He was responsible for implementing the 2017 oil-industry-drafted cap-and-trade bill, AB 398. He's now the partner in charge of AJW's Carbon Markets practice. ajw-inc.com/carbon-markets/
During Corey's leadership oil won big on cap-and-trade, rolling back state and local regulations on the oil industry combined with a side deal to keep the state program swimming in bad offsets and surplus allowances, as @lisalsong wrote in Propublica. propublica.org/article/cap-an…
Read 9 tweets
Apr 23, 2021
Governor Newsom is generating headlines for announcing an end to oil production in California, but as far as I can tell today's news only sets up a process rather than achieves any concrete outcomes.

A thread 👇
latimes.com/california/sto…
Here's the Governor's announcement.

It specifies two concrete actions.

gov.ca.gov/2021/04/23/gov…
First, the Governor has asked the director of CalGEM, which regulates oil production and issues drilling permits, to begin a regulatory process to ban new fracking permits by 2024.
Read 21 tweets
Oct 19, 2020
1/ Book announcement!

Making Climate Policy Work
(with David G. Victor)

🇪🇺🇬🇧EU/UK release Oct 2020, 🇺🇸US Dec 2020
@politybooks, discount code VBT99 politybooks.com/bookdetail/?is…
2/ The book pulls together big ideas in a short, accessible package. David and I look at the global experience with carbon pricing — particularly carbon markets — and ask what’s gone wrong. We set out to explain why carbon pricing hasn’t been working, then offer solutions.
3/ We’re not the first to point out political problems with carbon pricing, of course. Recently @mmildenberger and @leahstokes made their case in @BostonReview, drawing on my work in California. bostonreview.net/science-nature…
Read 23 tweets
Sep 24, 2020
Thanks to @jtemple for including me in his story on the big news from Governor Newsom's new executive order, which sets a goal of 100% zero emission new car and truck sales by 2035.

I'll do a deeper dive on the legal situation below.
First thing to say is what an executive order (EO) is.

Generally, an EO can't create law. It can only direct policy outcomes that the law already allows.

EOs also set political goals around which laws more readily form. Most of California's major climate laws started as EOs.
Today's EO sets a goal of having 100% of light-duty vehicles sold in California by 2035 be zero emissions vehicles (ZEVs). That's a big deal!
Read 22 tweets
Aug 4, 2020
I have begrudgingly come around to the same view as @drvox, at least in the U.S.

My biggest surprise? The *exact same* political games that undermine public policy implementation are happening in the private sector, too.
I'm cautiously optimistic that at least some companies will set a high bar and demand better outcomes than we see in the public sector.

(Other firms are looking to greenwash instead, as are some governments that fail to follow through on bold climate announcements.)
The problem is that the constituency for quality in climate policy is weak, so both public and private leaders can satisfy public demands with hollow pledges.
Read 4 tweets
Jul 10, 2020
This is a key point.

Opt-outs looked legally unnecessary in FERC orders after the SCOTUS opinion in FERC v. EPSA, and now with today's DC Cir decision in NARUC v. FERC there's a path open for FERC to close opt-outs in future rules concerning ISO/RTO access.
For FERC rules addressing something broader than ISO/RTO market access, however, there's not a lot to point to in today's decision. I expect to see a lot of debate over the implications in the months ahead.
In plain English:

Some states block demand response (DR) and distributed energy resources (DERs) from participating in FERC's wholesale electricity markets. But today's decision suggests FERC can require open access to its wholesale markets without any state-level opt-outs.
Read 5 tweets

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