The Quebec Carbon Cap & Trade Regulation

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1 The Quebec Carbon Cap & Trade Regulation Impacts and solutions for the industy Mustapha Ouyed IETA BUSINESS CAP-AND-TRADE DIALOGUE Toronto - July 9, 2015 Some material is adapted from the Quebec government carbon market training workshop provided by ÉcoRessources inc. with the support of Golder Associés -

2 Reporting and Verification Thresholds GHG Emission Level tco 2 eq./yr GHG Reporting and Verification Threshold tco 2 eq./yr GHG Reporting Threshold Establishments A B C

3 Sectors of activity targeted by the Quebec cap-and-trade system 1. Mining, quarrying and oil and natural gas extraction 2. Electric power generation, transmission and distribution 3. Natural gas distribution (including Gas marketers or brokers) 4. Steam and airconditioning production for industrial purposes 5. Manufacturing (except activities to process waste by dismembering and related) 6. Pipeline transportation of natural gas

4 Main principals It is now on prohibited for a regulated entity to emit verified greenhouse gases (GHGs) unless it acquires necessary permits called Emissions Allowances (EUs) or greenhouse gas emission units A regulated entity has no cap on its GHG emissions as far as it acquires enough EAs to cover for 100% of its verified emissions within a defined timeframe Most large industrial emitters (total covered GHG emissions >= 25000t CO 2 e) are the first group of regulated entities starting in Most of them have access to free EAs that covers a large portion of their needs. Fuel distributors (refiners, importers, ) are held accountable for GHG emitted by non regulated fuel combustion sources of their clients starting in When those emissions are >= 25000t CO 2 e, the fuel distributor is then considered as a covered entity. Fuel distributors do not have access to free allowances

5 Mandatory Compliance At the end of a compliance period, regulated enterprises must surrender as many emission allowances as they reported and verified for that period. For a given compliance period, this enterprise must cover 100,000 tco 2 eq. Emission allowances

6 MtCO 2 eq. Millions of Emission Units Emission Units Cap and Business As Usual Emissions Mt Reduction Target: 14.7 Mt Emissions Target for Covered Emissions in 2020 : 54.7 MtCO 2 eq Industrial Electricity Production Transportation Residential, Commercial and Institutional Agriculture Waste 6

7 MtCO 2 eq. Issuance of Emission Units in the Auction Account Government Strategic Reserve Auction Account Réserve stratégique du gouvernem ent Industrial Electricity Production Transportation Residential, Commercial and Institutional Agriculture Waste

8 Compliance Options Obtaining early reduction credits Obtaining free emissions allowances v Internal reduction Purchase of emission units at the auctions Trading between emitters and participants registered to the CTSEA Purchase of offset credits Purchase of emission units from the strategic reserve

9 Early Action Reduction Credits Recognized calculation methods or according to the RMR Not a result of a reduction in production Permanent and irreversible reductions Additionnality in terms of GHG emission intensity reduction Reference period January 1, 2005 December 31, 2007 Eligibility period for early reduction credits January 1, December 31, 2011 Application deadline May 31, 2013 Calculations must be verified

10 Activities Eligible for Free Emission Allowances Activity Mining and quarrying (except oil and gas) 212 Electric power generation sold under a contract signed prior to 1 January 2008, not renewed or extended, in which the sale price is fixed for the duration of the contract, with no possibility of adjusting the price. Acquisition, for the consumption of the enterprise or for sale in Québec, of power generated in another Canadian province or territory or in a state in which the government has established a cap-and-trade system for greenhouse gas emission allowances targeting power generation, but has not signed an agreement with Quebec 6-digit NAICS* code beginning with 2211 Steam and air-conditioning supply for industrial purposes Manufacturing 31, 32 or 33

11 Calculation of Free EAUs A 20xx = I 20xx x Pr 20xx A 20xx = Total number of emission units allocated without charge for a given year I 20xx = Intensity target of emissions (to be calculated each year based on historical emissions intensities (GHG/production) of years 2007 to 2010) Pr 20xx = Total quantity of reference units produced or used during the given year

12 Free Allocation of Emission Units - Four Calculation Methods Non-Sectoral Covered in 2013 Sectoral Covered in 2013 Non-Sectoral Covered after 2013 Sectoral Covered after 2013 Sectorial : lime production; cement production; prebaked anode production and aluminum production using prebaked anode technologies

13 Three Types of Emissions 1. Fixed Process Emissions : CO 2 emissions resulting from a fixed chemical reaction process for production purposes that generates CO 2, from chemically-bonded carbon in the raw material, or from the carbon used to remove an undesirable component from the raw material where there is no substitutable raw material E.g. : Lime production; Anode consumption (aluminum production); Hydrogen production process Limestone CaCO 3 Heat CO 2 Calcination Lime CaO 100% free allowances from 2013 to 2020 based on historical emissions intensity factor and actual production of reference units

14 Three Types of Emissions 2. Combustion emissions : emissions resulting from the exothermic reaction of any fuel, except CO 2 emissions attributable to the combustion of biomass or biomass fuels E.g. : Boiler, combustion turbine; Engines, incinerator; Acid gas scrubbing equipment Fuel oil CO 2 Combustion Heat 80% to 100% free allowances in 2013 and 2014 then decreases based on historical emissions intensity factor and actual production of reference units

15 Three Types of Emissions 3. Other Emissions : emissions that do not meet the criteria for fixed process emissions or combustion emissions. E.g. : Fugitive emissions from a cooling system; Mobile equipments on site (excluding vehicles that are not directly related to the production and road vehicles within the meaning of the Highway Safety Code); Acetylene welding; Explosives; Water treatment system; 100% free allowances in 2013 and 2014 then decreases based on historical emissions intensity factor and actual production of reference units

16 GHG emissions units auction At most 4 times per year Accessible to emitters and participants Every bidder must, at least 12 days before the date of the auction, submit a financial guarantee to the Minister The emission units are auctioned in lots of 1,000 emission units of the same vintage The minimum price of the emission units is set at $10 for auctions conducted in 2012; increased annually by 5% plus inflation after 2012 Maximum units that may be purchased by the same bidder is limited to: 25% in the case of an emitter; and 4% in the case of a participant. A bidder or participant must not disclose whether or not it is taking part in an auction, or any other confidential information

17 Emission Units Auction Example Date: May 2015 Number of lots auctionned: 36 Vintage: 2015 Minimum Price : $12.44 Buyers Comments Number of Lots Wanted Price Offered by Emission Unit 9 lots 8 lots 6 lots 8 lots 9 lots 9 lots 49 lots wanted $30 $20 $35 $13 $40 $16 Awarding Order Number of Lots Awarded by Buyer

18 Emission Units Auction Example Date: May 2015 Number of lots auctionned : 36 Vintage : 2015 Minimum Price : 12,44 $ Buyers Comments Number of Lots Wanted 9 lots 8 lots 6 lots 8 lots 9 lots 9 lots 49 lots wanted Price Offered by Emission Unit $30 $20 $35 $13 $40 $16 Awarding price : $16 Awarding Order 3 rd 4 th 2 nd Number of Lots Awarded by Buyer Not awarded 1 st Last awarded 9 lots 8 lots 6 lots 0 lot 9 lots 4 lots Buyers awarded according to price offered 36 lots awarded

19 Results of Last Quebec California Auction May 28, 2015

20 Offset Credits Protocols currently adopted in Quebec: Agriculture Management of Manure Storage Waste Management: Waste disposal sites (LES) Ozone-Depleting Substances (ODS) Reduction projects in sectors covered by the CTSEA are not eligible. The total quantity of offset credits that an emitter can use to cover its emissions cannot exceed 8% of its total emissions for the compliance period. In Quebec, offset credits cannot be revoked after being issued or bought by an emitter.

21 Mutual Agreement from the Reserve Account Only for emitters: With a covered establishment in Quebec That do not hold emission units within their general account Fixed prices according to 3 categories (in 2013): Category A: $40 Category B: $45 Category C: $50 Starting 2014, price revised upward to 5% and indexed annually according to inflation.

22 Main issues still raised by Qebec industry Cost of compliance Absence of economic impact evaluation How Quebec will use the 3.3 billion$ to be collected by 2020 The impact of US&CAN $ exchange rate Risk for double counting when it comes to fuel distribution Competitiveness issue with non carbon regulated jurisdictions Are free emissions allowances subject to provincial and/or federal taxes Need for more carbon offset protocols

23 Main learnings from Quebec experience This is a complicated multidisciplinary legal new context. It needs a multidisciplinary approach and strategy The more you educate your people within the company the better you reduce the regulatory risk and increase business opportunities Good organized industry lobby is a factor for reducing regulatory risk Internal reductions is an option that needs a high attention Money collected through auctions and sale by mutual agreement mechanisms can be a good source for your projects financing, For smaller non regulated facilities, financial impact can be higher than the one for large regulated companies

24 Impacts on regulated vs non regulated emitters STEEL FACILITY A STEEL FACILITY B 80,000 t GHG combustion emissions 64,000 t free allowances 16,000 t purchased EAs EAs cost at 15$/t = $ Total production 400,000 TPY of steel Compliance cost per 0,6 $/t of steel t GHG combustion emissions 0 t free allowances t passed on EAs by distributor EAs cost at 15$/t = $ Total production 100,000 TPY of steel Compliance cost 3 $/t of steel

25 Tools to manage the regulation risks Tons of CO 2 eq Émissions prévues (t CO2e) UÉ gratuites (t CO2e) Production (t métal) Surplus / Déficit (-) t CO2e Intensité cible (t CO2 e/t) ,07 0,068 0,066 0,064 0,062 0,06 0,058 0,056 0,054 0,052 0,05 Tons of CO 2 eq. / Tons of metal produced

26 Tools to manage the regulation risks

27 Process Heat Recovery Project Cost savings: $450,000/year GHG reduction: 2,800 tco 2 e/year Capital cost: $2,000,000 Simple payback: 4.4 years Net present value: $2.9M Considering cap-and-trade: Negative abatement cost! Simple payback: 4.1 years Net present value: $3.4M

28 Fuel Switching Project Capital Cost: $2,000,000 Switching from coal/petroleum coke to biomass GHG reduction: 70,000 tco 2 e/year Considering cap-and-trade: Negative abatement cost ~ $1,000,000 in carbon savings

29 Reach Higher with Cap-and-Trade Process Heat Recovery Renewable energy O&M improvements Cap-and-trade Biomass Diesel to electric Right-size equipment Turn off equipment when not in use Ventilation on demand July 10,

30 THANK YOU If you have any questions please contact us: Montreal Mustapha Ouyed +1 (514) Mississauga/Toronto Sean Capstick +1 (905) X1145 Ottawa/Kingston Camille Taylor +1 (613) ext. 4236

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