Financial Reporting for Cap-and-Trade Emissions Reduction Programs

Financial Reporting for Cap-and-Trade Emissions Reduction Programs Yonca Ertimur, Jennifer Francis, Amanda Gonzales and Katherine Schipper Duke University Based on the FASB s Conceptual Framework, we propose an accounting treatment for cap-and-trade emissions reduction programs, and compare it with current practice and alternative treatments being considered. Our proposal has the following elements: (i) At inception, firms recognize emission allowances received or purchased as an intangible, non-amortizable asset, measured at fair value. The offsetting credit for purchased allowances would be to cash or other assets; for allocated allowances, the offsetting credit would be to a current period gain. (ii) Firms accrue liabilities, at fair value, as they emit, with the offsetting debit to current period expense. (iii) After inception, both the asset and the liability are measured at fair value, with changes in fair value included in income. We then use transaction-level data from the U.S. SO 2 program for 1993-2009 to empirically calibrate the effect that our proposed accounting treatment and alternative treatments would have had on 56 public U.S. companies quarterly financial statements. We find that the differences in the accounting treatments generate significant differences in key financial indicators for firms, including the debt-equity ratio, return on assets, and volatility in net income. Finally, we examine the market s perception of the assets and liabilities generated under the SO 2 program. We find that the market positively values the emission allowances carrying values recognized under the proposed and alternative treatments. In addition, we find that the market positively values the government grant recognized under one model in which the offsetting credit for allocated allowances is a government grant liability, rather than a current period gain. Preliminary and incomplete November 2010 Corresponding author: amanda.gonzales@duke.edu, Fuqua School of Business, Duke University, Durham, NC 27708. This research was partially supported by a grant from the Doris Duke Charitable Foundation. The price data for SO 2 emission allowances used in this paper were obtained from Cantor Fitzgerald; we are responsible for all of the analyses of the data.

Financial Reporting for Cap-and-Trade Emissions Reduction Programs 1. Introduction This paper describes the financial reporting issues associated with cap-and-trade emissions reduction programs and proposes an accounting treatment that is based on the precepts of the Conceptual Framework of the U.S. Financial Accounting Standards Board (FASB). 1 The paper then examines the financial reporting effects and capital market perceptions of our proposed treatment, as well as several alternative accounting treatments, using empirical-archival data from the U.S. Acid Rain Program. Cap-and-trade programs are one of several mechanisms that might be used to reduce certain emissions designated by policy-makers. In a cap-and-trade program, there is an overall limit (a cap ) on the amount of emissions of a specified type that are permitted during a compliance period. The government sets the cap to achieve emissions reduction goals and enforces it by requiring entities in the program to surrender emission allowances to cover their emissions during the compliance period. The trade aspect of a cap-and-trade program arises because the allowances are exchangeable. The resulting market for allowances creates a price for emissions (for example, CO 2 ) that serves as a signal for emitters to make emissions-reducing expenditures. An emitter will purchase allowances (real options that allow the emitter to defer emissions-reducing expenditures) until the price of allowances reaches the point where those expenditures become cost-effective. [U.S. EPA, Cap and Trade: Essentials] Cap-and-trade programs currently in existence include the U.S. Acid Rain Program (the SO 2 program), which began in 1993, and the European Union s Emission Trading System (E.U. ETS), which began with a practice round in 2005. [U.S. EPA, Cap and Trade: Acid Rain Program Basics; EC, Emission Trading System (E.U. ETS)] The American Clean Energy and Security Act of 2009 (H.R. 2454) was passed by the U.S. House of Representatives on June 26, 2009. The bill proposes to introduce a broad cap-and-trade system, the Global Warming Pollution Reduction Program ( the proposed U.S. program ). The goal of the 1 While our analysis is based on the FASB s Conceptual Framework, we believe that an application of the precepts in the IASB s Framework for the Preparation and Presentation of Financial Statements would lead to the same conclusions. 1

proposed U.S. program is the reduction of U.S. greenhouse gas (GHG) emissions to 17% of their 2005 level by 2050. As of November 2010, the passage of climate change legislation in the U.S. Senate and the contents of any such legislation are uncertain. Therefore, this paper focuses on the provisions of H.R. 2454. The key components of the proposed U.S. program also apply to the U.S. SO 2 program and the E.U. ETS. There is no authoritative guidance in either U.S. generally accepted accounting principles (U.S. GAAP) or International Financial Reporting Standards (IFRS) on the accounting for cap-and-trade arrangements. The implementation body of the International Accounting Standards Board (IASB), the IFRIC, issued guidance in 2004. The IASB withdrew that guidance in 2005. Both the IASB and the FASB have added projects to their agendas to provide authoritative guidance for emissions programs. In this paper, we apply the ideas of the FASB s Conceptual Framework to the rights and obligations created in a cap-and-trade program and propose an accounting treatment that we believe is consistent with the Conceptual Framework. We also discuss current accounting practice and some of the ideas currently under consideration by the IASB and FASB. We then investigate how the proposed and alternative accounting treatments would affect financial reports by using transaction-level data from the U.S. SO 2 program to simulate the effects of each treatment on the quarterly financial statements of 56 public U.S. companies covered by the program. Using these data, we create as-if balance sheets and income statements for each firm for each quarter during 1993-2009, under each accounting treatment. Because we are using transaction-level data, we can precisely calculate the income statement effects of both selling emission allowances to third parties and remeasuring emission allowances and emission obligations to fair value at each reporting date. This allows us to probe the consequences of each treatment on measures of financial performance, leverage and volatility. We find that differences in the accounting treatments generate significant differences in key financial indicators for firms, including the debt-equity ratio, return on assets, and volatility in net income. Finally, we examine the market s perception of the assets and liabilities generated under the U.S. SO 2 program. This is in a similar spirit as previous research on the value-relevance of various pieces of 2

accounting information. However, in contrast to many other studies, in our setting the market price of allowances is readily available, so the reliability of the measurement of emission allowances and emission obligations is not an issue. Instead, we can focus on investors perceptions of whether the rights and obligations generated in a cap-and-trade program create assets and liabilities that are reflected in equity prices. We find that the market positively values the emission allowances carrying values recognized under the proposed and alternative treatments. In addition, we find that the market positively values the government grant recognized under one model in which the offsetting credit for allocated allowances is a government grant liability, rather than a current period gain. This paper proceeds as follows. Section 2 describes the key elements of the proposed U.S. capand-trade program. Understanding these elements is important for applying accounting guidance to the rights and obligations created by such a program. 2 Section 3 analyzes the compliance obligations and compliance instruments (emission allowances) in the context of the FASB s Conceptual Framework, describes our proposed accounting treatment, and compares it to current practice, including alternatives being considered by the FASB and IASB. Section 4 describes our empirically-calibrated simulation, including the financial reporting effects and capital market perceptions of the differences in the alternative accounting treatments for cap-and-trade emissions reduction programs. Section 5 summarizes and concludes. 2. Components of a Cap-and-Trade Program There are four key elements of a cap-and-trade program: (1) A government determined cap establishing a mandatory limit on the amount of permitted emissions. (2) A fixed, government determined number of allowances, distributed in various ways, including allocation and auction. (3) A requirement 2 We do not address the accounting for derivative instruments whose underlying is emission allowances that might be developed in response to the implementation of an emissions reduction program. The accounting for such derivatives is not part of the IASB and FASB projects on emissions reduction programs. It is expected that existing guidance on the accounting for derivative instruments (FASB ASC Topic 815, formerly Statement No. 133, Accounting for Derivative Instruments and Hedging Activities, and IAS 39 Financial Instruments: Recognition and Measurement) will apply. 3

that each covered entity deliver a number of allowances to the government equal to the amount of emissions by that entity. (4) The ability to exchange allowances both with other entities and over time. The remainder of this section discusses these components in the context of the proposed U.S. program, as detailed in H.R. 2454. The emission allowance is the main instrument through which entities demonstrate compliance with a cap-and-trade program. Entities must hold one emission allowance for each ton of CO 2 equivalent emitted in the previous calendar year. To achieve specified emission reduction goals, the program establishes a limited, decreasing quantity of emission allowances available in each calendar year, starting with 4,627 million allowances in 2012 and decreasing to 1,035 million allowances in 2050 and each year thereafter. Each emission allowance has a unique identification number that includes its vintage year, defined as its first year of use for compliance. An entity may use an emission allowance for compliance purposes in the vintage year for that allowance or in any subsequent year. 3 In addition to compliance, an entity that holds an emission allowance may sell, exchange, transfer, or retire that allowance without restriction. Entities covered by the program must hold enough emission allowances as of April 1 st of each calendar year to cover their previous year s GHG emissions. As soon as is practicable after that date, the government retires those emission allowances. An entity that does not hold sufficient emission allowances to cover their previous year s emissions is assessed a penalty of twice the auction clearing price (for the earliest vintage year emission allowances in the last government auction before the compliance deadline) multiplied by its excess emissions (actual emissions less allowances held). Further, the penalized entity s obligation to surrender emission allowances is not extinguished: it must submit 3 However, an entity may also borrow from future vintage year allowances to satisfy its current compliance obligation. Specifically, an emission allowance may be used for compliance in the year immediately preceding its vintage year with no interest payment. An entity may satisfy up to 15% of its compliance obligation using emission allowances with vintage years up to five years in the future, but it must make an up-front interest payment to the government of.08 multiplied by the number of years between the vintage year and the calendar year in which the allowance is being used. 4

emission allowances in the following year to offset those excess emissions. We view this program as providing economic compulsion for covered entities to acquire emission allowances. Entities may acquire emission allowances from government allocation without payment and/or from government auction. During the initial years of the program, most emission allowances will be allocated to entities free of charge. Some of those allowances must be used for specified purposes (e.g., local electric and natural gas distribution companies will receive allowances that must be used to benefit their consumers) while other allowances will be allocated with no restrictions. Entities with compliance obligations and entities without compliance obligations will receive allowances; the latter includes, for example, state and federal agencies that will receive allowances for public purposes, such as building energy efficiency programs. The government also plans to auction a percentage of emission allowances each year and use the proceeds for a variety of purposes, e.g., 15% of auction proceeds will fund an energy refund program to benefit low income consumers. Government auctions will occur four times per year and are open to entities with and without compliance obligations. An entity may also obtain emission allowances from other sources. First, it may purchase them from a third party. Second, it may obtain compensatory allowances (which can be used in lieu of emission allowances) in return for the destruction or conversion of certain GHG. 4 Third, it may exchange an emission allowance issued previously by a qualifying domestic or international program. To qualify, the international program must be at least as stringent as the proposed U.S. program and must impose absolute tonnage limits on GHG emissions. Finally, an entity may earn offset credits (which can be used in lieu of emission allowances) by completing qualifying projects that result in reductions, avoidance or sequestration of GHG either domestically or in developing countries. 5 4 Compensatory allowances are also available for the non-emissive use of certain products if allowances were already retired for the production or emission of the related GHG. 5 An entity may satisfy its compliance obligation by holding one domestic or international offset credit in lieu of an emission allowance. Beginning in 2018, an entity must hold 1.25 international offset credits to substitute for one emission allowance. A collective cap of 2 billion tons of GHG emissions annually that can be covered with offset credits is split equally between domestic and international offset credits and is divided pro rata among covered entities. The proposed U.S. program requires the EPA to establish a mechanism to ensure that the sequestration of 5

3. Accounting for Rights and Obligations of Emissions Reduction Programs We apply the guidance provided by the FASB s Conceptual Framework to the components of cap-and-trade programs (section 3.1) and use this analysis to structure our proposed accounting treatment (section 3.2). We then describe current practice, including certain alternatives considered by the FASB and IASB (section 3.3), and compare our proposal with these other treatments (section 3.4). 3.1 Applying the Conceptual Framework to emissions reduction programs Standard setter decisions about the development of U.S. accounting standards are supposed to be guided by the FASB s Conceptual Framework. The objective of financial reporting is to provide financial information about the reporting entity that is useful to existing and potential investors, lenders, and other creditors in making decisions about providing resources to the entity [FASB, SFAC 8, para. OB2]. To achieve that objective, financial reporting should provide information to help investors, lenders, and other creditors assess the amount, timing, and uncertainty of (the prospects for) future net cash inflows to the entity [FASB, SFAC 8, para. OB3]. It should also provide information about the financial position of a reporting entity, which is information about the entity s economic resources and the claims against the reporting entity and information about the effects of transactions and other events that change a reporting entity s economic resources and claims [FASB, SFAC 8, para. OB12]. In the FASB s Conceptual Framework, Chapter 3 of Concepts Statement No. 8, Qualitative Characteristics of Useful Financial Information, describes the qualitative characteristics that make financial reporting information useful for making investment, credit and similar decisions including relevance, faithful representation and comparability. Relevant information is capable of affecting a resource allocation decision; information should also be counted on to represent faithfully what it purports to represent; comparable information means that similar items are accounted for the same way, and different items are accounted for differently. We apply these qualitative characteristics and the definitions GHG achieved through offset projects is permanent, for example, by imposing an offset reserve in which a portion of the offset credits that an entity earns is set aside based on the risk of reversal. 6

of financial statement elements, described next, to reach conclusions about the accounting for cap-andtrade programs. FASB Concepts Statement No. 6, Elements of Financial Statements, defines financial statement elements as the broad classes of items that financial statements comprise: assets, liabilities, revenues and expenses. A standard setter analyzes commercial arrangements such as cap-and-trade programs in terms of their rights and obligations. Rights that qualify as assets are recognized as such (subject to recognition criteria) and obligations that qualify as liabilities are recognized as such (subject to recognition criteria). FASB Concepts Statement No. 5, Recognition and Measurement in Financial Statements of Business Enterprises, specifies the following criteria for the recognition of items in an entity s financial statements (para. 63): meets the definition of an element of financial statements; has a relevant attribute measurable with sufficient reliability; is capable of making a difference in user decisions; and is representationally faithful, verifiable, and neutral. We apply these recognition criteria to cap-and-trade programs by analyzing the rights and obligations that arise as a result of the program. Analysis of rights. The implementation of a cap-and-trade program regulates access to a resource that previously was not restricted, thus creating rights to use that resource, similar to fishing rights and import quotas. Emission allowances and credits satisfy the definition of an asset in Concepts Statement No. 6 that is, they are probable future economic benefits obtained or controlled by a particular entity as a result of past transactions or events (para. 25). A participant in a cap-and-trade program can sell the allowance or use the allowance to settle its obligation to deliver allowances to the government for its emissions. To be recognized in the balance sheet, an asset must also have a relevant attribute that can be measured with sufficient reliability. Both acquisition cost and fair value are candidate measurement attributes for emission allowances. The acquisition cost measurement attribute recognizes (measures) the allowance at the amount the entity paid to acquire it. This attribute can be simple to implement costs are 7

typically obtainable, and verifiable, from invoices. 6 After initial measurement, acquisition cost does not capture economic conditions at the balance sheet date, including changes in economic conditions while allowances are held. The fair value measurement attribute recognizes (measures) the allowance at its exit value, the price at which it could be sold in an orderly transaction with a market participant at the measurement date. [FASB ASC paragraph 820-10-35-2, formerly, SFAS 157, para. 5] The fair value measurement attribute could be applied only at the initial acquisition of the allowance or it could be applied both at the initial acquisition of the allowance and in subsequent reporting periods (that is, the allowance would be remeasured to fair value at each reporting date). Because the allowances in a cap-and-trade program are freely exchangeable, the measurement of fair value can be done by reference to transaction prices. In addition, when applied in subsequent reporting periods, this attribute captures economic conditions at the balance sheet date, including changes in those conditions while allowances are held. One way to approach the determination of the most decision-useful measurement attribute for emission allowances is to apply the qualitative characteristic comparability, which prescribes similar accounting treatment for similar items. Entities may acquire fungible, exchangeable and otherwise indistinguishable emission allowances (or substitutable instruments) in a variety of ways through government allocation, through government auction, through purchase from a third party, through generating offset credits. Because of the various mechanisms for acquiring emission allowances, otherwise indistinguishable allowances will have different acquisition costs. Therefore, if the allowances are recognized at cost, they will have different balance sheet measurements, ranging from zero (if the allowances are allocated) to arms-length transaction prices (if the allowances are acquired in market transactions). In addition, allowances may be held by covered entities (that is, those with obligations under the program) or by non-covered entities; the former could use, sell, or save allowances while the latter could sell or save their allowances. However, at every balance sheet date the fair value of an 6 Complications will likely develop if the allowance arises from an offset credit that is the result of a substantial and complex capital expenditure program; however, those complications are not substantively different from the allocation and measurement issues involved in calculating the acquisition cost of a self-constructed long-lived asset. 8

emission allowance captures the opportunity cost to the entity of continuing to hold an emission allowance, so it provides a comparable measure for allowances regardless of how and when the entity acquired that allowance or how it expected to use or dispose of that allowance. Comparability, therefore, would specify fair value as the measurement attribute as long as any one emission allowance is economically similar to any other one. The question thus arises whether the economic characteristics of an emission allowance change based on how the allowance was acquired, the characteristics of the entity holding the allowance, or the entity s intended use of the allowance. Based on the discussion in section 2, we conclude that emission allowances are indistinguishable from one another regardless of how they were acquired, who holds them, and how the entity intends to use them. We therefore conclude that measurement at fair value best meets the decision usefulness criterion. Analysis of obligations. A cap-and-trade program creates an obligation for a covered entity because the covered entity must deliver emission allowances to cover its emissions when previously it could emit an unlimited amount. Once emissions occur, a covered entity has an obligation that satisfies the definition of a liability in Concepts Statement No. 6, probable future sacrifices of economic benefits arising from present obligations of a particular entity to transfer assets or provide services to other entities in the future as a result of past transactions or events (para. 35). Specifically, a liability has three essential characteristics (para. 36): a present (as opposed to a future) duty that entails settlement by probable future transfer of assets; little or no discretion to avoid the future sacrifice; the obligating event has already occurred. The timing of liability recognition is thus determined by the occurrence of the obligating event; an entity recognizes a liability when the entity has a present obligation that it cannot reasonably avoid. An entity that emits gases covered by a cap-and-trade program can expect to have an obligation to surrender allowances or pay the requisite penalty, based on the amount of emissions. The obligating event is thus the act of emitting. Merely holding an emission allowance does not obligate an entity to transfer assets or provide services; in particular, it does not create an obligation to emit GHG or to surrender the allowance. Rather, the obligation arises if and when the entity emits a substance that is covered by the program an entity 9

that does not emit has no present obligation with regard to future emissions or existing emission allowances. Plans, intentions or commercial necessity to emit do not create an obligation; only the act of emitting does. This reasoning has a long tradition in accounting and supports the recognition of items such as employee compensation as expenses if and when the employee provides services, regardless of the employer s intention, plan or perceived commercial necessity to have employees and pay them. Application of the liabilities definition, therefore, results in the entity recognizing (accruing) the obligation as it emits. Application of the qualitative characteristics and the recognition criteria would recognize (measure) the liability at the amount that would be required to settle the obligation generally, this would be the fair value of the required allowances. The obligation is accrued over a compliance period and settled at the date specified in the cap-and-trade program by transferring emission allowances to the government. 3.2 Our proposed accounting treatment for emissions reduction programs Based on the reasoning in section 3.1, our proposed accounting treatment for emissions reduction programs would recognize and measure assets and liabilities, and related expenses and income, as follows. When an entity acquires an emission allowance, it will recognize an asset at its fair value. If the exchange is for cash or other assets, the offsetting credit is to cash or other assets. If the exchange is nonreciprocal (i.e., the entity receives the allowance as a government allocation), the offsetting credit could be to income or to deferred income (to be later amortized into income). Recognition of deferred income (a liability) is appropriate if the receiving entity has not completed all of its obligations in order to be entitled to the benefits of holding the allowances. In this case, the entity recognizes income as it satisfies the remaining obligations. As discussed in section 3.1, merely holding an emission allowance does not obligate an entity to transfer assets or provide services. Entities can immediately access the benefits of emission allowances allocated to them free of charge by the government they can sell them or use them to settle their obligations to surrender allowances to the government for emissions. The receipt of an allowance does not create an obligation to emit GHG or to surrender the allowance. 10

Therefore, our proposed treatment recognizes an offsetting credit to income when an entity receives allowances as a government allocation. Continued fair value measurement of emission allowances after inception implies that the balance sheet value would change to reflect changes in economic conditions, with those changes included in income. This is consistent with the decision to also reflect the effects of changes in economic conditions on the emission obligation in income. In terms of classification, emission allowances satisfy the definition of an intangible asset assets (not including financial assets) that lack physical substance [FASB ASC Section 350-30-20, formerly Appendix F, Glossary to SFAS 142, Goodwill and Other Intangible Assets]. Although they have some similarities to financial assets, they do not satisfy the definition of a financial asset. 7 Although they are potentially used in an entity s operations, they are not inventory. 8 An emission allowance has a service life (determined by the policies of the cap-and-trade program) but its service potential does not diminish over time. Therefore, an emission allowance would not be amortized. 9 Emission allowances would be further classified as current intangible assets if expected to be consumed or sold within the current operating cycle, and as non-current intangible assets if expected to be consumed or sold further in the future. As an entity emits gases that are covered by the cap-and-trade program, it accrues a liability, the obligation to surrender allowances. The offsetting debit is to expense, a reduction of current period income. The initial recognition of the liability would be at the amount that would be required to settle the obligation, equal to the fair value of the emission allowances needed to settle the obligation accrued this period. After initial recognition, subsequent fair value measurement implies that the balance sheet value 7 Financial instrument is defined in FASB ASC Section 825-10-20, formerly Appendix F, Glossary of SFAS 133, Accounting for Derivative Instruments and Hedging Activities, to include cash, ownership interests, and contracts that require delivery or receipt of cash or other financial instruments on terms that are potentially differentially favorable to one of the exchanging parties. 8 Inventory is described in FASB ASC Section 330-10-20, formerly chapter 4, paragraph 2 of ARB 43, Restatement and Revision of Accounting Research Bulletins, as items of tangible personal property that are held for sale in the ordinary course of business or are in the process of being produced for sale (that is, work in process) or are to be currently consumed in producing goods and services to be available for sale. 9 If the emission allowance was measured at cost subsequent to inception (rather than fair value, as we propose), it would be subject to impairment testing. 11

of the liability would change to reflect changes in economic conditions, with those changes included in income. Note that because the proposed U.S. program requires covered entities to surrender allowances to the government by April 1 st of the year following the emitting calendar year, the liability would be classified as a current liability for much, if not all, of a firm s fiscal year. While our proposed accounting treatment is consistent with the guidance provided by the Conceptual Framework, it is not consistent with authoritative pronouncements in two respects. First, we recommend that emission allowances be classified as intangible assets and measured at fair value both at and subsequent to inception. Our proposed treatment would, therefore, allow for both upward and downward revaluations of an intangible asset. While IFRS permits this treatment for intangible assets where ready markets exist (IAS 38, Intangible Assets) with revaluations recognized in other comprehensive income rather than in net income, U.S. GAAP does not (FASB ASC Topic 350, formerly SFAS 142, Goodwill and Other Intangible Assets). Second, we recommend that the emitting obligation be recognized at fair value both at and subsequent to inception. With few exceptions (for example, certain derivatives and certain financial liabilities under the fair value option), U.S. GAAP does not measure liabilities at fair value subsequent to inception. 3.3 Other possible accounting treatments for emission allowances Current accounting practice. U.S. GAAP does not provide authoritative guidance for accounting for emission trading arrangements such as cap-and-trade programs. It appears that some U.S. SEC registrants are applying guidance found in the Uniform System of Accounts published by the Federal Energy Regulatory Commission (FERC) in their financial reports. That guidance, which takes the form of regulations, not financial reporting standards, was developed for the SO 2 program in the early 1990s. The lack of guidance on this topic is not limited to the U.S. When the E.U. was implementing the first phase of its emission trading system, the IASB attempted to provide guidance to prevent diversity in practice from developing. The IASB s International Financial Reporting Interpretations Committee (IFRIC) issued IFRIC 3 Emission Rights in December 2004; the IASB withdrew IFRIC 3 in June 2005 amidst controversy, mainly about volatility in income due to mismatches in the recognition of changes in the 12

value of emission allowances and an entity s emission liability. Not surprisingly, given the lack of authoritative financial reporting guidance, there is diversity in practice in the accounting for emissions reduction programs. A survey of 26 companies by PricewaterhouseCoopers (PwC) and the International Emissions Trading Association identified as many as 15 variations of accounting among entities covered by the E.U. ETS. [PwC, 2007] We describe four: the net approach, the IFRIC 3 cost approach, the IFRIC 3 revaluation approach, and the hybrid IFRIC 3 cost-net approach. Appendix A summarizes the resulting financial statement effects of each approach, as well as our proposed treatment. Appendix B provides detailed journal entries for the recording of transactions under the approaches. The available evidence suggests that the predominant method of accounting is the net approach. Under this approach, the entity recognizes allowances as an intangible asset, measured at cost. Allowances allocated to an entity in a nonreciprocal arrangement will not appear in the balance sheet because they have zero cost, while allowances that an entity purchases through a government auction or from a third party will be recognized at the cost of the purchase transaction. Entities subsequently account for emission allowances at cost, less impairment losses. Entities recognize a liability for their obligations to deliver allowances to the government as emissions are produced, measured as the carrying value of the allowances on hand at the reporting date (up to the level of allowances that the entity is required to surrender) plus the market value of allowances for emissions, if any, in excess of the allowances on hand. In practice, application of the net approach means that a liability will be reflected on the balance sheet (and an expense recognized in the income statement) only if actual emissions exceed the number of allowances allocated to an entity free of charge by the government. 10 10 The FERC approach would result in financial statements that resemble those produced under the net approach for an entity that holds and uses allowances for compliance purposes (as opposed to speculative purposes). We, therefore, do not separately consider the FERC approach in our analysis. Under the FERC approach, allowances are classified as inventory and accounted for at cost, unless they are acquired for speculative purposes, in which case they are accounted for as other investments. Allowances owned by an entity, but withheld by the Environmental Protection Agency, are separately identified. On a monthly basis, an entity recognizes an expense for that month s emissions on the basis of the cost of the allowances to be remitted for the emissions. That cost is calculated based on the weighted average of the cost of the allowances held with a particular vintage year. If an entity determines that its actual emissions exceed the allowances it owns, it estimates the cost to acquire the additional allowances needed and charges that amount to expense, while crediting its inventory of allowances. In practice, the FERC approach specifies different accounting treatments depending on management intent with regard to emission allowances 13

An entity applying the IFRIC 3 approach recognizes emission allowances as intangible assets accounted for in accordance with IAS 38 Intangible Assets. 11 At inception, measurement is at fair value. If an entity receives emission allowances for less than fair value, the difference between the amount paid and fair value is recognized as a government grant that is classified as deferred income and amortized into income on a systematic basis over the compliance period for which the allowances were issued. After inception, an entity may choose to apply the cost model (measure allowances at cost less impairment losses) or the revaluation model (measure at fair value). The choice of subsequent measurement gives rise to two variations of the IFRIC 3 approach, which we label IFRIC 3 cost and IFRIC 3 revaluation. The entity recognizes a liability for the obligation to deliver allowances to the government as the entity produces emissions. The liability is accounted for in accordance with IAS 37 Provisions, Contingent Liabilities and Contingent Assets, and is measured at the best estimate of the expenditure required to settle the present obligation at the end of the reporting period [para. 36]. That is, the liability is measured at the fair value of the emission allowances required to offset the entity s accrued liability at the reporting date. The fourth approach is a variation of the net approach and IFRIC 3 approach which we term the hybrid IFRIC 3-net approach. Under this variation, the emission allowance asset is accounted for using the IFRIC 3 approach (cost or revaluation), and the emitting obligation is accounted for using the net approach. The empirical analysis in this paper is based on the cost approach in IFRIC 3 and thus is labeled the hybrid IFRIC 3 cost-net approach. Application of these approaches leads to different financial statement outcomes. In the balance sheet, the net approach reflects only the cost of purchased allowances, whereas under the IFRIC 3 approach the balance sheet reflects the fair values of both allocated and purchased allowances (at initial (trading/speculation versus surrender to the government). In addition, the FERC approach has balance sheet effects that are similar to the effects of the net approach, in that an entity would not recognize a liability unless its emissions exceed allowances it holds. 11 IFRIC 3, which underlies the IFRIC 3 approach, has been withdrawn (so it is not authoritative guidance). However, several IASB members noted at that time that its guidance is an appropriate interpretation of existing standards. Therefore, some entities continue to use the IFRIC 3 approach to account for emissions reduction programs. 14

recognition for entities using the cost model and also in subsequent reporting periods for entities using the revaluation model). There are two types of income statement effects. The first arises from the use of different measurement attributes for the right (the asset) and the obligation (the liability) under the IFRIC 3 model. Using the cost model of IAS 38 to account for the allowance asset results in a mismatch between the measurement of the liability (remeasured to market value with changes in net income) and the measurement of the asset (cost). Alternatively, an entity that applies the revaluation method of IAS 38 would display changes in the fair value of the allowance asset in other comprehensive income and the change in the fair value of the liability in net income. The second income statement effect arises from patterns of expense recognition and income recognition. In particular, the IFRIC 3 approach recognizes a current period expense equal to the fair value of the emissions produced during the period and recognizes income equal to the amortization of the government grant associated with allocated allowances. In contrast, the net approach results in the recognition of expense only when emissions exceed the allowances received free of charge from the government. Current IASB and FASB proposals. Both the IASB and FASB have added projects to their agendas to provide authoritative guidance for emissions programs. Neither has issued a due process document for public comment. The scopes of the FASB s project and the IASB s project are similar. They encompass asset and liability recognition and measurement (including asset impairment); timing of profit/loss recognition, accounting for vintage year swaps, presentation and disclosure. The intent is to provide guidance for all emissions reduction programs and related tradable rights, to be applicable to entities covered by the program and to non-covered entities that acquire rights. In September and October 2010, the FASB and IASB reached tentative decisions on the accounting for emission allowances and liabilities in a cap-and-trade program. The Boards tentatively decided that both purchased and allocated emission allowances meet the definition of an asset and should be recognized in the balance sheet at fair value both initially and in subsequent reporting periods. In addition, the Boards tentatively decided that the allocation of allowances creates an obligating event that meets the definition of a liability (even before the entity has emitted any greenhouse gases) and should be 15

recognized as such in the balance sheet. The liability for the allocation should reflect the quantity of allowances to be returned to the government based upon an entity s expectations of emissions or emissions reductions. In addition, the Boards tentatively decided that an additional liability should be recognized for emissions that exceed the allocated amount of allowances, but did not agree on the timing of the recognition of such a liability. [IASB Update, September and October 2010] At this time, it is unclear what the full accounting model for cap-and-trade programs being developed by the FASB and IASB will entail. Therefore we do not analyze this model further in the remainder of the paper. 3.4. Comparing our proposed treatment to alternative treatments Our proposed accounting treatment has two features that distinguish it from current practice and from some of the proposals discussed by the IASB and FASB. First, our proposed treatment does not match the income statement effects of asset recognition and liability recognition, implying that there is income volatility that could be avoided. More precisely, our proposal results in the recognition of income upon receipt of an allocated allowance. 12 To avoid this volatility, some observers recommend that purchased allowances be measured at fair value while allocated allowances be measured at cost (which would be zero). We disagree with this treatment because it results in non-comparable accounting. An alternative view is to recognize both a liability and an asset, at the same amount, when an entity receives allocated allowances. The argument here is based on the idea that the purpose (that is, the government intent) of an emission trading program is to impose obligations (costs) on emitters; this argument links the accounting for the asset with the accounting for the obligation. Recognizing both an asset and a liability at the time an entity receives an allocated allowance implies that the entity has incurred an obligation because of government intent with regard to the emissions trading program. We disagree with this view because there is no necessary connection between a governmental decision to impose a cost on certain emitters and a governmental decision to provide subsidies (allocated allowances) 12 Although the recognition of income upon receiving allocated allowances in a nonreciprocal transaction is troublesome for some, existing accounting guidance (for example, FASB ASC paragraph 845-10-30-1, formerly APB Opinion No. 29, Accounting for Nonmonetary Transactions, para.6) specifies fair value measurement for an asset received in a nonreciprocal transaction. The gain from such a transaction arises from the receipt of the assets, and not from the passage of time or from emitting or not emitting. 16

to offset some or all of these costs. That is, a government could instead require that a covered entity make a cash payment at the end of every year based on the amount of the entity s emissions. A noncontroversial accounting treatment for such a payment would require the entity to accrue the cost over the year as emissions occurred (that is debit expense and credit obligation); the obligation would be settled by paying cash. If, instead, the government allocates allowances that can be used to settle the obligations that arise as emissions occur, an entity that receives an allocation can hold them to settle the obligation or sell them, with the understanding that if it sells them it must meet its obligation in another way. 13 Matching measurement bases for assets and liabilities is viewed as the solution to artificial income volatility (that is, income volatility induced by accounting measurement and not by changes in economic conditions) for entities holding allowances for compliance purposes. 14 The net approach described earlier matches the measurement bases for assets and liabilities (using cost incurred in excess of allocated allowances), and therefore, provides for relatively low income volatility. However, this approach is not consistent with IAS 37 which requires the liability to be measured at its settlement amount (i.e., the fair value of the required allowances). Matching in this case would imply measuring the allowance assets at fair value, as well. The second feature of our proposed treatment is its invariance with regard to both the government s intent in creating a cap-and-trade program and the entity s intent with regard to emission allowances it holds (for example, selling allowances versus using them to satisfy its emission obligations). As noted above, accounting based on government intent could be used to support recognizing an obligation when an entity receives allocated emission allowances. Accounting based on management intent raises questions about whether entities should apply different accounting to 13 For example, power firms might sell forward power contracts during the first half of a year and buy allowances to cover the projected emissions. The sellers in the first half of the year include industrial emitters such as steel and cement firms who buy allowances in the second half of the year based on more information about their annual emissions. These buy-and-sell patterns are affected by economic conditions which affect the output (and therefore the emissions) of industrial emitters. For a discussion, see No run-up in EUA prices this year Nomura, Carbon Finance Online, http://www.carbon-financeonline.com/index.cfm?section=lead&action=view&id=12200. 14 During the development and subsequent withdrawal of IFRIC 3, constituents requested that entities be permitted to remeasure emission allowances at fair value with changes reflected in profit or loss, to match the measurement of the entity s liability for emissions that would be measured at current value. Our proposed treatment reflects this accounting. 17

allowances held for compliance and allowances held for trading. That is, should the accounting for emission allowances be based on management s intended use of those allowances, which in turn derives from the entity s business model? 15 We disagree with the notion that intentions of governments or managements should factor into decisions concerning the appropriate accounting treatment for emissions programs. Our concern is that intent-based accounting introduces avoidable non-comparability because economically similar emission allowances receive different accounting treatments. 4. Empirical Evidence on the Financial Reporting and Capital Market Effects of Alternative Accounting Treatments for Cap-and-Trade Programs In this section, we investigate two questions arising from the analysis of alternative accounting treatments in this paper. First, do the differences identified in the alternative accounting treatments have statistically and economically significant effects on firms financial reports? Second, how does the capital market perceive the assets and liabilities arising under a cap-and-trade program? We explore these questions by simulating the effects of the alternative accounting treatments on the quarterly financial statements of 56 U.S. public companies. Our simulation uses transaction-level data from the U.S. SO 2 program that results in as-if balance sheets and income statements for each company for each quarter during 1993-2009, under each alternative accounting treatment. The combination of transaction-level data and market prices allows us to calculate measures of the carrying values of emission allowances and emission obligations and the related effects on government grants, net income, and comprehensive income. We can also incorporate the effects of firms trading activities (i.e., buying and selling of allowances with third parties). 16 As a result, we can precisely examine the actual financial 15 A recent example of intent-based accounting is IFRS 9, Financial Instruments, issued by the IASB in November 2009. That guidance applies an intent-based test as one factor to distinguish financial assets that are permitted to be measured at amortized cost subject to impairment. Specifically, the test is whether the objective of holding the asset is to collect the contractual cash flows, as opposed to selling it before maturity to realize the change in fair value. 16 In ongoing work, we plan to use this transaction-level data to explore the trading behavior of firms with respect to the emission allowances that they have on hand. For example, do firms mainly trade allowances for compliance purposes (i.e, to cover their emission obligations) or do firms also trade allowances to make profits? Is there a pattern in the timing of trading and in the vintage years of the allowances traded? 18

reporting differences that would have arisen by using alternative accounting treatments for the U.S. SO 2 program. In contrast, previous research has often used non-financial measures to examine the capital market effects of emissions-related items. For example, Hughes (2000) uses firms annual percentage of SO 2 emitted relative to total airborne emissions (SO 2 + NO x + CO 2 ) as a measure of environmental exposure and finds that, on average, high-polluting utilities' exposure to SO 2 emissions decreased their mean 1990 share price by 16 percent for a sample of electric utilities covered by Phase One of the U.S. SO 2 program. Johnston et al. (2008) find that the capital market assigns a positive price to a firm s bank of SO 2 emission allowances for a sample of firms similar to ours. The authors use data available from the EPA on the number of allowances that firms have banked for future use. This number of allowances is available on an annual basis and does not reflect allowances with future vintage years. 17 Chapple et al. (2009) assess the effect of emissions on market valuations using firms annual level of emissions in Australia. The authors find that the market assesses the firms with the highest level of carbon emissions a reduction of between 7% and 10% of market capitalization relative to other sample firms. Matsumura et al. (2010) find that the annual level of carbon emissions voluntarily disclosed by S&P 500 firms is negatively associated with firm value, that the cost of debt (equity) is increasing (decreasing) in carbon emissions, and that the market expects future cash flows to be lower for high carbon-emitting firms than for low carbon-emitting firms. None of these studies using non-financial measures related to emissions explores the effects of alternative accounting treatments. Veith et al. (2009) perform an analysis that is most similar to ours in that it examines four accounting alternatives for emission rights. The analysis is based on a sample of 46 firms covered by the E.U. Emission Trading System and focuses on the period between March 2005 and September 2007. The 17 In contrast, our measure of emission allowances reflects all allowances that have been allocated to a firm s account, including those allowances with future vintage years. Although a firm cannot use those allowances to settle its emission obligation with the government, our data demonstrates that firms are buying and selling those allowances. Therefore, our data allows us to incorporate the actual number of allowances that an entity can use (either surrender to the government or sell to a third party) at each reporting date. This means that we are unable to make a direct comparison of our results with those of Johnston et al. (2008). 19

authors do not have transaction-level data; they know only the annual quantities of allowances allocated by the government to firms, firm emissions, and allowances surrendered to the government. As a result, they must make a number of assumptions in addition to the ones that we must make in our study. The key additional assumptions are: Allowances are received on March 1 and surrendered on April 30. No speculation occurs. Market transactions occur only when there is a difference between the number of allowances that an entity is allocated and the number that it surrenders. Market transactions occur immediately after the shortfall/excess is known at the end of the calendar year. Allowances are used only to settle the obligation incurred during the calendar year that they are received. The transaction-level data that we use does not require these assumptions because we have data on when each transaction occurs, at what price, and whether it was needed to satisfy a firm s emissions levels for the period. Because our data are at the transaction level (not the annual level, as in Johnston et al. (2008) or Veith et al. (2009)), we are able to examine the effects of alternative accounting treatments on quarterly (as well as annual) financial statements. Finally, because transactions-data for SO 2 emission allowances have identification numbers and are dated, we are able to calculate gains and losses on each transaction with precision, because we are able to trace the purchase and sales prices for each transaction in our database. We believe these aspects of our data are important, especially for examining differences in accounting treatments where income is expected to be affected because of either or both gains/losses on sales and changes in fair values. In particular, our data allow us to precisely determine the financial statement effects of the alternative accounting treatments. We describe the data and sample used in our analysis and the process used to generate the as-if balance sheets and income statements for our sample companies (section 4.1). We then examine the financial reporting effects of the alternative accounting treatments for our sample companies (section 4.2). 20

Finally, we discuss the research design used to explore the capital market perception of the assets and liabilities arising under the U.S. SO 2 program and our related empirical results (section 4.3). 4.1 Data and sample We collect data on all transactions of emission allowances since the inception of the U.S. SO 2 program in 1993 to 2009 (571,394 transactions), including the identity of the transacting parties, the confirmation date of the transaction, the number of allowances transacted, the vintage year of the allowances transacted, and the type of transaction (for example, initial allocation of allowances from the government, purchase of allowances at an EPA auction, private transfer of allowances between third parties, etc.). We also collect data on entities annual SO 2 emissions levels. These data are publicly available from the U.S. Environmental Protection Agency (EPA). Because the transactions are reported at the facility (plant) level, we aggregate them to the utility level by determining the utility ownership of each plant; we then aggregate to the firm level by determining the parent company ownership of each utility. In aggregating to the firm level, we eliminate all intercompany transactions. Using this data, we identify 79 U.S. public firms that are covered by (that is, have compliance obligations under) the U.S. SO 2 program from 1995 to 2009. 18 These are firms that own electric power plants fired by coal, oil, or gas. After eliminating firm-quarters missing required data from COMPUSTAT and CRSP, we have data for 74 firms and 2,997 firm-quarters. We also eliminate firms with insubstantial amounts of emissions (less than 1,000 tons of emissions per year for every year that the firm is covered by the SO 2 program), for a final sample of 2,487 firm-quarters of data for 56 U.S. public firms. The sample selection process and a list of sample firms are summarized in Table 1. We then create as-if balance sheets and income statements for each of the 56 firms in our sample for each quarter from 1993-2009 under the five alternative accounting methods described in section 3 (net approach, our proposed treatment, IFRIC 3 cost approach, IFRIC 3 revaluation approach, and hybrid IFRIC 3 cost-net approach). First, we categorize each of the transactions into the following seven types: 18 The SO 2 program began in 1993 with the allocation of emission allowances to entities by the government. However, entities did not have compliance obligations under the program until 1995. 21

1 receive allocation of allowances from the government free of charge 2 surrender allowances to the government to cover emissions 3 purchase allowances from a third party (private transaction or auction) 4 sell allowances to a third party 5 surrender allowances to the government not to cover emissions (e.g., for unexplained underutilization during the first phase of the program) 6 purchase allowances from government auction 7 reverse previous retirement deductions Then we recreate the related journal entries for the transactions under each of the alternative accounting methods. The journal entries are summarized in Appendix B. We use the market prices for traded SO 2 allowances as the relevant transaction price or fair value at each transaction date, except that for purchases of allowances from government auctions, we use auction price data available from the EPA. We have monthly prices for traded SO 2 allowances from Cantor Fitzgerald from August 1994 and daily prices beginning on October 4, 2001. For transaction dates from March 1993 (the beginning of the SO 2 program) through July 1994, we interpolate market prices based on the graph in Figure 4 of Ellerman and Montero (2007). We use daily price data when available. If a transaction occurs on a non-trading day, we use the price data from the first trading day immediately prior to the transaction date. For transactions before October 4, 2001, we use the monthly price for all transactions occurring in that month. At the end of each quarter, we also prepare journal entries, as needed, to recognize the firms emission obligations, remeasure the firms emission allowances and emission obligations, and amortize any related government grants on a systematic basis. In this process, we assume that the firms annual emissions levels are generated equally over the four quarters. We amortize any government grants based on this calculated quarterly level of emissions. Finally, we obtain the firms quarterly balance sheet and income statement data from COMPUSTAT. Based on our understanding of current practice and discussion provided in the annual reports of several firms in our sample, we assume that firms are using the net approach to account for transactions related to the SO 2 program. Therefore, the firms unadjusted COMPUSTAT data provides the basis for the quarterly financial statements under the net approach (therefore, labeled the baseline 22

approach ). We then use the journal entries created above to calculate the differences in the quarterly balances of emission allowances (current and noncurrent), emission obligations (current and noncurrent), government grants, retained earnings, accumulated other comprehensive income, net income, and comprehensive income between the net approach and the other four alternative accounting treatments. We are able, therefore, to create as-if balance sheets and income statements for each quarter during 1995-2009, under each accounting treatment. Table 2 presents the descriptive statistics pooled over all firm-quarters in our sample. The average differences between Methods 1-4 and the baseline approach are much higher for emission allowances and government grants than for emission obligations. In addition, the average differences in net income relative to the baseline approach are small, but the variability in net income is large. As noted in section 3.3, this is important because volatility in income was one of the main concerns that led to the withdrawal of IFRIC 3 and continues to be discussed as part of the FASB s and IASB s projects on emissions trading schemes. In untabulated t-tests, we find that the average carrying values of emission allowances, emission obligations and government grants under Methods 1-4 as well as the average quarterly net income under Methods 2-4 are all reliably different from the values under the baseline approach at conventional statistical levels (p-values <.0001 for the allowances, obligations, and government grants; p-values <.01 for net income). 19 In addition, the average carrying values of emission allowances under Methods 1 and 3 are reliably different from the values under Methods 2 and 4 (p-values <.0001). The average carrying value of emission obligations under Method 4 is reliably different from that under Methods 1-3 (p-value <.0001) and the average quarterly net income is reliably different under all of the methods (p-values <.01). Thus, Table 2 provides evidence that the qualitative differences between the alternative accounting 19 The results of the t-tests discussed in this paragraph are robust to using annual measures of the variables. Although some significance levels are diminished, all differences between the alternative accounting treatments remain statistically significant at conventional levels (p-values <.06). In addition, the average annual net income under Method 1 is reliably different from net income under the baseline approach (p-value <.001). 23

treatments discussed in section 3 have statistically reliable quantitative effects on the financial reporting of the firms in our sample. Table 3 presents the correlations between our variables. Note that the correlations between the differences in emission allowances under the alternative accounting treatments are high, as are the correlations between the differences in emission obligations (all p-values <.001). We would expect this result due to the overlap in the accounting treatments. Also note that the Pearson correlations between the differences in net income relative to the net approach and market value of equity are generally insignificant. 4.2 Financial reporting effects of alternative accounting treatments Table 4 presents the effects of each alternative accounting treatment on measures of financial performance, leverage and volatility. First, we calculate the average values of the variables (unscaled) under each of the five alternative accounting treatments. The average values are calculated for each firm and then averaged over the 56 firms in our sample. Panel A of Table 4 shows that the differences that arise between the alternative accounting treatments can be significant for the firms in our sample. For example, for the average firm in our sample, using Method 1 (our proposed accounting treatment) instead of the net approach increases the assets value by $933 million, from $26,657 million to $27,590 million (p-value of difference <.0001). In contrast, using Method 2 (the IFRIC 3 cost approach) increases the asset value relative to the net approach by only $421 million, from $26,657 million to $27,078 million (pvalue of difference <.0001). Therefore, switching to Method 1 would increase assets by 3.5%, whereas switching to Method 2 would increase assets by 1.6%. The alternative accounting treatments can also have significant effects on measures of liquidity and financial performance. For example, using Method 2 (the IFRIC 3 cost approach) instead of the net approach increases the debt-equity ratio for an average firm by 0.79, from 3.20 to 3.99 (p-value of difference <.04). Using Method 1 (our proposed treatment) instead of the net approach reduces return on assets by over 50%, from.68% to.32% (p-value of difference <.0001). 24

Panel B of Table 4 examines the volatility of key financial indicators under the alternative accounting treatments. For example, the average quarterly volatility in net income for the average firm in our sample is $556 million under Method 1 (our proposed treatment), compared to $205 million under the baseline net approach (p-value of difference <.0001). The average quarterly volatility in net income under Methods 2-4 is between $233 and $237 million, which is significantly lower than that under Method 1 (p-values of differences <.0001). In summary, Table 4 provides evidence that differences in the alternative accounting treatments for cap-and-trade programs can result in significant financial reporting effects for the firms involved. 4.3 Capital market perceptions of assets and liabilities arising in a cap-and-trade program To explore the capital market s perception of the assets and liabilities arising under a cap-andtrade program, we estimate the following equation in pooled cross-section using ordinary least squares (OLS) for each alternative accounting treatment: MVE it = β 0 + β 1 BVE it + β 2 ASSETDIF it + β 3 OBLDIF it + β 4 GGDIF it + β 5 NI it + β 6 NIDIF it + β 7 SALESGRW it + β 8j QTR jit + ε it (1) where i and t denote firm and quarter, respectively. The variables are defined as follows: MVE = market value of equity at the end of quarter t scaled by sales; BVE = book value of equity (minority interest plus shareholders equity) at the end of quarter t assuming the net approach for SO 2 transactions scaled by sales; ASSETDIF = difference in emission allowance carrying value relative to the net approach at the end of quarter t scaled by sales; OBLDIF = difference in emission obligation carrying value relative to the net approach at the end of quarter t scaled by sales; GGDIF = difference in government grant carrying value relative to the net approach at the end of quarter t scaled by sales; NI = net income for quarter t assuming the net approach for SO 2 transactions scaled by sales; NIDIF = difference in net income relative to the net approach for quarter t scaled by sales; SALESGRW = average sales growth over the last three 25

years; and QTR = dichotomous variable that is equal to one if the observation is from quarter t, zero otherwise. 20 Following Ohlson (1995), which suggests that the correct specification for a price association regression includes both book value and income, we include net income (NI). We also include SALESGRW to capture potential growth opportunities not reflected in book value or income. To mitigate concerns about heteroskedasticity, we scale the accounting variables by quarterly sales, a measure that is unaffected by alternative accounting treatments for emission allowances. 21 We do not predict the signs or magnitudes of the coefficients on the differences between the emission allowances, emission obligations, and government grants under the various accounting alternatives. These coefficients depend on how the market perceives the rights and obligations generated under the SO 2 program. The purpose of our analysis is to shed light on this issue. Table 5 presents the results. The results of a (untabulated) comparison of the adjusted R 2 of the alternative accounting treatments using the Vuong test reveals that the adjusted R 2 s for Methods 1-4 are significantly higher (p-values <.0001) than that for the baseline approach. None of the adjusted R 2 s for Methods 1-4 are significantly different from each other (p-values >.10). The key finding is that the additional value recognized as an emission allowance asset under Methods 1-4 relative to the net approach has a positive and statistically significant market valuation effect (p-values <.05). The main difference between Methods 1-4 and the net approach is that Methods 1-4 recognize emission allowances received free of charge from the government at fair value, whereas the net approach does not reflect these allowances in the balance sheet. The results in Table 5 suggest that the 20 When we rerun Equation (1) including firm fixed effects instead of quarter fixed effects, the coefficient on the emission obligation difference under Method 1 becomes statistically significant (p-value <.05), the coefficient on the emission obligation difference under Method 2 becomes positive and statistically significant (p-value <.01), and the coefficient on the net income difference under Method 3 becomes statistically significant (p-value <.01). When we include quarter fixed effects and cluster standard errors by firm, none of the coefficients on the differences between Methods 1-4 and the baseline approach are statistically significant (p-values >.10). 21 Using unscaled data, the coefficients on the asset differences under Methods 2 and 4 and the government grant balance under Method 3 are no longer statistically significant (p-values >.10). The coefficients on the emission obligation differences under Methods 1 and 3 are negative and statistically significant (p-values <.10). 26

market perceives that the allocation of allowances free of charge from the government to an entity creates an asset. The results in Table 5 also suggest that the government grant balance recognized under the IFRIC 3 revaluation approach (Method 3) is valued positively by the market. However, a statistically significant effect is not found for the government grant balance under Methods 2 and 4, even though the amount of the government grant balance is the same under all three methods. We are unable to explain this finding at this time. If the market views a government grant as a performance obligation, we would expect the coefficient on government grants to be negative. The positive coefficient suggests that the market might view the government grant balance as a signal of current and future income. The FASB and IASB are discussing whether the allocation of emission allowances to a firm free of charge generates a performance obligation as part of their current deliberations in the emissions trading project. None of the coefficients on the differences in the emission obligation and net income relative to the net approach are statistically significant in Table 5 (p-values >.10). 22 As noted in Table 2, the average differences in emission obligations and net income are small relative to the differences in emission allowances and government grants. It might be that the differences in emission obligations and net income are too small to produce statistically significant results in Table 5. It is possible that either investors perceive that the differences in the approaches to accounting for the emission obligations and the resulting income effects do not indicate economic differences that should be reflected as part of firm value or that investors are unable to observe these differences. The latter explanation might arise because firms are not required to separately disclose this information. It might be that the quantity of emission allowances allocated to a firm is more readily available than the amount required to be surrendered to the government or the emissions trading activity of a firm. In ongoing work, we are further examining the accessibility of emissions-related information to investors. 22 When we rerun equation (1) using annual data, the coefficients on the differences in net income relative to the net approach are positive and significant (p-values <.05) for Methods 2-4. In addition, the coefficient on the government grant balance in Method 4 is also positive and statistically significant (p-value <.05), but the coefficients on the asset difference for Methods 2-4 are no longer statistically significant (p-values >.10). 27

As noted above, the market seems to perceive that emission allowances allocated by the government free of charge to an entity create an asset that should be reflected in firm value. However, Table 5 does not help us distinguish whether the market perceives the value of that asset to be the initial fair value of the allowances at the time that they are received (Methods 1-4) or whether the remeasurement of allowances to fair value in subsequent reporting periods (Methods 1 and 3) produces additional information that is also valued by the market. To explore this issue, we rerun Equation (1), but separate the effects of the initial measurement of the emission allowances at fair value (ASSETDIFinitial) from the effects of remeasuring the allowances to fair value in subsequent reporting periods (ASSETDIF-subsequent). MVE it = β 0 + β 1 BVE it + β 2 ASSETDIF-initial it + β 3 ASSETDIF-subsequent it + β 4 OBLDIF it + β 5 GGDIF it + β 6 NI it + β 7 NIDIF it + β 8 SALESGRW it + β 9j QTR jit + ε it (2) The results are presented in Table 6. The results suggest that the incremental value for emission allowances recognized under Methods 1 and 3 as a result of remeasuring the allowances to fair value is not reflected in the market valuation of the related firms. This suggests that the positive coefficient on asset differences in Table 5 is driven by the measurement of allowances at fair value at initial recognition (rather than at zero, as is the result under the net approach when allowances are received through allocation from the government free of charge) and that the remeasurement of allowances to fair value does not produce additional information that is valued by the market. 5. Summary and Conclusions We describe the components of cap-and-trade emissions reduction programs from a financial accounting perspective, that is, in terms of the rights and obligations that arise from those arrangements. Applying the precepts of the FASB s Conceptual Framework yields the conclusions that an entity covered by a cap-and-trade program would recognize emission allowances as intangible assets, measured at fair value; entities would recognize the related obligation, measured at fair value, as emissions occur. For both the asset and the liability, subsequent revaluations to fair value to reflect changes in economic conditions 28

would be included in income. Our proposed accounting treatment would not distinguish between purchased allowances and allocated allowances (received free of charge in nonreciprocal transactions) and between allowances held for use and allowances held for speculation/trading. We then investigate how our proposed accounting treatment and alternative treatments would affect financial reports by simulating the effects of each treatment on the quarterly financial statements of 56 public U.S. companies. We find that differences in the accounting treatments generate significant differences in key financial indicators for firms, including the debt-equity ratio, return on assets, and volatility in net income. We find that the market positively values the emission allowances carrying values recognized under both our proposed accounting treatment and the alternative treatments we consider. This response seems to be driven by the recognition of emission allowances allocated free of charge by the government to entities at fair value, rather than at a zero cost, which commonly occurs in current practice under the net approach. In addition, we find that the market positively values the government grant recognized in one specification in which the offsetting credit for allocated allowances is a government grant liability. We do not find incremental valuation effects associated with the differences in net income under the alternative accounting treatments, but we find that the volatility of net income under the alternative treatments varies significantly. 29

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Balance sheet effects Appendix A Summary of the financial statement effects of alternative accounting treatments for cap-and-trade emissions reduction programs Emission allowances Timing of recognition Initial measurement Subsequent measurement Net Approach Our Proposed Treatment IFRIC 3 Cost Approach IFRIC 3 Revaluation Approach Hybrid IFRIC 3 Cost-Net Approach (Baseline Method) (Method 1) (Method 2) (Method 3) (Method 4) At purchase or allocation Cost (measured at zero in the case of allocated allowances) Cost subject to impairment At purchase or At purchase or At purchase or At purchase or allocation allocation allocation allocation Fair value Fair value Fair value Fair value Fair value Cost subject to impairment Fair value Cost subject to impairment Emission obligation Timing of recognition When gases emitted When gases emitted When gases emitted When gases emitted When gases emitted Initial and subsequent measurement For quantity of allowances on hand needed to cover emissions For excess allowances needed to cover emissions Carrying value Fair value Fair value Fair value Carrying value Fair value Fair value Fair value Fair value Fair value Government grant Timing of recognition N/A N/A At allocation of allowances from government Measurement at inception N/A N/A Fair value of allowances received Subsequent measurement N/A N/A Amortized on systematic basis At allocation of allowances from government Fair value of allowances received Amortized on systematic basis At allocation of allowances from government Fair value of allowances received Amortized on systematic basis 33

Appendix A (continued) Summary of the financial statement effects of alternative accounting treatments for cap-and-trade emissions reduction programs Net Approach Our Proposed Treatment IFRIC 3 Cost Approach IFRIC 3 Revaluation Approach Hybrid IFRIC 3 Cost-Net Approach (Baseline Method) (Method 1) (Method 2) (Method 3) (Method 4) Income statement effects Allocation of allowances from N/A Current period gain Deferred gain Deferred gain Deferred gain government Emission of gases Expense equal to carrying value of allowances on hand plus the fair value of any additional allowances needed to meet emissions obligation Expense equal to the fair value of allowances required to meet emissions obligation Expense equal to the fair value of allowances required to meet emissions obligation Expense equal to the fair value of allowances required to meet emissions obligation Expense equal to carrying value of allowances on hand plus the fair value of any additional allowances needed to meet emissions obligation Changes in assets during period due to economic conditions Impairment losses (and subsequent reversals) included in current period income Changes in fair value included in current period income Impairment losses (and subsequent reversals) included in current period income Changes in fair value generally included in current period other comprehensive income until realized Impairment losses (and subsequent reversals) included in current period income Changes in liabilities during period due to economic conditions Changes in the calculated amount of the emissions obligation (due to either changes in the carrying value of allowances on hand or the fair value of excess allowances needed) included in current period income Changes in fair value included in current period income Changes in fair value included in current period income Changes in fair value included in current period income Changes in the calculated amount of the emissions obligation (due to either changes in the carrying value of allowances on hand or the fair value of excess allowances needed) included in current period income Amortization of government grant N/A N/A Current period gain Current period gain Current period gain 34

Appendix B Journal entries under alternative accounting treatments for cap-and-trade emissions reduction programs Net Approach (Baseline Method) 1 Receive allocation of allowances from the government free of charge No journal entry, but increase quantity of emission allowances on hand. 2 Surrender allowances to the government to cover emissions Dr. Emission expense [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation * [quantity surrendered/total quantity] Cr. Obligation to surrender allowances Remeasure related emission obligation to current value [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation * [quantity surrendered/total quantity] Dr. Obligation to surrender allowances Cr. Emission allowances (intangible asset) Cr. Profit or loss Record surrender of allowances [carrying value of allowances on hand + fair value of excess emissions] * [quantity surrendered/total quantity] quantity surrendered * [carrying value of allowances/total quantity of allowances] difference 3 Purchase allowances from a third party (private transaction or auction) Dr. Emission allowances (intangible asset) quantity acquired * fair value Cr. Cash quantity acquired * fair value 4 Sell allowances to a third party Dr. Cash Cr. Emission allowances (intangible asset) Cr. Profit or loss quantity sold * fair value 35 quantity sold * [carrying value of allowances/total quantity of allowances] difference

5 Surrender allowances to the government not to cover emissions Dr. Profit or loss quantity surrendered * [carrying value of allowances/total quantity of allowances] Cr. Emission allowances (intangible asset) quantity surrendered * [carrying value of allowances/total quantity of allowances] 6 Purchase allowances from government auction Dr. Emission allowances (intangible asset) Cr. Cash quantity acquired * fair value quantity acquired * fair value 7 Reverse previous retirement deduction Dr. Emission allowances (intangible asset) Cr. Obligation to surrender allowances quantity acquired * [carrying value of allowances/total quantity of allowances] quantity acquired * [carrying value of allowances/total quantity of allowances] O Recognize emission obligation based on annual emissions divided equally into four quarters Dr. Emission expense [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation Cr. Obligation to surrender allowances [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation R Recognize remeasurement or impairment of emission allowances Dr. Profit or loss carrying value of total emission allowances - fair value of total emission allowances Cr. Emission allowances (intangible asset) carrying value of total emission allowances - fair value of total emission allowances For impairment losses or reversals of impairment losses only. No upward revaluations. Reversals are recognized up to amount of cumulative impairment losses on emission allowances recognized in previous periods that have not been reversed. 36

RO Remeasure emission obligation (based on current carrying value of allowances on hand and fair value of excess allowances needed) Dr. Emission expense [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation Cr. Obligation to surrender allowances [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation G Amortize government grant on systematic basis N/A Our Proposed Treatment (Method 1) 1 Receive allocation of allowances from the government free of charge Dr. Emission allowances (intangible asset) quantity received * fair value Cr. Profit or loss quantity received * fair value 2 Surrender allowances to the government to cover emissions Dr. Emission expense [fair value of total emission obligation - carrying value of total emission obligation] * [quantity surrendered/total quantity] Cr. Obligation to surrender allowances [fair value of total emission obligation - carrying value of total emission obligation] * [quantity surrendered/total quantity] Remeasure related emission obligation to fair value Dr. Emission allowances (intangible asset) [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Cr. Profit or loss [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Remeasure related emission allowances to fair value 37

Dr. Obligation to surrender allowances Cr. Emission allowances (intangible asset) Record surrender of allowances quantity surrendered * fair value quantity surrendered * fair value 3 Purchase allowances from a third party (private transaction or auction) Dr. Emission allowances (intangible asset) quantity acquired * fair value Cr. Cash quantity acquired * fair value 4 Sell allowances to a third party Dr. Emission allowances (intangible asset) [fair value of total emission allowances - carrying value of total emission allowances] * [quantity sold/total quantity] Cr. Profit or loss [fair value of total emission allowances - carrying value of total emission allowances] * [quantity sold/total quantity] Remeasure related emission allowances to fair value Dr. Cash Cr. Emission allowances (intangible asset) Record sale of allowances quantity sold * fair value quantity sold * fair value 5 Surrender allowances to the government not to cover emissions Dr. Emission allowances (intangible asset) [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Cr. Profit or loss [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Remeasure related emission allowances to fair value Dr. Profit or loss Cr. Emission allowances (intangible asset) Record surrender of allowances quantity surrendered * fair value quantity surrendered * fair value 38

6 Purchase allowances from government auction Dr. Emission allowances (intangible asset) Cr. Cash quantity acquired * fair value quantity acquired * fair value 7 Reverse previous retirement deduction Dr. Emission allowances (intangible asset) Cr. Obligation to surrender allowances quantity acquired * fair value quantity acquired * fair value O Recognize emission obligation based on annual emissions divided equally into four quarters Dr. Emission expense quantity emitted * fair value Cr. Obligation to surrender allowances quantity emitted * fair value R Recognize remeasurement or impairment of emission allowances Dr. Emission allowances (intangible asset) fair value of total emission allowances - carrying value of total emission allowances Cr. Profit or loss fair value of total emission allowances - carrying value of total emission allowances RO Remeasure emission obligation (based on current carrying value of allowances on hand and fair value of excess allowances needed) Dr. Emission expense fair value of total emission obligation - carrying value of total emission obligation Cr. Obligation to surrender allowances fair value of total emission obligation - carrying value of total emission obligation G Amortize government grant on systematic basis N/A IFRIC 3 Cost Approach (Method 2) 1 Receive allocation of allowances from the government free of charge Dr. Emission allowances (intangible asset) quantity received * fair value Cr. Government grant (deferred income) quantity received * fair value 39

2 Surrender allowances to the government to cover emissions Dr. Emission expense [fair value of total emission obligation - carrying value of total emission obligation] * [quantity surrendered/total quantity] Cr. Obligation to surrender allowances [fair value of total emission obligation - carrying value of total emission obligation] * [quantity surrendered/total quantity] Remeasure related emission obligation to current value Dr. Obligation to surrender allowances Cr. Emission allowances (intangible asset) Cr. Profit or loss Record surrender of allowances quantity surrendered * fair value quantity surrendered * [carrying value of total allowances/total quantity of allowances] difference 3 Purchase allowances from a third party (private transaction or auction) Dr. Emission allowances (intangible asset) quantity acquired * fair value Cr. Cash quantity acquired * fair value 4 Sell allowances to a third party Dr. Cash Cr. Emission allowances (intangible asset) Cr. Profit or loss quantity sold * fair value quantity sold * [carrying value of total allowances/total quantity of allowances] difference 5 Surrender allowances to the government not to cover emissions Dr. Profit or loss quantity surrendered * [carrying value of total allowances/total quantity of allowances] Cr. Emission allowances (intangible asset) quantity surrendered * [carrying value of total allowances/total quantity of allowances] 40

6 Purchase allowances from government auction Dr. Emission allowances (intangible asset) Cr. Cash quantity acquired * fair value quantity acquired * fair value 7 Reverse previous retirement deduction Dr. Emission allowances (intangible asset) Cr. Obligation to surrender allowances quantity acquired * fair value quantity acquired * fair value O Recognize emission obligation based on annual emissions divided equally into four quarters Dr. Emission expense quantity emitted * fair value Cr. Obligation to surrender allowances quantity emitted * fair value R Recognize remeasurement or impairment of emission allowances Dr. Profit or loss carrying value of total emission allowances - fair value of total emission allowances Cr. Emission allowances (intangible asset) carrying value of total emission allowances - fair value of total emission allowances For impairment losses or reversals of impairment losses only. No upward revaluations. Reversals are recognized up to amount of cumulative impairment losses on emission allowances recognized in previous periods that have not been reversed. RO Remeasure emission obligation (based on current carrying value of allowances on hand and fair value of excess allowances needed) Dr. Emission expense fair value of total emission obligation - carrying value of total emission obligation Cr. Obligation to surrender allowances fair value of total emission obligation - carrying value of total emission obligation G Amortize government grant on systematic basis Dr. Government grant (deferred income) Cr. Profit or loss quantity emitted * [carrying value of total government grants/total quantity of government grant allowances] quantity emitted * [carrying value of total government grants/total quantity of government grant allowances] 41

IFRIC 3 Revaluation Approach (Method 3) 1 Receive allocation of allowances from the government free of charge Dr. Emission allowances (intangible asset) quantity received * fair value Cr. Government grant (deferred income) quantity received * fair value 2 Surrender allowances to the government to cover emissions Dr. Emission expense [fair value of total emission obligation - carrying value of total emission obligation] * [quantity surrendered/total quantity] Cr. Obligation to surrender allowances [fair value of total emission obligation - carrying value of total emission obligation] * [quantity surrendered/total quantity] Remeasure related emission obligation to fair value Dr. Emission allowances (intangible asset) [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Cr. Other comprehensive income --OR-- profit or loss [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Remeasure related emission allowances to fair value. Changes in fair value are recognized in other comprehensive income (OCI) unless there is a decline in value with no OCI balance to reduce or there in an increase in value after a previous decline had been recognized in profit or loss. In those cases, the change in value is recognized in profit or loss. Dr. Obligation to surrender allowances Cr. Emission allowances (intangible asset) Record surrender of allowances quantity surrendered * fair value quantity surrendered * fair value Dr. Revaluation surplus (equity) Cr. Retained earnings quantity surrendered * [revaluation surplus balance/total quantity of emission allowances] Transfer related revaluation surplus balance to retained earnings when realized on an average allowance basis 42 quantity surrendered * [revaluation surplus balance/total quantity of emission allowances]

3 Purchase allowances from a third party (private transaction or auction) Dr. Emission allowances (intangible asset) quantity acquired * fair value Cr. Cash quantity acquired * fair value 4 Sell allowances to a third party Dr. Emission allowances (intangible asset) [fair value of total emission allowances - carrying value of total emission allowances] * [quantity sold/total quantity] Cr. Other comprehensive income --OR-- profit or loss [fair value of total emission allowances - carrying value of total emission allowances] * [quantity sold/total quantity] Remeasure related emission allowances to fair value. Changes in fair value are recognized in other comprehensive income (OCI) unless there is a decline in value with no OCI balance to reduce or there in an increase in value after a previous decline had been recognized in profit or loss. In those cases, the change in value is recognized in profit or loss. Dr. Cash Cr. Emission allowances (intangible asset) Record sale of allowances quantity sold * fair value quantity sold * fair value Dr. Revaluation surplus (equity) Cr. Retained earnings quantity sold * [revaluation surplus balance/total quantity of emission allowances] Transfer related revaluation surplus balance to retained earnings when realized on an average allowance basis quantity sold * [revaluation surplus balance/total quantity of emission allowances] 43

5 Surrender allowances to the government not to cover emissions Dr. Emission allowances (intangible asset) [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Cr. Other comprehensive income --OR-- profit or loss [fair value of total emission allowances - carrying value of total emission allowances] * [quantity surrendered/total quantity] Remeasure related emission allowances to fair value. Changes in fair value are recognized in other comprehensive income (OCI) unless there is a decline in value with no OCI balance to reduce or there in an increase in value after a previous decline had been recognized in profit or loss. In those cases, the change in value is recognized in profit or loss. Dr. Profit or loss Cr. Emission allowances (intangible asset) Record surrender of allowances quantity surrendered * fair value quantity surrendered * fair value Dr. Revaluation surplus (equity) Cr. Retained earnings quantity surrendered * [revaluation surplus balance/total quantity of emission allowances] Transfer related revaluation surplus balance to retained earnings when realized on an average allowance basis quantity surrendered * [revaluation surplus balance/total quantity of emission allowances] 6 Purchase allowances from government auction Dr. Emission allowances (intangible asset) Cr. Cash quantity acquired * fair value quantity acquired * fair value 7 Reverse previous retirement deduction Dr. Emission allowances (intangible asset) Cr. Obligation to surrender allowances quantity acquired * fair value quantity acquired * fair value O Recognize emission obligation based on annual emissions divided equally into four quarters Dr. Emission expense quantity emitted * fair value Cr. Obligation to surrender allowances quantity emitted * fair value 44

R Recognize remeasurement or impairment of emission allowances Dr. Emission allowances (intangible asset) fair value of total emission allowances - carrying value of total emission allowances Cr. Other comprehensive income --OR-- profit or loss fair value of total emission allowances - carrying value of total emission allowances Changes in fair value are recognized in other comprehensive income (OCI) unless there is a decline in value with no OCI balance to reduce or there in an increase in value after a previous decline had been recognized in profit or loss. In those cases, the change in value is recognized in profit or loss. RO Remeasure emission obligation (based on current carrying value of allowances on hand and fair value of excess allowances needed) Dr. Emission expense fair value of total emission obligation - carrying value of total emission obligation Cr. Obligation to surrender allowances fair value of total emission obligation - carrying value of total emission obligation G Amortize government grant on systematic basis Dr. Government grant (deferred income) Cr. Profit or loss quantity emitted * [carrying value of total government grants/total quantity of government grant allowances] quantity emitted * [carrying value of total government grants/total quantity of government grant allowances] Hybrid IFRIC 3 Cost-Net Approach (Method 4) 1 Receive allocation of allowances from the government free of charge Dr. Emission allowances (intangible asset) quantity received * fair value Cr. Government grant (deferred income) quantity received * fair value 45

2 Surrender allowances to the government to cover emissions Dr. Emission expense [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation * [quantity surrendered/total quantity] Cr. Obligation to surrender allowances Remeasure related emission obligation to current value [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation * [quantity surrendered/total quantity] Dr. Obligation to surrender allowances Cr. Emission allowances (intangible asset) Cr. Profit or loss Record surrender of allowances quantity surrendered * fair value quantity surrendered * [carrying value of total allowances/total quantity of allowances] difference 3 Purchase allowances from a third party (private transaction or auction) Dr. Emission allowances (intangible asset) quantity acquired * fair value Cr. Cash quantity acquired * fair value 4 Sell allowances to a third party Dr. Cash Cr. Emission allowances (intangible asset) Cr. Profit or loss quantity sold * fair value quantity sold * [carrying value of total allowances/total quantity of allowances] difference 5 Surrender allowances to the government not to cover emissions Dr. Profit or loss quantity surrendered * [carrying value of total allowances/total quantity of allowances] Cr. Emission allowances (intangible asset) quantity surrendered * [carrying value of total allowances/total quantity of allowances] 46

6 Purchase allowances from government auction Dr. Emission allowances (intangible asset) Cr. Cash quantity acquired * fair value quantity acquired * fair value 7 Reverse previous retirement deduction Dr. Emission allowances (intangible asset) Cr. Obligation to surrender allowances quantity acquired * [carrying value of allowances/total quantity of allowances] quantity acquired * [carrying value of allowances/total quantity of allowances] O Recognize emission obligation based on annual emissions divided equally into four quarters Dr. Emission expense [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation Cr. Obligation to surrender allowances [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation R Recognize remeasurement or impairment of emission allowances Dr. Profit or loss carrying value of total emission allowances - fair value of total emission allowances Cr. Emission allowances (intangible asset) carrying value of total emission allowances - fair value of total emission allowances For impairment losses or reversals of impairment losses only. No upward revaluations. Reversals are recognized up to amount of cumulative impairment losses on emission allowances recognized in previous periods that have not been reversed. RO Remeasure emission obligation (based on current carrying value of allowances on hand and fair value of excess allowances needed) Dr. Emission expense [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation Cr. Obligation to surrender allowances [carrying value of allowances on hand + fair value of excess emissions] - carrying value of emission obligation 47

G Amortize government grant on systematic basis Dr. Government grant (deferred income) Cr. Profit or loss quantity emitted * [carrying value of total government grants/total quantity of government grant allowances] quantity emitted * [carrying value of total government grants/total quantity of government grant allowances] 48

Table 1 Sample selection Firms Firmquarters U.S. public firms covered by the EPA's SO 2 program (1995-2009) 79 4,252 Quarters missing required financial data from COMPUSTAT (assets, liabilities) - (107) Quarters missing required pricing data from CRSP (price, shares outstanding) and COMPUSTAT (market value) (5) (1,148) Firms with insignificant covered emissions (always less than 1,000 tons/year) (18) (510) Total observations in sample 56 2,487 Sample firms AES Corporation Alcoa Inc Allegheny Energy Inc Allete Inc Alliant Energy Corporation Ameren Corporation American Electric Power Co Black Hills Corporation Calpine Corporation Cleco Corporation CMS Energy Corporation Consolidated Edison Inc Constellation Energy Group Inc Dominion Resources Inc DPL Inc DTE Energy Co Duke Energy Co Dynegy Inc Edison International Empire District Electric Co Energy Future Holdings Corporation Entergy Corporation Exelon Corporation FirstEnergy Corporation Goldman Sachs Group Inc Great Plains Energy Inc IDACORP Inc Integrys Energy Group Inc MDU Resources Inc MGE Energy Inc MidAmerican Energy Holdings Mirant Corporation NiSource Inc Northeast Utilities NRG Energy Inc NV Energy Inc OGE Energy Corporation Otter Tail Corporation PacifiCorp Pepco Holdings Inc PG&E Corporation Pinnacle West Capital Corporation PNM Resources Inc Portland General Electric Co PPL Corporation Progress Energy Inc Public Service Enterprise Group Inc RRI Energy Inc SCANA Corporation Southern Co TECO Energy Inc UGI Corporation Unisource Energy Corporation Westar Energy Inc Wisconsin Energy Corporation Xcel Energy Inc 49

Table 2 Descriptive statistics Quarterly descriptive statistics (pooled over the full sample) Mean Std. dev. First quartile Median Third quartile MVE 4.676 2.646 3.077 4.327 5.898 BVE 3.046 1.508 2.112 2.942 3.775 ASSETDIF1 0.798 1.075 0.121 0.422 1.067 ASSETDIF2 0.394 0.417 0.070 0.275 0.592 ASSETDIF3 0.798 1.075 0.121 0.422 1.067 ASSETDIF4 0.394 0.417 0.070 0.275 0.592 OBLDIF1 0.017 0.057 0.000 0.004 0.020 OBLDIF2 0.017 0.057 0.000 0.004 0.020 OBLDIF3 0.017 0.057 0.000 0.004 0.020 OBLDIF4 0.009 0.017 0.000 0.003 0.011 GGDIF1 0.000 0.000 0.000 0.000 0.000 GGDIF2 0.511 0.486 0.159 0.397 0.691 GGDIF3 0.511 0.486 0.159 0.397 0.691 GGDIF4 0.511 0.486 0.159 0.397 0.691 NI 0.064 0.192 0.039 0.073 0.111 NIDIF1-0.036 0.487-0.050 0.000 0.057 NIDIF2-0.003 0.093-0.007 0.000 0.006 NIDIF3-0.010 0.097-0.012-0.001 0.001 NIDIF4-0.005 0.088-0.003 0.000 0.001 SALESGRW 0.125 0.284 0.015 0.067 0.146 All variables except SALESGRW in millions of dollars and scaled by quarterly total sales. MVE Quarter-end market value of equity. Price * shares outstanding in CRSP. If CRSP data is not available, market value of equity in COMPUSTAT. BVE Quarter-end value of minority interest plus total shareholders' equity in COMPUSTAT. ASSETDIF# OBLDIF# GGDIF# NI NIDIF# SALESGRW Quarter-end difference in emission allowance carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarter-end difference in emission obligation carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarter-end difference in government grant carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarterly net income from COMPUSTAT. Quarter-end difference in net income relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Average sales growth over the previous three years. Calculated using sales from four, eight, and twelve quarters previous to the current quarter. If required data is unavailable to calculate sales growth for the previous three years, we use a two-year or one-year average. 50

Table 3 Correlation matrix Variable MVE BVE ASSET DIF1/3 ASSET DIF2/4 OBLDIF 1/2/3 OBLDIF4 GGDIF 2/3/4 NI NIDIF1 NIDIF2 NIDIF3 NIDIF4 SALES GRW MVE 0.613 *** 0.347 *** 0.423 *** 0.118 *** 0.244 *** 0.433 *** 0.136 *** -0.068 *** 0.063 *** 0.011 0.046 ** -0.154 *** BVE 0.661 *** 0.242 *** 0.368 *** 0.023 0.178 *** 0.486 *** 0.018-0.069 *** -0.029-0.048 ** -0.040 ** -0.224 *** ASSETDIF1/3 0.358 *** 0.259 *** 0.690 *** 0.614 *** 0.553 *** 0.586 *** 0.000-0.118 *** 0.117 *** -0.042 ** 0.065 *** -0.112 *** ASSETDIF2/4 0.377 *** 0.350 *** 0.901 *** 0.407 *** 0.658 *** 0.875 *** -0.028-0.026 0.156 *** 0.088 *** 0.135 *** -0.056 *** OBLDIF1/2/3 0.121 *** -0.002 0.613 *** 0.530 *** 0.689 *** 0.333 *** -0.015-0.172 *** 0.083 *** 0.010 0.034 * -0.053 *** OBLDIF4 0.132 *** 0.042 ** 0.577 *** 0.577 *** 0.962 *** 0.580 *** -0.060 *** -0.113 *** 0.115 *** 0.070 *** 0.092 *** -0.049 ** GGDIF2/3/4 0.423 *** 0.491 *** 0.730 *** 0.854 *** 0.401 *** 0.468 *** -0.019-0.066 *** -0.025-0.082 *** -0.052 *** -0.112 *** NI 0.413 *** 0.254 *** 0.101 *** 0.147 *** -0.030-0.009 0.189 *** -0.004 0.028 0.022 0.030-0.113 *** NIDIF1-0.002 0.005 0.122 *** 0.070 *** 0.072 *** 0.037 * 0.016-0.022 0.253 *** 0.133 *** 0.222 *** 0.033 NIDIF2 0.010 0.008-0.008 0.044 ** -0.083 *** -0.068 *** -0.014 0.022 0.067 *** 0.937 *** 0.952 *** 0.024 NIDIF3-0.061 *** -0.026-0.204 *** -0.074 *** -0.208 *** -0.159 *** -0.126 *** 0.048 ** 0.073 *** 0.828 *** 0.921 *** 0.035 * NIDIF4 0.013 0.016-0.007 0.042 ** -0.020-0.010-0.015 0.061 *** 0.425 *** 0.669 *** 0.725 *** 0.027 SALESGRW -0.217 *** -0.324 *** -0.087 *** -0.085 *** -0.017-0.016-0.177 *** -0.134 *** -0.070 *** -0.003 0.013-0.058 *** This table presents the Pearson (bottom-left) and Spearman (upper-right) correlation coefficents for the quarterly scaled variables used in this paper. * indicates p value <.1, ** <.05, *** <.01. All variables except SALESGRW in millions of dollars and scaled by quarterly total sales. MVE Quarter-end market value of equity. Price * shares outstanding in CRSP. If CRSP data is not available, market value of equity in COMPUSTAT. BVE ASSETDIF# OBLDIF# GGDIF# NI NIDIF# SALESGRW Quarter-end value of minority interest plus total shareholders' equity in COMPUSTAT. Quarter-end difference in emission allowance carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarter-end difference in emission obligation carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarter-end difference in government grant carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarterly net income from COMPUSTAT. Quarter-end difference in net income relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Average sales growth over the previous three years. Calculated using sales from four, eight, and twelve quarters previous to the current quarter. If required data is unavailable to calculate sales growth for the previous three years, we use a two-year or one-year average. 51

Table 4 Effect of alternative accounting treatments on key financial indicators Panel A: Average values of quarterly measures (measured over 1995-2009) Calculated as the average of the average values for each firm. That is, the average value for a variable is calculated for a firm over the number of quarters that it is in the sample (up to 60 quarters). Then the table presents the average of these values over the 56 firms in the sample. ($ in millions) Net Approach Our Proposed Treatment IFRIC 3 Cost Approach IFRIC 3 Revaluation Approach Hybrid IFRIC 3 Cost - Net Approach (Baseline Method) (Method 1) (Method 2) (Method 3) (Method 4) Variable Mean Median Mean Median Mean Median Mean Median Mean Median Assets 26,656.89 11,909.41 27,589.82 12,739.61 27,078.23 12,363.80 27,589.82 12,739.61 27,078.10 12,363.80 Liabilities 22,187.13 8,496.82 22,215.81 8,506.73 22,770.75 9,219.39 22,770.75 9,219.39 22,754.67 9,184.92 Equity 4,469.76 2,790.89 5,374.01 3,632.28 4,307.48 2,628.16 4,819.07 3,014.52 4,323.43 2,634.24 Liabilities/Assets 0.7130 0.7085 0.6692 0.6502 0.7356 0.7289 0.7124 0.7069 0.7349 0.7280 Debt/Equity 3.1951 2.5919 4.2048 1.9811 3.9888 2.8800 3.0964 2.5688 3.6854 2.8699 Current Ratio 1.0573 0.9828 1.0552 1.0078 1.0512 0.9814 1.0749 1.0001 1.0813 1.0093 Asset Turnover 0.1097 0.0959 0.1022 0.0902 0.1056 0.0919 0.1022 0.0902 0.1056 0.0919 Net Income 116.74 48.88 57.47 18.32 110.75 41.97 102.18 39.19 107.85 40.70 Return on Assets 0.0068 0.0075 0.0032 0.0042 0.0063 0.0071 0.0056 0.0064 0.0062 0.0070 Return on Equity 0.0201 0.0247 0.0025 0.0118 0.0278 0.0251 0.0138 0.0205 0.0193 0.0243 Panel B: Average standard deviations of quarterly measures (measured over 1995-2009) Calculated as the average of the quarterly standard deviation measures for each firm. That is, the standard deviation of a variable is calculated for a firm over the number of quarters that it is in the sample (up to 60 quarters). Then the table presents the average of these values over the 56 firms in the sample. ($ in millions) Net Approach Our Proposed Treatment IFRIC 3 Cost Approach IFRIC 3 Revaluation Approach Hybrid IFRIC 3 Cost - Net Approach (Baseline Method) (Method 1) (Method 2) (Method 3) (Method 4) Variable Mean Median Mean Median Mean Median Mean Median Mean Median Assets 9,310.95 3,529.77 9,555.81 3,771.86 9,308.09 3,574.62 9,555.81 3,771.86 9,307.99 3,574.61 Liabilities 8,129.02 2,932.36 8,136.58 2,934.71 8,185.62 2,963.49 8,185.62 2,963.49 8,180.18 2,961.63 Equity 1,544.49 845.65 1,909.02 1,259.77 1,483.00 829.20 1,860.71 1,209.97 1,486.85 828.46 Liabilities/Assets 0.0474 0.0416 0.0581 0.0555 0.0441 0.0379 0.0551 0.0500 0.0439 0.0388 Debt/Equity 2.0167 0.5154 9.3398 0.4800 3.6931 0.5920 1.8694 0.6489 2.3289 0.5833 Current Ratio 0.3281 0.2493 0.3742 0.2520 0.3374 0.2484 0.3363 0.2531 0.3428 0.2517 Asset Turnover 0.0343 0.0221 0.0315 0.0197 0.0325 0.0209 0.0315 0.0197 0.0325 0.0209 Net Income 205.27 97.79 556.37 347.75 237.12 123.54 236.55 126.54 233.48 122.67 Return on Assets 0.0113 0.0079 0.0314 0.0280 0.0133 0.0103 0.0131 0.0101 0.0131 0.0101 Return on Equity 0.0701 0.0288 0.1379 0.0849 0.1342 0.0398 0.0812 0.0386 0.0910 0.0398 52

Table 5 Market valuation of alternative accounting treatments for cap-and-trade emissions reduction programs MVE it = β 0 + β 1 BVE it + β 2 ASSETDIF it + β 3 OBLDIF it + β 4 GGDIF it + β 5 NI it + β 6 NIDIF it + β 7 SALESGRW it + β 8j QTR jit + ε it Net Approach Our Proposed Treatment IFRIC 3 Cost Approach IFRIC 3 Revaluation Approach Hybrid IFRIC 3 Cost-Net Approach (Baseline Method) (Method 1) (Method 2) (Method 3) (Method 4) Variable Coef. Coef. Coef. Coef. Coef. Intercept 0.232 0.601 * 0.750 ** 0.467 0.752 BVE 1.104 *** 1.002 *** 0.980 *** 0.961 *** 0.980 ASSETDIF 0.478 *** 1.463 ** 0.270 ** 1.485 OBLDIF -0.755-0.080-0.560-0.162 GGDIF -0.163 0.609 ** -0.180 NI 1.532 *** 1.555 *** 1.640 *** 1.594 *** 1.641 NIDIF -0.109 0.310 0.653 0.198 SALESGRW 0.000 0.000 0.000 0.000 0.000 N 2485 2485 2485 2485 2485 Adjusted R 2 0.457 0.478 0.488 0.483 0.488 ** *** ** *** The sample period is 1995-2009. t-statistics are based on White (1980) standard errors. Coefficients and related t-statistics on the quarter dummy variables are suppressed. The 2,485 firm-quarter observations correspond to 56 firms. ***, **, * indicate that the coefficient is significantly different from zero at the 1%, 5%, and 10% levels, respectively. All variables except SALESGRW in millions of dollars and scaled by quarterly total sales. MVE Quarter-end market value of equity. Price * shares outstanding in CRSP. If CRSP data is not available, market value of equity in COMPUSTAT. BVE ASSETDIF OBLDIF GGDIF NI NIDIF SALESGRW Quarter-end value of minority interest plus total shareholders' equity in COMPUSTAT. Quarter-end difference in emission allowance carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarter-end difference in emission obligation carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarter-end difference in government grant carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Quarterly net income from COMPUSTAT. Quarter-end difference in net income relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. Average sales growth over the previous three years. Calculated using sales from four, eight, and twelve quarters previous to the current quarter. If required data is unavailable to calculate sales growth for the previous three years, we use a two-year or one-year average. 53

Table 6 Examination of the measurement attribute used for emission allowances in cap-and-trade emissions reduction programs MVE it = β 0 + β 1 BVE it + β 2 ASSETDIF-initial it + β 3 ASSETDIF-subsequent it + β 4 OBLDIF it + β 5 GGDIF it + β 6 NI it + β 7 NIDIF it + β 8 SALESGRW it + β 9j QTR jit + ε it Net Approach Our Proposed Treatment IFRIC 3 Cost Approach IFRIC 3 Revaluation Approach Hybrid IFRIC 3 Cost-Net Approach (Baseline Method) (Method 1) (Method 2) (Method 3) (Method 4) Variable Coef. Coef. Coef. Coef. Coef. Intercept 0.268 0.751 ** 0.793 ** 0.814 ** 0.792 BVE 1.096 *** 0.951 *** 0.969 *** 0.965 *** 0.969 ASSETDIF-initial 1.265 *** 1.462 ** 1.509 *** 1.475 ASSETDIFsubsequent 0.070 0.069 OBLDIF -0.630-0.119-0.470-0.139 GGDIF -0.168-0.236-0.181 NI 1.516 *** 1.635 *** 1.634 *** 1.636 *** 1.635 NIDIF -0.172 0.311-0.245 0.202 SALESGRW -0.145-0.117-0.119-0.115-0.118 N 2485 2485 2485 2485 2485 Adjusted R 2 0.457 0.488 0.488 0.488 0.488 The sample period is 1995-2009. t-statistics are based on White (1980) standard errors. Coefficients and related t-statistics on the quarter dummy variables are suppressed. The 2,485 firm-quarter observations correspond to 56 firms. ***, **, * indicate that the coefficient is significantly different from zero at the 1%, 5%, and 10% levels, respectively. All variables except SALESGRW in millions of dollars and scaled by quarterly total sales. MVE Quarter-end market value of equity. Price * shares outstanding in CRSP. If CRSP data is not available, market value of equity in COMPUSTAT. BVE Quarter-end value of minority interest plus total shareholders' equity in COMPUSTAT. ASSETDIF-initial Quarter-end difference in emission allowance carrying value relative to the net approach that arises from measuring allocated allowances at fair value at initial recognition using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. ASSETDIF-subsequent Quarter-end difference in emission allowance carrying value relative to the net approach that arises from remeasuring emission allowances to fair value in subsequent reporting periods using either our proposed treatment (Method 1) or the IFRIC 3 revaluation approach for all SO 2 transactions. OBLDIF Quarter-end difference in emission obligation carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. GGDIF Quarter-end difference in government grant carrying value relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. NI Quarterly net income from COMPUSTAT. NIDIF Quarter-end difference in net income relative to the net approach using either our proposed treatment (Method 1), the IFRIC 3 cost approach (Method 2), the IFRIC 3 revaluation approach (Method 3), or the hybrid IFRIC 3 cost-net approach (Method 4) for all SO 2 transactions. SALESGRW Average sales growth over the previous three years. Calculated using sales from four, eight, and twelve quarters previous to the current quarter. If required data is unavailable to calculate sales growth for the previous three years, we use a two-year or one-year average. ** *** ** *** 54