COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a Decision of the European Parliament and of the Council concerning the establishment and operation of a market stability reserve for the Union greenhouse gas emission trading scheme and amending Directive 2003/87/EC
Date: 2014-01-22
Institutions: European Commission
Subjects: EU Emissions Trading Scheme, environmental statistics, greenhouse gas, reduction of gas emissions, reservation

EUROPEAN 
COMMISSION 

Brussels, 22.1.2014  
SWD(2014) 18 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Decision of the European Parliament and of the Council 

concerning the establishment and operation of a market stability reserve for the Union 
greenhouse gas emission trading scheme and amending Directive 2003/87/EC 

{COM(2014) 20 final} 
{SWD(2014) 17 final} 

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COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Decision of the European Parliament and of the Council 

concerning the establishment and operation of a market stability reserve for the Union 
greenhouse gas emission trading scheme and amending Directive 2003/87/EC 

1. 

PROBLEM DEFINITION 

At the start of the third trading period (2013-2020), the EU Emissions Trading System (ETS) 
was characterised by a surplus  of around 2  billion allowances.1 Over the coming years, this 
surplus is expected to grow and to reach more than 2.6 billion allowances by 2020, to only 
gradually decrease to around 2.1 billion by 2028 (reference scenario2).  

The  current  imbalance  in  the  EU  ETS  is  primarily  due  to  the  economic  crisis  and  a  large 
inflow of international credits at the end of phase 2 in view of restrictions on the use of certain 
credits  introduced  in  phase  3.  There  is  a  mismatch  between  the  auction  supply  of  emission 
allowances, which is fixed in a very rigid manner, and demand for them, which is flexible and 
impacted by economic cycles, fossil fuel prices as well as complementary policies delivering 
abatement.  

Although in a cap-and-trade system, such as the EU ETS, the agreed environmental objective 
expressed  by  the  cap,  limiting  total  emissions  for  a  given  period,  is  guaranteed,  the  cost-
efficiency objective expressed in the total cost is also of central importance. The presence of a 
large  surplus  is  a  problem  as  it  is  expected  to  lock  the  EU  into  high  carbon  capital  and 
investment. It reduces the dynamic efficiency of the market-based outcome and thus increases 
overall  costs  when  considered  over  the  mid-  and  long-term  that  are  relevant  for  the  climate 
change challenge. 

As  a  short  term  measure  to  mitigate  the  effects  of  this  problem  in  the  context  of  additional 
temporary  imbalances  caused  by  regulatory  changes  linked  to  the  transition  to  phase  3,  the 
Commission proposed to back-load the auctioning of 900 million allowances in the beginning 
of  phase  3.  Back-loading  has  received  a  favourable  opinion  from  Member  States  in  the 
Climate  Change  Committee  in  the  comitology  process.  While  the  measure  is  now  under 
scrutiny  by  the  European  Parliament  and  the  Council,  this  Impact  Assessment  takes  back-
loading  for  a  fact.  Back-loading  and  the  measures  considered  in  this  Impact  Assessment 
pursue complementary objectives.  

1 

2 

Surplus  is  defined  as  the  difference  between  the  cumulative  amount  of  allowances  available  for 
compliance  at  the  end of  a given  year,  and the  cumulative  amount  of  allowances  effectively  used  for 
compliance with the emissions up to that given year.   
The reference scenario assumes full implementation of existing policies, including the achievement of 
the renewable energy and greenhouse gas reduction targets for 2020 and implementation of the Energy 
Efficiency  Directive.  The  baseline  scenario  assumes  only  already  implemented  policies,  and does not 
achieve in all Member States all targets, for example the renewables targets. In the baseline scenario, 
the surplus is expected to stay at 2 billion in 2020.    

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As  already  highlighted  in  the  Report  on  the  State  of  the  European  Carbon  Market  in  2012 
(Carbon  Market  Report)3,  however,  back-loading  leads  to  a  rebound  in  the  surplus  in  2019 
and  2020  and  hence  does  not  affect  the  average  size  of  the  structural  surplus  of  over  1.8 
billion allowances in phase 3, peaking at 2.6 billion allowances in 2020 (see Figure 1). It is 
the structural surplus (and solutions for addressing it in a sustainable way) that is the focus of 
this Impact Assessment. 

Figure 1: Historical and projected future profile of supply and demand up to 2028 with back-loading 

OBJECTIVE 

2. 
The operational objective is to ensure inter-temporal efficiency4 of the carbon market in the 
short-term and beyond in a market setting characterised by large-scale auctioning, taking into 
account  the  need  for  simplicity  and  predictability.  This  requires  addressing  the  structural 
surplus  expected  to  remain  in  place  even  with  other  possible  measures  after  2020  in  the 
context of the 2030 framework (i.e. revision of the linear reduction factor, use of international 
credits, extension of the scope). It also requires increasing the resilience of the EU ETS in the 
light of large-scale events that may severely disturb the supply-demand balance. 

3. 

OPTIONS 

In November 2012, the Commission set out a non-exhaustive list of six options for structural 
measures  in  the  Carbon  Market  Report.  The  impact  assessment  on  the  2030  climate  and 
energy  framework  includes  a  general  assessment  of  the  impacts  of  those  options  that 
realistically do not have the potential to restore the balance between supply and demand in the 
short-term,  but  would  only  have  an  impact  in  the  context  of  the  2030  framework  (early 
revision of the linear reduction factor, extension of the scope of the EU ETS to other sectors 
and using access to international credits). The option of increasing the target is excluded from 
the  focus  of  the  2030  impact  assessment  based  on  stakeholder  feedback.  During  the  public 
consultation  on  the  structural  measures,  an  additional  option  –  to  establish  a  reserve 

3 
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COM(2012) 652 
In the context of carbon markets, this refers to the optimal balance between the carbon price signal and 
low-carbon investment that is needed now, and those that will be needed in the future.  

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mechanism to render the auction supply of emission allowances more flexible – has emerged 
from the discussion.  

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Table 1: Comparison of the options from the Carbon Market Report 

a) Increasing the 
EU reduction 
target to 30% in 
2020  

b) Retiring a 
number of 
allowances in 
phase 3 

c) Early revision 
of the annual 
linear reduction 
factor 

d) Extension of 
the scope of the 
EU ETS to other 
sectors 

e) Use access to 
international 
credits 

Stakeholder views* 

Potential effectiveness in improving the functioning 
of the European  carbon market in phase 3 

Very limited support 

Not focus of the assessment  

Would  have  been  accompanied  by  a  reduction  of 
auction supply over phase 3 by some 1.4 bn allowances. 
This  might  have  the  potential  to  improve  market 
functioning in the short-term  

Reference  emission  projections  for  2020  actually 
already come very close to levels associated with a 30% 
reduction  target.  This  means  that  while  the  EU  might 
not  be  ready  to  increase  its  target  to  30%,  the  full 
achievement  of  other  agreed 
targets  can  reduce 
emissions in the EU to the level in line with what would 
be required to achieve a step up to a 30% target 

Retiring  a  number  of  allowances  early  on  has  the 
potential 
improve  market 
functioning in the short-term 

to  create  scarcity  and 

Limited  potential  to  improve  market  functioning  the 
short-term 

But expected to have a positive impact in the mid- and 
long-term 

Medium support 

Medium support 

Limited support (for 
phase 3) 

Limited  potential  to  improve  market  functioning  in 
phase the short-term 

Assessment  of  administrative  challenges  and  potential 
to improve market functioning as of phase 4 needs to be 
further investigated 

But potential other benefits, e.g. in terms of technology-
neutral incentives across sectors 

Limited support (for 
phase 3) 

Very  limited  potential  to  sufficiently  improve  market 
functioning in the short-term  

Aggregate surrender of international credits has already 
used  up  more  than  two  thirds  of  the  amount  allowed 
until 2020 

f) Discretionary 
price management 
mechanisms 

Very limited support 
for a mechanism 
focused on price 

Not focus of the assessment 

EU ETS is an instrument based on volume not price 

Additional option  Medium support for a 

mechanism focused 
on (auction) supply to 
address market 
imbalance   

Potential  to  improve  market  functioning  in  the  short-
term 

Most  useful  and  simplest  mechanism  expected  to  be  a 
reserve of allowances 

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Accordingly, the focus of this assessment is on the three options, and several sub-options, that 
could realistically be implemented, and already restore the orderly functioning of the EU ETS 
in the short-term: 

• 

• 

• 

Option 1: Retirement of a number of allowances in phase 3; 

Option  2:  More  flexible  auction  supply  in  the  form  of  a  market  stability  reserve 
(additional option building on a variant of option of discretionary price management 
mechanisms from the Carbon Market Report). 

Option 3: Combination of a market stability reserve with the retirement of a number 
of allowances in phase 3 

3.1. 

Sub-options for a permanent retirement 

For  the  purpose  of  this  assessment,  in  the  light  of  the  current  surplus  and  its  expected 
evolution,  a  larger  upper  limit  of  1400  million  allowances  is  put  on  the  number  of  retired 
allowances.  

Of course other amounts of retired allowances could be conceived. As a sensitivity analysis, 
another sub-option with a lower amount of 500 million allowances is assessed (option 1b). 

3.2. 

Sub-options for a market stability reserve 

A market stability reserve would, in principle, function by:   

• 

• 

Adding  allowances  to  the  reserve  by  deducting  them  from  future  auction  volumes 
with the aim of mitigating market instability due to a large temporary surplus in the 
EU ETS; 

Releasing  allowances  from  the  reserve  and  adding  them  to  future  auction  volumes 
with the aim of mitigating market instability due to a large temporary deficit in the 
EU ETS. 

A  market  stability  reserve,  as  a  rule-based  mechanism,  would  only  change  the  timing  of 
auction  volumes.  It  would  not  affect  the  level  or  timing  of  free  allocation.  It  would 
furthermore be "cap-neutral" and not lead to a change of the environmental ambition level. 

Based on the pre-assessment of the various design aspects, several sub-options relating to the 
decisive factors for adding to or releasing allowances from the reserve (triggers) as well as the 
size  of  the  adjustment  are  assessed  in  terms  of  impact  on  the  market  imbalance.  Other 
combinations of elements would also be possible.   

Table 2: Sub-options for a market stability reserve 

Description 

Option  Trigger 

Adjustment amount 

Relative narrow 
band & unlimited 

Relative narrow 
band & limited 

Absolute broad 
band & unlimited 

Absolute broad 
band & limited 

2a 

Total surplus outside 40-50% of the cap 

2b 

Total surplus outside 40-50% of the cap  

2c 

2d 

Total surplus outside 400-1000 mio 
allowances 

Total surplus outside 400-1000 mio 
allowances 

Distance from the 
band/unlimited 

Limit of 100 mio 
allowances 

Distance from the 
band/unlimited 

10% of cumulative 
surplus/instalment of 
100 mio allowances 

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Annual change & 
unlimited 

Annual change & 
limited 

2e 

2f 

Annual change in surplus >100 mio 
allowances 

Annual change in surplus >100 mio 
allowances 

GDP 

2g 

GDP growth forecast outside 2-3% 

Unlimited/ surplus 
change above 100 mio 
allowances 

50% of the surplus 
change above 100 mio 
allowances 

Instalments of 200 mio 
allowances 

The  majority  of  the  sub-options  focus  on  surplus-based  triggers.  They  have  the  important 
benefit of being able to account for the impact of complementary policies, such as renewables 
and energy efficiency measures. Considering stakeholder views on the importance to maintain 
the nature of the EU ETS as a quantity-based instrument, where the carbon price signal is not 
fixed by policy-makers but revealed by the market, price-based triggers are not in the focus of 
this assessment.   

The  first  set  of  sub-options  focuses  on  the  surplus-based  triggers  (options  2a-2f),  either  in 
relation  to  the  cumulative  surplus  or  change  in  the  surplus.  The  mechanism  would  aim  to 
maintain the surplus within a pre-defined target range (band). As views on the optimal values 
for the triggers are not yet conclusive, different levels of the surplus band are chosen in a way 
to allow for sensitivity analysis in terms of impacts of different levels and widths of the band. 
In  general,  two  variants  are  assessed,  one  where  there  is  some  kind  of  a  safeguard  to  avoid 
large changes in the auction supply (either in form of a limit on the size of the adjustment or 
the  adjustment  defined  as  a  percentage  of  the  cumulative  surplus),  and  one  with  unlimited 
adjustments.  

One option looks at a reserve with an external indicator-based trigger, more specifically based 
on  the  GDP  growth  forecasts  published  in  the  European  Economic  Forecast  –  autumn 
editions.  As  the  band  is  not  directly  expressed  in  emission  allowances,  external  indicator-
based triggers in any case require an additional step of determining the amount of allowances 
placed  into  /  released  from  the  reserve.  Given  the  difficulties  of  precisely  translating  the 
relation  between  the  unit  of  GDP  growth  into  a  number  of  allowances,  the  external-based 
indicator trigger is only assessed in combination with pre-determined adjustment amounts of 
200 million allowances. 

3.3. 

Sub-options  for  a  combination  of  a  market  stability  reserve  and  permanent 
retirement 

For ease of comparison, the same amount is used for the permanent retirement part as under 
option 1b – 500 million allowances. Regarding the design of the market stability reserve part, 
there  it  is  based  on  the  central  option(s)  that  appears  from  the  pre-assessment  of  different 
market  stability  reserve  sub-options,  i.e.  one  without  a  broad  absolute  band  and  the  annual 
adjustment putting allowances into the reserve defined as a share of the cumulative surplus.   

4. 

ANALYSIS OF IMPACTS 

4.1.  Market balance 

It is assessed whether the permanent retirement and market stability reserve options address 
the existing problem of the large market imbalance. In case of the market stability reserve, it 
is  also  assessed,  using  phase  2  (2008-2012)  data,  whether  the  various  options  would  have 
prevented the problem if they had already been implemented in phase 2. 

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Permanent retirement: 

• 

• 

The  large  permanent  retirement  (option  1a)  is  expected  to  reduce  the  market 
imbalance early on, without a rebound in the surplus later on in phase 3. This appears 
to be more consistent with the objective of inter-temporal efficiency than the baseline 
option 0.   

Lowering the amount of permanent retirement to 500 million allowances (option 1b) 
would  correspondingly  decrease  the  stabilising  impact  of  the  measure,  with  a 
rebound in the surplus later on in phase 3, with a more limited improvement in inter-
temporal efficiency than a large retirement. 

Market stability reserve: 

• 

• 

• 

• 

• 

• 

There  is  a  difference  between  the  ability  of  various  sub-options  to  prevent  a  large 
surplus from accumulating and to address it once it has already built-up (see Error! 
Reference  source  not  found.).  Certain  sub-options  would  have  prevented  the 
problem to a different degree than others. However, all sub-options are expected to 
address the problem, albeit with different speeds.  

Surplus-based triggers are more efficient than GDP-based ones as regards capturing 
changes  in  demand  not  only  due  to  macroeconomic  changes,  but  also  due  to  other 
factors that may affect demand, such as the impact of complementary policies. They 
also better capture supply side factors such as changes in the inflow of international 
credits.  

Comparing the different surplus-based triggers, those based on a cumulative surplus 
are expected to perform better than those based on annual changes in the surplus in 
the situation where the market balance has already been improved by back-loading. 
While triggers based on changes in the balance may be more effective in avoiding a 
market  imbalance,  they  do  not  lead  to  further  reductions  in  the  surplus  after  the 
market is no longer in balance. 

Surplus-based  triggers  with  an  absolute  band  score  better  in  relation  to  simplicity. 
Moreover,  a  relative  band  which  tapers  off  in  line  with  the  decreasing  cap  may 
perform badly if the trend in hedging needs increased.  

A broader band is expected to lead to lower amounts and frequency of adjustments as 
well as lower variability in auction volumes. In contrast, a narrower band is likely to 
lead  to  a  larger  number  of  interventions  and  in  both  directions,  i.e.  a  number  of 
adjustments putting allowances into the market stability reserve only to be followed 
by release of those allowances shortly thereafter.  

Limited  adjustments,  either  with  an  explicit  limit  on  the  amount  of  adjustment  or 
determined  as  a  certain  percentage  of  the  cumulative  surplus,  get  a  better  score  in 
terms of predictability. They also lead to  more continuity in terms of auctions, and 
gradual changes to both the surplus and market stability reserve. However, unlimited 
adjustments  get  a  better  score  in  terms  of  flexibility  in  addressing  large  and  rapid 
fluctuations  in  the  market  balance  and  generally  restore  the  market  balance  more 
swiftly.  However,  in  situations  with  a  large  surplus,  as  the  market  is  expected  to 
experience by the end of phase 3, they may lead to no auction supply coming to the 
market for several years. 

Figure  2:  Evolution  of  the  surplus  under  various  sub-options  for  a  permanent  retirement  and  market 
stability reserve if implemented in phase 4 

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For ease of comparison, not all the options for a market stability reserve are taken forward for 
further analysis. Considering a combination of criteria, it is proposed to take option 2d (with 
volume  triggers,  with  a  broad  absolute  surplus  range  between  400  and  1000  million 
allowances  and  annual  adjustment  putting  allowances  into  a  reserve  defined  as  10%  of  the 
cumulative surplus) as the central option for the market stability reserve to be assessed further 
in terms of impacts other than on market balance and compared to the permanent retirement 
options. This option has an important advantage in terms of simplicity. While it may not fully 
address the market imbalance in phase 3, it starts doing so at the beginning of phase 4. 

This sub-option also forms the market stability reserve part for the option for a combination 
of a market stability reserve with permanent retirement: 

• 

While  the  option  leads  to  a  rebound  in  the  surplus  at  the  end  of  phase  3,  it  does 
reduce  it  compared  to  the  baseline  option  0.  It  also  keeps  gradually  decreasing  the 
surplus in phase 4. It seems to be more consistent with the objective of inter-temporal 
efficiency than the baseline option 0.   

4.2. 

Potential impact on carbon price formation 

In  a  situation  without  back-loading  and  any  structural  measures,  the  carbon  price  in  the 
reference  scenario  used  for  the  impact  assessment  of  the  2030  climate  and  energy  policy 
in 2020, while the surplus of allowances is 
framework is expected to be €5 in 2015 and €10 
projected  to  continue  to  grow  to  above  2.5  billion  allowances  in  2020  and  only  gradually 
decrease afterwards. With back-loading of 900 million allowances (baseline option 0) being 
implemented  in  phase  3,  prices  should  in  principle  not  increase  significantly  above  these 
projections, if the remaining surplus in the relevant period is large enough.  

In  terms  of  a  large  retirement  (option  1a),  the  impact  on  the  carbon  price  would  be  at  least 
similar to back-loading in the early years of phase 3, but without a price rebound as of 2019. 
If  a  permanent  retirement  only  reduced  the  projected  surplus  to  a  limited  extent,  by  500 
million allowances (option 1b), impacts on prices are expected to be correspondingly limited.  

Prices  can  increase  when  a  market  stability  reserve  builds  up.  Once  it  is  in  place  and  the 
market is more balanced, prices should be more strongly driven by the decreasing mid- and 
long-term cap. When allowances are released from the reserve, prices can decline in relative 
terms. Any reserve that reduces the surplus to a level that supports the orderly functioning of 

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the carbon market, would thus rather support the gradual transition to lower emissions, also in 
case of a higher ambition in the EU ETS in the context of a 2030 framework. This is expected 
to reduce the risk of too little low-carbon investment in the short term which increases costs in 
the mid- and long-term. However, a detailed assessment of the annual magnitude of the price 
impacts of a market stability reserve cannot be made for a number of reasons5. 

Prices are expected to increase in relative terms towards the end of phase 3 due to a combined 
effect  of  a  market  stability  reserve  complemented  with  the  permanent  retirement  of  500 
million allowances. Hence, this is expected to provide more support than solely a permanent 
retirement of the same amount would (option 1b). It is also likely to have a higher impact than 
a  similar  market  stability  reserve  alone  would  (e.g.  option  2d).  However,  the  option  would 
still result in some rebound of the surplus at the end of phase 3 and hence have less of a price 
impact than the large permanent retirement (option 1a). 

4.3. 

Competitiveness impacts 

Not strengthening the EU ETS in the short-term would in the longer term have an impact on 
the EU’s competitiveness. The unrepresentatively weak carbon price signal that the EU ETS 
has provided recently and that may remain at a fairly low level well into phase 4, would have 
adverse effects on investment and innovation of low-carbon technologies. It would also lead 
to  a  disintegrated  EU  energy  and  climate  policy,  and  an  increasingly  fragmented  internal 
market.  The  stronger  the  carbon  price  signal  in  the  short  term,  the  smaller  these  negative 
consequences should be. 

In  terms  of  possible  short-term  direct  cost  for  the  energy-intensive  sectors  deemed  to  be 
exposed to a risk of carbon leakage, it is to be noted that the verified emissions data for phase 
2  show  in  aggregate  a  surplus  of  free  allowances  in  relation  to  emissions  reported  from 
industrial  sectors  (excluding  the  power  sector)  of  more  than  34%  or  around  895  million 
allowances6. This is an estimate for industry as a whole, obviously with potential variations 
between sectors and installations. If emissions in phase 3 were similar to those in any year of 
phase 2, except for 2008, then continued free allocation is still expected to result in a surplus 
over phase 3 taking into account the existing surplus from phase 2.  

If emissions were to be similar as in 2005 or 2008, then continued free allocation in addition 
to the existing surplus would not be sufficient to cover all industry needs, which would partly 
need to be covered by buying extra allowances on the market. In this case, industry could see 
increased cost in phase 3 due to a structural measure for purchasing allowances. 

In relation to possible short-term increases in electricity cost due to the EU ETS (indirect cost) 
every  €1  increase  in  the  carbon  pr ice  may  on  average  translate  into  an  increase  of  0.8% 
compared  to  the  current  price  for  industry7.  These  figures  do  not  take  into  account  the 
expected  lower  cost  pass-through  in  the  Member  States  applying  the  derogation  allowing 
transitional  free  allocation  for  the  modernisation  of  electricity  generation,  or  the  decreasing 
importance of fossil fuel-based plants in electricity price setting due to a robust carbon price.   

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the 

see 

information 

chapter  4.1  of 

For  more 
http://ec.europa.eu/clima/policies/ets/cap/auctioning/docs/swd_2012_xx2_en.pdf  
Some  of  this  surplus  may  have  already  been  sold  by  industry,  in  which  case  the  value  of  those 
allowances  for  industry  would  not  be  lost  but  now  arise  in  the  form  of  money.  Data  includes  all 
stationary  installations  reported  in  the  European  Union  Transaction  Log  (EUTL)  that  do  not  have  as 
activity code "combustion".  
Ranging  from  0.4%-1.7%  at  Member  State  level.  Based  on  a  simple  average  of  increases  for  EU 
Member States, hence not weighted average. 

assessment  on  backloading: 

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4.4. 

Social impacts 

A  €1  increase  in  the  carbon  price  could  on  aver age  translate  into  an  increase  of  0.5% 
compared to the current price for households8. Decarbonisation policies also reduce emissions 
of PM2.5, SO2 and NOx. Through a more stable carbon price signal, a carbon market can have 
positive  health  impacts  by  in  short-term  by  improving  air  quality  through  encouraging  fuel 
switching from coal to gas and in the mid- and long-term by discouraging financing new coal 
facilities. Revenues from the auctions may increase and can be used to cushion adverse social 
impacts.  The  2030  impact  assessment  shows  that  when  auction  revenue  are  recycled  and  if 
carbon  pricing  extended  to  all  sectors,  decarbonisation  policies  can  lead  to  an  increase  in 
employment  of  0.2%  or  430.000  net  jobs  created  by  2030.  The  higher  the  impact  on  the 
carbon price signal, the higher these impacts are expected to be. 

4.5. 

Environmental impacts 

The environmental impact of the EU ETS in terms of emissions in the sectors covered over a 
certain  period  of  time  is  determined  by  the  cap.  As  the  options  that  entail  a  permanent 
retirement (1a, 1b, 3a and 3b) would imply a change of the cap for phase 3, they have more 
positive impacts in terms of emission reductions than the market stability reserve options.  

8 

Ranging  from  0.2%-1.3%  at  Member  State  level.  Based  on  a  simple  average  of  increases  for  EU 
Member States, hence not weighted average.  

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