Legal impact of carbon pricing in Australia Sep11

7/29/2019 Legal impact of carbon pricing in Australia Sep11

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Environment & Environmental Markets Australia

Australian Government'sProposed Carbon Pricing

Mechanism Martijn Wilder Partner +61 2 8922 [email protected]

A guide to the Clean Energy Bills Paul Curnow Partner

+61 2 8922 [email protected]

Andrew Beatty Partner +61 2 8922 [email protected]


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Contents1. Scheme Overview 1

2. Scheme Coverage 2 2.1 Included and Excluded Sectors 2 2.2 Treatment of transport 3

3. Who is liable and can liability be transferred? 5

3.1 Liable entities 5 3.2 Natural gas 6 3.3 OTNs 6 3.4 Joint Ventures 7 3.5 Liability transfer 8

4. Carbon units 10 4.1 Characterisation of carbon units 13 4.2 Treatment of Carbon Units 14

5. What is a liable entity's surrender obligation? 15 5.1 Timing for compliance 15 5.2 Unit shortfall charges 15

6. How does the scheme work in the fixed price period? 17 6.1 Starting price and the fixed price period 17 6.2 Free allocation of units 18

7. How does the scheme work in the flexible price period? 19 7.1 Transition arrangements and setting pollution caps 19 7.2 Flexible price architecture price ceilings and floors 20 7.3 Flexible price architecture Banking and Borrowing 20 7.4 Flexible price architecture Auctioning 21

8. Access to domestic and international offsets 22 8.1 Carbon Farming Initiative eligibility 22 8.2 International linking 23

9.

Tax treatment 25

9.1 Tax treatment 25

10. What assistance is available to industry? 27 10.1 Industry assistance EITEs 27 10.2 Industry assistance electricity generation 29 10.3 Additional sector-specific industry assistance not agreed by

the MPCCC steel and coal 30

11.

Governance of the Scheme 31

11.1 General governance 31 11.2 Authority 31 11.3 Regulator 32 11.4 Information Gathering & Monitoring Powers and

Requirement to be Notified 33 11.5 Land Sector Carbon and Biodiversity Board 33 11.6 Penalties for Non-compliance 33 11.7 Administrative Review 34

12. Other assistance packages 35 12.1 Key transitional support to business 35 12.2 Key energy efficiency measures 36 12.3 Other initiatives 36

13. Key compliance dates in fixed price and flexible price periods 38

bakermckenzie.com The Australian Government's Proposed Carbon Pricing Mechanism Baker & McKenzie | 1


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Feature Key policy element Legislation Analysis

Adjustments to fuel tax credits and excise will be annualduring the fixed price phase and every six months (basedon the average carbon price over the previous six months)during the flexible price phase. The ProductivityCommission will undertake a review of fuel tax credit andexcise mechanism to asses its effectiveness, however, nodate has been set for such a review.



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3. Who is liable and can liability be transferred?Feature Key policy element Legislation Analysis

For most sectors, the liable entity for emissionsfrom a facility will be the person with operationalcontrol over that facility.

Clean Energy Bill: Part 3 Division 2

A person who had operational control of afacility which passes the threshold test in aneligible financial year shall be the liable entity(s.20).

3.1Liableentities

Designated joint ventures and facilities where aliability transfer certificate is in force are exempt(and liability is addressed separately seeTable 3.4 ).

As noted, the liable entity for emissions from a facility willgenerally be the person with "operational control" over that facility.

This is a departure from the CPRS where liability sat withthe controlling corporation. The previous CPRS positionhad been criticised by a number of stakeholders as it didnot adequately address concerns raised about the abilityof subsidiaries and unincorporated joint ventures thathave operation control of facilities to pass through carboncosts under their supply contract. Most supply contractsare with the operator of the facility rather than itscontrolling corporation. This change helps to enable amore efficient and effective pass through of carbon liability

in contracts (as the controlling entity will not need to be aparty to the contract).

Under the CPRS, there was some criticism fromstakeholders that the legislation did not clarify whereexactly in the supply chain the carbon cost would sit (i.e.CPRS legislation did not set out the specificcircumstances where the costs could be passed through).The Government has not changed this key policy positionin the design of the Scheme, such that stakeholders will

need to continue to rely on the terms of existing supplycontracts to determine which party bears the carboncosts. This is a particular issue for existing supplycontracts that do not include a carbon pass throughmechanism or other trigger for price review (i.e. change of law).



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Feature Key policy element Legislation AnalysisA liability transfer certificate issued remains inforce indefinitely (s.88(3)). However, acertificate may be surrendered with the writtenconsent of the Regulator (s.89) or cancelled bythe Regulator (s.90).

If a declaration is in force regarding a liabilitytransfer certificate, a person who has consented

to the making of the application for thecertificate is taken to have guaranteed paymentof the unit shortfall charge and any penaltyamount (s.138)



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4. Carbon unitsSummary

Name Source Use in fixed price period Use in flexible price period

CU

Carbon Unit(also known as an EligibleEmissions Unit)

Clean Energy Bill (s.94) 100% use for compliance liability.

Freely allocated to liable entitieseligible under the Jobs andCompetitiveness Program; or Part 8 of the Bill (coal-fired electricitygeneration).

If no free allocation then mustpurchase from the Regulator at thefixed charge rate.

No trading or banking of units as unitsautomatically surrendered uponpurchase.

100% use for compliance liability (subject to availabilityof units under the cap).

May be purchased at auction.

Freely allocated to liable entities eligible under the Jobsand Competitiveness Program; or Part 8 of the Bill (coal-fired electricity generation).

Subject to a price ceiling and price floor in the first threeyears of the flexible price period.

Unlimited banking allowed.

Limited borrowing allowed: in any particular complianceyear, surrender of carbon units from the followingvintage year to discharge up to 5% of liability.

Kyoto ACCU

Australian Carbon CreditUnit (Kyoto-consistent)

CFI Carbon Credits (CarbonFarming Initiative) Bill (s.5)

See Eligible ACCU below. See Eligible ACCU below.

Non-Kyoto ACCU

Australian Carbon CreditUnit (non Kyoto-consistent)

CFI Carbon Credits (CarbonFarming Initiative) Bill (s.5)

Not able to be surrendered to acquitcompliance liabilities unless wouldotherwise have been issued as aKyoto ACCU, in which case subject torestriction below.

May be sold to the Government's landmanagement fund.

Not able to be surrendered to acquit complianceliabilities unless would otherwise have been issued as aKyoto ACCU, in which case subject to restriction below.

May be sold to the Government's land managementfund.



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Name Use in fixed price period Use in flexible price period

Eligible ACCU

Eligible Australian CarbonCredit Unit

(also known as an EligibleEmissions Unit)

Clean Energy Bill (s.5)

Kyoto ACCU

non-Kyoto ACCU that wouldhave otherwise been issued asKyoto ACCUs

ACCUs specified in theRegulation (can be convertedinto Assigned Amount Units)

Eligible for surrender to acquit up to5% of compliance liability.

No limitation of banking.

Can be converted to an RMU / AAUfor export during Kyoto Protocol's firstcommitment period.

Eligible for surrender to acquit up to 100% of complianceliability.

Not subject to floor price or floor cap.

Eligible InternationalEmissions Unit

(also known as an EligibleEmissions Unit)

CFI Australian National Registryof Emissions Units Bill (s.4) /Kyoto Rules

a CER (other than a temporarycertified emission reduction or a

long-term certified emissionreduction or generated inrespect of an excluded emissionreduction project type, e.g. HFC-23)

an Emission Reduction Unit(ERU)

a Removal Unit (RMU)

a prescribed unit issued inaccordance with the KyotoRules

a non-Kyoto InternationalEmissions Unit (e.g. fromanother ETS)

0% use for compliance liability. Eligible for surrender to acquit up to 50% of complianceliability.

If acquired CERs or ERUs issued prior to 31 December 2012 can be carried over subject to Kyoto Protocollimitations.



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Name Source Use in fixed price period Use in flexible price period

CER

Certified EmissionReduction

CFI Australian National Registryof Emissions Units Bill / KyotoRules

Clean Energy Bill (s.123)

Not able to be surrendered to acquitcompliance liability.

Eligible for surrender to acquit up to 50% of complianceliability subject to qualitative restrictions provided for inregulations.

Subject to a price ceiling and price floor in the first threeyears of the flexible price period.

ERU

Emission Reduction Unit(being a unit issued from aJoint ImplementationProjects)




RMU

Removal Unit (being aunit issued by an Annex IParty with respect tosequestration from land use,land use change andforestry activities)






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4.1Characterisation of carbon units

The domestic unit for compliance with theScheme will be the carbon unit.

Clean Energy Bill: Part 4

The Regulator shall issue carbon units onbehalf of the Commonwealth (s.94).

Each carbon unit shall have a uniqueidentification number and will have a vintage

year (for each financial year) (ss.95-96).Carbon units of a particular vintage may beissued at any time before 1 February of the year following the vintage year (s.97).

Carbon units shall be issued into the Registryaccount kept by the person purchasing or otherwise entitled to the unit (s.98).

The Regulator must not issue a carbon unitother than as a result of an auction; or theprovisions of s.100 which provides the fixedcharge units; or the Jobs and CompetitivenessProgram; or Part 8 of the Bill (coal-firedelectricity generation) (s.99).

The charge for units of a particular vintage year is specified in s.100 of the Bill.

The Regulator must ensure that the total

number of units with a particular vintage year that are auctioned or freely allocated equals thecarbon pollution cap for that vintage year (s.102)

The total number of carbon units allocated for free or atauction during the flexible price period will be equal to thepollution cap. This means that any units from the CFI or eligible international units imported will be in addition tothe cap.

All liable entities and auction participants must have anaccount in the Registry, in which Kyoto units and

Australian emissions units will be held.

Legislative backing for the National Registry of EmissionsUnits (Registry) is provided in the Australian NationalRegistry of Emissions Units Bill 2011. The mechanicaldetails about account opening procedures and unittransfers will be contained in regulations.



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Feature Key policy element Legislation AnalysisUnit shortfall calculations for the fixed priceperiod are provided for under ss.128 -132 of theBill; and for the flexible charge year under s.133of the Bill.If a person has a unit shortfall under s.125 for afixed price year, the unit shortfall charge is dueand payable 5 business days after 15 June inthe fixed charge year.

If a person has a unit shortfall under s.128 or 129 for a fixed price year, or s.133 for a flexibleyear, the unit shortfall charge is due andpayable 5 business days after 1 February nextfollowing the fixed charge year.If a unit shortfall charge payable remains unpaidafter the time it was due and payable, a penalty,calculated at the rate of 20% or such other amount prescribed by the regulations, will beapplied to the amount (s.135) unless theRegulator uses its discretion to remit a portionof the shortfall charge (s.134A)..The Regulator will have discretion to remit thewhole or any part of a penalty amount if satisfied that the person did not contribute to thedelay in payment and had taken reasonablesteps to mitigate the cause of the delay.(s.135(2).)A penalty amount (of a kind specified by the

regulations) may be set off against an amountowed by the Commonwealth to the person(s.137).The Regulator may extend the surrender deadline in circumstances where there havebeen malfunctions in the Registry computer systems or other telecommunications facilityservices (s.142).



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6. How does the scheme work in the fixed price period?Feature Key policy element Legislation Analysis

6.1Startingprice and thefixed priceperiod

During the fixed price period the carbon price willstart at $23 p/tonne and increase by 2.5% eachyear to $24.15 in 2013-14 and to $25.40 in 2014-15.

Liable entities may purchase carbon units fromthe Government at the fixed price, up to thenumber of their emissions each complianceyear (being 1 July to 30 June).

Any carbon units purchased at the fixed price willbe automatically surrendered and cannot betraded or banked for future use.

Clean Energy Bill: Part 4

When making an application for carbon units inaccordance with s.100 the number of carbonunits requested must not exceed the person's

total interim or final emissions number for thevintage year less the total number of eligibleemissions units surrendered by that person for the vintage year.

Carbon units issued in accordance with s.100will be automatically surrendered.

During the fixed price period, liable entities will need tosatisfy their compliance obligations by either purchasingcarbon units (for immediate surrender) from theGovernment at the fixed price in each compliance year, or surrendering domestic ACCUs created from eligible offsetprojects under the CFI.

The 5% limitation on the use of Kyoto-compliant ACCUsto meet liabilities during the fixed price period (seeTable 8.1 ) effectively means that during this period thefixed price will also become an effective price cap for Kyoto-compliant ACCUs.

Carbon permit prices are still likely to set prices for Kyoto-compliant ACCUs and international credits during flexible

price period despite unlimited use of Kyoto-compliant ACCUs and a 50% limitation on eligible international units(see Table 9). This is because traded volumes in carbonunits will be higher than traded volumes in Kyoto-compliant ACCUs and international credits traded into andwithin the Australian market.

Once the Scheme is legislated, it is expected that Schemeand other market participants will start to look at someforward purchasing of Kyoto-compliant ACCUs and

international credits (including CERs) ahead of surrender deadlines.



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6.2Freeallocation of units

Carbon units freely allocated may be either surrendered or traded until the true-up date for thecompliance year in which they were issued.They cannot be banked for use in a futurecompliance year.

The holders of freely allocated carbon units will beable to sell them to the Government from 1

September to 1 February of the followingcompliance year (at a slight discount to reflect thepresent market value).


Unused free carbon units issued in accordancewith the Jobs and Competitiveness Program or Part 8 of the Bill (coal-fired electricitygeneration) with a vintage year that is a fixedcharge year shall be cancelled if still in aRegistry account at 1 February of the year

following the vintage year for that carbon unit(s.115)

During the period 1 September in a vintage year until 1 February the year following the vintageyear, a person may request that the Regulator cancel free units in exchange for a buy-backamount. The buy-back amount is calculated byreference to the fixed charge for the vintageyear x factor specified in the regulations x the

number of units (s.116)

Under the Regulations applications for the allocation of free carbon units under the Jobs and CompetitivenessProgram must be made no later than 31 October in therelevant financial year. The Government has indicatedthat 75% of the allocations for direct emissions and all of the allocations for indirect emissions will be issued early inthe compliance year, likely prior to 1 September.

We note that once the units are issued into the Registryaccount of the holder they may be transferred inaccordance with the rules provided for under the

Australian National Register of Emissions Units Bill. Atthis stage, we are not aware of any restrictions on transfer (beyond limitations on use of units in subsequent vintageyears see Table 5.1 ).



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Feature Key policy element Legislation AnalysisUnder certain circumstances, a person's surplussurrender number may be reduced (133(8)).

7.4Flexiblepricearchitecture

Auctioning

Carbon units will be auctioned (with the exceptionof those that are freely allocated) by advanceauctioning of future vintage carbon units (with nodeferred payment arrangements).

There will be advance auctions of flexible pricecarbon units in the fixed price period.

There will be no double-sided auctions of carbonunits (i.e. liable entities who are over-allocatedcarbon units will not be able to sell them on themarket).

If carbon units are relinquished, the Regulator may, on behalf of the Commonwealth auction theunits.


Not more than 15 million carbon units will beissued with a particular vintage as a result of auctions if there are no regulations in effect that

declare the pollution cap (s.101).The Minister may, by legislative instrument,determine the policies, procedures and rulesthat apply in relation to the auctioning of carbonunits by the Regulator (s.113).

Units shall only be issued as a result of theauction process once the person has paid thecharge for the units or has lodged a deposit andtendered the balance of the total amount of thecharge (s.111).

Section 114 sets out the formula for establishingthe benchmark average auction charge for allauctions in a financial year and the last auctionfor a financial year.

Under the CPRS, monthly auctions were scheduled inrespect of carbon units for the current compliance year and the three subsequent years. Auctions were to beconducted on an "ascending clock" basis whereby biddersindicated the number of carbon units they were prepared

to purchase at the Government's published price and if demand exceeded supply, the auctioneer raised the pricein the next round where bidders resubmitted their bids(and the process continued until the number offered wasequal to or greater than demand, and bidders were to paythe price set at the previous round).

The government has not yet determined what method willbe adopted for the auctions or the frequency with which itwill hold auctions; however the Determination made under

s.113 is expected to address matters such as reserveprices, deposits, security, guarantees etc.



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Section 123 specifies the matters that theMinister may have regard to when making arecommendation to the Governor general torestrict the use of units including Australia'sinternational objectives ; internationalobligations; the environmental integrity of the

Act; reports from the ACA; and the extent towhich other international schemes such as theNZ ETS and the EU ETS restrict the use of those units,

The surrender limit for eligible internationalemission units (50%) is prescribed by s.133(7)of the Bill.

Purchasers will likely address this risk by seeking topurchase international units generated in respect of projectswith high environmental value, which will be less likely to bedisallowed, and otherwise manage this risk under forwardcontracts. Potential pricing issues relating to internationallinking are discussed in 'Starting price and the fixed priceperiod' above.)

Another issue relevant to pricing will be potentiallimitations in post-2012 CER supply. If the Governmentdoes elect to link the Scheme to other internationalschemes during the fixed price period, this may result inmarket distortions given that the largest scheme, the EUETS, which accounted for almost 85% of global tradingvalue in 2010 (World Bank, 2011), does not include fixedpricing.

Kyoto Protocol parties can carry over up to a maximum of 2.5% of CERs between Kyoto Protocol Commitmentperiods; this may make it possible to bank CERs after 2012.



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9. Tax treatmentFeature Key policy element Legislation Analysis

9.1Taxtreatment

The cost of a unit will be deductible, with thededuction effectively being deferred through therolling balance method until the unit is sold or surrendered. The proceeds of selling a unit will beassessable income on revenue account in theincome year the unit is sold. The legislationcontemplates carbon units being valued at marketvalue for taxation purposes for some internaltransfers, import and export of carbon units.

The legislation also provides that supplies of carbon units under the Scheme will be Goods andServices Tax (GST)-free. However, the normalGST rules will apply to transactions involvingfinancial derivatives of carbon units and thepayment of grants.

Other significant elements of tax treatment under the Scheme include:

Proceeds from selling units will be assessablein the year of sale.

Purchasers of units will be deemed to havereceived market value for a unit in certaincircumstances (e.g. transactions betweenrelated entities).

Company tax deductions will be allowed for thecost of acquiring units but the benefit of anysuch deductions will be deferred until the year inwhich the unit is surrendered or sold.

In relation to the valuation of units held at theend of financial years, unit holders of units willbe required to elect a valuation method from

Clean Energy (Consequential Amendments)Bill

Schedule 2 will amend the following taxationlegislation:

A New Tax System (Goods and ServicesTax) Act 1999 (s.38-590);

Income Tax Assessment Act 1936; and

Income Tax Assessment Act 1997 (notablyss.410-1, 420-15, 420-25, 420-42,Subdivision 420D).

The GST treatment of carbon units is consistent with theapproach adopted under the CPRS.

In relation to valuation methods, the default application of the cost valuation method has the potential to expose

some unit holders to the risk of fluctuations in marketprices.

Holders of units under the Scheme should carefullyconsider the taxation treatments of the units that they holdto ensure that the valuation method they select isappropriate to their circumstances.

We will release more detailed information on thetaxation treatment of carbon units under the Scheme .



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Feature Key policy element Legislation Analysiseither cost or market valuation methods. Thedefault method will be cost. Unit holders will beable to change valuation methodology onceduring the fixed charge period and will havelimited ability to change during flexible chargeyears.



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Feature Key policy element Legislation AnalysisThis assistance will decay at a rate of 1.3% per annum.

During the flexible price period, assistance will beprovided "early in each compliance year."

The Government will provide a buy-back facilityfor firms in receipt of free carbon units to sellthese carbon units back to the Government as

outlined above.Trade-exposure will be assessed throughquantitative and qualitative tests. Emissionsintensity assessment will be based on averageemissions per million dollars of revenue or emissions per million dollars of value added.

New entities conducting an existing EITE activitywill receive the same assistance as existing

entities conducting the same activity. Activitiesnew to Australia will be able to apply for EITEeligibility. Assessments and baselines will bemade on the basis of international best practiceemissions intensity. Allocations to existing entitiesconducting EITE activities will not be adjusted for allocations to new entrants.

Any changes to assistance arrangements that willhave a negative effect on business will not occur

before the sixth year of the carbon price. Threeyears notice will be provided for modifications toEITE allocations that will have a negative effect onbusiness.

Finally, the Legislative Package also includesfunding for structural adjustment innovation (seeTable 10.2 ).



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and Foundries Investment Program (3:1recipient / Government grant funding); and$200 million for the Clean TechnologyInnovation Program (matched funding).

$250 million over 6 years from 2010-11 toexpand the Low Carbon Communities program,including pilot energy efficiency projects for low-income households and additional support for local government and community organisationsto enhance energy efficiency.

The small business instant asset write-off threshold will be increased from $5,000 to$6,500 for depreciating assets (as defined in taxlegislation). It provides an immediate income taxdeduction for the costs of eligible assets.

12.2Key energyefficiencymeasures

Further development of the National EnergySavings Initiative (ESI) white certificate scheme.

Expansion of the Energy Efficiency Opportunitiesprogram to include energy generators,transmitters and distributors to incorporate over 60% of Australia's primary energy users, to beincreased to 65%.

The energy efficiency measures are not includedin the Legislative Package but the development of any ESI will likely be dealt with through COAG.

The measures will build on the support for tradeableenergy efficiency certificate schemes provided in the 2010"Report of the Prime Minister's Task Group on EnergyEfficiency" and the existing white certificate schemes inNew South Wales and Victoria.

It is important to note that any ESI will not beimplemented, and will not replace State and Territoryenergy efficiency schemes, without the agreement of theStates and Territories.

12.3Other initiatives

The Government has also announced thefollowing measures as part of the Schemepackage:

$946 million over six years from 2011-12 for the Biodiversity Fund, which will support therestoration and protection of biodiverse carbonstores.

The land sector programs are not included in theLegislative Package. Funding for these programswill be implemented through the budget process.

These measures will broaden the impact of the Schemeand will also make it more accessible.



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Feature Legislation Analysis

$200 million over seven years from 2012-13 tofacilitate structural adjustment in regionalareas;

a new national mandatory vehicle emissionsstandard for light duty vehicles up to 3.5tonnes, including passenger vehicles, sportsutility vehicles and light commercial vehicles.The Government has proposed that the

standard be 190g C02/km in emissions by2015 and 155g/km by 2024;

$44 million over five years from 2011-12 for the Regional NRM Planning and ClimateChange Fund, which will help regionalcommunities plan for the impacts of climatechange and maximise the benefits of carbonfarming projects; and

$22 million over five years from 2012-13 for the ongoing Indigenous Carbon Farming Fund,which will support Indigenous Australians toimplement carbon farming projects.



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13. Key compliance dates in fixed price and flexible price periods

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Legal impact of carbon pricing in Australia Sep11

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