RMIA Conference, November 2009

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THE IMPLICATIONS OF THE CARBON POLLUTION REDUCTION SCHEME FOR YOUR BUSINESS RMIA Conference, November 2009

AGENDA Now Important concepts Participating in the CPRS: compliance responsibilities Participating in the CPRS: transactional choices and risk management opportunities Participating in the CPRS: other management choices Participating in the CPRS: upstream and downstream issues This afternoon Developing organisational strategies: the make or buy choice 2

Classification of Greenhouse Gases IMPORTANT CONCEPTS Source: The Greenhouse Gas Protocol, A Corporate Accounting and Reporting Standard, World Resources Institute 3

Cap and Trade Schemes: Conceptual Government Revenue (to enable provision of Assistance) IMPORTANT CONCEPTS $ Carbon permit allocation Carbon permit trading Surrender permits = Annual emissions Penalty (and make good provisions) Total emission cap<bau Note: Permits grant the right to emit CO2 4

Australia s Greenhouse Gas Emissions by Sector IMPORTANT CONCEPTS Source: National Greenhouse Gas Inventory, Accounting for the Kyoto target, Australian Government Department of Climate Change May 2009 5

Compliance NGERS Registration Measurement Reporting & Assurance CPRS Measurement Report & Assurance Surrender Relinquish Significant holdings Transactional Purchasing strategy Auction participation Secondary market International Market Management approach Business unit/head entity: Liability Transfer Certificates Up/down stream: Obligation Transfer Number Requirements CPRS AND YOUR BUSINESS: NGERS COMPLIANCE 6

NGERS Scheme Timeline NATIONAL GREENHOUSE AND ENERGY REPORTING SYSTEM Source: :Australian Government Department of Climate Change 7

NGERS: Key Features National Greenhouse and Energy Reporting Act (NGER Act) came into effect September 2007 to develop a national consistent greenhouse gas (GHG) emissions, abatement actions and energy consumption and production reporting framework Establish an inventory of emissions, energy produced and energy consumed within Australia that will eventually underpin emissions trading scheme activity (CPRS) activity Reporting of Scope 1 and Scope 2 emissions will be mandatory for entities exceeding defined thresholds for energy production, energy consumption or GHG emission thresholds. Scope 3 reporting will be voluntary NGERS is expected to cover around 700 medium-sized and large facilities, of which an initial 300 400 reported for the first time in 2008/09 NATIONAL GREENHOUSE AND ENERGY REPORTING SYSTEM 8

Compliance NGERS Registration Measurement Reporting & Assurance CPRS Measurement Report & Assurance Surrender Relinquish Significant holdings Transactional Purchasing strategy Auction participation Secondary market International Market Management approach Business unit/head entity: Liability Transfer Certificates Up/down stream: Obligation Transfer Number Requirements CPRS AND YOUR BUSINESS: CPRS COMPLIANCE 9

CPRS: Key Features Who and what is covered? Six greenhouse gases included under the Kyoto Protocol Facilities that emit > 25,000 Tonnes CO2-e per annum included Stationary energy, industrial processes, transport, fugitive emissions, waste, forestry (opt-in) Agriculture excluded but may be included from 2016 subject to a review in 2013 Approximately 75% of Australia s emissions included How will permits be allocated? Through a combination of auctioning and free allocation to Emission Intensive Trade Exposed (EITE) and Coal Fired Electricity Generation. What is the point of obligation? Points of obligation are dependent upon the operations or composition of the industry and are either direct (at point of physical production of emissions), e.g. Stationary energy or indirect (applied at a point in the supply chain), e.g. transport CARBON POLLUTION REDUCTION SCHEME 10

CPRS: Key Features How is the Scheme linked internationally? Reductions from overseas Kyoto compliant projects Clean Development Mechanism (CDM) or Joint Implementation (JI) and permits bought from other schemes (e.g. EU ETS) are tradeable within the Australian CPRS. Australian Emission Units (AEU) are not tradeable in international carbon markets What price protection will be implemented? Initial price of $10 / Tonne CO2-e for first year A $40 / Tonne CO2-e price cap increasing by CPI + 5% for 5 years What assistance is available? Electricity Sector Adjustment Scheme free allocation of permits (approx $3.7billion) Free allocation of permits to certain industries (EITE) 90% free permits if emissions intensity > 2,000 tonnes C02-e / $m revenue or >6,000 tonnes CO2-e / $m value added 60% free permits if emissions intensity between 1,000 1,999 tonnes C02-e / $m revenue or 3,000 5,999 tonnes CO2-e / $m value added 8 eligible activities announced - production of carbon black, container glass, flat glass, methanol, newsprint, silicon, white titanium dioxide pigment and zinc CARBON POLLUTION REDUCTION SCHEME Direct and indirect assistance to low and middle income households Fuel excise reduction 11

CPRS: Key Features What grants and other funding is available for industry? Climate Change Action Fund for industries not entitled to free permit allocation (at corporate or individual level) What are the tax and accounting implications? Seeking fiscal neutrality and simple tax rules Mandatory assurance for large emitters How will the scheme be governed? An independent statutory regulator (Australian Climate Change Regulatory Authority) will be established to administer, oversee and regulate the scheme Parliament will set scheme caps and gateways CARBON POLLUTION REDUCTION SCHEME 12

CPRS - Compliance Obligations Register for NGER (mandatory or voluntary) Calculate annual emissions number Submit emissions reports Surrender emissions units Relinquish units (if required) Notify significant holdings Keep records Audit CARBON POLLUTION REDUCTION SCHEME 13

Compliance NGERS Registration Measurement Reporting & Assurance CPRS Measurement Report & Assurance Surrender Relinquish Significant holdings Transactional Purchasing strategy Auction participation Secondary market International Market Management approach Business unit/head entity: Liability Transfer Certificates Up/down stream: Obligation Transfer Number Requirements CPRS AND YOUR BUSINESS: CHOICES AND RISKS 14

Carbon Risk: Key Questions for Consideration What is our business as usual emission projection? How far can this be reduced to minimise exposure in the future? What measurement and management techniques do we develop? What is our marginal cost of abatement? Can we justify investing in low carbon technologies? What policy changes should we consider to manage our future exposure to carbon markets? How is our existing portfolio risk profile changed? How do we provide our shareholders with reassurance that the risk to return on their investment is minimised? CPRS AND YOUR BUSINESS: CHOICES AND RISKS 15

CPRS: Transactional Choices Auction participation and settlement How many certificates? At what price? How far into the future? Buy or sell? Secondary market participation How many certificates? At what price? How far into the future? What choices are available to manage the risks? International market participation Buy or sell? What kind of certificate? How many certificates? At what price? How far into the future? What choices are available to manage the risks? CPRS AND YOUR BUSINESS: CHOICES AND RISKS 16

Cost $ / t CO 2 e abated Marginal Abatement Cost Curve - Generic The fundamental question is do you buy permits or reduce emissions? Therefore you need to understand your carbon abatement costs. 30 20 F E 10 D C 0 B A -10 kt CO 2 e abated CPRS AND YOUR BUSINESS: CHOICES AND RISKS 17

Marginal Abatement Cost Curve - Australia CPRS AND YOUR BUSINESS: CHOICES AND RISKS Source: An Australian Cost Curve for Greenhouse Gas Reduction, McKinsey, February 2008. 18

VOLUME (million tonnes CO2) Price per tonne (EUR) European Carbon Futures Prices: Prices and Volumes 40 35 30 25 20 15 10 5 ECX EUA Futures Contracts: Price and Volume Total Volume Dec09 Sett 35 30 25 20 15 10 5 CPRS AND YOUR BUSINESS: CHOICES AND RISKS 0 0 Source: :European Climate Exchange 19

Australian Renewable Energy Certificates: Spot Prices CPRS AND YOUR BUSINESS: CHOICES AND RISKS Source: ASX Environmental Product Briefing, 16 October 2009 20

Global Carbon Market Comparison, 2007 v 2008 CPRS AND YOUR BUSINESS: CHOICES AND RISKS Source: World Bank 21

CPRS: The Valuation Task for Assessing Carbon Reduction Activities CPRS AND YOUR BUSINESS: CHOICES AND RISKS Source: Committee of Chief Risk Officers 22

Carbon Risk: Calculating the net gain or loss Category Negative Positive Indirect carbon costs Mainly electricity and fuel Pass cost increases through to consumers Direct carbon costs Operating costs Mitigation/Adaptation expenditure Net shareholder value Permit acquisition, voluntary offset acquisition, Penalties Carbon management costs Carbon derivative losses Operating costs Capital and R&D costs Disproportionate loss in asset value Carbon cost flow-through Sales of excess permits Sales of abatement credits Carbon derivative gains Cost reductions Free allocation of permits CPRS AND YOUR BUSINESS: CHOICES AND RISKS 23

Compliance NGERS Registration Measurement Reporting & Assurance Transactional Purchasing strategy Auction participation Secondary market International Market CPRS AND YOUR BUSINESS: IMPLICATIONS CPRS Measurement Report & Assurance Surrender Relinquish Significant holdings Management approach Business unit/head entity: Liability Transfer Certificates Up/down stream: Obligation Transfer Number Requirements 24

Now Important concepts Participating in the CPRS: compliance responsibilities Participating in the CPRS: transactional choices and risk management opportunities Participating in the CPRS: other management choices Participating in the CPRS: upstream and downstream issues This afternoon Developing organisational strategies: the make or buy choice ISSUES PARTICIPATING IN THE CPRS: UPSTREAM AND DOWNSTREAM 25

ASX 200 Carbon Intensity (tonnes CO2e / $m) ISSUES PARTICIPATING IN THE CPRS: UPSTREAM AND DOWNSTREAM Source: RepuTex, 2008 26

CDP 6 - Key Risks Identified Source: Carbon Disclosure Project Report 2008 Australia and New Zealand, Carbon Disclosure Project 27 ISSUES PARTICIPATING IN THE CPRS: UPSTREAM AND DOWNSTREAM

Business Response Framework: Carbon Management Activities R&D Energy Sourcing Upstream Procurement Energy Efficiency Manufacturing Carbon management activities Supply Chain Logistics & distribution Sales & marketing Product Opportunities Downstream End customer Behavioural Change Recycling Offsetting, Waste Management ISSUES PARTICIPATING IN THE CPRS: UPSTREAM AND DOWNSTREAM 28

Overall economic and cost impacts Assuming a permit price of $25 / Tonne CO2-e: Anticipated inflationary impact one off 1 1.5% increase in CPI Impact on electricity prices (pre allowance for assistance) 18 % average increase $4 - $5 / week impact on household Impact on gas prices (pre allowance for assistance) 12% average increase $2 / week impact on households (impact includes other gas and other fuels) ISSUES PARTICIPATING IN THE CPRS: UPSTREAM AND DOWNSTREAM 29

Carbon risk: Key Impact Points Operating Expenditure Permit costs Supply chain costs (electricity), fuel costs Abatement costs or savings Compliance costs (monitoring, verification, disclosure) Foreign exchange (via CER s) Capital Expenditure Emissions reductions technology (energy efficiency, fuel switch, investments etc) Location change Compliance costs Balance Sheet Physical weather exposure Asset base depreciation, underperformance M&A activity, transactions Litigation risk Market Elements Market risk (beta) Reputation & brand Revenue Sale of excess credits Consumer preferences CDM pipeline, portfolio, assets Foreign exchange (via CER s) ISSUES PARTICIPATING IN THE CPRS: UPSTREAM AND DOWNSTREAM 30

Business Impact Drivers Driver Emissions profile Transitional assistance Cap and permit allocation basis Complementary measures Market characteristics Strategy adopted Key factors Emissions level, emissions intensity, energy intensity Abatement costs and potential Relative competitiveness Level Duration Eligibility criteria Emissions cap and trajectory levels Permit price caps International linkages Tax rebates / grants / concessions Renewable energy targets Energy efficiency targets Pricing and volume impacts on major inputs and outputs Relative position - from adaptation and mitigation, through to trading ISSUES PARTICIPATING IN THE CPRS: UPSTREAM AND DOWNSTREAM 31

Patricia Boyce Peter Eben Director Director p> +613 9653 9460 p> +613 9653 9460 m> 0412 254 589 m> 0411 207 505 e> pboyce@seedadvisory.com.au e> peben@seedadvisory.com.au CONTACT DETAILS www.seedadvisory.com.au 32