Update on Cap and Trade Programs for and Presentations

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							             Update on
Cap and Trade Programs
   for SO2 and NOX
             Presentation for
     Environmental Markets Association
        11th Annual Fall Conference

           Clean Air Markets Division
     U.S. Environmental Protection Agency
           Office of Air and Radiation
               November 9, 2007
                     Coverage of ARP and NBP



                                                         NOx Budget Trading
                                                              Program (NBP)
                                                         covers ozone season
                                                   (summer) NOx emissions
                                                    in selected eastern states
                                                     for fossil-fuel generator
                                                        units (and other large
                                               stationary sources). There is
                                               also partial coverage of MO,
                                                         MI, and AL. Earlier
                                                        northeastern program
Acid Rain Program (ARP) covers fossil           replaced beginning in 2004.
generation annual SO2 emissions and NOx
emissions of coal-fired generators >
25MWe in contiguous U.S. (shown in blue
and red). Largest SO2 and NOx emitters
faced control in 1995 and 1996,
respectively; all others in program in 2000.
  CAIR Sets Stage for CAMR and CAVR

                                                                                                               CAIR Emission Caps*
                                                                                                                        (million tons)
                                                                                                                       2009/2010         2015

                                                                                               Annual SO2                  3.7           2.6
                                                                                               (2010)

                                                                                               Annual NOx                  1.5           1.3
                                                                                               (2009)

                                                                                               Seasonal NOx               .58            .48
                                                                                               (2009)

                                                                                                     *For the affected region.




                                                                                                            CAMR Emissions Caps
                                                                                                                     (tons)

                                                                                                                         2010            2018

                                                                                                Annual Mercury            38              15




States not covered by CAIR, which are covered by CAVR                                                             CAVR
States controlled for fine particles (annual SO2 and NOx)                                     Outside of CAIR Region – BART
States controlled for both fine particles (annual SO2 and NOx) and ozone (ozone season NOx)

States controlled for ozone (ozone season NOx)       Note: All States are covered by CAMR
SO2 Forecast with ARP and CAIR/CAMR/CAVR
                                                            Annual SO2 Emission (1,000 t/yr)




                         National Emissions of SO2
Thousand Tons




                10,000
                 8,000
                 6,000
                 4,000
                 2,000
                     0
                            2006     2010    2015    2020
                                         Year
                                      NOx Forecast with ARP, NBP, and
                                           CAIR/CAMR/CAVR
                                                           Annual NOX Emissions (1,000 t/yr)




                        National Emissions of NOX
Thousand Tons




                4,000
                3,000
                2,000
                1,000
                    0
                          2006     2010     2015    2020
                                       Year
 Where We Are on Implementation…
• CAIR State Implementation Plans
   – All States plan to utilize trading program
   – EPA is transferring NOX allowances into facility accounts this Fall
       • Allowances are already in for 3 states (IA, LA, TN)
       • As additional states are approved, allowances will be transferred
       • For a handful of States, EPA anticipates using the Federal Plan allocations
         (Final CAIR FIP NODA was published on Friday, November 2, 2007)

• CAIR Federal Plan (FP)
   – FP in effect June 2006
• Litigation
   – All briefs have been filed for CAIR, CAVR and CAMR
   – Oral arguments are not scheduled for CAIR or CAVR
   – CAMR oral arguments scheduled for December 6, 2007
       Advanced Pollution Controls for SO2 and NOX that Are Installed,
           Committed to, and Projected for Coal-fired Generation


                                                                                      Gigawatts
Gigawatts

 300                                                                                    300

 250            Projected
                  2020
                                                                                        250
                Projected                                                                                                                                   SCR &
 200              2015                    Projected                                     200                                                                Scrubber
                                            2020                    Projected                                                    SCR &
                                          Projected                   2020                                                      Scrubber
                                                                                                         SCR &
 150           Committed
                                            2015
                                                                   Projected
                                                                                        150             Scrubber
                                           Projected
               2007-2010                     2010                    2015
                                          Committed

 100                                      2007-2010
                                                                                        100                                       SCR
                                                                   Committed
                                                                                                          SCR                                               SCR
                                                                   2007-2010
  50           Installed by
                   2006                  Installed by                                     50            Scrubber                Scrubber                   Scrubber
                                            2006                  Installed by
                                                                      2006
   0                                                                                        0
              Scrubber                     SCR               SCR & Scrubber                         Total 2010               Total 2015              Total 2020

  The left bar graph provides the amount of coal-fired steam capacity that has either Scrubbers, SCRs, or both technologies in place by 2006 (from EPA’s
  NEEDs database 2007), committed to be operational from 2007-2010 (largely from 2007 survey results), and forecasted by EPA (using IPM) to be
  operating by the end of 2010, 2015, and 2020, respectively. In 2006, 2010, 2015, and 2020, the total coal-fired capacity is 318 GW, 320 GW, 335 GW
  and 373 GW, respectively. The right bar graph shows for 2010, 2015, and 2020 the amount of coal-fired steam capacity with Scrubbers, SCRs, or both
  controls. Both bar graphs included existing and new generation capacity. Virtually all coal-fired generation units have advanced particulate control
  systems. Some additional units will have SNCR controls and EPA expects virtually all of these units to have NOx combustion controls and the vast
  majority of the “nonscrubbed” units to use lower sulfur coals.
                                Private SO2 Allowance Transfers
Market is healthy based on volumes year-to-date – on track to approximate last year’s volume.
                                             Breakdown of Private SO2 Allowance Transfers 1994-2007*

                         25




                         20
                                                                           12.3
                                                                                         9.9
                                                                                                 9.8
                                                                                                                               12.9
  Allowances, Millions




                         15                                                                                            9.9

                                                                   12.5                                  8.4
                                                     7.3    4.0                                                 7.8
                         10           14.8

                                                                                                                                       13.9*
                                              3.8                          12.7          12.6
                                                                                                 11.6
                          5    8.3                          9.5                                                        10.0    9.5
                                                     7.9                                                 8.1    7.5
                                                                   6.2
                                              4.4
                                      1.9
                               0.9
                          0
                              1994   1995    1996   1997   1998   1999    2000          2001    2002    2003   2004   2005    2006    2007
                                                                                 Year
                                               Allowances Transfered Between Related Parties
                                               Allowances Transferred between Economically Distinct Parties
*Note: 2007 data includes all private allowance transfers from 1/1/2007 through 9/30/07. Classification not available
                            Historic Cumulative SO2 Transfers
                             Overall private transfers now top 350 million tons through Q3-07

                                        Cumulative Allowance Transfers 1994-2007*

                            400

                            350
SO2 Allowances (millions)




                                            EPA Transfers to Account
                            300
                                            Private Transfers
                            250

                            200

                            150

                            100

                             50

                              0
                              1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

                                                                    Year
                                  * Note: Data for 2007 includes tranfers through September 30, 2007.
                                 Historical Monthly SO2 Allowance
                                     Prices & Transfer Volume
December 2005 price spike was accompanied by low to moderate transfer volumes
                                                                   Average Monthly SO2 Allowance Price and Transfer Volume

                            $1,800                                                                                                                                                2.00

                            $1,600                                                                                                                                                1.80

                                                                                                                                                                                  1.60
                            $1,400




                                                                                                                                                                                         Transfer Volume (millions)
                                                                                                                                                                                  1.40
  Allowance price ($/ton)




                            $1,200
                                                                                                                                                                                  1.20
                            $1,000
                                                                                                                                                                                  1.00
                             $800
                                                                                                                                                                                  0.80
                             $600
                                                                                                                                                                                  0.60
                             $400
                                                                                                                                                                                  0.40

                             $200                                                                                                                                                 0.20

                               $0                                                                                                                                                 0.00
                                     Mar -94

                                               Mar -95

                                                         Mar -96

                                                                    Mar -97

                                                                              Mar -98

                                                                                        Mar -99

                                                                                                  Mar -00

                                                                                                            Mar -01

                                                                                                                      Mar -02

                                                                                                                                Mar -03

                                                                                                                                          Mar -04

                                                                                                                                                    Mar -05

                                                                                                                                                              Mar -06

                                                                                                                                                                        Mar -07
                               Daily SO2 Allowance Spot Price
                          A detailed look at the last 2½ years finds prices are down following the
                                     December 2005 price spike and relatively stable
                                                   Daily SO2 Allowance Spot Price for Promt Vintage
                                                           January 2005 - September 2007
                          $1,800

                          $1,600

                          $1,400
Price per Ton (dollars)




                          $1,200


                          $1,000

                           $800

                           $600


                           $400

                           $200


                             $0
                                  5




                                                                  6




                                                                                                    7
                               200




                                                               200




                                                                                                 200

                                                                            Date
                               Data based on Cantor-CO2e MPI
Forecasted & Actual SO2 Allowance Prices
       Current SO2 market compares favorably to forecast
EPA’s Forecast of Annual SO2 Allowance Price

                  Projected Price of an SO2 Allowance for CAIR Sources ($2006)

           1000
            900
                                                                                    $868
            800                     1 to 1 vintages
            700
            600                                          $671
 $ /to n




            500              $533                                            $434
            400                                       $336
                             2 to 1 vintages
            300
            200            $267                                               $305
                                                       $235     2.86 to 1 vintages
            100
              0

                          2010                        2015                  2020
Historical NOX Allowance Prices (spot)
                                     NOX Budget Program NOX Allowance Spot Price (Prompt Vintage)
                                                      January 2005 - September 2007
                $4,000

                $3,500

                $3,000
Price ($/ton)




                $2,500

                $2,000

                $1,500

                $1,000

                 $500

                   $0
                        05

                        05

                        05

                        05

                11 05

                          5

                        06

                        06

                        06

                        06

                11 06

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                 3/ 07
                        07

                        07

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                        07
                       00




                       00
                     20

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                    /2




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                                                                        Date
                         Notes:
                         1. Data Source: CantorCo2e's Market Price Indicator (MPI). See www.emissionstrading.com
                         2. Prompt vintage is the vintage for the "current" compliance year.
Historical 2009 CAIR NOX Annual Allowance Prices

                  $8,000

                  $7,000

                  $6,000
   Price, $/ton




                  $5,000

                  $4,000
                  $3,000

                  $2,000

                  $1,000

                       $0




                                                                                                          7
                          7



                                     7



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                                                                                               10
                                                                Date
                              Source: CantorCO2e (www.emissionstrading.com)
              Forecasted & Actual
        CAIR Annual NOX Allowance Prices
           EPA Projected Prices for                          October 2007 Spot Market
           CAIR Annual Allowances                                  Price Ranges
               (2006 Dollars)
                                                                         $3,900

                                                                         $3,691



                                   $1,716
                        $1,441
           $1,144




             2009    2015     2020                               2009 CAIR Annual
             CAIR Annual Allowance                                    Market

Sources: Forecasted price, EPA, 2006; Spot market prices, CantorCO2e (10/1-10/23/2007).
     CAIR Annual NOX Allowance Prices

• Fundamentals suggest to EPA that prices for 2009 annual NOX allowance
  should be between $1,500 to $2,000 per ton
    – Influenced by recent increases in capital costs
        • Industry reports of capital costs doubling on some projects
        • Labor and materials cost increases and shortages
        • Competition for scarce resources
             – NOX, SO2 and mercury programs implemented nationwide
             – Demand from China and elsewhere
• Current market not driven by cost fundamentals
    – A 400% capital cost increase would be needed for an SCR installation to approach
      $3,000 per ton NOX removal (when compared to current IPM inputs)
    – Risk aversion and lack of trading activity seem to be driving the market today
       • Classic case of too much demand, too little supply
       • Access to allocations may ease this pressure
                   Recent Market Events
•   EPA market tracking and analysis of allowance holdings suggests no one
    dominates the emission trading markets. FERC monitors this market and
    shares EPA’s view
•   EPA sees effective markets for SO2 and NOX allowances, although
    participants note that relatively modest changes in the levels of trading
    volumes tend to cause very noticeable allowance price changes
     – E.g., new entrants acquiring positions.
•   When there are “unanticipated” price movements, the markets work and
    correct themselves over time
•   On September 17, Senator Levin (D – MI) introduced a bill that could
    enhance regulation of commodities “from the burning of fossil fuels”
    including “carbon dioxide and sulfur dioxide”
•   On September 18, the Commodities Futures Trading Commission
    (CFTC) held a hearing on the potential for enhanced oversight of energy
    markets, including emission markets
•   On October 24, the House Committee on Agriculture, which oversees the
    CFTC, held a hearing on oversight of Exempt Commercial Markets (ECMs)
Visit the Clean Air Markets Web Site

 • Emissions data
 • Allowance transfers
 • Information on the acid rain and NOX
   trading programs
 • Program rules and guidelines
 • Studies and reports
 • NEW Google maps interface!
       Clean Air Markets Division
        www.epa.gov/airmarkets

						
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