Carbon Tax. September Deloitte Touche Tohmatsu Limited. All rights reserved.

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1 Carbon Tax September 2012

2 Background 2

3 Background During the 2009 Copenhagen climate change negotiations, South Africa voluntarily announced that it would act to reduce domestic Greenhouse Gas ( GHG ) emissions by 34% by 2020 and 42% by 2025 below BAU. On a per capita basis and from an emissions intensity perspective, South Africa is considered to be one of the world s worst polluters. While South Africa only contributes 1.1% to the world s total emissions, there has been increasing pressure from the international community to take mitigating action to reduce carbon emissions. 3

4 Despite global efforts to reduce CO 2 emissions, they continue to rise due to the increasing use of fossil fuels 4 *Source: Keeping track of our environment. From Rio to Rio 2011 United Nations Environment Programme

5 SA versus other middle income and commodity producing countries 5 Source: International Energy Agency Data 2008

6 SA versus other countries that have implemented a form of carbon tax 6 Source: International Energy Agency Data 2008

7 South Africa s top emitters 7 Source: International Energy Agency Data

8 Government s view on Carbon Tax 8

9 Carbon Tax timeline

10 Carbon Tax rationale The rationale for a carbon tax is that it will contribute to the global response to mitigate climate change. National treasury believes a modest carbon tax will begin to price carbon dioxide emissions so that the external costs resulting from such emissions start to be incorporated into production costs and consumer prices. This will also create incentives for changes in behaviour and encourages the uptake of cleaner-energy technologies, energy-efficiency measures, and research and development of low-carbon options.

11 Treasury s view Government is of the view that South Africa needs to reduce Greenhouse Gas emissions while working to ensure economic growth, increase employment, and reduce poverty inequality. Environmentally related taxes have an important role to play in discouraging activities that impose high social costs and in helping to ensure that economic growth and development are sustainable. Although a carbon tax does not set a fixed quantitative limit to GHG emissions over the short term, such a tax at an appropriate level and phased in over time to the correct level will provide a strong price signal to both producers and consumers to change their behaviour over the medium to long term. 11 The introduction of a carbon price will change the relative prices of goods and services, making emissions-intensive goods more expensive relative to those that are less emissions intensive. This provides a powerful incentive for consumers and businesses to adjust their behaviour, resulting in a reduction of emissions. SAICA Carbon Tax Reducing Greenhouse Gas Emissions: The Carbon Tax Option 2010

12 The Discussion Paper In December 2010 National Treasury released a discussion paper for public comment entitled Reducing Greenhouse Gas Emissions: The Carbon Tax Option The Discussion Paper. This Discussion Paper raised the issue of carbon tax as a potential carbon pricing mechanising for introduction onto SA for the purpose of reducing greenhouse gas emissions and more specifically carbon emissions in SA. The Discussion Paper makes a compelling argument for a carbon tax as a pricing mechanism for greenhouse gas emissions (GHG). An alternative to a carbon tax is an emission trading scheme which is based on market principles. 12

13 National Planning Commission s view 2015 Carbon tax in place 2020 Carbon budget approach has evolved into an important planning tool 2030 Carbon budget approach has matured and is aligned with international best practices. According to the planning document South Africa s transition to a lowcarbon, resilient economy and just society will be well underway by South Africa will have reduced its dependency on carbon, natural resources and energy by

14 National Planning Commission Key contributions to stabilising emissions include An advanced liquid and bio-fuels sector An expanded renewable energy programme Proactive local government climate change programmes A commitment to undertake mitigating actions Policy instruments that support mitigation An appropriate mix of carbon pricing mechanisms An effective mix of energy efficiency and demand management incentive 14

15 National Planning Commission Proposed mitigation instruments Carbon-budget approach A carbon budget sets the amount of carbon that can be emitted in a given time. This system would: Benchmark SA s total carbon budget against the national GHG trajectory range Consider the cumulative nature of carbon budget over the entire period under the national GHG trajectory range Use a bottom-up approach Flexibility for achieving reductions in different sectors of the economy over time. The carbon budgeting approach to mitigation must efficiently and appropriately apportion carbon space to the sectors and activities that add the greatest value, using a transparent set of criteria and indicators that include development criteria. 15

16 National Planning Commission Comments on Discussion Paper National Treasury, in its 2010 discussion paper, proposes a carbon tax approach. The commission supports this. If SA is to manage the transition in the least disruptive way possible it will need to introduce a broad-based pricing regime that covers all relevant sectors at one consistent price. This approach will need to include a range of temporary incentives and support mechanisms. This regime may need to be aligned with a carbon budget for specific sectors. Over the long term, the rebates, supporting policies and incentives will be phased out, leaving a carbon price that will be close to the social cost of carbon internationally. Given that electricity represents the source of most of SA s national emissions as well as much of its mitigation potential, it is critical that the sector is subject to an appropriate carbon price. A possible way to do this is by providing a tax rebate to the sector, with the Integrated Resource Plan remaining the primary mitigation instrument. The carbon price would need to be phased in to protect the economy and consumers from further crippling increases. 16

17 Department of Environmental Affairs' view A mix of economic instruments, including market-based instruments such as carbon taxes and emissions trading schemes, and incentives are required which should be complemented by appropriate regulatory policy measures. Due to current emissions-intense structure of the economy, many sectors require a flexible mitigation approach, which enables the development and use of lowest-cost options such as offset and other types of market-based mechanisms. A carbon budget approach will identify an optimal combination of mitigation actions at the least cost to-and with the most sustainable development benefit for the relevant sector and national economy to enable and support the achievement of the desired emission reduction outcomes consistent with the benchmark National GHG Emissions Trajectory Range. National Climate Change Response White Paper 17 SAICA Carbon Tax

18 National Energy Regulator South Africa All three options for introducing a carbon tax (direct on CO2 emissions, upstream on fuel producers, downstream on electricity) impact the cost of electricity produced. Carbon tax of R100/ton would increase the cost of producing electricity by about 10c/kWh (20% increase in average sales price of electricity) Will this electricity price increase achieve the objective of creating an adequate incentive to encourage behavioral change? 18

19 National Energy Regulator South Africa Price increases have negative behavioural consequences when the person paying the increased price has limited or no options to respond. A carbon tax is inappropriate for the centrally planned and controlled South African electricity sector. It may be effective in the case of a liberalised market. Regulations and regulatory rules would be more effective to influence the technology choice, the dispatch of generation and the efficient use of electricity. Such regulations would create new jobs and grow the economy and not merely burden the economy with a tax to which there is limited response. 19

20 Department of Energy s view IRP 2010 Base case Cost to the economy of R840bn. Carbon tax case Carbon tax at a level of R165/MWh in 2010, escalating to R332/MWh in 2020 before escalating to R995/MWh in CO2 emissions continue to grow to a level of 381 million tons at the end of 2030 The cost to the economy arising from the changed generation portfolio is R852bn. Water usage drops from million litres in 2010 to million litres in 2030 Average annual emissions at 269 million tons Water consumption declining to million litres in

21 2012 Budget Documentation 21

22 Carbon Tax It is proposed in the 2012 Budget Documentation that a carbon tax will be implemented in 2013/2014 at a rate of R120 per ton of carbon dioxide equivalent (CO 2 e) on direct emissions in line with in the Climate Change Response White Paper approved by Cabinet in Tax Free thresholds will apply between 60 and 100%. These thresholds will be reduced during the second phase ( ), and may be replaced with absolute emission thresholds thereafter. Based on the Deloitte original estimate of R82.5billion collections at a cost of R165 per ton, we estimate that total collections for the carbon tax to be collected in 2013/2014, at a cost of R120 per ton (in conjunction with the tax free threshold), to be approximately R20billion; increasing by per annum to 2020.

23 Carbon Tax Design features The proposed carbon tax will have the following design features: Percentage-based rather than absolute emissions thresholds below which a carbon tax will not be payable; A higher tax-free threshold for process emissions; Additional relief for trade-exposed sectors; The use of offsets by companies to reduce their carbon tax liability; A phased implementation; The tax will increase by per annum until 2020; The revenues received from the tax will not be earmarked, but consideration will be given to spending to address environmental concerns. Incentives such as the proposed energy efficiency tax incentive will be supported; and The CO 2 emissions will be calculated using agreed methods.

24 Carbon Tax Industry threshold A basic tax free threshold of 60% will apply during the first phase of the tax ( ). Further relief for trade exposed industries and process emissions will be allowed. The proposed tax free threshold per industry is as follows: Sector Basic Tax free threshold (%) below which no carbon tax will be payable during the first phase (2013 to 2019) Maximum Additional allowance trade exposure Additional allowance for process emissions Total Maximum offset percentage Electricity Petroleum (coal to liquid) Petroleum oil refinery Iron and steel Aluminium Cement Class & ceramics Chemicals Pulp & paper Sugar Agriculture, forestry and land use Waste Fugitive emissions: coal Other 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% % 40% - 60% 70% 70% 80% 80% 80% 80% 80% 70% 70% 100% 100% 80% 70% 5% 5% 5% 5% 5% - - 5%

25 Carbon Tax Adjustment of Basic Percentage Companies will be encouraged to reduce the carbon intensity of its products. A comparison based on industry emissions will be used to either reduce or increase the tax-free threshold. Companies whose carbon intensity of its products is higher than the industry standard will be penalised by reducing the 60% threshold. Likewise companies whose carbon intensity of its products is lower than the industry standard will receive a higher tax-free threshold capped at 90%. A carbon tax at a rate of R120 per ton CO 2 e is seen as modest per the budget documents especially when one takes the thresholds into account.

26 Carbon Tax Companies liabilities based on 2011 emissions Electricity price increases by 4.8 cents per kwh in 2013/2014 Note: based on 2011 coal fire power generation of of GWh

27 International Comparison 27

28 The global potential for Greenhouse Gas reduction is dominated by the policies of the top five emitting countries China USA Russia India Japan Germany Canada UK Iran Korea Italy Mexico Australia Saudi Arabia Indonesia France Brazil South Africa Spain Ukraine Million tons CO % of total Global emissions 60% of emissions are produced by the top 5 countries Source IEA - Top 20 CO2 Country emitters,

29 China s role as the top emitting country By 2020 China s emissions will increase by million tons. China s increased actual emissions for one year ( ) after abatement is more than South Africa s total BAU emissions in In addition to its 14 operational nuclear plants, China is constructing 25 new nuclear plants with more to start soon. Per capita carbon emissions are 4.03 tons for each Chinese compared to tons per American and 1.12 tons in India 29

30 India The impact on CO2 emissions of the tax is unknown as the tax has only been in place since April Time will tell if it has made any impact on emissions. India s carbon tax, the Clean Energy Cess is unlikely to reduce the usage of coal or reduce CO2 emissions, as it is currently priced at Rs 50 per tonne. The carbon tax was established as a funding mechanism for research into clean energy technologies. The PAT Mechanism is more likely to reduce CO2 emissions.

31 British Columbia Per the British Columbian Government the carbon tax at the current levels will initially have a small impact on emissions, which was intentional. Currently at $30 per tco 2 -e (increases at a rate of $5/annum). Recent study indicates a drop of 15% in the use of petroleum fuels in B.C., with GHG emission showing similar substantial decline. There are also evidence that the policy had no adverse affects on the economy of B.C. British Columbia is the first and only province or state to implement a carbon tax.

32 United Kingdom 27% % CO2 emissions: Coal (Mt of CO2) CO2 emissions: Oil (Mt of CO2) 35% CO2 emissions: Natural gas (Mt of CO2) According to the evaluation accepted by the UK government in 2007, the CCL will reduce annual CO2 emissions by 12.8 million tonnes by These savings have however come mainly from the effect its announcement had on raising awareness of the potential for energy savings. Most of these savings were therefore the result of actions taken before the tax actually came into operation. It is believed that the UK CCL is responsible for the second most reductions in CO 2 emissions. Only Phase II of the EU ETS exceeds CO 2 emissions reduction expectations. The CCL itself did not necessarily reduce CO 2 emissions and had hardly any effect at all.

33 Carbon Tax and Six Sigma 33

34 Carbon Tax and Six Sigma Opportunities Implementing processes/process changes that allow for emissions below industry benchmark resulting in increase of tax free threshold Implementing Six Sigma could leveraging from incentives for becoming more energy efficient: Manufacturing Competitiveness Enhancement Program (MCEP) Allowance for Energy Efficiency Savings (Section 12L) Proposed to be supported from Carbon Tax collections Investment and Training Allowances in respect of Industrial Policy Projects (Section 12I)

35 Carbon Tax and Six Sigma Incentive: MCEP Capital Investment Green Technology and Resource Efficiency Improvement Enterprise-Level Competitiveness Improvement

36 Carbon Tax and Six Sigma Incentive: MCEP Cleaner production Waste management GREEN TECHNOLOGY AND RESOURCE EFFICIENCY IMPROVEMENT FOCUS AREAS CATEGORIES QUALIFYING COSTS Cleaner production Improvements Eg: air compressing, pumping, steam systems Energy efficiency production audits, e.g. ISO Waste Management Improvement Building Improvements: lighting efficiency Audit and accreditation costs Certificate, measurement and verification costs Technology for re-cycling, re-use of waste and recovery of energy from waste Energy efficiency Water use efficiency Conformity assessments Energy efficiency improvement Water usage improvements Quality and environmental standards e.g. ISO Private conformity assessment bodies e.g. laboratories, inspection bodies Improved energy efficiency technology e.g. solar panels, pumps, motors Industrial waste water treatment facilities Certification against quality or environmental standards Setting up, installing and upgrading laboratory equipment Preparation for accreditation

37 Carbon Tax and Six Sigma Incentive: MCEP ENTERPRISE-LEVEL COMPETITIVENESS IMPROVEMENT FOCUS AREAS CATEGORIES QUALIFYING COSTS Process improvement Process Improvement E.g. world-class manufacturing practices Product improvements Conformity assessment Logistics improvements Information technology systems Skills development Product design improvement Product development improvement Conformity assessment of products e.g. testing, inspection, certification Product efficiency Consumer acceptability studies Packaging design Quality Management Improvement Accreditation Logistic arrangements and systems Acquisition and deployment of systems Training accredited by SAQA (not longer than 12 months) in: production Development, marketing, Financial, information technology (IT), Human Resource (HR), Business, Product and Quality Management Training existing and new consultants in areas of standards such as ISO 9001 etc to increase accreditation capacity (not longer than 12 months) Pattern-making, prototyping, grading, sizing and counter-sampling Improving product ranges and product adaptations for new markets Cost for Conformity assessment of products Improved product techniques, fess for the design of production information systems Marketing new or improved products to focus groups before product launch to market. Consultancy and design costs Installing or improving quality management systems Costs for preparations for accreditation and pre- /initial assessment Improving logistic efficiencies e.g. introducing logistic systems Acquisition of software for production, sales, accounting and human resource management Course Fees Course Fees Procurement process Improvements Bidding costs Introducing improved and efficient procurement processes Bidding for technical contracts with a minimum value of R50 million in State-Owned Enterprises (SOEs), public and private sector Cost of introducing new procurement processes Technical consultancy towards compiling bid documents up to a maximum grant of R7,5 million

38 Carbon Tax and Six Sigma Incentive: Section 12L Deduction allowed from taxable income: Amount of allowance: A = B C D A: Amount of allowance to be determined B: Energy efficiency savings (kwh) C: R0.45/kWh (lowest feed-in-tariff) D: 2, unless a different number has been announced in Gazette Valid until 31 December 2019

39 Carbon Tax and Six Sigma Incentive: Section 12I Additional investment and training allowances in respect of industrial policy projects Prerequisites for industrial policy projects: Skills Development >= average of 2% of annual wage bill Accredited by SAQA Energy Efficiency Brownfield: energy efficiency improvement of at least from baseline Greenfield: Utilise modern, viable energy efficient equipment and processes

40 Carbon Tax and Six Sigma Incentive: Section 12I

41 Way Forward 41

42 Carbon Tax Way Forward A better understanding of current data and policy must be obtained Scenario planning must be undertaken to understand the implications for business Engage with National Treasury regarding a carbon tax A draft policy paper on carbon tax for public comment will be released later in the year. It is vital that business analyse these carbon tax proposals and be prepared for the policy paper. Make use of the incentives made available by government.

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