In terms of the General cost structure ECGA s position is as follows: Risk of a shift of CO2 emissions due to indirect emissions

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1 General remarks by ECGA on the public consultation "New Guidelines for Government Aid in context of the changed EU emissions trading system" launched by the European Commission on 11 March 2011: For ECGA members the compensation of indirect CO 2 -costs is absolutely necessary to prevent carbon leakage in electricity-/energy-intensive processes, e.g. to achieve high temperatures in furnaces as base for production and processing of carbon and graphite. The PRODCOM-Codes mainly concerned are: , and In contrast to the European Commission s opinion, ECGA thinks that financial compensation would not lead to a distortion of competition in the EU-internal market. In fact it will counteract European companies' competitive disadvantages related to the emission trading scheme. ECGA expects to avoid the additional burden from anticipated electricity price increases, which will deeply affect the international competitiveness of the European Carbon and Graphite Industry. In terms of the Lack of the possibility for passing on the costs of indirect emissions ECGA s position is as follows: Generally, all industrial sectors named on the NACE 4 level and below in the "exposed sectors" list (Resolution of the EU Commission dated 12/24/2009, file no. K(2009)10251; 2010/2/EU) qualify for compensation. - Sectors should be deemed qualified as "exposed" in terms of receiving electricity price compensation in order to ensure equal treatment of direct and indirect emissions, i.e. plants belonging to the sectors or sub-sectors, which have been identified as "exposed" pursuant to 15 or 16 of the EU Commission proposal of 24 December 2009, qualify for financial compensation. As additional criteria for full compensation a threshold of 1 kwh/gross value added might be introduced. - Therein however it must at least be ensured that high-electricity plant types in the sectors that are on the "exposed sectors" list will receive comprehensive compensation. This conforms to the reasons of consideration 24 and 27 of the EU. - Furthermore, the few plants obtaining their allocation according to the "fuel-electricity inter-changeability" method in direct emissions (i.e. for process, heat and direct fuel emissions), should be examined in particular detail. The reason for this is that these plants must accept a complete deduction that is specific to their plant for their electricity related emissions. It entails that a plant with a large share of electricity will receive a lower allocation than a comparable plant with a large steam share, even if the CO 2 efficiency is the same in both plants. This should also be balanced by financial compensation of the indirect emissions. Compensation of ETS related electricity price increases does not affect the EU-wide greenhouse gases reduction target. In this regard the compensation of a part of the ETSliable plants will not lead to a shift of the distribution of burdens in emission savings either. Since the products of the European Carbon and Graphite Industry compete with products in the global market, it cannot pass on the cost increase from emissions trading to the customer. Therefore the industry does not get any costs for indirect emissions. 1

2 In terms of the General cost structure ECGA s position is as follows: Risk of a shift of CO 2 emissions due to indirect emissions The risk of a shift exists in materialised charge and is included in considerations at the companies in discussion about investments in new as well as existing plants. The electricity price burdens furthermore add up to burdens from other laws based on climate policy. Competitors to the production sites in countries outside of the EU do not have to bear comparable expenses. Energy costs, in particular costs of electricity, represent a factor becoming more important in the Carbon and Graphite Industry in consequence of their increasingly large share in production costs. The CO 2 price, regardless of whether in direct or indirect costs, has a central role in the consideration of site relocations. All costs incurred in production are examined in these considerations. Because in the 3rd trading period, costs are expected from the ETS at energy intensive companies of ca. 25% in relation to the electricity costs starting from 2013, in 2020 more than about 50%, and up to 60% in 2027, the energy intensive industries will be particularly affected by the risk of site relocation. In trading period 3, however, further substantial increases in electricity prices will become acceptable on basis of higher certificate prices. Without compensation of the indirect costs from the ETS, enormous competitive disadvantages have to be feared for the sector. In terms of the Scope of aid ECGA s position is as follows: The compensation must not only be in view of the cost increase from the 2nd to the 3rd trading period, but it must also consider that there have already been massive cost increases from the inflow of free certificates by the energy supply companies! Therefore, the indirect costs must be compensated to full extent. The extent of government aid must not be capped from the outset. Rather, it has to be ensured that energy-intensive industries will receive full compensation of their ETS related electricity price increases. The government aid can be a tool to create incentives for the change of electricity. It is about preserving the competitiveness of industry! It is not necessary to create additional incentives for energy efficiency. The EU Emissions Trading Guideline is presently already providing for a CO 2 savings incentive: the guideline provides that government aid for indirect emissions must be based on ex ante benchmarks. The compensation serves maintaining competitiveness of an industry whose products are exposed to competition from the global markets. The government aid regulations thus should not provide for cost sharing from the outset. Rather, it has to be ensured that energyintensive industries will receive a complete compensation of their ETS related electricity price increases. State aid can be a tool to create incentives for the change of electricity. It is about preserving the competitiveness of industry! A compensation of electricity prices, which are caused by the ETS, cannot lead to a dependency on government aid. The compensation merely ensures competitiveness compared to non-eu competitors, which are not affected by emissions trading. The quality, performance and demand for the products will not be influenced by it. The compensation merely balances out the disadvantages of energy-intensive plants, which are located within the EU, but which sell their products in the world market. 2

3 Because of no international Agreement with regard to world climate conventions or a world emissions trading system, compensation for the support of competitiveness is urgently required. In terms of the Benchmarks ECGA s position is as follows: The electricity benchmarks serve the continuation of the idea of CO 2 savings behind the emissions trading system, even if there is compensation. The benchmarks must be identified by means of actual data and must not be arbitrarily used as an instrument of control. The objective of compensation is ensuring competitiveness at simultaneous observation of the idea of CO 2 savings. This tie is taken into account in the approach of setting benchmarks. In terms of the CO 2 emissions factor ECGA s position is as follows: The CO 2 emissions factor is equivalent to the CO 2 emissions per MWh of generated electricity. The question is, which CO 2 factor should be used as basis for the calculation of the compensation. In the non-paper directed to the European Parliament and the Council, the Commission stated that the actual CO 2 factor can generally be determined by means of electricity supply contracts, wherein it is specifically stated in what amount the EUA price/mwh is passed on to the price of electricity. If the electricity is acquired via a network (at an electricity trading place or the forward market), the average CO 2 intensity of the relevant electricity market. A uniform factor should be found for electricity price zones, which is guided by the value of the marginal-cost power plants inside of the electricity price zone. This electricity price zone can extend across individual countries. The European Commission is very welcome to direct inquiries to Mr. Peter Schallert. Answers to specific questions 1. Is there a CL-risk in your NACE-sectors? The carbon and graphite industry faces a very high carbon leakage risk as already can be seen from existing and applied for anti dumping/anti-subsidy cases. Already at PRODCOM-level ( ), following 15 and 16 (exposed by energy and trade intensity), the production of artificial graphite is on the carbon leakage list. Depending on the degree of vertical integration (finishing treatment of the intermediate products integrated or not) 3 PRODCOM-Codes are applicable: : Production of artificial graphite : Carbon and graphite for non-electrical applications : Carbon and graphite for electrical applications This is hardly comprehensible, as the energy intensive process is the same for all three products. But these 3 PRODCOM-Codes include still also various other non-energy intensive products. Therefore, these 3 PRODCOM-Codes still combine a variety of semi finished and finished products. In comparison: This problem does not exist in the US as its NACE/PRODCOM-code (see figure 1) only uses one number for all carbon and graphite products, which is also on the US carbon leakage list (see figure 2). 3

4 C:\Dokumente und C:\Dokumente und Einstellungen\muellert Einstellungen\muellert 4. Accurate information on cost structure would be very helpful. It would be particularly interesting to know whether it is possible to attribute consumed electricity to a certain source of electricity. As communicated by the carbon and graphite association (ECGA) to the European Commission, indirect costs due to carbon trading based on 0,465 mtco 2 /Mwh and 30 /mtco 2 amounted to > 4 % of the gross value added for all products. This shows how extremely important electricity price compensation is for this sector. Rising electricity prices due to carbon trading negatively affect businesses with high-energy consumption (= windfall profits for electricity producers) already since the beginning of the second trading period. As a result businesses with high electricity consumption are placed at a disadvantage in comparison to industries, which are faced with carbon leakage as the latter mainly emit directly. In principle, electricity is purchased via stock exchange or intermediaries (utilities sell also on wholesale pricing since producing and merchandising are separate). At present day it is not or hardly possible to purchase electricity directly from a power plant. If at all possible, a formula is usually provided which itself refers to the relevant stock exchange price. 5. At what price for CO 2 does a risk for carbon leakage exist? (Background: considerations to allow compensation only when a certain price for CO 2 is reached) Relocations happen already below a price for CO 2 of 0 since German electricity prices (8 to 10 ct/kwh according to the BMWi) are not competitive internationally due to taxes and other levies (Law on Renewable Energy; electricity tax; concessions levies, etc.) as well as political decisions (network development, competition on the electricity market, etc.). Electricity price paid by industry in the US amounts in certain areas to approximately 20 /MWh (= 2 ct/k Wh) (see figure 3). C:\Dokumente und Einstellungen\muellert In Germany this price (2 ct/k Wh) was reached at the beginning of the 21st century. 6. Factors for relocation Cost factors for the graphite industry (in decreasing order): 1. Raw materials 2. Electricity costs 3. Labour costs Since raw materials are traded on the world market, electricity costs are the decisive location factor. Against this background there have not been any major investments in electricity intensive carbon and graphite production plants outside of Europe by certain ECGA members (e.g. Malaysia, United States). 8. The question regarding the delocation of the hitherto existing ET-Periods is, as explained above, of crucial importance for our position. 4

5 Please see above, answers 5) and 6) 9. Also the differentiation between the ETS-2 and the ETS-3 will play a significant role for the evaluation of the need for compensation payments as of Investments in energy-intensive manufacturing-processes had been already done outside Europe in the 2 nd trading period (see above, answers 5) and 6) Questions 31-35: Relating to the questions regarding the scope of funding it is important to pay attention to the questions, in how far single companies (no self-producers) are able to influence the energy-mix and, moreover, which differences in costs are linked to this. Generally speaking, energy-consumption is not linked to the energy mix, as all energy generated by renewable energy sources is funded via the EEG -law and sold at the stock exchange s spotmarket just as set out in the law. If a company intends to buy energy directly at the producer of renewable energy, the company needs to make a higher offer than the EEG-funding sets out (e.g. Photovoltaic > 30 ct/kwh). Hence, industry needs to pay a price, which is up to six-times higher than the stock exchange price. This is very difficult from an economic point of view. The green electricity deals of energy providers are bluff packages: energy offered at the stock exchange includes 10 to 20% renewables. This energy is then sold with a price premium as green electricity. The remaining customers have to deal with grey, nuclear energy which increases as well. Questions 39 ff. tackles the question of determining CO2-factors, which was also the subject of discussion during our last meeting. A more general evaluation of the issue from your side would be highly appreciated. The real CO 2 -costs resulting from the increase of costs of the base load energy should be compensated. Traditionally in countries with Graphite production, base load energy being of relevance for industry was/ is produced in lignite or hard coal power generators. Based on a price of 30 /MWh (estimation of the European Commission for the Carbon Leakage List) the following can be concluded: Lignite: 1,1 mtco 2 /MWh x 30 /mtco 2 = 33 /MWh Stone coal: 0,9 mtco 2 /MWh x 30 /mtco 2 = 27 /MWh A compensation of ca. 30 /MWh respectively 3ct/kWh. Taking into consideration the current prices for CO 2 of ca. 15 to 20 /mtco 2 a compensation of ca. 1,5 to 2 ct/kwh can be estimated. Also a compensation based on gas-fired powerplants (ca. 0,4 mtco 2 /MWh) would not account for the risk of carbon leakage as the production of energy in gas-fired powerplants is comparably expensive and also e.g. China does still build on stone coal powerplants. Gas-fired power plants: app. 7 ct/kwh (current gas price as of powerplant: ca. 3ct/kWh) Hard coal power plants: app. 4 to 5 ct/kwh Contrary to the original intention, this approach fosters the relocation of energy intensive productions to countries for which no CO 2 -costs are charged (e.g. energy production in Asia is mainly based on coal without CO2-carges). 5