The European Union Emission Trading System (EU ETS) is a strong market-based policy instrument to adjust for the externalities of greenhouse gas emissions within the EU. At its outset, it is a first-best policy, which accounts for all or some of the external costs by internalizing them into prices. However, there are a number of other sources of industry market failures, such as potential transition barriers. These can be categorised as technical-, regulatory-, market-, and coordination barriers, and will lead to markets not functioning efficiently (Löfgren & Rootzén, 2021).
Furthermore, perspectives such as energy security, equity, and technical innovation are important to consider in the transition towards a low carbon economy. Therefore, several EU-policies are focused on ensuring a just and equitable transition, long term security of energy supply, and stimulating technical innovation (European Commission, n.d.a; European Parliament, 2020; European Commission, n.d.b). The ETS is also subject to several adjustments, such as the market stability reserve and the carbon border adjustment mechanism (yet to be implemented). These are adjustments made to ensure investment stability and therefore incentives, and to consider the global aspect.
It is also important to notice that there can be public and political opposition to efficient environmental regulation, for example as a result of undesirable distributional impacts. Hence, in the pragmatic world of policymaking, it is often better to implement an economically sub-optimal policy to deal with an environmental problem, than no policy at all.
2.1.4.1 Introducing measures within existing policy regimes
If the EU ETS was implemented as a pure first best policy, any subsequent intervention in the market would be without effect in the short run; emissions from energy production are subject to trading and constraints within the EU ETS. Hence any incentives (or removed incentives) for reduced emissions from energy production and consumption will, in the short run, be offset by adjustments in the market for emission allowances. The total amount of allowed annual emissions has already been established, and additional incentives can only influence the distribution of emissions among different sources. Consequently, compensation measures that remove incentives for energy conservation would not impact emissions levels, although they could affect the costs associated with emission reductions.
However, the EU ETS is, with its many revisions and adjustments, like the market-stability-reserve, a complex system of regulations. Neither the EU ETS market or the primary market for products and services in which the EU ETS market operates are “Markets under perfect competition”. For example, Silbye & Sørensen (2019) show that subsidising green energy within the ETS will first be neutralized by the end of the century. As climate policy does distinguish between emissions now and later, this is crucial. The analysis by Silbye & Sørensen was made before the latest revision of the ETS system, yet their conclusions still have relevance. In another study, Kruse-Andersen & Sørensen (2022) analysed optimal national policies within the ETS system if countries want to be frontrunners in dealing with leakage. Both of these studies are examples on how important it is to look at the detail of regulations, as they are normally taking place in a second-best world.
Finally, it is important to note the endogeneity of policy target setting: Ambitious targets depend on political support, and this is more likely to be received if it is not too costly for the industry and households. Correspondingly, the long-term effects of an incentive might be different from the short-term effects. For example, the Swedish government proposed an annulment mechanism for surplus emission allowances within the EU-ETS. This proposal was based on the fact a significant number of emission allowances were being left unused, which gave political room to manoeuvre and propose changes in the legislation. This proposal has been accepted and has become a part of the 4th trading period within the EU ETS (Swedish Environmental Protection Agency, 2023a).
2.1.4.2 Interplay between climate policies and compensation measures
When compensation measures effectively alleviate the financial burden of high energy costs, they can inadvertently reduce the urgency for individuals and companies to actively engage in efforts to reduce climate impacts, such as energy conservation. If the costs of energy consumption are offset or mitigated through compensation measures, the incentive to adopt energy-efficient practices and technologies is reduced.
The introduction of compensation measures to alleviate the immediate financial burden of high energy costs may also create an expectation of sustained support. Hence, when individuals and companies anticipate future compensation, they may delay or forgo proactive investments in energy-saving technologies or practices today. This reliance on compensation measures can therefore hinder the development of a long-term culture of energy efficiency. If the compensation measure is certain to be a one-time event, it is crucial to effectively communicate that. This is even more important in the context of climate change, since climate policies are long-term policies. Hence, clear and transparent communication is necessary to manage expectations and avoid creating a sense of reliance on repeated compensation for price shocks.
2.2 Analytical framework
Based on the theoretical framework presented above, we designed an analytical framework aimed at evaluating the compensation measures assisting households and companies facing high energy and fuel costs. In our analytical framework we chose to focus on criteria that best address the project objectives. Hence, we focused on elements that address distributional impacts and disincentives for climate positive behaviour and investments, with a secondary focus on policy coherence and on other environmental aspects. This framework follows evaluation criteria inspired by the literature (e.g., Sterner & Coria, 2013, Goulder & Parry, 2008). However, the potential to evaluate a compensation measure across all criteria is dependent on available data and supporting literature, which varies between countries and measures.
By assessing several evaluation criteria, we sought to provide an understanding of the impact of the compensation measures in addressing energy cost challenges while aligning with climate goals and ensuring proper distributional effects. The evaluation criteria assessed were:
The distributional impacts criterion focuses on how funding was distributed among different socio-economic groups, and whether the support was targeted to alleviate the burden for the individuals most affected by the high energy prices. To the extent feasible, we also analysed regional differences. The climate impact criterion focuses on 1) short-term market effects, 2) short-term emissions, 3) altered incentives for climate-friendly behaviour, 4) altered incentives for climate positive investments, 5) other environmental effects. The coherence criterion comments on factors such as efficiency, transparency, and transaction costs.
2.2.1 Distributional impacts
The distribution criterion evaluates the extent to which policies specifically target and support vulnerable households and companies. It is important to assess whether the policies effectively address energy cost challenges for those who are disproportionately burdened and financially strained. By analysing the policy's design, implementation, and impact, it is possible to determine whether it provides sufficient support and resources to vulnerable groups. An often-discussed aspect of environmental and other policies is whether the impacts are relatively more positive (or less negative) for people with lower incomes (i.e. progressive policy) or if the policy has the opposite effect (i.e., regressive policy). Furthermore, other factors for distributional impacts that may be relevant include geography (e.g., rural vs urban), gender, age, and ethnicity (e.g., if immigrant groups are more vulnerable). In our assessment we will primarily focus on income and vulnerability towards energy price increases.
Compensation measures that effectively target any of these factors include income-based eligibility criteria, subsidies tailored to low-income households, or support programs for energy-intensive industries facing financial difficulties. Ensuring equitable access to monetary assistance and consideration of the unique needs and challenges of vulnerable populations are key considerations in assessing the policy's ability to reduce energy cost disparities and promote equity in energy access and affordability.
2.2.2 Climate impacts
The provision of monetary support for high energy costs may affect incentives for climate-positive behaviours. Depending on the policy design, disincentives for reductions in energy consumption may be created if energy price signals are blunted, reducing the urgency of behaviours to reduce energy usage. Disincentives arise if monetary support is aligned with current energy consumption, as it keeps the cost of energy relatively low. If monetary support is instead based on past consumption or provided as a lump-sum to all consumers regardless of their energy use, incentives for reductions in energy consumption remain effective. By avoiding disincentives for energy reduction, consumers internalise the high costs into their household budgets, which generally should encourage adoption of energy-efficient behaviours like adjusting indoor temperatures or minimizing hot water usage during showers (European Scientific Advisory Board on Climate Change, 2023). Monetary support for high energy costs may also affect investments in climate-positive initiatives such as energy efficient technology and retrofitting.
A critical consideration, for both behaviour and investment, is the influence on beliefs (expectations) regarding future policies and supports, as beliefs significantly impact current behaviour and investment incentives. If compensation policies are believed to be repeated in the future, the urgency to change behaviour or invest in energy-efficient technologies or retrofitting may be diminished in the short term
Given the importance of whether support is given for past or current energy use, and of beliefs, it is also highly important that the design of the measure and its potential re-occurrence is communicated effectively. Correct communication helps prevent the perceptions of being ‘bailed out’ and the formation of expectations for repeated support.
2.2.3 Coherence with existing climate policies
The coherence criterion relates to how well the compensation measure aligns with other existing climate policies on energy and transport on both national and transnational level. The assessment analyses whether the measure complements, distort or conflicts with other environmental policies in terms of reaching specific reduction targets, interest conflicts and cost efficiency. Emphasis is placed on the measure’s overall objectives in relation to other policy objectives on climate, relating to energy and transport.