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Testimony: 

Before the Committee on Finance, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT:
Wednesday, July 8, 2009: 

Climate Change Trade Measures: 

Estimating Industry Effects: 

Statement of Loren Yager, Director: 
International Affairs and Trade: 

GAO-09-875T: 

[End of section] 

Mr. Chairman and Members of the Committee: 

Thank you for the opportunity to appear again before the Committee to 
provide insights from GAO's work on issues related to important 
international issues. Changes in the earth's climate attributable to 
increased concentrations of greenhouse gases may have significant 
environmental and economic impacts in the United States and 
internationally. To mitigate climate change effects, countries are 
taking or considering varying approaches to reducing greenhouse gas 
emissions, such as carbon dioxide, which is the most important 
greenhouse gas due to its significant volume. Between 2007 and 2009, 
Congress introduced a number of climate change bills, many of which 
contained proposals for a domestic emissions pricing system, such as a 
cap-and-trade system or a carbon tax. However, imposing costs on energy-
intensive industries in the United States could potentially place them 
at a disadvantage to foreign competitors. In addition, emissions 
pricing could have negative environmental consequences, such as "carbon 
leakage," whereby emissions reductions in the United States are 
replaced by increases in production and emissions in less-regulated 
countries. As Congress considers the design of a domestic emissions 
pricing system, a key challenge will be balancing the need to reduce 
greenhouse gas emissions with the need to address the competitiveness 
of U.S. industries. 

In my testimony today, my comments are based on a report that we are 
issuing today to the Senate Committee on Finance.[Footnote 1] In 
particular, I will briefly describe some of the key challenges 
associated with estimating the industry effects from climate change 
measures, and provide illustrations of key characteristics for 
potentially vulnerable industries. 

To address these objectives, we interviewed officials and reviewed 
climate change literature and documents from U.S. agencies, 
international organizations, policy institutes, and professional 
organizations; reviewed and analyzed a selection of climate change 
legislation introduced between 2007 and 2009 and congressional hearing 
records; analyzed data from the Census Bureau and the Departments of 
Energy and Commerce, among others; and reviewed and presented summary 
results for studies attempting to quantify the potential international 
competitiveness effects on domestic industries from emissions pricing. 
We conducted our work from October 2008 to July 2009 in accordance with 
all sections of GAO's Quality Assurance Framework that were relevant to 
our objectives. We believe that the information and data obtained, and 
the analysis conducted, provide a reasonable basis for any findings and 
conclusions in this product. 

Summary: 

Estimating the potential effects of domestic emissions pricing for 
industries in the United States is complex. If the United States were 
to regulate greenhouse gas emissions, production costs could rise for 
certain industries and could cause output, profits, or employment to 
fall. Within these industries, some of these adverse effects could 
arise through an increase in imports, a decrease in exports, or both. 
However, the magnitude of these potential effects is likely to depend 
on the greenhouse gas intensity of industry output and on the domestic 
emissions price, which is not yet known, among other factors. 

Estimates of adverse competitiveness effects are generally larger for 
industries that are both relatively energy-and trade-intensive. In 
2007, these industries accounted for about 4.5 percent of domestic 
output. Estimates of the effects vary because of key assumptions 
required by economic models. For example, models generally assume a 
price for U.S. carbon emissions, but do not assume a similar price by 
other nations. In addition, the models generally do not incorporate all 
policy provisions, such as legislative proposals related to trade 
measures and rebates that are based on levels of production. 

Proposed legislation suggests that industries vulnerable to 
competitiveness effects should be considered differently. Industries 
for which competitiveness measures would apply are identified on the 
basis of their energy and trade intensity. Most of the industries that 
meet these criteria are in primary metals, nonmetallic minerals, paper, 
and chemicals, although significant variation exists for product groups 
(sub-industries) within each industry. Additional variation arises on 
the basis of the type of energy used and the extent to which foreign 
competitors' greenhouse gas emissions are regulated. To illustrate 
variability in characteristics that make industries vulnerable to 
competitiveness effects, we include illustrations of sub-industries 
within primary metals that meet both the energy and trade intensity 
criteria; examples that met only one criterion; and examples that met 
neither, but had significant imports from countries without greenhouse 
gas pricing. 

Background: 

Countries can take varying approaches to reducing greenhouse gas 
emissions. Since energy use is a significant source of greenhouse gas 
emissions, policies designed to increase energy efficiency or induce a 
switch to less greenhouse-gas-intensive fuels, such as from coal to 
natural gas, can reduce emissions in the short term. In the long term, 
however, major technology changes will be needed to establish a less 
carbon-intensive energy infrastructure. To that end, a U.S. policy to 
mitigate climate change may require facilities to achieve specified 
reductions or employ a market-based mechanism, such as establishing a 
price on emissions. Several bills to implement emissions pricing in the 
United States have been introduced in the 110th and 111th Congresses. 
These bills have included both cap-and-trade and carbon tax proposals. 
Some of the proposed legislation also include measures intended to 
limit potentially adverse impacts on the international competitiveness 
of domestic firms. 

Estimating Competitiveness Effects: 

Estimating the effects of domestic emissions pricing for industries in 
the United States is complex. For example, if the United States were to 
regulate greenhouse gas emissions, production costs could rise for many 
industries and could cause output, profits, or employment to fall. 
However, the magnitude of these potential effects is likely to depend 
on the greenhouse gas intensity of industry output and on the domestic 
emissions price, which is not yet known, among other factors. 
Additionally, if U.S. climate policy was more stringent than in other 
countries, some domestic industries could experience a loss in 
international competitiveness. Within these industries, adverse 
competitiveness effects could arise through an increase in imports, a 
decrease in exports, or both. 

For regulated sources, greenhouse gas emissions pricing would increase 
the cost of releasing greenhouse gases. As a result, it would encourage 
some of these sources to reduce their emissions, compared with business-
as-usual. Under domestic emissions pricing, production costs for 
regulated sources could rise as they either take action to reduce their 
emissions or pay for the greenhouse gases they release. Cost increases 
are likely to be larger for production that is relatively greenhouse 
gas-intensive, where greenhouse gas intensity refers to emissions per 
unit of output. Cost increases may reduce industry profits, or they may 
be passed on to consumers in the form of higher prices. To the extent 
that cost increases are passed on to consumers, they could demand fewer 
goods, and industry output could fall. 

While emissions pricing would likely cause production costs to rise for 
certain industries, the extent of this rise and the resulting impact on 
industry output are less certain due to a number of factors. For 
example, the U.S. emissions price and the emissions price in other 
countries are key variables that will help to determine the impact of 
emissions pricing on domestic industries. However, future emission 
prices are currently unknown. Additionally, to the extent that 
emissions pricing encourages technological change that reduces 
greenhouse gas intensity, potential adverse effects of emissions 
pricing on profits or output could be mitigated for U.S. industries. 

Several studies by U.S. agencies and experts have used models of the 
economy to simulate the effects of emissions pricing policy on output 
and related economic outcomes. These models generally find that 
emissions pricing will cause output, profits, or employment to decline 
in sectors that are described as energy intensive, compared with 
business-as-usual. In general, these studies conclude that these 
declines are likely to be greater for these industries, as compared 
with other sectors in the economy. However, some research suggests that 
not every industry is likely to suffer adverse effects from emissions 
pricing. For example, a long-run model estimated by Ho, Morgenstern, 
and Shih (2008) predicts that some U.S. sectors, such as services, may 
experience growth in the long run as a result of domestic emissions 
pricing.[Footnote 2] This growth would likely be due to changes in 
consumption patterns in favor of goods and services that are relatively 
less greenhouse gas-intensive. 

Potential international competitiveness effects depend in part on the 
stringency of U.S. climate policy relative to other countries. For 
example, if domestic greenhouse gas emissions pricing were to make 
emissions more expensive in the United States than in other countries, 
production costs for domestic industries would likely increase relative 
to their international competitors, potentially disadvantaging 
industries in the United States. As a result, some domestic production 
could shift abroad, through changes in consumption or investment 
patterns, to countries where greenhouse gas emissions are less 
stringently regulated. For example, consumers may substitute some goods 
made in other countries for some goods made domestically. Similarly, 
investment patterns could shift more strongly in favor of new capacity 
in countries where greenhouse gas emissions are regulated less 
stringently than in the United States. 

Stakeholders and experts have identified two criteria, among others, 
that are important in determining potential vulnerability to adverse 
competitiveness effects: trade intensity and energy intensity. Trade 
intensity is important because international competitiveness effects 
arise from changes in trade patterns. For example, if climate policy in 
the United States were more stringent than in other countries, 
international competition could limit the ability of domestic firms to 
pass increases in costs through to consumers. Energy intensity is 
important because the combustion of fossil fuels for energy is a 
significant source of greenhouse gas emissions, which may increase 
production costs under emissions pricing. 

Legislation passed in June 2009 by the House of Representatives, H.R. 
2454, 111th Cong. (2009), uses the criteria of trade intensity and 
energy intensity or greenhouse gas intensity, among others, to 
determine eligibility for the Emission Allowance Rebate Program, which 
is part of the legislation.[Footnote 3] H.R. 2454 specifies how to 
calculate the two criteria. Trade intensity is defined as the ratio of 
the sum of the value of imports and exports within an industry to the 
sum of the value of shipments[Footnote 4] and imports within the 
industry. Energy intensity is defined as the industry's cost of 
purchased electricity and fuel costs, or energy expenditures, divided 
by the value of shipments of the industry. 

Reducing carbon emissions in the United States could result in carbon 
leakage through two potential mechanisms. First, if domestic production 
were to shift abroad to countries where greenhouse gas emissions are 
not regulated, emissions in these countries could grow faster than 
expected otherwise. Through this mechanism, some of the expected 
benefits of reducing emissions domestically could be offset by faster 
growth in emissions elsewhere, according to Aldy and Pizer (2009). 
[Footnote 5] 

Second, carbon leakage may also arise from changes in world prices that 
are brought about by domestic emissions pricing. For example, U.S. 
emissions pricing could cause domestic demand for oil to fall. Because 
the United States is a relatively large consumer of oil worldwide, the 
world price of oil could fall when the U.S. demand for oil drops. The 
quantity of oil consumed by other countries would rise in response, 
increasing greenhouse gas emissions from the rest of the world. These 
price effects may be a more important source of carbon leakage than the 
trade effects previously described. 

Potentially Vulnerable Industries: 

Two key indicators of potential vulnerability to adverse 
competitiveness effects are an industry's energy intensity and trade 
intensity. Proposed U.S. legislation specifies that (1) either an 
energy intensity or greenhouse gas intensity of 5 percent or greater; 
and (2) a trade intensity of 15 percent or greater be used as criteria 
to identify industries for which trade measures or rebates would apply. 
Since data on greenhouse gas intensity are less complete, we focused 
our analysis on industry energy intensity. Most of the industries that 
meet these criteria fall under 4 industry categories: primary metals, 
nonmetallic minerals, paper, and chemicals. However, there is 
significant variation in specified vulnerability characteristics among 
different product groups ("sub-industries"). 

[End of section] 

Although our report examined the four industry categories, figures 1 
through 4 or the following pages illustrate the variation among 
different sub-industries within the primary metals industry, as well as 
information on the type of energy used and location of import and 
export markets.[Footnote 6] The data shown in these figures are for the 
latest year available. 

Figure 1: Energy and Trade Intensity Indicators for Primary Metals Sub- 
Industry Categories: 

[Refer to PDF for image: illustration] 

This illustration depicts a grid indicating the energy and trade 
intensity indicators for primary metals sub-industry categories. The 
grid plots trade intensity in percentage versus energy intensity in 
percentage. The following data is represented: 

Criteria for industry vulnerability: 
Trade intensity: about 15%; 
Energy intensity: about 5%. 

Sub-industry category: Primary metals; 
Value of output: [Empty] 
Trade intensity: about 40%; 
Energy intensity: about 6%. 

Sub-industry category: Steel manufacturing; 
Value of output: $19.9 billion; 
Trade intensity: about 10%; 
Energy intensity: about 3%. 

Sub-industry category: Aluminum products; 
Value of output: $16.7 billion; 
Trade intensity: about 10%; 
Energy intensity: about 4%. 

Sub-industry category: Ferrous metal foundries; 
Value of output: $20.1 billion; 
Trade intensity: about 10%; 
Energy intensity: about 6%. 

Sub-industry category: Iron and steel mills; 
Value of output: $93.2 billion; 
Trade intensity: about 36%; 
Energy intensity: about 8%. 

Sub-industry category: Electrometallurgical products; 
Value of output: $1.7 billion; 
Trade intensity: about 72%; 
Energy intensity: about 7%. 

Sub-industry category: Primary aluminum; 
Value of output: $6.7 billion; 
Trade intensity: about 62%; 
Energy intensity: about 24%. 

Source: GAO analysis of Department of Commerce energy data for 2006 and 
trade data for 2007. 

[End of figure] 

As shown by sub-industry examples in figure 1, energy and trade 
intensities differ within primary metals. For example, primary aluminum 
meets the vulnerability criteria with an energy intensity of 24 percent 
and a trade intensity of 62 percent. Ferrous metal foundries meets the 
energy intensity criteria, but not the trade intensity criteria. Steel 
manufacturing--products made from purchased steel--and aluminum 
products fall short of both vulnerability criteria. Iron and steel 
mills has an energy intensity of 7 percent and a trade intensity of 35 
percent and is by far the largest sub-industry example, with a 2007 
value of output of over $93 billion. The energy and trade intensity for 
all primary metal products is denoted by the "x" in figure 1. 

Figure 2: Type of Energy Used by Primary Metals Sub-Industry 
Categories: 

[Refer to PDF for image: stacked vertical bar graph] 

Share of 2002 total energy consumed in percentage of BTUs: 

Sub-industry category: Iron and steel mills; 
Coal and coke: 56.3%; 
Natural gas: 28.7%; 
Renewables and other: 2.3%; 
Net electricity: 12.7%. 

Sub-industry category: Electrometallurgical products; 
Coal and coke: 18.5%; 
Natural gas: 25.9%; 
Renewables and other: 11.1%; 
Net electricity: 44.4%. 

Sub-industry category: Steel manufacturing; 
Coal and coke: 0%; 
Natural gas: 53.3%; 
Renewables and other: 11.1%; 
Net electricity: 35.6%. 

Sub-industry category: Ferrous metal foundries; 
Coal and coke: 18.2%; 
Natural gas: 46.7%; 
Renewables and other: 2.4%; 
Net electricity: 32.7%. 

Sub-industry category: Aluminum; 
Coal and coke: 0%; 
Natural gas: 28.5%; 
Renewables and other: 30.7%; 
Net electricity: 40.8%. 

Source: GAO analysis of data from the Department of Energy. 

[End of figure] 

Among the primary metals sub-industry examples shown in figure 2, the 
types of energy used also vary. Iron and steel mills uses the greatest 
share of coal and coke, and steel manufacturing and ferrous metal 
foundries uses the greatest proportion of natural gas. Since coal is 
more carbon-intensive than natural gas, sub-industries that rely more 
heavily on coal could also be more vulnerable to competitiveness 
effects. The carbon intensity of electricity, used heavily in the 
production of aluminum, will also vary on the basis of the source of 
energy used to generate it and the market conditions where it is sold. 
Data shown for "aluminum" include primary aluminum and aluminum 
products, and net electricity is the sum of net transfers plus 
purchases and generation minus quantities sold. 

Figure 3: Source of Imports for Primary Metals Sub-Industry Categories: 

[Refer to PDF for image: stacked vertical bar graph] 

Share of 2007 total U.S. imports: 

Sub-industry category: Iron and steel mills; 
EU plus: 34.8%; 
Canada: 17.1%; 
China: 13.1%; 
Mexico: 7.5%; 
Brazil: 8.3%; 
Other: 19.2%. 

Sub-industry category: Electrometallurgical products; 
EU plus: 8.9%; 
Canada: 3.2%; 
China: 11.3%; 
Mexico: 0.9%; 
Brazil: 5.5%; 
Other: 70.2%. 

Sub-industry category: Steel manufacturing; 
EU plus: 19.3%; 
Canada: 13.7%; 
China: 36.9%; 
Mexico: 7.3%; 
Brazil: 0.7%; 
Other: 22.1%. 

Sub-industry category: Ferrous metal foundries; 
EU plus: 23%; 
Canada: 13.3%; 
China: 31.5%; 
Mexico: 5%; 
Brazil: 5.3%; 
Other: 21.9%. 

Sub-industry category: Primary aluminum; 
EU plus: 4.1%; 
Canada: 65.1%; 
China: 1.3%; 
Mexico: 1.3%; 
Brazil: 2.7%; 
Other: 25.5%. 

Sub-industry category: Aluminum products; 
EU plus: 17.1%; 
Canada: 32.6%; 
China: 33.9%; 
Mexico: 3.3%; 
Brazil: 0.6%; 
Other: 12.5%. 

Source: GAO analysis of data from the Department of Commerce. 

[End of figure] 

Industry vulnerability may further vary depending on the share of trade 
with countries that do not have carbon pricing. To illustrate this 
variability, figure 3 provides data on the share of imports by source, 
since imports exceed exports in each of the primary metals examples. As 
shown, while primary aluminum is among the most trade-intensive, the 
majority of imports are from Canada, an Annex I country with agreed 
emission reduction targets.[Footnote 7] For iron and steel mills, over 
one-third of imports are from the European Union and other Annex I 
countries, not including Canada ("EU plus"). However, for iron and 
steel mills, almost 30 percent of imports are also from the non-Annex I 
countries of China, Mexico, and Brazil. While less trade-intensive, 
steel manufacturing and aluminum products each has greater than one-
third of imports from China alone. 

Figure 4: Chinese Imports as Share of Primary Metals Sub-Industry 
Categories: 

[Refer to PDF for image: multiple line graph] 

Year: 2002; 
Iron and steel mills: 2.7%; 
Steel manufacturing: 11.4%; 
Aluminum products: 6.1%. 

Year: 2003; 
Iron and steel mills: 3%; 
Steel manufacturing: 15.6%; 
Aluminum products: 9.6%. 

Year: 2004; 
Iron and steel mills: 7.3%; 
Steel manufacturing: 20.1%; 
Aluminum products: 17.6%. 

Year: 2005; 
Iron and steel mills: 7.8%; 
Steel manufacturing: 27.6%; 
Aluminum products: 26.3%. 

Year: 2006; 
Iron and steel mills: 11.7%; 
Steel manufacturing: 33.7%; 
Aluminum products: 34.2%. 

Year: 2007; 
Iron and steel mills: 13.1%; 
Steel manufacturing: 36.9%; 
Aluminum products: 33.9%. 

Total U.S. imports by value (U.S. dollars in millions): 

Iron and steel mills: 
2002: $12,558; 
2003: $10,808; 
2004: $23,355; 
2005: $25,131; 
2006: $33,060; 
2007: $30,445. 

Steel manufacturing 
2002: $1,110; 
2003: $1,184; 
2004: $1,792; 
2005: $1,884; 
2006: $1,916; 
2007: $1,822. 

Aluminum products 
2002: $498; 
2003: $549; 
2004: $718; 
2005: $913; 
2006: $1,209; 
2007: $1,183. 

Source: GAO analysis of data from the Department of Commerce. 

[End of figure] 

As shown in figure 4, adverse competitiveness effects from emissions 
pricing could increase the already growing share of Chinese imports 
that exists in some of the sub-industries. Among the examples, iron and 
steel mills, steel manufacturing, and aluminum products exhibit a 
growing trade reliance on Chinese imports since 2002. This trend has 
largely been driven by lower labor and capital costs in China, and, 
according to representatives from the steel industry, China has 
recently been producing 50 percent of the world's steel. 

Mr. Chairman, this concludes my prepared statement. Thank you for the 
opportunity to testify before the Committee on some of the issues 
addressed in our report on the subject of climate change trade 
measures. I would be happy to answer any questions from you or other 
members of the Committee. 

Contacts and Acknowlegments: 

For further information about this statement, please contact Loren 
Yager at (202) 512-4347 or yagerl@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this statement. Individuals who made key contributions 
to this statement include Christine Broderick (Assistant Director), 
Etana Finkler, Kendall Helm, Jeremy Latimer, Maria Mercado, and Ardith 
Spence. 

[End of section] 

Footnotes: 

[1] GAO, Climate Change Trade Measures: Considerations for U.S. 
Policymakers, [hyperlink, http://www.gao.gov/products/GAO-09-724R] 
(Washington, D.C.: July 8, 2009). 

[2] Ho, Mun S., Richard Morgenstern, and Jhih-Shyang Shih. (November 
2008) "Impact of Carbon Price Policies on U.S. Industry." RFF 
Discussion Paper No. 08-37, Resources for the Future, Washington, D.C. 

[3] Proposed legislation specifies that, in addition to trade 
intensity, either energy intensity or greenhouse gas intensity should 
be considered. 

[4] An industry's value of shipments represents its value of output. 

[5] Aldy, Joseph E. and Pizer, William A. (May 2009) "The 
Competitiveness Impacts of Climate Change Policies." Pew Center on 
Global Climate Change, Arlington, VA. 

[6] For examples in nonmetallic minerals, paper, and chemicals, as well 
as further information on data sources and our methodology, see 
[hyperlink, http://www.gao.gov/products/GAO-09-724R]. 

[7] Annex I countries are parties to the United Nations Framework 
Convention on Climate Change that are industrialized countries and were 
members of the Organization for Economic Cooperation and Development in 
1992, plus countries characterized as economies in transition. 

[End of section] 

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