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GAO-10-851R: 

United States Government Accountability Office: 
Washington, DC 20548: 

August 19, 2010: 

The Honorable Darrell Issa: 
Ranking Member: 
Committee on Oversight and Government Reform: 
House of Representatives: 

Subject: Carbon Trading: Current Situation and Oversight 
Considerations for Policymakers: 

Dear Mr. Issa: 

This letter transmits to you our briefing slides in response to your 
request concerning carbon trading in the United Sates and various 
design and implementation issues to be considered in discussions about 
a possible national carbon trading program. Industrial activities in 
the United States emit significant amounts of carbon dioxide and other 
greenhouse gases each year, substantially affecting the earth's 
climate, according to the National Academy of Sciences. In an effort 
to reduce these emissions, some have suggested capping emissions and 
allowing them to be traded in secondary markets just as other 
commodities are traded. We briefed your committee staff on the results 
of our work on July 23, 2010. Specifically, we provided information on 
(1) carbon-related products currently traded in the United States and 
the extent of trading; (2) risks and challenges posed by these 
products; (3) the extent to which and how these products are 
regulated; and (4) issues that market observers identified for 
policymaker consideration as part of creating a national cap-and-trade 
carbon market. The attached briefing slides were updated to reflect 
additional information as discussed during the briefing, including how 
carbon products are also subject to political and regulatory risk and 
how they are treated under laws applicable to transactions in 
commodities. 

We reviewed publicly available reports, congressional testimonies, and 
federal laws; reports from GAO, Congressional Research Service, and 
the Congressional Budget Office; studies and reports from several 
professional associations, World Bank, and academics; and information 
from, among others, the Commodity Futures Trading Commission (CFTC), 
Chicago Climate Exchange, Chicago Climate Futures Exchange, New York 
Mercantile Exchange (NYMEX), and European Climate Exchange. We also 
met with knowledgeable staff at CFTC and the U.K Financial Services 
Authority, industry associations, U.S. and European exchanges, a 
carbon emitter, financial institution, and academics known as experts 
on carbon trading. 

We conducted this performance audit from April 2010 to August 2010, in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Summary: 

Various carbon products are traded in the United States, but volumes 
have been small compared to other commodity markets. The products 
traded include carbon allowances, which entitle the holder to emit a 
specific amount of a greenhouse gas, and carbon offsets, which are 
measurable reductions of greenhouse gas emissions from an activity or 
project in one location that are used to compensate for emissions 
occurring elsewhere.[Footnote 1] Derivatives on carbon products are 
also traded in the United States, including primarily futures 
contracts.[Footnote 2] Although no official measure of volume of 
trading exists, various sources estimated that from $2.4 billion to 
$2.7 billion of carbon products traded in United States in 2009, with 
offsets accounting for around $74 million.[Footnote 3] U.S. carbon 
trading volumes appear to have fallen sharply in 2010, with volumes of 
RGGI allowances trading at around 15 percent of their 2009 levels as 
of June 2010. 

Carbon product trading poses various risks and challenges that were 
similar to those found in other commodity markets. For example, carbon 
products pose market risk, which is the exposure to losses from 
changes in product prices. Similarly, carbon product markets face the 
risk of potential manipulation and fraud. Although no fraud involving 
carbon products has been identified in the United States since 2001, 
carbon products traded in Europe have been part of several fraudulent 
activities, including those involving value-added tax violations. 
Carbon markets could be significantly affected by political or 
regulatory changes after implementation of any U.S. cap-and-trade 
program, but market observers noted that this risk could be mitigated 
by including elements in the program that increased certainty of its 
duration and features. 

Under the Commodity Exchange Act (CEA) carbon emissions are considered 
to be an "exempt commodity." Before Congress amended the CEA in the 
recently enacted Dodd-Frank Wall Street Reform and Consumer Protection 
Act (Dodd-Frank Act, Pub. L. No. 111-203), derivatives on exempt 
commodities were eligible for limited oversight by the primary U.S. 
commodities regulator, CFTC. They could be traded between qualified 
parties on an over-the-counter (OTC) basis generally free from CFTC 
regulation.[Footnote 4] CFIV's authority over such trading was limited 
to instances in which CFTC suspected fraud or manipulation. Although 
typical transactions in carbon emissions qualified for OTC trading, to 
date market participants have traded carbon products mostly on 
exchanges subject to CFIV's full authority. The Dodd-Frank amendments, 
which are not yet in effect, replaced this regime with clearing 
requirements and other requirements intended to increase transparency 
of the OTC derivatives market and reduce the potential for 
counterparty and systemic risk. The amendments provide an exemption 
from clearing, exchange trading, and other requirements for 
counterparties that qualify as end users. 

The market participants, academics, regulators, and other market 
observers that we spoke with identified several issues for 
policymakers' consideration in the event that the United States 
implements a national cap-and-trade program. Some noted that the 
design of the primary carbon market can significantly affect the 
secondary carbon market. For example, the liquidity of trading in the 
secondary markets could be limited if emissions caps are set too high 
or if emitters are not allowed to hold or "bank" emissions allowances 
for future use. Observers also saw value to allowing both exchange-
based and OTC carbon trading as a way to increase the ability of 
participants to manage their specific risks and allow for innovation, 
although the recent financial crisis highlighted that OTC trading can 
create credit exposures that can sometimes pose systemic concerns if 
overly concentrated. Given these risks, effective oversight of 
secondary market trading under a national cap-and-trade program may 
depend on the adequacy of CFIV's surveillance authority and its level 
of resources. The Dodd-Frank Act requires that an interagency working 
group to be chaired by the CFTC Chairman study the oversight of 
existing and prospective carbon markets to ensure an efficient, 
secure, and transparent carbon market.[Footnote 5] 

Conclusions and Recommendation for Executive Action: 

Although carbon products pose risks similar to those posed by other 
commodities traded currently, the potential for the existence of 
fraudulent activities reinforces the importance of ensuring that any 
trading associated with a national cap-and-trade program is adequately 
regulated. The study of the interagency working group called for in 
the Dodd-Frank Act offers an opportunity to further explore and better 
understand how one would develop an efficient, secure, and transparent 
carbon trading market. Having this group consider the issues we 
identified relating to alternative designs of the primary and 
secondary markets and the regulatory oversight of these markets would 
be helpful in making any decisions on the design and oversight of 
existing and prospective carbon markets. 

We recommend that the Chairman of the CFTC ensure that the interagency 
working group created by the Dodd-Frank Act explores (1) how the 
design of any primary carbon market could affect the liquidity of any 
secondary market trading; (2) the structure of the secondary market, 
including the role OTC markets may play in carbon trading; and (3) the 
resources federal regulators may need to effectively oversee domestic 
carbon markets. 

Agency Comments: 

We provided CFTC a draft of this report for review and comment. In an 
e-mail the CFIV's Senior Counsel, Legislative Affairs, stated that the 
issues we highlighted in our report will be raised and considered 
during further study of carbon trading. CFTC also provided technical 
comments, which we incorporated as appropriate. 

As arranged with your office, unless you publicly announce the 
contents of this report earlier, we plan no further distribution until 
30 days from the report date. At that time, we will send copies to the 
Chairman, CFTC, and interested congressional committees. This report 
will be available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have questions regarding this report, please 
contact me at (202) 512-8678 or williamso@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Key contributors are listed in 
enclosure II. 

Sincerely yours, 

Signed by: 

Orice Williams Brown: 
Director, Financial Markets and Community Investment: 

Enclosures--2: 

Enclosure I: Briefing to the Ranking Member, House Committee on 
Oversight and Government Reform: 

Briefing for Ranking Member, House Committee on Oversight and 
Government Reform: 

Carbon Trading: Current Situation and Oversight Considerations for 
Policymakers: 

Briefing Outline: 
* Introduction; 
* Objectives; 
* Scope and Methodology; 
* Summary of Findings; 
* Background; 
* Findings; 
* Conclusions and Recommendation for Executive Action; 
* Attachment I—Additional Details on European Emission Credits, 
Allowances, and Trading Associated with Them; 
* Attachment II—States Included in U.S. Regional Cap-and-trade 
Programs. 

Introduction: 

Industrial activities in the United States emit significant amounts of 
carbon dioxide (CO2) and other greenhouse gases each year that have 
substantial effects on the earth's climate, according to the National 
Academy of Sciences. 

Some have suggested that these emissions could be priced and traded as 
a commodity as part of a broader effort to efficiently reduce national 
carbon emissions, known as cap-and-trade. 

A cap-and-trade system for sulfur dioxide (SO2) began in 1995 and has 
been in use in Europe since 2005 for greenhouse gases. 

Pending legislation in Congress would establish a cap-and-trade system 
for greenhouse gas emissions in the United States. 

Carbon trading is seen as a cost-efficient way to control greenhouse 
gases, but also raises a number of potential concerns and uncertainty 
about how to ensure that such trading is effectively overseen and 
regulated. 

Ranking Member Issa of the House Committee on Oversight and Government 
Reform asked us to study the viability of a carbon offset market and 
evaluate whether the government was prepared to manage and oversee it. 
This briefing examines factors to consider in designing and regulating 
a national secondary carbon trading market. As part of this request, 
GAO will report on the design of carbon offsets. 

A carbon offset is a measurable reduction of greenhouse gas emissions 
from an activity or project in one location that is used to compensate 
for emissions occurring elsewhere. 

* Offsets are typically quantified in metric tons-2,205 pounds—of 
carbon dioxide equivalent. 

* An example of an offset project is a system at a waste disposal 
landfill that captures the landfill 's methane, which is a greenhouse 
gas. 

For the purpose of this briefing, the primary market is the point at 
which emission allowances would be distributed and offsets are 
created. In the secondary market, participants purchase the emission 
allowances and carbon offset credits or conduct transactions involving 
derivatives relating to carbon products. 

[End of section] 

Objectives: 

1. What carbon-related products are currently traded in the United 
States, and what is the extent of trading? 

2. What risks and challenges do these products pose? 

3. To what extent and how are these products regulated? 

4. What issues were identified by market observers for policymaker 
consideration as part of creating a national carbon market? 

[End of section] 

Scope and Methodology: 

We reviewed documentary evidence, including: 

* publicly available reports, congressional testimonies, and federal 
laws; 

* reports from GAO, Congressional Research Service, and the 
Congressional Budget Office; 

* studies and reports from several professional associations, World 
Bank, and academics; and; 

* information from, among others, Commodity Futures Trading Commission 
(CFTC), Chicago Climate Exchange, Chicago Climate Futures Exchange, 
New York Mercantile Exchange (NYMEX), and European Climate Exchange. 

We interviewed market observers, including officials and staff from 
organizations currently participating in or researching carbon 
markets, including: 

* domestic and international regulators (CFTC and the U.K. Financial 
Services Authority); 

* industry association groups (International Emissions Trading 
Association and International Swaps and Derivatives Association); 

* U.S. and European exchanges; and; 

* academics known as experts on carbon trading. 

We conducted this performance audit from April 2010 to August 2010, in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Summary of Findings: 

A variety of carbon products currently trade in the United States, but 
trading volumes are small, and most trades take place on organized 
exchanges rather than in over-the-counter (OTC) markets. 

Carbon products traded in the U.S. carbon markets have risks similar 
to those posed by other commodity products and have experienced 
problems (including fraud) domestically and internationally. The risk 
that political or regulatory changes could affect the carbon markets 
was a concern, but market observers noted it could be mitigated in the 
program's design. 

Most of the carbon trading to date in the United States has occurred 
on regulated futures markets and is subject to the regulatory 
jurisdiction of CFTC. 

Market observers in the United States and elsewhere identified several 
issues for consideration by policymakers relating to the design and 
regulation of a carbon market if the United States creates a national 
cap-and-trade program. 

[End of section] 

Background: 

Under cap-and-trade programs, governments reduce the overall amount of 
greenhouse gas emissions by granting regulated entities limited 
allowances to emit and allowing the entities to trade allowances among 
themselves. 

* Each allowance represents a set quantity of greenhouse gas 
emissions, such as 1 metric ton. Regulated entities, must surrender 
enough allowances for all of their emissions at the end of specified 
time periods. 

* Regulated entities need to hold allowances for their emissions and 
each allowance would entitle them to emit a specific amount of a 
greenhouse gas. 

* Governments distribute carbon allowances in the primary market by 
selling them, distributing them for free to regulated entities, or 
both. 

* If a regulated entity's emissions exceeds the number of carbon 
allowances it receives or purchases in the primary market, it can 
purchase additional allowances in the secondary market or, if the cap-
and-trade program allows it, purchase carbon offset credits. 

* Carbon offset credits can be serialized and accounted for in a 
registry or other approved tracking system to help ensure that they 
are traded and transferred legitiff1ately. For example, a centralized 
registry can be used to help prevent double counting of offset credits. 

The European Union has a cap-and-trade program for certain sectors, 
but currently the United States has only a regional cap-and-trade 
program that limits emissions from certain power plants in 
participating states. 

* The European Union created its Emission Trading Scheme (ETS) to help 
EU member states meet their Kyoto Protocol commitments. The protocol 
set binding emissions targets for 37 industrialized countries and the 
European Community to achieve between 2008 and 2012. 

* Under the Kyoto Protocol's Clean Development Mechanism, countries 
with binding emission targets can implement projects that reduce or 
avoid emissions—such as the construction of infrastructure for 
renewable energy (e.g., wind, solar, renewable fuels) projects—in a 
developing country that does not have a binding emissions target under 
the protocol. These projects earn Certified Emissions Reduction 
credits (carbon offsets) that an industrialized country sponsoring the 
project can sell or use to comply with its Kyoto target. These 
credits, along with carbon allowances and derivatives on those 
allowances, are traded on several markets. (See attachment I for more 
detail.) 

* The industrialized countries' Kyoto Protocol emissions targets are 
tracked in national registry systems. As of May 2010, there were 37 
national registries, an European Community registry, and a Clean 
Development Mechanism registry, which is used to issue and distribute 
the offset credits generated under that mechanism to the national 
registries. 

* The ETS currently covers emissions from power plants; certain 
industrial sectors, such as oil refining, cement, and glass; and 
aviation. 

Currently, the United States has one regional cap-and-trade program in 
operation, but other regional cap-and-trade programs are in various 
stages of development. 

* The Regional Greenhouse Gas Initiative (RGGI) was created in 2005 
and regulates the carbon dioxide emissions of large fossil fuel 
electricity generators in 10 participating northeastern and mid-
Atlantic states. 

* Other states are currently developing regional greenhouse gas 
initiatives. The Midwestern Greenhouse Gas Reduction Accord is an 
agreement among six midwestern states and one Canadian province to 
establish a greenhouse gas reduction program. The Western Climate 
Initiative is a collaboration among seven states and four Canadian 
provinces that aims to tackle climate change through a regional cap-
and-trade program and other initiatives. (See attachment II for the 
members of each regional program). 

Regulators told us that emission reduction programs depend on the 
timely registration of carbon allowances and offsets in registries. 
Existing registries include, among others: 

* The Climate Registry, a nonprofit collaboration among North American 
states, provinces, territories, and Native Sovereign Nations that sets 
standards to calculate, verify, and publicly report greenhouse gas 
emissions. 

* The California Climate Action Registry, a program of the Climate 
Action Reserve that serves as a voluntary greenhouse gas registry to 
protect and promote early actions to reduce greenhouse gas emissions 
by organizations. 

[End of section] 

Findings: 

1. Current Carbon Trading: 

In the absence of a national cap-and-trade program, the volume of 
carbon trading in the United States has been modest. 

No centralized official measure of market volumes exists, but the 
World Bank and Point Carbon, an industry tracking firm, estimated the 
value of the total U.S. carbon market at around $2.4 billion to $2.7 
billion in 2009. 

* In the allowance market, the World Bank estimates that in the ETS, 
$119 billion worth of allowances and derivatives changed hands in 
2009, compared to about $2.2 billion in the United States ($50 million 
on the Chicago Climate Exchange and $2.18 billion in RGGI). In a 
recent report, Point Carbon found that the volume of RGGI allowances 
traded in the first half of 2010 was less than 15 percent of RGGI 
allowances traded in all of 2009. 

* In the offset market, Point Carbon estimates that in 2009, offsets 
purchased by organizations located in the United States represented 
0.2 percent of the global carbon offset market, or approximately $74 
million. 

Of the trading that occurs in the U.S. carbon market, offsets, which 
tend to be unique transactions, are generally traded on OTC markets, 
while allowances, which are more standardized products, are generally 
traded on exchanges. 

* Bilateral OTC markets allow eligible parties to enter into bilateral 
contracts directly, without using an exchange. In the carbon market, 
OTC contracts are made predominantly between emitters and liquidity 
providers, such as financial intermediaries. 

* In 2009, the value of the OTC/bilateral offset market was 
approximately $64 million of the $74 million market total, according 
to Point Carbon, with exchange trading accounting for the remaining 
$10 million. 

Various types of allowances, offsets, and other carbon products are or 
expected to be traded in the United States. 

Allowances are traded as part of various mandatory and voluntary 
programs. 

* For example, electric power generators covered by RGGI and others 
can buy, sell, and trade emissions allowances. 

* In a voluntary market active in the United States, participants on 
the Chicago Climate Exchange agree to limit their emissions to certain 
levels. They are then issued certain numbers of standardized carbon 
financial instruments, each representing 100 metric tons of CO2 
equivalent that exchange participants can trade among themselves. 

Offsets are also traded as part of these programs in the United States. 

* By registering an offset project with the Chicago Climate Exchange, 
members can receive Carbon Financial Instruments they can trade on 
that exchange. 

* The Climate Action Reserve in California is a voluntary offsets 
program that issues carbon offset credits known as "climate reserve 
tonnes," which can be registered and traded among the reserve's 
participants nationwide. 

* RGGI allows offsets that can be used for compliance, but to date 
allowances have been sufficient to meet current demand, and no offsets 
have been issued. 

Derivatives are traded on underlying allowances and offsets. 

To facilitate efficient trading and risk management, derivatives, 
including futures contracts and other products, are traded on U.S. 
carbon products. 

* Futures are agreements to purchase or sell a commodity for delivery 
in the future. Like other types of derivatives, their prices are based 
on the value of an underlying commodity. 

* For example, a subsidiary of Chicago Climate Exchange—the Chicago 
Climate Futures Exchange—trades futures that call for the future 
delivery of Chicago Climate Exchange's carbon financial instruments. 
This exchange also trades futures on RGGI allowances and Climate 
Action Reserve's climate reserve tonnes offsets. Another exchange, 
NYMEX's Green Exchange Venture (Green Exchange), also trades futures 
on RGGI allowances and climate reserve tonnes. 

* The Chicago Climate Futures Exchange and the Green Exchange also 
trade futures on Certified Emission Reduction credits, and the Green 
Exchange trades futures on EU allowances. 

Options contracts are traded on U.S. carbon exchanges. 

* Options allow a purchaser the right, but not the obligation, to buy 
or sell a specified amount of the underlying asset for a specified 
price within a specified time in the future. 

* The Chicago Climate Futures Exchange trades options and futures. The 
Green Exchange also trades options on the same products it uses for 
futures contracts. 

Derivatives, including forward contracts and options, are also traded 
in OTC markets. 

* Forwards are non-standardized contracts that obligate the seller to 
deliver assets to the buyer at a predetermined time in the future at 
an agreed-upon price. 

* Options can also be customized and traded off exchange in OTC 
markets. 

* None of the sources we reviewed provided a clear estimate of the 
extent to which forward contracts and options on carbon products are 
traded OTC. 

Adopting a mandatory cap-and-trade program in the United States could 
create the largest carbon market in the world. 

According to two industry observers, the sheer size of the U.S. 
economy means that if the United States established a mandatory cap-
and-trade program, the resulting market for carbon emissions products 
would become the largest in the world, attracting traders from around 
the globe. 

2. Risks and Challenges: 

Trading carbon offset credits and other products poses market, credit, 
and operational risks similar to those in other commodity markets, 
although political risk can also be a concern. 

Market risk arises from changes in asset prices. 

* Prices of carbon products fluctuate because of changes in supply and 
demand, economic conditions, and costs of carbon abatement. 

* Some academics noted that carbon markets could have significant 
price volatility. 

- According to one economist, carbon prices are prone to extreme 
volatility because the supply of allowances is relatively fixed and 
the demand for allowances changes little in the short run. 

- Large price swings can result from unanticipated changes in economic 
activity, weather, fuel prices, or technological developments. 

Carbon products also can present credit and operational risks. 

* Credit risk is the potential for a seller to fail to meet its 
obligations in accordance with agreed terms. 

* Carbon products could produce operational risk losses if a holder 
does not have adequate internal risk management or other systems in 
place. 

Trading in carbon products could also be affected by the risk of 
political or regulatory uncertainty. 

* Trading volumes, prices, and the number of participants willing to 
trade could fall if certain legislative, regulatory, or legal actions 
significantly changed the design and implementation of a U.S. cap-and-
trade program. 

* Market participants said that political and regulatory uncertainty 
would have to be mitigated by designing a U.S. cap-and-trade program 
that has a long time frame, no early sunset provisions, and other 
elements that increase the certainty of the program's structure or 
that reduce the potential for significant changes after implementation. 

Like other financial products, market manipulation would be a risk in 
carbon markets. 

* As with any commodity product, allowances could be subject to 
attempts to amass positions with the intent of manipulating prices. 
Participants may attempt to artificially reduce supply, particularly 
if not enough allowances are available for trading. 

* For example, a trader might attempt to "corner" the market by 
amassing a large inventory of allowances while simultaneously taking 
futures or forward positions that required others to make delivery to 
it. As a result, other traders with delivery obligations that they 
must fulfill are "squeezed" into buying from the manipulator at 
inflated prices. 

* CFTC staff and academics we interviewed told us that while the risk 
of market manipulation exists, it would not be unique to carbon 
trading and also exists in the trading of other commodity products. 

* According to one economist, the risk of cornering the carbon 
allowance market would likely be low, provided a large volume of 
allowances is available and demand for them is widespread, making it 
difficult for any one participant to accumulate enough to manipulate 
prices. 

As with other commodities, carbon trading is not immune to fraudulent 
activities. 

Market observers we interviewed told us that recent types of fraud are 
not unique to carbon but can happen in any newly traded product market. 

* Although regulators have not identified any recent fraud in the 
United States, from 1999 through 2001, an emissions trader ran a Ponzi 
scheme involving California's pollution trading program. Such schemes 
involve paying purported returns to existing investors from funds 
contributed by new investors. According to one market observer, these 
schemes may be more likely to occur in newly created markets, because 
potential investors do not fully understand how the markets operate. 

* Some market observers told us that carbon products were recently 
subject to carousel fraud relating to the value added tax systems used 
in various European countries. In these cases, parties bought carbon 
allowances in one country without paying tax and sold them in another 
country, pocketing the tax included in the price of the allowance. 

* In 2010, another fraud in Germany involved use of a "phishing" 
scheme (using false e-mail and a fake Web site) to obtain carbon 
trading account information for individual accounts on national carbon 
registries that were part of the ETS. The rogue traders were able to 
carry out a number of transactions before they were discovered. 

* Other fraud cases involving carbon products can also occur under cap-
and-trade programs, such as reselling offset credits that have already 
been surrendered for compliance or that do not represent verified 
emissions reductions. As noted above, no such cases have been 
identified in the United States. 

* Several national audit offices told us that they were planning to 
conduct reviews of carbon trading activities soon. 

3. Current Regulation: 

Carbon emissions are considered to be an "exempt commodity" under the 
Commodity Exchange Act and the primary U.S. commodities products 
regulator—CFTC—will have limited authority to act over any OTC trading 
until a more extensive regulatory regime takes effect for OTC 
transactions under the Dodd-Frank Act. 

* Exempt commodities include all commodities other than those 
specifically designated in law as agricultural (such as corn or wheat) 
or as excluded (such as interest rates or currencies). 

* For exempt commodities trading on an OTC basis, CFTC can only act if 
it suspects fraud or manipulation is occurring. 

However, the majority of trading in carbon products in the United 
States to date has been of products traded on a fully-regulated 
futures exchange over which CFTC has full authority. 

* As noted earlier, most of the carbon trading in the United States 
has occurred through the RGGI futures contract traded on the Chicago 
Climate Futures Exchange. 

* Because this market is registered with CFTC as a designated contract 
market, it is subject to the full range of CFTC oversight. 

* For trading on designated contract markets, CFTC can take various 
steps to detect fraudulent or abusive trading practices, including 
daily monitoring of electronic trading. It can also perform 
examinations of these exchanges and their members' activities and 
require participants to provide reports of activities to CFTC. 

Carbon products traded on an OTC basis are subject to more limited or 
no CFTC oversight, depending on how trades occur. 

* Trades on the Chicago Climate Exchange are considered part of the 
OTC market and are subject to more limited CFTC oversight. 

- The Chicago Climate Exchange is registered as an exempt commercial 
market (ECM), which is an OTC electronic trading facility for 
commodities that are not specifically named in law as agricultural or 
as excluded commodities. Trades on this market are allowed between 
eligible commercial entities, which are large, sophisticated 
participants that trade on a principal-to-principal basis. 

- CFTC's authority over trading on an exempt commercial market like 
the Chicago Climate Exchange is more limited than its authority over 
designated contract markets. Transactions on an exempt commercial 
market generally are not subject to substantive regulation by CFTC or 
its enforcement jurisdiction, except for its fraud and manipulation 
authority. However, if CFTC determines that a contract has a 
significant price discovery function (i.e., is used by other market 
participants to determine the price for a commodity) it can subject 
the ECM to extensive CFTC oversight and responsibilities with respect 
to that contract. 

- CFTC cannot routinely examine or require periodic reporting from 
ECMs or their participants that are trading products not determined to 
perform a significant price discovery function. 

- CFTC can request information on trading on ECMs if it receives 
allegations of fraud or suspects manipulation. 

* CFTC does not oversee other OTC trading and does not oversee 
distribution of allowances and offsets in the primary markets, 
although it could seek information and take action in the event of 
perceived attempts to manipulate the prices of the carbon futures on 
the two U.S. designated contract markets over which it has authority. 

Other authorities could act in the event of problems relating to 
carbon products. 

* Unlawful activities associated with carbon products could be subject 
to actions by the Federal Trade Commission (FTC) and/or criminal/civil 
law enforcement agencies such as the Department of Justice (DOJ) and 
state authorities. For example, a fraudulent scheme involving carbon 
offsets might constitute an anticompetitive or unfair trade practice 
subject to FTC jurisdiction or anticompetitive or criminal conduct 
subject to the jurisdiction of DOJ and state authorities. 

* As a result of the Dodd-Frank Wall Street Reform and Consumer 
Protection Act (Pub. L. No. 111-203, title VII), CFTC will provide 
greater oversight of many OTC derivative products, including carbon 
products. The Dodd-Frank Act that was recently signed into law 
includes various provisions that would change requirements applicable 
to OTC derivatives and generally would require standardized contracts 
to be cleared on central clearinghouses.[Footnote 6] 

4. Design and Regulatory Issues for Any National Cap-and-Trade Carbon 
Market: 

Market observers we spoke with noted several issues associated with 
the design of the primary carbon market that could affect the success 
of secondary trading of carbon products in the financial markets. 

* The level at which emissions caps are set in primary markets can 
affect secondary markets' liquidity (the ability to buy or sell 
without causing large price movements). For example, in Phase I of the 
ETS, market observers said that the cap was set too high, and trading 
and prices declined significantly with the onset of the current 
recession. 

* Allowing participants to hold or "bank" allowances or having the 
allowances expire after a certain time period could also affect 
secondary market trading. Allowing the banking of allowances can, 
among other things, allow for longer-term financial products. 

* Ensuring that adequate and timely requirements are in place to 
register allowances also could help maintain the integrity of the 
secondary market for carbon products, CFTC staff, several economists, 
and exchange officials noted that providing timely information to 
recognized carbon registries would be necessary to ensure that 
allowances and offsets were not used more than once. For example, the 
Hungarian government resold surrendered credits. These duplicative 
transactions have been unwound, and regulation has been enhanced to 
prevent this type of error from occurring again. 

Market participants and observers supported allowing carbon products 
to be traded in OTC markets as well as exchanges. 

Various market observers we spoke with supported allowing wide 
participation in the markets as a way of increasing liquidity and saw 
allowing carbon products to be traded on OTC markets as well as on 
exchanges as a way of increasing participation. 

* OTC markets may allow for emitters to become innovative at managing 
their risks. According to market observers and participants, when the 
EU markets were being developed, the OTC markets helped facilitate 
innovation and risk management. 

* OTC markets allow for customized contracts, variable collateral 
requirements, and the ability to negotiate prices bilaterally. 

- Market observers noted that having OTC markets would allow 
counterparties the flexibility to structure nonstandardized contracts. 
For example, most exchange-traded futures contracts trade only a 
limited number of years into the future (typically 3-5 years), but in 
some cases, contracts may need to be extended several years or decades. 

- OTC markets could attract a wide range of participants, increasing 
the capital available to the carbon markets. 

Although offering benefits, OTC activities can also pose risks, 
including systemic risk, counterparty credit risk, and concentration 
risk. Our recent work involving credit default swaps illustrated that 
OTC markets can lack transparency that creates uncertainty over the 
levels of risks in such markets and the extent to which risk exposures 
are concentrated.[Footnote 7] 

Additional mechanisms to better ensure effective oversight and 
interagency coordination could be important to the success of U.S. 
carbon markets. 

* Because CFTC does not have clear authority to act over all trading 
activities, carbon markets might not be effectively overseen and 
regulated. Our work examining issues related to credit default swaps 
indicated that having multiple regulators that individually lacked 
complete authority hampered U.S. regulators' efforts to monitor and 
manage the potential systemic risk arising from those products. 

* Sufficient CFTC resources would be needed to ensure effective 
oversight of a carbon market. CFTC officials told us that while their 
agency would be able to leverage its existing surveillance system, it 
would need more people and more resources to oversee the volume of 
trading likely to develop under a national cap-and-trade program. 

* In addition to CFTC, other agencies are likely to have important 
roles in a national cap-and-trade program, such as the Environmental 
Protection Agency, which might administer the primary market, and the 
U.S. Department of Agriculture, which could be involved in 
administering certain agricultural offsets. 

* U.S. regulators that must cooperate with other domestic or 
international bodies often use formal memorandums of understanding to 
specify how such interactions occur. 

- CFTC has such memorandums with such entities as the Securities and 
Exchange Commission and with foreign commodities regulators. 

* Although CFTC staff told us that they are already coordinating with 
the U.S. Department of Agriculture and the Environmental Protection 
Agency, it has yet to establish such memorandums with these agencies. 

* Section 750 of the Dodd-Frank Act requires that an interagency 
working group conduct a study on the oversight of existing and 
prospective carbon markets to ensure an efficient, secure, and 
transparent carbon market, including oversight of spot markets and 
derivative markets. 

* This interagency group is to be chaired by the Chairman of CFTC and 
includes the Secretary of Agriculture, the Secretary of the Treasury, 
the Chairman of the Securities and Exchange Commission, the 
Administrator of the Environmental Protection Agency, the Chairman of 
the Federal Energy Regulatory Commission, the Commissioner of the 
Federal Trade Commission, and the Administrator of the Energy 
Information Administration. 

[End of section] 

Conclusions and Recommendation for Executive Action: 

Conclusions: 

* Trading of carbon products has been limited to date in the United 
States. Our work identified various issues that require further 
exploration as part of the debate surrounding the creation of a 
national mandatory cap-and-trade program. 

* Although carbon products pose risks similar to those posed by other 
commodities that are traded currently, the potential for fraudulent 
activities reinforces the importance of ensuring that any trading 
associated with a national cap-and-trade program is adequately 
regulated. 

* The study of the interagency working group called for in the Dodd-
Frank Act offers an opportunity to further explore and better 
understand how to develop an efficient, secure, and transparent carbon 
trading market. Although its mandated areas for study were broad, 
having this group consider the issues identified in this briefing 
relating to alternative designs for the primary and secondary markets 
and the regulatory oversight of these markets would be helpful in 
making any decisions on the design and oversight of existing and 
prospective carbon markets. 

Recommendation for Executive Action: 

In his capacity as chair of the working group addressing the design 
and regulation of carbon markets under a national cap-and-trade 
program, we recommend that the CFTC Chairman explore (1) how the 
design of any primary carbon market could affect the liquidity of any 
secondary market trading; (2) the structure of the secondary market, 
including the role OTC markets may play in carbon trading; and (3) the 
resources federal regulators may need to effectively oversee domestic 
carbon markets. 

[End of section] 

Attachment I: Additional Details on European Emission Allowances, 
Kyoto Protocol Clean Development Mechanism Offset Credits, and Trading 
Associated with Them: 

Certified Emission Reduction credits (CER) generated by Clean 
Development Mechanism projects can be used by industrialized countries 
to meet their Kyoto targets. Regulated entities can also use a limited 
amount of CERs to satisfy their compliance obligations under the EU 
Emission Trading Scheme (ETS). 

* Each CER is equivalent to 1 metric ton of carbon dioxide. 

* CERs are issued for projects that meet several key requirements, 
including review by national officials of the country where the 
project occurs and independent validation of the emission. reduction. 

Countries participating in the ETS issue EU allowances (EUA). 

* EUAs are tradable emissions allowances that regulated entities can 
surrender to cover emission of 1 ton of carbon dioxide equivalent. 

* The amount of EUAs allocated to regulated entity is set out in 
national allocation plans prepared by the member states. 

Kyoto Protocol emission targets for industrialized countries are 
expressed as levels of allowed emissions, or assigned amounts units 
(AAU). Under the protocol's emission trading mechanism, AAUs can be 
traded. Each AAU equates to one ton of CO2 equivalent. Because the 
United States is not a party to the protocol, it does not have AAUs 
and is not eligible to trade them. 

Intercontinental Exchange (ICE) Futures Europe is the world's largest 
carbon market and trades instruments very similar to those already 
used in the United States. 

According to an exchange official, at least 90 percent of the world 
carbon products are European Climate Exchange contracts traded on ICE. 
These markets offer several products, including: 

* Original instruments—CERs and EUAs; 

* Futures and options on CERs and EUAs; and; 

* CER and EUA daily futures contracts, which are like contracts for 
the buying and selling of physical products. 

[End of section] 

Attachment II: States Included in U.S. Regional Cap-and-trade Programs: 

* RGGI includes 10 states--Connecticut, Delaware, Maine, Maryland, 
Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and 
Vermont—-as members; Pennsylvania and 3 Canadian provinces-—New 
Brunswick, Ontario, and Quebec-—are observers. 

* Midwestern Greenhouse Gas Reduction Accord includes 6 states-—Iowa, 
Illinois, Kansas, Michigan, Minnesota, Wisconsin-—and 1 Canadian 
province—Manitoba—-as members; Indiana, Ohio, and South Dakota and the 
province of Ontario are observers. 

* Western Climate Initiative includes 7 states-—Arizona, California, 
Montana, New Mexico, Oregon, Utah, and Washington—-and 4 Canadian 
provinces—British Columbia, Manitoba, Ontario, and Quebec. Arizona and 
Utah have dropped out of the cap-and-trade portion of the initiative; 
Utah may join the cap-and-trade program at a later date; Montana has 
not yet enacted legislation authorizing the cap-and-trade program; 
Oregon's participation may depend on the outcome of the gubernatorial 
election in November 2010; and a California ballot initiative, if 
approved, would suspend implementation of the state law authorizing 
the cap-and-trade program until the unemployment rate in California is 
5.5 percent or less for a specified time period. 

[End of section] 

Enclosure II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Orice Williams Brown (202) 512-8678 or williamso@gao.gov. 

Staff Acknowledgments: 

In addition to the individual named above, Cody Goebel, Assistant 
Director; John Forrester; Mike Hix; Richard Johnson; Jessica Lemke; 
Akiko Ohnuma; David Rodriguez; Andrew Stavisky; Jeeanette M. Soares; 
and Paul Thompson made key contributions to this report. 

[End of section] 

Footnotes: 

[1] Offsets are typically quantified in metric tons--2,205 pounds-—of 
carbon dioxide equivalent. An example of an offset project is a system 
at a waste disposal plant that captures the plant's methane-—a 
greenhouse gas. 

[2] Futures are agreements to purchase or sell a commodity for 
delivery in the future. Like other types of derivatives, their prices 
are based on the value of an underlying commodity. 

[3] These estimates included those by the World Bank and Point Carbon, 
an industry consulting firm. 

[4] Exempt commodities include all commodities other than those 
specifically designated in law as agricultural (such as corn or wheat) 
or as excluded (such as interest rates or currencies). 

[5] Pub. L. No. 111-203 § 750 (2010). 

[6] Pub. L. No: 111-203, 2010. 

[7] GAO, Systemic Risk: Regulatory Oversight and Recent Initiatives to 
Address Risks Posed by Credit Default Swaps, [hyperlink, 
http://www.gao.gov/products/GAO-09-397T] (Washington, D.C.: Mar. 5, 
2009). 

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