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Q1 2022 Research Theme: The Pivotal Role of Carbon Markets in the Energy Transition


A year ago (Q1 2021) we wrote a thematic research note providing an overview of the carbon capture, usage and storage (CCUS) market and its role within the Energy Transition to Net Zero, along with a few illustrative examples of various leading-edge technologies being developed to either capture CO2 emissions, recycle CO2 within industrial applications or provide long-term sequestration for CO2.

Any enterprise required to comply with an emission-based carbon tax or ‘cap’ will necessarily base its investment decision and choice of CCUS technology on how the full-cycle unit cost of such technology compares with the prevailing and prospective market price of carbon, or rather CO2 emissions.

Companies developing carbon reduction, avoidance or removal projects or technologies must likewise understand the price dynamics of carbon markets worldwide, both compliance-driven and voluntary.

We found ourselves asking the question: what therefore is the risked return on investment for emerging CCUS technologies under various carbon price scenarios? Some governments have set out future carbon taxes through to 2030, but many others rely on market-based solutions where the future clearing price for carbon cannot be known. And, of course, carbon policy (and government leadership) can change.

While our investment strategy focuses on technologies that reduce carbon intensity within the energy industry, this complex legislative backdrop naturally ‘raises the bar’ for prudent investment in emerging CCUS technologies, particularly when many such companies engage in proverbial ‘green washing’ to boost valuations alongside forecasted fundamentals that remain relatively unknown today.

What is abundantly clear to us is that carbon markets will undoubtedly grow in scale and will continue to perform a pivotal capital allocation role in the ongoing transition toward fully decarbonised economies.

We are therefore actively looking at alternate business models centered on this growing carbon market – one example being trading and software solutions that, by relying on arbitrage spreads, lay off much of the risk and uncertainty related to the absolute pricing of carbon credits and offsets in years to come.

As part of building out our investment thesis, we explore these carbon markets in greater detail below.

No Global Carbon Market Yet Exists … No Global Carbon Benchmark Price

Governments and businesses worldwide increasingly recognise that carbon pricing will perform a pivotal capital allocation role in the ongoing transition toward fully decarbonised economies.

The growing international consensus related to carbon reduction policies has not yet resulted in a unique, globally-adopted approach to carbon pricing: no global carbon market exists and thus no global carbon benchmark price.

Instead, political unions such as the EU, individual countries, states and provinces have each set up distinct mandatory, or compliance, carbon markets – albeit in pursuit of the same goal: decarbonisation.

Sixty-four distinct compliance carbon markets currently exist worldwide, evenly split between those that levy a regulated carbon tax on CO2 emissions and those with ‘cap and trade’ emissions trading schemes (ETS), where carbon pricing is not regulated but instead set by the supply/demand balance at carbon credit trade auctions amongst market participants.

One-fifth of annual global greenhouse gas (GHG) emissions, 11 Gigatonnes (Gt) of CO2eq emissions, are covered by compliance carbon markets, whether by carbon taxes or ‘cap and trade’ emissions trading schemes.

80% Of Global GHG Emissions Lie Outside Compliance Carbon Markets

That therefore leaves 80% of global GHG emissions to be addressed by other market mechanisms such as the voluntary carbon market which, albeit relatively modest in scale, is forecast to grow substantially.

The voluntary carbon market operates in parallel with but distinct to compliance carbon markets.

Voluntary carbon offsets, generated by an extensive global array of certified projects that reduce or remove CO2 emissions, are not fungible within compliance carbon markets, unless specifically allowed.

To address any potential confusion between carbon credits and carbon offsets:


Carbon credits and carbon offsets both represent one metric tonne of CO2-equivalent emissions.

Carbon credits exist within mandatory ‘cap and trade’ emissions trading schemes (ETS). Each carbon credit is an indexed tradable permit issued by the relevant governing authority that gives its owner the right to emit one tonne of CO2-equivalent emissions. They are, by definition, homogeneous – solely representing one metric tonne CO2eq – no more, no less. Furthermore, they are, bar a couple of exceptions, not transferable between jurisdictions.

Carbon offsets exist within the voluntary carbon market. Generated by eco-projects worldwide rather than specific governing authorities, each carbon offset is an indexed tradable instrument, related to a specific eco-project, that represents the reduction or removal of one tonne of CO2-equivalent emissions. By contrast with carbon credits, voluntary carbon offsets are not identical project-to-project since each eco-project generates a diverse range of ESG benefits alongside the carbon offset. With different buyer needs/preferences for such ESG ‘side-benefits’, the result is a broad market range for voluntary carbon offset pricing. In addition, buyers not subject to emissions compliance are free to source voluntary carbon offsets from any project worldwide.


Carbon credits dominate global trade across all carbon markets. 2021 saw the value of carbon credits traded within compliance ETS markets hit a record US$851 billion, up 164% year-on-year, on trade volume representing 8.7 Gt of CO2eq emissions, principally driven by trading within the EU ETS, the largest and most established carbon trading market.

The Voluntary Carbon Market Is Growing Rapidly Amid Booming Corporate Demand

However, the voluntary carbon market has undergone dramatic growth in recent years, albeit from a small base, amid booming corporate and individual demand for voluntary carbon offsets. As more and more companies, not subject to any mandatory carbon emission compliance requirements, announce corporate net-zero and ESG programs, so they increasingly seek to purchase certified voluntary carbon offsets to offset their more costly, hard-to-abate GHG emissions.

The estimated overall value of voluntary carbon offsets traded in 2021 over-the-counter or via the small but growing number of carbon offset exchanges exceeded US$1 billion for the first time, on trade volume representing ca. 340 million tonnes (0.3 Gt) of CO2eq emissions.

Furthermore, recent studies1 estimate that demand for voluntary carbon offsets could increase five-fold or more to reach 1.5 – 2.0 Gt by 2030, potentially 30-fold by 2050 to reach ca. 10 Gt. The overall market for voluntary carbon offsets could be worth upward of US$50 billion by 2030, US$100 billion by 2050.

1 Taskforce on Scaling Voluntary Carbon Markets; Network for Greening the Financial System

How Much Is A Tonne Of CO2 Worth? …. Well It Depends ….

Before moving to the main focus of this note – compliance and voluntary carbon markets, the trading and pricing of carbon credits and offsets – we discuss the simplest form of carbon pricing: carbon taxes.

Carbon Taxes

Carbon taxes set an explicit price on carbon, or rather CO2eq emissions, via a unit tax (i.e. $ per tonne of CO2eq) levied on all designated CO2eq emissions within the area of jurisdiction.

Carbon taxes alone do not dictate the pace, extent or nature of emission reductions enacted by industry and citizens alike: essentially, the carbon price is known but the emissions outcome is not.

Canada’s federal carbon tax stands at C$50/tonne CO2eq and will increase by C$15/tonne each year until it reaches C$170/tonne CO2eq in 2030. Canada’s provinces and territories are free to introduce their own carbon taxes or emissions trading schemes provided that they match or exceed this federal backstop.

Canada’s federal carbon tax is imposed in two ways: as a fuel charge levied on all forms of fossil fuel consumption and, in addition, as an industrial levy on all facilities that emit 50,000 tonnes or more of CO2eq emissions per year, the latter benchmarked by sector and scale.

Canada plans to introduce a carbon offset program whereby domestic agricultural, forestry and waste projects that reduce or remove GHG emissions can generate and sell carbon offsets to regulated industrial facilities to meet compliance obligations at a cost below that of the federal carbon tax.

Compliance ‘cap and trade’ emissions trading schemes (ETS) can also operate in parallel with carbon taxes. For example, Sweden currently imposes a carbon tax of $137/tonne CO2eq on emissions related to the transport and buildings sectors, but other industrial sectors and operators already subject to the EU ETS remain largely exempt from this carbon tax.

The UK originally introduced a Carbon Price Floor minimum levy of US$25/tonne CO2eq on power producers’ CO2 emissions due to historic price weakness and instability within the EU ETS. Post-Brexit and despite the recent enactment of its own ETS, this minimum carbon tax will remain in place for the power generation sector until at least 2024.

‘Cap and Trade’ Emissions Trading Schemes

Emissions trading schemes are designed to provide an efficient mechanism for countries, states, provinces and companies alike to reduce their carbon footprint. Simple in theory – market forces rather than regulation determine the prevailing carbon price, spurring innovation and levels of investment appropriate to meeting stringent reductions in overall emissions, the result being that mandated emission reductions are delivered at the lowest economic cost. In practice, these schemes often prove more complex.

Thirty distinct ‘cap and trade’ emission trading systems – international, national, state and provincial – exist worldwide to regulate and drive down greenhouse gas (GHG) emissions from those industrial sectors, e.g. cement & steel, pulp & paper, utilities and domestic aviation, that are responsible for the majority of GHG emissions – essentially targeting the ‘low-hanging fruit’.

By way of example, the mandatory emission trading systems operating within the EU, UK and California markets cover 40%, 31% and 80% of their respective overall GHG emissions.

All ‘cap and trade’ emissions trading systems operate in a broadly similar manner:

  • The regulator sets an overall GHG emissions cap and creates a matching number of carbon credits.

  • These carbon credits are distributed to regulated entities either for free or via auction.

  • Each year, fewer carbon credits are issued, thus the annual cap on overall GHG emissions declines.

  • Each regulated entity has an individual cap that declines in tandem with the overall emissions cap.

  • Any regulated entity with excess emissions above its cap must acquire sufficient carbon credits via trade auctions or a market exchange to cover such excess emissions or face heavy fines.

  • Those entities with emissions below their cap – due to investments in new technology or improved operating practices – can trade unneeded carbon credits via trade auctions or a market exchange.

  • The supply/demand balance of carbon credits at auction or on an exchange determines the prevailing market price for carbon credits.

Most emissions trading schemes preclude regulated entities from using voluntary offset credits rather than carbon credits to satisfy their obligation to cover excess emissions. However, a small but growing number of ETS programs do now accept voluntary carbon offsets – fully verified, high quality and typically locally generated – to meet a modest fraction of market participants’ obligations.

With a few clear exceptions (EU & Switzerland, California & Quebec), there is little to no harmonisation between the various ETS programs worldwide i.e. no inter-ETS fungibility of carbon credits, and therefore no immediate likelihood of a uniform carbon price benchmark.

Indeed, as stakeholder pressures to drive down domestic GHG emissions increase, various ETS systems, such as the EU, no longer accept international carbon credits in lieu of domestic carbon credits.


Introduced in 2005, the EU ETS is the oldest and largest ‘cap and trade’ ETS worldwide. In its early form, it encountered serious issues with over-issuance of free carbon credits to protect certain industrial sectors from foreign competition, the result being near-complete market failure and thus a collapse in carbon credit pricing. Although EU GHG emissions did decline, in its infancy the EU ETS itself played little part in driving investment toward emissions reduction. Tighter regulations regarding carbon credit allocations, fungibility of international carbon credits and offsets and more stringent reductions of overall emissions from 2021 have prompted substantial growth in the EU ETS carbon pricing.

As the largest, most liquid market in carbon credits, representing 90% of global carbon credit trade increased speculation on EU ETS carbon spot and futures contracts likely plays an increased role.

EU ETS Carbon Credit Pricing, 2015 to date (Euro per tonne CO2eq)

California ETS

California’s carbon cap-and-trade program was launched in 2013 and is now one of the largest multi-sector emissions trading systems worldwide. Furthermore, since 2014 California’s and Canada’s Quebec Province cap-and-trade systems have been linked via the Western Climate Initiative, ensuring that compliance carbon credits issued by either jurisdiction are fully fungible.

California’s program currently applies to utilities and industrial emitters (e.g. oil & gas producers, refiners, cement manufacturers and others) that in aggregate are responsible for about 80% of the state’s overall greenhouse gas (GHG) emissions.

Tight auctions coupled with increased auction reserve prices have provided steady support to carbon pricing within these two markets, prompting action by market participants to reduce GHG emissions.

California-Quebec Joint Auction Settlement Prices And Volumes

Source: CARB

Importantly, market participants within these two compliance ETS markets can tap the voluntary carbon offset market to address any compliance shortfall – but such carbon offsets must meet stringent state-approved hurdles and represent no more than 8% of their annual compliance cap (now 4% in California), with at least half of such carbon offsets stemming from projects local to either jurisdiction.

California Low Carbon Fuel Standard – A Victim Of Its Own Success?

In parallel with its ‘Cap and Trade’ ETS which regulates large emitters within the industrial, utility and fuel sectors, California also operates the Low Carbon Fuel Standard (LCFS) market, the aim being to lower the carbon intensity of California’s overall transport fuel supply by 20% by 2030.

The LCFS program sets out annual carbon intensity (CI) benchmarks, which reduce over time, for gasoline, diesel, and the fuels that replace them but, importantly, lets the market determine what mix of fuels will be used to reach the program targets.

Fuels and fuel blendstocks introduced into the California fuel system that have a CI higher than the prevailing benchmark generate LCFS deficits. Similarly, fuels and fuel blendstocks with CIs below the prevailing benchmark generate LCFS credits. Annual compliance requires regulated parties to purchase LCFS credits (each representing a tonne CO2eq) to match any deficits. 2021 saw market participants trade about 25 million LCFS credits at an average credit price of US$187 per tonne CO2eq.

However, of late California’s LCFS program has become a victim of its own success.

Pricing of LCFS credits has slumped by 45% year-on-year to US$106/tonne CO2eq. This price drop can no longer be attributed solely to demand-side events such as a continued slump in gasoline consumption amid growing EV market share. On the supply-side, outsized expansion of dairy herd methane gathering has caused the average carbon intensity of renewable natural gas (RNG) to collapse alongside increased supplies of renewable diesel into the California marketplace – the result being a burgeoning LCFS credit market overhang.

California – LCFS Credit Pricing, May 2021 to date – Pressured By Growing Market Overhang

Source: Neste

British Columbia (BC) operates a similar LCFS market, albeit much smaller with 550,000 LCFS

credits traded in 2021 at an average price of US$350 per tonne CO2eq. While BC LCFS pricing remains firm currently, California’s LCFS market demonstrates that supply/demand fundamentals can swiftly weaken.

British Columbia – LCFS Credit Pricing, 2019 to date

Source: British Colombia Ministry of Energy, Mines & Petroleum Resources Monthly Credit Market Reports

Voluntary Carbon Offset Markets

The world’s first voluntary carbon offset project actually preceded the Kyoto Protocol of 1997 and the first compliance GHG emission trading scheme, the EU ETS, set up in 2005.

Compliance carbon markets are, by dint of separate oversight and legislation, restricted by geography (e.g. Canada, California, EU, UK, Korea etc) and, bar a few exceptions, the fungibility of their respective carbon credits. By contrast, the voluntary carbon offset market is considerably more flexible, unrestricted by regional, national or political boundaries.

Furthermore, an entire economy can participate in the voluntary carbon offset market rather than the small number of industrial sectors typically prescribed by the compliance market.

Despite its headstart and such relative freedoms, the voluntary carbon offset market did not evolve as originally envisioned and has thus remained relatively small for many years, particularly when compared with the growth and scale of compliance carbon markets such as the EU ETS.

However, as previously mentioned, trading in voluntary carbon offsets has surged as more and more companies worldwide, although not subject to any mandatory carbon compliance requirements, announce corporate net-zero and ESG programs in response to increased stakeholder pressure.

By year-end 2021, over 2,200 companies worldwide have announced science-based (i.e. independently verified) emissions reduction targets or commitments. One in five of the world’s 2,000 largest publicly listed companies have now committed to a net-zero emissions target.

However, delivery of such commitments, particularly net-zero emissions targets, is difficult and costly to achieve at pace where industrial processes or complex supply chains prevent rapid solutions. Voluntary carbon offsets allow businesses to swiftly offset their costly, hard-to-abate GHG emissions while they endeavour to transition to new low-carbon manufacturing routes and processes.

How Big Could The Voluntary Carbon Market Be?

According to industry surveys by Ecosystem Marketplace, the global value of voluntary carbon offsets traded over-the-counter or via the small but growing number of carbon offset exchanges grew more than three-fold year-on-year to well over US$1 billion in 2021, on near-double trade volume representing ca. 340 million tonnes (0.3 Gt) of CO2eq emissions.

Relative to compliance carbon markets, which cover one-fifth of global greenhouse gas (GHG) emissions, or 11 Gt of annual CO2eq emissions, the voluntary carbon market is obviously miniscule currently.

But there is a huge prize available for the voluntary carbon market, namely the 80% of global GHG emissions, over 40 Gt of annual CO2eq emissions, that remain as yet unaddressed by carbon markets.

Further studies estimate that demand for voluntary carbon offsets could increase five-fold or more to reach 1.5 – 2.0 Gt by 2030, potentially 30-fold by 2050 to reach ca. 10 Gt. The overall market for voluntary carbon offsets could be worth upward of US$50 billion by 2030, US$100 billion by 2050.

Voluntary Carbon Offsets – Growth Scenarios to 2030, 2050, Gigatonnes CO2eq per annum

Source: McKinsey, PillarFour Capital analysis

As we describe below, carbon offset projects, unlike carbon credits, are not just simple ‘carbon commodities’ - they possess diverse ESG attributes of different value to different buyers. Matching individual buyers with suppliers of their chosen nature of voluntary carbon offset has long been a time-consuming and inefficient process, best transacted over-the-counter by well-informed brokers.

The voluntary carbon market has thus remained largely fragmented and complex, with limited liquidity and price transparency. In addition, the environmental credentials of some vintage carbon offsets can occasionally prove rather dubious, placing further pressure of the need for strict third-party verification.

For the voluntary carbon market to prosper and grow by an order of magnitude or more in both scale and potential value, structural change is necessary – buyers and sellers of carbon offsets both require a voluntary carbon market that is liquid, transparent, verifiable and environmentally robust.

The good news is that change is already afoot.

Voluntary Carbon Offsets – Diverse Sources, Geographies, Co-Benefits

Voluntary carbon offsets are generated from a dizzyingly broad suite of projects worldwide, both land and marine-based. Leading examples would include forestry conservation, soil management, mangrove, seaweed and seagrass cultivation, efficient cookstoves, methane gathering, bio-digesters etc.

  • Each project has unique attributes e.g. carbon removal/avoidance, nature/technology, geography.

  • Diverse project attributes ensure a broad range of base costs for the carbon offsets created.

  • Each project may, beyond generating the sought-after carbon offsets, also offer co-benefits by addressing UN-defined sustainable development goals (SDG) e.g. education, clean energy, local economic growth – such co-benefits potentially bring additional value to some purchasers.

  • Buyers have different preferences; some just wish to purchase low-cost offsets (e.g. a fuel distributor that simply wishes to sell a carbon-neutral marine fuel), while others are prepared to pay up for ‘higher-quality’ carbon offsets with additional co-benefits (e.g. public companies that seek to burnish their ESG credentials with social actions like community projects and saving wildlife).

The lack of homogeneity among both projects and buyers within the voluntary carbon market has traditionally limited trading to over-the-counter (OTC) transactions, the result being limited price transparency and market liquidity, and a broad offset price range ranging from as little as US$1/tonne CO2eq for older projects with fewer verifiable co-benefits, to over US$20/tonne CO2eq for projects with unique features and specific co-benefits, such as biodiversity and support for indigenous people.

Despite such diversity, projects can be grouped into broad categories:

Note: REDD+: Reduced Emissions from Deforestation and forest Degradation, allied to conservation & sustainable management Source: Platts

Reduction/Avoidance projects reduce or avoid CO2 emissions into the atmosphere. Examples include nature-based projects such as preventing deforestation or farming emission reductions and technology-based projects such as off-grid renewable energy or the development of energy-efficient buildings.

Removal projects remove CO2 emissions directly from the atmosphere. Examples include nature-based projects such as using trees, wetlands or soil to remove and capture carbon as well as technology-based projects such as direct air capture and CCUS.

Removal carbon offsets tend to trade at a premium to reduction/avoidance carbon offsets, largely due to the capital requirements but relatively short supply of technology-based offsets, but also high latent demand since they are viewed as a permanent and thus ‘high quality’ solution to excess CO2 emissions.

The Structure of the Voluntary Carbon Market

Illustrative Project Setup Providing Voluntary Carbon Offsets & Community Co-Benefits

Source: Taskforce On Scaling Voluntary Carbon Markets, Jan 2021

Voluntary Carbon Offsets Must Be Validated To Ensure Market Integrity …

Given the growing number and global diversity of projects that create voluntary carbon offsets – market integrity requires that projects are independently validated and each and every carbon offset uniquely identified and verified, alongside a record of its issuance, transfer and subsequent retirement.

Validation of carbon offset projects is carried out by a variety of not-for-profit agencies, the most respected and best-known being Verra (2021: 88% market share), Gold Standard, CAR and ACR.

For a project to be validated, the associated carbon offsets must be:

  • Real and measurable i.e. truly avoid or absorb a tonne of CO2eq that can be measured or computed;

  • Additional i.e. emission reductions or removals above and beyond ‘business as usual’.

  • Permanent without ‘leakage’ i.e. irreversible without driving up emissions elsewhere

… But Validation Process Is Becoming Increasingly Bottlenecked

Rapid growth in demand for carbon offsets is more than matched by the rapid growth in funding and initiation of numerous carbon offset projects worldwide. No wonder that the small number of respected not-for-profit validation agencies mentioned above are now snowed under and the validation process increasingly bottlenecked.

Voluntary Carbon Offset Trading Continues To Surge, Exchanges

Taking Significant Market Share

The significant majority of voluntary carbon offsets continue to be traded over-the-counter or off-exchange via a network of broker/dealer intermediaries, however a growing number of exchanges including CBL, CTX, ACX, ICE and CME now trade spot and future carbon offset contracts.

In a market long viewed as fragmented and opaque with trading almost exclusively over-the-counter, a number of innovative exchanges have launched and captured significant market share. Indeed, overall exchange-traded volumes currently represent about 40% of all transactions in carbon offsets.

Xpansiv’s CBL exchange is currently the largest worldwide for trading carbon offset contracts, hosting around 90% of all voluntary carbon offset exchange-based transactions worldwide. 2021 saw over 121.5 million tonnes CO2eq of carbon offsets trade on the CBL exchange platform, equating to an overall market share of 36%. The CBL platform allows clients to view individual carbon offset projects, see live pricing and trade a broad range of carbon offset projects from the major verification registries.

Xpansiv teamed up with the Chicago Mercantile Exchange in early 2021 to launch exchange-traded futures carbon offset contracts: CBL GEO, CBL N-GEO and CBL C-GEO.

CBL GEO & NGO Carbon Offset Futures Contracts – Market Performance To Date

CTX was the first global exchange for voluntary carbon offsets. Unlike other carbon exchanges, CTX is a member-based spot exchange with participants ranging from brokers to project developers and large corporations. CTX accepts EU carbon credits and Verra and Gold Standard registered carbon offsets.

Launched in 2019, AirCarbon Exchange (ACX) originally acted as an exclusive exchange for airlines to trade carbon offsets. ACX has since expanded its product offering and client base by securitizing individual carbon offsets from various projects into six distinct tradable carbon asset classes. ACX employs blockchain distributed ledger technology to provide full traceability between the original carbon offsets and the resulting securitized and tradable digital token.

Singapore-based carbon exchange Climate Impact X (CIX) plans to conduct new auctions for carbon credits in early 2022, followed by the launch of standardized carbon contracts.

The Opportunity

With an investment strategy focused on technologies that reduce carbon intensity within the energy industry, it is imperative to have a clear understanding of the carbon market: structure, growth and the compliance burden imposed on key industrial sectors – whether in the form of carbon taxes or carbon credits, depending on jurisdiction – that companies must consider regarding capital allocation decisions.

The last few years have witnessed an important and measurable shift within the capital budgeting process of oil and gas operators globally. Traditionally such investment decisions would have been almost exclusively focused on the cashflow impact on operations (ie. least expensive, most efficient).

With the energy sector clearly in the ‘sights’ of the ESG movement, as it seeks to address growing stakeholder pressures, operators must also consider the carbon intensity impact of such decisions.

As this research piece illustrates, there are a host of regional carbon pricing mechanisms and a range of carbon offsets available. We believe it likely that carbon pricing will continue to increase over time, whether driven by legislation or by demand, in turn driving the need for oilfield innovations that will make operations more efficient, less carbon intensive and thus less costly.

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PillarFour Capital - Q1 2022 Investment Research Theme - Carbon Markets
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