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Emission permits

Outcome paper:English
Cover note:English
Comment template:English
Global consultation status:Open
Deadline for comments:15/03/2011
Number of comments:32
Comments from the global consultation
Posted onProvided byComments
20/04/2011New Zealand / Statistics New Zealand1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
No, Statistics New Zealand does not agree that the revised SEEA should treat emission permits as recommended by the ISWGNA. The sink function of the atmosphere should be included within the asset boundary making the treatment of emission permits consistent with the lease of a natural asset. Statistics New Zealand prefers this treatment for SEEA vol 1 and also for SNA08. In our view, the SNA08 has erred in its prescriptive wording of para. 17.363. The SNA08 does not need to categorically rule out the atmosphere as a natural asset with no value placed on it. As the development of the ETS has shown, the sink function of the atmosphere does have economic value and you can assign property rights to it. So, just as water may be brought within the asset boundary via the extension of property rights, so may certain aspects or functions of the atmosphere. If the SNA08 allowed for this, then the lease treatment of emission permits could be accommodated within standard national accounts and there would be no need for a SEEA and SNA08 difference on these economic transactions. This would still leave SEEA with the important satellite account role of extending the asset boundary to embrace other functions of the atmosphere. If the ISWGNA has been asked to revisit this issue, then this simple change to SNA08 para 17.363 would be a good starting point.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes, However the level of detail required to populate the tables is a concern. It may be beneficial to introduce a short-list of simplified standard tables and provide supplementary tables for those countries with the capability to provide more detail.
  3. Any other comments?
No further comments
31/03/2011Statistics Portugal1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Although we support the framework related to the tables, we have some reservations regarding the data requirements to fill them. The tables for general government could be filled out, but those regarding industries would have severe data restrains, especially in information concerning the secondary market (permits traded several times). Thus, if the inclusion of these tables implies that their full filling is mandatory, we do not agree with their incorporation on the revised SEEA.
17/03/2011Statistics Finland1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes
17/03/2011Philippines/National Statistical Coordination Board1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
We fully agree, as the SEEA being a satellite account of the SNA.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
The proposed tables on emission permit are fine however, not all countries can or are ready to have such tables. Hence, some recommendations should be made for cases wherein countries are not yet into the use/adoption of emission permits in their economies.
16/03/2011Germany, Federal Statistical Office1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
yes
16/03/2011Malaysia/Department of Statistics1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
No comment
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
No comment
  3. Any other comments?
The Department of Statistics Malaysia (DOSM) has no experience in developing any environmental account using the SEEA framework. However, DOSM is currently trying to develop one of the SEEA account (eg Water account) with the experience and knowledge gain while visiting Australia Bureau Statistics (ABS), and also with the guide of the SEEA 2003. However DOSM, experience constrains in developing this account with lack of expertise in this field, human resources and budget. 2. DOSM also wants to learn in detail how to develop the SEEA account. Please inform and include us if there is any training/workshop to be conducted in future. 3. Therefore DOSM is unable to contribute fruitful comments for the revision of the SEEA. However, DOSM would like to be involved in further development of this matter.
16/03/2011Turkish Statistical Institute1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes. Treatment of this kind of permits is the same in the national accounting system.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
This is related with SEEA, but, numbers, stocks, sales and holds are very good information for satellite account purposes.
  3. Any other comments?
In Turkey, there is no big market for emission permits but it will be very important in near future.
16/03/2011Australian Bureau of Statistics1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
We note that the February 2012 meeting of the UNSC discussed the treatment of ETS within the SNA and initiated a process to reconsider the clarification issued by the ISWGNA. This process is expected to culminate in an agreed position at the February 2012 meeting of the UNSC. The ABS is of the view that the revised SEEA should be consisitent with the clarification that emerges from that process.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
The tables presented in the annexe to the outcome paper contain a range of appropriate physical and economic information and represent an appropriate minimum for inclusion in the SEEA Rev. We do not anticipate that information contained in these proposed tables will be overly difficult to generate. We expect these data will be compiled in the process of meeting SNA reporting requirements.
16/03/2011Norway/Statistics Norway1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes, we agree with consistent treatment with SNA.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
We do agree that there should be tables included in the revised SEEA including information on emission permits. However, we do not agree with the proposed amount of tables that are recommended to be included in the revised SEEA or with the detailed level of information that are recommended to be included in the various tables. There are not many countries that have regular production/experience with the compilation of emission permit accounts. In general we would therefore recommend making the tables as simple as possible in order to have the basic needs for this issue covered. Some of the information asked for is not easy accessible information. Detailed comment about the tables: We recommend that table A1.1 (the balance sheet of General Government) could be set up in a simple way making the increase and decrease in the stocks during the period covered by the balance sheet more clearly. We question if the tables A1.3 and A1.4 are necessary to be included as single tables in a revised SEEA. The information included in these tables is to a high extent also included in table A1.5 (balance sheet by industries). In table A1.5 we also question the need of differentiate between “of which free permits” from “of which non-free permits” under the numbers 3 (Purchased), number 4 (Credits…) and number 5 (Sold permits..). It would perhaps be technical possible to withdraw this information from the emission permit trading registry (since each permit issued for free has a serial number), but the information from the Norwegian Climate and Pollution Agency (which operate the Norwegian emission permit trading registry) is that this will be a very time consuming job and is absolutely not easy accessible information. The solution chosen for the division of sold credits (number 6) could be a possible solution for sold permits (number 5) and hence the division between “of which from other residents” and “of which from the rest of the world” for number 3 and number 4. Although we do see the need and wish of using the division between “of which to other residents” and “of which to rest of the world” as used in number 6 our colleagues in the Norwegian Climate and Pollution Agency told us that this is not easy accessible information either. At least in the Norwegian emission permit trading registry, one can trace transactions between domestic and foreign “accounts” in the registry. But, the owner of the domestic “account” does not necessary need to be a domestic company. It is possible to withdraw information about the owners of the various accounts, but this is time-consuming work. We would therefore recommend that the need for splitting “of which to/from other residents” and “of which to/from the rest of the world” is better explained. It will depend on what issue to address if this split is regarded as a need. For the monetary tables, the same comments as for the physical tables are valid. In addition, we would recommend including more information in the texts regarding how to value the various components included in the tables. This is not clear and very little experience exists in this field. Is it for example intuitive how to value the entries labelled “free of charge”, what transactions that are to be recorded and what prices to use when etc? This is not well described in the paper and these questions are strongly correlated to the questions raised in part B related to the valuation of emission permits in the national accounts. The valuation of the emission permits need to be included in the national accounts in monetary terms in an appropriate way.
  3. Any other comments?
What tables to include and what detailed level of information included in the various tables are closely linked to the purpose of compiling emission permit accounts. And it is particularly information regarding the purpose of why including emission permit accounts in the revised SEEA we would recommend to make more clearly than what is done in the paragraphs 48-50. It is not very clear what question or policy issue is being addressed, and therefore it is difficult to know if the information gathering is helpful in answering the “need”. We should also have in mind how these proposed physical emission tables in the revised SEEA compare to the reporting/reconciliation that countries are required to do for compliance with the Kyoto reporting. The purpose of why including recommendations for the emission permits accounts in the revised SEEA has to be evident. We recommend that the terminology in use regarding permits vs. credits should be defined clearer. For us the link between permits and credits as it is included in the outcome paper is not clear. Are permits and credits seen as two distinct things, or are credits actually just a special type of permits?
15/03/2011France/ Ministry of Ecology1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
No. We will only comment on the accounting treatment of the emissions permits. The “timing difference betweeen cash received by government for the permits and the time of the emissions” indeed gives rise to a finacial asset, to be treated as such in compliance with the SNA.
As regards the treatment of emission permits in the SEEA, we consider that it should take advantage of the opportunity offered by its flexibility with respect to its relationships with the SNA framework.
In this context, we have a preference for the treatment consisting in considering that, through emission permits, polluting producers rent the atmosphere, treated as an asset, under a leasing agreement with the government(s), the owner(s) of the asset. In addition, the rents should actually be valued using the market prices of the permits at the time the pollution takes place (time of accrual). Some explanations of this proposal are provided below.
The purpose of market-based policies to control carbon emissions is to put a price on such emissions. More precisely, the mechanism at work in cap-and-trade programs consists in fixing the quantity of emissions and leaving the market to determine the price. Therefore, the price of the permit is deemed to reflect the opportunity cost of carbon emission by producers.
This observation drives the reflections on the treatment of emission permits in the national accounting context, as expressed in the specific Task-Force. The TF concluded in a consensus that the price of the permit is the market price.
However, the solution retained by the ISWGNA to divide this value into two asset components mainly results from the focus on the possible consequences of this alternative solution1 on the government accounts, which is a legitimate concern given the use that is made of these accounts in the central national accounts. This is the well-known vision of the national accounts as a multi-purpose system. But there is apparently not such a constraint on the SEEA. For instance, the SEEA accounting framework does not include a financial balance sheet for the government sector. Instead, the SEEA should focus on the economic impact of carbon emission on the environment, measured by its social cost as reflected in the market price of carbon.
In this context, the rents of the above proposal should be valued by the full market price of the permits at the time of emission, and not by the issue price of this permit. It is indeed the market price which represents the actual cost for the producer/polluter.
The situation is actually quite similar to the one of a producer who has hedged on the futures market against the changes in the price of a raw material that it uses as an intermediate input in its production process. When the production takes place, we record the intermediate consumption of the raw material at its market price - replacement cost - as observed at the time of production. We do not record in the production account the actual monetary cost, as it results from the hedging mechanism.
The choice of the market price to be used for valuing the emission costs may be rather flexible, as it is always the case in national accounting. There is no obligation to stick to the last price reported on too few market transactions.
There is first a need for the existence of deep and broad markets, on which observations can be made. As a second best option, if market prices resulting from transactions on the secondary market are felt to be too volatile, it is possible to take the price that results from the issuing of permits in the current period by government, where the issuance is made through auctions. However, when large auctions take place, it is likely that the resulting price will be a reference for the markets. All in all, this solution seems rather simple to implement since it only needs the availability of the number of permits - expressed in carbon units - that are surrendered during the period under review, and of a single market price.
This solution may also be retained if permits are issue free of charge by governments, since, in this case also, it is the social cost of carbon which would be reflected in the SEEA. However, in this case there is a risk of more volatile market prices - or reference prices - than in the situation where large auctions take place.
1) solution which sometimes referred to as the « financial asset option ».
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes.The annex is very useful to understand the different situations and points of view (industries, government,…) and specifies clearly how to record the flows.
In addition, we have some proposals, and are not sure to fully understand some recordings.
Table A.1.2: for the last institutional sector it has to be titled S14 + S15 (not only S14).
Table A.1.4: there is a numeric error in the column C (the total is lower than the constituents).
We don't understand the interrelation between the tables A.1.2, A.1.3 and A.1.4. For instance, in the table A.1.2 non financial corporation purchased 1165 permits (which are broken down by industries in the table A.1.5). Yet these permits are not described in table A.1.3.
We have difficulties to interpret the figures contained in the table A.1.3 (issues and purchases). There are two industries concerned by a number of non free permits issued and (in fact “or”?) purchased (79 for B and 25 for K). We find these both figures in the table A.1.5 but for permits sold - not purchased – (and probably with a column error for 25).
Anyway for a clearer understanding, it would be relevant to make a clear distinction between issues and purchases (or sales) of permits in the tables A.1.3 and A.1.4.
Lastly, in the tables A1.2, 1.3, 1.4, 1.5, 1.7, 1.8, 1.9, 1.10, is it possible (and useful) to differentiate the three "of which" when a permit is purchased to another corporation for example?"
15/03/2011Mexico / INEGI1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes, because the fact that emissions allowances are treated as payments of taxes on production will reduce the amount of operating surplus in the accounting of companies that pollute, in addition, the report on the amount of emissions permits would allow greater management control over the care of the environment reflected in the environmental economic accounting, this being compatible with the developed in the SNA.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes, because the tables in physical units can provide information about the structure of energy consumption in the industries and therefore, about the potential demand for emission permits for sustainable production. From de tables in monetary units they can be derived indicators such as unit costs per tonne of CO2, which could be harnessed for sectoral economic assessments.
  3. Any other comments?
Not at the moment
15/03/2011Central Bureau of Statistics Israel1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes. We also agree that if possible the share of each industry (or institutional sector), which is part of the ETS should be identified, and an indication of the origin of the permit (primary, secondary market) should be given.
15/03/2011Statistics Netherlands1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
No, we do not agree that the treatment of emission permits in SEEA should be consistent with the treatment recommended by the ISWGNA. One of the main purposes of SEEA is to provide, one way or another, information and indicators dealing with environmental scarcity issues. This is why the asset boundary of the SEEA includes a broader range of environmental assets than the SNA. Governments introduce pollution permits with the purpose of regulating the use of the atmosphere as a carbon sink. In cap and trade systems governments are the only agents that can manifest themselves on behalf of society as the eventual owners of the atmosphere. In the SEEA context one can convincingly argue that the permit grants its owner the right to use the atmosphere for carbon storage. The existence of an underlying asset implies that the SEEA should follow a different accounting treatment. In the SNA the atmosphere is explicitly not considered an asset and the pollution permit can therefore only be considered to represent a tax payment. In the SEEA context, however, the atmosphere is recognised as the underlying asset and, as a consequence, the permit should represent a (prepaid) resource rent. Also from a policy perspective the tax solution seems in the SEEA context less appropriate. In pollution abatement policy strategies cap and trade systems are often explicitly distinguished from pollution taxes. Taxes fix the price polluters have to pay while the eventual pollution loads may vary. Cap and trade systems fix the maximum allowable pollution load while the price of pollution is deliberately kept flexible. In cap and trade systems it is not the government but eventually the interaction between supply and demand that determines the price of pollution. In the SEEA it seems quite relevant to accentuate this important distinction from pollution taxes.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
yes.
  3. Any other comments?
The following issues may require some clarification or additional attention: 1. As national emission authorities do not register monetary values of transactions, and alternative sources (VAT register, production statistics, dedicated questionnaire, etc.) are hardly an alternative, how should the monetary values be estimated? What method of generating monetary values could and preferably should be applied to the different transactions (issuance, internal trade, cross border trade, surrender) and recurrent trade? 2. How to get the prices right as part of the trade is at the spot market and part on the forward (future contracts / options) market? Who’s supposed to be the owner? 3. Data collection or access may face severe difficulty for several reasons. Access to the national emissions authorities’ registers can be hampered due to the ETS regulation in place. In case of the EU, large part of the data is supposed not to be published within 5 years. Also the fear of influencing competition at the carbon market may (obviously) be a reason. How to get this solved? What are experiences of countries that tried to get the data on permits specific? 4. Treatment of Clean Development Mechanism (CDM) and Joint Implementation would require attention separately in our view. How should the CERs from CDM, and ERU’s from JI be treated? In particular in monetary terms? What price should be used? This in particular can be arbitrary for the CERs (and ERU’s) stemming from the primary market as it can be a result of an investment project. Governments and/or companies from countries with an emissions ceiling (Annex I) can be investors themselves. What to do with permits obtained from, and eventually traded at the secondary market? What tax should be recorded? 5. Clarification is required on ETS part (one out of the three Kyoto flexibility mechanisms) with trading versus non-ETS part of countries’ Kyoto obligation. In the ETS part there is supposed to be trading between participants either ‘operators’ or ‘traders’. To meet the objective of the non-ETS part, in general governments buy (large) quantities of CERs. How to treat those (as these represent the non-ETS part)? 6. In context of emission trading and meeting Kyoto objectives next to government, two main groups exists. These are 1. the companies obliged to participate, the operators (with large emissions), and 2. other parties such as financial institutions or individuals also allowed to participate in permit trading – the traders. Wouldn’t it reasonable to treat these separately? Background for participation and behaviour is quite different. 7. How should the trade on the different trading platforms for permits, the ‘Climate Exchanges’ as for example the ECX, enabling a mixture of financial products (EUA & CER Futures, options, spot contracts) applicable to ETS, be treated? It appears that (part) of the daily transactions on these platforms do not appear in the registers of the national emissions authority. How should (1) trade on those platforms be treated and (2) how should the different financial products (spot, future, options, etc.) and the influence on price be treated? The national emission authorities thus do not fully cover all transaction of permits, leading to underestimation in the figures. 8. How should the paid (net) VAT to government be registered / recorded? 9. How to deal with fraude taking place within the ETS system, for example with VAT fraude or with the stolen allowances from the registers? 10. In context of the design of the registration of permits (allowances, etc.) can something be said about system change? In the post-Kyoto era, the design of the trading system is supposed to change significantly as is the registration of the permits (less national, more international). How can the current system of registration in NA / Environmental Accounts be prepared for that?
15/03/2011United States/Bureau of Economic Affairs1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
No. Our understanding is that the at the recent UNSC meeting it was decided that this would go back to the AEG for further study and we support that decision.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
No. See above
15/03/2011Central Statistical Bureau of Latvia1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes
15/03/2011Jordan/Department of Statistics(DoS)1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes We agree, but at the same we would like to confirmed the difference between taxes and permits. For taxes it should be paid on production, while Permits could be transfer or sale to another part when the owner of the permits improve his environmental commitments and his manufacturing conditions and vice versa.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes we do agree but with caution to source of these data and allowing access to such data. Also, we would prefer short list of the general tables rather than the details tables.
  3. Any other comments?
Such data demands capacity buildings of the interested staff, particularly in the developing countries, because reporting such data is a very important process and at the same time, it is a tool to monitor compliance to environmental regulations. Further more statistical perspective should play an essential role to measure the performance of the outcomes of the environmental strategies and actions.
15/03/2011Statistics Sweden1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes. However, it is also important that the SEEA in the chapter on environmentally related taxes is very clear and in an easy fashion can explain what the final tax data should actually include. It would be good if the SEEA in the tax tables could have a specific category on emission permits under energy taxes.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes, we agree that the tables should be incorporated in the revised SEEA since it is such an important and increasingly used policy tool and the possibilities to compare it to other economic policy tools will be many. This enables SEEA to be widely used as an analyse tool for policy analyses. However, it is also important that the tables are described well in the SEEA, especially on how to calculate the price for ETS allocated for free (in for example table A1.6 balance sheet of GG).
  3. Any other comments?
In Sweden the NA is considering free allocations of ETS as a capital transfer (D9). This means that the free allocation would fall under the category of a subsidy (if the SEEA includes current and capital transfers as suggested in earlier outcome papers) and thus recorded as an environmentally related subsidy. The specific ETS tables proposed is a very good way of combining the information but it is important that the SEEA makes the appropriate links to other tables also proposed to be included in the revision, (i.e. the environmentally related taxes and environmentally related subsidies.
15/03/2011Spain/National Statistics Institute1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes. However, the System of National Accounts 2008 (2008 SNA) does not fully address the recording of tradable emission permits, recognising that further guidance is needed and including the issue in the Research Agenda. The OECD-Eurostat TF established to consider this issue was not able to arrive at a consensus and the issue was deferred to the ISWGNA that provided a clarification of the recording, but recognising that the issue may need to be reviewed again in future. Consequently we consider that it is still an open topic and, the different approaches about financial asset-liability of government, do not affect essentially the environmental accounts core. The SEEA could make reference to this issue reflecting the Paragraph 17.363 of the SNA 2008, permit classified as taxes, and constituting assets valued at market price. However the clarification by the ISWGNA could only be included in the SEEA as a reference mark.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes, partly. That tables could be considered as the starting point for the record of emission permits. However, we consider that the tables could be simplified in order to be tested on a first trial run before being presented with such detailed development.
15/03/2011Ukraine/State Statistics Service1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
No comment
15/03/2011UNSD1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Agree.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Agree.
14/03/2011Switzerland/Federal Statistical Office1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
We agree with this recommendation, which is more consistent with the proposed asset boundary for Volume 1 of the revised SEEA, more consistent with the treatment of such payments in the SNA and which finally allows more compatibility in the presentation of data under different government regulatory arrangements – e.g. both CO2 emission permits and CO2 taxes would be treated as taxes.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes
  3. Any other comments?
No
14/03/2011Lithuania/Statistics Lithuania1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes, we agree
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Statistics Lithuania does not currently have sufficient subject matter expertise to comment on the issue 2.
14/03/2011United Kingdom/Office for National Statistics1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Agree with consistent treatment with SNA.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Agree in principle.
  3. Any other comments?
Sensible proposals. We need to pursue access to source data to confirm delivery in practice.
14/03/2011Denmark/Statistics Denmark1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
YES. However it should be noted that there is a large number of tables and it may be useful to consider whether all of them should be included in the present form and whether it is possible to generalise the tables a little more, since the present form reflects the European trading scheme to a large extent.
14/03/2011Iran/Statistical Centre of Iran1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
The tables contain very detailed information. They are very useful tables but it is not possible to have such information in detail specially in developing countries.
14/03/2011Mauritius/Central Statistics Office1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes.
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes.
14/03/2011Armenia/National Statistical Service1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Да. Должно быть соответствие с СНС.
Yes. Must be consistent with the SNA
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Да.
Yes
14/03/2011Kyrgyz Republic/National Statistical Committee 3. Any other comments?
On behalf of the National Statistical Committee of the Kyrgyz Republic let us thank you for your letter regarding Global Consultation - SEEA Revision Issue # 8b. But unfortunately the Kyrgyz Republic do not develop tha national accounts on environment therefore we coul dnot submit the comments.
14/03/2011Egypt/CAPMAS1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes. It is important to indicate the type kinds of production and its quality level
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
Yes
  3. Any other comments?
It is better to put the tables presented in the annex in 3,4 categories from basic and simple data to complex data , because there are many countries which can not produce all the data required in tables
01/03/2011ROMANIA/National Institute of Statistics1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
We agree with the treating of the emission permits in the revised SEEA similarly to the treating of the emission permits in the SNA 2008.
28/02/2011Bulgaria/National Statistical Institute1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
  2. Do you agree that the tables for recording information on emission permits as presented in the annex to the outcome paper should be incorporated into the revised SEEA?
NSI has no views on the matter.
  3. Any other comments?
No
24/02/2011Iraq/Central Statistics Organization1. Do you agree that in the revised SEEA the treatment of emission permits should be consistent with the treatment recommended by the ISWGNA in their clarification of the 2008 SNA where the payments to government for emission permits at the time the emissions occur are treated as payments of taxes on production on an accrual basis and the timing difference between cash received by government for the permits and the time of the emission gives rise to accounts receivable and payable (financial asset) and that the difference between the prepayment of tax and the market price of permits represents a marketable contract (a non-produced non-financial asset) for the holder?
Yes
 

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