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Feebates – Summary

DEVELOPMENT OF OPTIONS FORA VEHICLE FEEBATE IN CANADA

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EXECUTIVE SUMMARY

Background and Objectives

In the 2005 Federal Budget, the Government of Canada tasked the National Round Table on the Environment and the Economy (NRTEE) to develop options for a vehicle feebate for Canada. The options were to be revenue neutral, to apply to all light-duty vehicles, and to be flexible to adapt to changing circumstances. The Budget set out A Framework for Evaluation of Environmental Tax Proposals as the basis for evaluating this and future environmental proposals involving the tax system. In response,  the NRTEE commissioned this study, whose objectives are to: understand the nature of the motor vehicle market in Canada and trends, including the recent Memorandum of Understanding (MOU) between the industry and the Government on greenhouse gas (GHG) emissions; identify the key feebate options that meet the mandatory parameters identified by the Government; and, assess the options against the criteria established in the Budget 2005 Framework.

The Automotive Sector – Challenges and Opportunities

The  Canadian Auto Sector is currently facing a number of difficult challenges, including low prices and poor profitability, both of which are linked to a problem of excess supply. Although these problems affect all manufacturers, import name plates have responded more successfully and, as a result, have gained significant market share. These manufacturers also represent an increasing share of Canadian manufacturing capacity.
In contrast with the US, Canadian vehicle ownership is low and relatively stable, and preferences are for smaller, more fuel-efficient vehicles. However, both Canadians and Americans purchase less fuel-efficient vehicles than those purchasers in other countries. Furthermore, there are significant regional differences in Canadian purchasing preferences. Transactions involving used vehicles represent more than 50 percent of the market. Consumer choice is driven primarily by purchase price, value, reliability and styling. In comparison, consumers rank ‘fuel economy’ and ‘safety features’ in the middle of the pack and they rank ‘environmentally friendly’ last of 21 factors in new-vehicle purchase.
Since  1990, the fuel consumption of Canadian vehicles has improved by approximately 5 percent, far less than it could have, were it not for offsetting changes in horsepower and weight, and for a shift from cars to trucks in the early 1990s. As far as GHG emissions are concerned, the improvements in vehicle fuel efficiency have been negated by the increasing number of vehicles and longer distances travelled. According to Natural Resources Canada (NRCan), the automotive sector represents almost 90 megatonnes (Mt), or more than 12 percent of Canada’s total GHG emissions, and the sector’s emissions have increased by more than 17 percent since 1990.
There  are a number of technologies that are available to improve fuel economy. Some have already been widely adopted, some are now maturing and becoming cost-effective, and others are expected to remain expensive for some time to come. In addition to conventional technologies, diesel and hybrid technology are expected to play an increasing role.
Since  most vehicles manufactured in Canada are exported (over 85 percent) and most vehicles sold in Canada are imported (over 75 percent), in theory the policy environment for vehicles should not affect manufacturing decisions.
However, it is reasonable to assume that perceptions of market negativity could affect manufacturer investment decisions.
 
   
Key  policies affecting the design and sales of vehicles include: safety regulations, air emission standards, and climate change. The key climate change initiative is the 2005 MOU between the Canadian Automotive Industry and the Government of Canada. This MOU voluntarily commits the industry to achieving a 5.3-Mt reduction in GHG emissions from the light duty vehicle sector in 2010.

Options  for a Feebate

A feebate is an economic instrument under which vehicles are subject to taxes or rebates in proportion to how
much they exceed or fall below a specified reference factor (the pivot point). Typically this factor is the
The MOU targets are aggressive and there is some uncertainty as to how the vehicle companies will achieve their commitments. Since the agreement is voluntary, the Government retains the right to regulate GHG emissions and the industry retains the right to terminate the MOU if regulations are implemented. The industry has not taken an official position on a feebate system relative to the MOU.
A feebate is an economic instrument under which vehicles are subject to taxes or rebates in proportion to how much they exceed or fall below a specified reference factor (the pivot point). Typically this factor is the mean fuel consumption rating for the vehicle for a particular year. (So, in lay terms, a feebate refers to the combination of a fee on low-mileage vehicles and a rebate on fuel-efficient vehicles.) There are an infinite number of design options, based on nine main variables:
  • RateBasis. Fuel consumption expressed as litres(l) per 100 kilometres (km) is the most likely choice;this ensures that each litre saved has the same value      
  • Form of the Feebate Function.Linear functionsare possible; caps provide ways of avoiding excessivefees or rebates that contribute little to the effectivenessof the measure, and deadbands provide a way of avoidinglarge numbers of small transfers close to the pivot point.   
  • Rate.Assuming a linear function, this refers to the slopeof the line.      
  • Numberof Classes. The options include a singlesystem, a two-tier system (cars and trucks), or multipleclasses (by weight, or interior volume).        
  • Applicationand Exemptions. Various classes of vehiclescould be exempt.        
  • ManufacturerFeebate or Consumer Feebate. This choiceshould make little difference as manufacturers willdetermine how to factor in the feebate when determiningprices.       
  • RevenueNeutrality. While preserving the principleof revenue neutrality, there are a variety of optionson how to handle the uncertainty associated with havingto predict the overall balance between fees and rebates.       
  • Phase-InPeriod. Any length of time is possible.         
  • Paidat Purchase or Annually. This refers to thepossibility of an ongoing feebate implemented throughthe vehicle registration system.       

Modeling of Feebate Options In order to evaluate the different options, two separate models were used:

  • TransportCanada Variant of Greene et al. Vehicle Purchase Model.This is a spreadsheet-based, nested multinomial logitmodel that estimates the effect of feebates on consumerpurchasing behaviour and manufacturer investment infuel economy technologies. Transport Canada modified the model to use aggregated 2003 Canadian and US sales data and updated the technology cost curves based on a 2005 literature review.   
  • NRCanVehicle Stock Model. This is a simple representationof vehicle turnover and usage.      
Like
all modeling exercises, there are a number of limitations
and simplifications that apply. In the real world, manufacturers
and consumers make decisions based on a variety of factors
that are not easily represented by simple parameters.
This model assumes that manufacturers redesign their vehicles to maximize consumer surplus. The model does estimate changes in sales but does not address profits, since producers are assumed to be perfectly competitive.
  • Itwould give greater weight to the fairness criterion,while still being reasonably environmentally effectiveand economically efficient.     
  • Itwould give firms time to adjust.       
  • Itwould contribute to a risk management strategy byproviding the opportunity to: gather better informationon factors such as elasticities and valuation; assessissues regarding, for example, the import of usedcars; and, assess other implementation problems.   
Depending on the results, the rate could eventually be increased to the optimal level justified by the information gained. The key risks that affect the assessment are as follows
  • importantlimitations of modeling       
  • poorknowledge of Canadian elasticities       
  • poorknowledge of Canadian perceived value of fuel savings       
  • opportunitycosts for consumers       
  • riskof vehicle arbitrage       
  • heavyadjustment costs for some manufacturers       
As suggested above, a lower rate to begin (phase-in period) would help hedge against these risks and would provide an opportunity to gather real information on costs and benefits. If the MOU and feebates were implemented simultaneously,many or most of the benefits of the feebate would be included in the reference case. In theory this could mean that the effects would be additive. However, the reaction of manufacturers is unknown and there is a risk that they would respond to a feebate by withdrawing from the MOU. This suggests that feebates might best be considered as an alternative policy to the voluntary MOU, or as a subsequent policy following the expiration of the MOU.
A feebate is an economic instrument under which vehicles are subject to taxes or rebates in proportion to how much they exceed or fall below a specified reference factor (the pivot point). Typically this factor is the mean fuel consumption rating for the vehicle for a particular year. (So, in lay terms, a feebate refers to the combination of a fee on low-mileage vehicles and a rebate on fuel-efficient vehicles.) There are an infinite number of design options, based on nine main variables:
  • RateBasis. Fuel consumption expressed as litres(l) per 100 kilometres (km) is the most likely choice;this ensures that each litre saved has the same value      
  • Form of the Feebate Function.Linear functionsare possible; caps provide ways of avoiding excessivefees or rebates that contribute little to the effectivenessof the measure, and deadbands provide a way of avoidinglarge numbers of small transfers close to the pivot point.   
  • Rate.Assuming a linear function, this refers to the slopeof the line.      
  • Numberof Classes. The options include a singlesystem, a two-tier system (cars and trucks), or multipleclasses (by weight, or interior volume).        
  • Applicationand Exemptions. Various classes of vehiclescould be exempt.        
  • ManufacturerFeebate or Consumer Feebate. This choiceshould make little difference as manufacturers willdetermine how to factor in the feebate when determiningprices.       
  • RevenueNeutrality. While preserving the principleof revenue neutrality, there are a variety of optionson how to handle the uncertainty associated with havingto predict the overall balance between fees and rebates.       
  • Phase-InPeriod. Any length of time is possible.         
  • Paidat Purchase or Annually. This refers to thepossibility of an ongoing feebate implemented throughthe vehicle registration system.       

Modeling of Feebate Options In order to evaluate the different options, two separate models were used:

  • TransportCanada Variant of Greene et al. Vehicle Purchase Model.This is a spreadsheet-based, nested multinomial logitmodel that estimates the effect of feebates on consumerpurchasing behaviour and manufacturer investment infuel economy technologies. Transport Canada modified the model to use aggregated 2003 Canadian and US sales data and updated the technology cost curves based on a 2005 literature review.   
  • NRCanVehicle Stock Model. This is a simple representationof vehicle turnover and usage.      
Like
all modeling exercises, there are a number of limitations
and simplifications that apply. In the real world, manufacturers
and consumers make decisions based on a variety of factors
that are not easily represented by simple parameters.
This model assumes that manufacturers redesign their vehicles to maximize consumer surplus. The model does estimate changes in sales but does not address profits, since producers are assumed to be perfectly competitive.
  • Itwould give greater weight to the fairness criterion,while still being reasonably environmentally effectiveand economically efficient.     
  • Itwould give firms time to adjust.       
  • Itwould contribute to a risk management strategy byproviding the opportunity to: gather better informationon factors such as elasticities and valuation; assessissues regarding, for example, the import of usedcars; and, assess other implementation problems.   
Depending on the results, the rate could eventually be increased to the optimal level justified by the information gained. The key risks that affect the assessment are as follows
  • importantlimitations of modeling       
  • poorknowledge of Canadian elasticities       
  • poorknowledge of Canadian perceived value of fuel savings       
  • opportunitycosts for consumers       
  • riskof vehicle arbitrage       
  • heavyadjustment costs for some manufacturers       
As suggested above, a lower rate to begin (phase-in period) would help hedge against these risks and would provide an opportunity to gather real information on costs and benefits. If the MOU and feebates were implemented simultaneously,many or most of the benefits of the feebate would be included in the reference case. In theory this could mean that the effects would be additive. However, the reaction of manufacturers is unknown and there is a risk that they would respond to a feebate by withdrawing from the MOU. This suggests that feebates might best be considered as an alternative policy to the voluntary MOU, or as a subsequent policy following the expiration of the MOU.  
Other key limitations include:
  • Valuationof fuel savings. A central assumption of the modelis that consumers undervalue fuel savings. Althoughthere is evidence to this effect, there is no informationon the magnitude of the undervaluation. Sensitivityanalysis is done to investigate the effect.   
  • Consumerelasticities. These values determine the extent towhich consumers respond to price signals. Since thereis no data on Canadian elasticities, our approachhas been to use the elasticities proposed by Greeneet al. but to halve them, as a way of approximating long-run responses and to better represent assumed Canadian circumstances. We also undertake a sensitivity analysis.   
  • Hybridand diesel technologies are not included. As mentionedabove, hybrids and diesels are expected to play asignificant role in improving fuel economy. Unfortunately,the current version of the model lacks the informationnecessary to include these options. As a result, the  effectiveness of feebates is underestimated.   
  • Effectson used vehicle markets are not modeled. As mentionedabove, the used vehicle market represents more thanhalf of vehicle sales. However, the model assumesthat consumers primarily respond by shifting purchasesto other new vehicles. As a result, the effectiveness of feebates is overestimated.   
A series of 12 scenarios are modeled, representing a selection of options and assumptions. The most significant findings are:
  • Most scenarios result in significant fuel savings and GHGreductions.      
  • Most scenarios produce a net economic benefit, mostly inthe form of unvalued fuel savings.      
  • Most scenarios produce a significant shift in sales buttechnology still accounts for more than two thirdsof the improvement.     
  • GHG reductions and the shift in sales increase relativelylinearly with an increasing feebate rate.      
  • Benefits are positive for all rates but level off between $500and $1000.      
  • A cap removes incentives for highly inefficient vehiclesto improve, since a fixed fee is paid on them.      
  • A deadband removes incentives to improve fuel economyfor vehicles near the pivot point.      
  • If consumers are assumed to fully value fuel savings,the base case becomes more advantageous and the benefitsof feebates are correspondingly reduced. Fuel economystill improves but there is a net cost per tonne ofGHG emission reductions.   
  • Differentiating pivot points for cars and trucks means a lower feeor even a rebate as larger vehicles are assessed onlyagainst their cohorts. This discourages shifting tosmaller vehicles (less change in market shares) andmeans less improvement in consumer surplus and fewer GHG reductions. Going to 11 classes has little additional effect.   
  • With North American implementation, all vehicles improveaccording to the full change in consumer willingnessto pay. As a result, GHG reductions are larger andthe change in Canadian surplus is larger.    
  • With Greene’s original elasticities, consumers aremore sensitive to price changes. As a result, thesales mix changes more easily but policies are lesscostly, since consumers take greater advantage ofthe option to purchase other vehicle types. This doubles the size of the sales shifts and the GHG reductions.   
  • A higher fuel price means that there is more incentivefor fuel economy present in the base case. Thus, theincremental of the feebate on fuel and GHG savingsis reduced. On the other hand, the unvalued fuel savingsare worth more, so the overall benefit is higher and the benefit per tonne is greater. The price of fuel has little impact on the sales mix.   
The main value of the model is to assist in understanding the relationships between inputs and various indicators of environmental effectiveness, economic efficiency and other factors. Even though limitations and assumptions may affect individual results, there are a number of findings that are robust, including:
  • Feebates will encourage additional investment in fuel-efficiencytechnology and shift the market towards more fuel-efficientvehicles (trucks to cars, large cars to small cars,more fuel-efficient cars in the same class).    
  • Over time, this will improve the fuel efficiency of thevehicle stock and will reduce GHG emissions.      
  • The investment in fuel-efficiency technology will raisethe cost of individual vehicles and reduce consumersurplus accordingly.     
  • To the extent that consumers undervalue fuel savings,feebates will capture savings that would otherwisenot have been realized. If the undervaluation is significant,over the life of the vehicle fuel savings are likelyto exceed the added cost to vehicles, resulting in  a net economic benefit to society.   
  • Higher prices will depress vehicles sales.       
  • The shift towards more fuel-efficient vehicles will alsoreduce overall revenues.      
  • In a single-class feebate, General Motors (GM), Ford,and DaimlerChrysler (DCX) will lose additional marketshare and bear a disproportionate share of the adjustmentcosts. This could be alleviated by adopting separateclasses for trucks and cars, though doing so would reduce GHG savings and economic benefits.   
  • The extent of the shifts is determined by the elasticitiesof demand. If elasticities are greater than expected,the environmental and economic benefits will be greaterbut so will the adjustment costs. Conversely, if elasticitiesare less than expected, the environmental and economic benefits will be reduced, as will the burden on manufacturers.   

Assessment of Feebate Options

The Framework for Evaluation of Environmental Tax Proposals includes five criteria:
  • EnvironmentalEffectiveness. Feebates are less well-targetedthan alternatives such as fuel taxes but the mainconcern, the rebound effect, is expected to be nomore than 23 percent, and probably less. Consumersare expected to respond by switching from trucks to cars, from larger vehicles to smaller vehicles, and to more fuel-efficient vehicles within a given class.The car share of the vehicle market is expected to increase by 1–6 percent, depending on the rate. Manufacturers will respond primarily by investing in cost-effective technologies; however, some less fuel-efficient models may be dropped. The combination of technology improvements and shifts in purchasing is expected to yield fuel consumption improvements of 0.2 litres per 100 km to 0.8 litres per 100 km. Corresponding GHG reductions are expected to range from 1.5 Mt per year to 6.2 Mt per year, with 3.0 Mt per year for a $500 per litre per 100 km feebate. Adopting two or more separate classes would significantly lower the GHG reductions (because these are cumulative).The environmental effectiveness (as well as the revenue neutrality) of feebates could be compromised by the possibility of vehicle “arbitrage”—the import of relatively new large vehicles from the US and the export of relatively new smaller vehicles to the US. 
  • FiscalImpact.By definition, the measure will berevenue neutral. However, there will be administrationcosts and reductions in fuel taxes to consider. Thesecould be recovered from the feebate, but this couldbe perceived as a tax increase. It will also be necessary to consider options on how to handle the uncertainty associated with having to predict the overall balance between fees and rebates.   
  • EconomicEfficiency. To the extent that consumersfail to value fuel savings correctly—this issupported by the market research in Canada, thoughthe extent is unknown—feebates provide a meansof correcting this perception. Feebates also provide an indirect means of giving value to GHG reductions. Feebates impose costs which rise as the rate increases, but the reduction in consumer surplus is more than compensated for by unvalued fuel savings that are realized. The benefits are positive for all rates up to $1000 but marginal costs begin to outweigh benefits between $500 and $1000. Adopting two or more classes reduces the benefits significantly while creating a relative subsidy for larger vehicles. Because of the unvalued fuel savings, feebates produce economic benefits as opposed to costs. These range from $40 per tonne for a $250 per litre per 100 km feebate, to $10 per tonne for a $1000 per litre per 100 km feebate. If it is assumed that consumers already fully value fuel savings, then there are no unvalued fuel savings and the costs are in the range of $10 per tonne. By selectively targeting fuel economy, feebatesimpose opportunity costs. Feebates will only affect vehicle sales in Canada, so there should be no impact on exports. Furthermore, feebates should have no impact on the environment for manufacturing. However, as noted previously, an environment interpreted as hostile to the product could affect investment decisions. Overall vehicle sales are expected to decline slightly(at most 6000 or approximately 0.5 percent of annual  sales for a $1000 feebate). Of greater importance is the shift to less expensive models, which overall would reduce revenues by approximately $1.5 billion per year. (Note: these results are very sensitive to elasticity assumptions.) Although net sales may only decrease slightly, the employment impacts could be greater if imports are substantially increased. On the other hand, a large proportion of the North American adjustment may occur in the US. Given the overall economic benefit, the loss of jobs in this industry should be more than offset by job gains elsewhere in the economy.  
  • Fairness.In terms of market share, the main impact is furtherloss in market share for GM/Ford/DCX. The shift increasesas the rate increases, reaching 4 percent for a $1000per litre per 100 km feebate. This shift can be significantlymitigated by segmenting the market into two classes.(Having 11 classes does not make much additional difference.)  As far as profitability is concerned, the assumption is that all costs and savings are passed on, and so profits are unchanged. However, since there will be a shift to smaller vehicles, and historically these vehicles have had lower profit margins, it is reasonable to conclude that profits will be adversely affected. As far as parts suppliers and retailers are concerned, they will be affected in proportion to their exposure to GM/Ford/DCX. For individuals, the key issue is price. The price of each individual vehicle will rise to pay for new technology. However, consumers are expected to shift to lower priced models within classes and to lower priced classes overall, so average prices will decline. Certain consumers who are unable or unwilling to shift will bear a greater burden. For example, the estimated 50 percent of consumers who use trucks for commercial purposes may not be able to avoid the higher fees. Similarly, larger families may be restricted in shifting to smaller vehicles. Regions and areas that have a greater preference for larger vehicles (western Canada and rural areas, for example) will find that their traditional choices are more costly. Conversely, consumers who would have purchased fuel-efficient vehicles anyway will gain a windfall. Because lower income households tend to purchase smaller vehicles, the measure is progressive overall. (Feebates will eventually influence prices in the used car market as well as new cars.)  
  • Simplicity.The size of the transfers will range from approximately$300 million per year to $1.1 billion per year, whereasthe number of transactions will be equal to the numberof new vehicle sales (1.5 million per year). A singleclass would clearly be the simplest approach, whereas11 classes could be cumbersome to manage. Because definitions are unclear, anything more than one class creates the potential for gaming (artificially changing features to move vehicles into a different class). Similarly, the use of a cap, plateau or deadband would introduce added complexity and induce responses that would reduce the effectiveness of the measure. In terms of administrative practicality and costs, the measure could be similar to the Goods and Services Tax (GST). Retailers would need to collect the fees, pay the rebate, and submit the appropriate paperwork on a regular basis. Overall, given the experience of the GST, it would be anticipated that costs would be significant at first but would fall substantially after the initial implementation.  

Conclusions

As noted previously, the modeling results are subject to significant limitations and assumptions, but some robust conclusions are possible:
  • Feebatescan be designed to be environmentally effective andeconomically efficient. Although other measures suchas fuel taxes may be better targeted, feebates area legitimate alternative should other measures notbe feasible.   
  • Theimposition of feebates will involve difficult adjustmentsfor automobile manufacturers at a time when the industryis faced with the challenge of oversupply. GM, Fordand DCX will bear most of the burden.    
  • Themeasure is administratively feasible and can be designedto be fiscally neutral.      
  • Thereare significant uncertainties and risks that affectthe magnitude of the benefits as well as the marketshifts involved.     
Overall, a feebate of $1000 per litre per 100 km would appear to be most promising since it delivers the greatest economic benefit, and avoids the large shifts in market share associated with higher rates. This option would produce GHG reductions of 3 Mt per year in 2010 rising to 6 Mt per year by 2018. (By comparison, the MOU target is 5.3 Mt per year in 2010.) However, starting with a rate of $500 per litre per 100 km would be helpful in three ways: