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Capacity for innovative change: Governing competing pressures in energy delivery Caroline Euler Master of Public Administration, Class of 2021, London School of Economics and Political Science Photo by Frédéric Paulussen on Unsplash Photo cropped and modified to black and white

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Capacity for innovative change: Governing

competing pressures inenergy delivery

Caroline EulerMaster of Public Administration, Class of 2021,

London School of Economics and Political Science

Photo by Frédéric Paulussen on UnsplashPhoto cropped and modified to black and white

ABSTRACT

Germany drastically expanded renewable energy sources and improved energy efficiency; yet, paradoxically, emission levels remain virtually unchanged (Pahle, 2010; Pearce & Evans, 2016). The paper extends Murray Horn’s (1995) transaction cost approach with path dependency and institutional logic elements (Acemoglu & Robinson, 2012; Pierson, 2000; North, 1996). Applied to Germany, the framework offers an understanding of Germany’s lengthy coal phase-out and seemingly contradictory latest climate policy. Preference and price changes induced by the European Union’s push for liberalisation and public opinion changed the coal industry’s characteristic transaction cost mix. In contrast, strong lobby groups, an extensive system of coal subsidies and increasing returns of an early nuclear phase-out exerted a strong pull for the status quo. Managing these competing pressures, the government sustained a declining and harmful industry for decades past its socially- and economically efficient lifespan. A shifting balance of these pressures eventually enabled innovative climate policy, albeit non-transformational and within established strategies. The framework provides an understanding of the divergences between the passed 2020 ‘Climate Exit Law’ and the Coal Commission’s recommendations. The analysis fosters our understanding of how even climate policy-leading, prosperous nations struggle to undergo institutional change in an environment of dynamic, competing and sustained tensions.

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TRANSFORMATION THROUGH ENERGY MARKET LIBERALISATION

Countries are undergoing a “large-scale ‘socio-technical structural’” transformation by developing, implementing and enhancing low-emission energy technology (Haley, Gaede, Winfield & Love, 2020 p.2). Theoretically, adopting renewable energy technology enables economies to further uncouple economic growth from increasing emissions – a trend that has characterised Western economies for decades (Bernauer, Kalbhenn, Koubi & Spilker, 2010; Stern, 2007). Germany drastically expanded renewable energy sources and improved energy efficiency. Yet, paradoxically, emission levels are virtually unchanged in light of increasing investments and subsidies to an outdated coal industry (Pahle, 2010; Pearce & Evans, 2016). Still, coal-generated electricity accounts for 20% of the domestic and 65% of the European public electricity market (Frauenhofer, 2020; BMWI, 2020). The most recent 2019 Kohleaustiegsgesetz [coal exit law] specifies 2038 as the coal exit deadline, exceeding other time horizons by 8 to 16 years (e.g. Sweden, Denmark and Portugal) (BMWI, 2020).

According to Douglas North’s (1996) institutional logic approach, sustained economic growth requires allocative efficiency and adaptive efficiency. The latter implies setting prices right over time by rewarding innovations while dissolving obsolete and inefficient industries (Ibid.). For Germany, adaptive efficiency would entail a reorganisation of the delivery of energy and electricity by the dominant coal industry. Yet, a complex corporatist state culture with long-standing ties to coal dampened reorganisation and prolonged the industry’s decline beginning in 1958 (Peter, Lenz & Lenck, 2019). The associated large public, environmental and economic costs threaten Germany’s adaptive efficiency (North, 1996).

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The German government faced agents advocating for the transformational potential of renewable energy opposed by well-established structures favouring the coal industry. The challenge intensified for the ‘grand coalition’ government of Christian-Conservatives (CDU/CSU) and Social Democrats (SPD) after the decision to phase out nuclear in 2010. The paper combines and extends Murray Horn’s (1995) transaction cost (TC) approach with path dependency and institutional logic elements to understand how the German government managed competing pressures for and against complete energy market liberalisation (Acemoglu & Robinson, 2012; Pierson, 2000; North, 1996). Hence, the paper sheds some light on paradoxically high emission levels, subsidies to an outdated industry and a highly compensated, late coal exit. Section one discusses in detail the competing pressures and their management by the German government over time. Section two offers a perspective on how dynamic shifts lead to the most recent innovative but unambitious climate legislation.

COMPETING PRESSURES

Pressures for Change

According to Horn (1995), the enacting legislators determine governance structures to maximise their political support under electoral competition. Legislators exchange votes against regulations that positively affect private cost-benefit-calculations in qualitative, quantitative and persistent ways. German private coal enterprises started enjoying massive special privileges after the 1958 coal crisis when international competition made domestic mining and burning uneconomic – that is nine years after the industry’s peak (Höök, Zittel, Schindler & Aleklett, 2010; Storchmann, 2005). These privileges included a complicated set of direct and indirect subsidies (e.g. for ground sinking); protection

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from competition and high rents from under-pricing natural resources; social, structural, R&D and decommissioning support; and sales preferences (Storchmann, 2005; Haley et al., 2020; ZDF, 2018; Peter et al, 2019). More broadly, based on the proximity to the German government, creditors were implicitly guaranteed against the industry’s failure (Horn, 1995; Pahle, 2010).

Yet, in the TC framework, legislators’ opportunities to increase public support are limited by total transaction costs and involve trade-offs (Horn, 1995). Given available policy tools and bounded rationality, maximising political gains hence means minimising total transaction costs (Ibid.). In Germany, two emerging and strengthened agents shifted the available instruments and transaction cost mix: The European Union (EU) and German taxpayers. Hence, politicians needed to readjust for constituents’ interests demanding organisational reform and liberalisation (Ibid.).

The European Union

First, the formation of the European Union embodies North’s (1996) two sources of institutional change: preference and price changes. Equipped with new supranational institutional mechanisms, the EU was determined to build a harmonised European single market with a free, competitive and efficient market philosophy (Peter et al, 2019). Before 1996, Germany’s electricity market was organised as vertically-integrated large utility companies forming natural area monopolies, mixed with rare municipality-ownership (Ibid.). For instance, in 2000, four large suppliers owned the utility network grid and half of the end-user contracts (Ibid.).

The EU guided Germany’s energy market liberalisation process and pushed climate concerns through three energy packages in 1996, 2003 and 2009 (Peter et al, 2019). Directly, these directives broke up monopoly structures, induced competition,

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expanded market access, and protected customer and their right to choose suppliers (Ibid.). Negotiations to end direct subsidies worth 3.5 billion Euros started in 2007 (DW, 2007). Indirectly, price changes through competitive European electricity trading pushed old and inefficient anthracite coal power plants off the market after 2002 (Peter et al., 2019). Additionally, the European Emissions Trading System (EU ETS)’s carbon price started threatening high-emission lignite coal fuels (Peter et al, 2019; Blondeel, Graaf & Haesebrouck, 2020). Furthermore, renewables received special privileges through subsidies and priority in network feed-in (Peter et al, 2019).

Adjusting the electricity market’s formal and informal rules, the EU interventions reduced three of Horn’s (1995) transaction costs previously justifying coal’s special privileges. First, competition problems from previously large energy companies and network externalities reduced with unbundling services, outsourcing utility grid management and encouraging market access of small-scale renewable energy producers (Horn, 1995; Peter et al, 2019). Second, the coal industry’s forward and backward linkages reduced (Horn, 1995). Consumers and energy-intensive industries rely less on coal (Peter et al., 2019). Price changes and providing a transparent regulatory environment enabled renewable energy to replace coal as the primary energy source (Ibid.). Low-emission energy sources recently surpassed 50% of the net public electricity generation (Frauenhofer, 2020). Moreover, the coal industry is no longer a key employer or economic sector such as automobiles (Appunn, 2019; Pieper, 2019; Schulz & Schwartzkopff, 2015). Thus, decreasing pressures for government intervention based on powerful consumer, supplier and labour union groups (Horn, 1995). Third, the importance of former non-commercial objectives reduced (Horn, 1995). Given ameliorated market failures and improved energy storage systems, renewables dissolved the ‘energy policy trilemma’ between affordability, security and efficiency (Peter

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et al., 2019; Evans, 2018; Evans & Pearce, N.a.). Moreover, the end of the Cold War and increasing connectivity of European electricity grids ended political energy security concerns which previously necessitated coal (Evans, 2016; Peter et al, 2019).

German Taxpayers

Next to the EU, German taxpayers forced legislators to consider further market liberalisation. In contrast to special interest groups, taxpayers have diffuse and weak interest in the performance of public enterprises (Horn, 1995). Thus, they typically are ignorant of the large regulatory expenses they carry (Ibid.). Yet, citizens increasingly became aware of their individual costs of the highly privileged coal industry. First, private cost from climate change impact became more transparent with the EU’s intervention and indemnification of climate targets (Peter et al, 2019; IPCC, 2014). Second, subsidies became highly visible as the previously complex set of 38 distinct measures in 1982 were bundled to six in 2002 (Storchmann, 2005; Schleifer, 1998). Third, taxes on end-user electricity prices rose from subsidising both coal and renewables (Peter et al., 2019). Consequently, taxpayers demand improving financial performance through privatisation (Horn, 1995).

Upon changed participation cost-benefits ratios, German taxpayers express their demands through voting (Horn, 1995). Particularly, voters’ pro-climate preferences showed through the Green Party’s large electoral successes in local elections (Weidner & Mez, 2008). Given Germany’s mixed electoral rules, niche parties have a reasonable chance of governing (Lampe & Trinius, 2009; Weidner & Mez, 2008). Facing heightened electoral competition, the CDU-SDP coalition was forced to make concessions to the general public (Horn, 1995). Consequently,

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past reasons for both taxpayers and political parties to accept subsidies to the coal industry significantly reduced.

Pressures for the Status Quo

The EU and German taxpayers pressured legislators to rethink the balance of interests between the public and coal constituents through preference, price and electoral changes. Despite alterations to the distinctive transaction cost mix, the coal industry’s structural form did not fully follow function (Horn, 1995; North, 1996). While similar pressures lead to privatisation of the UK’s coal industry in the 1980s, Germany’s liberalisation process is still ongoing (Horn, 1995; Peter et al., 2019). Correspondingly, there has been no major decline in the coal industry after halving production between 1965 and 2000 (Pearce & Evans, 2016). Institutional logic and path dependency elements contributions to the TC approach’s explanatory gaps is two-folded. Firstly, explaining the coal enterprises’ ownership and, secondly, how liberalisation was further slowed down by transactionally, symbolically and structurally strengthened coal constituents (Horn, 1995; North, 1996).

Institutional path dependency and logic provides the necessary stability and continuity to engage in complex and uncertain industry-politics interactions across space and time (North, 1996). Otherwise, we could only partially explain why Germany opted for private, heavily privileged monopolist structure rather than state-ownership in the first place (Horn, 1995; North, 1996). Archetypically, the former exhibits high TC from both sides’ inability to trust relational contracts and fear of opportunism (Horn, 1995). Yet, Germany mitigated through a corporatist, consensus-based logic with strong legalist conventions and social-market-economy principles (Schaffrin, Sewerin & Seubert, 2014; North, 1996).

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Clashing with the EU paradigm, institutional logic explains industry groups’ heightened ability to hinder and slow down decisiveness and full liberalisation. Directly, losers of the ‘creative destruction’ process try to maximise profits within regulatory constraints for as long as possible (Acemoglu et al, 2012; North, 1996). For example, until 2011, operators exploited the EU’s legislative gaps that allowed for insider trading based on information asymmetries on coal sites’ operational conditions (Peter et al., 2019). Indirectly, interest groups influence procedures and decisions (North, 1996). For instance, Germany was the only European country choosing a negotiated rather than regulated grid access in 1996, failing to produce sufficient competition until further EU intervention in 2013 (Peter et al., 2019). Moreover, interest groups lobbied for grandfathering of carbon permits in the EU-ETS (Ibid.). Consequently, leading to windfall profits and a very low carbon price that failed to internalise the emission externalities of accessible lignite reserves (Peter et al., 2019; Blondeel et al., 2020; Grubb, 2014).

The symbiotic evolution of regional economies and political parties further strengthened coal constituents’ position by solidifying former transaction cost constellations (North, 1996). First, the symbolic image of a coal miner associated with post-war Germany’s Wirtschaftswunder [Economic Miracle] is still closely intertwined with the SPD’s political identity (Peter et al., 2019; ZDF, 2018; Commerell, 2013). Second, former coal regions generally remain structurally disadvantaged, despite most mining workers’ retirement or re-training between 1990 to 2012 and cities remodelling into innovation centres (Schulz & Schwartzkopff, 2015; Schuck, 2018). Cultural coal-based identities are only slowly changing (ZDF, 2018; Schuck, 2018). Although former monopolist structures might suggest otherwise, coal is no standard product with local economies having developed and specialised in close historic relations (Horn, 1995; Peter et al., 2019; Thorade, 2016). Third, today, these regions largely overlap

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with persisting structural divisions between former East-West Germany and increasing support of the populist Alternative for Germany party (Pearce & Evans, 2016; BPB, 2015; Decker, 2018). Consequently, symbiotic evolution increased the political burden of non-commercial objectives and electoral threat from the right (Horn, 1995).

In Horn’s (1995) framework, path dependency is an exogenous variable determining the available policy instruments to legislators who optimise total TC in the face of forward-looking constituents. However, endogenously, constituents and legislators also take short-term opportunities and react to ideas and ideologies (North, 19996; Pierson, 2000). These choices exhibit increasing returns, leading to partially unintended consequences and creating a new path (Ibid.). Subsidies starting as temporary support of the coal industry in 1958 became increasingly irretrievable (Storchmann, 2005). Reacting to the industry’s proximity to government and an inappropriately low carbon price, investors’ increased capital flows into coal plant construction in 2009 (Pahle, 2010). The high sunk cost associated with a revitalised ‘dash for coal’ either would have locked Germany into a higher-carbon emissions path for at least four decades or required larger compensation (Ibid.). Furthermore, reversal costs increased as politicians reacted to the short-term opportunity of broad public acceptance of the anti-nuclear movement (Pierson, 2000). The 2011 Fukuyama nuclear explosion was a critical junction shifting the CDU policy stance and thereby uniting all three major political parties behind the Energiewende [energy transition] paradigm (Evans, 2016). Constituents are unlikely to have been as forward-looking to realise that prioritising a nuclear phase-out would sharply reduce low-emission alternatives to ensure Germany’s energy security.

These procedural rationality-based decisions generated a different emissions-reduction performance outcome based on

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two unintended consequences in the electricity market (North, 1996; Pierson, 2000). First, lignite became more profitable given unthinkable nuclear energy, a low carbon price, subsidised renewable energy and increasing capital flows. So profitable, it increasingly drove natural gas off the market (Pearce & Evans, 2016; Capion, 2019; Blondeel et al., 2020). Thus, high-emissions lignite replaced lower-emission energy sources such as anthracite coal, nuclear and natural gas energy sources. Second, lignite and renewable energy sources became mutually dependent. Renewable energy supply is naturally volatile as geographically proximate plants produce simultaneously (Pearce & Evans, 2016). The result is price cannibalising - energy prices by default are pushed down exactly when production capacity is optimal (Ibid.). Until the EU improved storage conditions, renewables relied on coal-generating capacity as a ‘transition’ or ‘back up’ option (Ibid.). In turn, a large renewables share is needed to avoid blowing up Germany’s carbon budget (Bundesregierung, N.a.; Pearce & Evans, 2016). The so-called Energiewende paradox arises as a consequence of profitability of high-emission lignite and dependency of renewable energy. Despite an absolute decrease of unsustainable energy sources, total energy production emissions remained seemingly unchanged (Pearce & Evans, 2016).

COAL EXIT LAW: INNOVATION VS TRANSFORMATION

The above shows how the German government carefully managed competing pressures by only responding to EU directives only as much as formally needed and within its institutional logic. It responded to demands by extending special privileges to both sides, often following seemingly contradicting goals (Storchmann, 2005; Peter et al., 2019). For coal, simultaneously supporting closures and production

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(Storchmann, 2005). For renewables, subsidising extensions but limiting expansion through a cap and regulatory barriers (Pearce & Evans, 2016). Similarly, taxpayers were encouraged to reduce their energy use while receiving counterproductive financial relief (BR, 2019).

Ultimately, specifying a coal exit plan was required to manage the growing tensions which threatened the delicate balance of interests. The main enacting legislator, the CDU-SPD governing coalition party, proposed a new governance structure in the Kohleaustiegsgesetz [coal exit law], adding to the prior 2019 Strukturstärkungsgesetz [structure strengthening law] (BPB, 2019; Bundesregierung, N.a.). In line with general climate and energy policy, there has been no radical shift in the institutional-logic-driven strategy (Schaffrin et al, 2014). Nonetheless the coal exit law introduces substantial policy innovations including a larger use of market-tools (Ibid.). Considering path dependence and institutional logic, Horn’s (1995) four intertwined transaction cost bundles help understand the latest climate policy and its lack of the needed radical transformation.

Decision-making Costs

Horn’s (1995) first transaction cost bundle states that legislators’ decision-making costs increase with intensifying interest conflicts. Climate movements gained momentum and public support, fuelled by years of delayed liberalisation and increasing visibility of climate impacts such as extensive summer droughts (Patel, 2020). The Green party criticises compensations of the coal industry and capping renewable energy expansion (Pearce & Evans, 2016; Pieper, 2019). They now actively threaten the grand coalition’s majority in national parliament (Lückoff, 2019; Tagesschau, 2019; Springer, 2019; Ehni, 2019). On the other side, as it has become apparent that a coal phase-out is

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inevitable, economic losers such as coal plant investors demand large compensation (Acemoglu et al., 2012).

The government responded by extending formal participation rights and proposal powers to a range of actors through a temporal advising body: the Commission on Growth, Structural Change and Employment (Acemoglu et al., 2012; BMWI, 2020). This institutional setting allowed civil society and experts such as environmental scientists to bargain and actively take part in the political-economic exchange (North, 1995). The coal commission was tasked with the unspecific and partially contradictory objective of agreeing on a coal exit both socially acceptable and meeting Germany’s climate targets (BMWI, 2020). In Horn’s (1995) framework, high decision-making costs necessitated vague legislation, hence, further delaying policy action. For instance, based on interest conflicts in the coal commission, power plants will not be closed based on specific emission levels but ‘steadily’ -- allowing the government to alter sequencing lower-emission anthracite coal plants’ closures before higher-emission lignite ones (BMWI, 2019).

Despite formal equal participation rights, the government informally was disproportionally responsive to private demands at the expense of civil society groups (North, 1996; Horn, 1995; BMWI, 2019). Based on the TC approach, the latter’s leverage relies on the broader public’s volatile interests with larger collective action problems (Horn, 1995). In contrast, smaller private interest groups united by the high individual stake’ outcome can sustain their influence at low participation costs; thus, allowing them to exploit vague legislation (Horn, 1995). Comparing the coal commission’s proposal to the passed legislation captures the possibility for further delays, avoidance of specific emission reduction targets and contentious issue of new power plants (BMWI, 2019). For example, the coal exit law provides the legal basis to dissolve emission permits freeing up

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from coal plants’ closures (BMWI, 2019). However, the practical utilisation of said law remains at the government disposal and does not have to be exercised (Ibid.). Furthermore, the coal commission agreed to prohibit the opening of new power plants constructed during the ‘dash for coal’ (BMWI; 2019). Yet, the passed legislation has a ‘special permissions’ loophole which the government is planning to use to open the ‘Datteln IV’ lignite power plant (BMWI, 2019).

Agency loss

In the TC framework, vaguer legislation shifts the burden of refining implementation to administrative and private agents (Horn, 1995). Thus, enabling private and public agents to deviate from the commission’s intended policy (Ibid.). Private agents, including power plant operators and mine owners, have to react to governance incentives as well as administer the coal exit plan. Private agency loss, for example, could arise from the ambiguous voluntary auctioning system. Ideally, anthracite coal plants able to shut down at the lowest demanded compensation should exit first with payments progressively decreasing until 2027 (Schmidt, 2020). Yet, without prescribing the necessary emission reduction, the legislation does not prevent anthracite coal plants with an economic incentive get off the grid anyway to make a profit without actually lowering emissions (BMWI, 2019).

Public agency loss arises from unspecified final offers and measures. The coal commission agreed to forcefully close the coal plant in case a negotiated solution would fail (BMWI, 2019). While passing such a forced progressive clause for anthracite coal, the legislator did not for lignite plans (BMWI, 2019). Thus, shifting the burden to public and private agents as well as decreasing the formers’ negotiation powers through the absence of a credible threat. Nonetheless, the broader German political

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structure reduces agency loss. Ministers monitor each other. For instance, the Green budget minister announced a reassessment of the finance minister’s decision to compensate coal power plants with 4.2 Billion Euros (Kista, 2020). Additionally, the Ministry of Economy and Energy will evaluate Germany’s general progress.(BMWI, 2019).

Commitment Problem

The third transaction cost bundle, political uncertainty, requires instruments to reduce costs from mistrusting--- regulatory longevity (Horn, 1995). Generally, legal oversight increases the governing coalitions’ ability to maximise electoral support from forward-looking coal constituents (Horn, 1995). For example, securing the coal exit by a strong agent independent of the legislator, aka the German courts, limits the scope of future legislators to undermine the promised compensations to the coal industry (Horn, 1995). Moreover, placing the highest exit compensation payments closer to the legislation’s enactment reduces political uncertainty (Horn, 1995; BMWI, 2019). Additionally, the risk of upward adjustment is minimised by referring to generous climate targets enshrined into German law (Appnn, 2019; BMWI, 2019). However, the legal oversight’s maximising effects are limited. For instance, the vague parts of the coal exit law have a higher chance of future renegotiations with the coal constituents’ defending their privileges (Horn, 1995). Particularly, in light of the EU strengthening of environmental groups’ legal position and legal monitoring of the industry (Fuder, Elspaß & Wilcock, 2019; Peter et al., 2019). Plans to sue the opening of the power plant ‘Datteln IV’ are underway (Gero, 2020).

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Risk and Cost Uncertainty

Next to political uncertainty, constituents adjust their electoral support on risk distribution and cost uncertainties (Horn, 1995). The main beneficiaries, coal plant owners and operators, carry the risk of higher than expected compliance costs (Horn, 1995). Yet, the risk is considerably minimised by the above listed favourable conditions as well as increased Länder’s structural aids and employment adjustment compensations (BMWI, 2019; BMWI, N.a.; Bundesregierung, N.a.; Schmidt, 2020). In comparison, taxpayers face high compensation costs as well as cost uncertainties relating to insufficient emission reductions and unstable electricity markets (Gero, 2020; Peter et al., 2019; Evans, 2018). Especially, since the coal industry is predicted to ‘naturally’ phase out through the ongoing market liberalisation, a higher European carbon price, and additional national carbon prices for fuels (Capion, 2019; Tagesschau, 2019). Yet, partially responding to concerns, the government plans to limit taxpayers’ and energy-intense industries’ electricity price surges (BR, N.a.). According to the TC approach, distributing these predominantly manageable risks are misplaced since taxpayers have no direct impact on the performance or negotiations with the coal industry (Horn, 1995).

CONCLUSION

Combining Horn’s (1995) transaction cost approach with path dependency and institutional logic theories fosters our understanding of how even climate-leading, rich nations struggle to undergo institutional change in an environment of competing, dynamic and sustained pressures (Acemoglu & Robinson, 2012; Pierson, 2000; North, 1996; Amelang, Egenter & Eriksen, 2019). Hence, ultimately sustaining a declining and harmful

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coal industry for decades past its socially- and economically efficient lifespan. In the last decades, the EU’s and broader public’s preference and price changes altered the coal industry’s characteristic transaction cost mix. Consequently, politicians were increasingly constrained in their ability to maximise net electoral support from extending massive privileges to the coal industry. Corporatist-consensus style politics and increasingly irreversible, self-enforcing choices filled two gaps in the TC approach: first, Germany’s ability to overcome commitment problems in the semi-private enterprise setting; and second, unintentionally exacerbation of the dependency on coal. Balancing pressures, the legislator pursued contradictory measures of supporting both coal and renewable energy sources.

With rising tensions and a coal phase-out becoming inevitable, the governing coalition continued their overall strategy but adjusted the governance arrangement in the coal exit law in 2019 (BR, N.a.). Advocates of change, the EU and civil society organisations, were provided with formal participation rights and open dialogue (BMWI, N.a.). Taxpayers and Länder on both sides of the debate receive further structural, employment adjustment and retrofitting subsidies as well as electricity price certainty (BMWI, 2019; Bundesregierung, N.a.; BMWI, N.a.; Schmidt, 2020). The divergence from the coal commission proposal suggests that Germany’s institutional logic remains primarily about consensus between governing parties and private interest groups. The lignite industry in particular was thereby allowed to maximise flexible direct and indirect special privileges, including: compensations, negotiation power and a long exit time horizon with relatively fixed and predictable costs. The energy’s sector high forward linkages, for example to the transport sector, makes reducing emissions crucial (Kemmler, 2020). The current climate action and coal exit legislation risk putting Germany on an above-2°C-pathways, implying high-probability high-risk

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climate impacts with immense economic damages (IPCC, 2014; Gero, 2020).

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