Market Forces

Trump Moves to Cook the Books, Undercutting Common Sense Climate Protections

By / Bio / Published: March 20, 2017

This blog was co-authored with Martha Roberts

It’s reported that the Trump Administration is poised to continue its barrage of attacks on some of our most vital health and environmental protections, following last week’s assault on broadly supported fuel economy and greenhouse gas safeguards for cars and light trucks. Here’s one attack that they may try to sneak under the radar—a move that would undercut common sense climate protection all across the federal government: directing federal agencies to abandon the use of social cost of carbon estimates in their evaluation of new policy.

The social cost of carbon is a measure of the economic harm from the impacts of climate change. Specifically, it’s the dollar value of the total damages from emitting one ton of carbon dioxide into the atmosphere. Weakening or eliminating the use of the social cost of carbon would result in skewed and biased policy-making that ignores the benefits of crucial safeguards and stacks the deck against actions to protect communities from the mounting costs of climate change.

The devastating impacts of climate change on health and the environment – such as extreme weather events, the spread of disease, sea level rise, and increased food insecurity – can cost American businesses, families, governments and taxpayers hundreds of billions of dollars through rising health care costs, destruction of property, increased food prices, and more. Many of these impacts are already being felt by communities across the country, as the government’s leading scientific agencies have found.

When the federal government develops policy affecting the carbon pollution causing climate change, it is both reasonable and essential that it takes these costs into account. The social cost of carbon is a tool that allows policy-makers to do just that.

Currently, the federal government uses a social cost of carbon estimate—roughly $40 per ton of carbon pollution—that was developed through a transparent and rigorous interagency process, relied on the latest peer-reviewed science and economics available, and allowed for repeated public comment as well as input from the National Academy of Sciences.

But that may not last much longer. As we’ve seen, the Trump Administration is waging war against an array of our most crucial health and environmental protections, ignoring the urgent threat of climate change while prioritizing fossil fuel interests. President Trump’s new Administrator of the Environmental Protection Agency, Scott Pruitt, denies that carbon pollution is a primary contributor to climate change, and built his political career by suing EPA 14 times as Oklahoma Attorney General to block protections from mercury, arsenic and smog pollution, hand in hand with the worst elements of the fossil fuel industry. Meanwhile the Administration is proposing devastating cuts to the budgets for EPA and climate research, and is moving towards revoking the Clean Power Plan, America’s first-ever nationwide limits on carbon pollution from power plants.

All of this points to a clear disregard for basic science, economic principles, and our nation’s clean air laws. Eliminating or weakening the social cost of carbon is another pernicious tactic by the Administration to undermine the development of crucial climate safeguards – by erroneously making it appear as though reducing carbon pollution has little or no benefit to society and the economy. Even the current figure is very likely a conservative lower bound since it does not yet include all of the widely recognized and accepted impacts of climate change.

The details of the upcoming attack are still unclear. It’s possible that the Administration may end use of the uniform social cost of carbon estimate at the federal level—despite its rigorous basis and judicial precedent. Other indications suggest that the Administration may choose to artificially and arbitrarily discount the costs of climate change for the health and economic well-being of our kids, grandkids, and future generations—ignoring the growing consensus among economists that supports valuing these impacts more, as does a recent report from the Council of Economic Advisors. Or the Administration may decide to disregard the fact that our greenhouse gas pollution has harmful impacts outside U.S. borders that can have costly repercussions for Americans.

Throwing out the social cost of carbon may play well with President Trump’s supporters in the fossil fuel industry. But the importance and appropriateness of accounting for these costs is a matter of both economics and law. We also know that nearly two thirds of Americans are concerned about climate change. Undermining limits on pollution—protections that are rooted in rigorous scientific research, reflecting long-standing bipartisan economic principles—will ultimately harm the health and environmental safety of all Americans, including Trump’s supporters.

Posted in Politics, Social Cost of Carbon, Uncategorized / Leave a comment

The United States Could Lead the Next Tech Revolution by Investing in Clean Energy

By / Published: January 9, 2017

New Risky Business Report Finds Transitioning to a Clean Energy Economy is both Technologically and Economically Feasible

In the first Risky Business report, a bi-partisan group of experts focused on the economic impacts of climate change at the country, state and regional levels and made the case that in spite of all that we do understand about the science and dangers of climate change, the uncertainty of what we don’t know could present an even more devastating future for the planet and our economy.

The latest report from the Risky Business Project, co-chaired by Michael R. Bloomberg, Henry M. Paulson, Jr., and Thomas F. Steyer, examines how best to tackle the risks posed by climate change and transition to a clean energy economy by 2050, without relying on unprecedented spending or unimagined technology. The report focuses on one pathway that will allow us to reduce carbon emissions by 80 percent by 2050 through the following three shifts:

1. Electrify the economy, replacing the dependence on fossil fuels in the heating and cooling of buildings, vehicles and other sectors. Under the report’s scenario, this would require the share of electricity as a portion of total energy use to more than double, from 23 to 51 percent.
2. Use a mix of low- to zero-carbon fuels to generate electricity. Declining costs for renewable technologies contribute in making this both technologically and economically feasible.
3. Become more energy efficient by lowering the intensity of energy used per unit of GDP by about two thirds.

New Investments Will Yield Cost Savings

Of course, there would be costs associated with achieving the dramatic emissions reductions, but the authors argue that these costs are warranted. The report concludes that substantial upfront capital investments would be offset by lower long-term fuel spending. And even though costs would grow from $220 billion per year in 2020 to $360 billion per year in 2050, they are still likely far less than the costs of unmitigated climate change or the projected spending on fossil fuels. They’re also comparable in scale to recent investments that transformed the American economy. Take the computer and software industry, which saw investments more than double from $33 billion in 1980 to $73 billion in 1985. And those outlays continued to grow exponentially—annual investments topped $400 billion in 2015. All told, the United States has invested $6 trillion in computers and software over the last 20 years.

This shift would also likely boost manufacturing and construction in the United States, and stimulate innovation and new markets. Finally, fewer dollars would go overseas to foreign oil producers, and instead stay in the U.S. economy.

The Impact on American Jobs

The authors also foresee an impact to the U.S. job market. On the plus side, they predict as many as 800,000 new construction, operation and maintenance jobs by 2050 would be required to help retrofit homes with more efficient heating and cooling systems as well as the construction, operation and maintenance of power plants. However, job losses in the coal mining and oil and gas sectors, mainly concentrated in the Southern and Mountain states, could offset these employment gains. As we continue to grow a cleaner-energy economy, it will be essential to help workers transition from high-carbon to clean jobs and provide them with the training and education to do so.

A Call for Political and Private Sector Leadership

Such a radical shift won’t be easy, and both business and policy makers will need to lead the transition to ensure its success. First and foremost, the report asserts that the U.S. government will need to create the right incentives.  This will be especially important if fossil fuel prices drop, which could result in increased consumption.  Lawmakers would also need to wean industry and individuals off of subsidies that make high-carbon and high-risk activities cheap and easy while removing regulatory and financial barriers to clean-energy projects. They will also need to help those Americans negatively impacted by the transition as well as those who are most vulnerable and less resilient to physical and economic climate impacts.

Businesses also need to step up to the plate by auditing their supply chains for high-carbon activities, build internal capacity to address the impacts of climate change on their businesses and put internal prices on carbon to help reduce risks.

To be sure, this kind of transformation and innovation isn’t easy, but the United States has sparked technological revolutions before that have helped transform our economy—from automobiles to air travel to computer software, and doing so has required collaboration between industry and policymakers.

We are at a critical point in time—we can either accelerate our current path and invest in a clean energy future or succumb to rhetoric that forces us backwards. If we choose to electrify our economy, reduce our reliance on dirty fuels and become more energy efficient, we will not only be at the forefront of the next technological revolution, but we’ll also help lead the world in ensuring a better future for our planet.

Posted in Energy efficiency, Politics, Technology / Leave a comment

America needs critical energy data in a “post-fact” world: 2 quick examples

By / Bio / Published: December 28, 2016
This post originally appeared on EDF’s Voices blog.

We learned earlier this month that scientists are rushing to save critical climate data on government websites before the Trump administration takes over in January. They fear that such data may be deleted and forever lost, and it’s not hard to see why.

The incoming administration has announced plans to roll back existing climate change initiatives and there have been proposals to cut research programs that support a broad range of scientific expertise, such as weather prediction critical to farmers and to states vulnerable to major disasters.

In addition to science-based climate data, however, there is concern that other critical information and analyses under the purview of agencies such as the U.S. Department of Energy may be imperiled early next year. Unbeknownst to many – including, perhaps, to the president-elect and his circle of insiders – all these datasets benefit a broad range of sectors that rely on solid economic forecasting.

Here are just two datasets that are absolutely central to the work economists and analysts do to help industry and other decision-makers interpret energy opportunities and challenges in a rapidly changing world.

1. Energy forecasts: companies depend on them

The Annual Energy Outlook reports produced by the Energy Information Administration – a 30-year-old, independent office within the Energy Department – offers economic and energy forecasts with data invaluable to the transportation and manufacturing sectors, among others. Researchers, regulators and policymakers use them, too.

It includes data on economy-wide energy consumption and electricity prices all the way down to minute information such as carbon emissions from residential clothing dryers. Companies use the report to inform energy cost projections as they strategize and forecast business operations.

This way, an aluminum smelting company that uses a very energy-intensive process, for example, can anticipate changes in energy prices and make decisions accordingly.

We already heard about a proposal to cut NASA’s climate research funding, so it’s no mystery we also worry about how a report such as the Annual Energy Outlook could be affected by a wider crackdown on scientific and economic research and data generation.

Notably, EIA was part of a controversial questionnaire the Trump administration recently sent the Energy Department.

2. Cost comparisons: help investors be smart

The cost of renewable energy is a constant source of debate and has a direct impact on innovation and investment. A utility that needs to add generation, for example, must remain informed about how the operational costs of wind turbines compare with those of a natural gas-fired power plant.

The Energy Department’s prestigious National Renewable Energy Laboratory provides a terrific amount of research on the costs of this and other sources of renewable energy, feeding them into tools such as the Transparent Cost Database.

These estimates help investors as well as consumers evaluate the cost of renewable energy sources in direct comparison to fossil fuels in an unbiased way. The outcome is smarter and more informed decisions.

Our national labs would be overseen by Texas Gov. Rick Perry if he’s confirmed as the Trump administration’s secretary of energy. The governor, who lacks the science credentials of past energy secretaries, once said he would eliminate the agency altogether.

So why the panic over data?

We know that many of the people picked for the Trump cabinet so far openly question climate science, or science in general, and that several of the nominees who will oversee agencies producing such data have a history of putting the interest of the fossil fuel industry ahead of progress on clean energy.

Beyond that, potential budget cuts are looming. Government agency heads opposed to climate action or investments in renewable energy could easily starve the programs that maintain, update and share data with the public if such information no longer fits the administration’s agenda.

Scientists are thus taking steps to download data in preparation for the day when access may be interrupted.

But a country needs hard facts and sound evidence to make smart decisions about its energy and economic future. So we need to continue to lean heavily on the apolitical data that hardworking researchers in government produce for our industry, farmers, entrepreneurs, local and state policymakers, and world-renowned researchers.

Perhaps more than ever before, we must protect and defend this vital information.

Posted in Climate science, Politics / 1 Response

How Companies Set Internal Prices on Carbon

By / Published: December 8, 2016

This post was co-authored with Elizabeth Medford

Despite the uncertainty created by the recent election, companies around the globe are demonstrating a commitment to keeping climate change in check. More than 300 American companies signed an open letter to President-elect Trump urging him not to abandon the Paris agreement. Others are acting on their own to reduce emissions in their daily operations, by setting an internal price on carbon.

The number of companies incorporating an internal carbon price into their business and investment decisions has reached new heights, a recent CDP report shows, with an increase of 23 percent over last year. The more than 1,200 companies that are currently using an internal carbon price (or are planning to within two years) are using them to determine which investments will be profitable and which will involve significant risk in the future, as carbon pricing programs are implemented around the world. Sometimes, they also use them to reach emissions reduction goals.

Not all carbon prices are created equal, and companies differ in how they set their specific price. Here’s a look at some of these methods:

Incorporating Carbon Prices from Existing Policies

 Some companies set their carbon price based on policies in the countries where they operate. For example, companies with operations in the European Union might decide to use a carbon price equal to that of the European Union Emissions Trading System (EU ETS) allowances, and those operating in the Northeastern United States might adopt the carbon price that results from the Regional Greenhouse Gas Initiative market.

ConocoPhillips, for example, focuses its internal carbon pricing practices on operations in countries with existing or imminent greenhouse gas (GHG) regulation. As a result, its carbon price ranges from $6-38 per metric ton depending on the country. For operations in countries without existing or imminent GHG regulation, projects costing $150 million or greater, or that results in 25,000 or more metric tons of carbon dioxide equivalent, must undergo a sensitivity analysis that includes carbon costs.

Using Self-Imposed Carbon Fees

Others take a more aggressive approach by setting a self-imposed carbon fee on energy use. This involves setting a fee on either units of carbon dioxide generated or a proxy measurement like energy use. These programs also often include a plan for using the fees such as investment in clean energy or energy efficiency measures. This can be an effective method for incentivizing more efficient operations.

Microsoft, for example, designed its own system to account for the price of its carbon emissions. The company pledged to make its operations carbon neutral in 2012 and does so through a “carbon fee,” which is calculated based on the costs of offsetting the company’s emissions through clean energy and efficiency initiatives. Each business group within Microsoft is responsible for paying the fee depending on how much energy it uses. Microsoft collects the fees in a “central carbon fee fund” used to subsidize investments in energy efficiency, green power, and carbon offsets projects. Still, by limiting carbon fees to operational activities, Microsoft has yet to address a large chunk of their emissions.

Setting Internal Carbon Prices to Reach Emissions Reduction Targets

 Other companies set an internal carbon price based on their self-adopted GHG emissions targets. This involves determining an emissions reduction goal and then back-calculating a carbon price that will ensure the company achieves its goal by the target date. This method is a broader approach focused more on significantly reducing emissions while also mitigating the potential future risk of carbon pricing policies.

Novartis, a Swiss-based global healthcare company, uses a carbon price of $100/tCO2 and cites potential climate change impacts as a motivator. The company has its own greenhouse gas emissions target, which it is using to cut emissions to half of its 2010 levels by 2030. These internal policies mean that Novartis, which is included in the European Union’s Emissions Trading Scheme (EU ETS), has been able to sell surplus allowances and thus far avoid an increase in operating costs.

Where we go from here

 While these internal carbon pricing activities are welcome – and we hope they continue – they are not sufficient to reduce greenhouse gases to the degree our nation or world requires. Like these forward thinking companies, nations around the world, including the United States, need to consider the costs of inaction, including the climate-related costs, to avoid short-sighted investments. Ultimately, we will need public policies that put a limit and a price on carbon throughout the economy.

The spread of internal carbon pricing could signal greater support for carbon pricing by governments. But companies can do more: the ultimate test of a company’s convictions and commitment to carbon pricing might be their willingness to advocate for well-designed, ambitious policies that achieve the reductions we need.

Posted in Cap and Trade, International, Politics / Leave a comment

Good news in California as carbon auction results improve, and carbon emissions continue falling

By / Published: November 23, 2016

Co-authored by Erica Morehouse and Jonathan Camuzeaux (this post was originally posted in EDF Talks Global Climate).

While we hope President-elect Trump will listen to the almost unanimous global voice of governments and business leaders who all understand that we must act to avert catastrophic climate change, it’s indisputable that leadership from U.S. states will be of paramount importance. Amidst this chaos and uncertainty California and Quebec are now four years into a successful cap-and-trade program with shrinking carbon pollution footprints and thriving economies.

California and Quebec released results today from a much anticipated carbon auction that took place on November 15, and sold a greater number of allowances than in the past two auctions resulting in proceeds for the state Greenhouse Gas Reduction Fund.  This good news comes after California’s 2015 greenhouse gas reporting data earlier this month showed another year of carbon pollution decline for the Golden State.

These year-over-year pollution declines are the most important indicator of success.  But understandably the auction performance and amount raised for climate investment priorities will get a lot of attention in California, Quebec, and Ontario, which is slated to launch its own cap-and-trade program in January with linkage likely to California and Quebec in 2018.

Auction results see increased demand

The November 15 auction offered more than 87 million current vintage allowances (available for 2016 or later compliance) and sold almost 77 million. Approximately 10 million future allowances were offered that will not be available for use until 2019 or later; over one million of those allowances were sold.

These auction results represent a significant increase in demand from the August auction which offered a similar number and sold about 31 million allowances, up from a little over eight million allowances sold at the May auction, the first auction to experience very low demand for allowances.  The May and August auctions raised almost no revenue for the California Greenhouse Gas Reduction Fund (GGRF).  While final numbers won’t come in for another few weeks, based on the allowances sold, this auction likely raised over $360 million for the California GGRF. 

Impacts on demand for this auction

A number of factors, good and otherwise, contributed to this quarter’s results.

  1. One of the most immediate factors that likely contributed to increased demand in this auction is the knowledge that the minimum sale price or “floor price” will rise to about $13.50 in 2017. This is the last auction that participants will be able to purchase allowances for $12.73 before the annual increase.
  1. A constant during this and previous auctions is litigation brought by the California Chamber of Commerce and others challenging California’s cap-and-trade program design. The case was brought the day before California’s very first auction in 2012 and California won at the trial court level. The plaintiffs appealed, and the Court of Appeals will hear oral arguments on January 24, 2017. This outstanding litigation may be leading some potential auction participants to take a wait-and-see approach.
  1. This wait-and-see approach is only possible if regulated businesses in California already have enough allowances to cover their 2016 obligations. California just released preliminary data for 2015 which shows emissions were about 14 percent below the cap. This suggests a successful set of climate policies that are incentivizing polluters to lower levels of pollution below required levels if they are able.  Some have referred to this as an oversupply of allowances, but it’s perhaps more accurate to refer to it as over-compliance.  Businesses have a choice of how to respond when they over-comply: avoid buying allowances in a future auction or buy allowances when they are presumably cheaper and bank them for future use.

A big question is how much the passage of SB 32 in August has impacted auction demand.  Governor Brown had previously established a target of reducing carbon pollution 40 percent below 1990 levels by 2030 through an executive order, but SB 32 cemented this requirement into law making it much more certain.  Setting a 2030target could increase demand for allowances, but the market will not necessarily get certainty about that target or how California will meet it in one fell swoop.  While SB 32 set the 2030 target, like AB 32 it was silent on policy tools to meet that target so decisions about cap-and-trade post-2020 are still outstanding.

Greenhouse gas emissions decline again in 2015

California’s Mandatory Greenhouse Gas Reporting program requires that state’s largest polluters to report their emissions annually. The California Air Resources Board released the final tally of 2015 greenhouse gas emissions on November 4th, which showed yet another year of carbon pollution decrease.

In 2015, California’s emissions covered under the cap-and-trade program decreased by roughly one percent compared to the year before. California is on track to meet its target of reducing pollution to 1990 levels by 2020.  Carbon pollution for capped and uncapped sources was down in 2015.

Meanwhile, data from the Bureau of Economic Analysis shows the state’s gross domestic product increased by almost six percent in 2015 – while California also experienced an increase of total employment of a little over two percent in 2015 – proving again that economic output and emissions don’t necessarily go hand in hand.

With these results California is on solid footing to continue as a beacon of hope for climate action in the United States and perhaps even to attract new partners inside or outside the country who are ready to join a successful program.

Posted in Uncategorized / Leave a comment

Ensuring Environmental Outcomes from a Carbon Tax

By / Bio / Published: November 3, 2016

How can we ensure that a carbon tax delivers on its pollution reduction potential? An innovative, new idea could provide greater certainty over the environmental outcome.

As momentum intensifies around the world for action to fight climate change, the United States is emerging as a leader in the new low-carbon economy. But if we are going to reduce climate pollution at the pace and scale required — cutting emissions 26-28% below 2005 levels by 2025 and at least 83% by 2050, on a path to zero net emissions —we need to roll up our sleeves on a new generation of ambitious climate policies that harness the power of the economy and American innovation. An emerging idea could be a game-changer for the prospects of a carbon tax to help tackle climate pollution.

Economics 101 teaches us that market-based policies, including cap-and-trade programs as well as carbon taxes, are the most cost-effective and economically efficient means of achieving results. Both put a price on carbon emissions to reduce dangerous pollution. Cap-and-trade programs place a “cap” on the total quantity of allowable emissions, directly limiting pollution and ensuring a specific environmental result, while allowing prices to fluctuate as pollution permits are traded. The “guarantee” that the cap provides is a primary reason this tool has been favored by EDF and other stakeholders focused on environmental performance. That U.S. targets are based on quantities of pollution reductions also speaks to the need for policy solutions tied to these pollution limits.

In comparison, a carbon tax sets the price per unit of pollution, allowing emissions to respond to the changes in behavior this price encourages. The problem, from an environmental standpoint, is that a carbon tax lacks an explicit connection to a desired pollution reduction target — and therefore provides no assurance that the required reductions will actually be achieved. We know that a carbon tax will impact emissions, but even the most robust modeling cannot provide certainty over the magnitude of that impact. Furthermore, fundamental factors like energy or economic market dynamics can change over time, affecting the performance of a tax. Because greenhouse gas pollution accumulates in the atmosphere over time, even being slightly off the desired path over several decades can produce significant consequences for cumulative emissions, and thus climate damages.

A new approach: Environmental Integrity Mechanisms (EIMs)

Two recently-released papers by the Nicholas Institute at Duke University and Resources for the Future (RFF) directly address this key concern with a carbon tax —and suggest an innovative path forward. They illustrate how a suite of provisions – we’ll call them “Environmental Integrity Mechanisms” or “EIMs,” though each paper uses different terminology – could provide greater levels of certainty regarding the emissions outcome, by allowing for adjustment of the carbon tax regime over time to course-correct and keep us on track for meeting our targets.

EIMs – if carefully designed – can play an important role in connecting a carbon tax to its performance in reducing pollution. They are a type of built-in insurance mechanism: they may never be triggered if the initial price path achieves its projected impact, but provide a back-up plan in case it does not.

These mechanisms are analogous to well-studied “cost containment” provisions in cap-and-trade that are designed to provide greater certainty over prices. Cost containment provisions are included in several successful cap-and-trade programs around the world. For example, California’s cap-and-trade program includes a price collar that sets a floor as well as a ceiling that triggers the release of a reserve of allowances.

EIMs are a parallel effort to introduce greater emissions certainty into a carbon tax system. With the recent publication of these two papers, EIMS are beginning to receive well-deserved greater attention. These provisions help bridge the gap between caps and taxes, merging the strengths of each to create powerful hybrid programs.

How EIMs might work

Let’s take a closer look at how these “EIMs” could work.

• First, the initial tax level and/or growth rate could be adjusted depending on performance against an emissions trajectory or carbon budget benchmark. This could occur either automatically via a simple formula built into the legislation, by Congressional intervention at a later date based on expert recommendations, or by delegation of authority to a federal or independent agency or group of agencies.

There are clear advantages to including an automatic adjustment in the legislation. This avoids having to go back to a sluggish Congress to act; and there is no guarantee that Congress would make appropriate adjustments. Moreover, Congress is likely to be loath to relinquish its tax-setting authority to an executive agency — and such delegation could even face legal challenges. Delegating tax-setting authority to an executive agency could also introduce additional political uncertainty in rate setting.

In designing such an automatic adjustment, policy makers will need to consider the type, frequency and size of these adjustments, as well as how they are triggered. The RFF paper in particular discusses some of the resulting trade-offs. For example, an automatic adjustment will reduce the price certainty that many view as the core benefit of a tax. On the other hand, by explicitly and transparently specifying the adjustments that would occur under certain conditions, a high degree of price predictability can still be maintained – with the added benefit of increased emissions certainty.

• Second, the Nicholas Institute brief discusses regulatory tools that could be employed if emission goals were not met –including existing opportunities under the Clean Air Act, or even new authority. The authors point out that relative to automatic adjustment mechanisms, regulatory options are more difficult to “fine-tune.” Nevertheless, they could provide a powerful safeguard if alternatives fail.

• Finally, as the Nicholas Institute brief discusses, a portion of tax revenue could be used to fund additional reductions if performance goals were not being met. This approach could tap into cost-effective reductions in sectors where the carbon tax might be more challenging to implement (e.g. forestry or agriculture). The revenue could also be used to secure greater reductions from sectors covered by the tax — for example, by funding investments in energy efficiency. In a neat twist, the additional revenue needed to fund these emissions reductions would be available when emissions were higher than expected — that is, precisely when more mitigation was needed.

EDF’s take

Our goal is to reduce the amount of carbon pollution we put into the atmosphere in as cost-effective and efficient a manner as possible. This means putting a limit and a price on carbon pollution.

Even at this preliminary stage in the exploration of EIM design, one takeaway is clear: all carbon tax proposals should include an EIM with an automatic adjustment designed to meet the desired emissions path and associated carbon budget.

More work is needed to develop and evaluate the range and design of EIMs. And while a cap is still the most sure-fire means of guaranteeing an emissions outcome, this growing consideration by economists and policy experts opens a new path for the potential viability of carbon taxes as a pollution reduction tool in the United States.

The bottom line is this: The fundamental test of any climate policy is environmental integrity. For a carbon tax, that means an EIM.

Posted in Cap and Trade, Markets 101, Uncategorized / 1 Response