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	<title>Comments on: Does Cap-and-trade Punish Virtue?</title>
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	<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/</link>
	<description>Pricing carbon efficiently and equitably</description>
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		<title>By: Dan</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-115007</link>
		<dc:creator>Dan</dc:creator>
		<pubDate>Wed, 02 Sep 2009 00:22:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-115007</guid>
		<description>James,

I respond to your comment #7. I recognize that your first paragraph may have been a bit tongue-in-cheek, but will respond anyway. 

Buying a coal mine has the same problem that buying forest land to protect it from logging or conversion to agriculture has in the offset business. It is hard to ensure that the &quot;developer&quot; or logger won&#039;t just go cut down or burn some other forest. The same potential &quot;leakage&quot; occurs if I buy a mine.

In contrast, if there are 4 billion emission allowances issued and I buy and permanently hold 100 of them, then actual emissions will be only 3,999,999,900 tonnes. There is not the same potential for leakage here as there is in the forestry example or in the coal mine example. Conservation easements on land have similar problems that I won&#039;t go into here.

Regarding your second paragraph; both caps and taxes will be politically-set. There&#039;s no difference on that score.

Maybe the caps in Waxman-Markey are scientifically-inadequate, but, in general, a cap does not have to be inadequate; and the adequacy of a tax is not a certainty. What happens, for example, if demand elasticities are not what is predicted? We could adjust the tax rate, but that gets us back to a politically-set situation and still no guarantee of adequacy because prices of fuel are influenced by multiple unpredictable factors.

By the way, I favor a carbon tax. I just don&#039;t like some of your arguments on this particular matter of virtue.</description>
		<content:encoded><![CDATA[<p>James,</p>
<p>I respond to your comment #7. I recognize that your first paragraph may have been a bit tongue-in-cheek, but will respond anyway. </p>
<p>Buying a coal mine has the same problem that buying forest land to protect it from logging or conversion to agriculture has in the offset business. It is hard to ensure that the &#8220;developer&#8221; or logger won&#8217;t just go cut down or burn some other forest. The same potential &#8220;leakage&#8221; occurs if I buy a mine.</p>
<p>In contrast, if there are 4 billion emission allowances issued and I buy and permanently hold 100 of them, then actual emissions will be only 3,999,999,900 tonnes. There is not the same potential for leakage here as there is in the forestry example or in the coal mine example. Conservation easements on land have similar problems that I won&#8217;t go into here.</p>
<p>Regarding your second paragraph; both caps and taxes will be politically-set. There&#8217;s no difference on that score.</p>
<p>Maybe the caps in Waxman-Markey are scientifically-inadequate, but, in general, a cap does not have to be inadequate; and the adequacy of a tax is not a certainty. What happens, for example, if demand elasticities are not what is predicted? We could adjust the tax rate, but that gets us back to a politically-set situation and still no guarantee of adequacy because prices of fuel are influenced by multiple unpredictable factors.</p>
<p>By the way, I favor a carbon tax. I just don&#8217;t like some of your arguments on this particular matter of virtue.</p>
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		<title>By: James Handley</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-112208</link>
		<dc:creator>James Handley</dc:creator>
		<pubDate>Sun, 23 Aug 2009 23:54:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-112208</guid>
		<description>Dan, 

Instead of buying up carbon allowances on a market that would surely be manipulated, why not buy coal (or if you&#039;re ambitious, a coal mine), and sit on it, keeping the CO2 out of the air? Analogous to a conservation easement where people put land into a trust to keep it away from developers?

But seriously, why should additional reductions below a politically-set and scientifically-inadequate &quot;cap&quot; depend on the willingness of people (like you?) to buy up allowances? We need a system that rewards innovation and conservation: a revenue-neutral carbon tax.</description>
		<content:encoded><![CDATA[<p>Dan, </p>
<p>Instead of buying up carbon allowances on a market that would surely be manipulated, why not buy coal (or if you&#8217;re ambitious, a coal mine), and sit on it, keeping the CO2 out of the air? Analogous to a conservation easement where people put land into a trust to keep it away from developers?</p>
<p>But seriously, why should additional reductions below a politically-set and scientifically-inadequate &#8220;cap&#8221; depend on the willingness of people (like you?) to buy up allowances? We need a system that rewards innovation and conservation: a revenue-neutral carbon tax.</p>
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		<title>By: Dan</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-111191</link>
		<dc:creator>Dan</dc:creator>
		<pubDate>Fri, 21 Aug 2009 17:09:51 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-111191</guid>
		<description>A cap on emissions does, in effect, preclude reductions below the cap level. However, a cap on emission allowances  could lead to emission reductions below the intended emissions cap. 

If allowances (instead of emissions) were capped, one could purchase allowances and voluntarily retire them without using them as a permit to emit. By purchasing allowances and withholding them from emitters, total emissions would be reduced below the intended emission cap.</description>
		<content:encoded><![CDATA[<p>A cap on emissions does, in effect, preclude reductions below the cap level. However, a cap on emission allowances  could lead to emission reductions below the intended emissions cap. </p>
<p>If allowances (instead of emissions) were capped, one could purchase allowances and voluntarily retire them without using them as a permit to emit. By purchasing allowances and withholding them from emitters, total emissions would be reduced below the intended emission cap.</p>
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		<title>By: Ken Johnson</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-110535</link>
		<dc:creator>Ken Johnson</dc:creator>
		<pubDate>Thu, 20 Aug 2009 04:17:05 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-110535</guid>
		<description>Re Anand&#039;s comment #1: Whether the cap is fixed or continuously reducing, it is predetermined and does not respond to changing technologies or market conditions. Any additional emission reductions from technology advances, voluntary efforts, or unanticipated conditions will free up surplus emission allowances that will be used to increase emission elsewhere. However, this would not be the case if allowances are trading at the price floor, in which case the number of issued allowances would be responsive to market conditions and the cap-and-trade system would, in effect, revert to a carbon tax.

Re Daniel Rosenblum&#039;s comment #2: Carbon fees could potentially obviate the need for renewable energy standards if the fee revenue is used to subsidize new, low-carbon energy sources. The fees and subsidies could be determined to give new renewables an immediate $100-per-ton price advantage over fossil fuels -- far higher than any of the current carbon-tax proposals -- but the fees would start out at zero because there would initially be no &quot;new&quot; sources. As renewables gain market share, the per-unit ($/MWh) fees would increase and subsidies would decrease, but the $100-per-ton price advantage would be maintained. The fee revenue would not be recycled to taxpayers, but ratepayers would nevertheless benefit because price competition from a growing, subsidized clean-energy industry would help maintain moderate retail electricity prices.</description>
		<content:encoded><![CDATA[<p>Re Anand&#8217;s comment #1: Whether the cap is fixed or continuously reducing, it is predetermined and does not respond to changing technologies or market conditions. Any additional emission reductions from technology advances, voluntary efforts, or unanticipated conditions will free up surplus emission allowances that will be used to increase emission elsewhere. However, this would not be the case if allowances are trading at the price floor, in which case the number of issued allowances would be responsive to market conditions and the cap-and-trade system would, in effect, revert to a carbon tax.</p>
<p>Re Daniel Rosenblum&#8217;s comment #2: Carbon fees could potentially obviate the need for renewable energy standards if the fee revenue is used to subsidize new, low-carbon energy sources. The fees and subsidies could be determined to give new renewables an immediate $100-per-ton price advantage over fossil fuels &#8212; far higher than any of the current carbon-tax proposals &#8212; but the fees would start out at zero because there would initially be no &#8220;new&#8221; sources. As renewables gain market share, the per-unit ($/MWh) fees would increase and subsidies would decrease, but the $100-per-ton price advantage would be maintained. The fee revenue would not be recycled to taxpayers, but ratepayers would nevertheless benefit because price competition from a growing, subsidized clean-energy industry would help maintain moderate retail electricity prices.</p>
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		<title>By: James Handley</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-108843</link>
		<dc:creator>James Handley</dc:creator>
		<pubDate>Fri, 14 Aug 2009 05:30:25 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-108843</guid>
		<description>In response to comments:

1) &lt;strong&gt;Volatility&lt;/strong&gt; under cap-and-trade is projected to delay needed investment in low-carbon energy by a decade. (&quot;&lt;a href=&quot;http://www.brattle.com/_documents/UploadLibrary/Upload736.pdf&quot; rel=&quot;nofollow&quot;&gt;CO2 Price Volatility: Consequences and Cures&lt;/a&gt;,&quot; Brattle Group.) Volatility in the EU&#039;s cap-and-trade system (with a loose cap, depressing carbon prices) are thwarting investment in alternatives. (See &quot;&lt;a href=&quot;http://www.gao.gov/new.items/d09151.pdf&quot; rel=&quot;nofollow&quot;&gt;Lessons Learned...&lt;/a&gt;,&quot; GAO.) Volatility does have an upside -- for traders (e.g., Goldman Sachs), but not for Earth&#039;s climate.  (&quot;&lt;a href=&quot;http://www.motherjones.com/politics/2009/06/could-cap-and-trade-cause-another-market-meltdown&quot; rel=&quot;nofollow&quot;&gt;Could Cap and Trade Cause Another Market Meltdown?&lt;/a&gt;,&quot; Mother Jones.)

2) &lt;strong&gt;Renewable Electricity Standards:&lt;/strong&gt; Germany&#039;s experience (reported by RFF) and economic theory suggest that until carbon prices (under cap or tax) reach levels that make burning coal for electricity more expensive than burning natural gas, an RES would displace relatively expensive gas with renewables but do little to reduce coal use. In contrast, a briskly-increasing carbon tax, made possible (politically and economically) by recycling the revenue directly to taxpayers, would be an efficient, fair way to phase out coal first, followed by phase-out of other less-carbon-intensive fuels while immediately opening up financing and predictably-expanding markets for renewables.

3) ACESA would lock-in and reinforce an inadequate cap and would breathe new life into the coal industry. (Rep. Boucher assures us &lt;a href=&quot;http://blogs.wvgazette.com/coaltattoo/2009/06/30/boucher-climate-bill-is-good-for-coal/&quot; rel=&quot;nofollow&quot;&gt;of coal&#039;s bright future under ACESA&lt;/a&gt;.) &lt;strong&gt;Because ACESA would also create vested interests in allowance trading and offset selling who would resist future reforms, I wholeheartedly agree, it&#039;s worse than no legislation.&lt;/strong&gt;  (Which would leave EPA to regulate sources of GHGs -- an inefficient and cumbersome prospect, but likely easier to reform than ACESA.)

I feel the anxiety of many climate policy advocates as we&#039;re confronted with a choice between ACESA and the prospect of starting over. That&#039;s why it&#039;s crucial to put a more effective, fairer and more sustainable plan on the table now, before &lt;a href=&quot;http://www.politico.com/news/stories/0809/25802.html&quot; rel=&quot;nofollow&quot;&gt;ACESA fails&lt;/a&gt;.</description>
		<content:encoded><![CDATA[<p>In response to comments:</p>
<p>1) <strong>Volatility</strong> under cap-and-trade is projected to delay needed investment in low-carbon energy by a decade. (&#8220;<a href="http://www.brattle.com/_documents/UploadLibrary/Upload736.pdf" rel="nofollow">CO2 Price Volatility: Consequences and Cures</a>,&#8221; Brattle Group.) Volatility in the EU&#8217;s cap-and-trade system (with a loose cap, depressing carbon prices) are thwarting investment in alternatives. (See &#8220;<a href="http://www.gao.gov/new.items/d09151.pdf" rel="nofollow">Lessons Learned&#8230;</a>,&#8221; GAO.) Volatility does have an upside &#8212; for traders (e.g., Goldman Sachs), but not for Earth&#8217;s climate.  (&#8220;<a href="http://www.motherjones.com/politics/2009/06/could-cap-and-trade-cause-another-market-meltdown" rel="nofollow">Could Cap and Trade Cause Another Market Meltdown?</a>,&#8221; Mother Jones.)</p>
<p>2) <strong>Renewable Electricity Standards:</strong> Germany&#8217;s experience (reported by RFF) and economic theory suggest that until carbon prices (under cap or tax) reach levels that make burning coal for electricity more expensive than burning natural gas, an RES would displace relatively expensive gas with renewables but do little to reduce coal use. In contrast, a briskly-increasing carbon tax, made possible (politically and economically) by recycling the revenue directly to taxpayers, would be an efficient, fair way to phase out coal first, followed by phase-out of other less-carbon-intensive fuels while immediately opening up financing and predictably-expanding markets for renewables.</p>
<p>3) ACESA would lock-in and reinforce an inadequate cap and would breathe new life into the coal industry. (Rep. Boucher assures us <a href="http://blogs.wvgazette.com/coaltattoo/2009/06/30/boucher-climate-bill-is-good-for-coal/" rel="nofollow">of coal&#8217;s bright future under ACESA</a>.) <strong>Because ACESA would also create vested interests in allowance trading and offset selling who would resist future reforms, I wholeheartedly agree, it&#8217;s worse than no legislation.</strong>  (Which would leave EPA to regulate sources of GHGs &#8212; an inefficient and cumbersome prospect, but likely easier to reform than ACESA.)</p>
<p>I feel the anxiety of many climate policy advocates as we&#8217;re confronted with a choice between ACESA and the prospect of starting over. That&#8217;s why it&#8217;s crucial to put a more effective, fairer and more sustainable plan on the table now, before <a href="http://www.politico.com/news/stories/0809/25802.html" rel="nofollow">ACESA fails</a>.</p>
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		<title>By: David Collins</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-107518</link>
		<dc:creator>David Collins</dc:creator>
		<pubDate>Mon, 10 Aug 2009 17:57:41 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-107518</guid>
		<description>Prof Mankiw states that the axiom &quot;Don&#039;t let the perfect be the enemy of the good&quot; does not apply, because the current climate bill (Waxman-Markey) is not good enough. I would go further. The Carbon Tax is far from perfect: there remains a need for &quot;Thou-Shalt&#039;s&quot; and &quot;Thou-Shalt-Not&#039;s&quot; (see Dan&#039;s comment #2 above), just for starters. And I would go beyond Mankiw&#039;s low-end assessment, that the present climate bill is worse than no good, it is just plain bad. One bad feature is that seemingly reasonable people are claiming it actually is worth something, which somewhat kneecaps efforts to bring forth something that would actually work.</description>
		<content:encoded><![CDATA[<p>Prof Mankiw states that the axiom &#8220;Don&#8217;t let the perfect be the enemy of the good&#8221; does not apply, because the current climate bill (Waxman-Markey) is not good enough. I would go further. The Carbon Tax is far from perfect: there remains a need for &#8220;Thou-Shalt&#8217;s&#8221; and &#8220;Thou-Shalt-Not&#8217;s&#8221; (see Dan&#8217;s comment #2 above), just for starters. And I would go beyond Mankiw&#8217;s low-end assessment, that the present climate bill is worse than no good, it is just plain bad. One bad feature is that seemingly reasonable people are claiming it actually is worth something, which somewhat kneecaps efforts to bring forth something that would actually work.</p>
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		<title>By: Daniel Rosenblum</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-107437</link>
		<dc:creator>Daniel Rosenblum</dc:creator>
		<pubDate>Mon, 10 Aug 2009 02:33:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-107437</guid>
		<description>While a gradually increasing carbon tax would increase the cost of high-carbon fuels and stimulate demand for low-carbon alternatives, it would not obviate the need for renewable energy standards.  Renewable energy standards are necessary to provide important economic, environmental and national security benefits in addition to those addressed by a carbon tax. Renewable energy standards will produce those benefits more rapidly than a gradually increasing carbon tax, particularly given current natural gas prices.</description>
		<content:encoded><![CDATA[<p>While a gradually increasing carbon tax would increase the cost of high-carbon fuels and stimulate demand for low-carbon alternatives, it would not obviate the need for renewable energy standards.  Renewable energy standards are necessary to provide important economic, environmental and national security benefits in addition to those addressed by a carbon tax. Renewable energy standards will produce those benefits more rapidly than a gradually increasing carbon tax, particularly given current natural gas prices.</p>
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		<title>By: Anand</title>
		<link>http://www.carbontax.org/blogarchives/2009/08/07/does-cap-and-trade-punish-virtue/comment-page-1/#comment-107259</link>
		<dc:creator>Anand</dc:creator>
		<pubDate>Sun, 09 Aug 2009 03:01:51 +0000</pubDate>
		<guid isPermaLink="false">http://www.carbontax.org/?p=2941#comment-107259</guid>
		<description>This problem is unlikely to be substantial because of two reasons (1). The cap is continuously reducing as a function of time, so that polluters have the right incentives for future investments (2). Price volatility, that has rightly been pointed out as a problem, has a flip side as well, which is that a firm that decides to invest in a polluting technology because others have reduced emissions may quickly find that the price has risen substantially (volatility cuts both ways)</description>
		<content:encoded><![CDATA[<p>This problem is unlikely to be substantial because of two reasons (1). The cap is continuously reducing as a function of time, so that polluters have the right incentives for future investments (2). Price volatility, that has rightly been pointed out as a problem, has a flip side as well, which is that a firm that decides to invest in a polluting technology because others have reduced emissions may quickly find that the price has risen substantially (volatility cuts both ways)</p>
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