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Honorable Pete V. Domenici
Chairman, Committee on Energy and Natural Resources
364 Dirksen Office Bldg
Washington, DC 20510
Dear Senator Domenici:
The undersigned organizations are writing to share our concerns about a provision in one of Senator Chuck Hagel’s climate bills. Section 1612(a) of S. 388, the Climate Change Technology Deployment and Infrastructure Credit Act, would create a program to award, register, and track “transferable credits” for “voluntary” actions to reduce greenhouse gas emissions. Such credits have no monetary value apart from the imposition or threat of a Kyoto-style cap on fossil energy use. Consequently, every credit holder will have an incentive to lobby for a cap. Only under a cap will credit holders be able to turn otherwise worthless piles of paper assets into pots of gold. Transferable credits will grow the “greenhouse lobby” of rent-seeking firms eager to profit from energy rationing.
Assurances that a credit program can do no harm because it is “voluntary” and “win-win” (good for business; good for the environment) are false. A cap is a legal limit on how many tons companies may emit and, thus, on how many credits they may use. If a future carbon cap is not to be broken, the supply of emission credits allocated to companies in the mandatory period must be reduced by the exact number awarded for “early” reductions in the pre-regulatory period. For every company that earns a credit under Section 1612(a), there must be another that loses a credit under the future cap.
Hence, companies that do not “volunteer” will be penalized, forced in the mandatory period to make deeper cuts than the cap would otherwise require, or pay higher credit prices than would otherwise prevail. Programs that penalize non-participants are coercive, not voluntary. Programs that enrich participants at the expense of non-participants are zero-sum, not win-win. This coercive, zero-sum dynamic ensures that a credit program will operate as a political force-multiplier for the Kyoto agenda. Many businesses will “volunteer” just to avoid getting shoved to the shallow end of the credit pool later on. The predictable result is a large mass of companies holding paper assets that mature and attain full market value only under a cap.
Congress has consistently rejected Kyoto-style policies. Unfortunately, by expanding the ranks of energy-rationing profiteers, transferable credits would shift the political balance of power in favor of carbon caps before any serious national debate even takes place.
Competitive Enterprise Institute