Dear Mr. President:
Congratulations on your Administration’s tour de force performance at the Sustainable Development Summit in Johannesburg. We applaud your successful efforts to keep the Kyoto Protocol off the agenda and focus discussion on the true prerequisites of human welfare and environmental improvement: property rights, the rule of law, and the wealth creation such institutions foster and sustain.
We are concerned, however, that the Administration’s plan to award regulatory credits for “voluntary” greenhouse gas (GHG) reductions will strengthen pro-Kyoto forces here at home – interests adverse to your supply-side economic and energy policies.
Transferable GHG credits will: (a) create the institutional framework for a future Kyoto-style emissions cap-and-trade program, and (b) grow the “greenhouse lobby” of Enron-like companies seeking to profit from energy rationing schemes.
We appreciate your efforts to replace Kyoto’s mandatory, anti-growth, emission tonnage targets with voluntary, growth-friendly, emission intensity targets. However, we believe supply-side reforms such as accelerated depreciation are a better way to speed up capital turnover and emissions intensity reduction.
Here are nine key reasons why the Administration should rethink this plan:
· Transferable GHG credits will mobilize lobbying for energy rationing and cap-and-trade schemes. Credits do not attain full market value unless a GHG cap and energy rationing are imposed. In effect, credits are Kyoto stock that bears dividends if, but only if, Kyoto or equivalent regulation is adopted.
· Although touted as “voluntary” and “win-win,” transferable credits create a coercive system in which one company’s gain is another’s loss. For every company that gains a credit in the pre-regulatory period, there must be another that loses a credit in the mandatory period (or else the emissions “cap” will be broken). Consequently, companies that do not “volunteer” will be penalized – forced in the mandatory period to make deeper emission reductions than the cap itself would require, or pay higher credit prices than would otherwise prevail.
· Transferable credits will stack the political decks against your pro-growth economic and energy policies. Since the scheme penalizes non-participants, many businesses will “volunteer” just to avoid getting shoved to the shallow end of the credit pool later on. Many companies will end up holding energy rationing coupons that mature only under Kyoto or comparable regulation.
· Transferable credits will penalize small business. Participants gain at the expense of non-participants. Small businesses will not participate, because they cannot afford to hire carbon accountants and engineers.
· Transferable credits are a brainchild of the Green Left. During the 105th and 106th Congresses, Environmental Defense, Pew Center on Global Climate Change, the Clinton-Gore Administration, and Senators Chafee and Lieberman devised and marketed transferable credits to build a pro-Kyoto business clientele.
· Transferable credits empower politicians to pick economic winners and losers. Consider Sen. James Jeffords’ “Clean Power Act,” which would impose Kyoto-like CO2 controls on power plants. Up to 99 percent of the CO2 credits would go to persons and entities that produce little or no electric power.
· Transferable credits increase the risk of future Enron-type scandals. Firms might “earn” credits by not producing things, outsourcing production, shifting facilities overseas, or “avoiding” hypothetical future emissions. A market in such dubious assets will be fertile soil for creative accounting.
· Transferable credits will thwart your efforts to replace Kyoto’s mandatory tonnage targets with a voluntary intensity goal. A carbon intensity goal offers no alternative to Kyoto if it is coupled with a crediting scheme that fuels pro-Kyoto lobbying.
· Removing tax barriers to capital investment is a better way to reach the goal. Accelerated depreciation would speed up capital turnover, carbon intensity reduction, and economic growth – all without picking winners and losers, setting the stage for CO2 regulation, or encouraging Enron-like asset manipulation. Accelerated depreciation is a true “no regrets” policy.
In conclusion, transferable GHG credits imperil your efforts to stimulate growth and secure affordable energy for the American people. We encourage you instead to promote tax reforms that reduce carbon intensity while strengthening the economy. We are eager to help you develop initiatives to advance those objectives.
Fred L. Smith, Jr., Presidentand Marlo Lewis, Jr. Senior FellowCompetitive Enterprise Institute
Paul BecknerPresidentCitizens for a Sound Economy
John BerthoudPresidentNational Taxpayers Union
L. Patricia CallahanPresidentAmerican Association of Small Property Owners
David KeeneChairmanAmerican Conservative Union
Kevin L. KearnsPresidentU.S. Business and Industry Council
Karen KerriganChairmanSmall Business Survival Committee
James MartinPresident60 Plus Association
Grover NorquistPresidentAmericans for Tax Reform
Duane PardeExecutive DirectorAmerican Legislative Exchange Council
Dwight PetelDirectorAssociation of Concerned Taxpayers
John PowellSenior Vice President & Chief Operating OfficerThe Seniors Coalition
Mark Q. RhoadsVice PresidentUnited States Internet Council
Tom SchatzPresidentCitizens Against Government Waste
Fran SmithExecutive DirectorConsumer Alert
Benjamin C. WorksExecutive DirectorSIRIUS (Strategic Issues Research Institute)