Dear Mr. President

1600 Pennsylvania Ave. NW
Washington, DC 20500

Dear Mr. President,

Thank you for acknowledging the need for a new, comprehensive national energy and climate change plan. It’s refreshing. This was a pillar of your campaign and a main reason we supported you. As the Senate prepares to consider the American Power Act we urge you however to think bigger about the energy sources that can power this nation, and job growth, while not imperiling future generations. We urge you to support a fee-and-dividend framework in lieu of the flawed cap and trade.

Political sweeteners for specific industries, such as coal, natural gas, ethanol, utilities, and old nuclear, are not examples of such big thinking. Yet the American Power Act is chalk full of them. It is also full of emissions goals. The fact is you can set all the GHG abatement goals you want, but so long as you keep permitting OCS drilling, new coal plants, or tar sand pipelines and oil shale mines with Canada that will burn and emit for decades, if not centuries, with no proven capture technology, there is no realistic pathway for such reductions.

The American Power Act also provides billions of tons of unverifiable GHG offsets/exemptions some 40% above the total cap. In addition to significantly diluting any potential GHG reductions, such offsets create all manner of perverse incentives. Some examples include encouraging the creation of pollution just to sell the rights to destroy it, or enabling someone else to buy energy inefficient goods because one entity emitted below the cap, or giving an economic incentive for accountants, companies, and governments to inflate future emissions projections to claim higher current offsets, or encouraging dictators to over report their populations or suppress their economy to generate surplus credits to sell to the rich world. These perverse incentives just further increase the likelihood that U.S. goals will fail like those of the U.N. set under the Framework Convention. Japan for instance made the goal of a modest 5% baseline reduction under Kyoto, and even with significant investment, honest effort and a stagnant economy, actually increased emissions 10% over that period.

Goals are at best guiding principles, not self-executing mechanisms. Goals are also endless excuses for haggling and bickering among nations over who gets the rights to emit GHGs and under what inexact assumptions (basing it on past emissions benefits the developed world, basing it on current emissions benefits emerging economies, basing it on future emissions benefits poor economies; there are many such abstract issues of equity in originating and distributing emissions rights). A primary reason the world still lacks a climate treaty 20 years after the United Nations Framework Convention on Climate Change was ratified in 1990 is because a top-down "all at once" global regime requires asset distribution that inevitably hurt certain countries ex ante. Climate change also represents a tragedy of the commons, where no one stands to lose in the status quo, but there are potential private gains from assigning property rights to these public goods, and so a strong incentive for hording, gaming and free-riding. The most effective way to lead in such a case is not by decree or simultaneously negotiating with dozens of countries. As the UNFCCC shows, and theory supports, there is not necessarily a rationale to expect such an approach to ever work. The best way to lead is by demonstrating the gains to be made from clean energy investment at a domestic level. Once you show the gains to be made by a more efficient tax system (by shifting taxes from socially beneficial things like income to costly things like GHGs) there is a strong incentive for similar regional and global reform, and increasing demand for U.S. GHG technology exports.

Goals are nice but meaningless without incentives, such as a fee-and-dividend approach. EPA has estimated the marginal utility value of CO2 at $21/ton. Other organizations have estimated it to be more in the $30-40 range. If you introduced a carbon tax below this rate that gradually increased above it, offering predictability for industry and business, and returned 100% of the revenue to households, via for instance quarterly checks, you would have a real incentive and economic mechanism for emissions reductions and clean energy investment and demand- much more so than any top-down “goals”. You would also have a majority of lower and middle income families that emit below average, who really love getting more money back from the government than they pay in energy taxes. Not to mention huge demand for new labor to renovate the nation’s aging energy infrastructure. Fee-and-dividend would be a strong, tangible signal for global cooperation on the grounds of self-interest, while maximizing employment effects by neither increasing the tax burden nor assigning property rights imperfectly.

We know you know all this. And we recognize fee-and-dividend is not currently as politically tenable as the opaque and ill understood cap and trade, a tax which provides widespread exemptions, escape valves, and a huge new secondary market for Wall Street to game, inflate, and ultimately distort. Do we really need to go through this again with GHGs like MBS? Do you have that much confidence in the SEC and CFTC who let a simple pyramid scheme go unchecked for years to parse what are real and fake emissions, or prevent a speculative bubble in a brand new market they have little experience with? Mr. President- scrap the cap, see the fee.

As the legislative process proceeds, hold off on new OCS and Arctic permitting. They contain a small amount of reserves compared to either U.S. demand or global reserves, yet spews billions more tons of CO2 into the atmosphere for the next 150 years for your children and the countless unborn to reckon with. The paleoclimate record already suggests we are near committed to a 2 degree centigrade global mean increase, overwhelming natural temperature forcing nearly ten-fold.

Three policy recommendations:

1) Enact a revenue neutral carbon tax, i.e. fee-and-dividend. Carbon equivalents could initially be taxed at a low level to provide an early signal for the market to begin transitioning to a carbon constrained world. The tax could begin in 2012 at $10/ton (about 10 cents per gallon of gasoline) and increase over time as a multiple of inflation. All revenues must be 100% returned to the taxpayers, a central element for both economic efficiency and fairness. Each legal adult resident should get an equal share via electronic transfer to bank accounts or debit cards, with half a share for children up to two children per family. Opposition will attack you no matter what you do. Framing this as a multi-hundred billion dollar tax cut to stop global climate change and drive innovation and job creation is a potent (and true) counter-argument, one that cannot be made with cap and trade. WTO compliant cross-border tariffs could be applied at the port of entry on imports that do not meet this requirement in order to prevent free-riding and emissions leakage. Allowing each nation to keep the revenues from its carbon tax will align the individual interest of sovereign governments with the common interests of the global community. China for instance seemed open to strong incentives for clean energy at Copenhagen. Instead they were presented a cap on future emissions based on the past emissions of Europe and the U.S. They not surprisingly rejected it. The world will listen to incentives that create and drive new markets.

2) Invest in and build a demonstration fast-breeder (4th generation nuclear or FBR) nuclear facility as a prototype for industry to study and scale up. These reactors can reduce nuclear waste nearly 100 fold compared to current commercial models, and can burn a much wider portfolio of fissile materials, including waste from current generation reactors (which we have centuries worth). Fast-breeder reactors also reduce the depletion timeframe of waste production from tens of thousands of years to hundreds of years, making storage vastly more feasible. DOE had a demonstration plant in the 1990s called the Integral Fast Reactor that was close to completion, but it was mistakenly cancelled/defunded in 1994 because of unwarranted environmental alarmism. Nuclear should realistically be 10-20% of the energy supply to provide reliable baseload energy. Great work being done here by Bill Gates and others: http://intellectualventures.com/Libraries/TerraPower/IV_Introducing_TWR_February_2010.sflb.ashx

3) Lease federal land parcels in the Southwest U.S. for the development and expedited permitting of concentrated solar plants (CSP). There’s ample solar forcing, cheap unused land, and green jobs would help the whole economy. The parcels could generate revenue via auction; these parcels and CSP would be quite valuable because of the fee-and-dividend. CSP is vastly more efficient than traditional photovoltaic systems and can provide up to 80% baseload reliability- more than enough to meet normal household needs. It would be cheaper to produce and buy with a gradually increasing carbon tax. Today CSP costs about $.10/kWh compared to coal at $.05kWh, which would imply a real tax of about $50/ton. Additionally, tax credits and land for the construction of next generation transmission lines are necessary.

Stop throwing money at every technology and leaky window in the country while not reducing the deficit in the process. Instead, set up clear rules of the road with a fee-and-dividend framework that would put many more people to work than fast expiring, temporary job-creating appropriations and let the market scale up clean energy. This will take some audacity.

Sincerely,
Wyatt Boyd

cc:
Rahm Emanuel
Lawrence Summers
Christina Romer
Peter Orszag
Steven Chu
Melody Barnes
Lisa P. Jackson
Nancy Sutley
Carol Browner
Timothy Geithner
Neal Wolin
Mona Sutphen
James Jones
Xav Briggs
Phil Schirilo
David Axelrod
Valerie Jarrett