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Environmental Education 501(c) 3
La Cienega Valley Citizens for Environmental Safeguards

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Carbon Credit Rebates
Basics 101: Carbon Offset Credits

The Difference of Carbon Tax Rebates

Carbon Offsets mitigations are not working. Restoring a wetland from the aftermath of a hurricane or planting trees as part of community efforts to beautify, mitigate and help efforts toward restoration of a watershed helps to recharge the aquifer, water quality and erosion problems which is a fine effort. For years many community and environmental organizations along with the diversity of treehuggers have applied for federal, state or private NGOs foundations grants under initiatives to comply with a mandate under the Clean Water Act. It has been a healthy practice.</b> Now with the Clean Development Mechanisms (CDM) in place, created for offsets and carbon trading schemes, it appears the American fundamental free market ideologues have seized another investment banking “opportunity”; as their insatiable greed and moral disregard for humanity and the Earth reins fraud over a proposed system.This system sets up aj opportunity that thirsts for more resources, deregulation and privatizing of pollution sources and has been shown to fail miserably. The carbon “offsets” market along with cap and trade carbon trading promotes fraudulent and failed carbon credits system and further privatizates the crises of climate disruption.

When the Bush Administration took office CDM was the only thing in the Kyoto Treaty the administration could take advantage and blessed the EPA with new directives on mitigation wetland banking. In 2008, the Poseidon Corporation lobbied for approval of a desalination plant lobbying for “carbon emission offsets.” Poseidon Resources (the water manager of the project) was going to offset the plant’s GHG emissions by creating a wetlands project to be compliant under the law to comply with California AB32 for the Carlsbad Desalination Plant. This effort was squashed during the second phase of the permitting process when the project was challenged to show cause. This may be a wake-up call to other projects in the nation and worldwide regarding investment in the offset markets and as educational efforts becomes realized.

The cap and trade scheme and carbon offsets were dropped into the Kyoto Protocol as a market driver to mitigate pollution known as the Clean Development Mechanism (CDM) to mitigate pollution were later adopted by EPA to offset carbon emission. These deregulation practices were used to usurp accountability and responsibility under the Section 404 Clean Water Act on permits that were applied for under the Army Corp of Engineers (ACOE) to mitigate polluting projects that are approved (including wetlands) and would caused irreparable harm to the water courses. The CDM is intended to reduce offsets carbon emissions from projects by rewarding developing countries/corporations for investing in clean technologies and best practices. In fact, evidence is accumulation that it is increasing GHGs behind the guise of promoting sustainable development. The misguided mechanism is handing out billions of dollars to chemical coal and oil corporations and the developers of destructive dams and many cases for projects they would have built anyway. This whole offsets idea provides the means for entities emitting greenhouse gases and other pollutants to avoid reducing their own emissions by purchasing emission reductions in some far off place. This allows them to continue business-as-usual practices and avoid making the needed investments in pollution control equipment or switch to clean energy options.

Lieutenant Governor and Head Commissioner of the California State Lands Garamendi had asked in the hearing how Poseidon Resources would demonstrate that the adjacent wetlands project will lead to cuts in GHG emissions; “additional” to what would have happened without the availability of credits. Of course, Poseidon failed to answer the question and the permit for the desal plant is on hold.

The concept of ‘additional’ is at the core of the creditability of the concept of the CDM. The buyers of CDM credits are companies in developing nations… who use them to offset their own emissions. They are allowed to put carbon credits towards targets they would otherwise have to meet at their own factories which are much more expensive.

The problem with mitigation banks are that they are a form of “third party” compensatory mitigation credits, in which the responsibility for the compensatory mitigation implementation and success is assumed by a party other than the permittee. This transfers the liability which has been a very attractive feature for the Section 404 permit-holders that will be held responsible for the design, construction, monitoring, ecological success and long term protection of the site.

A working paper from two senior Stanford University academics examined more that 3,00 projects applying for or already granted up to $10 B of credits from the UN’s CDM funds over the next four years, and concluded that the majority should not be considered for assistance because the projects would have been built anyway.

The one thing that Poseidon could not answer is the element of time. “In fact, there is a large time lag; from the time the emissions are released into the atmosphere and the carbon neutralizing of these emission happens over a much longer period. It is part of the problem’ in terms of climate change that it takes a forest 100 years or more to offset carbon, when a company keeps buying offset credits, their rate of emission keeps climbing at a faster rate than the carbon is being neutralize through a project such as reforestation and wetlands banking. These actions are far from being carbon ‘neutral’ just the opposite is happening. Many if not most offset operators in the voluntary carbon market trade in the “future” for reductions; selling their offsets credits often long before the actual reduction that has been taken place, or with the offset actually happening or even hoped to happen.

Then there are the negative consequences of the free market carbon mitigations on indigenous peoples in the global South. The growing practice of purchasing carbon dioxide credits in order to offset ‘ affluent customers’ excessive greenhouse gas emissions is increasingly opposed by people on the receiving end. Carbon offsets. Whether sold on the internet or negotiated through the Kyoto Protocol’s CDM also favors the conversion of forests into monoculture plantations and further the displacement of traditional communities.”

Meanwhile, the EPA is elated from not having to regulate any projects permitted by of the Army Corps of Engineers because the transfer credit offset transfers legal responsibility over because the mitigation bank then takes on the responsibility of financing, planning and professionally advising on the ways to mitigate a potential project. There are no permitting time lines that developers of a project have to wade through. This mitigation banking clears all obstacles for developers to pass go, collect their money, as they skip on by to invest in more credits in their free market ‘monopoly game’ of carbon trading, creating a bubble of the likes of the economic crash of 2008. In essence, they can release any amount of emissions and then the polluter’s “agent” the mitigation bank provides assurances of environmental law compliance. The mitigation banks in essence take over the role of the regulator and become deregulators of pollution that is the process of hollowing out government and the last hurrah towards a privatized and unaccountable government.

This scheme, also, is by the National Research Council (NRC) that the advantage of third party compensatory mitigation plan was that it fulfilled the regulatory goals…And there is a consensus-driven interagency review process used to approve banks. ‘Sixty-two percent of the banks identified in the Environmental Law Institute’s 2002 study were privately owned entrepreneurial mitigation banks; entrepreneurial providers of bank credits have an emerged as a nationally organized industry contributing hundreds of millions of dollars annually to the domestic product.” Here we go-go again economics by prospectively creating a bubble based on fraudulent carbon credits claims and on the back of impending violations of the rights of indigenous people in the global South. In a petition to the Members of the Permanent Forum on Indigenous Issues, Seventh Session of the United Nations Permanent Forum on Indigenous Issues April 20, 2008 – May 2, 2009. “The vast majority of indigenous peoples feel that the Reduced Emissions from Deforestation in Developing Countries, (REDD) will not benefit Indigenous Peoples, but in fact will result in more violations of Indigenous peoples’ rights. It will increase the violation of our rights, to our lands, territories and resources; because forced evictions; prevent access and threaten indigenous agriculture practices; destroy biodiversity, cultural diversity, traditional livelihoods and knowledge systems; and cause social conflicts. Under REDD, States and carbon traders will take more control over our forests.” Demonstrations in Espirito Santa, Brazil, 2005 Carbon Credits will finance expansion of already vast eucalyptus plantations, destroying local agriculture, after approximately 7 years trees will be cuts to make charcoal, produce pig iron, make steel manufacture cars and allow more CO2 in the atmosphere.

What this boils down to is that carbon trading and mitigation banking are not the way for the affluent nations of the world to “lift up” the developing countries and the people. In the developing nations and industrial nations there is a problems with verifying projects and allows an incentive for fraud. “UN regulators are concerned that some independent auditors of the CDM projects, who are responsible for vetting their environmental legitimacy, have been letting project developers push through ventures of questionable environmental value. The crackdown challenges a plank of the world’s campaign on climate change: that polluters can pay someone else to clean up the mess…The UN says it isn’t suggesting that most of the develop-world projects are illegitimate. Evaluating whether a project warrants being built without carbon credit system… the UN regulators are questions the actions of two main players in the Carbon market: Project developers who put together projects in order to sell the credits to western industrial buyers; and the auditing firms that inspect and verify to the UN that the Projects are environmentally legitimate… ‘There is a high incentive for companies to put together environmentally questionable carbon credits projects. “Because there is a lot of money that can be earned…People are getting inventive, so it’s getting harder to detect problems… there is concern that the system is open to collusion between auditors and project developers to push through environmentally dubious projects.’ The suggestions that are floating are that the system now needs “to oversee the overseer’s”.

The entire CDM process shows that a unregulated system will not work under the fundamental free market ideologue principles that are behind the carbon trading market, which has been a rouse and has shown the world that the $75 million fraud has neither the mechanisms to creditability assess the projects nor the will to ensure that only qualified projects get credits.

Where is the guarantee that a tree planted in New Mexico, or China to offset $10 worth of travel won’t be chopped down or die from the lack of water and care before is absorbs the requisite? And what if whatever that was planted is destroyed some way and it begins to emit carbon who pays then? This scheme gets stickier all the time.

The Trust for Public Lands (TPL) has also jumped on the CDM bandwagon. On their website they promote “Encouraging carbon sequestration through TPL projects, including the sale of carbon credits for reforested land. Current purchasers of carbon credits from TPL include Entergy, Detroit Edison, Conoco-Phillios and Volkswagen of American amongst others. The fact is that the Trust does good work in conservation, there is no question about that. However, I think they are about to walk into quicksand by being involved with CDM credits and the backlash that it will come from offering carbon offsets cause in the months ahead. This dysfunctional and enabling business practices lacks of integrity and diminishes confidence that TPL is willingly risking their reputation of their good works against the findings of this fraudulent system and beg questioning that they are acting in the best interest of the Earth and our the right stewards for the lands that they oversee. When privatizing governmental regulatory responsibility, it then begs the question, who is overseeing the overseer?

Regional Greenhouse Gas Initiative (RGGI) will start auctioning off carbon credits in 10 states in the Mid-Atlantic and New England is auctioning off allowances of one ton of carbon into the atmosphere, the brainchild of Jonathan Schrag who is no conservationist. He purports that all fossil fuel is to be utilized including tar sand mining, oil drilling, nuclear, coal, all the deadly fuels are is up for grabs with Schrag, he is a free marketer ideologue that designed a way to create a “Whimpy” carbon market that may never sequester CO2. What was Whimpy’s line in the Popeye series, “I’d gladly pay you Tuesday for a hamburger today” The levels that the caps are starting at under RGGI will not start sequestering carbons for over 10 years thus allowing continued emissions until then and only bring emissions down by 10% if that. We need rigorous caps and tax to bring the carbon emissions way down by 80 percent worldwide. In a press release RGGI said, “Under the RGGI process, the then participating states will stabilize power sector CO2 emissions at the capped level through 2014. The cap will then be reduced by 2.5 percent in each of the four years 2015 through 2018, for a total reduction of 10 percent.”

According to Washington Post’s Juliet Eilperin reported in the article, Carbon is Building up in Atmosphere Faster than Predicted, “The rise in global carbon dioxide emissions last year outpaced international researchers’ most dire projections…In 2007, carbon released from burning fossil fuels and producing cement increased 2.9% over that released in 2006 to a total of 8.47 gigatonnes or billions of metric tons.”

The tipping point is coming up on us very quickly, meanwhile, Canada and Japan and several of the industrialized countries have not met their commitment to reducing their carbon emission under the Kyoto Protocols. The new date also show that forests and oceans, which naturally take up much of the carbon dioxide humans emit, are having less impact. These “natural sinks” have absorbed 54 percent of CO2 emission since 2000, a drop of 3 percent compared with the period between 1959 and 2000. “Mission Control we have a problem”

It is no joke when it comes to carbon sequestering offsets and the Cap and trade system as are empty attempts to make it appear that Politicians and corporations are doing something, like the one across the country called, the “Western Climate Initiative.” These are very weak caps and do not allow for the rigorous offsets that are required. Something is not that same as the correct solution that actually mitigates 80% of carbon emissions. In addition, Congress and the Senate will have to risk their careers on doing the correct thing- a noble endeavor. What is so infuriating is that organizations like Environmental Defense Fund are selling offsets on their web site and the NRDC is promoting carbons trading and offsets in the Western Climate Initiative as well. Their cavalier attitude of supporting big oil and coal is a 180 degree about face from their past work and is diminishing any real clean energy future which stifles technological innovations and distracts from what will be required to achieve the systemic energy and transport infrastructure we need to make low-carbon economies a possibility.

What the most important aspect of this problem is this is a display of opportunism, trumping what use to be their colleagues years of environmental education efforts of media, legislators and the people. Most importantly because it supports a deepening of fundamentalist free market ideology of the most radical deregulation, the deregulation of pollution and privatization with no tax on pollution, nor reduced carbon outcomes and shows the world that they settled for a potentially fraudulent system. It is as if the Board Members of these two “environmental” firms have been liberated by the Chicago Boys themselves, for they have discarded the idea of the government as regulator, of protecting citizens and consumers from detrimental forces; that they betrayed the Earth systems and the people who trusted that they were supposedly protecting.

These actions and ideas have consequences, it takes good hard science of earth science, biology and ecology that begun a dialogue with politics and psychology where it became imbedded in a fundamental ideology that consumed them, for it is the nature of the ideologue.

There were many things wrong with the Kyoto Protocols and it was a start to get people to the table, sit down and come to a solution for the common good. The Kyoto Protocols were not strong enough and allowed this charade to be played out on the world market while lives of the poor, working and middle classes were hanging the balance. It had not help the issues of carbon emissions one iota.

The hard-fact is right now there should be NO MORE COAL. We must decommission coal fire plants NOW and not allow operations after 2015.

The answer is not a scheme, it combines real tax and 100% dividend and comes down to hard work, work that builds the wind and solar technology while backing it up with natural gas for base load protection and replaces coal as fast as we pssibly can. We could replace coal fire within 5 years worldwide, this is all the time we have may be even less. This mitigation of carbon credit offsets has been a scheme to control the world pollution through deregulation. This is where the grassroots movement can be affective mainly because there is a wide belief now that, ‘We, the people’ are not buying.

The most important thought to take away is to not support the cap and trade schemes and the carbon offsets that there are another ways for the free market to splatter other bubbles. It is to hold stockholders accountable for their support of a process within corporations that burdens the earth and her entire system.

Endnotes

“Discredited Strategy” The Guardian 21, 2008, http://redpepper.org.uk/  http: // ejmatters.org

“Carbon “ Offsets” a lose-lose-lose Scenario to address Climate Change” http: // ejmatters.org July 2008

Ibid

Ibid

Mitigation Banking Fact Sheet “Compensating for impact to Wetlands and streams  What is a mitigation Bank” US EPA

“ Offset standard in off target” Red Pepper Magazine, April /May 2008 “Carbon “ Offsets” a lose-lose-lose Scenario to address Climate Change” http: // ejmatters.org July 2008

“Hot Air and Snake Oil: carbon Offset Upsets,” transnational Institute, Jan 20 2008, http://www.tni.org’detail_page.phtml?act_id=17827&username=guest@tni.org&password=999&publish=Y

Brian Tokar, “Global warming and the struggle for justice,” Z magazine Jan.1,2008 htt://zcommunications.org//zmag

Interpreted from the EPA’s Mitigation Banking Fact Sheet “Compensating for impact to Wetlands and streams  What is a mitigation Bank” US EPA page 4

Mitigation Banking Fact Sheet “Compensating for impact to Wetlands and streams  What is a mitigation Bank” US EPA page 4

NRC, 2001 page 163

“Carbon “ Offsets” a lose-lose-lose Scenario to address Climate Change” http: // ejmatters.org July 2008 Larry Lohmann , Case studies Slide show, Spring 2007, Http://www.thecomerhouse.org.uk.pdf.document.OffsetsMarket.pdf

UN Effort to Curtail Emissions I Turmoil, Wall Street Journal April 12 2008“Carbon “ Offsets” a lose-lose-lose Scenario to address Climate Change” http: // ejmatters.org July 2008

Himanshu Thakkar, Leman Development Mechanism: the $75 Million Fraud-Deccan Herald, May 15, 2008 “Carbon “ Offsets” a lose-lose-lose Scenario to address Climate Change” http: // ejmatters.org July 2008

Spencer  Reiss, “carbon Credits were are great idea but he benefits are illusory,” Wired Magazine may 19, 2008 “Carbon “ Offsets” a lose-lose-lose Scenario to address Climate Change” http: // ejmatters.org July 2008

www.tpl.org TPL and Climate Change: The Trust for Public Lands 2/2008 Downloaded Posted  10/11/08

A recurring joke is Wimpy's attempts to con other patrons of the diner into buying him his lunch. Wimpy often tries to outwit fellow patrons with his convoluted logic. His famous line, which was first introduced to the cartoons in the 1934 cartoon We Aim to Please, is "I'd gladly pay you Tuesday for a hamburger today". http://en.wikipedia.org/wiki/J._Wellington_Wimpy

RGGI States’ First CO@ Auction Off to a Strong Start, Http:// www.dnerec.delaware.gov/News/Pages/RGGIStates%E2

Juliet Elperin, Carbon is building Up in Atmosphere Faster than Predicted. Washington Post.com posted September 26, 2008 download same day.

Apollo 13 is a 1995 Academy Award-nominated film that dramatized the event of the ill-fated Apollo 13 lunar mission in 1970. The movie was adapted by William Broyles Jr. and Al Reinert from the book Lost Moon by Jim Lovell and Jeffrey Kluger and was directed by Ron Howard. It stars Tom Hanks, Kevin Bacon, Bill Paxton, Gary Sinise and Ed Harris, and features Kathleen Quinlan.

http://www.edf.org/page.cfm?tagID=23994 carbon offset buying

http://docs.nrdc.org/globalwarming/glo_07031901A.pdf download

“Carbon “ Offsets” a lose-lose-lose Scenario to address Climate Change” http: // ejmatters.org July 2008

Naomi Klein, “Wall St Crisis Should be for Neoliberalism what Fall of Berlin Wall was for Communism.” Oct 6, 2008, Democracy no transcript of a lecture at the University of Chicago.

Cormac Cullivan If nature had rights: What would people need to give up? Orion, January. Feb 2008

 

 
 
   

CARBONTAX.ORG Link

Debunking Myths:
Regional Disparities on CarbonTax Finding

As debate over climate legislation heats up in the 111th Congress, some members are voicing concern that measures to impose a price on carbon emissions will disproportionately burden energy users in their district or state. "We're looking for some type of regional equity in whatever they propose," said Rep. Marcy Kaptur (D-OH) during Energy and Commerce Committee deliberations over the Waxman-Markey climate bill, as reported in the New York Times on May 8, 2009. At a Senate Finance Committee hearing on proposed cap-and-trade legislation, Senator Orrin Hatch (R-UT) complained that a $50/ton CO2 price would increase electric rates by 70% in his state, which relies heavily on coal for electricity. The root of the issue is variations in regional fuel mix, compounded in some instances by variations in levels of energy use. Electricity rates in the Pacific Northwest, which is generously endowed with hydro-electric power, should scarcely be affected by carbon emissions pricing through either a tax or cap-and-trade system. In contrast, the Plains states, which primarily employ coal for electricity generation, and the Northeastern states, which rely heavily on fuel oil for heating, could face disproportionate impacts. In addition, people in rural areas tend to drive longer distances than city-dwellers, so their transportation costs would be expected to rise more. Are these regional differences significant? What if any steps should be taken to address them in designing a carbon tax and the accompanying revenue-recycling measures? A thorough analysis of these questions is “The Incidence of a U.S. Carbon Tax: A Lifetime and Regional Analysis” (October 2007). In this AEI working paper, economists Kevin A. Hassett, Aparna Mathur and Gilbert E. Metcalf considered both the direct and indirect incidence of a hypothetical carbon tax of $15 per metric ton of CO2. They defined the direct component as the increased cost of gasoline, home heating and electricity. The indirect component is the increased cost of other goods, ranging from air travel to food purchases, resulting from the higher cost of fuel used in their provision. The two components are of similar magnitude, but the indirect component is nearly uniform across the U.S., reflecting our national market for consumer products. Hassett et al. chose the household as the unit of consumption and considered the lifetime incidence of a hypothetical “upstream” carbon tax. When both direct and indirect impacts of the carbon tax were included, Hassett et al. calculated that in 2003 the largest variation between regions was less than 0.37% of household income. (This was less than the maximum regional differences in the two other years chosen for the analysis — 0.42% in 1987, and 0.89% in 1997.) They concluded: Carbon taxes are… thought to have uneven regional effects. We … find that the regional variation is at best modest. By 2003 variation across regions is sufficiently small that one could argue that a carbon tax is distributionally neutral across regions. The U.S. Census Bureau reports that the median U.S. household income in 2006 was $48,201. Thus, the 0.37% difference represents a difference of just $178 annually between typical households in the most affected and the least affected regions. The average interregional difference is much less. Nevertheless, aggregated over millions of households this difference could be considerable, especially if, as urged by CTC and others, a carbon tax (or cap-and-trade system) quickly attains and surpasses the relatively modest carbon emissions price level in the Hassett analysis. More recently, in “The Incidence of U.S. Climate Policy: Alternative Uses of Revenues from a Cap-and-Trade Auction” (Resources for the Future, April 2009), Dallas Burtraw, Richard Sweeney, and Margaret Walls examined income and distributional effects (across eleven regions) of an emissions cap with auctioned permits that resulted in a price of $20/ton CO2. (The regional incidence of a carbon tax would mirror that created by pricing carbon emissions using a cap.) They considered distributional effects on an annual basis which tends to magnify disparate impacts between income groups (and may also magnify regional differences) in contrast to Hassett et al.’s lifetime incidence analysis which tends to minimize them. Burtraw et al. found that “putting a price on CO2 emissions can distribute costs unevenly across income groups and regions, and that revenue allocation decisions can either temper or exacerbate these distributional effects.” They found that, compared to revenue recycling via reduced payroll tax rates, a direct “dividend” approach would result in slightly larger net regional differences, especially in the lowest income groups. Yet even those differences would amount to no more than 2% of total annual income, assuming the $20/ton CO2 price. Disparate impacts on households across regions can be compounded by regional differences in impacts on energy-intensive industries and their workers. For example, while energy consumers in coal-mining states might be affected only slightly more than those in other states, workers who mine, process or transport coal would face far larger impacts as a carbon tax (or cap) created pressure to shift away from coal to low-carbon alternatives. Conversely, the same tax (or cap) could be expected to benefit workers in states with abundant renewable resources. A state like Montana, with both coal and wind resources, might be a net employment gainer under a carbon tax as construction and operation of wind generation facilities increased; but its coal workers would still need transition assistance. Policy Options Prof. Metcalf suggests a straightforward way to mitigate distributional disparities: adjust the amounts of revenue recycled according to the average regional carbon tax burden. For instance, if households in the Pacific Northwest would indeed pay less in carbon taxes than the national average, individuals or households in that region would receive proportionately lesser payroll tax reductions or direct distributions of revenue. Households in the Plains states might receive a correspondingly greater share of the recycled revenue. In this way, a revenue-neutral carbon tax could be regional-neutral as well. To address disparate impacts on energy-intensive industries, Congressman Larson’s proposal designates 1/12 total of initial carbon tax revenues to assist affected workers and industries. (This “transition assistance” would be phased out over a decade.) A different approach in cap-and-trade legislation introduced by Reps. Inslee and Doyle would grant free allowances to “energy-intensive, trade-exposed” industries; however this would appear to mute the very price signal that such industries require to reduce emissions. Other regional and affected-industry adjustments — hopefully temporary — could be made under either a carbon tax or cap-and-trade. We believe that under an explicit carbon tax they would be far simpler, more transparent and less likely to undermine carbon reduction incentives. A Contrasting Analysis In May 2009, economists Michael Cragg (UCLA) and Matthew E. Kahn (The Brattle Group) published a fascinating analysis correlating county-level CO2 emissions with the political beliefs and climate-policy voting records of Members of Congresss. Their paper, Carbon Geography: The Political Economy of Congressional Support for Legislation Intended to Mitigate Greenhouse Gas Production, finds that: [C]conservative, poor areas have higher per-capita carbon emissions than liberal, richer areas. Representatives from such areas are shown to have much lower probabilities of voting in favor of anti-carbon legislation. In the 111th Congress, the Energy and Commerce Committee consists of members who represent high carbon districts. These geographical facts suggest that the Obama Administration and the [Energy & Commerce] Committee will face distributional challenges in building a majority voting coalition in favor of internalizing the carbon externality. At this writing (mid-May 2009), the Cragg-Kahn analysis appears to be on target, with the Waxman-Markey bill now laden with free allowances, "clean coal" RD&D funds, and other emoluments designed to win support from Democrats representing high-carbon districts. However, unlike the AIF and RFF papers discussed above, the Cragg-Kahn paper is not an "incidence" analysis. This is because its unit of analysis (statistically, the "dependent variable") is carbon emissions rather than carbon consumption. Thus, the analysis assigns 100% of carbon emissions from power plants to the counties and districts where the plants are located, rather than allocating them to end-use customers -- the households, offices and facilities that purchase the electricity and will pay the carbon tax or emission permit fees as they are passed through the supply chain. It therefore cannot depict precisely how carbon emissions pricing will add differently to expenditures in one county or state versus another. Nevertheless, we commend the Cragg-Kahn paper as a provocative piece of political economy, along with John Kemp's Reuters column, Carbon Geography of the United States, that brought the paper to our attention. Last updated: May 18, 2009 August 14th, 2009

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