Cap and Trade: An Unserious Policy Framework.. Towards a Serious Climate Policy – Part 2 December 13, 2009Posted by Michael Hoexter in Climate Policy, Energy Policy, Sustainable Thinking.
In part I, I made the general case for cap and trade as an unserious policy framework that inserts extraneous elements into pricing carbon that threaten the whole enterprise. I generated general definitions of seriousness and unseriousness and applied them to cap and trade and its market mechanisms.
Dimensions of Cap and Trade’s Unseriousness: Four Aspects
There are a number of aspects of cap and trade’s fundamental unseriousness that apply to specific actors involved in the framework. On one level the designers of cap and trade had an intellectually speculative distance from their subject matter which suggests that the policy has many characteristics of an economic “thought experiment”. On another, more obvious level, polluters are encouraged to view the process of obtaining a price on carbon as a game which needs to be played both at government sponsored auctions and in a trading market. Finally there are invitations, explicitly and implicitly, for third-party financial speculators to become involved in carbon trading markets in search of trading profits.
1. Scientific Unseriousness
The formulation of emissions trading was an effort by social scientists, political operatives, and activists to make environmental regulations acceptable within the US economic policy framework of the 1980’s and 90’s that exaggerated the power of markets to do social good. Within this historical timeframe, regulators and government officials were to approach powerful economic interests solicitously and without the conviction that they were defending the common good. Government became the junior partner in regulation, an attitude which has led us to so much grief in the financial sector. If applied to issues that were a matter of “improving environmental quality” or even the regulation of human-to-human affairs, the unseriousness of the policy would remain a matter of regulatory or political “taste”. However, in dealing with the unique and largely irreversible damage to the climate system as a whole, the unseriousness of cap and trade becomes catastrophic.
There is a fundamental disconnect between the emissions trading instrument and the domain of action in which that instrument is supposed to act. While economists have a long history of misrecognizing their models of reality with reality itself (most notably the recent models that did not see the huge asset bubble pre-2008), it appears in cap and trade that this tradition continues with potentially disastrous effects. Modeling that one MIGHT be able to “cap” global warming pollution by regulating quantities of emissions by selling and trading permits is not the same thing as providing substantial evidence that this would actually work better than the alternatives. And given the potential that we would be irreversibly altering the biosphere, we need to be choosing from the best tools available. I will allow that cap and trade could theoretically, using it’s particularly arbitrary administrative component, achieve its targets in an ungainly and economically damaging way but this is not relying on its much discussed carbon market component.
The sole supposed success story for emissions trading, the US acid-rain cap and trade system, has not been as successful as direct regulation of emissions in Europe and Japan in reducing sulphur dioxide the main acid rain causing pollutant. Why turn away from what works better for vague or insubstantial reasons? The unseriousness of arguments for cap and trade is that they are “selling” the idea that one could avoid more traditional government-led ways of controlling emissions and effecting social change. When one “sells” an idea in the sciences, one overlooks elements of reality that falsify or do not support one’s hypothesis.
One of the prime selling arguments for cap and trade is that it is supposedly a more economical way to cut emissions per tonne, for which I have not yet seen a serious, comparative study. However this argument for cap and trade, if it has any truth in it at all, overlooks the entire point of carbon mitigation: to cut emissions radically, securely and fast to avoid major catastrophes. The costs of NOT achieving carbon emissions goals is that whatever incremental costs within reason are associated with another instrument (direct regulation or taxation) are well worth playing if those instruments are going to get us there faster and more reliably. This argument is always left out by cap and trade advocates who continue harping on “least cost” solutions. In this context any instrument that is more reliable or faster than cap and trade would appear to be much more valuable.
The constant and alarming repetition of the “least cost” doctrine as a fundamental value in discussions of carbon mitigation is also a sign of how distant the designers and advocates of the cap and trade policy are from the actual physical and business domain where emissions are cut. Many of the large scale cuts in emissions in the area of energy and transportation will be infrastructure projects or high quality durable goods that are meant to last 10 to 50 years. In this domain “least cost” bids do not necessarily win the job because of concerns by project commissioners/buyers for the financial viability of the constructors and the quality of the resulting product with which they will live for decades. So “least cost” excludes most of the large-scale emissions cuts that can happen within a period of 3 to 10 years. The building of infrastructure falls almost entirely out of the orthodoxy of climate economics which assumes an undifferentiated, infinitely divisible mass of carbon mitigation measures which can be efficiently and effectively filtered almost entirely via cost, leaving aside their appurtenance to a given emissions source.
The means by which carbon pricing, of which cap and trade is one type, will transform energy use is to send a “price signal” to owners of polluting facilities to invest in technologies that cut these emissions. As discussed above cap and trade sends a signal of relatively poor quality as compared to a carbon tax, as it makes it difficult to predict the price of carbon into the next 5 or 10 years. This is crucial from the point of view of making the long-term investments needed to cut carbon emissions. So the touted equivalence between cap and trade and carbon taxation which is sometimes uttered by the current generation of environmental economists, is misleading when one considers the type of investments required to actually cut emissions on a firm-by-firm basis.
Cap and trade is actually a hybrid instrument, the mixture of a price and a permit regulatory instrument with an administrative component. By mixing these two components, cap and trade appears to offer a “one stop shop” to government officials. However in “mashing together” these two types of instrument, the quality of both components is substantially degraded: carbon taxes/fees are a much better price instrument and direct regulation and rulemaking, if funded, are far more effective and rational than cap and trade’s administrative measures that will either concern themselves with permit fraud or arbitrary shut down of facilities that have no more permits.
Finally and perhaps most difficult to appreciate is that cap and trade translates the problem domain (carbon mitigation) into it’s own language, foreclosing the possibility for insiders and potentially outsiders to examine how it is doing. This might be called “cap-and-trade solipsism.” While there is a long tradition in economics and other social sciences in inventing special use languages and terminology, cap and trade’s language makes everything within this domain a problem of markets and its own artificial market structures to a degree that impedes more general understanding and ultimately troubleshooting or comparison between alternatives. Recently I exchanged a series of comments with a gentleman who persisted in returning the discussion to one of “allowance prices” when I was bringing up a comparison between cap and trade and carbon tax. The inability or unwillingness to use a generic framework means discussions become distorted. There is large-scale epistemological issue for the social sciences here that unfortunately needs to be resolved simultaneously with improving climate policy. Put in other words, “quality control” in the social sciences is very difficult to put into action because of their fragmented structure.
Instead of basing the world’s most important policy instrument upon social scientific principles that have been shown again and again to alter consumer and investor behavior (clear incentives, clear and stable disincentives [taxes, fees, and rules], funded mandates, public investment), the choice has been made over and over again by people who should know better to go with the “thought experiment” that was assumed to have political benefits but has turned out to be less effective and terribly cumbersome as a policy. These supposed political benefits also by implication undermine the only stance that is going to significantly reduce emissions: that government action backed by the ethical concern of leaders and the public will impose direct limits on and help restructure our energy use system. If, according to cap and trade’s philosophy, the market is “doing it by itself” then the public should “stand back” and let the market do its work. This is a recipe for nothing getting done in the area of substantial emissions cuts.
2. Unseriousness for Politicians
As implied above, cap and trade kicks the political can of responsibility for climate protection “down the road” or “passes the buck” to markets or a future generation of politicians that will have to name a price for carbon mitigation. The declaration of the cap is the political “candy” with which politicians can claim an easy virtue for themselves without naming costs. In instituting a cap and trade framework, no leader is fully committing to regulating industry and consumer wants in the name of climate protection. An effective climate policy simply cannot “pass the buck”. Cap and trade institutionalizes “buck passing” via deferral to carbon markets, via the use of offsets and by not naming a price on carbon at the outset. The declaration of the cap, which is largely symbolic because if ambitious it is unenforceable, remains a fig-leaf behind which no pressure or commitment of public or consumer funds is required.
As I have argued here, and in conformance to the fears of many opponents of action on climate change, there is no getting around a strong role for government in transforming our fossil fuel-using habits; cap and trade, at least within the US context, furthers the myth that government is secondary to the process of carbon mitigation, which carbon markets will do better. If we take SOx regulation as an example, a far simpler task, this will definitely not be the case. Furthermore achieving carbon neutrality will mean lots of new public or government-incentivized investment in public goods like electric train lines, electric transmission and various large and small public works projects. To soft-pedal government is a mistake from the outset if you are serious about carbon mitigation.
Within this context there may be a differential perception of cap and trade when viewed in societies with a long history of government social welfare, higher taxes including energy taxes, and an across-the-political spectrum agreement that the government regulation is OK. To Europeans, for instance, cap and trade is just another regulatory program (that was supposed to be more acceptable to the Americans) that of course involves costs and raising the price of energy (like many European taxes), blending in with other initiatives. In the American context, cap and trade is supposed to circumvent government’s role and also promise no or negligible costs. Cap and trade might appear to be more acceptable in a context where government has a greater role in setting energy prices, planning infrastructure and there is already a fairly high level of taxation.
Ultimately government leaders will need to take responsibility for leading carbon mitigation efforts inclusive of the associated frustrations and transformations of old habits for business and consumers. While individual citizens taking responsibility for their own carbon footprints will also be crucial, leaders must lead and provide the matrix within which lower carbon choices are not acts of social and economic exile. As open as possible a discussion and confrontation with the costs and dislocations associated with this process is not only desirable but entirely necessary. Cap and trade, wherever the myth of market self-sufficiency is strong, undermines the development of a political discourse where both leaders and the public at large can examine the costs and benefits to action on climate change.
3. Unseriousness for Polluters
The cap and trade policy with its indirection, use of market “games”, and generally lax goals in implementation sends the message to polluters that they shouldn’t take climate change too seriously. The fundamental problem with cap and trade is that not only is it often in actual implementation a “sweet deal” for large polluters but it distracts them, with its market game playing (auctions, trading, permit allocation debates, offsets) from the serious tasks facing them in making their businesses largely carbon neutral within a couple decades. Auctions and trading are supposed to tap into the competitive mindset of businesspeople and are efforts to “come over to their side of the table”. While none of this is necessarily as trivial a game as football or baseball, the insertion of these elements into cap and trade are extraneous to pricing carbon and then letting businesspeople make decisions about how to reduce their carbon costs. The assumption is made that somehow, perhaps due to short attention spans or a lack of interest in the actual technological and processual challenges in cutting emissions that one would in some sense patronize businesses by creating a carbon “House of Games” from cloth from the (paper trading aspects) of the business world.
Furthermore, the notion that via carbon markets polluters would seek any “least cost” solution to mitigating carbon erases any notion of duty to innovate and stanch one’s own emissions, which might involve perhaps developing a small research and testing function within one’s organization. The policy, in reiterating what already is the mission of businesses, to reduce their costs, aligns itself with a price oriented rather than a process-oriented approach to emissions controls. The diversion of the market for pollution credits makes the job of mitigating carbon relatively “unserious” for the largest emitters.
4. Unseriousness for Financial Markets
One of the major challenges for many nations currently is to create an environment where long-term infrastructure and capital investment can thrive, especially for the purpose of transforming energy use. The US economy in particular has deindustrialized considerably and has a decaying infrastructure that is heavily dependent upon fossil fuels of both the imported (oil) and the domestic (coal and natural gas) kinds. The serious challenge associated with climate change is making the investment in this type of infrastructure and real energy and transport capital more attractive than the more speculative financial instruments based largely on paper rather than real assets which have dominated finance over the last 25 years.
Some economists and critics of the financial excesses of the last decades have called for finance to be made boring (again), meaning less financial engineering and, among other things, more financing of real engineering projects. The carbon permit market and the potential for the generation of various carbon derivatives opens another lucrative market for financial firms to make the quicker buck by trading rather than becoming involved in a long-term lending relationship with industrial and project development firms. On Wall Street, it has been an almost non-stop financial “party” over the last few decades as financial rewards have outstripped any meaningful economic value that this work has created.
Cap and trade then works against more general financial reform efforts that attempt to constrain banking and reduce the attractions of trading in favor of productive investments that create real jobs (and cut emissions) in the wider economy. The trading component of cap and trade and the creation of a new tradable financial abstraction and property right works almost diametrically against the process by which capital would be funneled towards long-term investments in things like wind farms, concentrating solar thermal farms, transmission, electric vehicle charging stations, etc. To trade is the financial “candy” that allows for high returns to traders within short time frames.
Common Feature of Cap and Trade’s Unseriousness
Cap and trade in its scientific attitude, orientation to politics, financial market design, and permit regulation all have one commonality: the cap and trade system inserts one or more extraneous elements that do not serve the purpose of cutting emissions or increasing the overall efficiency of the system. In most cases this “stop” along the way to achieving the goal is some form of “visit” to the carbon market before the actual job of cutting emissions or financing the emissions cutting projects can occur. The insertion of the carbon market into the process impedes rather than enhances the process of cutting emissions as this inserts variability and the structure of the permit market and its many superfluous stakeholders into the emissions cutting process.
The insertion of extraneous stakeholders into the process of cutting emissions means that there are people who have already developed financial interests in a status quo that will not accelerate emission cutting but will keep it only at a low boil, as they seek profits from price variability. These stakeholders will try to extract profits from the differences between “buy” and “sell” prices without much oversight or necessitate the erection of an additional regulatory structure WITHIN the cap and trade structure. As we have as yet not even succeeded in regulating the already existing derivatives market in the broader economy, why should be we be optimistic, as the salespeople of cap and trade will respond, that we would succeed in regulating this market, if the will is even there, once we have set up a structure that insures that variability? The stupidity of this altogether avoidable situation is mind-boggling.
Some take this to the extreme and say that profit-making itself is wrong or make various efforts to accuse others of making profit off doing good, as a way to impugn their characters. Instead, profit needs to be made for delivering real value rather than thoughtlessly offering a massive new lease on life to the overblown financial trading sector at a time that we can ill afford it. An ill-informed, undifferentiated endorsement of all profit-making leads to the giveaway of the planet’s biosphere to a coalition of extremely short-sighted people, while a condemnation of all profit-making insures that the value of efficiently run businesses will be excluded from the discussion.
“Carbon finance” despite its novelty, moors our financial system in the past rather than propels it into the future. Carbon finance interferes with an orientation towards investment in real assets that cut carbon by offering the “carrot” to financial firms of greater profits from trading carbon derivatives. Maybe with more time or a flusher economic system we could afford to play around with trading markets and carbon but we literally do not have the time anymore.
A “serious” carbon policy removes the extraneous elements because, frankly, we don’t have time to play around with someone’s intellectual hobby horse or third-parties’ wishes to extract excess trading profits from a transaction between two other parties. So-called “carbon finance” is not the same thing as project finance or venture investment. We need finance and investment with reasonable returns on investment without the “sweetening” for financial players of the trading profits associated with carbon trading.
Why is Cap and Trade’s Unseriousness Invisible or Tolerable to Well-Meaning Folk?
Even in an environment of skepticism about financial derivatives, cap and trade seems to have escaped critical scrutiny by people concerned about the climate. Paul Krugman, for instance, who is highly critical of how Wall Street has been regulated, puts out an occasional Op-Ed or blog post that supports cap and trade. Joe Romm, a blogger who wrote a good deal last year on his blog about a “global Ponzi scheme” and “rip-offsets”, has as of this year almost nothing critical to say about cap and trade. Even if writers and bloggers have reasons of personal political position or paychecks involved in exempting this instrument from any meaningful critical gaze, the equation of cap and trade with action on climate is widespread in the mainstream environmental movement and in liberal circles. Why is this so?
There are components to the “invisibility cloak” that makes it more likely that climate activists and politicians continue to support cap and trade despite (perhaps) knowing better.
1) Consumer Society and Unseriousness
A feature of wealthier consumer societies is that we have become used to pushing away or avoiding difficulties by moving on to the next product or fashion. After all, President George W. Bush after the 9/11 terrorist attacks recommended that people “go shopping” as a way to fight the terrorists. While at the time this seemed somewhat logical (keeping the economy going), it remained a superficial response to the dynamics that led to 9/11.
While we can pillory ex-President Bush for his awkward paean to consumerism, the attitude that simply a change of scenery or of product will make a world of difference is deeply embedded in the wealthier societies of the world. Therefore in this context, a “shopping” or market model for reducing emissions fits right in: cap and trade suggests that polluters are simply shopping for the “best buy” on the emissions reductions market, which, according to the global free trade ideal, should extend around the world.
Participants, and I include myself in this, in consumer society often become “unserious” people, in the sense that we are often preoccupied by largely trivial distinctions between products and services and questions of our own social identities. Public information systems and mass media that make the most of the latest scandals and inconsequential aspects of celebrity personalities add to the trivialization of choice. Cap and trade’s lack of seriousness blends in within this context.
2) Normalization of Derivative Trading-Based Finance
Trading financial instruments involves not seriously committing to a project or firm but simply trying to “work the spread” between buy and sell over a short period of time. There is a generation of people under 45 or 50 who grew up in a time when banking and finance came to be represented by the “glamorous” lifestyles and reputations of bankers/traders or the individualized pursuit of wealth of the day-trader. This generation compresses or misrecognizes the difference between investment and financial trading, having no memory of a different time when banking was largely “boring” and involved long-term commitments between financiers and borrowers. The abstract and individually isolated nature of financial trading hides the externalities (damages to others) created by a trading-dominated financial system.
Cap and trade’s design is a product of the confusion of these two functions of financial markets and misapplies a trading instrument where an investment instrument is actually needed. I can imagine that younger supporters of cap and trade have difficulty imagining a finance sector that sees its primary duty as issuing long-term loans rather than being involved in fast-paced swaps and trades.
3) Decline of an Ethic of Justified Profit-Making
In earlier periods in the economic history of capitalism there developed in some circles an ethic of justified profit-making: that one needed in some way to show that one had delivered a certain product or service with which one’s wealth became defined. This allowed the new social class of business owners to find a reason to feel superior to those who simply inherited their wealth or collected rent from large inherited landholdings. What Max Weber, called the “Protestant work ethic” (that is recently being disputed as being exclusively associated with Protestant portions of early Europe) helped define the mixture of ownership of productive assets (capital) and the entrepreneur’s work which promoted in the business owner a sense of virtue while risking committing the ancient sin of greed.
However, in the periodic speculative bubbles that have marked the history of our economic system, the relationship between entrepreneurial risk-taking in real enterprises and amounts of profit becomes frayed. In these periods, profits from trading relatively overpriced assets or paper derivatives of those assets can outstrip those earned by real entrepreneurs. James Galbraith has suggested that there exist a class of economic “predators” that thrive in speculative bubbles by their talent at locating opportunities to make what in other eras would be considered to be unearned profits.
In our current era, we are just beginning to hear calls for something like ethical profit-making, where the ethics is not simply inserted by association with a nominal cause or label attached to enterprise (“green” capitalism) but to the actual mechanism by which rewards are dispersed to individuals. Was risk taken? Was the product or service useful and/or socially useful? Was the compensation scheme just? In advanced industrial countries like the US, that have deindustrialized, more people are asking the question whether an “industrial policy” or systematic reform of the finance system will redirect capital to productive uses.
As outlined above, cap and trade, while it has a green veneer, creates a massive structure for targeting and achieving trading profits that are not compensation for a useful product or service. In the cap and trade framework those who profit the most will be not those who cut the most emissions either via innovation, efficiency or implementation.
As the policy’s designers have normalized a financial trading-led economic system they have developed a conception of business profit that does not distinguish between profit from investment and entrepreneurial risk and profits from exploiting asymmetrical information in trading markets.
4) Climate Economics is Tied to Monetarist Ways of Thinking
The economics of climate change has emerged in an era when monetarism had become the new orthodoxy in economics. Most practitioners of climate economics are focused to an excessive degree upon setting a price on carbon rather than also looking at the specific technological and infrastructure challenges associated with addressing climate change. A Keynesian approach to economics, which had fallen out of favor in the 80’s and 90’s, enables economists to appreciate the vital role of government investment and leadership, though it doesn’t deliver any ready-made solutions in the area of climate change (in part because it is underdeveloped through recent neglect). In this context, making the sole choice of policy between two carbon pricing instruments, cap and trade and carbon taxation, flattens some of the differences between the two instruments (though in an objective analysis still favors carbon taxation). Additional benefits of carbon taxes or fees, that they can complement or do not interfere so much with other policies, are left out of the picture.
5) Knowledge Gap Regarding Relevant Business Investment Decision Making Processes
There is a knowledge gap among the designers of policy, its supporters and those who will actually use the policy to make investment decisions in the domain of energy efficiency and business process reform. The economists who theorize about cap and trade and the environmental advocates of the policy do not in general have business experience and neither do political decision makers. Critical knowledge of how capital investment decisions are evaluated within businesses has evaded the notice of most of the policy designers, including the basic cash-flow analysis tools, like NPV and IRR. Many of the business leaders who endorse cap and trade and may be consulted by political leaders are not necessarily motivated to help policy designers to create the most aggressive or most effective policies. Engineers who understand which measures are relevant to their industries might not have been consulted by either one or the other of these groups. So those who are motivated to cut emissions do not know how the microeconomics works and they don’t communicate regularly with those who know something about the technical challenges and available equipment.
6) Expectations of a Machiavellian Politics
Speaking mostly of the US, but also taking into account its outsized influence on climate policy, sincere supporters of cap and trade see themselves faced with what amounts to be a false choice: support any proposal labeled “climate policy”, which unfortunately has been indentified largely with the cap and trade instrument, or implicitly support the rabid denial of climate change coming from opponents of any and all action to stem GHG emissions. In the US at least this type of choice between principles and pragmatism is particularly stark as negotiations often start with the liberal-left having taken it’s principled position off the table from the start.
While the political Right, which has historically been opposed to action on climate change, has often made proposals that start with their “first principles”, reformers from the center and the left in the US have made political careers lately by starting from a position of compromise or even appeasement. The successes of the Clinton Administration such as they were, were based on policy efforts that sacrificed principle from the beginning of the negotiation rather than in the middle. Even if we assume, in a democracy, that no one gets exactly what they want, we find that this self-censorship on the part of the liberal or Left side of the spectrum has, along with massive infusions of money from wealthy interest groups, truncated the scope of reform proposals and narrowed public political discussion. Unfortunately, the current Obama Administration has inherited some of the Clinton Administration’s emphasis on strategy that divorces itself from principle.
In such an atmosphere, the actual policy proposals for reform become tailored more for communication with an “inside politics” and lobbyist audience rather than the population at large. It is now common for the press and officials to generate a public discourse of “do-ability” without the need to explain why the focus on legislative success will concretely help the broader public. Political leaders and journalists want to be “insiders” and the public is expected to acknowledge that their interests may take a back seat in public discussion and in enacted policy. If one expects policy and politics to be about the self-preservation of political careers, cap and trade blends in, not for the success that it promises but it’s structure that remains impenetrable to all but the inside stakeholders.
Dimensions of Serious Climate Policy
While elsewhere I have offered summaries of two sets of policies and one overarching meta-economic framework for effective (serious) climate policy, here I will offer another point of entry into why I think climate policy needs a thoroughgoing revision. If we accept that we are in serious situation, an emergency, certain approaches are appropriate while others are not appropriate at all and should be left off the table. I believe looking at climate policy through the lens of “seriousness” or otherwise can reveal important dimensions of policy. While I believe I have offered two and half serious climate policies, I do not want these principles to suggest that these are the only possible serious climate policies
A serious climate policy
- Can cut greenhouse gas emissions with the highest (or close to the highest) level of rapidity without endangering economic development in the long term.
- Can be implemented (started) rapidly
- Recognizes and builds on existing emissions-reducing technology
- Tracks and promotes promising emerging technologies
- Supports energy research and innovation but does not hold policy hostage to unknown future breakthroughs.
- Aligns incentives (self-interest) to the greatest degree possible with cutting emissions.
- Excludes extraneous, non-climate related concerns from the core of the policy insofar as they may slow or undermine the most rapid action on climate; resist
- Can be adjusted to cut more or less emissions
- Draws strength from and mobilizes the “moral sentiments” and our sense of duty to each other and to the future.
- Enables transparent and equitable negotiations about global obligations and the price of climate change action between nations
- Prioritizes stanching the largest sources of emissions (coal-fired electrical power, tropical deforestation, fossil-fueled transport) from day one of the enactment of policy.
- Considers “emergency” measures that may lead to more rapid mitigation or cooling effects, inclusive of research into so-called “geo-engineering”.
- Addresses the balance between expenditures for aid for climate adaptation and expenditures for climate mitigation
- Increases the attractiveness of longer term investments in emissions reductions and sustainability.
- Addresses black carbon emissions nationally and internationally.
Wishlist for COP15
As COP15 is proceeding apace this week, I wanted to put out a wishlist for the outcome of that event as relates to a serious climate policy. Minds may already be made up and I am just one voice but here it goes:
- Commit to ambitious targets (30% over 1990 emissions by 2020 for industrialized nations, reduce deforestation related emissions by 90% by 2020)
- Do not commit to emissions trading as the means to achieve these goals
- Create a standing international committee to evaluate the institution of a price-based international instrument or other, perhaps project-based, alternatives to cap and trade
- Commit to a science- and evidence-based approach to policy