REFRAMING THE CONSERVATION CONVERSATIONUNLEASHING MARKET INNOVATION TO PROTECT THE ENVIRONMENT
JACOB DUBBERTJIMMY SENGENBERGERANDREW BARNESS
POLICY WHITE PAPER DECEMBER 16, 2019
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Millennial Policy Center Policy Paper December 16 | 2019
REFRAMING THE CONSERVATION CONVERSATIONUNLEASHING MARKET INNOVATION TO PROTECT THE ENVIRONMENT
JACOB DUBBERT JIMMY SENGENBERGERANDREW BARNESS
ABOUT THE AUTHORS
Jacob Dubbert is an Economic Opportunity and Fiscal Policy Fellow at the Millennial Policy Center. He also works as an economist in Denver, Colorado, Jacob received his Masters in Global Finance, Trade, and Economic Integration from the University of Denver and his Bachelors in Finance from Colorado State University.
Jimmy Sengenberger serves as Chairman, President, and CEO of the Millennial Policy Center. Jimmy is also a seasoned radio talk show host on Denver's News/Talk 710 KNUS and has been published in a number of national and Colorado-based publications. He is a 2011 graduate of Regis University, Summa Cum Laude, with a degree in Politics and a minor in Economics, and also spent nearly three years as a legal assistant.
Andrew Barness is an Energy and Environment Fellow at the Millennial Policy Center. The primary author of this paper, Andrew is currently preparing to enter law school. Andrew interned for MPC in 2018, and in 2019 he received his Bachelors in Political Science from the University of Northern Colorado with a minor in Legal Studies and Public Policy and Administration.
The Millennial Policy Center is a research and educational institute (a think tank) dedicated to addressing public policy issues that affect the Millennial Generation (born 1981-1997) and to developing and promoting policy solutions that advance freedom, opportunity, and economic vitality for Millennials throughout the United States.
In collaboration with our policy advisors and policy fellows, the Center generates and shares knowledge, and it fosters public debate and understanding through various mediums.
For more information please visit our website: WWW.MILLENNIALPOLICYCENTER.ORG
ABOUT THE MILLENNIAL POLICY CENTER
ACKNOWLEDGMENTSA special thanks is due to Dr. Robert Margesson, Ph.D., Regis University associate professor; Major Clifford Andersen, U.S. Army Special Forces Ret.; Mr. Keith Nobles, National Security Policy Advisor; and Mrs. Michelle Stinnett for their input and time in reviewing and offering suggested revisions for this paper.
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Millennials – the most environmentally-conscious generation – are leading the charge for a more
sustainable future. We take for granted that conserving the environment is vital to the wellbeing of
individuals around the world, yet we have come of age in an era of mainstream policies that almost
universally rely on government intervention. And this intervention has not worked.
Indeed, conventional wisdom holds that, with unprecedented growth in population and economic
output over the past century, a large burden has been placed on Earth’s scarce resources and
environment. Governments, therefore, have a fundamental obligation to alleviate this strain and protect
the environment. Conventional wisdom also holds that climate change is a prime example of “market
failure” that requires government direction. Yet government efforts to address environmental concerns
seem to have little success while exerting a large economic toll on Americans.
The Green New Deal is an impractical, untenable “solution” offering false hope to young people. It's
time for a renewed environmental agenda that harnesses Millennials’ drive to make a difference in the
world while unleashing diverse, innovative, and effective solutions. Our purpose is to offer Millennials
an alternative approach to environmental stewardship – one that capitalizes on, rather than diminishes,
individual freedom and is more cost-effective than today’s overbearing, top-down approach.
The problem with the current atmosphere of centralized solutions is that, while some were successful in
the past, recent experiments tend to fail. Environmental regulations and policies force a constrictive
burden on individuals, companies, and industries, attempting to protect the environment while risking
economic growth and personal wellbeing – and achieving dubious rewards for the risk.
The great success of free markets has provided an unprecedented plethora of choice, opportunity, and
prosperity, enabling us to tackle problems in creative and innovative ways. Environmental conservation
must lean on free market-based incentives to protect the environment. Environmental problems largely
result from the absence of markets, not because of them. Turning the environment into an asset and
embracing market mechanisms would both promote economic growth and provide environmental
protection. By establishing and enhancing well-defined property rights and promoting positive
incentives, we can realize diverse and efficient solutions to preserve our environment.
Ultimately, the best way to protect the environment is by boosting economic growth and the standard of
living. Free and developed societies that embrace free enterprise overwhelmingly attain both. The
common idea that there is a trade-off between economic growth and environmental protection is false.
As free societies have grown wealthier, investment, opportunity, and innovation have risen and driven
efficiency gains, leading to a decreased burden on the environment.
Our renewed agenda offers market solutions to guard against further degradation of our environment in
the most cost-effective way, while retaining the freedom, opportunity, and prosperity that are vital to all.
It’s time to breathe new life into the environment debate by advocating for a revitalized environmental
conservationism.
EXECUTIVE SUMMARYEXECUTIVE SUMMARYEXECUTIVE SUMMARYEXECUTIVE SUMMARY
Reframing the Conservation ConversationReframing the Conservation ConversationReframing the Conservation ConversationReframing the Conservation Conversation
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American environmental policy largely centers on federal government regulation of activities that may
or may not have an environmental impact. The theory is that environmental problems stem from market
failures and therefore, government must step in to fix them. According to the Environmental Protection
Agency (EPA), there are two methods available for policymakers to change a society's consumption and
production habits: Command and Control (CAC) and economic incentives.1 The CAC method involves
directly regulating an industry or activity that has clear standards and is easy to enforce and implement.
The economic incentive method leans on policies that leverage market forces to correct for producer and
consumer behavior.2 These two methods are widely identified as the preferred strategy to protect the
environment, and a sweeping approach like the Green New Deal would likely involve both.
Command and Control (CAC) RegulationCommand and Control (CAC) RegulationCommand and Control (CAC) RegulationCommand and Control (CAC) Regulation CAC regulation is “the direct regulation of an industry or activity by legislation that states what is
permitted and what is illegal.”3 CAC is traditionally used in the United States and often sets specific limits
for pollution emissions or mandates that certain clean technologies or energy should be used.
CAC rests on three main regulatory mechanisms: ambient, emissions, or technology standards.4 Ambient
standards set the maximum amount of a pollutant that can be present within a specific environment. An
example of an ambient standard is the Clean Air Act, which requires the EPA to set air quality standards for six pollutants considered harmful to public health and the environment: carbon monoxide, lead,
nitrogen dioxide, ozone, particle pollution, and sulfur dioxide.5
Emissions standards limit the amount of emissions that a firm, industry, or area is allowed to release.
These standards are much more direct than ambient ones in that they seek to reduce the overall amount
of pollutants on a firm by firm level. Finally, technology standards are implemented by regulators and
mandate that firms adopt a specific pollution control technology. Examples include the installation of
scrubbers in coal-fired power plants.
Evaluating Command and Control RegulationEvaluating Command and Control RegulationEvaluating Command and Control RegulationEvaluating Command and Control Regulation The AdvantagesThe AdvantagesThe AdvantagesThe Advantages Early on, CAC environmental regulations were highly successful. The EPA was established in 1970 to
“enforce activities to ensure environmental protection.”6 Congress subsequently adopted the Clean Air Act (1970) and the Clean Water Act (1972) to address air and water pollution, respectively. These laws did initially improve America’s air and water quality.
Yet the main reason there was such a vast improvement is because of how terrible things were to begin
with. Environmental stewardship was very low, with terrible air and water quality being the norm, so it
was relatively easy to improve conditions quickly from such a low base. But these laws only solved the
“easy” environmental problems. As expectations for greater environmental protection have increased,
policymakers have implemented more costly methods to address less-pronounced challenges than
before. Consequently, the marginal benefits have diminished.
SECTION ONESECTION ONESECTION ONESECTION ONE
The Current State of U.S. Environmental PolicyThe Current State of U.S. Environmental PolicyThe Current State of U.S. Environmental PolicyThe Current State of U.S. Environmental Policy
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The overall gains from CAC regulation stem from simplicity. Regulators identify a specific problem and
then develop and execute a policy. Maximum pollutant levels provide benchmark goals that can be easily
evaluated. If firms exceed the proposed limit, they are fined. Ultimately, CAC enables regulators to
quickly respond to individuals or firms that fail to abide by the set standards.
The DisadvantagesThe DisadvantagesThe DisadvantagesThe Disadvantages As with most regulatory initiatives, government regulations imposed for the environment have
significantly overreached. Additionally, while some original CAC regulations successfully fostered
environmental conservation, the marginal costs of regulation have increased, and the marginal benefits
have declined. This is because the foundation of the CAC method stifles innovation, empowers
bureaucracies, upsurges the cost of goods and services, infringes on individual freedom, and ultimately,
derails the market mechanism.
First, CAC red tape fails to adequately encourage companies to find innovative ways to protect the
environment. Government-prescribed methods are often uniformly applied with no consideration of
differences among firms and the individual costs for each firm. Pollution control technologies mandated
by regulators can be costlier for some firms, so it is frequently not the most cost-effective solution.
Limiting decision-making flexibility when it comes to reducing pollution or to protecting the
environment eliminates the incentive for companies to research innovative, new ways to reduce their
impact.7 Additionally, firms lack motivation to reduce emissions beyond the mandated level. Once they
hit the regulated level, they won’t go beyond it because they’ve already met the standards.
Second, environmental regulations are often politically motivated, and the costs and subjective benefits
are rarely measured properly.8 Government policies rely on information provided by bureaucrats, and
political incentives tend to cloud information and skew the judgement used to form important
environmental policies. It’s highly likely that key facts will be misrepresented to achieve political ends
and influence policy.
Third, CAC regulation is very costly. By imposing narrow standards or strictly limiting to certain
technologies, firms must execute expensive adaptations to their business that can significantly reduce
productivity. These costs of compliance put an undue hardship on businesses, often instigating job losses
and higher consumer prices. The process of creating regulations and enforcing them also stimulates
higher costs to American taxpayers. This is because it is very difficult and time-consuming for regulators
to gather the information needed to effectively implement the rules.
Fourth, CAC impedes on individual freedom. Like most government intervention, it strips away an
individual’s or firm’s decisions on how to act by attempting to control behavior. This erodes the
fundamental idea that Americans are free to think, free to act, and free to choose.
The free market has been the bedrock of American prosperity because it helps drive competition, foster
innovation, and enhance efficiency. Regulatory red tape distorts these positive outcomes. By mandating
green technologies or green energy use, production costs rise, thereby inhibiting firms’ competitive edge.
This stunts companies’ motivation to generate new ways to reduce their impact on the environment and
artificially props up inefficient industries that are “greener.” Ultimately, markets drive efficiency, and the
best way to conserve and maximize resources and dampen humans’ environmental impact is to pioneer
groundbreaking ways to boost productivity.
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TTTThe High Cost of Command and Control Regulationhe High Cost of Command and Control Regulationhe High Cost of Command and Control Regulationhe High Cost of Command and Control Regulation The prevailing environmental policy consensus suggests that “protecting the Earth” justifies any costs and any strategy. While environmental stewardship is essential, the problem remains that the policies
proposed typically do little to actually protect the environment but inflict a large economic toll.
Environmental policies must consider the costs because economic vitality is the most prominent
contributor to an individual’s wellbeing and personal incentive to protect the environment. Therefore,
decisions on centrally-planned environmental policies should prioritize estimates of economic burden.
Like all regulations, environmental policies pose different costs on different entities. Sometimes these
costs can be significant, unfairly burdening individuals and firms. The costs of environment regulation
include regulatory costs of implementation and enforcement, as well as compliance costs that are realized
by firms and households. Specifically, environmental regulations have been found to upsurge electricity
prices, increase costs for taxpayers and companies of all sizes, and reduce the availability of jobs in certain
sectors.9,10 For example, California’s average commercial electricity price in August 2019 was 63.6 percent
higher than the U.S. average, and the industrial price was 102.9 percent higher, translating into ratepayers
paying $104 billion more than ratepayers elsewhere in the U.S.11
Taxpayer costs from EPA activities are easily calculated. According to the EPA, their budget has steadily
increased over the years from around $4.6 billion in 1980 to just over $8 billion in 2017.12 The EPA's
budget was cut 23.2 percent for 2019, at just over $6 billion.13
It's much more difficult to identify the overall direct and indirect compliance costs on consumers and
firms that stem from environmental policies. Direct compliance costs to firms are the change in
production costs resulting from a policy. Indirect costs discourage private investment. Regulations with
stringent standards on new equipment could delay investment into new, more productive equipment.14
Fortunately, it is possible to assess the impacts of specific policies. Two recent examples of this are the
Clean Power Plan (CPP), which never went into effect but was recently replaced by the Trump
Administration’s Affordable Clean Energy (ACE) Rule, and the Paris Climate Accord. Both the CPP and
the Paris Accord were specific attempts to address climate change. In addition, an even more expansive
proposal is the Green New Deal.
The Clean Power PlanThe Clean Power PlanThe Clean Power PlanThe Clean Power Plan CPP was approved by the Obama EPA in 2015. Due to a Supreme Court stay on the CPP in 2016, the
program never went into effect. Ultimately, the Trump EPA repealed the unimplemented rule and
replaced it with a less-constrictive alternative, the Affordable Clean Energy (ACE) Rule.15
The CPP would have set “carbon dioxide limits for new fossil fuel-fired power plants” with the goal of
reducing the carbon dioxide (CO2) emitted from electrical power generation by 32 percent by 2030,
relative to 2005 levels.16 The plan expressly targeted coal-burning power plants and promoted renewable
energies and energy conservation. Doing away with the CPP slashes the red tape suffocating development
of U.S. energy resources.
A report by NERA Economic Consulting studied the potential impacts of the CPP and found the costs
to be significant.17 Under one scenario, average annual electricity sector CO2 emissions would be reduced
by about 22 percent, but at the cost of higher natural gas prices of about two percent and a rise in
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consumer electricity prices of about 12 percent from 2017 through 2031. A more aggressive scenario
suggests CO2 emissions would have been slashed by 40 percent, but at the cost of 29 percent higher
natural gas prices and 17 percent higher consumer electricity prices over the same period.
The Energy Information Association (EIA) also modeled and assessed the potential impacts of the CPP.18
While the report found that the CPP would reduce projected power sector CO2 emissions by 2030 by 29
percent to 36 percent relative to 2005 emissions levels, electricity prices would increase by 3 percent to 7
percent, on average, from 2020 to 2025. Additionally, GDP, industrial shipments and consumption
would be reduced under the CPP, with an estimated cumulative 0.17 percent to 0.25 percent decline in
GDP from 2015-2040.
The CPP would have deeply burdened the coal industry. While coal production emits more CO2 than
natural gas, wind, or solar, it still represents roughly 30 percent of total American energy consumption.
This reliance on coal supports many jobs and more affordable consumer energy prices throughout the
country. Until electrical grids change and alternatives to coal become more cost effective, coal will
remain an important part of our energy mix. With that said, the energy market is switching to cleaner,
more efficient natural gas, but this has been a consequence of market forces, not government edicts.
There is no need to further disadvantage coal producers to the benefit of other energy producers.
The Paris AccordThe Paris AccordThe Paris AccordThe Paris Accord When the Paris Agreement was signed on November 4, 2016, many viewed it as groundbreaking. The
accord pushes countries to undertake an ambitious goal to hold global temperature rise below 2 degrees
Celsius (3.6 degrees Fahrenheit) above pre-industrial levels through 2100.19 The agreement also aims to
further limit the temperature increase by the year 2100 to 1.5 degrees Celsius (2.7 degrees Fahrenheit)
and to help countries deal with climate change impacts.
While the U.S. was originally party to the agreement under former President Barack Obama, President
Donald Trump fulfilled his campaign promise and announced that he would withdraw the U.S. shortly
after taking office. Recently, President Trump officially began the process of withdrawing the U.S. from
the accord, making it the only country to reject it.20 The Obama Administration pledged to initially cut
U.S. greenhouse emissions by 26 to 28 percent by 2025 and move to an 80 percent cut in the future.21 The
proposal included CO2 regulations for new and existing power plants (CPP), fuel-efficiency and
greenhouse gas regulations for vehicles, energy-efficiency regulations for residential buildings, and
methane regulations for landfills and the oil and gas sector.
While the Paris Agreement is well-intentioned, its costs are high for the U.S. – and with minimal benefit.
President Trump is right to withdraw, as the accord will do very little to actually address climate change.
The agreement puts no accountability on countries to live up to their commitment, and there are no
guarantees whatsoever that China and India – the world’s two largest greenhouse gas emitters – will
follow through. Ultimately, the Paris Agreement would put a significant burden on American businesses,
workers, taxpayers, and the economy.
A Heritage Foundation study found that, by 2035, U.S. participation in the accord would cut American
jobs by nearly 400,000, reduce income for a family of four by $20,000, increase household electricity costs
by 13 to 20 percent, and slice $2.5 trillion off of an aggregate GDP.22
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An additional report by NERA Economic Consulting projected the impact on the U.S. economy out to
2040 if industrial companies took part in the U.S. greenhouse emissions reduction effort under Paris.23
Their baseline analysis suggests future greenhouse gas regulation could reduce U.S. GDP by about $250
billion by 2025 and $2.9 trillion by 2040. Additionally, job losses could reach around 2.7 million by 2025
and 31.6 million by 2040. While the study estimates there would likely be relatively large reductions in
emissions, the economic cost would be profound.
Most importantly, all the costs resulting from the agreement are widely found to only have an
insignificant effect on actually limiting climate change and global temperature rise. In fact, studies by
proponents of the agreement find the reduction in global temperature rise to be nil. The MIT Joint
Program on the Science and Policy of Global Change, for example, concluded that proposed cuts would
only result in about 0.2 degrees Celsius (0.36 degrees Fahrenheit) less warming by 2100.24 While this is
only an estimate of current commitments, of which are expected to strengthen over time, it is one
example of how little of an effect we can actually have on reducing global temperature rise.
The The The The Green New DealGreen New DealGreen New DealGreen New Deal Among many in the Millennial Generation and Generation Z, the Green New Deal (GND) is en vogue as a preferred, widescale way of “saving the planet” from climate change. Introduced and advanced by
democratic socialist Congresswoman Alexandria Ocasio-Cortez of New York, herself a Millennial, the
GND would represent the most expansive government initiative in American history. Although billed
as an environmental effort, “the GND is not just a climate change policy. It is a vision for a new kind of
economy, built around a new set of social and economic relationships. It is not merely a way to reduce
emissions, but also to ameliorate the other symptoms and dysfunctions of a late capitalist economy:
growing inequality and concentration of power at the top.”25
The GND seeks a “fair and just transition” away from fossil fuels to significantly cut America’s
greenhouse gas emissions through central planning. Its goal is to achieve “100 percent of [U.S.] power
demand…through clean, renewable, and zero-emission energy sources.”26 It does this through a direct
assault on coal, oil, natural gas, automobiles, and numerous other non-energy sectors (such as housing).
Although some incentives-based strategies like subsidies and carbon taxes may be in the policy mix, the
GND would mostly utilize CAC strategies. One analysis from the Left suggests that, to accomplish the
GND’s climate goals: “Decarbonizing transportation will involve radically accelerating the spread of
electric vehicles, possibly by banning gasoline and diesel vehicle sales by 2030, and figuring out what to do with aviation and heavy transport…Decarbonizing buildings will involve implementing zero-carbon standards for all new buildings and funding the wholesale retrofitting of existing buildings, millions of
which use fossil fuels like natural gas for heating and cooling” (emphasis added).27 “Bans,” “standards,”
and “wholesale retrofitting” require government force and an express CAC approach – a tried-and-failed
strategy.
Moreover, the economic harm and costs are astronomical. Although the GND is vague on specifics, the
full program would cost tens of trillions of dollars over a decade. Former White House Budget Director
Douglas Holtz-Eakin and colleagues at the American Action Forum estimated the total taxpayer expense
at $93 trillion – or $600,000 per American – from 2020-2029.28 In addition, a Heritage Foundation
analysis of the carbon components alone – using its Heritage Energy Model – found that, “by 2040 one
can expect:29
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A peak employment shortfall of over 1.4 million jobs.
A total income loss of more than $40,000 for a family of four.
An aggregate gross domestic product (GDP) loss of over $3.9 trillion.
Increases in household electricity expenditures averaging approximately 12 to 14 percent.”
Such an overt assault on individual liberty, coupled with high taxpayer costs and economic harm, renders
the GND economically infeasible, politically impractical, and genuinely outlandish. Thus, this will be
our only discussion of the GND in this paper.
In recent years, market incentives-based policies have become increasingly prevalent in addressing
environmental issues. This method again stems from the view that environmental problems stem from
market failures, and it focuses on incorporating the full social or external costs in production. The
approach offers strategies to reduce emissions by putting a price on negative environment externalities
and creating incentives for private actors to incorporate pollution abatement in their decisions.30
According to Robert Stavins, “Market-based instruments are regulations that encourage behavior
through market signals rather than through explicit directives regarding pollution control levels or
methods.”31 Ultimately, the incentive approach to environmental protection is meant to thwart outcomes
of market activity by altering incentives or individual decision-making through government.
Incentives-based methods recently evolved into a seemingly bipartisan pathway to environment
conservation. Although many have viewed as a right-leaning solution to environmental problems, left-
wing politicians and academics have embraced them. Then-President Obama, in his 2013 State of the
Union address, urged a cap and trade policy, previously offered during the Bush administration by then-
Senators John McCain and Joe Lieberman. Carbon taxes are often proposed as well.
While the addition of incentives-based methods to our environmental toolbox is an improvement, as
they offer greater flexibility and practicality than command and control regulation, they are still generally
onerous to individuals and firms. Incentives-based methods are typically called “market-based” because
they leverage some market principles to change behavior through a government-guided, incentives-
based approach. However, since they restrict the ability of individuals or firms to freely make decisions
through a regime of restrictions or taxes on polluters, we don’t consider them to be “market-based.”
IncentivesIncentivesIncentivesIncentives----Based MethodsBased MethodsBased MethodsBased Methods There are three primary, incentives-based methods generally proposed: tradable permits, pollution
charges, and subsidies.32
Tradable PermitsTradable PermitsTradable PermitsTradable Permits Tradable pollution permits are intended to create an artificial market through which pollution can be
limited at an optimal cost to an industry. They allow a “right to pollute” to be sold in the market and
“rely on the market to identify the most cost-efficient way to allocate regulatory obligations.”33
SECTISECTISECTISECTION TWOON TWOON TWOON TWO
Market IncentivesMarket IncentivesMarket IncentivesMarket Incentives----Based PoliciesBased PoliciesBased PoliciesBased Policies
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According to the EPA, this approach is flexible in that firms are able to reduce their own emissions
voluntarily or “purchase pollution allowances from other firms who have reduced below their required
level.”34 Firms that maintain emissions below the set standard can sell their extra permits, and firms with
excess emissions can purchase permits to meet their own demand. The idea is that firms will reduce
emissions as much as possible because they are driven by financial benefit. The EPA says there are two
types of tradable permit systems currently used in the U.S.: Emission Reduction Credits (ERCs) and
capped allowance (“cap and trade”) systems.
Many consider tradable permits to be a good alternative to CAC regulations because they offer firms
greater flexibility, promote some innovation, and encourage faster reduction in emissions. Flexibility
increases with tradable permits because they allow a firm to recognize the most optimal way to meet
policy targets. Firms aren't required to comply with a specific standard or implement specific technology;
rather, they are free to innovate on their own. Due to the ability to profit or save money from the sale of
allowances or credits, reducing emissions is usually in a firm’s best interest.
While tradable permits are often promoted as a market-based alternative to overbearing regulations,
opponents often point out that they are essentially a tax on energy use that leads to higher energy prices
and job losses, reduced consumer spending power, and lower GDP. Of course, the idea of a cap and trade
program is to increase the price of energy in order to incentivize the shift away from some energy sources.
The Institute for Energy Research found that the Lieberman-Warner cap and trade program introduced
during the early years of the Obama administration would have increased the cost of electricity by 77 to
129 percent, reduced U.S. jobs by up to four million, and sliced disposable income per household by
$4,022 to $6,752 – all for a 63 percent decline in emissions.35
Emission Taxes, Fees and ChargesEmission Taxes, Fees and ChargesEmission Taxes, Fees and ChargesEmission Taxes, Fees and Charges An emission tax uses prices within markets to shift investment and behavior among firms and
individuals. Theoretically, the negative externalities associated with polluting activities are internalized
to polluters with a tax, encouraging them to reduce their pollution and help clean up the environment.
Emission taxes are considered more dynamic than CAC regulations because, rather than prescribing a
mandated method or level of acceptable emissions, they offer firms and individuals the room to select
whichever method(s) to decrease emissions they prefer. Firms are also free to emit as much as they wish;
they will just have to pay the price associated with it.
While emission taxes have gained immense popularity in recent years as an alternative to top-down
regulation, the idea of taxing emissions isn't new. Then-President Bill Clinton attempted to pass a BTU
tax in 1993,36 former President Obama was a proponent of taxing emissions, and many Democrats have
endorsed the idea. The center-right Climate Leadership Council (CLC) offered their own plan to tax
greenhouse gas emissions at $40 per ton and returns a climate dividend to taxpayers.37
A bill with a similar approach, the Energy Innovation and Carbon Dividend Act, has been introduced in Congress.38 The legislation would do four main things. First, it would establish a tax on carbon
emissions, with some exemptions. The tax would be $15 per metric ton of CO2 in the first year, with a
$10 per ton increase annually ($15 if emissions targets aren’t met) until emissions hit 10 percent of 2016
levels. Second, because the bill’s sponsors recognize costs for American producers will rise as a result of
the tax, a border adjustment tax (tariff) would be implemented on imports to the U.S. so as to maintain
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a “level playing field.” Third, the EICDA would put a hold on CO2-related regulations for a decade while
the tax is in effect; regulations would kick in after 10 years if emissions targets aren’t met. Finally, the tax
revenue raised would be returned to individual energy consumers in the form of a “carbon dividend” to
help offset the inevitable, increased energy costs. The dividend amount would ratchet up over time,
rising to an estimated $200 per month per family after five years according to advocates.
The problem with emission taxes, such as the EICDA proposal, is that these are taxes, so they carry with
them the negative effects inherent with taxation. In particular, this tax would heavily impact users and
producers of natural gas, coal, and oil, which constitute the majority of the energy we consume. The tax
would be transferred to consumers through higher prices for electricity and gasoline and would cause
many job losses in the energy sector. Proponents actually view this as a positive, acknowledging that the
tax will intentionally increase fuel prices and thereby reduce consumers’ incentive to use the fuel – much
like the argument behind a tobacco tax.
At the same time, many carbon tax advocates – such as those backing the EICDA – favor the idea of a
“carbon dividend” rebated to Americans from the revenue to offset price increases. As noted above, the
EICDA would eventually give $200 per month per family to help, but this appears in no way to be enough
to offset higher energy bills and prices at the pump. Importantly, emission taxes are regressive and
impact the poor more heavily than wealthier individuals. This is because low-income households spend
a larger portion of their income on electricity and fuel than higher-income households. In fact, a study
by Energy Efficiency for All found that low-income households spend 7.2 percent of their income on
utility bills – more than triple the 2.3 percent spent by high-income households.39 Therefore, by raising
the cost for poorer families to heat their homes, a carbon tax would reduce their discretionary income.
Moreover, as the economy has improved since the Great Recession, more Americans have gained access
to their own vehicles. In fact, one review of U.S. Census data found that “only 20 percent of adults living
in poverty in 2016 reported that they had no access to a vehicle,” which is “down from 22 percent in
2006.”40 Despite all sorts of government subsidies for transit in California, “increasing car ownership,
particularly among lower-income residents, was likely the biggest factor in declining transit ridership in
Southern California.”41
A carbon tax would inevitably – and intentionally42 – result in higher prices at the pump. This will eat
into the incomes of poorer Americans who are finally, in increasing numbers, seeing higher wages and
feeling as though they are active participants in our economy. Lower-income families have less flexibility
to cover basic costs like wealthier people do. Higher gasoline prices and energy bills may mean they’ll
miss out on a Christmas family vacation or won’t get to take their kids to enjoy the rare opportunity to
see a professional football game. Even more, higher gasoline prices will not lead these lower-income
drivers to buy new, electric vehicles (EVs) even with subsidies. There are two reasons for this. First, EVs
are charged at home or at charging stations, both of which require conventional electricity. Thus, the
cost to charge these coal-fired or natural gas-powered vehicles will rise as household energy prices rise.
Second, EV subsidies do not provide sufficient incentive for lower-income and even middle-class drivers
to buy new EVs. If years of such tax credits had actually worked, we’d see far more on the road than the
1.8 percent of the automobile market electric vehicles make up (approximately 1.18 million EVs).43
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SubsidiesSubsidiesSubsidiesSubsidies Government subsidies support pollution reduction and activities deemed environmentally-friendly.44
Subsidies are like other incentives-based mechanisms that seek to induce changes in behavior; however,
instead of charging (punishing) polluters for emissions, they offer rewards for reducing them. Subsidies
are often used to tackle negative externalities, and advocates contend they promote positive externalities
that would be otherwise unobtainable through the private market.
The EPA identifies many examples of subsidies for pollution control, including grants, low-interest loans,
favorable tax treatment, and procurement mandates. Special tax treatment for electrical vehicles and tax
credits for the investment and production of renewable energy are forms of subsidization.
Even though subsidies may appear to serve the public good, they are a prime example of government
distorting the market byhand-picking winners and losers. Instead of letting legitimate market forces
determine the most efficient allocation of resources and therefore the success or failure of a business,
subsidies promote an inefficient allocation, resulting in decreased competition and innovation and
inevitably leading to higher prices and inferior products or services for consumers.45,46
Without question, Millennials – the largest generation in the workforce today – recognize the importance
of environmental sustainability. America must embrace it as well, but in a way that supports continued
economic growth. The goal of our revitalized environmental conservationism is to encourage a free-
market approach to environmental stewardship through markets, freedom, competition, prosperity, and
most of all, innovation.
We acknowledge the large burden humanity can place on our planet’s scarce resources, and that the
climate is changing. While the extent to which humans influence climate change is up for debate, there
are steps we should take to alleviate our burden on the environment in a more effective and cost-efficient
manner. We recognize, however, that environmental issues are largely the consequence of the
mismanagement of common resources and the absence of clear and enforced property rights. Genuine
markets – not weaker ones – and well-defined property rights answer our environmental problems. Thus,
this isn’t an approach that completely rids of government involvement, but it relies on fortified property
rights and thriving market forces.
The Five Core PrinciplesThe Five Core PrinciplesThe Five Core PrinciplesThe Five Core Principles Our solutions are rooted in five core principles for environmental conservation. The first two tenets
have already been addressed. The five principles are:
1.1.1.1. Environmental conservation is inherently valuable and an important social good.
2.2.2.2. Government regulation and central planning may bring about some environmental benefits, but
it stunts overall innovation and harms individual economic wellbeing.
3.3.3.3. Private property rights are fundamental to protecting the environment, as they create incentives
for responsible actions and provide the basis for meaningful markets.
SECTION THREESECTION THREESECTION THREESECTION THREE
A Revitalized, 21A Revitalized, 21A Revitalized, 21A Revitalized, 21stststst Century Environmental ConservationismCentury Environmental ConservationismCentury Environmental ConservationismCentury Environmental Conservationism
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4.4.4.4. Free markets promote a more flexible approach that more accurately reflects all costs involved
than government-directed policies or markets.
5.5.5.5. Economic growth and increased wealth foster better environmental stewardship.
The Significance of Property RightsThe Significance of Property RightsThe Significance of Property RightsThe Significance of Property Rights Protecting private property rights is a fundamental part of environmental conservation because they
motivate individuals to take care of property and resources, as they possess the exclusive right to use
those resources as they see fit. When property rights are clear and protected, good stewardship is
promoted naturally. They let long-term incentives maximize the value of a property because individual
ownership of resources (such as land or water) encourages owners to better manage and conserve them
for future use. But when property rights are ambiguous or not enforced, resources are more prone to
exploitation. That is because individuals have little or no incentive to protect public areas, a phenomenon
known as the “tragedy of the commons.”
Well-defined and well-enforced property rights depend greatly on government institutions. In a free
society, government’s first responsibility is to protect individual rights and ensure individual liberty is
not trampled upon. Douglass North famously demonstrated the primary economic benefit to society
when institutions embrace secure and transferrable property rights. According to North, institutional
arrangements and property rights are essential to economic growth and efficiency. That’s because they
create incentives to “channel individual effort into activities that bring the private rate of return close to
the social rate of return.”47 Applying North’s insights on property rights to the environment offers a
viable answer to the stewardship question.
Property rights help solve the tragedy of the commons because they align an owner’s incentives with the
value of the underlying resource. In Hardwin's famous work The Tragedy of the Commons, a “commons” is defined as a resource shared by many but over which no one individual has a claim to any
part of the resource.48 When resources are common, Hardwin explains, a tragedy develops in the absence
of regulation. That is, individuals exploit the commons to maximize their gain, eventually depleting and
ruining the resource. Since people are naturally self-interested, they will derive as much from the
commons as they can, and the costs are spread among all the others sharing the commons.
This “tragedy” arises from poor, underlying institutional arrangements and the absence of meaningful
property rights. Private property owners have good reason to preserve their own resources, whether for
economic gain or simple pleasure, and others are prevented from exploiting resources or property that
isn't theirs. When property rights are absent or poorly protected, there isn’t a way to attribute the full
cost of resource degradation to any entity.
One famous example of the tragedy of the commons involves fisheries. Fish stocks in oceans and
commonly-held fisheries have been greatly depleted around the world. This is mainly because they are
unowned; they are open and free to all individuals for fishing and there are no enticements to conserve
the fish. So, individuals are encouraged to extract as many fish as possible, inevitably leading to the
overexploitation and depletion of the fish stock. However, when individuals have rights to the fish, the
tragedy of the commons is avoided. Owners have cause to avoid overfishing and to conserve the fishery
so they can enjoy it for future use. Multiple studies on publicly- and privately-managed fisheries support
the claim that property rights help avert the tragedy of the commons. Many governments have
successfully guarded against overexploitation of them by securing property rights.49,50
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Natural Market Incentives, Economic Growth and Increased WealthNatural Market Incentives, Economic Growth and Increased WealthNatural Market Incentives, Economic Growth and Increased WealthNatural Market Incentives, Economic Growth and Increased Wealth Decentralized methods of addressing environmental issues like user fees, incentives, and markets can
work much better than top-down central planning, such as subsidies, bureaucracy, and regulation. That’s
because markets provide the required information, such as price signals, and create natural incentives to
improve environmental quality. Contrarily, government-created markets like cap-and-trade artificially
distort markets rather than better informing them.
Incorporating natural economic incentives into environmental issues promotes a more flexible, lower-
cost alternative to government regulation. The idea is not to eliminate regulation altogether, but to make
the system more effective and less obstructive. Moreover, positive incentives are especially important
and can turn the environment from a collective liability into an asset for an owner.51
Capitalism and economic growth are frequently cited as the main reasons for environmental
degradation. While there may be some support for this claim, it is very misleading. First, with 7.6 billion
people on the globe, humans will unavoidably leave an environmental footprint. Second, capitalism
leverages competitive markets, and markets have led to amazing gains in efficiency, innovation, and
wealth. They enable people to innovate and develop better solutions for many of the problems we face.
These creations drastically boost efficiency in many arenas, making for a more productive society that
can do less with more, a cleaner environment, and consistent economic growth. Third, economic growth
and environmental quality positively correlate once income reaches a certain point, known as the
environmental Kuznets Curve. Studies find that environmental degradation occurs initially, but as
incomes rise, societies reach a “turning point” and environmental quality starts to rise with income.52
Most significantly, despite claims to the contrary, economic growth and increased wealth and prosperity
have historically been linked to better environmental conditions and awareness. History proves the most
successful means to generate economic growth is the free market. Although there is an “initial
degradation of the environment as economic growth occurs, environmental quality eventually increases
with income.”53 Richer, more developed countries have much cleaner environments than poorer ones.
This can be seen in the U.S., where greenhouse gas emissions declined by 14 percent from 2005 to 2017,
according to the EPA, even though economic growth expanded and emissions in other countries have
increased. In fact, the U.S. “leads the world in energy-related carbon dioxide emission reduction since
2005” and “U.S. economic growth in 2017 was 29 percent less carbon-intensive” than 2005 levels.54 This
is largely attributable to advances in technology and energy efficiency, brought on by economic growth,
market incentives, and private sector innovation.
In short, a developed nation like the U.S. has the luxury of being able to care about the environment
compared to poorer, less-developed countries, where citizens may simply be wondering how to put food
on the table for their families.
Five Key Policy ProposalsFive Key Policy ProposalsFive Key Policy ProposalsFive Key Policy Proposals With the above core principles in mind, our plan for revitalized environmental conservationism involves
five central policy proposals.
1.1.1.1. Embrace cleaner energy and continue to nurture energy innovation.
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2.2.2.2. Strengthen private property rights to promote environmental stewardship.
3.3.3.3. Recognize private sector leadership on environmental conservation.
4.4.4.4. Expand the system of green bonds to help finance energy innovation.
5.5.5.5. Unleash the private energy sector by continuing and expanding the Trump administration’s
strategic deregulatory efforts.
Embrace Embrace Embrace Embrace Cleaner EnergyCleaner EnergyCleaner EnergyCleaner Energy and Energy Innovationand Energy Innovationand Energy Innovationand Energy Innovation Embracing cleaner energy and continuing to foster energy innovation is important. This means both
expanding wind, solar, and nuclear power development and accepting cleaner fossil fuels. And it is necessary that this transition doesn’t neglect the economic importance of the existing fossil fuel industry,
which keeps energy costs low, employs millions of Americans, and contributes significantly to economic
growth.
The energy and energy efficiency sectors play a vital role in the American economy. According to the
2019 USEER Report, in 2018, 59 percent (1.2 million) of the nearly 2 million workers in the Electrical
Power Generation and Fuels sectors were employed in traditional oil, natural gas, and coal industries.55
Another 611,000 Americans were employed in zero emissions generation (renewables and nuclear) and
189,000 were in low-carbon emission technologies (biofuels, low emissions gas). Put differently:
625,369 Americans are employed in the natural gas industry, with natural gas employment in
Electrical Power Generation rising by over 5,200 jobs to 113,000;
197,418 Americans work in the coal industry;
799,531 Americans are employed by the petroleum industry;
72,146 Americans work in the nuclear industry;
242,000 American workers spend most of their time on solar energy;
111,000 Americans are employed at wind energy farms; and
“the traditional energy and energy efficiency sectors continued to outperform the economy as a
whole, adding 152,000 new jobs.”
The report also finds that, in 2018, 2.35 million Americans were at least partially engaged in designing,
installing, and/or manufacturing energy efficiency products and services. This number was up by 76,000
from 2017. And more than 2.53 million Americans are employed in the motor vehicles sector (excluding
dealerships and retailers), 74,000 more for the year 2018. Among those workers, nearly 254,000 worked
with alternative fuel vehicles – up almost 34,000 from the prior year – and 486,000 employees are
involved in creating vehicles with greater fuel efficiency.
Energy is a high-paying sector. The average wage for an oil and gas worker charts in at $25.80 per hour.
This industry offers high-paying, blue collar jobs, and Millennials make up a sizable proportion.56 Bureau
of Labor Statistics data show that the average industry worker nationally earns nearly $50,000 more than
the typical 2016 worker across all industries. The Millennial Generation constitutes 34 percent of total
employment in the oil and gas industry (when petrochemicals are included) – a number expected to grow
to 41 percent by 2025. Even more, “Millennials account for 46% of all industry employment in unskilled
blue-collar occupations and 42% in semi-skilled blue-collar occupations.”57 In 2016, 45 percent of hired
Millennials were members of a minority group.
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Similarly, while “clean energy” jobs lag in number compared to the traditional energy industry, they also
offer exciting, good-paying opportunities for workers. According to the Brookings Institution, the
average national wage is $27.25 – more than $3.39 above the national average of $23.86 an hour.58
A large shift in energy use from coal to natural gas has taken shape in the last decade – resulting in
cleaner, affordable energy and a large reduction in carbon emissions. This change has been driven by
voluntary action and technological advancements that have increased natural gas production and supply.
While the switch mainly results from market forces and not government mandate, government policies
have made coal more expensive, artificially exacerbating the move away from coal production.
According to the EIA, natural gas is now the largest source of electric power generation in the U.S.,
representing 31.7 percent of the total.59 Coal has dropped from its dominant position of supplying
roughly half of all U.S. power generation to 30.1 percent. Nuclear accounts for 20 percent, and renewables
have been slowly trending upward to represent 17.1 percent of the total U.S. electricity generation.
Natural gas emits about half as much CO2 as coal and 30 percent less than oil; thus, the shift has helped
reduce U.S. greenhouse gas emissions significantly.60 In fact, power-plant carbon emissions are at their
lowest level in 30 years despite increased economic and population growth. As electricity generation is
the largest source of U.S. CO2, the market-driven shift to natural gas contributed to the 22.5 percent cut
in U.S. carbon emissions from 2006 to 2016.61 A climate advocacy group, Climate Brief, found that natural gas was responsible for 33 percent of the emissions reduction, with wind energy and solar energy
accounting for 19 percent and 3 percent, respectively.62
EIA data amplifies this point. In a February 2018 report, the agency noted the following:63
Total U.S. emissions reduction is estimated to be 14 percent from 2005 to 2017.
From 2005 to 2017, coal-related emissions declined by 39 percent and petroleum-related emissions dropped by
11 percent. Natural gas emissions rose 24 percent – but that’s a net 25 percent decrease in emissions generated
from fossil fuels.
EIA’s conclusion: “The underlying energy consumption trends that resulted in these changes – mainly because
more electricity has been generated from natural gas than from other fossil fuels – have helped to lower the U.S.
emissions level since 2005 because natural gas is a less carbon-intensive fuel than either coal or petroleum.”
While wind and solar energy are largely cleaner than natural gas, the energy can only be utilized part of
the time as sunlight and wind are highly variable. Until a method to store solar and wind energy
efficiently and in large quantities is developed, this will continue to be the case. Natural gas, however, can
be used 24 hours a day, 7 days a week, and can readily support our ongoing energy demand. Because of
this, the Brookings Institution estimates combined-cycle natural gas turbines cut 2.6 times more
greenhouse gas emissions than wind and four times more than solar.64
Innovations in horizontal drilling and hydraulic fracturing (fracking) have made it easier and cheaper to
obtain natural gas, enhancing efficiency and driving down overall energy prices. Lower energy prices
have greatly benefited consumers, boosting purchasing power and bolstering economic growth.
Unfortunately, many politicians and environmental groups have called for steep taxes or outright bans
on fossil fuel production in favor of advancing solar and wind energy. But banning natural gas will
squeeze working Americans and make it harder to realize the tremendous gains in CO2 reduction we've
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seen over the last decade. Moreover, as of September 2019, the U.S. is now a net exporter of both natural gas and oil. 65,66 This not only offers opportunities for job creation and won America its long-awaited
energy independence – strengthening our national security – but sales of American-produced natural
gas across the globe will help reduce carbon emissions in other countries.
This is essential given the expansion of coal-based energy production overseas. As the Manhattan
Institute’s Jonathan Lesser notes:67
Three decades ago, coal-fired power plants produced 38 percent of the world’s electricity or about 3,700
terawatt-hours (TWh) per year. Despite the growth in natural gas to generate power and the push for wind and
solar, by 2017, according to data published in the 2018 BP Statistical Review of World Energy, global coal-fired
electricity generation had more than doubled to over 9,700 TWh in 2017, with an increase in global
consumption that accounts for over 40 percent of total world generation. (By comparison, in 2017 total U.S.
electric generation was around 3,900 TWh from all generating resources.)
In the U.S., over the past decade coal-fired generation fell by a whopping 40 percent: from 2,000 TWh in 2007
to just 1,200 TWh in 2017. And that happened without a carbon tax.
But when it comes to meeting the world’s growing hunger for electricity, coal is still king. In 2017 alone, world
electricity generation increased by 630 TWh — more than the total combined electricity consumption of
California and Texas.
As countries increasingly electrify their economies, coal continues to be the resource of choice. Over the last
decade, coal generation increased by 1,500 TWh.
Realistically, the U.S. should encourage other countries – specifically those who are expanding their coal energy consumption – to purchase abundant U.S. natural gas. It makes no sense to ban or tax that
production into oblivion – especially when it is far more cost-effective and practical for other parts of the
world to use natural gas than to switch to wind, solar, or nuclear at this time.
Indeed, when it comes to exporting energy, the U.S. economy will benefit by continuing efforts to supply
developing countries with natural gas, rather than trying to export renewable energies such as wind and
solar. Renewables have three critical disadvantages compared to fossil fuels, and these hindrances render
renewables unlikely to become the standard power source in developing countries. They are capital costs,
plant operation models, and subsidization by developing nations.
Capital costs and fossil fuel subsidies are the biggest hurdles that renewables must get around. At the
same time, trying to dodge those obstacles and ship them across the world is an expensive endeavor. A
solar energy system in 2017, for example, cost a developing nation $2,000-$3,700/kw to construct and
operate. Meanwhile, a natural gas plant cost the same nation $1,000-$1,700/kw to build and run.68
Moreover, because developing countries save a lot by preferring fossil fuels, they can reinvest the savings
in other parts of their economies. A reinvestment for many developing nations – where government is
typically provides their energy – might be to offer fuel subsidies to make the cost of energy affordable to
the public. This allows for more citizens to use their earning to consume and thus grow the nation’s
economy.69
Finally, solar and wind plants operate on a decentralized model. This means that, for a solar or wind
plant to generate enough energy, multiple plants must be spread out – often in remote areas – to
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guarantee continual energy generation.70 To do this, developing nations must have advanced
infrastructure to enable high capacity batteries, a modern power grid, and transmission lines capable of
crossing vast distances. These are very expensive, long-term investments that take time to progress;
hence, many developing nations still prefer centralized plants like coal, oil, and natural gas.
Whether here at home or abroad, the economics overwhelmingly support natural gas because it is a low-
cost, efficient, and abundant energy source – and much better for the environment than coal. We should
embrace it more as a cleaner fuel source and encourage other nations to follow suit.
Strengthening Private Property RightsStrengthening Private Property RightsStrengthening Private Property RightsStrengthening Private Property Rights Recall our earlier discussion about property rights and the distinct role they play in providing meaningful
incentives for property owners to conserve the environment and be good stewards of natural resources.
This allows society to avoid the tragedy of the commons. Policymakers should examine ways to fortify
and expand the role property rights play in environmental conservation, such as what follows.
First, we should all acknowledge the superiority of a property rights-based approach to “political
conservation” managed by the government. As Case Western Reserve University professor Jonathan H.
Adler has argued, the latter “often generates a zero-sum game in which only the most popular initiatives
receive funding” while “private property empowers forward-looking conservationists to pursue
unpopular ecological causes.”71 He goes on:
At the turn of the last century, groups such as the National Audubon Society were able to use private property
to protect threatened species habitat at a time when there was no political support for government action…In
a similar fashion, a handful of individuals saved the bison from extinction on the western plains at a time when
the federal government was subsidizing its slaughter. Were it not for these efforts, it is unlikely that there would
be any buffalo in Yellowstone National Park today.
Property rights need not be individuated to serve environmental goals. Collective entities, from conservation
groups to condominium associations, play an important role in conservation…There is no single property
arrangement that is appropriate for every resource, but this does not mean that the institution of property
ownership can be disregarded in conservation efforts.72
Second, governments at every level should refrain from expanding publicly-owned lands. Even more
importantly, the U.S. Department of Interior should categorically resist outside efforts to halt its ongoing sale of public lands or its efforts to open up public lands to private development. As is widely reported,
Secretary David Bernhardt is leading the most significant reduction in federally-owned land to date.73
While some are dismayed by the Trump administration’s efforts here, we are encouraged. The U.S.
government already owns approximately one-third of all land in the country. This total is approximately
640 million acres, only 80 million of those acres constitute the country’s 419 national parks, and while 7
percent of the total exists east of the Rockies, the other 93 percent is in just 12 western states.74 Federal
lands are managed inefficiently, encourage expensive courtroom litigation and bureaucratic
mismanagement, and squander any room for creativity when addressing environmental problems.
Even more, they are like quicksand for taxpayers when it comes to the value and money lost on these
lands. “According to the Property and Environmental Research Center, the Forest Service and Bureau
of Land Management lost $4.38 per acre from 2009–2013, while trust lands in four western states earned
$34.60 per acre. The National Park Service alone has $11.6 billion in deferred maintenance and another
$2.6 billion in ‘critical or serious deferred maintenance,’ including building repair, water and wastewater
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systems and trails. And while fewer fires start on federal land, they cause more damaged acreage for lack
of actively managing forests. This cost taxpayers a record $3 billion in 2018.”75
Contrary to popular belief, privatizing public lands is a surefire way to promote innovative
environmental solutions. As David J. Theroux of the Independent Institute explains:
[P]rivatization would have produced complete resolution of the problems of land mismanagement found with
BLM, USDA, and other federal agency involvement. The enormous contrasts between the quality of
management observed on private lands and that observed on non-private lands – whether federal or state –
proves the point. There are no clear-cutting, depletion, or soil erosion problems in Boise Cascade or other
private forests. Similarly, there are precious few overgrazing problems on private ranches.
Privatization of western lands would also solve a seldom mentioned but very real problem – the United States’
dependence on unreliable foreign sources of essential minerals such as columbite, strontium, titanium,
manganese, chromite, and cobalt. An extremely high percentage of mineral-rich land is in the public domain
and effectively locked away from exploration and development. In private hands, sudden needs would be
reflected in market prices signaling demand for production of vital minerals.76
Moreover, as the Heritage Foundation’s Katie Tubb observes:
More state and private management of currently federal lands would put these assets and responsibilities in the
hands of people who have an immediate stake in wise management. It would also give local communities
greater say in decisions that directly impact their livelihoods. As it has elsewhere, this could allow for creative
compromises between varied and sometimes competing interests to better reflect the unique circumstances,
histories, and priorities of states. America would benefit from the innovation and experimentation in state
policies.77
Third, property rights should be expanded to new areas that may have been previously off-limits to
private entities. Such expansions should follow historical precedents like water rights:
For decades, many western states only recognized property rights in water that was used for irrigation, drinking,
or another productive use. Leaving instream water flows to enhance fish habitat was not deemed a productive
use and could not be advanced through private market transactions. Over time, however, states such as Oregon
have begun to recognize property rights in instream flows to various degrees. Today, local environmental
groups such as the Oregon Water Trust purchase instream flows from farmers to improve salmon habitat. This
approach can be more cost-effective, and certainly less contentious, than pushing to tighten regulatory
restrictions on water use. This institutional change has facilitated greater conservation by expanding the
definition of property rights to encompass environmental values.78
Fourth, policymakers should guarantee that property owners are compensated in order to improve
efforts at environmental conservation. It is widely understood that private lands are heavily regulated by
federal, state, and local governments in order to achieve environmental objectives. Oftentimes, such
regulations are intended to “limit or constrain development and other productive land uses, and can have
a significant effect on land values. So long as a given regulation, by itself, does not cause a ‘total wipeout,’
however, a landowner is unlikely to be compensated for her loss.” 79 And yet research demonstrates that
“failing to compensate private landowners for the costs of federal land use controls discourages voluntary
conservation efforts and can encourage the destruction of environmental resources on private land.”80
Furthermore, when a property owner is severely restricted by regulation in how that property can be
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used, and is not compensated for the costs that result, tensions (and lawsuits) will develop. This makes
sense: when regulations limit the use of a piece of property, they detract from its value. Moreover, “failing
to require compensation means that land use regulation is ‘underpriced’ as compared to other
environmental protection measures for which government agencies must pay. This results in the
‘overconsumption’ of land use regulations relative to other environmental protection measures and less
effective environmental policies. Taken together, these effects suggest that uncompensated regulatory
takings are themselves a threat to greater environmental protection.”81
Property owners should receive just compensation from any level of government. That compensation
could, for example, come in the form of direct cash reimbursements or property tax credits, in an amount
that would make up for the costs of meeting the mandates or for the lost income or property values that
would otherwise have been generated if not for the restrictions. In its recent decision in Knick v. Township of Scott, Pennsylvania, the U.S. Supreme Court affirmed the right of property owners to
recover takings (financial losses) from local government regulations in federal court.82 This means that,
in accordance with the Fifth Amendment to the U.S. Constitution, mineral rights owners, such as those
with water or oil well rights, can petition a federal court for payment by local and state governments for
their lost property values. Such an approach is critical to providing property owners with adequate
incentives to conserve and make the most effective use of natural resources. It should also apply to
situations like fisheries, forests, ecotourism, endangered species protections, and countless other uses.
Recognize Private Sector Leadership andRecognize Private Sector Leadership andRecognize Private Sector Leadership andRecognize Private Sector Leadership and InnovatioInnovatioInnovatioInnovationnnn Absent government direction and in response to consumer demand, more private companies are driving
environmental sustainability. This is often underrecognized in the climate change conversation because
the consensus is that centrally-planned solutions are the key. But it is crucial to acknowledge this
development and realize the free market’s potential to reduce our environmental footprint.
Millennials’ environmental conscience has tremendously impacted private companies and is sure to
drive firms’ behavior in the future, pushing them to make a positive impact on the world. In this way,
companies – not executive branch fiat or congressional legislation – are leading the way on
environmental conservation, a much more efficient and effective approach.
The Millennial Generation is now the largest in America and the most environmentally-conscious
generation today. A recent Pew survey found that 81 percent of Millennials – more than any other
generation – correctly believe there is solid evidence the earth is warming.83 In addition, a survey by the
Shelton Group found that Millennials worry about the environment more than other American
generations, with 76 percent saying they are “somewhat to extremely concerned about the impact climate
change will have on their quality of life during their lifetimes,” compared with 51 percent overall.84
This is encouraging. Unfortunately, most Millennials have been taught that the only approach is the
tried-and-failed, government-knows-best one. Even worse, public discussions about climate change tend
to neglect the opportunities afforded by private companies and the free market.
Millennials’ market influence drives the sustainable brand revolution due to their intense attention to
the environmental impact their purchases involve. According to a recent survey, 70 percent of Millennials
said a company’s environmental practices have the largest impact when they’re deciding which products
to purchase.85 And a 2016 Deloitte survey found, “A motivational trifecta of environmental sensitivity,
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practicality, and affordability is driving residential consumers and businesses to find ways to utilize more
renewables and expand energy management practices…The report highlights the increasing influence of
millennials aged 21-34, the largest and most dominant consumer group, as a dynamic force behind the
shift to cleaner sources of energy – inspired by the desire to reduce their personal carbon footprints.”86
Importantly, the market has responded with companies such as Whole Foods87, Procter & Gamble88,
Toyota89, and Walmart90 working to improve their sustainable practices. Ridesharing companies like
Uber and Lyft are popular among Millennials and are leading the way in environmental sustainability.
Lyft is voluntarily working to offset the carbon emissions of every ride on their platform around the
world.91 This is in addition to its “climate impact goals,” which state the company’s intention to have all
their electric autonomous vehicles powered by 100 percent renewable energy, provide at least 1 billion
rides per year using electric autonomous vehicles by 2025, and reduce CO2 emissions for the U.S.
transportation sector as a whole by at least 5 million tons per year by 2025.92
According to the EPA, the transportation industry is the largest contributor of greenhouse gas emissions
in the U.S., accounting for 28.5 percent the total in 2016.93 To move toward environmental sustainability,
reducing emissions in this sector could have a profound impact.
Given that ridesharing often provides a cheaper and easier-to-use service compared with vehicle
ownership, it decreases the number of vehicles on the road. A study by the University of California at
Berkeley found that each carsharing vehicle in use replaces on average 9 to 13 vehicles.94 With fewer
vehicles on the road, air pollution is improved. The same study found this reduction in vehicles leads to
a residual greenhouse gas reduction per household per year of 34 to 41.
This exemplifies the market at work and how there is no real need for government direction. Companies
are taking note of consumers’ demands and changing models because it is in their interest to do so. Concern for the environment isn’t going away, and customer awareness will influence consumer buying
behavior even more. This will keep driving change in corporate America and help conserve our
environment not through government, but through market forces and the profit motive.
Grow the Green Bonds MarketGrow the Green Bonds MarketGrow the Green Bonds MarketGrow the Green Bonds Market Green bonds offer a great opportunity for joint private- and public-sector approach to fostering a cleaner
and more sustainable nation. This innovative source of financing gives investors the chance to capitalize
on the growing green energy industry and have a positive impact on society. Millennials, among other
generations, are more conscious of their environmental impact. With most Millennials now well into
their careers, many will become conscious of the environmental impact of their investment assets,
helping to fuel the demand for sustainable investments.
Green bonds are essentially fixed income instruments that provide funding for projects related to
renewable energy, pollution prevention, and conservation, as well as other sustainable infrastructure
projects.95 Both public and private entities can issue green bonds to help them fund these projects, and
institutional investors can allocate capital to them. From 2008 to 2018, $521 billion in green bonds were
issued by institutions and governments around the world, and forecasts for 2019 are for $250 billion,
according to a Climate Bonds Initiative report.96 The U.S. was the top country for green bond issuance in 2018, and the largest issuers were financial corporate and non-financial corporate entities.97
Ultimately, the large and growing green bond market offers an ample and innovative incentive to meet
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investors’ drive for profit and the need for a more sustainable environment for the population.
Continue and Expand DeregulationContinue and Expand DeregulationContinue and Expand DeregulationContinue and Expand Deregulation One of the basic steps policymakers must undertake is a robust and strategic deregulatory effort that
dwarfs what even the Trump EPA has already accomplished under Administrator Andrew Wheeler and
former Administrator Scott Pruitt. By unleashing an all-of-the-above energy industry revolution from
onerous regulations, natural market forces will continue to shrink our environmental footprint.
As Emily Folk wrote for Renewable Energy Magazine:98
In states with customer choice, people can shop around for energy suppliers, rather than having one option for
everyone. That means they can switch to a new company if they find a better price. Deregulation also empowers
alternative energy suppliers to enter the market. These suppliers can offer 100 percent renewable energy options
to customers. These options are often more expensive than buying standard utility electricity, but some may
choose it to reduce their environmental footprint and support the renewable energy market. The idea is that
markets that offer consumers a choice give them a chance to vote with their wallets. This increased participation
in the renewables market will help the clean energy sector grow and help customers live greener lifestyles.
As Folk notes, laws and regulations could require firms to “take these steps, but these routes are often
less efficient than letting the market work.”99 It is also important to note that regulations almost always
benefit the large corporations and punish the smaller entrepreneur, who is obligated to clear a high bar
even if that bar adds no tangible environmental benefit. That is, it presents a higher barrier to entry for
newer and smaller enterprises, thereby making it much more difficult to start or build a company and
compete against larger competitors. This helps explain why Big Oil opposes the Trump EPA’s efforts to
ease methane regulation,100 or a company like General Motors would publicly embrace stricter federal
electric and zero-emission vehicle standards.101
With all this in mind, a robust deregulatory agenda should benefit all forms of energy production, but
especially wind, solar, nuclear, and natural gas. It must engage federal, state, and local governments.
Letting Wind Energy Soar Wind energy production holds tremendous promise for the U.S. It is already one of the fastest-growing
sources of electricity, having doubled capacity since 2010 and now capable of meeting “the average
electricity needs of 30 million households.”102 Unfortunately, wind energy’s potential to soar to new
heights is being held back by regulatory challenges.
According to industry group Windustry, there are two obstructive layers of regulation.103 First, in some
states, “one or more state agencies have siting responsibilities for wind developments.” Thus, wind energy
producers must be approved by state-level agencies. Moreover, local planning commissions, county
boards, zoning boards, or city councils often have primary jurisdiction over windmill authorizations.
Second, “a number of federal agencies [are] likely to be involved in permitting any wind project.”104
Depending on the circumstances, any one or more of these federal agencies may be involved: Bureau of
Land Management, United States Forest Service, Bonneville Power Administration, Western Area Power
Administration, Federal Aviation Authority, United States Fish and Wildlife Service, agencies
implementing the National Environmental Policy Act, and/or the Army Corps of Engineers. Plus, a wind
energy company will need to file for permits like the National Pollutant Discharge System permit and
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have a communications tower search conducted through the Federal Communication Commission.
This process will likely require studies before approval is granted.
Windustry cautions that “a building permit fee…can amount to $5,000-$10,000 per turbine. The cost to
hire consultants and complete the required studies can range from $5,000-$50,000 for a single turbine
project.”105 This regulatory process is arduous, costly, and time-consuming from start (when determining
which agencies must give their blessing) to finish (when getting the permits to construct), especially for
smaller companies that may face a higher barrier to entry as a result.
Therefore, one key to expanding wind energy production is not a new line of direct subsidies or tax
credits. Instead, these agencies – or at least their authorities over wind power authorization – ought to
be consolidated, the permitting process must be streamlined, and regulatory reductions must be
undertaken to generate more wind energy production. Federal and state policymakers should take cues
from Texas, where deregulation greatly contributed to the ascendance of wind farms. “[N]ational and
even global companies [were] drawn to the state by its Wild West power-generation atmosphere with no
regulatory agency, no permitting and no wind laws.”106
Brightening the Prospects for Solar Energy The potential to harness the sun’s energy and put it to use is both widely understood and increasingly
being utilized across the country and around the globe. We’re now at the point where neither technology
nor funding holds back solar energy implementation. In the past few years, solar power has been catching
on, creating more jobs, and getting progressively more affordable. Now, solar photovoltaic-generated
electricity is in many cases even more affordable than grid electricity.107 The technology is also where it
needs to be for meaningful implementation. Unfortunately, a driving force preventing solar from fully
realizing its full potential are regulatory hurdles. Many of these obstacles for solar power are local in
nature. In particular, “[z]oning laws, licensing requirements and price controls are all factors that can
impact customers' ability to install their own clean energy resources.”108
According to a study by Michigan Technological University Associate Professor Joshua M. Pearce and
his colleagues, outdated regulations cost the solar energy market roughly $70 billion more than costs
would otherwise.109 We agree this red tape ought to be cut back substantially. Pearce identifies plug-and-
play solar photovoltaic systems as one key aspect of the industry that ought to be unbound. These systems
are “affordable (you buy one solar panel at a time for a few hundred dollars) and portable solar electric
systems that tie into the electric grid. They can be installed on a porch or backyard by an average person
with no training, and they can be transported from home to home.”110 Potential savings for the “prosumer
(producing consumer),” Pearce notes, would offer “approximately $13 billion/year in cost savings, which
would be expected to increase by about 3% per year over the year lifetime of the systems.”111
Deregulating plug-and-play solar systems – along with a robust reevaluation of zoning laws, licensing
requirements and price controls – is critical to helping further unleash solar energy production.
Releasing Nuclear Power’s Potential Those who genuinely wish to shrink our carbon footprint should fervently support nuclear power
expansion. MPC’s recent report, “Restoring the Promise of Nuclear Energy in America: How to Unleash
America’s Nuclear Power Potential – And Why We Must,” explores this in great depth.
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As we note in that paper, nuclear power’s potential is tremendous.
All current Generation (Gen.) II and III+ light-water reactors (LWRs) and heavy-water reactors (HWRs) emit
only one type of exhaust during the nuclear process: steam. Heat from the reactor core is turned into steam to
power electrical generators. Then the steam is emitted from the plant via exhaust vents. The visible steam is
what gives off the impression that the reactor is “emitting” something into the air. However, it is harmless water
vapor. Environmental groups claim the nuclear process and the refining process are the same, but they are not.
As the USEIA explains, “Nuclear reactors do not produce air pollution or carbon dioxide while
operating…However, the process of mining and refining uranium ore and making reactor fuel all require large
amounts of energy.”
As for other environmental benefits of reactors, reactors do not have to alter the existing ecosystem to fit the
plant. On the contrary, if a hydro-electric dam is built, there must be physical manipulation of the surrounding
landscape and water biome. This can cause eroding carbon sinks, depriving ecosystems of water nutrients, and
increasing water tables of which, if flooded, could cause extreme risk to towns and cities downstream. Another
benefit afforded by reactors is that nearby residents do not have to worry about harmful chemicals being
released into the air and the environment when making facility upgrades. Contrary to popular perception, solar
panels must use toxins such as lead and cadmium (a known carcinogen) in order to capture the energy from
the sun. If a panel is cracked or broken, these toxins, if released into the air, can cause medical harm as well as
environmental damage to the surrounding area.112
There is a popular belief that the high costs of constructing a nuclear power plant is the most prohibitive
thing keeping new ones from being built beyond the 99 currently-active plants. As our paper found, this
is incorrect. The main obstacle is regulatory: The Nuclear Regulatory Commission (NRC) – which
oversees nuclear power in the U.S. – “does not like to implement new reactor technology other than
[outdated reactor types] LWRs and HWRs, it does not allow much state or private construction oversight,
and its licensing process is too slow and inefficient.”113
America already has some of the strictest safety guidelines in the world, and the chance of a meltdown is
very small. There’s a reason France has implemented nuclear power so widely. American policymakers
need to relax the NRC’s tight grip on nuclear power generation. As our previous paper underscores,
there are three primary steps to accomplish this. First, the NRC needs to make it easier to develop and
implement new reactor technology, lest the U.S. persist in falling behind China, Britain, France, and
other countries. Second, policymakers must loosen the NRC’s regulatory grip and allow state and private
entities to provide oversight of nuclear power generation and have a greater role in the licensing process.
Third, the NRC’s supremely-expensive, outrageously-excessive, and time-consuming licensing process
must be retooled and streamlined to make nuclear power generation easier to accomplish.
Unleashing Natural Gas As noted earlier, the EIA has concluded that U.S. emissions levels have been gone down significantly
since 2005 “mainly because more electricity has been generated from natural gas than from other fossil
fuels.”114 Not only is natural gas relatively cheaper to produce than most forms of energy, but it is cleaner
than traditional fossil fuels and more easily and affordably transported and implemented on a national –
and global – scale than wind and solar. And contrary to popular belief, numerous studies show hydraulic
fracturing (“fracking”) has become safer over time for both the environment and for human beings.115
Unfortunately, natural gas production – generally done through fracking – is under attack in states across
the country. In Colorado, for example, the Democratic legislature passed SB19-181, signed into law by
Governor Jared Polis.116 The law vastly expanded the power of the state’s chief regulator, the Colorado
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Oil and Gas Conservation Commission (COGCC), to control and restrict oil and gas development.
These limitations may be put in place regardless of whether they are “technically feasible” for industry to achieve if “environmental protection” is the goal. SB19-181 also authorized greater “local control” for
counties and municipalities seeking to enforce stricter regulations than the COGCC. (The law, however,
forbids local governments from setting standards below those of the COGCC.) Several Colorado localities have already established moratoriums on new production. SB19-181 – coupled with other
actions the legislature has taken that together constitute a “Green Little Deal” of sorts – is expected to
greatly weaken the state’s economy, in which oil and gas is a critical player.117
No matter the level of government – federal, state, or local – onerous and undue regulations should be
reduced, especially given that natural gas production has been instrumental in shrinking America’s
carbon footprint. It is worth mentioning that, in Colorado, oil and gas production has quadrupled since 2010, and it has become the nation’s fifth-largest natural gas-producing state.118 Despite this substantial
uptick in production, Colorado has decreased its overall greenhouse gas emissions. From 2010 to 2015,
it’s estimated that the state’s emissions fell from 133 million tons of CO2-equivalent to 127 million tons.119
The only way to secure such massive increases in fossil fuel production and simultaneously decrease emissions – however modestly – is through technological advancement accomplished by the private
sector. Constrictive laws like SB19-181 must be undone across the country. Moreover, as discussed
previously, policymakers need to understand that laying regulatory floors encourages companies to only
meet those floors and not go above and beyond.
Millennials get that environmental stewardship is a meaningful mission, environmental protection is a
worthwhile objective, and climate change is a legitimate concern worthy of being addressed. We
wholeheartedly agree. We also recognize that this objective cannot be achieved through expansive
government micromanagement schemes like the Green New Deal, a carbon tax, or a strict regulatory
approach. Rather, the evidence underscores why policymakers must undertake a different strategy.
The single most effective, practical, and affordable way to advance environmental conservation is by
strengthening private property rights to promote conservation leadership and enhancing private sector
innovation through a comprehensive deregulatory strategy. We strongly encourage policymakers to
reaffirm and fortify property rights, eliminate energy subsidies across the board to smartly level the
playing field, and expand and build upon the Trump EPA’s successful strategic deregulatory efforts with
a focus on an all-of-the-above approach. We cheer private sector businesses that continue listening to
consumers and innovate more to address environmental concerns, and we look forward to a brighter
future for ourselves and our planet.
Contact tContact tContact tContact the Millennial Policy he Millennial Policy he Millennial Policy he Millennial Policy CenterCenterCenterCenter 120120120120 To contact the Millennial Policy Center, please reach President and CEO Jimmy SengenbergerJimmy SengenbergerJimmy SengenbergerJimmy Sengenberger at 720-
316-1072 (office) or [email protected] (email).
CONCLUSIONCONCLUSIONCONCLUSIONCONCLUSION
Protecting the Environment Sensibly and StrategicallyProtecting the Environment Sensibly and StrategicallyProtecting the Environment Sensibly and StrategicallyProtecting the Environment Sensibly and Strategically
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ENDNOTESENDNOTESENDNOTESENDNOTES
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potential-for-renewable-20180921/. 99 Ibid. 100 The Editorial Board. “Explaining the Methane Rule Panic.” The Wall Street Journal, 30 Aug. 2019, https://wsj.com/articles/explaining-the-methane-rule-panic-11567205659/. 101 Barra, Mary. “General Motors CEO: We Call for Federal Electric and Zero-Emission Vehicle Policies.” USA Today, 26 Oct. 2018, https://usatoday.com/story/opinion/2018/10/26/general-motors-zero-emission-vehicle-electric-cars-
mary-barra-ceo-column/1760801002/. 102 Pressler, Mary. “2019 Outlook for the US Wind Power Industry.” Energy Central, 20 June 2019,
https://energycentral.com/c/cp/2019-outlook-us-wind-power-industry/. 103 Daniels, Lisa. “Chapter 6: Permitting Basics.” Windustry,
Page | 28
http://windustry.org/community_wind_toolbox_6_permitting_basics/. 104 Ibid. 105 Daniels, Lisa. “Chapter 8: Costs.” Windustry, http://windustry.org/community_wind_toolbox_8_costs/. 106 “Retiring Worn-out Wind Turbines Could Cost Billions That Nobody Has.” Energy Central News, 21 Feb. 2017, https://energycentral.com/news/retiring-worn-out-wind-turbines-could-cost-billions-nobody-has/. 107 Pearce, Joshua M. “Solar Is Being Held Back by Regulations, Not Technology.” Harvard Business Review, 15 Dec. 2016, https://hbr.org/2016/12/solar-is-being-held-back-by-regulations-not-technology/. 108 Folk, Emily. “Energy Deregulation Opening up Potential for Renewable Energy Future.” Renewable Energy Magazine, 21 Sept. 2018, https://renewableenergymagazine.com/emily-folk/energy-deregulation-opening-up-
potential-for-renewable-20180921/. 109 Mundada, Aishwarya S., Prehoda, Emily W., and Pearce, Joshua M. “U.S. Market for Solar Photovoltaic Plug-and-
Play Systems.” Renewable Energy, 2016. https://academia.edu/29941674/U.S._Market_for_Solar_Photovoltaic_Plug-
and-Play_Systems/. 110 Pearce, Joshua M. “Solar Is Being Held Back by Regulations, Not Technology.” Harvard Business Review, 15 Dec. 2016, https://hbr.org/2016/12/solar-is-being-held-back-by-regulations-not-technology/. 111 Aishwarya S. Mundada, Emily W. Prehoda, and Joshua M. Pearce. “U.S. Market for Solar Photovoltaic Plug-and-
Play Systems.” Renewable Energy, 2016, https://academia.edu/29941674/U.S._Market_for_Solar_Photovoltaic_Plug-
and-Play_Systems/. 112 Barness, Andrew, Dubbert, Jacob, and Sengenberger, Jimmy. “Restoring the Promise of Nuclear Energy in America:
How to Unleash America’s Nuclear Power Potential – And Why We Must.” Millennial Policy Center, Dec. 5, 2019,
https://millennialpolicycenter.org/wp-
content/uploads/2019/12/191205_MPC_PolicyPaper_Restoring_the_Promise_of_Nuclear_Energy.pdf/. 113 Ibid. 114 “U.S. energy-related CO2 emissions expected to rise slightly in 2018, remain flat in 2019.” U.S. Energy Information
Administration, 8 Feb. 2019, https://eia.gov/todayinenergy/detail.php?id=34872/. 115 “Studies Show Fracking Is Safe.” Coloradans for Responsible Energy Development, 4 Sept. 2019,
https://cred.org/studies-show-fracking-safe/. 116 “SB19-181: Protect Public Welfare Oil and Gas Operations.” Colorado General Assembly, 2019 General Session.
Signed April 16, 2019, https://leg.colorado.gov/Bills/sb19-181/. 117 Sengenberger, Jimmy. “How Colorado's Green Little Deal Is Set To Ruin The State Economy.” The Federalist, 4 Nov. 2019, https://thefederalist.com/2019/11/04/how-colorados-green-little-deal-is-set-to-ruin-the-state-economy/. 118 “Colorado - State Energy Profile Overview.” U.S. Energy Information Administration, 17 Jan. 2019,
https://eia.gov/state/?sid=CO/. 119 Woodruff, Chase. “Colorado's Major New Greenhouse Gas Report, Explained in Four Charts.” Westword, 17 Sept. 2019, https://westword.com/news/colorado-major-new-greenhouse-gas-report-explained-11408036/. 120 The Millennial Policy CenterMillennial Policy CenterMillennial Policy CenterMillennial Policy Center is a policy research, development, and education program (a think tank) whose
mission is to address public policy issues that affect the Millennial Generation (born between and including the years
1981 to 1998) and to develop and present policy solutions that advance the constitutional values of freedom,
opportunity, and economic vitality for Millennials throughout the United States. Our website is
MillennialPolicyCenter.org.
WWW.MILLENNIALPOLICYCENTER.ORG
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