Michael Waggoner (Colorado) has published Critique of U.S. House Bill 2454 on Climate Change, 2 Amsterdam L. Forum 61 (2010). Here is the abstract:
This article criticizes the recently-passed House Bill 2454 on climate change for:
(a) its harms to U.S. industries competing with competitors not subject to cap and trade;
(b) weakness of cap and trade as a control on emissions, based on overestimating the
effectiveness of SO2 limits and overstating the analogy between sulfur and carbon
oxide limitations;
(c) the often bad or limited effects of regulation and subsidies;
(d) the regressive impact of cap and trade.In each of these areas, a carbon tax would be simpler, more fair and effective, and less destructive.
This article concludes that where cap and trade has met with great resistance from the developing nations, they would have reason to accept a carbon tax. A carbon tax would boost their revenues, where cap and trade will place a drag on their economies. A carbon tax, imposed on imports and rebated on exports, would be simplified by eliminating the impose/rebate system on trade between nations with similar carbon taxes, thus giving developing nations an incentive to join the developed nations in imposing such a tax.




