You know the story. For over three years, Joe Biden’s critics repeatedly pointed out what should have been obvious to anyone paying attention that the guy wasn’t mentally with it. However, despite evidence steadily piling up supporting that conclusion, the President’s supporters insisted he was fine. Even great! A sycophantic leftist press corps eagerly went along with the make-believe…. And then came the debate.
Well, the Clean Heat Standard (aka Unaffordable Heat Act) looks like it’s about to have its Joe Biden Debate moment.
For three years, critics such as your humble author here have been repeatedly pointing out that this Rube Goldberg Carbon Tax (Copyright Dick McCormack) is unworkably complicated and that any attempt to implement it would be wildly, unbelievably, absurdly expensive. Pshaw! sneered its sponsors. Misinformation! cried the propagandists in the media.
But now, just days away from when the Public Utilities Commission is scheduled to pull the sheet off their draft plan for how this thing will work for all the world to finally see, Efficiency Vermont (who as the presumptive Default Delivery Agent in this scheme has presumably had a peek) submits eight-pages of comments and recommendations. We’ll get to the specifics in a moment, but here’s my translation of the gist: The Clean Heat Measure/Carbon Credit market will never work, and you need to scrap this whole thing and start over.
Their wording is, of course, more formal, phrased in politically delicate terms, and I’ll say it, painfully turgid, but here’s a key passage:
Efficiency Vermont can anticipate that such arrangements for transfer of credits will necessitate bilateral or potentially complex multilateral agreements between customers, the EEU, Distribution Utilities, contractors, installers, midstream dealers, and could even include upstream manufacturers. The complexity of these arrangements also give rise to concerns over the veracity of projects claiming credits and the rigor of their completion….
It is not intuitive nor technically defined how such a market is intended to work or benefit the suite of existing programs in practice throughout Vermont…. but without knowing how a credit is bought, sold, or traded via market process, Efficiency Vermont is unsure of the efficiency or efficacy of monetizing credits….
[I]n an unorganized and unregulated market where multiple entities hold credits (i.e., supply from existing parties), and multiple entities seek credits (i.e., demand from obligated parties), there are a seemingly infinite number of combinations that may result in obligated parties acquiring the appropriate amount of credits that is equal to their specific compliance obligation…. The risk of an unregulated market, therefore, is that while compliance may ultimately be achieved after several years, the buying and selling of credits itself becomes grossly inefficient, asymmetrical, and potentially more costly for all parties.
Yeah. Like I’ve been saying, it’s unworkably complicated, unverifiable, and crazy expensive for all concerned. And I’m going to steal “grossly inefficient” for future use.
Beyond that, it appears, reading between the lines, that given the complexity demanded by the legislature, the PUC has not actually figured out how to make it work. When Efficiency Vermont says things like, “Market formation to monetize and transfer ownership of credits is, therefore, a critical component that the Commission should consider in determining the draft rule,” the implication is the PUC hasn’t done so, and that is kinda problematic.
“Should consider” is too polite. “Shall” is what’s legally required. The Clean Heat Standard IS a carbon credit trading scheme based on turning clean heat measures into, as the law states, “a tradeable, nontangible commodity that represents the amount of greenhouse gas reduction attributable to a clean heat measure. The Commission shall [emphasis added]establish a system of management for clean heat credits pursuant to this chapter.” Without a working credit market, there is no program. Are we about to find out next week that the dog ate the PUC’s homework?
Efficiency Vermont’s memo isn’t all criticism of the law as it is written, they do have alternative suggestions. They are, option A, to scrap the idea of turning clean heat measures (actions like installing heat pumps or weatherizing buildings) into tradable carbon credits, and instead conduct auctions in which a set number of carbon allowances would be sold to obligated parties bidding on them. And option B, just implement a straightforward carbon tax on fossil heating fuels – which is what this #$^&*! thing is and has been all along!
And what to do with all that cash when it’s collected? Efficiency Vermont has a suggestion for that too: just give it to Efficiency Vermont! Which is also what this scam has been about all along.
So, I’ll offer option C. Scrap the whole thing, fire every legislator who voted for it, and replace them with lawmakers who will kill it for good.
Video Extras
Want a good laugh (or cry)? Check out members of the Technical Advisory Group tie themselves in knots trying to not call the Clean Heat fees fees. This is the gaslighting, folks!
And nice to see some members of the Equity Advisory Groups expressing some realism regarding the Unaffordable Heat Act. It’s too expensive, and Vermonters will have to turn to burning wood when this law makes heating fuels too expensive.
