To view the current sticker, click here. To see what the tut-tutting scolds at EPA and NHTSA want to replace it with, click here.

 Among other rationales for the new sticker design, the agencies claim that adding letter grades will help consumers make smarter purchases by combating something called the “MPG Illusion.”

The MPG Illusion refers to the common misperception that fuel savings from mpg increases are linear. People often assume that each additional 1 mile per gallon increase in a vehicle’s fuel economy reduces fuel consumption and gasoline expenditures by the same amount. Hence, some may conclude, if they can’t afford (or simply don’t want) a Toyota Prius, Chevy Volt, or some other high-mpg vehicle, there’s no point in buying a car with only modestly better fuel economy than their current vehicle. In reality, fuel consumption avoided and dollars saved decrease as mpg increases. Which is to say, the biggest fuel savings come from modest fuel-economy improvements in the lowest mpg vehicles. Some hypothetical (indeed fanciful) examples will make this crystal clear.

Suppose that your current car gets only 1 mile per gallon, you drive 100 miles per week, and gasoline costs $3.00 per gallon. This means you consume 100 gallons and spend $300.00 per week. If you replace that car with a 2 mpg vehicle, you’ll consume 50 gallons and save $150.00 per week. At the very bottom end of the scale, even a 1 mpg increase in fuel economy yields big savings.

Suppose now that your current car gets 99 mpg, you drive 100 miles per week, and gas costs $3.00. This means you consume 1.01 gallons and spend $3.03 per week. If you replace that car with a 100 mpg vehicle, you’ll consume 1 gallon and save 3 cents per week. At the very top of the fuel economy scale, the fuel and cost savings from an extra 1 mpg are negligible.

Turning to more realistic examples, EPA and NTSHA calculate (p. 28) that replacing a 10 mpg vehicle with a 15 mgp vehicle saves 33 gallons of gas for every 1000 miles driven whereas replacing a 30 mpg vehicle with a 35 mpg vehicle saves only an additional 5 gallons of gas for every 1000 miles driven. The same increase in fuel economy — in this case, an extra 5 mpg – saves more than six times as much fuel if the vehicle replaced gets 10 mpg rather than 30 mpg.

Professors Rick Larrick and Jack Soll of Princeton University put the MPG Illusion on the map when they published an article about it in Science magazine. They clearly explain the basic arithmetic in this Youtube video. Their illustrative case assumes a motorist who drives 100 miles per week. If the motorist has a 10 mpg vehicle and switches to a 20 mpg vehicle, he’ll cut his weekly fuel consumption from 10 gallons to 5 gallons — a savings of 5 gallons. If the motorist has a 25 mpg vehicle and switches to a 50 mpg  vehicle, he’ll cut his weekly fuel consumption from 4 gallons to 2 gallons — a savings of only 2 gallons.

“The key insight,” says Larrick, “is that improving inefficient cars, that have low mpgs, by even low mpg increases, saves a lot of gas.” Soll elaborates: “If you’re comparing two vehicles, one that gets 12 miles per gallon and the other that gets 15 miles per gallon, if you drive 10,000 miles in a year, you’ve saved about 170 gallons of gas [in the 15 mpg vehicle], and that comes out to be about $700.00 at $4.00 a gallon. So this [savings] is a significant amount even though the jump from 12 to 15 [mpg] may look pretty small.”

To counter the MPG Illusion, Larrick and Soll advise policymakers to express fuel economy in terms of the amount of fuel consumed per unit of distance traveled. Expressing fuel economy in the conventional way, as miles per gallon, leads people to “undervalue small improvements on inefficient vehicles” and “underestimate the value of removing the most fuel inefficient vehicles,” the researchers argue in Science magazine.

This, of course, is music to the ears of the anti-SUV crowd. Greenies would love to believe that the market for SUVs is sustained by an “illusion.” Because if that is so, then EPA and NHTSA can depress SUV sales just by making simple changes in how fuel-economy information is presented — just by redesigning the sticker! 

Years of SUV-bashing, fuel-economy prosyletizing, climate-change scaremongering, and high gasoline prices have failed to kill SUV sales. Could that have something to do with the attributes of the vehicles — their size, safety, and utility? I mean, there are objective differences between SUVs and cars greenies insist are “smart.” Just have a look! Nothing illusory about that.

If the MPG Illusion has anything to do with SUV sales, then you gotta ask: Who’s responsible for foisting the illusion on the public? Answer: the very people who’ve tried to brow beat us into believing that the only vehicle attribute worth considering is its mpg — the preachers and proselytizers of fuel economy! There’s no escaping the law of unintended consequences.

EPA and NHTSA  propose to combat the MPG Illusion in two ways. First, the sticker will estimate how many gallons of fuel the car will consume per 100 miles (as per Larrick and Soll’s advice). Second, the sticker will carry a letter grade.

Although the first option may counteract the MPG Illusion, the second will enhance it. As Larrick and Soll show, there is only a small difference in fuel savings between a 25 mpg car and a 50 mpg car. However, in the proposed EPA/NHTSA ratings (p. 37), the 25 mpg car gets a B and the 50 mpg car gets an A-. As anyone knows who has ever applied to college, an A- GPA is way better than a B GPA. The grading system implies that the biggest fuel savings are achieved at the top end of the scale.

On the other hand, a 14 mpg vehicle gets a C- whereas a 17 mpg vehicle gets a C. That 3 mpg increment is a big deal in fuel savings, according to Larrick and Soll. Yet how many car buyers will be impressed because a particular vehicle is rated C rather than C-? Except in jest, I’ve never met anyone who boasted of getting solid Cs in high school or college.

In short, the proposed EPA/NHTSA grading system perpetuates the MPG Illusion, which, unfortunately for fuel-economy zealots, cuts both ways. The illusion of linearity not only under-values savings from fuel-economy improvements in low-mpg vehicles, it also over-values savings from fuel-economy improvements in high-mpg vehicles.

EPA and NHTSA, apparently, want to manipulate the MPG Illusion rather than actually dispell it. They don’t like the illusion when (as they believe) it promotes SUV sales, but they like it when (as they hope) it promotes hybrid, plug-in hybrid, and electric vehicle sales. But the attempted manipulation fails, because the grading system, like the MPG Illusion, both over-values high-end mpg improvements and under-values low-end mpg improvements.

Grading cars actually means grading the people who buy them. People who buy cars with super-low or zero emissions are A or A+ people. Those who buy gas guzzlers wear dunce caps. The South Park spoof on the “Toyonda Pius,” Smug Alert, all-too-accurately depicts the greener-than-thou pretension of EPA and NHTSA’s proposed grading system.

The brief clearly lays out the absurdities of attempting to regulate greenhouse gases via common-law public nuisance litigation. Because global warming is, well, global, practically anyone on Earth could claim to be a victim. And because companies emit carbon dioxide (CO2) only as a byproduct of providing goods and services (electricity, cars, food, medical care, bites of information, etc.) to people, practically everyone on the planet could be sued as a contributor to the alleged injuries. In the memorable words of South Park’s hilarious global warming episode, Two Days Before The Day After Tomorrow, “We all broke the dam!”

In addition, the Obama brief points out that, “Establishing appropriate levels for the reductions of carbon dioxide emissions from power plants by a ’specified percentage each year for at least a decade’ (as Plaintiffs request), would inevitably entail multifarious policy judgments, which should be made by decision-makers who are politically accountable, have expertise, and are able to pursue a coherent national or international strategy — either at a single stroke or incrementally.”

Yet the brief stops short of reaching the obvious conclusion implied by its argument, namely, that climate policy is a “non-justiciable political question.” Instead, it advises the Supreme Court to direct the court of appeals to reassess its decision on “prudential” grounds. Rather than seek a decision that would preempt all future CO2 litigation, the brief instead seeks to put one particular CO2 lawsuit on ice.

I smell a rat. The Administration, I suspect, does not want the Court to rule that the political question doctrine precludes public nuisance litigation against CO2-emitters, because it wants the only solid, durable shield against litigation chaos to be the EPA’s “displacement” of common-law injury claims via the agency’s endangerment rule and the ensuing regulatory cascade.

Just as the Administration used the endangerment rule to try and spook Congress and industry into supporting cap-and-trade, it is now using CO2 litigation to try and spook them into supporting — or at least not aggressively attacking — EPA regulation of greenhouse gases via the Clean Air Act. 

In short, as I discuss in a column this week in Pajamas Media, the Administration needs to keep the prospect of CO2 litigation alive in order to sustain the ”greenhouse protection racket” — the strategy of regulatory extortion — on which warmists increasingly rely to promote their agenda.

The WSJ goes on to point out the obvious: “Currently the labels must show how many miles per gallon a car gets and its estimated annual fuel costs. Under the rules proposed Monday, new labels would carry a letter grade assigned by regulators.” Electric vehicles and hybrids would get the highest grades while big, heavy, gas-guzzling SUVs would get the lowest grades. “We think a new label is absolutely needed to help consumers make the right decision for their wallets and the environment,” explained Gina McCarthy, EPA’s assistant administrator for air and radiation.

“Absolutely needed” — as in, we’d be lost without them.

The proposed rules imply two judgments about Americans. One is that we’re too stupid to understand how miles-per-gallon and estimated annual fuel costs affect our wallets. Our math skills are so poor that quantitative information must be supplemented with letter grades labeling “this car good, that car bad.”

The second judgment, closely related to the first, is that Americans are school children and EPA/NHTSA are the Nation’s teachers. The agency folks apparently think that no matter how old we get, we still want to be teacher’s pet.

I propose an alternative rule — a “substantial” change in the titles of both agencies to ”School Marms R Us!”

Am I going to comment on the proposed rule? Maybe I’ll just submit a bumper sticker with the words: “Honk if you’ve outgrown school marms.”

In the paper, provocatively titled “Burning Water,” the Mulder team find that “the most water-efficient, fossil-based technologies have an EROWI one to two orders of magnitude [10 to 100 times] greater than the most water-efficient biomass technologies, implying that the development of biomass energy technologies in scale sufficient to be a significant source of energy may produce or exacerbate water shortages around the globe and be limited by the availability of fresh water.”

The Idsos note that these findings “will not be welcomed” by those who promote biofuels as a means of combating the alleged national security risks of global climate change.

We often hear, for example, that climate change will increase the risk of “water wars” by intensifying summer heat and drought. There’s not much evidence to support this alarm. About 90% of global fresh water consumption is for agriculture. As British scientist Wendy Barnaby found to her surprise when she set out to research a book about the coming “century of water wars,” nations in water-stressed regions typically do not come to blows but instead cooperate and import “virtual water” in the form of grain, leaving more water available for drinking and bathing. Even in the water-stressed, conflict-prone, Middle East, nations do not go to war over water. Nonetheless, to the extent that water stress undermines stability and peace, government policies ramping up biofuel production are likely a “cure” worse than the supposed disease.

In addition, some biofuel policies can increase food prices and world hunger, fostering instability and strife, especially if scaled up enough to make a meaningful difference in global carbon dioxide (CO2) emissions.  

Princeton researchers Stephen Pacella and Robert Socolow estimate that avoiding 1 gigaton (gt) of carbon emissions per year by 2050, by replacing gasoline with biofuels, would require 250 million hectares of high-yield energy crop planations, “an area equal to about one-sixth of the world’s current cropland.”

Let’s put this in perspective. One gigaton of carbon = 3.67 gt of CO2. Achieving the EU/UN emission stabilization target of 450 parts per million would require global CO2 emissions to decline roughly 38 gt below the baseline (business as usual) projection by 2050. In other words, the 3.67 gt reduction in CO2 that Pacala and Socolow say we can get via biofuels would achieve less than 10% of the reduction required to meet the target. Not a whole lot of environmental bang for all that land area buck. Indeed, dedicating 250 million hectares to energy crop production would likely squeeze many species out of their habitats.

Source: Stephen Eule, Scale and Scope of the Challenge to Reduce Greenhouse Gas Emissions, Institute for 21st Century Energy, U.S. Chamber of Commerce, February 2009

Note also that significant research indicates that converting grassland and forest land into biofuel plantations increases net greenhouse gas emissions over many decades by releasing the carbon stored in forests and soils. Growing biofuel on 250 million hectares of land might very well emit more CO2 than the gasoline it replaces.

The larger point, though, as Dennis Avery explains, is that the world is not well-fed now, and the demand for food and feed on farmlands is expected to more than double by 2050. Requiring biofuel production on 250 million hectares would be a recipe for disaster. Putting the equivalent of one-sixth of current cropland off limits to food production represents a much bigger decline in global agricultural productivity than is anticipated from drought in high-end global warming scenarios. 

Warmists warn that climate change is a “threat multiplier” or “instability accelerant.” However, the national security risks of climate change policy likely exceed those of climate change itself. 

For further discussion, see my CEI paper, DOD Should Consider the National Security Risks of Global Warming Policies, and economist Indur Goklany’s comprehensive study, Trapped Between the Falling Sky and the Rising Seas: The Imagined Terrors of the Impacts of Climate Change.

* When I first posted this, I failed to notice that Pacala and Socolow were measuring emission reductions in tons carbon whereas Stephen Eule was measuring reductions in tons CO2.

Few Republicans will be gulled by this line of chatter, but just to make sure, I posted a column debunking the Moler-Sharp argument on MasterResource.Org, the free-market energy blog.  

Republicans like markets (or say they do), and cap-and-trade is “market-based,” according to Moler and Sharp. In fact, cap-and-trade is politics-based. The demand for the traded commodity (the emission allowances) is entirely a creature of the cap, which is itself created not by the market but by politicians.

People posting comments on my column made astute observations, which suggest the following definition. Cap-and-trade: Government creation of a market in a commodity that everyone makes and nobody wants; from which a rent-seeking few gain windfall profits at consumers’ expense; and in which opportunities for corruption and creative accounting abound.

I used to think that we were just incredibly lucky that the alarmist movement was led by this group of second raters.   I now realize that it isn’t luck.  Global warming alarmism attracts incompetents, know-nothings, and looney tunes.

We have missed Al Gore in the debate, but luckily Kerry and Graham were fully up to sinking cap-and-trade in the Senate (not that it had much chance anyway) without any help from the leader of the forces of darkness. So it was good to see that Gore returned this week on a conference call sponsored by Repower America (aka the Alliance for Climate Protection).

Gore on the conference call acknowledged that cap-and-trade was dead and that the alarmists had lost in 2010.  He bitterly blamed the usual suspects: Big Oil, King Coal, right-wing media, and professional deniers (I believe that is where he would put me and CEI).  This is boilerplate nonsense.  Three of the big five oil companies (BP, Shell, and Conoco Phillips) support cap-and-trade, as well as most of the big electric utilities (Duke Energy, P G and E, Exelon, PNM Resources, Entergy, etc.) and many other major corporations, such as General Electric, Dow Chemical, General Motors, and Ford Motor.  Cap-and-trade died when the American people found out that it was a colossal transfer of wealth from them to corporate special interests (see the list in the previous sentence).

Gore even said that our system of government was not working as the founders intended it to work.  In fact, in the debate over cap-and-trade the system of checks and balances in the Constitution is working exactly as the founders intended.  It has prevented an elite from hijacking the economy for its own enrichment.

I can see why Gore is bitter.  His comparatively modest investments in green energy promised to make him a global warming billionaire if cap-and-trade were enacted. Unluckily for him, the American people have said no emphatically.

[This was originally posted on Politico's Energy Arena here.]

Unsurprisingly, sore losers are now calling for a change in Senate rules to abolish the filibuster or lower the number of votes required for cloture.

Congressional Quarterly Online reports that the BlueGreen Alliance, a coalition of labor unions and environmental organizations hawking cap-and-trade as a font of ”green jobs,” and a group of freshmen Democratic Senators led by Tom Udall of New Mexico, are calling for a change in Senate rules.

There’s just one small problem. It takes a two-thirds (67-vote) supermajority to change Senate rules. To belabor the obvious, two-thirds is more than three-fifths. If cap-and-traders were strong enough to change the rules, they wouldn’t need to change them — they could already easily overcome GOP filibusters.

If BlueGreenies can’t see what a pickle they’re in, they should try reading Aristophanes, the master of Greek comic poetry. 

Aristophanes’ play Ecclesiazusae, “Assemblywomen” or “Congresswomen,” is a ribald satire on egalitarian excess. Although written millennia ago, it is spot-on relevant in the Age of Reid, Pelosi, and Obama. 

As the play opens, a cabal of women led by Praxagora don fake beards, sneak into the Athenian Assembly, and agitate for a law to establish the rule of women. They gain the support of enough men to pull it off, because Athenians crave change and the rule of women is the only thing they have not yet tried.

Praxagora and her cohorts claim their agenda is to end all injustice, i.e., inequality. They set up cradle-to-grave welfare and institute a regime of free love in which every man may sleep with every woman.

To ensure that not even the natural assets of youth will be allowed to create inequality, Praxagora decrees that before a young man may sleep with a beautiful young woman, he must first sleep with an ugly old hag. Conversely, before a young woman may sleep with a stud, she must gratify a geezer. 

But, as Orwell was to observe centuries later, under socialism, some are more equal than others. Praxagora, you see, is married to a flatulent dotard named Blepyrus, so she has already done her duty to the elderly. She is now free to consort with as many young bucks as she pleases. It’s kinda like cap-and-trade, in which energy-rationing profiteers reap windfalls (regulatory rents) at public expense in the name of saving the planet.

To pass the Kerry-Lieberman bill, BlueGreenies would have to sneak into the Senate, don Republican disguises, and give Tom Udall and his pals a 67 vote super-majority.

Obviously, that’s not gonna happen, not this Congress or next, because fake beards only work in comedy.

If you are one of the hapless millions who watched Al Gore’s scare-you-mentary, An Inconvenient Truth, with its ad nauseum footage of hurricanes, tornadoes, drought, and floods, you might think that carbon dioxide emissions are making the world a more dangerous place.

Goks’ primer demolishes this falsehood. It also reaches the heretical conclusion that restrictions on carbon-based energy would actually impede progress in reducing deaths and death rates related to extreme weather.

Herewith a few excerpts:

Mortality Risk Declining

Based on 2000–08 data, extreme weather events are responsible for about 0.05% of all global deaths (31,700 deaths vs. 58.8 million, annually). That is, despite the media attention to such events, extreme weather events have a minor impact on global public health.

Long term (1900–2008) data show that average annual deaths and death rates from all such events declined by 93% and 98%, respectively, since cresting in the 1920s. These declines occurred despite a vast increase in the populations at risk and more complete coverage of extreme weather events.

Deaths and death rates from droughts were responsible for the majority (58%) of all deaths due to extreme weather events from 1900–2008. They also peaked in the 1920s. Since then, they have been reduced by 99.97% and 99.99%, respectively.

For floods, responsible for another 34% of aggregate deaths, deaths and death rates have declined by 98.7%–99.6% since the 1930s.

For storms (including hurricanes, cyclones, tornadoes, typhoons), responsible for 7% of extreme weather event deaths from 1900–2008, deaths and death rates declined by 47.0%–70.4% since the 1970s. 

“Blame” Fossil Fuels for Improving Safety

First, the decline in the death toll from droughts, in particular, is that global food production has never been higher than it is today (Goklany 1998, 2007). This is largely due to improved seeds, fertilizers, pesticides, irrigation, and farm machinery. This entire suite of technologies also enabled the Green Revolution.  But fertilizers and pesticides are manufactured from fossil fuels, and energy is necessary to run irrigation pumps and machinery. Without them, the benefits of improved seeds would be for naught. And in today’s world, like it or not, energy for the most part is synonymous with fossil fuels.

Additional CO2 in the atmosphere has also contributed to higher yields and food production (IPCC 2001: 254–257, 285) because it provides carbon, the basic building block of life, and also increases the efficiency with which plants use water helping offset declines in water availability, if any.

Another factor critical to reining food prices and reducing hunger worldwide is trade within and between countries which enables food surpluses to be moved to food deficit areas (Goklany 1995, 1998).  But it takes fossil fuels to move food around in the quantities and the speed necessary for such trade to be an integral part of the global food system, as it indeed is.  Moreover, fossil fuel dependant technologies such as refrigeration, rapid transport, and plastic packaging, ensure that more of the crop that is produced is actually eaten by the consumer. That is, they increase the overall efficiency of the food production system, which helps lower food prices and contain hunger worldwide.

The second important factor is better disaster preparedness, and more rapid response and delivery of humanitarian aid when disaster strikes.  Timely preparations and response are major factors that have contributed to the reduction in death and disease that traditionally were caused by or accompanied disasters from extreme weather events (Goklany 2007b).  Their success hinges on the availability of fossil fuels to move people, food, medicine and critical humanitarian supplies before and after events strike. 

Economic development also allowed the US (and other developed countries) to offer humanitarian aid to developing countries in times of famine, drought, floods, cyclones, and other natural disasters, weather related or not. Such aid, too, would have been virtually impossible to deliver in large quantities or in a timely fashion absent fossil fuel fired transportation.

Carbon Rationing Is Counter-Productive

Currently many advocate spending trillions of dollars to reduce anthropogenic greenhouse gases, in part to forestall hypothetical future increases in mortality from global warming induced increases in extreme weather events.  Spending even a fraction of such sums on the numerous higher priority health and safety problems plaguing humanity would provide greater returns for human well-being (Goklany 2009a, 2009b).

No less important, efforts to reduce greenhouse gas emissions would slow, if not retard, economic development and/or make fossil fuels scarcer and more expensive thereby militating against the very factors that have reduced deaths and death rates from extreme weather events.

Earlier, the Obama administration devoted $6 billion in taxpayer money to bailing out Greece, which ran into trouble because of generous pensions that let many occupations like hairdressers retire at age 50.

American workers are also suffering due to the stimulus package.  It is using taxpayer subsidies to replace U.S. jobs with foreign green jobs. It also destroyed thousands of jobs in America’s export sector.

Even more jobs will end up overseas if the Obama administration’s poorly conceived global warming legislation passes.

Reason magazine has an insightful article called “Five Lies About the American Economy.”

Today’s Climatewire (subscription required) features interviews with Exelon Corp. VP Betsy Moler and Phil Sharp, President of Resources for the Future, who lament that Republican lawmakers, the “inventors” of “market-based” environmental policy, have turned against their own “invention.” If I catch their drift, Moler and Sharp are trying to spin GOP opposition to cap-and-trade as self-contradictory, hence as unstable, hence as reversible. As Climatewire reports, Moler is not ready to “throw in the towel” and Sharp entertains the hope that a “new kind of coalition” will emerge in the next Congress.

Now, let’s look at this notion, peddled by Moler and Sharp, that Republicans betrayed themselves and besmirched their own legacy by blocking cap-and-trade. Here’s how it’s discussed in Climatewire:

In an interview, Moler said that her deep disappointment was the rejection by Republican leaders in Congress of a market-based strategy for raising the price of carbon emissions, to speed transitions by power plants, industry and consumers to cleaner energy.

The Democrats called it “cap and trade.” Republicans labeled it “cap and tax,” and the change in one word proved lethal.

“The thing that just amazes me, confounds me, surprises me is how successfully the Republican leadership and a lot of the people who would be potentially negatively impacted have been in vilifying what have historically been market-based solutions,” Moler said.

Inventors Turn on Invention

“Cap and trade is really a Republican instrument that grew out of a lot of the Republican thought leaders as a market-sensitive, market-friendly, anti-command-and-control mechanism” to reduce sulfur- and nitrogen-based air pollution in the 1990 Clean Air Act amendments. “Now, some of the same people who invented it have turned on it as an energy tax,” she said. “It’s a huge missed opportunity. I don’t know where you go next.”

Moler’sregret is seconded by Philip Sharp, president of Resources for the Future, who, as a Democratic House member from Indiana, stood with Moler in the 1990s in the energy deregulation campaign. Sharp was a pivotal factor in Congress’ adoption of the 1990 Clean Air Act amendments and the 1992 Energy Policy Act, which opened the way for FERC’s electricity market orders four years later.

“I’m not here to say cap and trade is the only way to do this,” Sharp said in an interview. “It worked magnificently with SO2 and a couple of other instances.” Scaling it up massively to deal with economywide carbon emissions is another question. “We don’t know we can manage it as effectively,” he said.

“But what is really unfortunate in the public debate is that the current Republican leadership has overthrown one of the great Republican successes in this country [under President George H.W. Bush], to capitalize on the flexibility of the marketplace” in achieving regulatory change, Sharp said.

“I don’t think people appreciate the extraordinary challenge that represented and the difficulty of getting it done” in the 1990s, he said. Now, with the demise of that approach, Congress has invited U.S. EPA to step in on the climate front “and regulate the living [daylights] out of everything and see how well a modern economy works doing that.”

Moler and Sharp miss several key points.

First, the Title IV acid rain cap-and-trade program enacted under President George H.W. Bush is not the “magnificent” success they suppose it is. As Kenneth Green, Steven Hayward, and Kevin Hasset of the American Enterprise Institute note, prices of tradable sulfur dioxide (SO2) emission permits have been highly volatile: “SO2 trading prices have varied from a low of $70 per ton in 1996 to $1500 per ton in late 2005. SO2 allowances have a monthly volatility of 10 percent and an annual volatility of 43 percent over the last decade.”

Second, utilities participating in the SO2 emissions trading program could meet all or part of their obligations by purchasing low-sulfur coal and/or installing scrubbers, a commercially-proven emission control technology. In contrast, there is no low-carbon coal, and no commercially-proven technology to “scrub” carbon dioxide (CO2) emissions out of power plant exhaust streams.

Third, unlike sulfur, which is an impurity or contaminant in coal and oil, carbon is intrinsic to the chemistry of fossil fuels. Consequently, whereas emission control requirements for SO2 do not logically entail an unlimited agenda aiming at total abolition of the fuel, emission control requirements for CO2 do imply abolition as the ultimate objective. Such extremism is reflected in the apocalyptic rhetoric of the global warming movement, in petitions demanding that EPA establish national ambient air quality standards (NAAQS) for CO2 at 350 parts per million and for other greenhouse gases at pre-industrial levels (not even a global depression lasting several decades would be sufficient to lower CO2 concentrations to 350 ppm), and in Al Gore’s campaign to “repower America“ with “zero-carbon energy” within “ten years.” More pertinently, pull-out-the-stops, sky-is-the-limit regulation lurks in the Waxman-Markey and Kerry-Lieberman bills’ escalator clauses, which all but ensure that the explicit emission reduction target (83% below 2005 levels by 2050) would be superseded by more aggressive requirements.

Fourth, just because a “market-based” approach is more efficient, in principle, than command-and-control regulation does not in any way obligate Republicans to support Waxman-Markey or Kerry-Lieberman if those same Republicans oppose all regulatory climate policies.

Fifth, every Republican in the Senate voted for the Murkowski resolution to block EPA regulation of greenhouse gases via the Clean Air Act. So it’s silly to say that Republicans “invited U.S. EPA to step in on the climate front ‘and regulate the living [daylights] out of everything. . .’” President Obama threatened to veto both the Murkowski resolution and the much weaker Rockefeller bill, which would merely postpone EPA regulation of stationary sources of greenhouse gases for two years. It’s the Democratic leadership, not the GOP, that has “invited” EPA to make climate policy through the regulatory back door.

Finally, Republicans betray themselves (ask President George “Read My Lips; No New Taxes” Bush) when they vote for rather than against higher taxes. Because carbon is intrinsic to the chemistry of fossil fuels, a carbon cap-and-trade scheme is a virtual broad-based energy tax. The same cannot be said of the SO2 program, which was merely a virtual pollution tax. Moler and Sharp would like GOP lawmakers to believe they can win elections by becoming the Party of Energy Taxes. Fortunately, most Republicans don’t need much coaching to realize that is complete bunk.