Desperate Fight for the Court

We have to be clear about what’s at stake.  Everything.

If Trump’s appointment is approved before the election, Trump can and will nullify the vote.  If he loses he’ll claim massive fraud, and the new Supreme Court will agree.  (Any later vote–should there be one–would be accompanied by voter suppression we can’t even imagine.)

This is no hypothetical issue.   In a Fox News piece today Ted Cruz had a list of reasons why Trump’s nominee needs to be approved immediately.  Item 3 was so that we can avoid a Constitutional crisis if the vote is contested–which comes down to precisely the same thing!

This is an attempted coup.  No other word is adequate.

Democratic Unity

The press is hard at work speculating why the current truce among Democratic factions is more apparent than real.  That may of course turn out to be true, but the real story seems the other way around—how the Covid crisis has improved the prospects for party unity.  I’d even go beyond that.  It has forced a common Democratic program that is more complete than anything we’ve had before.

This is necessarily theory, but there is logic to it.  Consider a few topics:

– Magnitude of the effort.

Any meaningful approach to Covid unemployment and climate change will be massive.  The scale is so large it’s hard even to formulate rational differences among factions.

– Jobs.

Previously the left wanted tariff protection and the center wanted retraining and support.  The answer now is something else—federal jobs.  Lots of them.  We still need to worry about trade, but that can become a matter for the WTO, where there is a real opportunity to go after all the factors that need to be taken into account.  We’ll still need retraining, but now we’re talking about real, waiting jobs better adapted the people we’re trying to help.

This is not just a temporary issue.  With Covid we’ve seen the limits of what the private sector can do.  There’s no question about the magnitude of our needs, and people must be hired to meet them.

– Healthcare

After Covid, it’s clear that an employer-based system is no solution.  Everyone wants to cover the whole population with a program that somehow or other grows out of Medicare.  The discussion is now about tactics, not policy.  Since this new form of Medicare is a non-trivial change, it seems reasonable to start with something less than a full flash-cut.  So we’re down to the size of the initial population group.  Is it really worth fighting about the 60-65 starting age group?

– Education

The Federal Government has stiffed the states and punted on federal help for the overwhelming job of reopening the schools.  Fixing this is real work.  We need Covid help, adequate state funding of K-12, keeping colleges and universities afloat, paying off student debt, and more.  At this stage you can’t really talk about factions, just a hope to make it right.

– Climate change

The current Biden proposal is the best I’ve seen yet. It even recognizes the importance of the international aspect—we need a new model for international cooperation or we will all fail.   There have been past differences of approach, but at this stage we need all of the above.

– Racial justice and national unity

This is obviously more than a Covid item.  But in any case events have made it an aspirational item for the party and even the country as a whole.  Differences may come, but for now there is commitment on all sides.

In all of these areas the biggest issues are actually planning and management—not partisanship.  These programs are not make-work precisely because there is so much that needs to be done.  We have to be the diametrical opposite of the corruption and self-dealing of the Trump people.  That’s a challenge all right, but one that all sides should be ready to embrace.

How We Won the Cold War

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“File:Map-Flag of the Soviet Union.svg” by NuclearVacuum is licensed under CC BY-SA 3.0

We hear every day how we need to get tough for our new cold war with China.  The unstated subtext is that threats and bluster are the “getting tough” that’s going to win. In fact we know exactly what won the last Cold War.  It’s worth paying attention to what that was.

The dynamism of our economy won the last cold war.   Our technological base reinvented itself many times over, and the top down economy of the USSR just couldn’t match it.  There were many individual factors behind the collapse—low growth, corrupt state enterprises, spending on defense, oil price collapse, Chernobyl.  But what it all came down to is that the Soviet economy collapsed because it just couldn’t find the resources to keep up.

Many factors made the difference—the historical strengths of the United States:

– A free market for new technologies.  A venture capital industry supported by anti-trust enforcement to protect new companies from powerful old ones.

– The US as world’s best destination for entrepreneurs from everywhere to realize their dreams.

– Openness to ideas from everywhere and active participation in international organizations of all kinds.

– Government support for pure research–to be on the forefront as new developments translated to opportunities.

– Expanding equality of opportunity, so ideas can come from everywhere.

The USSR had a well-trained population of elite engineers and scientists, but ultimately they couldn’t compete with the ability of the US model to reinvent itself and grow.

What can we say about the current situation with China?  There are three points:

  1. The rise of China actually followed the US model.

One part of this is familiar—China invested in its people:  education, infrastructure, health care, etc.  The regime tolerated no disagreements, but it put money (as we used to) into the environment necessary for success.

However the bigger part is less-discussed—what kicked off the Chinese miracle was an accidental surge of free enterprise.  As a weakening of collective economic control, Chinese municipalities were freed to carry out their own businesses once obligations to the state had been met.  That minor bit of freedom took over the economy.  Independent municipal businesses became dominant to the point that they dwarfed the hugely-corrupt state-run enterprises.  Municipal businesses grew into the independent private sector.

  1. Under Xi, China is abandoning that approach in favor of a return to central planning and control.

Xi is a princeling—a child of former revolutionaries brought up to believe he was born to rule.  All of his recent actions have been directed at crushing independent forces in the Chinese economy.  Appointments have been based on loyalty above all.

China is back to the old Soviet and Chinese world of massive state enterprises and a dictated economy.   That won’t change the immediate future, but we have no reason to despair of our ability to compete.

  1. Under Trump we are similarly abandoning our strengths.

Trump, like Xi, is an autocrat who view himself as the all-encompassing genius who needs to run everything.  He picks winners and losers with tariffs.  He awards exceptions to supporters.  He ignores real problems (such as Covid) that he doesn’t want to deal with.  Job appointments are based on loyalty over competence.  Every one of the listed US strengths is at risk:

– New enterprises are sacrificed to the existing powers that be.

– Xenophobia and nativism are pushing entrepreneurs elsewhere.

– Global participation is discouraged.

– Science is discredited and only mainstream technologies (e.g. AI) or Trump whims are funded. Climate change can’t even be mentioned.

– A political strategy of divisiveness means we’re fighting internally rather than drawing on everyone for progress.

 

We didn’t beat the Russians by mimicking their authoritarian control and top-down economy.  We won because they couldn’t compete with our ability to reinvent ourselves over and over again.  We have that opportunity today, but we’re losing it to the false god of dictatorship.

Democracy is not a nicety but the core of our success.

Dictatorships lose.  All-powerful leaders make disastrous mistakes that cannot be remedied.  They can ignore the well-being of the population.  They create massive corruption that cannot be contained.  All these tendencies are visible today (Covid alone shows several), and the effect is—as always—accelerating.

We still like to talk about the power of democracy and free markets, but both are slipping away.  Voter suppression is an openly-discussed goal.  Anti-trust enforcement has effectively ceased to exist.  The power of corporate lobbyists has starved the public sector (including infrastructure of all kinds) and defended the economic status quo against all comers.

Our problems today are not weaknesses of democracy but an indication of how far we’ve strayed from it.  There’s no reason to despair for our competition with China—or for the country generally.  It’s just a sign we have to get back to doing what we’ve always done best.

The Public be Damned

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“Face Mask” by shibuya246 is licensed under CC BY-NC 2.0

The logic behind medical face masks was never obscure.  When you sneeze or cough, droplets with virus are largely contained rather than spread.  That logic is clear and confirmed by statistics.

Who knows what Trump thinks, but the Republican Party certainly includes people capable of understanding that sentence.  Such people had a choice.  They knew they could save the country from a serious and completely unnecessary health risk, but they chose the political opportunities of divisiveness instead.

They made that choice.  Face masks had nothing to do with how quickly we were reopening the economy.   Many thousands will die for it.

This is hardly the first case of “public be damned” behavior.  But it is a very pure one.

The Green New Deal is Our Moment

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“Earth” by kristian fagerström is licensed under CC BY-SA 2.0

The name “Green New Deal” has become more apt than ever.  It was always a good idea to emphasize that fighting climate change can bring important benefits elsewhere in society.  However, post Covid-19 the name means more.

We’re in a deep hole, and both “New Deal” and “Green” are now policy imperatives.  That means we have to think more broadly about what the Green New Deal needs to be.  A new New Deal with a climate focus is the way out.

This isn’t a matter of changing the legislation but of realizing its aspirations.  There is much that was left deliberately unspecified in the initial draft.  Here are some suggestions for what there needs to be.

  1. We need a national plan.

The two recent stimulus measures (whatever their value) are examples of what we cannot afford to keep doing—quickly hacked-together combinations of incomplete and conflicting policies with problems in implementation.

Green New Deal is huge undertaking.  The climate side alone is a combination of many rapidly-changing technologies with major architectural choices and all sorts of issues with competing interests and local versus national administration.  In the new scope we have even more to do in making sure that our choices deliver economic and social benefits.  Business isn’t going to do it.  State and local interests aren’t going to do it.

The Green New Deal proposal already talks about modernizing the electrical grid.  That’s important but not the whole story.  We need a comprehensive plan including priorities at each stage of development. That effort needs to be funded, competent, and free of corruption.  It will take an organization charged with planning (starting even now) and a feedback process to work with all constituencies.

  1. Don’t limit the scope of jobs.

It’s true that fighting climate change will create many jobs.  But that was never the end of the story.  The country needs infrastructure of all kinds—and not just roads and bridges.  Education and healthcare are infrastructure too.  We don’t need make-work or “universal basic income” to stimulate the recovery; we just need the work that needs to be done.

The American Society of Civil Engineers keeps a website with a breakdown of national infrastructure requirements.  We currently rate a D+, and the inventory of problems is long.  We also need to restore our much-diminished upward mobility, through education and healthcare as mentioned but also with more mundane needs such as public transportation.  As a practical matter we also need daycare.

We also need to worry about the negative side—job loss.  The changes in fighting climate change will be significant; you only have to think how many people will be affected by the move to electric cars.  We have to guarantee that people will be made whole and plan how we’re going to do it.

  1. This really can be a locomotive for social justice.

The original New Deal was also conscious of this kind of goal, for example in bringing all regions of the country into the 20th century.  However its impact was more limited in matters of race or national origin.  For those we needed an even bigger national project—the mobilization of the population in World War II—to achieve some success (though blacks were explicitly excluded).  For many groups US history divides neatly into before and after World War II.

World War II was enough of a success to say it can be done.  The Green New Deal has to provide equal opportunity for everyone—again without corruption.  Fighting both climate change and a depression will require all of our resources in another nationwide battle against an existential threat.  Everyone has a part.

  1. This isn’t the 1930’s (any more than it was the 1950’s).

MAGA was a failed attempt to return the US to the 1950’s.  The failure was explicit: manufacturing was in recession before the virus hit, and essentially no jobs were ever brought home.  We have to be careful not to make a similar mistake about the 1930’s. This is a different economy.  As we’ve noted before, the transition of the US economy from manufacturing to services is a long-term trend with strong reasons to continue.

More and more companies are functionally software companies—with no skilled manufacturing career paths.  Amazon’s warehouse workers are not on track to the corporate offices in Seattle.  We can raise the minimum wage, but no combination of tariffs or other government policies is going to change the need to educate everyone for the good jobs that will exist.  We need a safety net and stronger unions, but above all we need to give people the tools to succeed.

We also need to think about government revenue in a different way.  Software companies are different—there is a strong tendency to monopoly, and cost of production is much less of an issue than product differentiation. Successful companies will tend to be highly international and with monopoly power.   The high profit margins and barriers to competition mean they should be taxable, but–as amply demonstrated by Apple—it’s seriously hard to do it.  That’s an international problem that needs to be solved.

  1. Don’t shortchange the international side.

Discussions of climate change tend to be parochial—solar panels on the house, then state issues, then national issues, and usually not beyond.  It’ll be tough to get carbon neutral, but then our job will be done; it’s up to everyone else to do the same.

In fact international issues are at least as important.  We control at most 15% of what happens to our atmosphere.  Our per capita energy consumption is twice anyone else’s, and we are by most measures the richest country in the world; it’s simply not going to happen that the rest of the world will just take care of itself.  We will need to be involved internationally, both for the underlying technologies and for their deployment.

The only international framework that exists for climate is the Paris Agreement.  That is entirely based on voluntary compliance in service of a common need.  There is no other mechanism.  We can’t bomb or tariff our way out of it.  We have to make it work.  Solving climate is a cooperative venture.

At worst this is a mess.  At best it is a model for international cooperation in other areas as well (trade, labor standards, taxation, environment standards).  The unanimity of the Paris Agreement was a major achievement of the Obama people.  The collapse of discussions since we opted out shows the risk.

  1. Need to create ongoing institutions.

For any activity with a fixed target—such as keeping carbon dioxide under the scientists’ limit—there is a tendency to think of reaching a new era where problems will finally be behind us. That’s a dangerous mindset.  For one thing it can produce a kind of eco-paralysis—with so many problems to be solved at once that you can’t make progress on anything.  (The recent Michael Moore movie is a symptom.)

More generally we have to recognize that even though we’re solving an existential problem for mankind, that will still leave plenty to do.  Having enough clean energy will help in many areas, but even for the environment we won’t finish all the problems we know.  And there will always be new issues beyond that.  So part of the job is making sure we will have the right institutions to go forward.

On the domestic side that means strengthening the regulatory agencies we have, and determining what is missing.  It’s possible that we will need more direct federal supervision or even operation of the power grid, for example.  We certainly need decades worth of large-scale spending on energy research.

On the international side there is also much to be done.  It should be recognized that the Covid-19 crisis was less an act of God than a failure of international governance.  China’s quarantine of Wuhan should have been matched by coordinated actions of other countries throughout the world.  That such an obvious consequence didn’t happen shows the vacuum created by the US abdication of power.  It also shows how we cause ourselves to suffer.

Most international institutions were our creation.  We had learned that the best way to exercise power was with rules we were willing to obey for ourselves.  We’ve now rejected that approach.  However, as a country, we have actual historical experience with such a situation.  The Articles of Confederation after the Revolutionary War almost destroyed the US before it could get started.  The solution was not more chaos, but an appropriate structure for success.

There’s another historical parallel worth mentioning.  After the second World War the US experienced unprecedented prosperity brought on in part by our rebuilding of Europe, including Germany.  The Marshall Plan paid real dividends.  The world has a similar opportunity in the developing middle classes of China, India, Korea, and elsewhere.  Instead we’re fighting a non-productive economic war with China that neither country will win, but virtually everyone will lose.  That’s not to say we have no issues with China, but in our eagerness for war we’ve shot ourselves in the foot.

The Green New Deal has become the defining task for our national moment.  For many issues—economic, political, racial, environmental, international—it represents a coherent way forward.  It is not the same task as the original New Deal, but certainly as challenging in its scope.  We have to recognize that we have it in our power to create a bright future for ourselves and for humanity.  The founding fathers of this country rose to their occasion.  Will we?

 

The Coronavirus Message for Climate

Since the coronavirus is at the top of everyone’s consciousness, there has been a lot written about what the coronavirus experience has to say on a great many issues.  After a while you start to get numb.  However for climate change the parallels are so explicit and telling that they need to be emphasized.  The argument in this piece is not new, but it’s worth spelling out in detail.

The coronavirus shows just how hard it is for us as a country—or as a world—to act ahead of a disaster even when the evidence is clear.  We were unprepared when the crisis came, because we just didn’t want to believe it could happen.  Our reluctance not to believe was of course encouraged by players (foreign and domestic) who felt there was something to be gained by delay.

The result is measured both by the numbers of dead and by the economic consequences of the drastic measures taken to stop the exponential growth of cases and deaths.  In the US that means on the order of 200,000 deaths and the worst job loss since the Great Depression.  The weeks of delay made this situation exponentially worse.  You can argue about the details, but there is no question that failure to act early cost us dearly on both counts.  We’ll muddle through, but badly wounded.

The parallels to climate change are explicit—but for climate the muddling through is no sure thing.  There are two primary points:

  1. CO2 in the atmosphere just adds up—which means that whatever problems finally force us to act will keep getting worse until we can manage to stop fossil fuels completely.  In other words from whatever time we recognize a crisis, we will be locked-in for many further years of worsening crisis.
  2. That’s even worse than it sounds because—as with epidemics—there is an exponential growth aspect here too.  To see this we can start with the example of hurricanes.  For hurricanes, the damages in the wind-speed categories are such that each step makes the previous look trivial.  In other words, as wind speed grows in a regular, linear way, damage goes up exponentially.

This isn’t just a matter of hurricanes; it’s typical for damage.  For floods you go from marginal areas affected to major cities.  In any category you can think of, damage goes up exponentially.  The bottom line is that for all those years of lock-in, every additional ton of carbon dioxide we add to the atmosphere will pack a wallop.  This is the stuff of nightmares.

The latest climate report gives us the timescale.  To avoid catastrophic consequences CO2 production needs to drop 45%  by 2030 and reach 0 by 2050.

We couldn’t get ourselves to believe the coronavirus would really happen, and climate disaster is even further from our past experience.  So the tendency to disbelieve is even stronger.

There are plenty of well-connected, interested players out to convince us to wait.  The oil companies and their allies are doing quite a good job of it.  Pence and Pompeo (among many others) are Koch organization soldiers in a Trump organization out to sabotage all efforts to control climate change.  Another indication of oil company power is Harvard University’s recent announcement of a commitment to fight climate change—by making their investment portfolio carbon-neutral starting in 2050, the year when the scientists say we need to be done!

That’s where we are.  Climate change is the coronavirus on a bigger scale.  It’s much more dangerous and with even more powerful forces out to convince us to wait, and wait, until it’s too late to matter anymore.  We’ve been warned.

Back to Normal from Covid-19

There has been much discussion of how to manage Covid-19 virus infections during the return to normal life.  There are many issues, but one in particular stands out for comment.

That issue comes from the much-noted age dependence of the virus death rate.  By now we’ve had plenty of experience of how this works.  For people under 50, the Covid-19 risk is similar to normal flu.  50-60 means more risk but still relatively small.  Over 60 it starts getting significantly worse, with the death rate more or less doubling for each ten years of age.  Pre-existing conditions make matters worse, but the age effect is still huge.  (There may be other categories of people worthy of attention, but that’s beyond the scope here.)

Overall reducing the death rate is primarily a matter of reducing the death rate for older people.  However, as a practical matter, focusing on the elderly is quite a big job.   If we’re going to protect the elderly from the virus at the very least we need to:  find them all, deliver food and other goods for them, assure fully-competent staff and daily testing at nursing homes.   No one is currently doing that.  On the contrary, death rates at nursing homes are scandalous, and individuals are largely left to manage themselves.  In Massachusetts as of this writing 610 of 1245 deaths were from nursing homes. Our extra hour of food shopping reserved for people over 60 is hardly a solution.

For the first bout with Covid-19 there has been neither the time nor the testing capability for such a strategy.  The countries that originally opted for “herd immunity”—with whatever they could do to protect the elderly—had to back off because of deaths.  The only alternative to catastrophe was to limit the spread of the virus in the population as a whole.  (There is a whole subculture of right-wing columnists claiming there was never a reason for the shutdowns, because it’s just a “simple” problem of isolating the elderly—without any proposals at all for how to do it.  For people who don’t go for that, there’s a different subculture dedicated to the proposition that the Covid-19 virus was never a problem to begin with!)

The point of this note is to recognize that the situation is different for the return to normality.  A focus on the elderly is both an obligation and an opportunity.  The obligation is that we just have to start doing a better job of protecting them.  It may be a logistical nightmare (only 5% of people aged 65+ are in nursing homes), but it’s a well-defined problem to be addressed with time, money, and commitment.  Testing is getting better.  It might even take the National Guard.  But we can certainly make things better if we start now.  We can call the right-wing’s bluff and spend the money to do it.

The opportunity of course is that reducing the elderly death rate will help ride through the ups and downs in new Covid-19 cases as people come back into the workforce.  People will still be getting sick, but children can go to school and parents can go to restaurants without risking anyone’s lives.  Whatever money is spent will be earned back in transition time.

This has to happen, it has to be fully-funded, and it has to start now.  “Flattening the curve” was essential to surviving the first onslaught of the virus.  For the return to normality, it’s “protecting the elderly” that will keep a difficult process going.

Short and Long Term Issues for Climate Change

In addressing climate change, one problem is that short and long term issues are not always the same.  As we’ve noted before, conservation is a legitimate short-term issue but not a primary long-term goal.

You can go a step farther with that:  there is technology we don’t want at all long-term that is still the best we’ve got for now.  That’s not just a matter of saving a little extra carbon dioxide; more importantly it’s buying time.

What the scientists have given us is not so much a schedule as a carbon budget—how much CO2 we can produce without irretrievable harm.  Many of the technologies we need to get off of fossil fuels completely are not 100% up to snuff.  What that means is that we can’t jump immediately into what we see as the right solution—more money won’t help.  That means accepting non-optimal technologies that cut some CO2 now.

Cutting CO2 buys time.  We need that time.

Here’s are a few areas that need work.  It’s too easy to wish them away:

– Electric cars are still too expensive and slow-charging to replace current technology.  This is a little like self-driving cars—the expectations have gotten ahead of the reality.

– Solar and wind may be cheap, but they’re not everywhere and not all the time.  For electric power generation that’s a problem.  In-network power storage is not up to the task of twenty-four hour operation.  With the current US grid, solar power in Arizona is not going to drive the rest of the country.

As an example, California’s aggressive deployment of solar electricity has forced external contracting to handle power peaks.  Currently the peaks are supplied by CO2-intensive fossil fuel plants in nearby states.

Local power generation can displace some residential and commercial demand, but at best that’s only 10% of the picture:

consumption-by-source-and-sector

– For heavy industry—steel and cement for example—CO2 production is not just a matter of power consumption, it’s intrinsic to the industrial processes.  There are no simple solutions to change that.  Flue-based carbon capture just has to get better.  (Direct air capture of CO2—despite much enthusiastic press—is even farther off.)

Prospects for fixing all of this are good, but we’ve got to buy time to get there.  That means taking steps with what we’ve got now.  Here are a few examples:

– We should think more about hybrid cars.  That’s increasingly cheaper technology, it saves considerable gas, and recent plug-in hybrids save more (perhaps leading even to upgradeable batteries).   The biggest problem with the technology is that, despite improving sales, we’re still not selling enough of it.  Initial carbon pricing should be aimed at universal hybrid penetration.  Tesla is great, but it’s not going to have a big enough impact now.

– Replacement of coal by gas saves 50% of CO2 production.  There aren’t always alternatives, for the reasons listed above.  Furthermore, lumping all fossil fuels together makes it easy to excuse coal.  When Germany and Japan closed nuclear plants, they didn’t go to gas, they went to coal.

While we’re currently seeing more growth of CO2 emissions with gas than with coal, it’s easy to draw the wrong conclusion.  Coal and oil still represent the vast part of CO2 production, and any replacement is a win.

s20_2019_Coal_Oil_Gas_Cement

– Carbon capture is unavoidable.  The first focus is on flue-based technologies, even if direct air capture is sexier.  This needs real money, because the industrial sector is huge worldwide.

To those items we should add one more difficult bit of reality:  the US needs a vastly improved national electric power network as a near-term prerequisite for much future work.  That means more high-voltage power interconnections.  That in turn means dealing with environmental issues and protection for the poorer neighborhoods that normally bear the brunt of such things.  One way or another this has to be made to happen, even though it involves competing concerns.

All of this underlines the need for a real plan—with both domestic and international aspects.  That needs to be a step-by-step prescription for what we should do about climate change.  That is what money needs to be spent on what technologies when and where.  For all their strengths, neither the Green New Deal nor the CCL’s carbon pricing is anything like a comprehensive plan.

Carbon pricing in particular remains a source of considerable confusion.  Since it is a critical component, we end with a few comments to avoid misunderstanding.

– Carbon pricing has to be a clear signal to industry of where the world is going.  It may start relatively low (as we’ve just discussed), but planned increases must send the message that the fossil fuel world is ending.  We need to get to at least $100 a ton in 5-10 years.  As such, proposals of $40 a ton with only nominal increases (coming from oil industry sources among others) are dead on arrival.  Carbon pricing is not good or bad in the abstract; it’s good or bad based on the numbers.

– Carbon pricing is not a tax, it’s killing a silent subsidy.  Carbon in the atmosphere costs all of us money in current and future climate change disasters.  Keeping it free represents an annual subsidy to the fossil fuel industry in the US of approximately $1T yearly (lower numbers are based on flawed cost models and just plain wrong).  That huge perversion of the economy has to end.  The money belongs to the public; it’s not there for the taking.  It needs to be given back in a way that mitigates the regressive effect of higher oil prices.  If we need more money for climate change or anything else, that needs to be done through the tax and budgeting system.  That’s where we make decisions about who pays.

– Carbon pricing will not solve all problems.  Government has many active roles to play, for example in putting together the new national electric power infrastructure that will be critical for progress.  Also government will need to address the enormous social consequences of remaking the economy.  We need to have carbon pricing to prevent perversion of the economy, but it’s only one element in a comprehensive plan.