Underfunded, Under Threat: Revamping Disaster Relief Funding in the Face of Climate Change

By Sam Horowitz (PZ ‘20 )

I. Introduction: Disasters on the Rise, and the Science Behind It

The frequency and intensity of natural disasters has been increasing in the United States and around the world. As seen in Fig. 1, natural disasters of every type have been increasing in number over the past forty years. This poses a grave risk to the United States, both economically and in terms of human life. The increase can be partially attributed to anthropogenic climate change. Carbon dioxide, which makes up the majority of greenhouse gas (GHG) emissions, is produced by the burning of fossil fuels during electricity generation, transport, or any number of energy-based actions. Along with other GHGs, carbon dioxide traps solar radiation reflected from Earth towards space, in a process known as the albedo effect.[1] GHGs then warm the captured radiation and emit it back towards Earth. This affects natural disasters through a variety of mechanisms: warmer temperatures can lead to an increase in droughts and provide favorable conditions for wildfires; the melting of ice caps (as well as heat-induced water expansion) can lead to sea level rise, putting coastal communities at risk; and increased ocean temperatures can provide the fuel for stronger storms. In the wake of the California wildfires and Hurricanes Harvey, Irma, and Maria, as well as the predicted increase in intensity and frequency of natural disasters, the United States must take action to protect its residents, infrastructure, and economy from the large scale damages that these disasters will inflict in the absence of action.

 

II. Current Conditions: Budgetary Woes and Climate Projections

 The intensity of extreme weather events is only likely to increase over the coming years. NASA has stated that for every 0.3°C increase in temperature, hurricane wind speed will likely increase by one knot.[2] Scientists have also calculated that warming over the course of the Twentieth Century caused a two times increase in the likelihood of a Katrina-magnitude event, while predicting that a further 1°C increase in temperature would increase the likelihood of a Katrina-magnitude event by two to seven times.[3] This is not just a problem that will manifest in the future. Scientists in the growing field of extreme event attribution have begun assessing the impacts of climate change on current natural disasters. In 2018, scientists hypothesized that anthropogenic climate change increased precipitation during Hurricane Harvey by roughly thirty-seven percent.[4] Anthropogenic climate change has already been shown to be correlated with increasingly intense natural disasters in the United States. As seen in Fig. 2, the increase in natural disasters which cost one billion dollars or more in damages has correlated with the increase in U.S. CO2 emissions. As emissions continue to increase, the intensity of natural disasters will only continue to rise. One study found that median “losses,” a measure of hurricane damage per national GDP, would increase by a factor of 2.91 by 2100, while losses from category 4 and 5 hurricanes would increase by a factor of 4.75.[5] Meanwhile, the Federal Emergency Management Agency (FEMA) has consistently faced budgetary inadequacies and uncertainty despite facing record amounts of damages. Per FEMA’s December 2017 Disaster Relief Fund (DRF) report to Congress, the DRF was scheduled to be depleted by June 2018.[6] For FY 2019, FEMA requested $6.9 billion in funding for the DRF.[7] While this may seem like a significant sum, it must be viewed in context. In 2017, natural disasters in the U.S incurred $306.2 billion worth of damages.[8]

III. Alternatives: Treating Surface-Level Concerns

     A. Increased Funding for the DRF

As the cost of disasters increases, FEMA’s DRF will need more funding in order to cope. Without a substantial increase to the DRF, response to and recovery from significant natural disasters will be inadequate. The DRF is used when state resources are insufficient to effectively handle a natural disaster, as determined by the President. The purpose of the DRF is to coordinate, manage, and fund recovery and response efforts, including but not limited to: the repair of damaged public infrastructure, hazard mitigation, and financial assistance to eligible survivors.[9] The DRF is essential to both immediate responses and long-term recovery. In fact, the DRF is still paying out millions of dollars to assist in the recoveries from Hurricane Sandy (2012) and Hurricane Ike (2008).[10] Congress has recognized the need for additional DRF funding in the past: when the DRF has been close to depletion, Congress has approved supplemental appropriations. Since 2004, Congress has approved $89.6 billion in supplemental appropriations for the DRF, largely in response to specific events.[11]  However, supplemental appropriations are neither an ideal source of funding nor a sustainable one. There are three main criticisms of this funding mechanism:

  1. Supplemental appropriations are an emergency expenditure, and can therefore exceed spending limits put in place to reduce the federal deficit. This means that lawmakers may underfund the DRF during the initial appropriations process.
  2. Supplemental appropriations are often rushed through Congress, meaning that there is less time to thoroughly assess the cost of damages; early damage evaluations may be overestimated; and provisions against waste, fraud, and abuse are not properly instituted.
  3. Riders unrelated to disaster relief, which in many cases would not pass by themselves, may be attached to supplemental appropriations, causing debate and further slowing down the appropriations process.[12]

The main concerns that must be addressed are the uncertainty regarding what services can and cannot be funded, and the slowing of the delivery of disaster relief. To ameliorate these issues, Congress should consider increasing funding for the DRF in the budget appropriations process. Based on the damages incurred in 2017, as well as the projected increase of major catastrophes, the DRF clearly needs increased funding. Despite requesting only $6.9 billion for FY 2019, DRF obligations for Hurricanes Irma, Harvey, and Maria, alone, are projected to be $28.2 billion through FY 2018. [13] I recommend appropriating no less than $8.2 billion[14] to the DRF, increasing at an appropriate rate that accounts for disaster projections and inflation. This will alleviate the need for supplemental appropriations, lessen uncertainty, and speed up recovery times. Congress should consider appropriating even more to the DRF based on the expected increases in damages from category 4 and 5 hurricanes. However, further study is needed to ascertain the future frequency of such climate events. Nonetheless, increasing funding would enhance the ability of FEMA to help communities rebuild and resettle, replace destroyed infrastructure, and remove debris.

     B. Increase Funding for Resiliency and Mitigation Efforts

One way to lessen the damages incurred by natural disasters is to increase resiliency efforts. By increasing funding levels for grants aimed at local level resiliency, such as flood protection, storm barriers, and proactive relocation, future costs—both in terms of casualties and monetary damages—may be lowered. This may be accomplished in part through an increase in funding for FEMA’s Pre-Disaster Mitigation (PDM) Grant Program. In FY 2017, the program was appropriated only ninety million dollars, with ten million set aside specifically for federally recognized Native American nations.[15] Given the actual costs of resilience measures, as seen in New York City (noted below), ninety million is hardly sufficient.

Funding resiliency initiatives boasts proven cost-benefits. An ongoing study has found that, for every dollar of federal funding invested in mitigation programs, an average of six dollars was saved in future costs.[16] This number increased to seven for riverine flood mitigation. A model of resiliency initiatives may be New York City’s OneNYC program. In the aftermath of Hurricane Sandy, the city committed to improving resiliency and mitigation efforts. Since 2015, New York City has invested over $3.7 billion in coastal protection alone, while also jumpstarting projects that train citizens, create shade zones to guard against extreme heat, change zoning, fund flood-resilient retrofits, strengthen infrastructure, and safeguard utilities.[17] Increasing funding for PDM to one billion dollars, as well as lesser increases for other smaller federal resiliency grants administered through NOAA, the EPA, and HUD, amongst others, will yield approximately six billion dollars in future savings. Not only will this save lives and lessen the cost of future damages, but it will lessen the need for an ever-increasing FEMA budget.

IV. Alternatives: Addressing the Causes While Providing Relief

     A. Instituting a National Cap and Trade System

Passing legislation to implement a nationwide cap and trade system will limit carbon emissions, a leading cause of climate change, while also providing revenue for disaster relief and resilience efforts in the present. A cap and trade system would put a “cap” on emissions, which would be gradually lowered over time. Emissions credits, which allow companies to emit a specified amount, would be bought at publicly administered auctions, and could be sold amongst companies, providing businesses a mechanism for profit. The price of a credit would be determined by the market. Revenue from the auctions could then be used to fund disaster relief and resiliency.

The American Clean Energy and Security Act of 2009, otherwise known as the Waxman-Markey Bill, is a practical measure to re-introduce. This bill represents the closest that nationwide cap and trade has come to implementation, having passed the House but not the Senate. Under the bill’s proposed Clean Air Act amendments, emissions would be capped at ninety-seven percent of 2005 levels by 2012, eighty-three percent of 2005 levels by 2020, fifty-eight percent of 2005 levels by 2030, and seventeen percent of 2005 levels by 2050.[18] Adapted for the current time period, under the assumption that it would be passed in 2018, this corresponds to 2021, 2029, 2039, and 2059, respectively. While this proposal presents a longer timeframe for effectiveness, it addresses a one of the leading drivers of anthropogenic climate change.

     B. Instituting a National Carbon Tax

A carbon tax puts a price on carbon emissions in an attempt to incentivize their reduction. This tax parallels a cigarette tax used to internalize the cost to public health associated with smoking. A carbon tax is appealing for a number of reasons. First and foremost, businesses are incentivized to find cost-effective measures to reduce their carbon emissions. However, a carbon tax also produces an assured revenue stream, some of which could be used to fund disaster relief and resilience efforts. The proposed carbon tax would start with a base rate of twenty dollars per ton of CO2. This number is much lower than some previous carbon tax proposals (for example, S.2368 and H.R.2014), suggesting greater political practicality. The tax would rise at a five percent rate each year, which would counterbalance the relatively low starting base fee over time, and keep revenues up as overall emissions decrease. By year twenty-four of the program, this will result in a tax of $60.17 per ton, unadjusted for inflation.[19] In 2050, the tax would become a fixed tax, remaining in effect at its then-current rate, so as not to increase to astronomical levels. Finally, the proposed tax would be revenue neutral, allowing for a portion of the revenue to be used for corporate income tax breaks. This is so that the bill may be bipartisan in nature. While emissions projections under a carbon tax are uncertain, CO2 emissions  are expected to decrease while generating significant amounts of revenue.

V. Assessing Policy Solutions: Projections, Tradeoffs, and Viability

     A. DRF Funding

Increasing DRF funding will help FEMA to better cope with increasingly intense and frequent disasters. Cities will be able to rebuild faster and more effectively, and citizens will be able to receive the proper assistance that they deserve after a disaster hits. Increasing funding will alleviate the need for supplemental appropriations, which can slow down service deliveries for disaster relief due to bureaucratic processes. However, increasing DRF funding has its drawbacks. Seeing that disasters will only occur more often and continue to worsen over time, DRF funding will have to increase over time as well. To ensure this, an annual percentage increase, based on up-to-date and robust climate projections, as well as inflation, should be implemented. Though this will undoubtedly help disaster relief efforts, it may prove to be an unsustainable approach to the issue. Funding cannot continue to grow exponentially: this is simply fiscally unsound. In addition, this is a reactive rather than proactive measure; it will not protect Americans from harm, nor alleviate future costs. While increasing appropriations is generally a difficult issue in Congress, it appears that decisions related to funding the DRF will prove to be more amicable than other subjects tend to be. Disasters do not discriminate between Democrat and Republican: Republican-led Texas has had the most expensive natural disasters since 1980, with the Democratic stronghold of New York not far behind.[20] The major damage inflicted in 2017 likely opened a policy window for DRF funding to be increased; while it may have closed by 2018, there will surely be other events which cause it to be reopened, offering an opportunity for legislators to increase appropriations.

     B. Resilience and Mitigation

Increasing resiliency and mitigation infrastructure and initiatives will help lessen damages associated with future disasters, while proactively protecting Americans from harm. It also represents a good investment, with, depending on the type of disaster, a minimum of three dollars saved for every one spent on resilience and mitigation.[21] Increasing resilience could potentially lessen the need for a continually-increasing DRF budget. Resilience is beneficial for individual property owners as well. Property owners in communities with the highest levels of mitigation standards received, on average, a forty-five percent discount on flood insurance premiums.[22] Increasing funding for mitigation efforts would extend this benefit to larger numbers of homeowners, not only those who can afford to retrofit their homes out of pocket. Currently, FEMA’s PDM grant funding is too miniscule to affect any meaningful, large-scale projects. As seen in Fig. 3, FEMA PDM spending has decreased substantially over the past decade, despite the increasing costs of disasters. Increasing PDM funding to at least a billion dollars, as well as increases to other federally-funded mitigation and resiliency grants, will help individuals, cities, and states to: retrofit buildings; implement stormwater management systems that will adequately cope with increases in precipitation; design and/or acquire flood barriers; create natural barriers to tides and flooding, such as wetlands or living shorelines; and protect essential utilities from harm.

While resilience and mitigation are undoubtedly important aspects of disaster relief, they are merely band-aid solutions to the real issue: CO2. Resilience must continue to increase in the face of projected escalations of natural disasters. There is simply no way to answer the question “at what point are we resilient enough?” Therefore, while investing in resilience will likely drive down costs in the long-term, it would still require a substantial, long-term investment. The political efficacy of increased resiliency funding is unclear. Though this is an area that social scientists and policy analysts have yet to investigate, the politics would likely be similar to that of the DRF. When disaster hits, policymakers are more future-oriented in terms of disaster relief and resilience efforts.

     C. Nationwide Cap and Trade Program

Instituting a nationwide cap and trade program under the specifications of the Waxman-Markey bill presents a long-term solution that targets the core issue—CO2 emissions. While such a program may not have significant effects on emissions for decades, it will create revenue in the meantime, which can be used for relief and resilience in the present. While the expected revenue is difficult to pinpoint, because it will be determined by the market, the Congressional Budget Office estimated that Waxman-Markey would generate $298 billion from 2010-2014, and $973 billion from 2010-2019, with those numbers decreasing after accounting for a loss in tax revenue[23] to $254 billion and $858 billion, respectively.[24] Cap and trade also has proven success in the United States, with California’s program, the Regional Greenhouse Gas Initiative (RGGI) in the Northeast, and the Acid Rain Program (ARP) under President George H.W. Bush, which represented the first national cap and trade program in America..[25] Under ARP, the United States reduced levels of nitrous oxides and sulfuric oxides, two major contributors to acid rain, by eighty-six and seventy-nine percent, respectively.[26]

According to my projections, a national cap and trade program with emission caps specified by Waxman-Markey will not become effective at reducing CO2 emissions until 2033 (Fig. 4). While it will undoubtedly generate large amounts of revenue, the emissions cap will remain higher than projected CO2 emissions for 14 years, assuming it is passed in 2018. While it is unlikely that U.S. CO2 emissions will rise to the cap, due to advances in renewable energy technology and projections which indicate that renewable energy will be less costly than most fossil fuels by 2020, this program will not be effective at reducing emissions for a number of years.[27] It is important to remember that CO2 reductions will have a delayed effect on atmospheric CO2 concentrations, because CO2 lingers in the atmosphere for decades. Therefore, it is imperative to make reductions as soon as possible.  However, the impacts of Waxman-Markey on businesses and households could be more immediate, and possibly severe. According to some analyses, the cap and trade program would cost the average household an additional $235 per year, although households in the lowest income bracket would see a net benefit of forty dollars.[28] However, a Heritage Foundation report indicated that impacts could be more extreme, with yearly job losses between two hundred- and nine hundred-thousand, and costs for manufacturers becoming so inhibitive that many would be forced to shut down or move overseas.[29]

While it has been effective in the United States on smaller scales and for acid rain, the EU’s cap and trade system, a more comparably-sized program to the proposed U.S. policy,  has struggled for many years. This is due to a number of factors, including an initial over-allocation of emissions credits and low market prices.[30] The prospects for a cap and trade system are also limited by an institutional constraint: the government would need to create an entirely new institution and bureaucracies to oversee auctions. Doing so would require large amounts of funding and an expansion of the government, two elements which are sure to draw political ire. Waxman-Markey failed to pass the Senate due to opposition from both political parties. Passing it as is, or similar cap and trade legislation, may prove to be impossible in the current political atmosphere.

     D. A National Carbon Tax

A carbon tax, like cap-and-trade, would reduce CO2 emissions in the hopes that doing so will nullify, or at least mitigate, projected increases in the frequency and intensity of natural disasters. According to my projections in Fig. 4, an initial twenty-dollar per ton carbon tax with a five percent annual increase will reduce CO2 emissions to a greater extent than cap and trade in the short- and medium-term, while still achieving significant reductions after being eclipsed by cap and trade. Expected revenue generated under this specific plan would near $1.5 trillion by 2028, assuming tax revenue was generated starting in 2019. A portion of this revenue would be used to reduce corporate income taxes, increasing the political efficacy of the proposal. A number of conservatives, including former cabinet members under Presidents Reagan and Bush, have expressed support for a revenue neutral carbon tax.[31] A lesser portion of the tax revenue would be reserved for current disaster relief efforts and resilience funding. A carbon tax is also appealing because it requires no additional institutional infrastructure, as cap and trade does. A carbon tax would be implemented under the auspices of existing taxation infrastructure, namely the Internal Revenue Service.

Implementation of a carbon tax faces a number of hurdles. It may be necessary to implement a border tax adjustment to ensure that a carbon tax does not make U.S. products substantially more expensive, and therefore noncompetitive, than products from countries without a carbon tax. While such a measure, if correctly crafted, would be consistent with World Trade Organization guidelines, implementing it would be an added complication.[32] Another concern is that, as part of a compromise for carbon tax legislation, environmental regulations could be rolled back, potentially negating emissions reductions from the tax. [33] There are significant economic concerns as well. A report from the National Association of Manufacturers projected that a carbon tax similar to the one proposed (twenty dollars per ton, rising at four percent each year) would decrease the wage rate by a maximum of 1.2 percent, while increasing energy prices by between two cents and three dollars, depending on the source of energy.[34] These costs would primarily be passed down to consumers. Low-income households, which spend a larger percentage of income on emissions-intensive goods and services, would see a greater share of their income spent on energy because of this.[35] However, energy rebates may be offered to help offset this added cost. Finally, no large country or U.S. state has implemented a carbon tax, leading to a lack of empirical evidence and best practices, while also pointing to a lack of political will on the part of current politicians.

VI. Conclusion: A Sound Investment Over Uncertainty

The United States should not continue to be reactive when it comes to natural disasters. With disasters projected to increase in frequency and strength in the coming years, America must commit to either: increased funding for the DRF, increased funding for resiliency and mitigation projects, a national cap and trade system, or a national tax on carbon emissions. While all four proposals have tradeoffs, some will be less disruptive than others. The expected long-term benefits of cap and trade and a carbon tax are not assured to stem the projected increase of natural disasters. There is currently no scientifically agreed upon threshold for an amount of carbon emissions that will reduce the threat of future natural disasters. The potential economic harm from both policies outweighs the uncertain benefits of reduced natural disaster threats, and the potential for either to be enacted is slim. While the United States may look to implement a carbon tax for other reasons, such as deficit reduction, it should not do so to mitigate the threat of natural disasters. Congress should consider increasing FEMA’s DRF budget. Doing so is a necessity to cope with disasters that will happen more often and inflict greater damages. However, while increasing the DRF is essential to helping hard-hit areas rebuild, it is still a reactive measure that will neither protect citizens nor lessen future damages. Rather, Congress should focus primarily on increasing funding for resilience and mitigation initiatives such as FEMA’s PDM grant. Initially increasing PDM grant funding to one billion dollars will save the government six billion in response and relief costs, while protecting the lives of Americans. This is a proactive, cost-effective method to reduce the impact of future disasters.

 

 

 

Appendix

Figure 1, World Meterorological Org., Atlas of Mortality and Economic Losses from Weather and Climate Extremes 1970-2012, at 15  (2015), https://public.wmo.int/en/resources/library/atlas-mortality-and-economic-losses-weather-and-climate-extremes-1970-2012.

Figure 2, data from Billion-Dollar Weather and Climate Disasters: Table of Events, Nat’l Oceanic & Atmospheric Admin., https://www.ncdc.noaa.gov/billions/events/US/1980-2018 (last visited Oct. 21, 2018).

Figure 3, data from Gov’t Accountability Off., GAO-16-797, Report to Congressional Committees: Federal Disaster Assistance (Sept. 2016), https://www.gao.gov/assets/680/679977.pdf.

Figure 4, partial emissions data from Total Energy: Monthly Energy Review, U.S. Energy Info. Admin., https://www.eia.gov/totalenergy/data/monthly/ (last visited Oct. 21, 2018); carbon tax projections using CTC’s model, Komanoff, supra note 19; cap and trade projections by author.

[1] Overview of Greenhouse Gases, Envtl. Protection Agency, https://www.epa.gov/ghgemissions/overview-greenhouse-gases  (last visited Oct. 21, 2018).

[2] The Impact of Climate Change on Natural Disasters, Nat’l Aeronautics & Space Admin. (Mar. 30, 2005), https://earthobservatory.nasa.gov/Features/RisingCost/rising_cost5.php (last visited Oct. 21, 2018).

[3] Aslak Grinsted, John C. Moore & Svetlana Jevrejeva, Projected Atlantic Hurricane Surge Threat from Rising Temperatures, 110 PNAS 5369 (2013).

[4] Mark D. Risser & Michael F. Wehner, Attributable Human-Induced Changes in the Likelihood and Magnitude of the Observed Extreme Precipitation During Hurricane Harvey, 44 Geophys. Res. Letters 12457 (2017).

[5] Tobias Geiger, Karja Frieler & Anders Levermann, High-Income Does Not Protect Against Hurricane Losses, 11 Envtl. Res. Letters 084012 (2016).

[6] Fed. Emergency Mgmt. Agency, Disaster Relief Fund: Monthly Report as of December 31, 2017 (Jan. 12, 2018), https://www.fema.gov/media-library-data/1516297447909-222f1bb738282615226e3cded66fd577/January2018DisasterReliefFundReport.pdf [hereinafter FEMA, Dec. 2017 Report].

[7] Off. Mgmt. & Budget, Efficient, Effective, Accountable: An American Budget (Feb. 2018), https://www.whitehouse.gov/wp-content/uploads/2018/02/budget-fy2019.pdf

[8] Fast Facts: Hurricane Costs, Nat’l Oceanic & Atmospheric Admin. (last modified Oct. 17, 2018) https://coast.noaa.gov/states/fast-facts/hurricane-costs.html (last visited Oct. 21, 2018).

[9] FEMA, Dec. 2017 Report, supra note 6.

[10] Fed. Emergency Mgmt. Agency, Disaster Relief Fund: Monthly Report as of March 31, 2018 (Apr. 10, 2018), https://www.fema.gov/media-library-data/1523479557758-37aaf5703acc6464ea19ca9414c9501e/April2018DisasterReliefFundReport.pdf [hereinafter FEMA, Mar. 2018 Report].

[11] Bruce R. Lindsay, Cong. Res. Serv., R43537, FEMA’s Disaster Relief Fund: Overview and Selected Issues (May 7, 2014), https://fas.org/sgp/crs/homesec/R43537.pdf.

[12] Id.

[13] FEMA, Mar. 2018 Report, supra note 10.

[14] This number was calculated using the aforementioned increase in losses from the average hurricane by a factor of 2.91 by 2100. 2100 was subtracted from the base year (2016), producing 84. 2.91 was then divided by 84 to produce the annual percentage increase (3.5%). This was then multiplied by the DRF appropriation for 2016, and that sum was then added to the 2016 appropriation. That number was then multiplied by 3.5% to get the 2017 number, and then repeated for 2018. While this is by no means a perfect method, it provides a rough estimate for how FEMA DRF funding should increase over time. Unfortunately, FEMA does not provide total FY spending data.

[15] Fed. Insurance & Mitigation Admin., FY 2017 Pre-Disaster Mitigation (PDM) Grant Program, https://www.fema.gov/media-library-data/1499868698311-25cdc5fcfb237df56a87da7cd7cc0717/PDM_FactSheet-for-FY_2017_508.pdf.

[16] Nat’l Inst. of Building Sciences, Natural Hazard Mitigation Saves: 2017 Interim Report (Dec. 2017), https://c.ymcdn.com/sites/www.nibs.org/resource/resmgr/docs/NIBS_MitigationSaves_Interim.pdf.

[17] City of New York, Progress Report: OneNYC 2018, https://onenyc.cityofnewyork.us/wp-content/uploads/2018/05/OneNYC_Progress_2018.pdf.

[18] H.R. 2454 – American Clean Energy and Security Act of 2009, 111th Cong. (2009-2010), https://www.congress.gov/bill/111th-congress/house-bill/2454 (last visited Oct. 21, 2018).

[19] Charles Komanoff, Carbon Tax Ctr., Carbon Tax Spreadsheet Model (2017),

www.komanoff.net/fossil/CTC_Carbon_Tax_Model.xlsx.

[20] Adam B. Smith, 2017 U.S. Billion-Dollar Weather and Climate Disasters: a Historic Year in Context, Nat’l Oceanic & Atmospheric Admin. (Jan. 8, 2018), https://www.climate.gov/news-features/blogs/beyond-data/2017-us-billion-dollar-weather-and-climate-disasters-historic-year (last visited Oct. 21, 2018).

[21] Nat’l Inst. of Building Sciences, supra note 16.

[22] It Pays to Prepare for Natural Disasters, Pew (May 8, 2017), http://www.pewtrusts.org/en/research-and-analysis/fact-sheets/2017/05/it-pays-to-prepare-for-natural-disasters.

[23] The CBO noted that buying credits would result in an additional business expense, which would lead to a reduction in taxable income.

[24] Cong. Budget Off., Cost Estimate: H.R.2454 American Clean Energy and Security Act of 2009 (June 5, 2009), https://www.cbo.gov/sites/default/files/111th-congress-2009-2010/costestimate/hr24541.pdf.

[25] Acid Rain Program, Envtl. Protection Agency, https://www.epa.gov/airmarkets/acid-rain-program (last visited Oct. 21, 2018).

[26] Envtl. Protection Agency, 2016 Program Progress – Cross-State Air Pollution Rule and Acid Rain Program, https://www3.epa.gov/airmarkets/progress/reports/pdfs/2016_full_report.pdf.

[27] Int’l Renewable Energy Agency, Renewable Power Generation Costs in 2017 (2018), https://www.irena.org/-/media/Files/IRENA/Agency/Publication/2018/Jan/IRENA_2017_Power_Costs_2018.pdf.

[28] Cong. Budget Off., The Estimated Costs to Households From the Cap-and-Trade Provisions of H.R. 2454 (June 19, 2009), https://www.cbo.gov/sites/default/files/111th-congress-2009-2010/reports/06-19-capandtradecosts.pdf.

[29] U.S. House of Reps Comm, on Oversight & Gov’t Reform Minority Staff, Comprehensive Staff Analysis of the Economic Impact of the Waxman/Markey Cap-and-Trade Legislation (Apr. 29, 2009), https://oversight.house.gov/wp-content/uploads/2012/02/20090428CapTrade.pdf.

[30] Tim Laing et. al., Ctr. for Climate Change Economics & Pol’y Working Paper No. 126, Grantham Res. Inst. On Climate Change & the Env’t Working Paper No. 106, Assessing the Effectiveness of the EU Emissions Trading System (Jan. 2013), http://www.lse.ac.uk/GranthamInstitute/wp-content/uploads/2014/02/WP106-effectiveness-eu-emissions-trading-system.pdf.

[31] See, e.g., James A. Baker III et al., Climate Leadership Council, The Conservative Case for Carbon Dividends (Feb. 2017), https://www.clcouncil.org/media/TheConservativeCaseforCarbonDividends.pdf

[32] Joost Pauwelyn, Carbon Leakage Measures and Border Tax Adjustments under WTO Law, in Research Handbook on Environment, Health and the WTO 448 (D. Prevost & G. Van Calser eds., 2012).

[33] Baker III et al,, supra note 31.

[34] Nat’l Assoc. of Manufacturers, Economic Outcomes of a U.S. Carbon Tax (2013), http://www.nam.org/Issues/Tax-and-Budget/Carbon-Tax/CarbonTaxExecutiveSumm/

[35] Cong. Budget Off., Effects of a Carbon Tax on the Economy and the Environment (May 2013),  http://www.cbo.gov/sites/default/files/cbofiles/attachments/44223_Carbon_0.pdf

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