by Rob Roper

Dan Barlow, executive director for Vermont Businesses for Social Responsibility, posted on Facebook this weekend, “Thank you to Vermont Natural Resources Council for inviting me to today’s VECAN conference to talk about the economic benefits of carbon pricing.” That’s what they call a Carbon Tax.

Barlow goes on to praise Senator Elect Chris Pearson, a Progressive from Burlington, who as a Rep. led the House Climate Caucus, which served as the launching pad for last session’s Carbon Tax legislation. Pearson will certainly bring his zeal for implementing the tax to the Senate.

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Additionally, VT Digger reports in their article “Local Global Warming Leaders Undeterred by Donald Trump,” that Johanna Miller, energy program director for the Vermont Natural Resources Council said. “We have to ensure Vermont is a beacon of hope and model of innovation. We have an obligation and an opportunity. The imperative of local and state efforts has never been greater.”

Digger also quotes Lauren Hierl, political director for the Vermont Conservation Voters advocacy organization, as saying Vermont “offered a more promising landscape.“

Clearly, these folks aren’t going away. In fact they’re doubling down on a Carbon Tax and an overall energy policy that is dangerous to Vermont’s economy.

- Rob Roper is president of the Ethan Allen Institute.

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by John McClaughry

A week ago Kim Strassel of the Wall Street Journal wrote that the climate activists are aghast at Trump’s pick of Myron Ebell to head his Environmental Protection Agency transition team.

I have respected Myron Ebell for over thirty years. We first met when he was working for the American Land Rights Association to keep the Federal government from stealing the property rights of national park and forest inholders. He later joined the Competitive Enterprise Institute, which has worked for three decades to get the Federal government to back off economy-choking regulations, especially Obama’s sweeping plans to defeat the menace of climate change – which is why the climate warriors are hysterical over Myron Ebell.

Kim Strassel observes that “The biggest battle lines will be drawn over the dismantling of Obama’s environmental regime. This is where the president’s crushing rules have arguably done the most broad-based damage to the economy. It is also where the progressive left is most organized—and most emotional… For years Republicans have been running scared on the environment, cringing under attacks from activists, constantly seeking to look “green” and play down their energy ambitions. Not so Mr. Trump, who has promised to  “cancel job-killing restrictions on the production of American energy” .

Myron may or may not become the EPA administrator, but he’s a decent, honest, guy with the brains and backbone to terrify the climate warriors. I wish him the best.

- John McClaughry is the vice president of the Ethan Allen Institute

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by Rob RoperRob Roper

What happens when an irresistible force meets and unmovable object? Vermonters will find out in January when the new Republican governor officially takes office along with a legislature that has, if anything, moved a little to the left.

During the campaign, governor-elect Scott, often accused by his critics of being non-committal and unspecific, was actually quite stalwart and crystal clear on a number of key issues: he will veto a carbon tax, wants a moratorium on large-scale wind energy development, believes Vermont’s gun laws are fine the way they are, and will not support a budget that spends at a rate greater than the previous year’s level of economic growth. Compared to the direction the majority in the legislature has doggedly pursued for the past decade, this is the opposite.

Scott, winning by a whopping nine points over Democrat Sue Minter in a near-record turnout election, can claim a mandate for his positions. Democrats, who picked up a couple of seats in the senate, the Lieutenant Governorship, and with a new Progressive/Democrat Senate President Pro Tem may see things differently. So the big question is, who’s going to blink?

On the carbon tax, Scott has the upper hand. The campaign illustrated just how unpopular the concept is with Vermonters. Minter tried to distance herself from the tax, but refused to totally renounce the idea as Scott did (no doubt hoping to avoid offending major donors to her campaign and her party). This straddle maneuver failed miserably, and Scott punished Minter relentlessly on the issue for months. Voters responded.

Sending a similar message, of the three incumbent Democrats who lost seats (as of this writing the Buxton/Ainsworth recount is still up in the air) two were sponsors of carbon tax legislation in the last session, Representatives Steve Berry of Manchester and Patsy French of Randolph. French had held her seat since 2003 and, until sponsoring the carbon tax, was considered bulletproof.

Since Republicans retained enough seats to sustain a Scott veto on their own, plus several Democratic candidates vociferously denounced the carbon tax in the run up to November 8th, and no politician in his/her right mind would possibly want to cast an official vote in favor of such a toxic policy, the carbon tax should be dead on arrival. However, VPIRG, the advocacy organization most aggressively pushing the carbon tax, still has quite a bit of influence in Montpelier, and deep pocketed donors to the majority party have a powerful financial interest in seeing the tax implemented. Don’t count them out yet.

Maintaining Vermont’s gun laws is another area where Scott will likely prevail without much of a fight. Though it’s hard to determine to what degree Second Amendment voters tipped the scales in Scott’s favor, it’s safe to say gun rights remains a third rail of Vermont politics. The anti-gun organization GunSense Vermont seems to be fading as a force and one has to wonder if legislators will have any appetite to make their issues a priority again in the near future.

Industrial Wind Development will be a bigger fight. Scott campaigned both as a candidate for governor and lieutenant governor advocating for a moratorium on industrial wind development. He also wants to give local communities greater say over how and where these projects are placed. This is, of course, a popular position with municipalities and homeowners that don’t want 500 foot wind turbines shoved down their throats.

However, Democrats are ideologically devoted to meeting their goal of getting 90 percent of Vermont’s energy from renewable sources by 2050, and wind turbines are a big part of that plan. David Blittersdorf of NRG Systems estimates that 200 miles of ridgelines will have to be developed with turbines to reach that goal. It doesn’t hurt that Blittersdorf donated over $100,000 to Democrats during the last election cycle, adding a powerful political motivation to battle Scott. Count on them to make a stand on this one.

Finally, there is the issue of the budget. This too will be a tough fight. Every year for the past half decade Montpelier has dealt with a budget gap of its own making by raising taxes and fees on Vermonters. Every year they have pushed forward with new programs and new spending despite the fact that we can’t afford the government we have in place. The legislative majority shows no signs of changing its ways, nor in their own races did the voters send them a message to do so.

So in roughly a month, the unstoppable Democratic legislature will hit the immovable Republican governor. Voters gave Phil Scott a mandate to scale back Montpelier’s influence in their lives and to put the state back on more fiscally responsible, “affordable” path. However, if Vermonters really want these things to become reality their support of the new governor must remain active and engaged. He’ll need lots of help from outside the State House in the days to come because he won’t get much help from within it.

- Rob Roper is president of the Ethan Allen Institute. 

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by John J Metzler

UNITED NATIONS—The tumultuous events which have swept the Mideast like a malevolent sandstorm have hardly abated; crises and conflict are now nearly entrenched. Thus looking back at the results of President Barack Obama’s two-term legacy, its clear we are facing a Mideast meltdown with dangerous and far reaching consequences for the region and the world at large.

In June 2009, speaking at Egypt’s Cairo University, Barack Obama made a far reaching and ambitions address to the Muslim world.   In a carefully crafted outreach, Obama began by offering his hope for a “new beginning between United States and Muslims around the world.”

The geopolitical Mideast map which the Obama Administration inherited was overshadowed by the ongoing conflicts in Iraq and Afghanistan. But even Obama admitted Afghanistan was “not a conflict of choice, but of necessity.” Iraq however presented the gordian knot for the new Administration to untie. In doing so he, and his former Secretary of State Hillary Clinton, unraveled the Middle East.

The Iraq Obama inherited was seemingly stable but with 144,000 American troops in country.

Saddam’s dictatorship was deposed. The 2007 Bush military surge had succeeded and Iraq was beginning to show long awaited signs of stability. But by a precipitous politically motivated withdrawal of U.S. forces, Obama’s policy mortgaged the hard won gains made through spilled blood and treasure and moreover allowed Iraq’s venal sectarian divide to dominate the Baghdad government.

While U.S. military brass and even many in the Administration believed in keeping a residual military force in country as a commitment to continued stability, the Baghdad rulers pressed for a complete withdrawal. Obama gladly obliged.

Thus the outcome, which witnessed the rise of ISIL, reflected a quick political fix rather than a commitment to long term stability. Key Iraqi cities fell to the Islamic militant insurgents. Fast forward. Now thousands of American special forces are back in Iraq trying to help the Iraqi military retake lost territory. We are still paying the price for Obama’s hasty withdrawal.

Iran in a sense represented a far more dangerous geopolitical challenge. The Islamic Republic’s nuclear weapons program as well as the regime’s state support of terrorism presented a long standing challenge to American policy. Obama’s multinational diplomatic “deal” reached with Tehran to presumably defuse the nuclear threat (primarily to Israel), remains just that a “deal” with a theocratic dictatorship who remains a clear and present danger to American, Israeli not to mention Arab Gulf interests.

Following the Iran “deal” the Obama Administration has dramatically loosened most economic sanctions and has literally sent planeloads of cash ($400 million) to the Islamic Republic to cover former frozen assets from the 1979 Islamic Revolution. Not surprisingly, Boeing is selling Iran Air scores of modern civil aircraft. You can’t make this up!

Egypt While much of the Mideast appeared strangely static, the Arab Spring exploded in Cairo in 2011. Pro-democracy demonstrations toppled the authoritarian but pro-American rule of President Hosni Mubarak ushering in a swirl of events which resulted in an elected but thuggish Muslim Brotherhood regime. Soon rising frustrations the following year led to a new military government in Cairo. Once close political ties between Cairo and Washington are destabilized.

Syria exploded in 2011 as demonstrations tried to topple the entrenched Assad Family regime, a secular but longtime Russian client. Syria’s original uprisings were probably democratic but soon were hijacked by hardline Islamic Al-Qaida forces. While Obama fiddled rhetorically while supporting the Syrian uprising, his Administration led from behind regarding decisive action. Before long Russia decided to support their longtime client. Over 500,000 people have been killed; Aleppo is a humanitarian hell. Millions of Syrians have become refugees, fleeing into neighboring Lebanon, Jordan and Turkey and flooding into Europe. There’s no end in sight.

Libya saw its longtime dictator Col. Gaddafi toppled by a series of tribal uprisings. Later the USA and France sent massive air support to help break in the impasse in the civil war. But what then? Radical jihadi militias burnt down the American consulate in Banghazi and killed four Americans including Ambassador Chris Stevens. Libya remains in chaos and serves as a conduit for refugee flows into Italy. While we are well rid of Gaddafi, what were Hillary Clinton’s State Department plans following the overthrow?

Yemen  Once touted as an Obama Administration’s socio-political success story, Yemen has descended into a dangerous spiral of conflict with amid sectarian divides. Saudi led coalition forces battle Iranian backed rebels. A UN official warned, “The state of Yemen is broken,” and there are 20 million people in need of humanitarian assistance.

Turkey   The once rock solid and reliable relationship between the USA and Turkey is threatened. Tragically Turkey’s once staunchly secular Republic is increasingly Islamic-lite under the authoritarian rule of President Erdogan. Ties with Washington are deeply frayed.

The Mideast suffers the aftershocks of Obama’s fundamentally failed foreign policy.

America’s new president inherits this geopolitical map.

- John J. Metzler is a United Nations correspondent covering diplomatic and defense issues. He is the author of Divided Dynamism The Diplomacy of Separated Nations: Germany, Korea, China

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“While social investing raises complex issues, public pension funds are not suited for this activity.” – Center for Retirement Research at Boston College

Last week, the Center for Retirement Research at Boston College released a new report examining the merit of using pension funds as a vehicle for social investing.  The paper looks at two fundamental questions: can ESG (environmental, social and governance) investing achieve the same returns as conventional allocations, and are public plans the appropriate forum to advance these goals.

The simple answer to both: No.

The Center for Retirement Research found what the professional investment community and Divestment Facts has known for years: making financial decisions for political purposes is not effective and impacts those dependent on the investment’s returns.  From the report:

While social investing raises complex issues, public pension funds are not suited for this activity. The effectiveness of social investing is limited, and it distracts plan sponsors from the primary purpose of pension funds – providing retirement security for their employees. Additionally, such activity involves a principal-agent problem since decision makers do not bear the risk of potential losses; rather, any losses will accrue to future beneficiaries and/or taxpayers.”

Though activists have ignored data and cherry pick timelines in order to make divestment look like the financially savvy thing to do, more prudent and long-term investors recognize that banning an entire sector is no way to manage a portfolio. As the report notes, “modern portfolio theory states that investors should diversify their asset holdings over a variety of securities so that their returns do not move in lockstep.”

As we know from Univ. of Chicago Law School Prof. Fischel’s study analyzing the impact of divestment on returns, the energy sector serves to diversify a portfolio and act as a hedge to maximize financial performance.  Without that exposure, Fischel found that a portfolio could lose more than 20 percent of its value over a 50-year timeframe.

The Center for Retirement Research found similar financial outcomes for portfolios that divested or focused on ESG investing.  The below table (excerpted from the report) shows clearly that conventional mutual funds outperformed ESG mutual funds over a one, five and ten year timeframe.

table 1

As seen in states like Vermont and California, there is an increased political push to force divestment on public pensions with legislation. This report found that such efforts are extremely detrimental to these pensions, and thus the beneficiaries, as “average annual returns of plans in states with divestment requirements are estimated to be 40 basis points lower than plans in states without such requirements.”

The report also determined a partial cause for these losses: high management fees by ESG fund managers. From the report:

“Part of the reason [for lower returns] is that the fees in the ESG funds are roughly 100 basis points higher than their Vanguard counterparts, which may reflect the additional resources required to perform the screening.”

figure 4

And what are these losses amounting to? According to the report, “the academic literature suggests that ESG screening is likely to have very little impact on the target company and that the impact on the pension fund depends on the scale of the screening.”  In translation, a state that goes down this path must be willing to forgo returns for pensioners to make a political statement that ultimately does nothing to impact targeted companies or the environment.

The report also points out the complexity of ESG investing, as the definition and focus is continually shifting.  What is important from an ESG standpoint this year may no longer be of interest five years down the road.  This leads to active managing and constant screening of investments.  As Prof. Hendrik Bessembinder found in his research, management and transaction fees are incredibly expensive, and could rob an endowment or pension of millions of dollars and up to 12 percent of its total value over a 20-year timeframe.

It is also important to remember the real purpose of the pension—to deliver benefits to pensioners.  According to the Center for Retirement Research, ESG investing presents a conflict of interest:

Social investing in public plans highlights a classic principal-agent problem in economics. The principals in this case are tomorrow’s pension beneficiaries and/or taxpayers: the people with skin in the game. The agents are the fund boards or state legislatures that make investment decisions on behalf of the principals. In theory, agents are supposed to act solely in the interests of the principals. In reality, especially in public plans, conflicts of interest may arise if state legislatures make investing decisions for political reasons. If social investing produces losses, tomorrow’s taxpayers will have to ante up or future retirees will receive lower benefits. The welfare of these future actors is not well represented in the decision-making process.” (emphasis added)

It’s clear that the symbolic act of divesting may generate some feel good headlines and may be applauded by activists, but at the end of the day, it inflicts more harm than good.

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John McClaughryby John McClaughry 

It now seems increasingly likely that most of President Obama’s signature achievement, ObamaCare, will end up on the scrap heap by the end of 2017, if not sooner.

Obama and his Democratic Congress rammed the Affordable Care Act through in 2010, without recognizing the likely consequences. In the ensuing five years, Obama has made numerous unilateral changes to the act to keep it from falling apart. Now President Trump can insist that the act be implemented exactly as written by the Democratic Congress and signed with great fanfare by Obama. That will be a death sentence.

In 2010 the for-profit health insurance industry agreed to support ObamaCare if Obama would abandon the progressive component, a government-owned “public option” company that would be able to undercut the premium rates of its (Federally regulated) competitors.

In addition, Obama also gave the industry a provision called “cost sharing reduction”. This was a Federal government promise to inject billions of dollars to reduce the cost of “Silver” benefit plans for lower-income Exchange purchasers.

But Congress didn’t appropriate any money for this purpose. So Obama snatched billions of dollars out of the tax credit refund program to make the payments. But that’s illegal, as a Federal District Court has already ruled (it’s on appeal).

If it’s illegal, the Trump administration can simply stop paying. Then at least some  insurance companies, facing an exodus of Exchange customers who can no longer afford Silver plans, will take advantage of another provision of the law to exit the program altogether.

And there’s more. The ObamaCare “risk corridor” program assessed most insurance companies to create a fund to bail out the ones that lost money by low-balling their premiums for unfamiliar customers under the new ObamaCare rules. The law requires that the first $5 billion of these assessments must be paid over to the Treasury.

Obama plans to divert the statutory $5 billion Treasury payment into more bailout dollars for the companies. The Government Accountability Office declared that that diversion is illegal.

Alternatively, Obama is now planning to take the needed money out of the Judgment Fund. This is a long-standing Treasury fund available to settle monetary judgments against the government. Obama’s intention is to settle the claims of the insurance companies that have sued, and presumably the others as well, and submit the settlement to court approval. This would avoid an unfavorable court ruling. It would also be another covert multibillion-dollar bailout to keep the insurance companies from jumping ship.

Trump doesn’t have to defy the Obama’s Affordable Care Act, or have Congress repeal it, to close out Obamacare and its recurring insurance industry bailouts. All he has to do is carry out the law as Obama and the Democratic Congress actually enacted it, and ObamaCare will then collapse. That would be a calamity for millions of Americans who could find themselves without health insurance.

The Republican Congress has vowed to prevent that calamity by passing a “smooth transition” act to put a new health care program in place. Trump has already said that “repeal” won’t end ObamaCare-mandated family coverage for children up to age 26, or the mandate that pre-existing conditions be covered at no extra charge.

Beyond that, Congress is likely to convert the Exchange premium tax credits to individual tax credits, repeal the tax penalty on those who fail to buy government-specified coverage (now $695 per adult), repeal the employer mandate, repeal the guaranteed issue and community rating mandates, liberalize access to Health Savings Accounts, and partially fund state high-risk pools to cover the uninsurable.

That’s not a complete program, of course, and there are problems with keeping the pre-existing condition provision that will require a creative solution.

What will this mean for Vermont? It’s too soon to say, since it depends on what replacement plan Congress and the President put into place. BlueCross/Blue Shield of Vermont, which insures over 90% of the individual and small group customers on Vermont Health Connect, has nowhere to go, and has become a “too big to fail” ward of the state. Medicaid, now covering over 184,000 Vermonters, will budget-wise remain “the monster that ate State Street”.

The future of Gov. Shumlin’s “All Payer” agreement with the Obama administration now depends on Gov. Phil Scott’s views on whether patient care and affordability will be improved by turning almost all health care in Vermont over to a statewide managed care monopoly called OneCare Vermont, whose care decisions will be controlled by a state-dictated global budget.

Vermont legislators, despite the chronic yearning of many for a single payer plan, should begin now to devise a new consumer-directed health care policy, built upon patient choice, price and outcome transparency, more legal protections for providers, and personal responsibility – instead of more government mandates, a medical provider monopoly, and ever-accumulating bureaucratic control.

- John McClaughry is vice president of the Ethan Allen Institute (www.ethanallen.org)  

 

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by Rob Roper

Governor Peter Shumlin was pretty much run out of town on a rail, nearly losing his election to Scott Milne in 2014 and, seeing the writing on the wall, declining to run in 2016. His would be successor, Sue Minter, got shellacked. And, a big reason for Shumlin’s demise was and is his utter failure and total mismanagement of healthcare reform.

Single payer was a long, drawn out, expensive disaster that ultimately failed to launch, and the Vermont Heath Connect website has cost taxpayers $200 million and it still does not work. Behind all of these disasters is Shumlin lackey and Director of Healthcare Reform, Robin Lunge.

However, the reward for all this costly incompetence (a symptom of arrogant, ideological blindness) is not a one way ticket out of town, but rather a six year, appointment to the Green Mountain Care Board — a job that requires 32 hours a week with an annual salary of $96,678.

Are… you… kidding… me…?

The Green Mountain Care Board was put in place to manage Vermont’s transition to a single payer healthcare model. That plan is dead, so, one might ask, is the GMCB even still around? If the body had any remaining vestige of credibility, it is gone with the flagrantly crony appointment of Lunge to its ranks. It is worth noting that Lunge replaces Dr. Alan Ramsay, and, as such there is no longer a single M.D. on the board that governs every aspect of our healthcare.

The new Scott administration will be coming into office facing a $50 – $70 million budget gap. One place to start filling that hole should be eliminating the Green Mountain Care Board and its budget from the state ledgers.

- Rob Roper is president of the Ethan Allen Institute

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by Rob Roper

The recent gubernatorial contest in Vermont featured a sharp contrast between the candidates on gun rights. Sue Minter was a proponent of more stringent regulations on firearms and firearm purchases, while Phil Scott insisted Vermont’s gun laws are fine just the way they are. Scott beat Minter by nine points.

To Scott’s argument, the latest statics from the FBI’s Uniform Crime Report once again place Vermont as the safest state in the union when considering crimes of murder, non-negligent manslaughter, rape, robbery, and aggravated assault with just 118 incidents per 100,000 residents (a total of 739) occurring in 2015. (Source: Burlington Free Press)

As has been pointed out on this site before, it is the states and cities that have the most restrictive laws regarding firearms that tend to be the most violent and experience the most crime, and how citizens who conceal-carry are the most law abiding on record. Why we would want to divert from something that is clearly working toward systems that are demonstrably dysfunctional is a bizarre notion. Apparently Vermonters agreed at the ballot box.

It will be interesting to see what happens with anti-firearm legislation in 2017. Will the Democrat majorities continue to press for expanded background checks and limits (or even outright bans) on semiautomatic firearms? Or will they drop it? A little time will tell.

Rob Roper is president of the Ethan Allen Institute. 

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by Rob Roper, 11/16/16

The real threat of voter fraud comes not from someone showing up at the polls claiming to be someone they’re not (though that’s certainly not good), but rather through the growing prevalence of absentee ballots.

How does the state or a town clerk know for sure that A) the person they sent an absentee ballot to is the person who actually requested it, B) that the absentee ballot was received by the person who was supposed to receive it, and C) that the ballot was filled out and returned by the voter authorized to do so? Answer: They don’t. No clue.

Vermont Watchdog recently ran a story on how absentee ballots could pose a major problem in our state in which the reporter posed some hypothetical situations for the Secretary of State’s office:

… someone wishing to commit fraud could request ballots without permission and have them sent to addresses where they can collect them and fill them out. When Watchdog posed that scenario to [Will] Senning [,director of elections], he admitted that the fraudster would “not necessarily” be caught.

Deborah Beckett, the Williston Town Clerk, confirmed, “Once a ballot leaves the office, you don’t know that it reaches the right person.” The reality is, the people running the elections and counting the votes have no way of knowing for sure if the people casting the votes are legitimate voters or not. So, how can these be considered valid votes?

Moreover, there is no way (barring luck) to identify if and/or how often fraud occurs. If someone did request an absentee ballot for someone else intending to commit fraud, and that voter did show up to the polls only to be told they had already voted absentee, would it be considered a clerical error or a crime? And if by chance a crime, how would authorities identify and catch the person who committed the crime? You probably couldn’t.

And, so officials like our Secretary of State, Jim Condos, say voter fraud doesn’t occur. But he has no clue whether it does or not because the system allows no way of knowing.

This is a big problem and getting bigger. 95,203 ballots in Vermont out of 320,467 were cast absentee. In North Carolina there is an investigation looking into fraudulent “absentee ballot mills” that could have impacted the outcome of their gubernatorial election. We’ll see what happens there.

But in the mean time the next legislature in Vermont should demand that systems be put in place to ensure our town clerks have the ability to prove that the votes they are counting are cast by voters who are who they say they are, and live where they say they live. Until that occurs, our elections are less than legitimate.

- Rob Roper is president of the Ethan Allen Institute

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by John McClaughry

One item of interest from last week’s  election was the decisive rejection of a carbon tax by voters in Washington State. As in Vermont, the carbon tax was promoted as a tool to combat the menace of climate change.

As reported in the Wall Street Journal, “the proposal would have imposed a new tax on gasoline and other fossil fuels and cut the state’s sales tax and taxes on manufacturers, while giving tax credits to low-income earners. It garnered only 41.5% of the vote after encountering opposition from some environmental groups as well as energy companies and large power users.”

“The Sierra Club, the Union of Concerned Scientists and some other environmental groups said they opposed it because they didn’t expect it to boost renewable energy. They also said the mix of tax increases and cuts would be a net negative for the state financially. Opponents pointed to an August analysis by the state Office of Financial Management that predicted the measure would reduce state revenue by $797 million in the first six years.”

The Washington Initiative was designed to be revenue neutral. By contrast, the Vermont carbon tax proposal is not revenue neutral. It proposed to grab ten percent of the revenues to subsidize renewable energy and weatherization projects, a net tax increase.

With Gov.-elect Phil Scott’s post-election reiteration of his vow to veto a carbon tax, VPIRG’s allies in Montpelier must be very discouraged.

- John McClaughry is vice president of the Ethan Allen Institute. 

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