Table Al: Main critics of carbon... | Emerald Publishing

Table Al:

Main critics of carbon pricing.

Authors (in alphabetical order)	Main Criticism (nrs. refer to Fig. 1)	Alternative instrument or strategy	Comments and previous responses
Aldred (2012)	5	None	Expresses ethical and justice arguments against emissions trading, which it regards morally objectionable as it “commodifies” the atmosphere and “prices that which is priceless”. However, what is “commodified” is not the atmosphere but substances (like CO2) which heat it up. Moreover, this objection overlooks that carbon pricing will generate revenues that can compensate inequitable impacts while guaranteeing effective (system-wide) and affordable emissions reduction.
Ball (2018a,b)	2,4,7,8	Phasing out coal, maintaining nuclear plants, making renewables cheaper. and mandating energy efficiency	States that in theory carbon pricing makes sense, but in practice it is failing. Emphasizes low coverage and price which is contradicted by current EU-ETS prices; carbon pricing tends to constrain emissions mostly in the electricity sector, leaving the transportation and building sectors largely unaffected: outdated as EU is expanding coverage to these. Generally, ignores evidence as we summarize in Table 1. Incorrectly states that carbon pricing “hits hardest” economically (i.e. causes the highest costs) whereas regulation really does so.
Böhm and Dhabi (2009), Böhm et al. (2012), Pearse and Böhm (2014)	1,2,3,4,5,7	None	Radical criticism aimed at “developing a framework for a Marxist analysis of carbon markets”. Uses many unusual concepts, several of which are cryptic (“loophole, corrupt, utopian, scientism, technocracy, metabolic rift, world ecology, and sub-imperialism”). No comparison with alternative instruments on these “criteria”. Approach is normative rather than analytical and empirical; one-sided, i.e. ignores or plays down any positive effects of carbon markets; and incorrectly equates carbon offsets with carbon markets (Purdon, 2018).
Cullenward and Victor (2020)	2,7,8	Industrial policy, minor role for carbon pricing	Offers a critical perspective on carbon markets with a lot of data on their functioning, focussing on the EU and the USA. Unbalanced in terms of criteria and comparison with other instruments. Neglects that non-pricing instruments have not good emissions coverage either. “Potemkin markets with low prices” was clearly written just before EU-ETS reached considerably higher prices. Neglects the policy performance criteria of rebound and international harmonization. Critical reviews by Bauman (2021) and Weil (2021). Claims about emissions trading in California and Quebec, which form an important element of the authors’ argument, are challenged by findings of Purdon et al. (2021). In a more positive review about the criticisms Tutt (2021) notes about their alternative proposal of industrial policy: “exposes them to the same political meddling by interest groups that weakened ETSs” concluding that “the book overstates its ability to provide effective alternatives”.
Green (2021a)	2,3,4,6,7	State to create public goods (not just prevent public bads). Remove offshore tax havens to reduce cooperate tax evasion	Considers carbon pricing as too much focus on market failure rather than societal transformation. Proposes “we need to think bigger” and “aggressive climate policy begins with a reassertion of state sovereignty”. It is unclear how this will guarantee either effective emissions reduction or political feasibility — rather the opposite as more radical and quick changes will invite for strong resistance. Major part of the paper is about multinational corporations using offshore tax havens to avoid paying taxes. It is not made clear that this is the main factor behind emissions though. Fine to fight offshoring, but unclear that thus reducing firms’ profits is an effective approach to reducing emissions.
Huwe and Frick (2022)	1,2,5	“Sustainable consumption corridors”	Focus on disproving optimality but does not refute effectiveness of carbon pricing. A long discussion about “what constitutes well-being?” where the essential point seems to be that “an important channel for decarbonization overlooked by carbon pricing: the planned phase-out of less essential production.” This does not acknowledge that carbon pricing assures that carbon-intensive activities which have no technical solution and do not produce highly valued goods will become more expensive and thus less popular, so will be gradually phased-out. Of course, production might shift to other countries with weaker policies, but this holds regardless of the instrument (carbon pricing or other), although this can be discouraged through border carbon adjustment tariffs. The authors further claim: “utilitarian assessment of costs and benefits underlying the rationale for carbon pricing does not recognize any objective reference point, neither in terms of biophysical limits nor minimum requirements of social justice.” However, this overlooks that the cap in an ETS may be chosen to reflect biophysical limits accepted by science.
Lejano et al. (2020)	5	None	The only paper here with an original empirical analysis of emissions from refineries participating in California’s cap-and-trade program to test if “carbon trading can have unanticipated disequities” as “emitters are disproportionately sited in so-called environmental justice communities”. Suggests tradeable carbon-emission permits create “hotspots” of “air toxics”. This short and superficial paper lacks a serious analysis to underpin its bold statements — notice its disclaimer “we do not include any tests of statistical significance for such a small sample size.” It further neglects the fundamental reason for any “problem shifting”, namely lack of effective environmental policies on “air toxics”.
Lilliestam et al. (2021)	2,3,4,7	Innovation policy	Although presented as a review, this actually is closer to an opinion article because it involved many subjective and debatable choices in the research; a detailed evaluation by van den Bergh and Savin (2021), a reaction (Lilliestam et al., 2022) and rejoinder (van den Bergh and Savin, 2023) show it contains a variety of errors, omissions, and misinterpretations which result in underplaying the innovation impact of carbon pricing.
Markard and Rosenbloom (2020)	2,4,6,8	Renewable energy policies, policy mix in which carbon pricing is a modest element	Argues that EU-ETS serves as “a trojan horse — a strategy to divert attention from, and fend off, more ambitious climate action in the form of complementary renewable energy policies (a similar point to the more general article by Swyngedouw, 2010; see also the evaluation by Bryant, 2016).” They assess positions in public consultations on the EU ETS and Renewable Energy Directive for 12 industry associations, six firms, and four environmental non-governmental organizations. They state (p. 11): “of the actors who advance this position, we also found a subset who articulate a very low commitment to climate action. and perhaps most telling, they also maintain that the ETS should remain weak”. But the latter does not apply to the current high prices of EU-ETS, so their point remains unproven. Also unclear why they suggest renewable energy policy as the alternative as this already exists, and as this excludes all other sectors and households.
Tvinnereim and Mehling (2018)	2,4,6,8	Technology phase-outs and clean technology subsidies; policy mix with a modest role for carbon pricing	Considers climate change as caused by many market failures, calling for a portfolio of policy instruments. This is not accurate — other failures than externalities hamper a good solution perhaps, but do not cause climate change. They call for a portfolio of policy instruments (innovation, regulation, subsidies) but this is the reality already in most countries — which has not provided a clear solution. So not only carbon pricing is to blame it seems. “To date, there is little evidence that carbon pricing has produced deep emission reductions, even at high prices.” But there were few high carbon prices before 2018. The authors stress efficiency and underplay effectiveness, while confusing low prices with small effects.
Mildenberger and Stokes (2020)	1,2,3,4,5,6,7,8	Lacks a clear message, instead many different statements: “bolder approach that centers the politics of climate change”; “standards, investments, and justice”; “large-scale industrial policy”; “never-ending legal battles to force fossil fuel companies to..negotiate a meaningful climate deal”.	Very long article in a popular magazine without headings and without clear structure. Anecdotal style providing only negative examples (cherry-picking), instead of looking systematically at the empirical evidence. Lots of rhetoric, e.g. “As climate change research grew more prominent in the 1980s, economists described pollution as a “negative externality” — polluters kept the profits from selling fossil fuels while society at large picked up the tab for the harm they caused.”, which completely misrepresents the idea of internalizing externalities. Suggests about carbon pricing “But as a short-term political strategy, it’s deeply flawed.” but also “The problem with carbon pricing is not the idea on paper — it is its application in practice.” Pessimism derives mostly from North America. Incorrectly equates rising emission trends with no effect, in the absence of a counterfactual. No fair comparison with other instruments. Simplifies: “is more politically powerful to shut down a coal plant than it is to have everyone turn off their lights more often”. Despite such a long text, no accounting for life-cycle effects and carbon/energy rebound. They incorrectly suggest that fossil fuel companies are participants in LTNFCCC negotiations for climate agreement. Say “the government should spend trillions of dollars on clean energy in the coming decade” — fine, but this simplifies the whole problem to renewables, as without carbon pricing energy growth will be high, especially relevant given low energy prices in the LTSA. Critical reviews by Komanoff (2020) and Majkut (2020).
Patt and Lilliestam (2018)	2,3,4,7	Technology support policies	“The time for incremental climate policy has passed. If the United States had adopted a carbon price in 1990, we would be in a very different world today. But fossil fuel companies and other big polluters resisted this approach.” So they suggest that “carbon prices are outdated”. Think that attacking so-called “neoclassical economics” suffices to cast doubts on carbon pricing. But support for carbon pricing comes theoretically and empirically from many corners beyond neoclassical economics. The paper overlooks positive evidence on effectiveness of carbon pricing. A critical review of this paper is by Kirchner et al. (2018).
Rosenbloom et al. (2020a)	1,2,3,6,8	Innovation policy and a policy mix with a modest role for carbon pricing	Use multilevel transitions theory, which downplays the role of prices. Big terms like “fundamental changes in existing sociotechnical systems”. Simplifies the impact of carbon pricing, and ignores the many changes it sets in motion, on demand and supply sides, involving consumers, producers, investors, and innovators. Makes the useful point that “system dimensions” like technologies and infrastructure contribute to lock-in and need additional strategies, such as infrastructure and innovation policies. However, despite professed systems perspective no clear explanation of what system-wide policy really means, and in line with this fails to acknowledge that it is not true that carbon pricing “places particular weight on efficiency as opposed to effectiveness.” In fact, something cannot be efficient if it is not effective in the first place. Indeed, the systemic nature of carbon pricing assures that cumulative price effects in production chains and life cycles of products/services will discourage emissions everywhere (including in production/purchase and use phases) and moreover limit rebound, thus resulting in a very effective approach. Rosenbloom et al. do not value efficiency much, not realizing that inefficient policies contribute, however, to less emissions reduction for a given cost, lower incomes, and unemployment — which will hamper stable political support for a low-carbon transition. Critically reviewed by van den Bergh and Botzen (2020, 2023), rejoinder by Rosenbloom et al. (2020b).
Spash (2010)	1,2,3,5,7	“Changing human behaviour, institutions and infrastructure”	Aims to show how the reality of permit market operation is far removed from the assumptions of economic theory and the promise of saving resources. Concludes that the focus on such markets is creating a distraction from the need for changing human behaviour, institutions, and infrastructure. Suggests that that it is not possible to prove efficiency given the all-pervasive character of greenhouse gases which means that carbon pricing will affect all the prices in the economy. But this is exactly the purpose of carbon pricing while the statement ignores that the evidence for efficiency (and effectiveness) is supported, among others, by general equilibrium theory which accounts for interactions between sectors and markets. Emphasizes influence of “corporate power” on “market operation” and “crowding-out of voluntary action”, but no support from empirical studies of carbon markets; in all fairness, it was too early at the time to observe the actual impact of carbon markets, which causes this paper to be dated. Regarding crowding-out it is overlooked that emissions are likely to decrease more by regulating and creating some crowding-out than by relying solely on voluntary behaviour. Many far-fetched points that make one lose sight of the main argument, e.g. “placing permits on electricity generating sources first will have different outcomes compared to placing them on transport sectors first” or “a statistically recognizable number of people may die in the process of implementing control strategies”). The paper ends with a long discussion of voluntary action and “growing voluntary carbon credit sector” — an unclear term and notion, which remains vague and seems the topic for another paper. The author’s employer at the time was critical of this study (Pincock, 2009).
Verbruggen (2021)	1,2,3,4,7	The author seems most positive about feed-in tariffs	“This book clarifies the pricing issues via two scientific channels and then calls to Act Now. The first channel is a critical review of carbon pricing with standard economic analysis as lens and toolbox. The second channel is a political economy analysis of EU ETS, a study of rational decision-making by a kaleidoscope of actors in a context of political and economic institutions, ideas, interests, and infrastructures. Finally, the research and findings are placed in a framework of disruptive and urgent policies to Act Now because Climate Change may turn into irreversible Climate Collapse.” A very idiosyncratic take on the EU-ETS. Criticizes a strawman, i.e. an outdated depiction of EU-ETS. Although the author is an economist, he makes statements that counter a basic insight of environmental economics, namely that heterogeneity in abatement options and costs makes uniform pricing useful as it selects the cheapest emission reduction options. Another unfounded statement is “Carbon pricing does not induce innovation” which lacks nuance and overlooks empirical evidence (Table 1) and the steadily rising EU-ETS price since 2020 to high levels. Odd writing style with sudden jumps, many bold and broad statements (e.g. “Progress in Act Now depends on the successful reclaiming of the paradigm of sustainable development with the substance of Our Common Future.”), and odd formulations (e.g. “electricity economic theory”). No attention for carbon/energy rebound despite a book-length treatment and mention of it as a relevant policy performance criterion (1d) in its Table A2. No quantitative information is offered to support any statement — all conceptual and opinionated.

Authors (in alphabetical order)	Main Criticism (nrs. refer to Fig. 1)	Alternative instrument or strategy	Comments and previous responses
Aldred (2012)	5	None	Expresses ethical and justice arguments against emissions trading, which it regards morally objectionable as it “commodifies” the atmosphere and “prices that which is priceless”. However, what is “commodified” is not the atmosphere but substances (like CO2) which heat it up. Moreover, this objection overlooks that carbon pricing will generate revenues that can compensate inequitable impacts while guaranteeing effective (system-wide) and affordable emissions reduction.
Ball (2018a,b)	2,4,7,8	Phasing out coal, maintaining nuclear plants, making renewables cheaper. and mandating energy efficiency	States that in theory carbon pricing makes sense, but in practice it is failing. Emphasizes low coverage and price which is contradicted by current EU-ETS prices; carbon pricing tends to constrain emissions mostly in the electricity sector, leaving the transportation and building sectors largely unaffected: outdated as EU is expanding coverage to these. Generally, ignores evidence as we summarize in Table 1. Incorrectly states that carbon pricing “hits hardest” economically (i.e. causes the highest costs) whereas regulation really does so.
Böhm and Dhabi (2009), Böhm et al. (2012), Pearse and Böhm (2014)	1,2,3,4,5,7	None	Radical criticism aimed at “developing a framework for a Marxist analysis of carbon markets”. Uses many unusual concepts, several of which are cryptic (“loophole, corrupt, utopian, scientism, technocracy, metabolic rift, world ecology, and sub-imperialism”). No comparison with alternative instruments on these “criteria”. Approach is normative rather than analytical and empirical; one-sided, i.e. ignores or plays down any positive effects of carbon markets; and incorrectly equates carbon offsets with carbon markets (Purdon, 2018).
Cullenward and Victor (2020)	2,7,8	Industrial policy, minor role for carbon pricing	Offers a critical perspective on carbon markets with a lot of data on their functioning, focussing on the EU and the USA. Unbalanced in terms of criteria and comparison with other instruments. Neglects that non-pricing instruments have not good emissions coverage either. “Potemkin markets with low prices” was clearly written just before EU-ETS reached considerably higher prices. Neglects the policy performance criteria of rebound and international harmonization. Critical reviews by Bauman (2021) and Weil (2021). Claims about emissions trading in California and Quebec, which form an important element of the authors’ argument, are challenged by findings of Purdon et al. (2021). In a more positive review about the criticisms Tutt (2021) notes about their alternative proposal of industrial policy: “exposes them to the same political meddling by interest groups that weakened ETSs” concluding that “the book overstates its ability to provide effective alternatives”.
Green (2021a)	2,3,4,6,7	State to create public goods (not just prevent public bads). Remove offshore tax havens to reduce cooperate tax evasion	Considers carbon pricing as too much focus on market failure rather than societal transformation. Proposes “we need to think bigger” and “aggressive climate policy begins with a reassertion of state sovereignty”. It is unclear how this will guarantee either effective emissions reduction or political feasibility — rather the opposite as more radical and quick changes will invite for strong resistance. Major part of the paper is about multinational corporations using offshore tax havens to avoid paying taxes. It is not made clear that this is the main factor behind emissions though. Fine to fight offshoring, but unclear that thus reducing firms’ profits is an effective approach to reducing emissions.
Huwe and Frick (2022)	1,2,5	“Sustainable consumption corridors”	Focus on disproving optimality but does not refute effectiveness of carbon pricing. A long discussion about “what constitutes well-being?” where the essential point seems to be that “an important channel for decarbonization overlooked by carbon pricing: the planned phase-out of less essential production.” This does not acknowledge that carbon pricing assures that carbon-intensive activities which have no technical solution and do not produce highly valued goods will become more expensive and thus less popular, so will be gradually phased-out. Of course, production might shift to other countries with weaker policies, but this holds regardless of the instrument (carbon pricing or other), although this can be discouraged through border carbon adjustment tariffs. The authors further claim: “utilitarian assessment of costs and benefits underlying the rationale for carbon pricing does not recognize any objective reference point, neither in terms of biophysical limits nor minimum requirements of social justice.” However, this overlooks that the cap in an ETS may be chosen to reflect biophysical limits accepted by science.
Lejano et al. (2020)	5	None	The only paper here with an original empirical analysis of emissions from refineries participating in California’s cap-and-trade program to test if “carbon trading can have unanticipated disequities” as “emitters are disproportionately sited in so-called environmental justice communities”. Suggests tradeable carbon-emission permits create “hotspots” of “air toxics”. This short and superficial paper lacks a serious analysis to underpin its bold statements — notice its disclaimer “we do not include any tests of statistical significance for such a small sample size.” It further neglects the fundamental reason for any “problem shifting”, namely lack of effective environmental policies on “air toxics”.
Lilliestam et al. (2021)	2,3,4,7	Innovation policy	Although presented as a review, this actually is closer to an opinion article because it involved many subjective and debatable choices in the research; a detailed evaluation by van den Bergh and Savin (2021), a reaction (Lilliestam et al., 2022) and rejoinder (van den Bergh and Savin, 2023) show it contains a variety of errors, omissions, and misinterpretations which result in underplaying the innovation impact of carbon pricing.
Markard and Rosenbloom (2020)	2,4,6,8	Renewable energy policies, policy mix in which carbon pricing is a modest element	Argues that EU-ETS serves as “a trojan horse — a strategy to divert attention from, and fend off, more ambitious climate action in the form of complementary renewable energy policies (a similar point to the more general article by Swyngedouw, 2010; see also the evaluation by Bryant, 2016).” They assess positions in public consultations on the EU ETS and Renewable Energy Directive for 12 industry associations, six firms, and four environmental non-governmental organizations. They state (p. 11): “of the actors who advance this position, we also found a subset who articulate a very low commitment to climate action. and perhaps most telling, they also maintain that the ETS should remain weak”. But the latter does not apply to the current high prices of EU-ETS, so their point remains unproven. Also unclear why they suggest renewable energy policy as the alternative as this already exists, and as this excludes all other sectors and households.
Tvinnereim and Mehling (2018)	2,4,6,8	Technology phase-outs and clean technology subsidies; policy mix with a modest role for carbon pricing	Considers climate change as caused by many market failures, calling for a portfolio of policy instruments. This is not accurate — other failures than externalities hamper a good solution perhaps, but do not cause climate change. They call for a portfolio of policy instruments (innovation, regulation, subsidies) but this is the reality already in most countries — which has not provided a clear solution. So not only carbon pricing is to blame it seems. “To date, there is little evidence that carbon pricing has produced deep emission reductions, even at high prices.” But there were few high carbon prices before 2018. The authors stress efficiency and underplay effectiveness, while confusing low prices with small effects.
Mildenberger and Stokes (2020)	1,2,3,4,5,6,7,8	Lacks a clear message, instead many different statements: “bolder approach that centers the politics of climate change”; “standards, investments, and justice”; “large-scale industrial policy”; “never-ending legal battles to force fossil fuel companies to..negotiate a meaningful climate deal”.	Very long article in a popular magazine without headings and without clear structure. Anecdotal style providing only negative examples (cherry-picking), instead of looking systematically at the empirical evidence. Lots of rhetoric, e.g. “As climate change research grew more prominent in the 1980s, economists described pollution as a “negative externality” — polluters kept the profits from selling fossil fuels while society at large picked up the tab for the harm they caused.”, which completely misrepresents the idea of internalizing externalities. Suggests about carbon pricing “But as a short-term political strategy, it’s deeply flawed.” but also “The problem with carbon pricing is not the idea on paper — it is its application in practice.” Pessimism derives mostly from North America. Incorrectly equates rising emission trends with no effect, in the absence of a counterfactual. No fair comparison with other instruments. Simplifies: “is more politically powerful to shut down a coal plant than it is to have everyone turn off their lights more often”. Despite such a long text, no accounting for life-cycle effects and carbon/energy rebound. They incorrectly suggest that fossil fuel companies are participants in LTNFCCC negotiations for climate agreement. Say “the government should spend trillions of dollars on clean energy in the coming decade” — fine, but this simplifies the whole problem to renewables, as without carbon pricing energy growth will be high, especially relevant given low energy prices in the LTSA. Critical reviews by Komanoff (2020) and Majkut (2020).
Patt and Lilliestam (2018)	2,3,4,7	Technology support policies	“The time for incremental climate policy has passed. If the United States had adopted a carbon price in 1990, we would be in a very different world today. But fossil fuel companies and other big polluters resisted this approach.” So they suggest that “carbon prices are outdated”. Think that attacking so-called “neoclassical economics” suffices to cast doubts on carbon pricing. But support for carbon pricing comes theoretically and empirically from many corners beyond neoclassical economics. The paper overlooks positive evidence on effectiveness of carbon pricing. A critical review of this paper is by Kirchner et al. (2018).
Rosenbloom et al. (2020a)	1,2,3,6,8	Innovation policy and a policy mix with a modest role for carbon pricing	Use multilevel transitions theory, which downplays the role of prices. Big terms like “fundamental changes in existing sociotechnical systems”. Simplifies the impact of carbon pricing, and ignores the many changes it sets in motion, on demand and supply sides, involving consumers, producers, investors, and innovators. Makes the useful point that “system dimensions” like technologies and infrastructure contribute to lock-in and need additional strategies, such as infrastructure and innovation policies. However, despite professed systems perspective no clear explanation of what system-wide policy really means, and in line with this fails to acknowledge that it is not true that carbon pricing “places particular weight on efficiency as opposed to effectiveness.” In fact, something cannot be efficient if it is not effective in the first place. Indeed, the systemic nature of carbon pricing assures that cumulative price effects in production chains and life cycles of products/services will discourage emissions everywhere (including in production/purchase and use phases) and moreover limit rebound, thus resulting in a very effective approach. Rosenbloom et al. do not value efficiency much, not realizing that inefficient policies contribute, however, to less emissions reduction for a given cost, lower incomes, and unemployment — which will hamper stable political support for a low-carbon transition. Critically reviewed by van den Bergh and Botzen (2020, 2023), rejoinder by Rosenbloom et al. (2020b).
Spash (2010)	1,2,3,5,7	“Changing human behaviour, institutions and infrastructure”	Aims to show how the reality of permit market operation is far removed from the assumptions of economic theory and the promise of saving resources. Concludes that the focus on such markets is creating a distraction from the need for changing human behaviour, institutions, and infrastructure. Suggests that that it is not possible to prove efficiency given the all-pervasive character of greenhouse gases which means that carbon pricing will affect all the prices in the economy. But this is exactly the purpose of carbon pricing while the statement ignores that the evidence for efficiency (and effectiveness) is supported, among others, by general equilibrium theory which accounts for interactions between sectors and markets. Emphasizes influence of “corporate power” on “market operation” and “crowding-out of voluntary action”, but no support from empirical studies of carbon markets; in all fairness, it was too early at the time to observe the actual impact of carbon markets, which causes this paper to be dated. Regarding crowding-out it is overlooked that emissions are likely to decrease more by regulating and creating some crowding-out than by relying solely on voluntary behaviour. Many far-fetched points that make one lose sight of the main argument, e.g. “placing permits on electricity generating sources first will have different outcomes compared to placing them on transport sectors first” or “a statistically recognizable number of people may die in the process of implementing control strategies”). The paper ends with a long discussion of voluntary action and “growing voluntary carbon credit sector” — an unclear term and notion, which remains vague and seems the topic for another paper. The author’s employer at the time was critical of this study (Pincock, 2009).
Verbruggen (2021)	1,2,3,4,7	The author seems most positive about feed-in tariffs	“This book clarifies the pricing issues via two scientific channels and then calls to Act Now. The first channel is a critical review of carbon pricing with standard economic analysis as lens and toolbox. The second channel is a political economy analysis of EU ETS, a study of rational decision-making by a kaleidoscope of actors in a context of political and economic institutions, ideas, interests, and infrastructures. Finally, the research and findings are placed in a framework of disruptive and urgent policies to Act Now because Climate Change may turn into irreversible Climate Collapse.” A very idiosyncratic take on the EU-ETS. Criticizes a strawman, i.e. an outdated depiction of EU-ETS. Although the author is an economist, he makes statements that counter a basic insight of environmental economics, namely that heterogeneity in abatement options and costs makes uniform pricing useful as it selects the cheapest emission reduction options. Another unfounded statement is “Carbon pricing does not induce innovation” which lacks nuance and overlooks empirical evidence (Table 1) and the steadily rising EU-ETS price since 2020 to high levels. Odd writing style with sudden jumps, many bold and broad statements (e.g. “Progress in Act Now depends on the successful reclaiming of the paradigm of sustainable development with the substance of Our Common Future.”), and odd formulations (e.g. “electricity economic theory”). No attention for carbon/energy rebound despite a book-length treatment and mention of it as a relevant policy performance criterion (1d) in its Table A2. No quantitative information is offered to support any statement — all conceptual and opinionated.