This paper analyzes changes in U.S. energy-intensive, trade-exposed (EITE) manufacturing over the past decade, through the lens of previously proposed climate policy measures. The American Clean Energy and Security Act of 2009 defined measures and thresholds for EITE eligibility and proposed compensatory allowances designed to reduce negative competitive impacts to domestic industry and to prevent emissions leakage. We undertook a retrospective analysis of the 2009 eligibility criteria, using the same methods with more recent data to examine trends over the 2004-2017 period. We find that energy intensity, emissions intensity, output, and emissions have fluctuated with economic conditions, and defining measures and thresholds that remain informative is challenging. Had ACES been enacted as written and not revised, the number of sectors qualifying for rebates would have decreased from 39 to 26, after adjustment for the changes in North American Industry Classification System definitions. Emissions from the eligible sectors fell 26% across the three periods of analysis, while emissions from manufacturing as a whole fell 5%. We decompose the changes in emissions into scale and intensity measures based on a hybrid measure derived from Grossman and Krueger [(1993). Environmental impacts of a North American free trade agreement. In The US-Mexico Free Trade Agreement, PM Garber (ed.). Cambridge, MA: MIT Press] and Kaya and Yokoburi [(1997). Environment, Energy, and Economy: Strategies for Sustainability. Tokyo: United Nations University Press]. As an alternative, we perform the same analyses using the EPA's Greenhouse Gas Reporting Program data. These data, not available when ACES was written, offer annual greenhouse gas estimates for facilities that emit more than 25,000 tons CO2e annually. Finally, we draw some recommendations for future policy including (1) using measures that make price level adjustments straightforward or unnecessary, (2) keeping EITE policy focused on a small group of industries to minimize sectoral reclassification problems, (3) identifying industries prone to emissions leakage rather than just changes in output and (4) consider spatial heterogeneity of emissions and trade patterns.
Keywords: Energy; Environment; Environmental Economics.