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 Since Russia attacked Ukraine two months ago, Western 
governments have been learning the hard way about the critical importance of 
energy to their national security. Germany’s 20-year, trillion-dollar 
“Energiewende” (Energy Transformation) has made its economy totally dependent on 
supplies of Russian natural gas and paralyzed its response to Russian 
aggression. French president Emmanuel Macron faces a tougher re-election fight 
this month thanks to soaring energy prices and failure to replace the nation’s 
aging fleet of nuclear power stations. The Biden administration is tapping 
America’s Strategic Petroleum Reserve in an effort to tamp down energy costs as 
inflation heads toward double digits. As the West grapples with the energy implications of a hostile 
Sino-Russian alliance, the steering group of the Net-Zero Asset Owner Alliance, 
whose members manage over $10.4 trillion of assets, issued a statement urging 
Western governments not to sacrifice climate goals for energy security.
 “The world is still heading for an excess of fossil fuel-based energy use that 
will vastly exceed the carbon budget needed to meet the 1.5° Celsius Paris 
agreement goal. This trend must be halted,” the United Nations-backed alliance 
said in its April 8 statement, arguing that “the national security argument for 
accelerating the net-zero transition has strengthened considerably.”
 
 What, one might ask, is the standing of asset managers to opine on national 
security matters? They have no expertise in this domain. It turns out that their 
understanding of the economics of energy policy is defective, too.
 The Net-Zero Asset Owner Alliance claims that development of new oil and gas 
reserves will lock in fossil fuel subsidies, exacerbating market distortions. In 
fact, the International Energy Agency (IEA) in its 2021 net-zero report states 
that under its net-zero pathway, tax revenues from oil and gas retail sales fall 
by about 40% over the next 20 years. “Managing this decline will require 
long-term fiscal planning and budget reforms,” the IEA warns. Similarly, 
Britain’s Office of Budget Responsibility estimates that net zero policies will 
result in the loss of tax receipts representing 1.6% of GDP. So much for the 
fossil fuel subsidy myth. If fossil fuels were heavily subsidized, eliminating 
them would mean fossil fuel subsidies disappear. Instead, it’s tax revenues that 
would melt away to zero.
 
 The net-zero investors cite figures for the decline in solar and wind energy 
costs. These numbers are based on so-called levelized cost of energy (LCOE), a 
metric that aims to measure a plant’s lifetime costs. Wind and solar power are 
intermittent, but LCOE metrics exclude the costs of intermittency, which 
increase the more wind and solar are put on the grid. Because wind and solar 
output responds to weather and not to demand, the value of this output declines 
the more installed wind and solar capacity is available. It was for these 
reasons that MIT professor of economics Paul Joskow concluded in a foundational 
2011 paper that using LCOE metrics to compare intermittent and dispatchable 
generating technologies, such as coal and natural gas, is a “meaningless 
exercise.”
 
 Wind and solar investors don’t need to understand the economics of the grid to 
make money – they are shielded from the intermittency costs their investments 
inflict on the rest of the grid, which is one reason why their views on energy 
policy can be taken with a pinch of salt. Their economic illiteracy does, 
however, make it easy for them to subscribe to the green fairy tale of 100% 
renewables. They’re not responsible for keeping the lights on – that depends on 
traditional power plants staying fueled up and ready to spin, which is what 
Germany can’t do without Russian gas. Adopt the net-zero alliance’s call for no 
new fossil-fuel investment, and the cost of energy is bound to spiral. And if 
the lights go out, politicians – not woke investors – get the blame.
 
 Investors’ opinions on energy and national security would 
matter less if they didn’t have political power. Bloomberg opinion writer Matt 
Levine argues that asset managers of giant funds form a parallel system of 
government that exercises overlapping legislative powers with those of 
governments. These government-by-asset-managers, as Levine calls them, tell 
companies to do things they think are good for society as a whole, “making big 
collective decisions about how society should be run, not just business 
decisions but also decisions about the environment and workers’ rights and 
racial inequality and other controversial political topics.”[to top of second column]
 
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  Foremost among these areas is climate policy. 
			Although the Biden administration has set a net-zero goal, Congress 
			has not legislated it, and it lacks the force of law. The absence of 
			legislation passed by democratically accountable legislators, 
			however, presents no barrier to government-by-asset-managers 
			legislating climate policy for the companies in which they invest. 
			“Investors are making net zero commitments for themselves and 
			demanding that companies issue greenhouse gas reduction targets and 
			transition plans for meeting those targets,” says the Reverend 
			Kirsten Snow Spalding of the not-for-profit Ceres Investor Network 
			on Climate Risk and Sustainability.
 Neither Spalding nor the Net-Zero Asset Owner Alliance make a case 
			that forcing net-zero targets on companies will boost investor 
			returns, demonstrating that this is not about investors’ traditional 
			concerns – making money – but about pursuing politics by other 
			means. In this, the Securities and Exchange Commission (SEC) is 
			working hand in glove with woke climate investors. Commenting on the 
			SEC’s newly proposed rule on climate-risk disclosure, Spalding says 
			that for investors who have committed zero emissions by 2050, “this 
			draft rule is absolutely critical.”
 
 It’s no coincidence that SEC Chair Gary Gensler chose Ceres to make 
			his first appearance to talk about the SEC’s proposed rule. Of 
			course, Gensler didn’t justify it in the same terms as Spalding. To 
			have done so would have heightened the risk of the courts striking 
			down the rule in subsequent litigation. Instead, Gensler attempted 
			to justify the rule as bringing “some standardization to the 
			conversation” and putting material climate information – the SEC 
			issued guidance in 2010 on how companies should disclose such risks 
			– in one place, saving investors the bother of piecing together the 
			information from different sources. Gensler’s explanation, to put it 
			politely, is an implausible one for imposing on corporate America 
			what amounts to a parallel climate-reporting regime to the 
			established framework of financial reporting. Whatever Gensler might 
			say in public, the effect of the SEC rule – if implemented – would 
			be to empower investors to impose net-zero targets on companies, to 
			monitor progress in meeting them, and to hold company boards to 
			account for them.
 
			
			 Unlike elected politicians, woke climate investors 
			are not accountable for the effects of their climate policies: They 
			exercise power without responsibility. This arrangement weakens 
			America’s ability to respond to the geopolitical challenges of a 
			revanchist Russia and an expansionist China. “We are on a war 
			footing – an emergency,” Energy Secretary Jennifer Granholm declared 
			at the CERA energy conference in Houston last month. “We have to 
			responsibly increase short-term supply where we can right now to 
			stabilize the market and to minimize harm to American families.” 
			Addressing oil executives in the audience, Granholm told them: “I 
			hope your investors are saying these words to you as well: In this 
			moment of crisis, we need more supply ... right now, we need oil and 
			gas production to rise to meet current demand.”
 As Granholm suggested, woke investors have been trying to do the 
			opposite. Despite the war in Ukraine, there has been no let-up in 
			investor pressure on oil and gas companies to scale down their 
			operations. Whatever criticisms might be made of the Biden 
			administration’s handling of the war in Ukraine, it is responsible 
			for taking the awesome decisions that war involves. Investors, by 
			contrast, have no responsibility for the nation’s security and 
			America’s ability to lead the West. By helping investors impose 
			their desired energy policies on American oil and gas companies, the 
			SEC is undermining the national security prerogatives of the Biden 
			administration and eroding America’s ability to meet the challenges 
			of a dangerous world. The SEC is playing in a domain that it has no 
			business being in.
 
			
			Rupert Darwall is a senior fellow at 
			RealClearFoundation, researching issues from international climate 
			agreements to the integration of environmental, social, and 
			governance (ESG) goals in corporate governance. He has also written 
			extensively for publications on both sides of the Atlantic, 
			including The Spectator, Wall Street Journal, National Review, and 
			Daily Telegraph. |