Response to Skip Stiles on Carbon Taxes and Environmental Offsets
February 2024
Skip Stiles wrote in the Daily Press advocating for a carbon tax, modeled in part on environmental offset programs, as a means to reduce carbon emissions. I appreciate the intent behind your argument. However, based on direct professional experience, I must disagree with the approach and caution against repeating mistakes Virginia has already made with nitrogen offset credits.
During the Obama era, Virginia implemented a nitrogen offset credit program for wastewater treatment plants—both centralized and decentralized—with the stated goal of protecting our waterways. In theory, the program sounded reasonable. In practice, it has often produced the opposite result.
Nitrogen offset credits are expensive and scarce, largely controlled by a small number of large urban wastewater treatment plants. When new or upgraded treatment is needed—particularly in rural or legacy communities—the cost of purchasing credits becomes prohibitive. As a result, rural communities are disproportionately burdened, while urban centers, which generate the largest nitrogen and phosphorus loads through stormwater runoff, face comparatively less pressure.
Local leaders are often reluctant to raise taxes in dense urban areas to address stormwater and nutrient loading. Instead, responsibility is deferred, and regulators’ hands become tied. The result is regulatory gridlock and continued pollution—not because solutions don’t exist, but because the financial mechanism prevents them from being implemented.
This problem is especially acute for aging communities built before 1960 that rely on decentralized wastewater treatment. Today, we can reliably achieve end-of-pipe limits near 10 mg/L BOD, 10 mg/L TSS, and total nitrogen in the 15–20 mg/L range. Yet these communities are still required to purchase credits to offset the remaining load—often on a recurring basis. Large urban treatment facilities understandably hoard credits for future needs, and when credits are offered, they are frequently unaffordable. The result is stagnation, not environmental improvement.
I speak from experience. In October 2024, I presented a paper on this very issue at the NOWRA Conference in Hampton, Virginia.
It is for these reasons that I caution against a carbon tax structured around offset credits. Such systems tend to regulate through financial pressure rather than measurable outcomes, imposing costs on average consumers while producing little global benefit. Even if the United States achieved carbon neutrality tomorrow, global emissions would continue to rise as China and India expand coal-fired power generation at record pace.
Environmental tradeoffs are also routinely ignored. Offshore wind development raises unresolved concerns about right-whale mortality and vessel traffic. Large-scale solar installations remove vegetation and disrupt ecosystems. Every proposed solution carries environmental costs. The question is not whether tradeoffs exist, but who bears them—and whether they meaningfully improve outcomes.
I will add one observation grounded in published research. NASA has documented that large-scale groundwater withdrawal has contributed to measurable shifts in Earth’s rotational axis, known as polar motion. According to NASA researchers, the redistribution of mass caused by groundwater extraction has altered Earth’s axis in recent decades. While this finding does not, by itself, explain climate change, it demonstrates that human land- and water-use practices can influence planetary systems in ways not fully captured by carbon-only climate models. It is reasonable to ask whether such physical changes—alongside atmospheric factors—may contribute to regional climate variation over time.¹
I care deeply about environmental stewardship. But experience tells me that credit-exchange systems often become revenue mechanisms rather than solutions. If you are open to it, I would welcome a conversation. I believe my experience could help inform approaches that actually improve environmental outcomes—without repeating the unintended consequences we are already living with.
Respectfully,
Reed Johnson
Reference
¹ NASA Earth Science research on groundwater depletion and polar motion:
https://www.nasa.gov/earth/climate-change/groundwater-pumping-and-earths-tilt/
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