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FOIA Number: 2017-1095-F FOIA MARKER This is not a textual record. This is used as an administrative marker by the William J. Clinton Presidential Library Staff. Collection/Record Group: Clinton Presidential Records Subgroup/Office of Origin: Council of Economic Advisers Series/Staff Member: Jeffrey Frankel Subseries: OA/ID Number: 13726 FolderID: Folder Title: Tax Cuts/Credits GCC [Global Climate Change] Stack: Row: Section: Shelf: Position: S 20 5 1 1 EXECUTIVE OFFICE OF THE PRESIDENT CC: JY COUNCIL OF ECONOMIC ADVISERS JA WASHINGTON, D.C. 20500 SR MEMBER November 20, 1998 QP MEMORANDUM FOR TODD STERN cong FROM: JEFF FRANKEL IF SUBJECT: A NEW IDEA HOW TO DO SOMETHING IN THE AUTO SECTOR I know that you have run into some roadblocks on the proposal for tax credits for fuel-efficient cars. You might be in the market for "outside the box" suggestions for how to do something in the auto sector. So I thought I would offer one. The Administration could announce a regular series of cash awards for anyone making an outstanding contribution to reducing GHG emissions in the auto sector. It could be annual, like the Baldridge Awards, or more frequent. Recipients could include large corporations, private research labs, national labs, individuals (e.g., authors or inventors), think-tanks, NGOs, and local governments. Hypothetical examples: Innovations in the vehicle: - redesigned engines that increase efficiency such as direct injection - light-weight materials - improved power source such as fuel cells Innovations in fuels: - improved refining methods that lower costs of reducing sulfur - improved natural gas or other alternative fuels Innovation in systems: - switch of corporate/government fleets - systems of delivering alternative fuels Innovations in infrastructure: - improved traffic monitoring and information to reduce congestion - automated tolls systems I have discussed this with other members of the economists team (though not at the senior level), and they are enthusiastic about the idea. cc: David Wilcox, Bob Cumby, Mark Mazur, Victoria Greenfield a: files Conques SK mg 4:30 To: Janet Yellen, Jeff Frankel From: Steve Polasky RE: Auto Tax Credit November 6, 1998 The idea of proposing a technology credit for automobiles to include in the Administration's 2000 budget is being seriously considered. The issue may go to principals as early as the week of November 9. Background. On November 2, Sally Katzen convened a meeting to discuss possible tax credits for fuel efficient vehicles to be included in the Administration's budget proposal for 2000. The performance-based tax credit in the 1999 Administration budget proposal died, largely because of lack of support from the Big 3 domestic producers. Transportation is a large sector with no climate change initiative at present. There is a strong desire within the Administration to put together an initiative that will be acceptable to the Big 3 and the environmental community. Performance-Based or Technology-Based Tax Credit The domestic producers favor a technology-based tax credit. The performance-based approach would give a tax credit for vehicles that were twice (2X) or three times (3X) as efficient as the average vehicle in its class. The auto companies feel that the 2X or 3X standard is too demanding and unlikely to be reached in the time frame proposed. In addition, they think there are problems with definition of vehicle classes. Another concern of the domestic producers may be the competitive advantage that a performance-based tax credit might give to foreign producers. The domestic producer's view is that if the introduction of new technology is the major policy goal, then a technology-based tax credit is the corfect approach. Treasury and environmental groups have argued for a performance-based approach. There is the standard criticism that a technology-based approach forces the government into the position of trying to pick winners. There is also the concern that without a performance standard, there may be no environmental gain from the tax credit. The fear is that the auto companies will include the technology but then offset this by building "bigger, faster, stronger" vehicles leaving average fuel efficiency largely unchanged. In particular, if CAFE constraints are binding, installing the technology on some vehicles allows a company to sell more large fuel inefficient vehicles, leaving fuel efficiency of the company's fleet at the CAFE constraint level. Even without a binding constraint, some improvement in technology will likely go toward performance enhancement (bigger, faster, stronger) rather than fuel efficiency. In reality, both the technology and the performance standards are subject to this criticism. Under a performance standard, increasing the proportion of vehicles in the large fuel-inefficient categories can allow a company to improve fuel efficiency of particular vehicles while still keeping overall fuel efficiency constant. Proposed Tier II Rules on Tailpipe Emissions A technology favored by the domestic producers is CIDI (compression ignition direct injection), which uses diesel fuel. Using current high sulfur diesel fuel would generate high levels of NOx and particulate matter emissions. Even with low sulfur fuel, diesel technology generates higher emissions of NOx and particulates than gasoline engines. The EPA is in the process of drafting new emissions standards for vehicles (Tier II standards). It is not clear that rewarding CIDI with a tax credit will be consistent with Tier II rules or will be acceptable to environmentalists. There is some tension between meeting NAAQS for ozone and PM and lowering carbon emissions. Summary There is no guarantee that a tax credit, either based on performance within a defined class or based on technology, will yield fuel efficiency or other gains. I am somewhat skeptical of the merits of pushing for a tax credit unless it could be based on a pure performance standard (without reference to classes), which seems to be a non-starter politically. Even so, the costs of the program are not likely to be large. If a proposal comes forward that can manage the difficult task of satisfying the various constituent groups, my inclination would be to try to insure that desirable outcomes are advanced with the tax credit rather than opposing it altogether. 2 Garliner 6/1/98 (1) CCT1 non in methodolay 133 fruit of results why ? we're consenative. 6381 (2) Dolo AEU % 1792 Baselive 1350 442 -132 1.25 1660 135 at $25/70 92 $ EC CLIMATE CHANGE AND THE BUDGET October 16, 1997 QUESTION 1: DO WE PROPOSE A REVENUE-NEUTRAL SET OF TAX CUTS ON CLIMATE CHANGE? There is much interest in a package of tax cuts in the near term to spur energy efficiency and lower-carbon technologies. But there are two critical questions about such a tax package: An overall strategic question, given the budget agreement, is whether we want to offer tax cuts in any area. A potential danger with proposing climate change tax cuts is that we could open up a bidding war over tax cuts generally. But it may be possible for us to draw an important distinction between gross and net tax cuts -- that we support only revenue-neutral tax plans. A specific question, if we decide to offer a tax cut package, is how best to design the package. Treasury tax policy staff are working with DOE, EPA, OMB, and other agencies to put together a package of tax cuts amounting to perhaps $1.5 billion per year. Some of the preliminary ideas include: Tax subsidies to convert coal-fired power plants to gas; Extension of the existing tax incentive for wind and "closed loop" biomass energy; Tax credits for purchases of "superstar" energy-efficient devices and fuel-efficient cars; Investment credits for energy-efficient buildings; and An expanded research tax credit for energy-efficiency research. P wants yo annource wel C.S. They'reall Tax cut pachage T R&D Packoql Rubin commy temble tax policy. Doesn't mean we shaldn't do iy- QUESTION 2: DO WE SPECIFY A FUNDING LEVEL FOR R&D/TECHNOLOGY? There seems to be unanimous support for an aggressive Federal technology and R&D effort on climate change. The Department of Energy's 5-Labs study, the Department of Energy's 11-Nation Labs draft study, and the recent report from the President's Committee of Advisors on Science and Technology (PCAST) have all studied potential technologies that could help to reduce the cost of carbon emissions reductions. One proposal that has been put together by DOE, with assistance from OMB and other agencies, would include an additional $500 million per year starting in FY 1999, and ramping up to an additional $1 billion by FY 2003. The effort would focus on promising areas including: Energy efficient equipment (e.g., a public service campaign to attract attention to the "Energy Star" label); 21st Century Housing (streamline federal, state, and local building and utility regulations in ways that encourage innovation in construction); Expanded Partnership for the Next Generation Vehicle (expand work on the next generation vehicle technologies including fuel cells; and expand PNGV to include light trucks/sport-utility vehicles); PNGV for Heavy Trucks (partnership with engine manufacturers to double the efficiency of heavy-duty trucks for civilian and military applications); Industries of the Future (enhance industry/government research partnerships in areas such as chemicals, aluminum, forest products and steel manufacturing technologies); and Renewables R&D (expand research partnerships in key renewable technologies such as wind, photovoltaics, geothermal, biomass and hydropower to accelerate cost reductions). 10/14/97 TUE 12:27 FAX 002 DRAFT A U.S. Strategy to Reduce Carbon Emissions: Technology Research, Development and Deployment A national commitment to energy technologies will ensure that the U.S. can reduce and stabilize carbon emissions while maintaining a robust and healthy economy. The U.S. strategy is designed to make this goal a reality through a four part plan: 1) technology research, development and deployment (RD&D) to develop new technologies and increase the use of the best of what is available today; 2) federal tax incentives to spur technology development; 3) statutory and regulatory reform to advance technology innovation and deployment in markets; and 4) actions to accelerate the use of these technologies in federal facilities and vehicles. The technology RD&D clement involves public-private partnerships and deployment initiatives. These actions require additional federal technology funding of $500 million in FY1999 - rising to $1 billion in FY2003. If successful, these actions could help reduce emissions by more than 175 MMT by 2010 and even more in later years. The specific actions are summarized below. Energy Efficient Building Equipment: Use of more cfficient equipment will be accelerated through expanded "Energy Star" labeling, accelerated equipment cfficiency standards and other means. Increased RD&D partnerships will cut costs and develop new technologies. 21" Century Housing: Partnerships with builders, suppliers, insurers, state and local governments, and federal regulators will lead to construction of more efficient, attractive and affordable housing. Expanded Partnership for the Next Generation Vehicle (PNGV): Increased funding of PNGV will better ensure the development of an 80 mpg mid-size car by 2005. A PNGV light trucks/sport-utility vehicle will also be developed. PNGV for Heavy Trucks: A partnership with engine manufacturers will double the efficiency of heavy-duty trucks for civilian and military applications. Advanced Aircraft: Advanced aircraft technologies and air traffic control practices will produce a 35% reduction in greenhouse gases per passenger miles traveled by 2020. Biofuels: Accelerated RD&D on energy crops, harvesting and fuel conversion processes will significantly expand use of biomass fuels for automobiles and other vehicles. Combined Heat and Power: Accelerated development of advanced turbines, fuel cells and other technologies along with streamlined permitting and other statutory and regulatory reforms will greatly accelerate use of highly efficient combined heat and power systems in industry. Industries of the Future: Enhanced industry/government research partnerships in energy intensive industries such as chemicals, aluminum, forcst products and steel will produce technologies that cut emissions while improving productivity. Efficient Motors and Production Systems: Accelerated use of market-ready electric motor systems, steam systems and compressed air storage will improve efficiency, cut emissions and boost productivity across industry. Renewable Energy RD&D: Expanded rescarch partnerships in kcy renewable technologies such as wind, photovoltaics, geothermal, biomass and hydropower will accelerate cost reductions and 10/14/97 TUE 12:27 FAX 003 DRAFT performance improvements. Coordinated demonstrations and other deployment actions will lay the foundation for the widespread use of these zero-carbon technologies. Advanced Fossil Energy RD&D: Accelerated RD&D will enable use of coal and natural gas in highly efficient, low-emissions power plants. Carbon Sequestration Technology RD&D: Research, development and demonstration of advanced sequestration technologies that could enable the continued use of high-carbon fuels such as coal. Advanced Nuclear Power R&D: Research and development of a proliferation-resistant, low waste reactor will allow zero-carbon nuclear power to bc a option for the future. Basic Energy Research: Research in materials, chemicals, biotechnology, geophysics, advanced computation, environmental and ecological sciences will establish the scientific foundation for revolutionary advances in technology necessary for substantial emissions reductions in the long term. 10/14/97 TUE 12:28 FAX 004 DRAFI Comparision of PCAST Recommendations and Draft White House Climate Technology Strategy Draft Strategy Budget (above FY98R) PCAST Recommended Recommended Incremental Budget Budget Increment Increment (v.FY98R) $500M FY99 Level $500M FY99 Level FY99 FY03 FY99 FY03 FY99 FY03 Buildings Efficiency 49 164 85 210 55 155 Building system design and operation 5 51 5 45 Building equipment and materials 20 74 45 140 25 70 Codes and standards 4 4 5 10 5 5 Cross-cutting activities 20 35 35 60 20 35 Industrial Efficiency 44 129 65 145 55 135 Industries of the future 9 54 20 60 20 60 Cross-cutting activities 32 62 30 60 25 8 Technology access 3 13 15 25 10 15 Transportation Efficiency 65 130 140 260 115 140 PNGV & II) 46 71 100 160 80 100 Advanced heavy vehicles 12 42 40 100 35 40 Advanced materials 4 14 Technology deployment 3 3 Fossil Energy (riet Including reductions) 33 87 50 100 50 110 Coal power -5 -2 15 20 Coal fuels -7 0 Gas power 14 -8 15 25 Oil and gas production and processing 9 36 Carbon sequestration 8 20 50 100 20 50 Methane hydrates 5 12 -10 Hydrogen production from fossil fuels 1 7 Collaborative International R&D 1 6 5 Management, env. Restor., coop. R&D, et. 7 16 Nuclear 45 176 0 0 30 70 Life extension -15 -15 Profiferation-resistant reactors 50 103 30 70 Advanced light water reactors -15 -15 Fusion 25 103 Renewable Energy 130 307 145 245 120 300 Biomass fuels 20 61 25 55 Blomase power 25 55 Geothermal 12 22 Hydrogen 1 2 Hydropower 3 11 Photovoltaics 28 63 Solar Thermal 12 27 Wind 10 27 Systems and storage, transmission 5 12 Solar buildings 2 5 International assistance 4 7 Resource assessment and analysis 5 6 Management, analysis, REPI, other 5 9 Basic Energy Research n/a n/a 0 0 35 50 TOTAL, TECHNOLOGY ELEMENTS 366 993 485 960 460 960 Non-PCAST Items: 40 40 40 o 40 40 PNGV tax incentives Renewable energy tax Incentives Industrial technology tax incentives Biofuels tax incentives Agriculture and forestry R&D 40 Advanced aircraft R&D 40 40 40 40 TOTAL ALL ELEMENTS 406 1033 525 960 500 1000 Recommended Changes to White House Draft Climate Strategy at the $500 million level: 1) Additional funding is provided for advanced natural gas and coal generation technology R&D. 2) Additional funding is provided for advanced proliferation-resistent nuclear generation technology R&D. 3) Buildings and transportation R&D are reduced slightly to make room for fossil and nuclear increases. 4) Additional funding is provided for cross-cutting R&D (e.g., industrial sensors and controls). 5) Renewable energy R&D is lowered slightly to be consistent with PCAST: 6) An Increment for climate related basic energy research is added. GCC Tax credits 11/21/97 Varl 5 Thease her They 1104 any Karl Joe Ene Gerardi Scholz Rom relever DOE Mark USTP jeremy Dave 9 Adels we Minank Henry relly Mark Siw Bd noniger 0571 M Twillo $ 1475hboll for carbon -savg techn. $54 world Split 50-50 Tax - spdq? -1} but discuctionaly caps Tyles. VP : want mde(Than $2/21 on MY ) $31 5 over Syrs. oxtax (2½ on SP. Bldgs. Hure ruly. Transp Me car classes under Doniger CAFE Styl no, nYhT? me cav't lot and 105. COUNT cockited as Travsit & vantool beuefit Industy Renevalle Energy Total 2.9 Gap 0.6 Henny Kelly 12/21/17 Treas 104 TAX CREDIT FOR SUPER EFFICIENT HOMES Option: Credit to persons who buy a home that uses 50% less energy than the model energy code. The tax credit would be for the purchase of a primary residence of 1% of the cost of a home, with a maximum credit of $2000. The credit would phase out or the goal changed in 2005. Verification: The tax credit would not come into effect until 1999. During the 1998 fiscal year, the National Institute of Standards and Technology (NIST) will work with industry, the Department of Energy and EPA to develop testing and verification procedures for these homes. NIST will use as it's baseline two existing items:(i) the International Measurement and Verification Protocol that has been sponsored by DOE, and (ii) lessons learned from the EPA energy star buildings program. The mechanism for verification will also be developed through existing DOE and EPA programs. NIST will complete the process in 6 months. This work will be closely coordinated with new efforts by major home insurance companies to rate the quality of new housing and housing components. Analysis: About 1.5 millions housing units are built each year for a total value of $128 billion. Three quarters of the new units are single units and of these about a third are mobile homes (or "manufactured housing"), most of which are never moved after installation. Current estimates suggest that with a $2000/unit tax credit in place and a major national program aimed at advertising the benefits of energy efficiency, about 2% of all new homes could meet the goal of the tax credit (50% below model code level) in 1999 rising to 10% by 2005. This would imply tax expenditures of $60 million in FY99 rising to $300 million in FY2005 when the program would end or be redefined. Benefit and Opportunity: Residential housing offers one of the largest sources of low-cost carbon savings available. Residences are responsible for 1/6 of all US greenhouse gases and technologies are available to cut this production in half at very low cost given adequate investment in innovation. Programs aimed at efficient appliances for retrofit will have the largest near-term impact on production of greenhouse gases but over the long term, innovation in the way houses are designed and built are essential to capture the potential. The potential of advanced housing components is often lost when they are installed in a poorly engineered structure. Climate change tax credits are not adequate to serve as a surrogate for a carbon trading mechanism. Carefully targeted, however, they can serve to spur innovation in directions that can change construction practices in ways that would result in large gains in energy efficiency as well as other benefits. Such targeted efforts are particularly important for home construction because the industry has traditionally had difficulty investing in innovation because of the way it has traditionally been regulated. The credits would give builders a way to reduce the risk of innovation and give them an important marketing tool. The credit would provide a highly visible, reliable indicator of quality (something difficult to achieve in a fragmented market), and would allow builders to recover development costs without raising initial home prices for the purchaser. Once R&D costs are recovered, the builders should be able to build units at costs below the costs of conventional construction. The effort can be accelerated by working closely with insurance firms and financial institutions. Many of the energy efficiency improvements also improve the durability and disaster resistance of the home. The insurance industry is particularly interested in helping develop measurement and verification protocols for residential structures, and can be a partner in spurring innovation. This tax credit, and the work needed to develop a reliable measurement tool, will leverage private sector investment and encourage them to play a more active role in helping to improve the quality of housing while keeping homes affordable. Assumptions: credits would be given to individual home buyers credits would be available for specific housing products from builders whose products had been given the needed rating. ratings would apply to the heating, cooling, ventilation, hot water, and major appliances commonly purchased with the home. They would not apply to appliances, such as television sets, purchased separately by homeowners. metrics would be developed for each major climate region. the tax credit would be given only for energy efficiency. The labeling and rating may well be developed in cooperation with insurance companies able to provide insurance rate benefits in addition to the tax credit the ratings would be an extension of the EPA energy-star rating. The EPA label would apply to a large class of new housing, the proposed credit would be given only to a small fraction of exceptional new housing. the ratings would need to be based in part on a construction method which ensured that each unit would meet the standard and would not require sophisticated inspections of each structure built. Alternative 1: High Threshold This option would provide $4,000 credits to 25,000 units per year for a total annual federal cost of $100M/year. This would allow each of five builders to construct 5,000 units. Pros: Higher incentive would attract higher interest and keener competition. Development costs could be written off against smaller total sales volume. Cons: Fewer builders would be affected (1.7% of total market). Could attract high-cost options. Credit still only 3% of value of average home Alternative 2: Low Threshold This option would provide $1,000 credits to 100,000 units. Pros: Incentives provided to larger number of builders and homeowners. 7% of all new homes would get the credit. Cons: Could dilute credit and not provide adequate incentives to individual builders. Could be used simply to finance additional insulation or other measures and not induce a transformation in construction methods. Alternative 3: State or Community Management The tax credits could be given to states or communities who would compete for the right to grant the credit much as empowerment zones were given specified tax exemption rights. Pros: This would allow competition on local regulatory streamline proposals as well as competition on the methods proposed for use in rating the structures. It could encourage communities to participate in PATH experiments Cons: Could add complexity and management problems for Treasury. Table 1 U.S. Home Construction 1990 1993 1994 1995 1996 Units (thousands) Total 1,193 1,264 1,457 1,345 1,477 1-unit 895 1,1256 1,198 1,076 1,161 Mobile Homes 243 286 311 364 2-unit 16.1 11.1 14.8 14.3 16.4 3 and 4 unit 21.4 18.3 20.2 19.4 28.8 5 units and more 260 133 224 244.1 270.8 Millions of Current Dollars Residential buildings 182,856 210,455 238,874 236,597 246,899 New housing units 127,987 144,071 167,919 162,898 176,378 1 unit 108,737 133,282 153,838 145,009 156,510 2 or more units 19,250 10,788 14,081 17,889 19,868 Improvements 54,869 66,384 70,955 73,699 N/A SOURCE: BUREAU OF THE CENSUS Vall 5 12/21 That " ' 04 Preliminary Preliminary revenue cost: revenue cost 1999-2003 per ton of KS Option ($ billions) carbon avoided Comments BUILDINGS This 1. Energy efficient building equipment. A 20 0.5 10 -20 Complements initiative to attract attention to energy star Urp percent tax credit for the purchase of certain labels. Barriers to these investments (information, financing) highly efficient equipment for residential and addressed through other programs. May be inefficient because commercial buildings, such as electric heat the government is picking the technology winners. Subsidies pump water heaters, fuel cells for power may be supporting technologies that turn out to be losers and generation, natural gas heat pumps and may crowd out other potentially more energy efficient electric heat pumps. Credit expires 2003. technologies. 2. Energy efficient homes. A tax credit 0.5 (if given to N.A. Would encourage the purchase of new energy efficient houses. ($1,000) would be provided for the purchase all energy star The proposal does not address the largest housing related of highly energy efficient new homes. Credit homes) energy problem - old homes are inefficient." This proposal expires 2003. would be difficult to administer as there presently is no federal program that certifies highly energy efficient new homes. Absent a high standard for energy efficiency, the credit would be largely a windfall. TRANSPORTATION 3. Fuel efficient vehicles. A $4,000 tax credit 0.2 110 900 Supports commercialization of vehicles under development in for the purchase of high fuel economy the Partnership for a New Generation of Vehicles. Most vehicles with 3 times the 1997 class average, eligible vehicles may be foreign and purchased by high-income and $2,000 for vehicles achieving twice the persons. 1997 class average. Credit phases down beginning in 2003 and phases out in 2011 for 3x vehicles (2003/2006 for 2x vehicles). 4. Transit and vanpool benefits. The tax 0.1 145 Allows employers to provide tax free transit and vanpool treatment of parking, transit, and vanpool benefits in lieu of compensation, a preference now available to benefits would be equalized by allowing parking benefits. Expands the difference in tax treatment of employers to offer employees transit and different forms of compensation. vanpool benefits in lieu of compensation. 4a Raise the transit pass/vanpool limit to parking limit INDUSTRY 5. Combined heat and power systems. A 10% 0.6 100 Could accelerate the adoption of this well-established tax credit for investments in combined heat technology. The definition of eligible equipment would have and power systems. Credit expires in 2003. to be refined, particularly in view of past history of problems in defining cogeneration. Installation of this equipment is already economic in many situations; the credit may merely provide a windfall for those already willing and able to install this equipment. RENEWABLE ENERGY 6. Electricity production from wind and 0.2 430 Supports commitment to renewables. Limited emissions biomass. Extension of the present 1.5 cents reduction potential since wind power is limited geographically per kWh tax credit for electricity production and is not continuously available. from wind and biomass for 5 years (i.e., production from facilities placed in service before July 1, 2004). 7. Rooftop solar systems. A 15 percent credit 0.1 200 - 300 Helps to implement the President's Million Solar Roofs for the purchase of rooftop solar systems. initiative. Will be purchased primarily by high-income Maximum credit would be $1,000 for households. thermal and $2000 for photovoltaic systems. Excludes hot water heaters for swimming pools. Credit expires 2003. 8. Methane recovery. A production tax credit 0.7 15 50 Would reduce emissions of methane, a potent greenhouse gas. for electricity or energy produced from Administration opposed extension of the section 29 credit. qualifying methane sources, such as certain landfills and coal mines. Restricted to third- party sales. The credit rate would be $1.10 per mil. Btu. Credit expires 2003. TOTAL 2.9 To make up the gap: A. Add items to option 1 (energy efficient building equipment) B. 10% credit for PFC recycling equipment under 5 Would reduce emissions of PFCs in the semiconductor installed in semiconductor fabrication industry. May be difficult to justify such a narrowly targeted facilities. credit. C. 10% credit for certain leaky electric power under 5 Would reduce emissions of sulfur hexafloride. Difficult to equipment (dual pressure power circuit monitor the destruction of old equipment. If old equipment is breakers manufactured before 1986) resold, emissions reductions may not be attained. D. 30% investment credit for small wind Negligible effect on greenhouse gas emissions. Unnecessary turbines (up to 40 kW). Credit phases down * 230 subsidy for a growing industry industry projects annual in 2006 and out in 2008. growth of 18% without the subsidy. N.A. means not available. * means less than $50 million. December 19, 1997