- Comes too late. So the budgeted reduction path is too long. Before 2040, climate is already going haywire.
- Is unmanageable. With tradable permits, you create trillions of euros in new value, and so you need fleets of carbon managers, carbon accounters, civil servants to implement social equity, controlers, traders and lawyers plus their equipment and buildings to manage this method in a context of competing interests.
- Is not valid. Because you do not include (for example) emissions from international transport to the deepest level (i.e. you do not include in the emissions per person (or kg) per mile all infrastructural emissions (including ports) that are needed to get the transport done) in the emissions of products or services, you are basing permit assignments and import adjustments on a false representation of reality. And so you are constantly easily contestable in courtrooms and elections.
On the other hand, the emissions data base of this method can do well in establishing strong volume-limiting policies if they were soon to become unavoidable.