The climate bill may be dead for the summer, but two enforcement attorneys with the EPA have gone public with their contentions with the bill that are important to recognize, even if the legislation is not considered until months from now.

Laurie Williams and Allan Zabel say there are

According to Williams and Zabel, the offsets are essentially just a financial instrument with the same potential for deception that brought down the financial markets, and the two lawyers want a congressional probe into how reliable any offset program would be before it is enacted.

Public Employees for Environmental Responsibility has posted their complaints, which they articulate into four main points:

- The complexity and subjectivity of offsets renders them impossible to certify, regulate or enforce;

- There is no reliable way to distinguish offset projects which will occur because of the offset incentive from those which would have happened anyway;

- In some cases, such as in the context of forestry projects, the offsets will fail to appreciably mitigate demand and the polluting activity (such as logging) will simply shift elsewhere; and

- The offsets will create perverse incentives to keep polluting activities legal so they can keep being sold as offsets.

More from PEER:

In speaking out as private citizens, Williams and Zabel are contradicting positions endorsed by their own agency, the EPA, which attempted to silence them last fall by demanding under threat of

Added PEER Executive Director Jeff Ruch,