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There’s no question that the politics may dictate giving the LDC’s quite a bit of say in how the implement the public benefit. That being said, it’s less clear to me that the politics precludes reducing this discretion along the dimensions that will blunt the consumer incentives created by a cost of carbon.

Trenchant analysis here, as usual. Unfortunately, while I agree that the LDCs have lots of latitude to play games with the allowances allocated for consumer benefit, I think the political exigencies would preclude implementing a system with more integrity, i.e. we bought off some very powerful opposition.