[Congressional Record Volume 162, Number 16 (Wednesday, January 27, 2016)]
[Senate]
[Pages S259-S260]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 2964. Mr. SCHATZ submitted an amendment intended to be proposed by 
him to the bill S. 2012, to provide for the modernization of the energy 
policy of the United States, and for other purposes; which was ordered 
to lie on the table; as follows:

       At the appropriate place, insert the following:

     SEC. ___. PHASE OUT OF TAX PREFERENCES FOR FOSSIL FUELS.

       (a) Findings.--Congress finds the following:
       (1) United States tax policy has provided tax breaks for 
     oil and gas production for 100 years.
       (2) United States tax policy has provided tax breaks for 
     coal production for over 80 years.
       (3) A substantial majority of the American public, 
     including majorities from both political parties, support the 
     repeal of tax preferences for fossil fuels.
       (4) A substantial majority of the American public, 
     including majorities from both political parties, favor 
     Federal support for renewable energy.
       (5) In order to ensure that all sources of energy compete 
     on an equal footing, as tax credits for renewable energy are 
     phased out over the next 4 years, fossil fuel tax preferences 
     should be phased out on the same schedule.
       (b) Expensing of Intangible Drilling Costs.--Section 263 of 
     the Internal Revenue Code of 1986 is amended--
       (1) in subsection (c), by striking ``subsection (i)'' and 
     inserting ``subsections (i) and (j)'', and
       (2) by adding at the end the following new subsection:
       ``(j) Phase Out of Deduction for Intangible Drilling 
     Costs.--In the case of intangible drilling and development 
     costs paid or incurred with respect to an oil or gas well, 
     the amount of such costs allowed as a deduction under 
     subsection (c) shall be reduced by--
       ``(1) in the case of any costs paid or incurred after 
     December 31, 2016, and before January 1, 2018, 20 percent,
       ``(2) in the case of any costs paid or incurred after 
     December 31, 2017, and before January 1, 2019, 40 percent,
       ``(3) in the case of any costs paid or incurred after 
     December 31, 2018, and before January 1, 2020, 60 percent, 
     and
       ``(4) in the case of any costs paid or incurred after 
     December 31, 2019, 100 percent.''.
       (c) Percentage Depletion for Oil and Natural Gas Wells.--
     Section 613A(d) of such Code is amended by adding at the end 
     the following new paragraph:
       ``(6) Phase out of percentage depletion for oil and natural 
     gas wells.--The amount allowed as a deduction for the taxable 
     year which is attributable to the application of subsection 
     (c) (determined after the application of paragraphs (1) 
     through (5) of this subsection and without regard to this 
     paragraph) shall be reduced by--
       ``(A) in the case of any crude oil or natural gas produced 
     after December 31, 2016, and before January 1, 2018, 20 
     percent,
       ``(B) in the case of any crude oil or natural gas produced 
     after December 31, 2017, and before January 1, 2019, 40 
     percent,
       ``(C) in the case of any crude oil or natural gas produced 
     after December 31, 2018, and before January 1, 2020, 60 
     percent, and
       ``(D) in the case of any crude oil or natural gas produced 
     after December 31, 2019, 100 percent.''.
       (d) Domestic Manufacturing Deduction for Fossil Fuels.--
     Section 199(d)(9) of such Code is amended by adding at the 
     end the following new subparagraph:
       ``(D) Phase out of deduction for oil related qualified 
     production activities income.--The amount allowable as a 
     deduction under subsection (a) (determined after the 
     application of subparagraph (A) and without regard to this 
     subparagraph) shall be reduced by--
       ``(i) in the case of any oil related qualified production 
     activities income received or accrued after December 31, 
     2016, and before January 1, 2018, 20 percent,
       ``(ii) in the case of any oil related qualified production 
     activities income received or accrued after December 31, 
     2017, and before January 1, 2019, 40 percent,
       ``(iii) in the case of any oil related qualified production 
     activities income received or accrued after December 31, 
     2018, and before January 1, 2020, 60 percent, and
       ``(iv) in the case of any oil related qualified production 
     activities income received or accrued after December 31, 
     2019, 100 percent.''.
       (e) Amortization of Geological and Geophysical 
     Expenditures.--Section 167(h) of such Code is amended by 
     adding at the end the following new paragraph:
       ``(6) Phase out of amortization of geological and 
     geophysical expenditures.--The amount of geological and 
     geophysical expenses paid or incurred by a taxpayer which are 
     allowed as a deduction under this subsection (without regard 
     to this paragraph) shall be reduced by--
       ``(A) in the case of any such expenses paid or incurred 
     after December 31, 2016, and before January 1, 2018, 20 
     percent,
       ``(B) in the case of any such expenses paid or incurred 
     after December 31, 2017, and before January 1, 2019, 40 
     percent,
       ``(C) in the case of any such expenses paid or incurred 
     after December 31, 2018, and before January 1, 2020, 60 
     percent, and
       ``(D) in the case of any such expenses paid or incurred 
     after December 31, 2019, 100 percent.''.
       (f) Percentage Depletion for Hard Mineral Fossil Fuels.--
     Section 613 of such Code is amended by adding at the end the 
     following new subsection:
       ``(f) Phase Out of Percentage Depletion for Hard Mineral 
     Fossil Fuels.--In the case of coal, lignite, or oil shale, 
     the allowance for depletion determined under this section 
     (without regard to this subsection) shall be reduced by--
       ``(1) in the case of any income received or accrued from 
     the property after December 31, 2016, and before January 1, 
     2018, 20 percent,
       ``(2) in the case of any income received or accrued from 
     the property after December 31, 2017, and before January 1, 
     2019, 40 percent,
       ``(3) in the case of any income received or accrued from 
     the property after December 31, 2018, and before January 1, 
     2020, 60 percent, and
       ``(4) in the case of any income received or accrued from 
     the property after December 31, 2019, 100 percent.''.
       (g) Expensing of Exploration and Development Costs for Hard 
     Mineral Fuels.--Section 617 of such Code is amended--
       (1) by redesignating subsection (i) as subsection (j), and
       (2) by inserting after subsection (h) the following new 
     subsection:
       ``(i) Phase Out of Expensing of Exploration and Development 
     Costs for Hard Mineral Fuels.--In the case of coal, lignite, 
     or oil shale, the amount of expenditures which are allowed as 
     a deduction under subsection (a) shall be reduced by--
       ``(1) in the case of any such expenditures paid or incurred 
     after December 31, 2016, and before January 1, 2018, 20 
     percent,
       ``(2) in the case of any such expenditures paid or incurred 
     after December 31, 2017, and before January 1, 2019, 40 
     percent,
       ``(3) in the case of any such expenditures paid or incurred 
     after December 31, 2018, and before January 1, 2020, 60 
     percent, and
       ``(4) in the case of any such expenditures paid or incurred 
     after December 31, 2019, 100 percent.''.
       (h) Capital Gains Treatment for Royalties of Coal.--Section 
     631 of such Code is amended by adding at the end the 
     following new subsection:
       ``(d) Phase Out of Capital Gains Treatment for Royalties of 
     Coal.--In the case of coal (including lignite), the amount of 
     gain or loss on the sale of such coal to which subsection (c) 
     applies shall be reduced by--
       ``(1) in the case of any such gain or loss after December 
     31, 2016, and before January 1, 2018, 20 percent,
       ``(2) in the case of any such gain or loss after December 
     31, 2017, and before January 1, 2019, 40 percent,
       ``(3) in the case of any such gain or loss after December 
     31, 2018, and before January 1, 2020, 60 percent, and
       ``(4) in the case of any such gain or loss after December 
     31, 2019, 100 percent.''.
       (i) Deduction for Tertiary Injectants.--Section 193 of such 
     Code is amended by adding at the end the following new 
     subsection:
       ``(d) Phase Out of Deduction for Tertiary Injectants.--The 
     amount of qualified tertiary injectant expenses allowable as 
     a deduction under subsection (a) shall be reduced by--
       ``(1) in the case of any such expenditures paid or incurred 
     after December 31, 2016, and before January 1, 2018, 20 
     percent,
       ``(2) in the case of any such expenditures paid or incurred 
     after December 31, 2017, and before January 1, 2019, 40 
     percent,
       ``(3) in the case of any such expenditures paid or incurred 
     after December 31, 2018, and before January 1, 2020, 60 
     percent, and
       ``(4) in the case of any such expenditures paid or incurred 
     after December 31, 2019, 100 percent.''.
       (j) Exception to Passive Loss Limitation for Working 
     Interests in Oil and Natural

[[Page S260]]

     Gas Properties.--Section 469(c) of such Code is amended by 
     adding at the end the following new paragraph:
       ``(8) Phase out of exception to passive loss limitation for 
     working interests in oil and natural gas properties.--In the 
     case of any loss from a working interest in any oil or gas 
     property, the amount of such loss to which paragraph (3) 
     applies shall be reduced by--
       ``(A) in the case of any such loss after December 31, 2016, 
     and before January 1, 2018, 20 percent,
       ``(B) in the case of any such loss after December 31, 2017, 
     and before January 1, 2019, 40 percent,
       ``(C) in the case of any such loss after December 31, 2018, 
     and before January 1, 2020, 60 percent, and
       ``(D) in the case of any such loss after December 31, 2019, 
     100 percent.''.
       (k) Marginal Wells Credit.--Section 45I(d) of such Code is 
     amended by adding at the end the following new paragraph:
       ``(4) Phase out of marginal wells credit.--The amount of 
     the credit determined under subsection (a) shall be reduced 
     by--
       ``(A) in the case of any qualified crude oil production or 
     qualified natural gas production after December 31, 2016, and 
     before January 1, 2018, 20 percent,
       ``(B) in the case of any qualified crude oil production or 
     qualified natural gas production after December 31, 2017, and 
     before January 1, 2019, 40 percent,
       ``(C) in the case of any qualified crude oil production or 
     qualified natural gas production after December 31, 2018, and 
     before January 1, 2020, 60 percent, and
       ``(D) in the case of any qualified crude oil production or 
     qualified natural gas production after December 31, 2019, 100 
     percent.''.
                                 ______