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Thank you for creating this time to listen - we all !earn when diverse viewpoints are heard. 

My name is Ray Roberts and I am the father of 2 awesome daughters, ages 8 and 11. It 1S because of them that I could no longer stay silent and why I have worked to start a Pittsburgh 

chapter of Citizens Climate Lobby: a non-partisan group dedicated to creating the political will 

to address climate change. 

I and Citizens Climate Lobby support the EPA and the Obama Administration in taking serious 

actions to address global warming. However I am sad and angry that congress has failed to act 

and forced the EPA to implement these rules. The costs of congressional inaction are growing 

each year and not in a linear way - the costs are growing exponentially. They are becoming 

more and more personal, also. This year I suffered my first asthma attacks, so I thank the EPA 

for stepping up and doing what needs to be done. 

Unfortunately, EPA rules are a blunt club of a tool compared to the laser scalpel of a legislative 

solution. A recently published study from MIT backs up this statement and I want to introduce a 

copy with my statement today. 

I cal! on our congress to step up and enact a market-based, revenue neutral carbon tax using a 

fee and dividend approach such as Citizens Climate Lobby advocates. Comparing apples-toapples, the EPA's blunt rules will reduce only 12.7% of C02 compared to a revenue-neutral carbon fee & dividend that would reduce C02 by 33% below 2005 levels by 2020. 

I believe those legislators who are complaining the loudest about EPA's power plant rules need 

to do their jobs and pass a law that does a better job than these EPA rules. The independent 

economic modeling group REM! has studied this legislation recommended by Citizens Climate 

Lobby and found that it would grow our economy, create 2.1 million jobs, and save 13,000 lives f' 

per year. Here is a summary of that report tJ.. 1

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However, the EPA's power plant rules, while maybe not my first preference - I do support them, 

and they are are a genuine step in the right direction which is far better than " the epic failure of 

our congress io act. 
I have three requests. 

First. I wish to introduce recently published research from the London School of Economics that 

raises three huge problems with the DICE model used by the US government to set a price for 

the social costs of carbon: these problems are 

1.) technology can't bounce back following repeated and increasing disasters, 

2.) failing to consider climate tipping points which for global warming act like pouring gasoline 

on a bonfire. 

3.) unexpected and unforeseen problems. When I leave my house each day, I don't expect it to 

burn down but I still have fire insurance. Currently, we're using math that assumes nothing unexpected ever goes wrong. 

If the DICE model for pricing carbon is adjusted it clearly points out the EPA's current carbon 

price of $38 per ton is way too low. Please increase your carbon price. I agree with the london 

School of Economics and I believe your price on carbon is dangerously low. 

Second, please include in your recommendations !or how states might satisfy the EPA rules a 

revenue-neutral carbon tax using a fee & dividend approach similar to the legislation Citizens 

Climate Lobby advocates. ! believe that if this form of carbon tax is implemented on a state-bystate level the economic benefits would push other states or our nation to follow suit. 

Third, I. believe there needs to be EPA rules to address the incredibly potent greenhouse gas. 

methane. Here in Pittsburgh, we have an aging infrastructure that leaks methane. For every 

ton of C02 the EPA's rules prevent, an equivalent amount of methane is 80 times more destructive in our atmosphere. Rules on other greenhouse gases are necessary next steps. 

The EPA is being forced to lead in taking action on climate change. It is a moral obligation not 

only to every citizen in our country, but to my daughters, and all the children in our nation. The 

greed of the most profitable companies in the history of the planet are rallying against you. You 

are doing the right thing and you have my support.