Re: The Environmental Protection Agency (EPA) Proposed Rule: 

Carbon Pollution Emission Guidelines for Existing Stationary Sources: 

Electric Utility Generating Units 

I want to thank President Obama for recognizing the urgency of climate change and 

for taking steps within the executive branch's power to begin to limit the CO2 

emissions from existing power plants, with the goal of reducing these emissions to 

30% below 2005 emissions by the year 2030. Since the U.S. Supreme Court has 

ruled that the EPA derives its rights to control carbon emissions from the Clean Air 

Act, it is fitting that the EPA should establish the rules being discussed today and I 

strongly support these rules. 

It should be noted that emissions from power plants represent about one third of 

the CO2 emissions in our country. The proposed regulations do not address 

transportation, residential, commercial, agricultural, or industrial emissions. So 

these standards should be seen as a minimal good start. Also, according to most 

accounts, we have already dropped our power plant emissions by 15% since 2005, 

and we will have about 15 years to drop by another 15%. So we are well on our 

way to reaching this goal. 

The EPA proposes to give states choice in how to meet the standards, and states can 

reduce emissions at the power plants or through offsets that are outside the fence of 

the power plant but within the state. 

Among economists, a carbon tax is widely accepted as the most economically 

efficient and cost-effective way to reduce CO2 emissions. Though directed at 

reducing CO2 emissions, carbon taxes can also help states reduce other fossil fuel 

byproducts, including particulates, mercury, and NOx and SOx emissions. 

Detractors who argue against a carbon tax say it will kill jobs, drag down the 

economy and burden families with higher energy bills. But a well-designed carbon 

tax that recycles revenue back to households and into the economy would protect 

families from rising costs and actually add jobs. A recent study by Regional 

Economic Models, Inc. (REMI) found that a carbon tax in California, even at very 

high levels, would increase GDP and add hundreds of thousands of jobs, provided 

the revenue is returned to the public, either as tax cuts or direct payments. This 

study can be found at http://etrus.org/remi-studies . REMI also just released a 20-

year analysis of the impacts of a gradually increasing national revenue-neutral 

carbon tax, and that study showed that under such a plan the U.S. would reduce CO2 

emissions to 50% of 1990 levels while growing the U.S. economy by $1.375 trillion 

and adding 2.8 million jobs. Real income will increase and premature deaths will 

decrease by 227,000. This study can be found at 

http://citizensclimatelobby.org/wp-content/uploads/2014/06/REMI-carbon-taxreport-62141.pdf) I want to add that Regional Economic Models, Inc. is a highly 

regarded non-partisan consulting organization that has been in business for 30 
years. Their clients include 47 state governments, cities, towns, Fortune 500 

companies and organizations such as the American Gas Association, the Nuclear 

Energy Institute, and Price Waterhouse. They approached the study from an 

economic point of view and they had no pre-conceived agenda on how it would turn 

out. 

The experience in British Columbia, Canada, is a real life example of how a revenueneutral carbon tax has worked. In 2008 British Columbia passed a gradually 

increasing revenue-neutral carbon tax and their experience shows that a subnational jurisdiction can significantly reduce CO2 emissions while strengthening its 

economy. See http://www.sustainableprosperity.ca/d1872&display for a report of 

the first four years of this program. 

As you determine the options that states will have to be in compliance of EPA 

regulations, I request that you consider the following: 

1) A carbon tax should be clearly specified in the final rule as a viable means of 

compliance. 

2) You should include clear guidance on the administration, implementation, 

price and escalation rate for a tax that would satisfy the requirements of 

EPA's new rule. 

States should have as many options available to them as possible, as long as they are 

effective in reducing carbon emissions. A carbon tax would be highly effective and 

easy to administer. If states choose to make such a carbon tax revenue-neutral, it 

will also strengthen their economies. 

On behalf of our children, grandchildren and future generations, thank you for 

taking a step to address the causes of global warming, the most urgent challenge of 

our lifetime. 

Susan Secord 

1280 Fairfield Drive 

Boulder, Colorado 80305