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

- tax

report-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 30years. 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 graduallyincreasing 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