Msg below submitted as comment on 09-22-14 at 0500P. Tracking number is lower case [ 1JH-8EIL-U4D4 ].
To: EPA
Re: Docket ID: EPA-HQ-OAR-2013-0602
Standards of Performance for Greenhouse Gas Emissions from Existing Sources:
Electric Utility Generating Units
There is abundant evidence that the earth is warming, that this warming is already producing harmful changes in our climate, and that these may become catastrophic if present trends continue.
We don’t need more evidence of the problem. We do need action to solve it, specifically to slow this warming. Most important is action to reduce the burning of fossil fuels.
You propose goals for each state to reduce greenhouse gas emissions (GHG) for electric power generation. This is an important step. You largely allow each state to decide its strategies and design its own plan. Conservation, greater efficiency, and alternative sources of energy can all play a role.
A fundamental holding in economics is that the use of something decreases as its price increases. Most economists agree that the most effective way to reduce the use of fossil fuels is to raise their prices.
One specific suggestion is to impose a fee on each kind of fossil fuel at its source: mine, well, or port of entry. Base the fee on the amount of CO2 that is produced when the fuel is burned. Start the fee low and raise it by a predetermined amount each year. This will provide a common base for planning by consumers and the business people who serve them.
The fee described above is commonly called a “carbon tax”. The revenue is controlled by the government and used in various ways. Examples: offset and allow other taxes to be reduced, support development of alternative sources of energy, assist those who are most adversely affected by the rising energy costs. All of these require government decisions and involvement.
A better approach, and the one I recommend, is called a “carbon fee and dividend” (CFD). The fee is established and collected like a carbon tax. But the revenue is divided into equal shares and distributed to the public. The CFD will produce the same incentives as a carbon tax, but with far less involvement of government. The free market will steer the funds to conservation programs and alternative sources of energy.
The carbon tax and CFD are normally presented as programs for the whole country. But they can be adapted to reduction of GHG emissions for power generation in single states. Impose the fee at the power plant, use some of the revenue to offset the increased energy costs for manufacturers of products that leave the state, and divide the remaining revenue among the residents of the state.
I strongly urge you to allow and encourage the states to include a carbon tax or CFD in their plans.
Bill Allen
44 Holmesbrook Road
Basking Ridge, NJ 07920
908-766-2876
wwallen29@verizon.net
September 22, 2014