Repetitive nagging from EDF and others prompted me to spend part of Earth Day composing the following comments in support of EPA Docket ID No. EPA-HQ-OAR-2011-0660 to limit carbon dioxide pollution from new U.S. power plants.

Dear EPA Administrator Lisa Jackson,

Thank you for advancing new carbon pollution standards for newly built power plants. I am greatly pleased to see the EPA taking action to carry out its mission of protecting human health and the environment. As the EPA knows well, decades of scientific research has demonstrated the negative effects created by greenhouse gas induced climate change. The U.S. is well past due for definitive action on this most serious environmental issue.

However, I am deeply disappointed that this effort to restrict greenhouse gas pollution, while targeted at large emitters, is piecemeal and regulatory in its approach. Numerous economic analyses have shown that the best way to mitigate the negative impacts of greenhouse gas pollution is through an emissions tax and/or emissions credits trading protocol, which would allow the free market to allocate investment capital to the technologies that most efficiently provide the energy we need without adding to atmospheric greenhouse gas levels. Such a comprehensive, market-based approach would affect all greenhouse gas emitters in all sectors of the economy and not penalize only builders of new power plants.

Even if the President and Congress do not have the political will to address this serious issue facing the country and the world, the EPA has a mission-driven commitment to do so. I urge that this move to regulate industrial carbon pollution from new power plants be integrated into a comprehensive, market-driven framework to phase in a nationwide cap on our greenhouse gas emissions to achieve the long-term goal of 350 parts per million of atmospheric carbon dioxide in the most economically efficient manner possible.