Comment Log Display

The rationale for discarding Alternative 5, the carbon fee, is
entirely based on conjecture.  Cap-and-trade is asserted to provide
certainty as to emissions reductions.  This is blatantly incorrect,
as Europe learned recently.  

The initiation of a cap-and-trade system requires the development
of vast new complex institutions, and depends on highly educated,
highly paid professionals, operating without transparency.  This is
a recipe ripe for manipulation.  Consider the sub-prime mortgage
and credit default swap crisis as a foretaste of the shennanigans
that cap-and-trade are likely to bring. That crisis has taught us
that a system that can only be understood by specialized PhDs is
not robust enough to base an economy on. The very popularity of
cap-and-trade with the business community ought to raise red flags
as to whether the public interest will be endangered. 

A carbon tax, on the other hand, will be very simple to implement.
 The institutions are mostly in place already.  While more
accountants will need to be hired to assume the larger
responsibilities of a carbon tax system, nothing exotic is needed. 
It will be easy to catch bad actors.  

And should monitoring determine that the trend line of GHG
reductions is not steep enough, the tax can easily be adjusted. 
This isn't rocket science.  Cap-and-trade, on the other hand, IS
rocket science.

I request that Paragraph G on page J-87, the analysis for
Alternative 5, be withdrawn and be recirculated with a conclusion
consistent with the comments above.