Strengthen the EPA's First-Ever Carbon Pollution Standards

Dear Administrator McCarthy,

Thank you for proposing a new rule to reduce carbon pollution from existing power plants. Reducing greenhouse gas pollution from power plants to mitigate the disastrous impacts of climate change is by far EPA's most urgent matter. Don't bow to climate change-denying extremists or fossil fuel propagandists willing to threaten our survival for profit. The proposed rule is critically important, but falls short:

1 - It contains massive loopholes: there are no limits for burning biomass, which can spew more carbon than coal; polluters have a full year to start building plants that will forever be exempt from limits; new plants can pollute freely for ten years if they invest in mythical "carbon capture and storage" (CCS) technology, which would cost time and money we need for renewables and efficiency. CCS actually would require burning more coal, which means more coal ash and more destructive mining.

2 - The rule should encourage clean energy and energy efficiency and not incentivize more nuclear power plants, or natural gas by counting changes to fracked gas power plants as an emissions reduction. Fracked gas has lifecycle greenhouse gas emissions close to, and possibly worse than, coal. Solar and wind power continue to grow exponentially nationwide--and along with energy efficiency this and power storage is where the states should concentrate efforts. I urge you to encourage states to include significant renewables in their plans so that by 2030, power sector carbon emissions are cut in half from today's levels.

3 - The rule should not allow states to meet targets via cap-and-trade, which benefits big corporate polluters who decide how to limit emissions based on profit. This makes it cheaper for the dirtiest plants to simply pay for permits instead of cleaning up pollution.

4 - Already, many states can reduce carbon beyond the rule's targets because they are retiring dirty power plants and scaling up renewables and energy efficiency. The standard should weigh this progress as a base to be built upon, not an excuse for states to avoid further action. The EPA has estimated that we could make faster reductions--27% by 2020 and 29% by 2025.

Please strengthen the rule accordingly.