The Brattle Group is an economic consultancy with substantial worldwide experience in the energy industry, including electricity, natural gas and petroleum. Based in the United States, we also have offices in Europe, and have significant experience in the energy industries of Australia and New Zealand. We have performed extensive analyses of the economic issues surrounding greenhouse gas policies, primarily in the context of electric utility capacity planning and U.S. climate policy. This work has been informed by our deep experience in North American power and energy markets, as well as lessons from the European experience with its Emissions Trading Scheme. Our submission here reflects our own objective assessment of the issues involved; it is not made in the context of work for or a relationship with any client on these issues. We thank the Task Group for its efforts in advising on these complex and controversial topics, and for providing the opportunity to comment on these important issues.