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According to the judges, most of the well described barriers to tax emissions presented in the proposal are accurate. However, it is not clear how the proposed Lifetime Emission Surcharges (LESs) will overcome them since they have the same economic nature, that is, pricing. LESs differ because they price in advance and, consequently, require predicting of emission flows. If predicted emissions differ from observed ones, a great deal of inefficiency is introduced in the pricing system. The vehicle LES example, for instance, will assume similar use and maintenance levels for each model. Efficiency of pricing requires that actual emission levels are charged. The judges considered the option technically complicated for limited gain compared with raising carbon prices across the board (higher tax rates or lower caps). They argue that it faces the same difficulties that raising carbon prices face, but compounds challenges on the technical feasibility, among others. Therefore, the judges encourage the author to improve its design and implementation justification.
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