In an end of a terrible year news dump, this morning EPA released its final aircraft CO2 standard. Some reflections, based upon over a decade of research @TheICCT (1/x) https://www.epa.gov/regulations-emissions-vehicles-and-engines/control-air-pollution-airplanes-and-airplane-engines-ghg
Control of Air Pollution from Airplanes and Airplane Engines: GHG Emission Standards and Test...

EPA finalizes rulemaking for control of Air Pollution from Airplanes and Airplane Engines: GHG Emission Standards and Test Procedures

https://www.epa.gov/regulations-emissions-vehicles-and-engines/control-air-pollution-airplanes-and-airplane-engines-ghg
Quick recap: after more than a decade of delay, in July EPA proposed a standard that, by its own admission, would allow aircraft CO2 to increase by at least 40% through 2040 and require no new investments on the part of manufacturers. (2/x) https://twitter.com/rutherdan/status/1286012420540964864
It was a stunningly weak proposal, with its centerpiece a 2028 standard that new aircraft being sold today already meet handily, as shown here (3/x)

https://theicct.org/publications/fuel-burn-new-comm-aircraft-1960-2019-sept2020
EPA’s justification for the proposal was that the US needs to harmonize with international (ICAO) requirements. Translation: US airframers need a domestic standard to sell their planes internationally. Fair enough. (4/x)
But EPA never made a clear case why the standard couldn’t be stronger since new aircraft today generally meet the 2028 standard by 10% or more. Member states can and do adopt more strict requirements than ICAO’s for safety and noise, for example. (5/x)

https://theicct.org/sites/default/files/publications/ICCT-ICAO_policy-update_revised_jan2017.pdf
But EPA never made a clear case why the standard couldn’t be stronger since new aircraft today generally meet the 2028 standard by 10% or more. Member states can and do adopt more strict requirements than ICAO’s for safety and noise, for example. (5/x) https://theicct.org/sites/default/files/publications/ICCT-ICAO_policy-update_revised_jan2017.pdf
But EPA never made a clear case why the standard couldn’t be stronger since new aircraft today generally meet the 2028 standard by 10% or more. Member states can and do adopt more strict requirements than ICAO’s for safety and noise, for example. (5/x) https://theicct.org/sites/default/files/publications/ICCT-ICAO_policy-update_revised_jan2017.pdf
So, 11 states plus DC, which account for about half of US aviation emissions and are federally preempted from regulating aircraft, signaled that they would sue EPA if the proposal wasn’t rescinded. (6/x) https://www.law.nyu.edu/centers/state-impact/issues/climate-action/aircraft-emissions
The Trump administration’s response? 1) Move up the timetable for a final decision from July 2021 to today; 2) Finalize the do nothing 2028 standard with no substantive changes; and 3) Enforce it immediately. (7/x)

https://www.epa.gov/sites/production/files/2020-12/documents/aircraft-ghg-caa-frm-2020-12-23.pdf
Why not tighten the 2028 requirements to at least reflect aircraft that are already beyond sold today? EPA’s arguments, with translation, are as follows. (8/x)
1) Adopting meaningful standards would place US manufacturers at a competitive disadvantage.

Translation: Requiring that OEMs sell more fuel-efficient planes, EVEN ONES THEY ALREADY MAKE, would bankrupt Boeing. (9/x)
(Regular readers will recognize a variation here of the Gandalf principle, whereby the aviation industry is continuously improving at exactly the correct rate and any attempts to accelerate that will end in disaster.) (10/x)
2) EPA has discretion to set the standards it desires, balancing emissions, safety, noise, and other factors.

Translation: We don’t want a stricter standard, and requiring that US manufacturers sell the aircraft they already build will make them dangerous and loud? 🤷‍♂️(11/x)
2) EPA has discretion to set the standards it desires, balancing emissions, safety, noise, and other factors. Translation: We don’t want a stricter standard, and requiring that US manufacturers sell the aircraft they already build will make them dangerous and loud? (11/x)
2) EPA has discretion to set the standards it desires, balancing emissions, safety, noise, and other factors. Translation: We don’t want a stricter standard, and requiring that US manufacturers sell the aircraft they already build will make them dangerous and loud? (11/x)
3) Adopting the @ICAO standard that won’t reduce emissions is critical to future cooperation to reduce worldwide emissions.

Translation: none necessary. (12/x)
3) Adopting the @ICAO standard that won’t reduce emissions is critical to future cooperation to reduce worldwide emissions. Translation: none necessary. (12/x)
3) Adopting the @ICAO standard that won’t reduce emissions is critical to future cooperation to reduce worldwide emissions. Translation: none necessary. (12/x)
4) Adopting internationally harmonized standards and test procedures will reduce the regulatory burden for US manufacturers.

Note: True, but tighter standards can be combined with the same test procedures to get a better result. One approach: (13/x)

https://theicct.org/publications/us-passenger-jets-icao-co2-standard
5) These standards will prevent backsliding on aircraft fuel efficiency, which is improving continuously due to market forces already.

Translation: 🤦‍♂️ (14/x)
6) Manufacturers will build even better planes in anticipation of future technology following standards that will by definition pass said planes.

Translation (1): Either regulators or manufacturers are suckers. (15/x)
Translation (2): Manufacturers will invest more in order to maintain large margins to the standard to please their airline customers.

There's an element of truth to this — even better would be to add incentives to promote overcompliance: (16/x)

https://theicct.org/publications/economic-incentives-fuel-efficiency-under-us-aircraft-co2-standard
Overall, pretty weak arguments to support a standard that EPA itself argues is below BAU. So why this rule, and why now? Two reasons.(17/x)
First, US manufacturers need a domestic CO2 standard in order for @FAANews to certify future designs for international sale. So this rule maintains manufacturers' access to FAA’s light regulatory touch rather than having to certify their planes overseas. (18/x)
Second, a final rule now will make it harder for the next administration to take action. That’s necessary given Biden’s commitment to net zero emissions plus the current US goal of capping airline emissions at 2005 levels starting this year (19/x).

https://www.icao.int/environmental-protection/Lists/ActionPlan/Attachments/30/UnitedStates_Action_Plan-2015.pdf
So, what’s next? In all likelihood, a lawsuit from those 11 states plus DC challenging EPA's standard. It will be interesting to see how hard the Biden administration decides to defend this in court. (20/x)
Long thread, much much more reading available for the interested (END):

https://twitter.com/rutherdan/status/1321895019674886144

https://twitter.com/rutherdan/status/1319303153292963840

https://twitter.com/rutherdan/status/1285959902410600449

https://www.nytimes.com/2020/07/22/climate/airplanes-climate-change.html
You can follow @rutherdan.
Tip: mention @twtextapp on a Twitter thread with the keyword “unroll” to get a link to it.

Latest Threads Unrolled:
Those who think consciousness raising & movement building are disconnected, or even a distraction from electoral politics have not paid attention to the history of social change.In this thread, we
Read more
The 2020s will be known as the Remote Work decadeA few predictions of what is likely to emerge[ a thread ] Third Space: Office and Working from Home will
Read more
1/29: Have you ever had a concept explained to you that helps frame complex issues you’ve been wrestling with and opens your eyes to new possibilities? A concept that I
Read more
By continuing to use the site, you are consenting to the use of cookies as explained in our Cookie Policy to improve your experience.