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Comments on Aircraft Greenhouse Gas Emission Standards

We recently submitted comments to the EPA regarding their endangerment finding and advance notice of proposed rulemaking on greenhouse gas emissions from aircraft. Our comments identify several economic efficiency problems that could undermine the EPA’s regulatory options, such as the EPA’s proposal to enforce performance standards only for new and in-production aircraft. We believe that such policies would unnecessarily risk inefficiencies from grandfathering, limited compliance flexibility, the rebound effect, enforcement difficulties, and a piecemeal sector-by-sector strategy.

In determining the stringency of aircraft emissions standards, we suggest that the EPA should use a cost-benefit analysis that reflects the social cost of carbon and the full range of other social benefits. In addition, we suggest that the EPA should create aircraft emissions standards independently of any international standards created by the International Civil Aviation Organization’s Committee on Aviation Environmental Protection (ICAO/CAEP), and create more stringent standards if cost-benefit analysis justifies doing so. In the event that the ICAO/CAEP process does not result in the adoption of aircraft emissions standards, it is our belief that EPA should continue to pursue such standards.

Our comments echoed many of the points included in our 2009 petition to the EPA calling for a cap on greenhouse gas emissions from all vehicle fuels (including aircraft fuels) under section 211 and 231 of the Clean Air Act.