Comments to EPA on Airplane Emissions Regulations
The Environmental Protection Agency (EPA) proposed airplane pollution standards that have no effect on emissions and require no technological improvements. EPA does analyze one scenario in the technical support for the proposal, however, that appears to have modest greenhouse gas emissions reduction effects. But the agency improperly monetizes and weighs those reductions. We submitted joint comments that detail flaws in EPA’s analysis and describe how the agency can correctly apply the social cost of carbon.