Air travel endangerment

May 16, 2016
Under pressure typical of the politics of energy and climate, the US Environmental Protection Agency soon will declare air transportation unhealthy. It should not also act as though air travel is too cheap.

Under pressure typical of the politics of energy and climate, the US Environmental Protection Agency soon will declare air transportation unhealthy. It should not also act as though air travel is too cheap.

The agency has submitted to the White House Office of Management and Budget its finding that emissions of greenhouse gases from aircraft engines endanger public health or welfare. It proposed the endangerment finding last June as a legally necessary first step toward Clean Air Act regulation of GHG emissions. The OMB submission indicates the process is nearly complete.

International standards

EPA is working in parallel with the International Civil Aviation Organization, part of the United Nations. The ICAO in February published recommendations, from its Committee on Aviation Environmental Protection, for an average 4% reduction in fuel consumption by new aircraft starting in 2028 from levels of aircraft delivered in 2015. The standards vary by takeoff weight, with the heaviest aircraft needing to achieve cuts of 11%.

The ICAO said the proposal accommodates improvements aircraft manufacturers have made in fuel-use efficiency and emissions performance. Boeing welcomed the move, saying the recommendations represent "real progress beyond the substantial industry achievements already made." If implemented, it said, the standard "will have the intended results of ensuring older aircraft are replaced by newer, more efficient aircraft that will further reduce fuel use and carbon emissions."

Environmental groups were less enthusiastic. The International Council on Clean Transportation said the standards "will serve primarily to prevent backsliding in emissions." Earthjustice called the standards "too weak to protect the climate." In April, it filed a lawsuit on behalf of the Center for Biological Diversity and Friends of the Earth calling on EPA to accelerate the rulemaking. The agency has indicated it will propose a regulation in 2017 that would take effect in 2018.

Environmental groups want EPA to make its regulation tougher than the ICAO recommendation. Groups representing aircraft manufacturers want EPA to conform with the ICAO proposal. They say multiple standards would compromise safety and generate uncertainty.

EPA should ignore the activist pressure. Environmental groups point with alarm to the rapid growth expected in air transportation and associated emissions of carbon dioxide. But it's growth from a small base. Air transport accounts for less than 2% of global emissions of CO2. Modernization of the aircraft fleet will continue to improve fuel-use efficiency and moderate whatever emissions increase accompanies the rise in travel.

Under a balanced approach to climate precaution, that would represent progress. Economic expansion would continue as environmental consequence per unit of growth diminished. But environmental groups won't settle for mere progress. They try to block GHG emissions immediately wherever they can, however they can.

Especially with air travel, their absolutism is unreasonable. People need to travel, often by air. Airplanes need liquid fuels. The only liquid fuels available in needed amounts and at reasonable cost come from hydrocarbons. Aviation fuel from renewable sources is available but too expensive and limited in supply to represent a practical substitute for petroleum. The best strategy for curbing emissions from aircraft engines therefore is to improve fuel-use efficiency. That's happening now in response to market forces, which include growing environmental concern from the traveling public.

Costs and safety

Requirements tougher than those proposed by the ICAO, capitalizing as they do on existing and anticipated progress, would raise the costs of building airplanes and ultimately of air travel. They would discourage ticket purchases by the most price-sensitive travelers and raise prices for everyone else. They probably wouldn't lower the number of air trips appreciably. They thus would have limited effect on emissions within a limited emissions category—and no effect on observed warming. And by deliberately straining aircraft manufacturers in single-minded pursuit of climatological goals, they probably would compromise safety.

Demands of the pressure groups promise unacceptable hardship and imperceptible benefit. Rejecting them would represent a refreshing display of restraint at an EPA usually too eager to regulate.