First Name | Adam |
---|---|
Last Name | Lazar |
Email Address | adamlazar@gmail.com |
Affiliation | |
Subject | Aircraft emissions in AB32 scoping plan |
Comment | Plain text version of comments follows; also included as an attachment in Microsoft Word. *********** Aircraft Emissions and the AB32 Cap-And-Trade Program December 10, 2008 Submitted By: Adam Lazar (SBN 237485) 1726 Page St Apt. 3 San Francisco, CA 94117 Introduction On behalf of myself and the public interest, the author respectfully submits these comments regarding the need to include airplane emissions in the AB32 Scoping Plan’s cap-and-trade program. The European Union has determined that aviation emissions contribute over three percent of the EU’s greenhouse gases, most of which are not subject to regulation under the Kyoto Protocol. The EU responded this year by including aircraft emissions in their cap-and-trade program. Aircraft engines emit significant levels of carbon dioxide, carbon monoxide, hydrocarbons, volatile organic compounds, nitrogen oxides, and particulate matter. It is well known that the carbon footprint of a commercial airplane far exceeds that of any other common mode of transportation. Moreover, the high-altitude discharge of greenhouse gases by aircraft engines cause a disproportionate impact on the atmosphere relative to surface discharges. Yet the California AB32 Scoping Plan appears to have overlooked these contributions and impacts entirely. This despite the seemingly large focus on other types of mobile sources in the Plan, via a combination of new engine and/or fuel regulations and the Pavley regulation of on-road vehicles. Given these other foci it is even more striking that references to aviation-derived emissions are wholly absent. Possible Justifications for Exclusion It is possible that regulation of aircraft emissions could derive from the Scoping Plan’s “inclusion of transportation fuels in the cap-and-trade program.” If this is so then the Scoping Plan should specifically identify aircraft fuel as included. Instead, there is a striking absence of discussion of aircraft in the text. Regardless, the inclusion of transportation fuels should be complimentary to, and not independent of, inclusion of aircraft emissions in the proposed cap-and-trade system. Aircraft Emissions As Incorporated Into EU Emissions Trading Scheme In September, 2008 the European Union issued a proposed directive to incorporate aircraft emissions into the EU Emissions Trading Scheme (“ETS”). The ETS is the Cap-and-Trade emissions program by which the EU meets its CO2 targeted reductions under the Kyoto Protocol. The EU proposed directive will require every plane departing from an EU member airport to purchase emissions credits to cover the CO2 emitted by the aircraft during flight . This credit requirement applies regardless of the nationality of the aircraft operator. California, like the EU, needs to include aircraft emissions in its cap-and-trade plan. California should become a world leader in regulating greenhouse gas emissions; a world leader should not ignore wholesale as large an issue as aircraft emissions. Note also that no entity has yet petitioned the US Environmental Protection Agency to regulate carbon dioxide emissions from aircraft. As with agricultural emissions, this area clearly needs to be more extensively regulated by the AB32 scoping plan. Addition of a Performance Based Standard CARB should consider additional regulation of aircraft emissions through performance-based standards on aircraft engines. This regulation is a reasonable and logical extension of the proposed regulation of other types of engines within the Scoping Plan. Aviation Emissions Reductions Through Public Transportation Projects (e.g. high speed rail) The Scoping Plan fails to specifically account for aircraft emissions reductions achieved through implementation of the California High Speed Rail. This despite the fact that the Los Angeles- San Francsico Bay Area market is far and away the largest aviation market in the state. Instead, the Plan only credits creation of high-speed rail for a single reduction in MMTCO2E in 2020—clearly undervalued if concurrent reductions in aircraft emissions are included. Co-Benefit of Cap-and-Trade and Regional Air Quality Attainment The AB32 scoping plan specifically attempts to identify public health benefits derived from climate change regulations. The NRDC identified aircraft emissions as a major contributing factor to regional non-attainment of air quality standards. Reducing aircraft emissions through their inclusion in California’s cap-and-trade system would provide clear health benefits in areas such as those surrounding LAX. Additional Means to Achieve Significant Aircraft Emissions Reductions Through Airport Efficiency In addition to including airplane emissions in California’s cap-and-trade scheme, the ARB should also include emissions-reducing measures both at the airport and/or as mandatory offsets for commercial ticket purchase. Virgin Atlantic Airlines has demonstrated how to decrease aircraft emissions at airports through towing aircraft from the gate to the taxiway. Continental Airlines has pioneered a program for customers to purchase carbon offsets for their flights. Each of these programs point to the variety of measures that could be considered by the ARB in its inclusion of aviation emissions in the AB32 Scoping Plan. Historical Omission of Aircraft Emissions In Air Regulation Aircraft emissions are historically regulated less than other common forms of transportation, leaving most meaningful emission reductions to a secondary benefit from improvements in efficiency and fuel burn. When NRDC conducted a survey of major airports across the country, it found that “Airports are not regulated in the same manner as other significant air pollution sources. Neither airports nor airlines are held accountable for the aggregate impacts of their ground-level aircraft emissions.” Given this history of under-regulation it is even more important to include aviation emissions in the AB32 scoping plan. Conclusion With the EU taking firm action on aircraft emissions as a significant contributor to global GHG emissions, California should attempt to mirror these efforts in order to create a position of global leadership for market-based emission reduction programs. Aircraft emissions should be included in the AB32 Cap-and-Trade plan, and performance-based standards for aircraft engines should be complimentarily implemented. The large direct benefit of these measures is further amplified by the indirect public health benefits in areas of high-density air traffic such as LAX. For all of these reasons, aviation should be addressed extensively, and control of their emissions should be integrated into the AB32 Scoping Plan document. |
Attachment | www.arb.ca.gov/lists/scopingpln08/1626-alazar_aviation_ab32_comments.zip |
Original File Name | Alazar Aviation AB32 comments.zip |
Date and Time Comment Was Submitted | 2008-12-10 11:20:39 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.