I’m reading one of the leaked versions (May 30 draft) of the EPA’s forthcoming Advanced Notice of Proposed Rulemaking (ANPR), “Regulating Greenhouse Gas Emissions under the Clean Air Act.” The ANPR presents information relevant to, and solicits public comment on, how EPA should respond to the Supreme Court’s decision in Massachusetts v. EPA.
Among scores of issues discussed, EPA raises the question of what level of greenhouse gas (GHG) emission reduction from the transportation sector would be “appropriate” if (as seems very likely) the agency decides that GHG emissions from new motor vehicles endanger public health and welfare.
“Without prejudging this important issue, and for illustrative purposes only,” EPA compares the GHG-emission reductions achievable by the Energy Independence and Security Act (EISA) with three long-term reduction goals policymakers are debating. Those goals are: President Bush’s goal of stopping U.S. GHG emissions growth by 2025, the IPCC goal of stabilizing global GHG emissions at 450 parts per million (ppm) by 2050, and the Lieberman-Warner goal of reducing U.S. emissions 70 percent by 2050.
EISA, for those who may not recall, is the energy-related legislation Congress passed and the President signed in December 2007. EISA requires new passenger vehicles and light trucks on average to get 35 miles per gallon by 2020 — a 40-percent increase in mpg compared to pre-EISA fuel economy standards. In addition, EISA requires blenders and refiners to sell 36 billion gallons of biofuel annually by 2022, of which 21 billion gallons must be “advanced” (low-carbon) biofuels.
The EISA targets will be tough to meet. Of 1,153 vehicle models on the road in 2007, only two met the 35 mpg standard. Advanced biofuels have been “just around the corner” for years, and may remain prohibitively costly for years to come.
But let’s assume the auto and fuel industries overcome all economic and technical challenges and hit their EISA fuel economy and renewable fuel targets. Will they come close to achieving any of the aforementioned long-term emission reduction goals?
Not by a country mile. According to EPA (p. 83), “EISA provides about 25 percent, 15 percent, and 10 percent of the transportation emissions reductions that would be needed for mobile sources to make a proportional contribution to meeting the President’s climate goal by 2050 . . . , the IPCC 450 ppm stabilization scenario by 2050 . . . , and a 70 percent reduction in 2005 levels in 2050 . . . , respectively.”
If EISA is just a baby step towards the auto emission reductions EPA will require, then Detroit is in for a rough ride. Even the fuel-economy zealots at the National Highway Traffic Safety Administration caution [see p. III-3 of this report] that, as fuel economy standards increase, “the incremental benefits [in fuel savings at the pump] are approximately constant while the incremental costs [to the manufacturer] increase rapidly.” Consequently, “as stringency is increased, costs rise out of proportion to the benefits or the fuel savings. Increasingly higher costs have a negative impact on sales and employment.”
But be not afraid, because EPA’s regs will increase the number of “green jobs” — at EPA. Even if the eventual rule is limited just to the transport sector (very unlikely, given the Clean Air Act’s multiple interconnections), EPA will be Technology-Forcing Central for decades to come. College grads looking for job security should send their resumes to Environmental Protection Agency, Office of Air & Radiation, Climate and Transportation Division. Unfortunately, there won’t be enough jobs to go around for all the autoworkers displaced by far more stringent standards on a less profitable class of automobiles.