Comment Log Display

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.