Emissions vs. Efficiency: Industry Can't Have it Both Ways

Add the Association of International Automobile Manufacturers (AIAM) to the list of industry heavyweights lending support to EPA's legal defense in the California waiver dispute. AIAM issued the following statement today, and in the process revealed some glaring flaws in their reasoning:

"This is not a lawsuit to resist greenhouse gas emissions regulation. Rather, our intervention is focused on only one issue -- who should set those standards," said Michael J. Stanton, President and CEO of AIAM. "We believe that for important policy and legal reasons, it is the federal government that should set those standards."

Stanton added, "In fact, AIAM was one of the most vocal supporters of the Energy Independence and Security Act of 2007, which requires an overall interim fleet standard of at least 35 mpg by 2020 - an increase in fuel economy of 40% or more - and the 'maximum feasible' level fuel economy by 2030.”

Leaving behind the reality that legal text and precedent-- not any legal and policy rationales AIAM might have for wanting a different regulatory regime-- are at stake here, Stanton is also wrong when he says that the industry isn't resisting greenhouse gas emissions regulation. That's because CAFE standards, which he cites the industry's (grudging) support for, are, by definition, auto efficiency standards that aren't directly related to emissions regulation.

To be sure, increased efficiency does have the secondary result of producing cleaner-emitting cars, and regulators charged with implementing CAFE do have to consult with EPA and take environmental impacts into account (note: they were recently found to be doing a poor job of this). But its not an emissions standard, explicitly focused on the environmental and public health impacts of CO2 emissions, by any stretch of the imagination. And no spin-driven attempt to substitute CAFE for California's GHG emissions program can change that.

The funny thing is, the industry is already on record arguing in court (incorrectly and unsuccessfully) that the Pavley standards are essentially a fuel efficiency program. Now, they're claiming that its the other way around, and CAFE is essentially a means to address emissions concerns. Both are in support of the same overarching preference for a single national standard, focused on efficiency and set by the Department of Transportation, but the rhetorical acrobatics engaged to make that case are worth noting.

Comments

[Larry Fafarman]

--"To be sure, increased efficiency does have the secondary result of producing cleaner-emitting cars, and regulators charged with implementing CAFE do have to consult with EPA and take environmental impacts into account (note: they were recently found to be doing a poor job of this). But its not an emissions standard, explicitly focused on the environmental and public health impacts of CO2 emissions, by any stretch of the imagination. And no spin-driven attempt to substitute CAFE for California's GHG emissions program can change that."--

What? "Not an emissions standard"? California's proposed GHG emissions standards are expressed in terms of fuel efficiency, not in terms of GHG emissions measurements in standardized tests.

[Timothy Dowling]

Larry -- You're the victim of misinformation. Here's the description of the Cal. regs from the Green Mountain Chrysler opinion (508 F. Supp.2d 295: "The AB 1493 Regulations provide that carbon dioxide emissions for passenger cars and light duty trucks less than 3750 pounds be less than 323 grams per mile starting with the 2009 model year, and decrease to 205 grams per mile of carbon dioxide in the 2016 vehicle year and beyond. The corresponding values for emissions of carbon dioxide in grams per mile for light duty trucks over 3751 pounds and medium duty passenger vehicles is 439 grams per mile in 2009, and 332 grams per mile in 2016 and beyond. The AB 1493 Regulations address four greenhouse gases: carbon dioxide, methane, nitrous oxide and hydrofluorocarbons. Although the emissions standards are expressed in grams of carbon dioxide per mile, the AB 1493 Regulations provide formulae for the conversion of other greenhouse gas pollutants to their carbon dioxide equivalents. The AB 1493 Regulations detail the method for computation of fleet average carbon dioxide emissions for the vehicle fleets being regulated."

The regs are available at Cal. Code Regs. title 13, section 1961.1 and they confirm this description. If you're going to comment on the content of the regulations, read them first.

[Larry Fafarman]

--"If you're going to comment on the content of the regulations, read them first. "--

Then why have all the news reports expressed the California greenhouse gas standards in terms of fuel efficiency? I didn't read the regulations because I did not suspect that the news reports were wrong.

Anyway, on conventional motor vehicles, there is a definite correlation between fuel efficiency and greenhouse gas emissions.

[Timothy Dowling]

Larry -- The auto industry does a very good job of confusing people on this issue, including the news media. If you want accuracy on these matters, stick with Warming Law.