EPA regulation of aircraft emissions could hurt green innovation

By Steve Brachmann
August 5, 2016

"A C-141 Starlifter Leaves Contrails over Antarctica" by U.S. Air Force. Public domain.

“A C-141 Starlifter Leaves Contrails over Antarctica” by U.S. Air Force. Public domain.

In late July, the U.S. Environmental Protection Agency (EPA) exercised authority it has under the Clean Air Act to begin the push towards regulating aircraft emissions. The agency issued an endangerment finding in response to a citizen petition filed by environmentalist groups which finds that emissions from aircraft, especially from large commercial jet engines, contribute to climate change and endanger the health of both the environment and the American public. Several pollutants contained within these emissions were cited including carbon dioxide, methane, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and nitrous oxide.

A draft finding on the aircraft emissions released by the EPA this June noted that aircraft emissions are the single largest source of greenhouse gas (GHG) emissions in the transportation sector, which remains unregulated by U.S. federal agencies. According to the Center for Biological Diversity, aircraft emissions contribute 11 percent of all GHG emissions from transportation sources and 3 percent of overall U.S. GHG emissions.

The EPA noted that the agency is not issuing any rules regarding aircraft emissions along with this finding, although the endangerment finding is a first step on the way towards such rules. The agency did state that its regulations would be at least as stringent as carbon emission standards issued by the International Civil Aviation Organization (ICAO). This February, the ICAO’s carbon emission standards received a unanimous recommendation from the agency’s Committee on Aviation Environmental Protection (CAEP). The recommendation from this committee, which represents 170 nations, is another step towards adoption by the United Nations’ Governing Council. The carbon emission standards developed by the ICAO target an average 4 percent reduction in cruise fuel consumption of new aircraft delivered in 2028 compared to fuel consumption of aircraft delivered during 2015.

Some aircraft companies have already been in the business of developing biofuels which create a lower carbon footprint. A so-called “green diesel” is being developed by Chicago-based aircraft company Boeing (NYSE:BA) which can emit up to 50 percent less carbon than traditional fossil fuels over its lifecycle. Boeing completed the world’s first flight using a fuel blend including green diesel in December 2014 when its ecoDemonstrator 787 aircraft took off with a blend of 15 percent green diesel and 85 percent petroleum fuel in its left engine.

Another Chicago airline company, United (NYSE:UAL), has also gotten into the jet biofuel development game. That company has committed to buying 15 million gallons of sustainably produced jet biofuel from Pasadena, CA-based AltAir Fuels over a three year period. United will create a fuel blend containing 30 percent biofuel and expects to reduce its carbon emissions by 60 percent over the course of the fuel’s lifecycle.

New aircraft designs being pursued by Netherlands-based aerospace company Airbus Group (EPA:AIR) could significantly reduce the amount of fuel consumed on a per-flight basis. The company is developing a single-aisle plane known as the A320neo which can utilize next-generation engine options and fuel-saving wingtip devices. Airbus believes that the A320neo can reduce fuel consumption up to 20 percent per flight by the year 2020.

There’s no argument to make against the development of technologies that can reduce the impact of aircraft emissions on the environment. Indeed, the completion of the world’s first solar-powered flight around the globe by the Solar Impulse 2 this July shows that the future of aviation could happen without consuming a drop of fuel. However, there is an argument worth pursuing that increased environmental regulations are perhaps misguided in the notion that the progress of aviation innovation can fit into a federally appointed timeline.

The EPA isn’t the first federal agency which has waded into the debate over reducing aircraft emissions. In June 2012, the Federal Aviation Administration (FAA) unveiled an aviation GHG emissions reduction plan, which announced the ambitious goal of achieving carbon-neutral commercial growth, meaning no increased carbon dioxide releases in production or operation, for the U.S. commercial aviation industry by 2020. The FAA assumed that within eight years, aircraft would be utilizing alternative fuels and thereby reducing carbon emissions by 80 percent over the fuel’s lifecycle. New engine technologies, reductions in cruise speed and other fuel-saving tactics could improve fuel efficiency by up to 30 percent, the agency reasoned.

It’s been a few years since that FAA GHG reduction plan came out and yet the industry is not seeing the downward trajectory required to hit the ambitious fuel consumption reduction goals. According to statistics published by the U.S. Department of Transportation, jet fuel consumption by certified carriers has hovered between about 11 billion gallons and 10 billion gallons between 2009 and 2014. That’s down from a high point of 14.4 billion gallons in 1999 but recent years are not showing a significant reduction in the amount of fuel consumption which could be expected from increased efficiency.

The limited impact of aforementioned biofuel and other aircraft innovations is also worth considering. The highest production levels conceived by Boeing for its green diesel would only supplant 1 percent of the world’s total jet fuel demand. The 15 million gallons of biofuel being used by United is similarly only a tiny fraction of what federal regulators are expecting in terms of rapid alternative fuel use and the airline company is only shipping that fuel to Los Angeles International Airport at the moment. The Solar Impulse 2 did complete a flight around the world but it took 16 months to do so and had to be grounded for at least one long stretch to fix battery damage.

The effect of increased regulations for the energy sector and their effect on American jobs also deserves some scrutiny. Between September 2014 and April 2016, the American coal mining industry lost 191,000 jobs according to analysis of data published by the U.S. Bureau of Labor Statistics. At least some of this job loss can be attributed to climate change initiatives being pursued by President Barack Obama and the EPA which the U.S. Chamber of Commerce reported would eliminate as many as 224,000 jobs in the coal industry by the year 2030. Increased coal production in the face of coal job losses indicates that technological improvements are more deleterious to jobs in the coal industry but the costs associated with increased regulation certainly aren’t helping. And alternative energy industries are not replacing these jobs, recently evidenced in SolarCity’s decision to reduce its jobs commitment at a solar panel production plant in Buffalo to a third of its original promise before the plant has even opened.

Add the fact that climate change might not be the nightmare doomsday scenario some of the American political elite has been suggesting, and increased emissions regulations seem even more misguided. Consider the 2003 climate change report issued by the U.S. Pentagon, which suggested that the Hague region of the Netherlands and inland California would both be underwater by 2007. Almost the opposite of that has occurred in California, which suffers from a multi-year drought, and life in the Hague continues on as per usual. And despite all of the clamor over the scientific claims over the effects of manmade climate change, even the environmental scientific journal Nature published a study this April on Northern Hemisphere hydroclimate variability going back 12 centuries from a research team in Stockholm, Sweden, which questions the currently existing scientific models on climate change. The study found anomalies in climate model simulations and concluded that “much work remains before we can model hydroclimate variability accurately.”

The fact that climate science and climate predictions may not be as accurate as many believe certainly doesn’t mean we shouldn’t pursue clean, green technologies, and the green economy is coming along, as well it should. Of course, the green economy is in its very infancy. Politicians who assume that increased regulation will naturally cause innovation occur faster will likely have a rude awakening. Innovation is the mother of necessity, but mandating necessity does not always mean that innovation will become readily available over the short term to meet unrealistic goals. 

It is also important for politicians and regulators to keep firmly in mind the reality that increased costs for regulatory compliance draws money away from potential research and development initiatives.

A study of the economic impacts of air quality regulations on American manufacturing plants between 1972 and 1993 conducted by the National Bureau of Economic Research found that the economic cost of such regulations caused a decline of 8.8 percent of profits in the manufacturing sector. That’s $21 billion per year that did not go to employee wages and couldn’t be used on research and development. Reduced economic output in the face of rising population numbers also produces a drag on the overall economy and R&D initiatives are often the subject of the first budget cuts during economic downturns. All of this points to a downward spiral in which increased environmental regulations actually pose an obstacle to the development of the green economy in the United States.

The Author

Steve Brachmann

Steve Brachmann is a freelance journalist located in Buffalo, New York. He has worked professionally as a freelancer for more than a decade. He writes about technology and innovation. His work has been published by The Buffalo News, The Hamburg Sun, USAToday.com, Chron.com, Motley Fool and OpenLettersMonthly.com. Steve also provides website copy and documents for various business clients and is available for research projects and freelance work.

Warning & Disclaimer: The pages, articles and comments on IPWatchdog.com do not constitute legal advice, nor do they create any attorney-client relationship. The articles published express the personal opinion and views of the author and should not be attributed to the author’s employer, clients or the sponsors of IPWatchdog.com. Read more.

Discuss this

There are currently 23 Comments comments.

  1. Curious August 5, 2016 12:16 pm

    It is also important for politicians and regulators to keep firmly in mind the reality that increased costs for regulatory compliance draws money away from potential research and development initiatives.
    Who needs clean air? Let’s take the catalytic converters off of cars, the scrubbers off of smoke stacks, use high-sulfur coal. We can be more competitive then — just like China.

  2. Gene Quinn August 5, 2016 12:20 pm

    Curious-

    Obviously, you missed the point of the article. The article is correct in everything it says, and does not suggest taking catalytic converters off cars.

    Steve merely recognizes what is factually true. Politicians cannot snap their fingers and alternative, clean technologies appear. Given the many unrealistic demands of politicians when it comes to the environment what winds up happening is exactly the opposite of what they say they want to happen.

    -Gene

  3. Curious August 5, 2016 1:42 pm

    Given the many unrealistic demands of politicians when it comes to the environment what winds up happening is exactly the opposite of what they say they want to happen.
    I wouldn’t say that. Businesses are in the business of making money (i.e., maximizing shareholder wealth) — it is what they do. If they are given the choice — produce a product without pollution or to produce the same product (albeit cheaper) with pollution — a significant percentage are going to choose the later. It isn’t that they are necessarily bad people, but their mission is to make money — not create a clean environment.

    Regulations on business (in whatever form) is an attempt, by the government, to push industries in certain directions that they might not readily pursue (or to make them pursue a direction more vigorously). Why is it necessary? The answer is because businesses are out to make a profit — not necessarily concern themselves with pollution, safety of their workers, safety of their consumers, etc. Sure, maybe 19 out of 20 business owners want to do the right thing. However, if just 1 out of 20 does the wrong thing and is more profitable because of it and is able to take away market share from the others, the 19 out of 20 will be forced to make a choice: do the right thing and be uncompetitive or follow the lead of the 1 out of 20 and stay competitive. Unless regulations are in place to force companies to do the right thing, there will always be a temptation for businesses to try to get ahead by doing things that are not good for society, as a whole. Its just part of human nature.

    As for the aviation industry, something I know a bit about, they’ve been working on fuel efficient jet engines for decades. This hasn’t been because they were looking to reduce emissions but because even a fraction of percent of increase in fuel efficiency can save airlines millions of dollars a year. As such, engine manufacturers go to great lengths to maximize fuel efficiency. The reduction in emissions is just a side benefit. Regardless, while airlines (and airplane manufacturers) have an incentive to use/make more fuel efficient airplanes, regulations are just an added incentive to make that happen. Just like the patent realm, where innovation will happen without patents, the existence of patents increases the incentive for innovation. While one system is a carrot and the other is a stick, both are government intrusion on the free market to cajole/force the market into doing something it might not already do (or do quickly enough).

    While I understand why certain people are sensitive about the over-regulation of industry, I also understand why its done. I do not automatically assume that all regulation is bad — instead, I believe each regulatory action needs to be evaluated against the costs it imposes versus the benefits it provides.

  4. step back August 5, 2016 1:58 pm

    Sorry Steve (and Gene),

    I’m going to have to wade in with Curios on this posting.

    This posting is basic politics (right wing?) and no more.

    No amount of money, or patents or other “internalities” is going to make the “externality” problems of air pollution and climate change go away.

    It is pure rhetoric to throw in the FUD factor of current climate models not being perfect. Almost no model is perfect. Not even Ohm’s law.

    Before you start touting the virtues of biodiesel, acquaint yourself with the externalities of soil erosion, fertilizer production, embedded energies, removing aggrigable land from food production, etc.

    These are very complex problems. There is not going to be an easy fix-it solution. The more you know, the more you realize how little you know.

  5. Gene Quinn August 5, 2016 2:14 pm

    Step-

    Whether you want to believe what is written in the article doesn’t change the fact that what is written is perfectly true. That you think the truth is a right wing political statement is curious.

    -Gene

  6. Gene Quinn August 5, 2016 2:23 pm

    Curious-

    You explain that the industry has great incentive to reduce the use of fuel, which would then create as a side benefit a reduction in emissions. Despite that great incentive, as you explain, not much has been done. To think that the government making unrealistic mandates will accelerate the science where there is already incredible incentive is wide eyed optimism to say the least. It should be self evident that politicians cannot simply snap their fingers and complicated new technologies will be invented.

    You say: “I do not automatically assume that all regulation is bad…”

    And nothing in the article suggested that all regulation is bad. To the extent you and others think the article says that you are projecting.

    There is nothing wrong with government offering incentives. That is what the patent system is supposed to do but thanks to Congress and the Supreme Court no longer does to any acceptable level. Mandating the existence of new technologies is not an incentive, and chasing the impossible absolutely does drain precious resources from other research and development. All of this should be hardly controversial.

    You say: “I believe each regulatory action needs to be evaluated against the costs it imposes versus the benefits it provides.”

    That would be wonderful. If that were done, however, there would be little or no regulation of the environment by the US. Given how China and India pollute anything the U.S. does will have minimal impact. Of course, if the US government got out of the mandate business and believed more in the incentive business (i.e., the patent system and/or tax cuts) there would be a much greater likelihood that long term these environmental problems would be addressed with technological solutions. Having been achieved those technological solutions would then find ways to be adopted by even polluters like China and India.

    -Gene

  7. Curious August 5, 2016 4:14 pm

    Despite that great incentive, as you explain, not much has been done.
    Au contraire my friend. The following article (6 years old) describes the drive for 60% efficiency (a “holy grail”) for power generation turbines (extremely similar to jet turbines). It also describes the historical efficiencies of turbines.
    http://www.decentralized-energy.com/articles/print/volume-11/issue-3/features/gas-turbines-breaking.html

    The next article (dated just a couple months ago) talks about their turbine reaching 62.2% efficiency.
    http://www.businesswire.com/news/home/20160617005141/en/GE-Sets-Guinness-World-Records%E2%84%A2-Title-Efficient

    I suspect that nearly all of the advances used to increase the efficiency of power generation turbines could be used to increase the efficiency of jet turbines. BTW — measuring the efficiency of a jet turbine is a far more complicated task since its operating conditions vary during flight, from airplane type to airplane type, and from airline to airline.

    Mandating the existence of new technologies is not an incentive, and chasing the impossible absolutely does drain precious resources from other research and development.
    I don’t think the regulations are mandating the existence of new technologies — they are mandating increased efficiency. I’m sure the regulations don’t care how the manufacturers get there.

    And nothing in the article suggested that all regulation is bad.
    I didn’t suggest otherwise in my statement. However, I am aware of the politics underlying an article such as this, and those politics nearly universally take a very dim view towards government regulations.

    Given how China and India pollute anything the U.S. does will have minimal impact.
    Some pollution is global and other pollution is local. If you want to learn more about China’s pollution problem — type “blue sky day” & “china” into your favorite search engine. No solution will ever be perfect — consequently, we should not discard imperfect solutions because they are not perfect.

    if the US government got out of the mandate business and believed more in the incentive business
    The whole carrot or the stick distinction. Personally, I don’t have much of a problem with carrots. However, they cost money. While carrots are more friendly, they are far more costly to the government and, hence, infrequently used. Also, it raises the question as to whether we should be paying polluters not to pollute? Isn’t a polluter asking for money (e.g., in the form of a tax cut) not to pollute (i.e., doing something that endangers the health of the community) akin to extortion?

  8. Gene Quinn August 5, 2016 5:24 pm

    Curious-

    You say: “I don’t think the regulations are mandating the existence of new technologies — they are mandating increased efficiency. I’m sure the regulations don’t care how the manufacturers get there.”

    And that is exactly that problem. Regulators don’t care how you you achieve the mandates, or even if it is technically feasible.

    You say: “No solution will ever be perfect — consequently, we should not discard imperfect solutions because they are not perfect.”

    Agreed.

    You say: “While carrots are more friendly, they are far more costly to the government…”

    Not always. The patent system is a carrot that costs the government nothing. Why the government (i.e., Congress, Supreme Court and White House) are so thoroughly trying to destroy the patent incentive, which costs the government nothing, is a mystery.

    You ask: “Isn’t a polluter asking for money (e.g., in the form of a tax cut) not to pollute (i.e., doing something that endangers the health of the community) akin to extortion?”

    This presupposes that polluting is a crime. It is a crime because government says it is a crime. Now, I’m not in favor of polluting, which is why we constantly profile green technologies in such a favorable light even if it is only a step in the right direction, if only conserving energy, or cleaning pollution already made. Having said that, the entire point of this article is to explain that government mandates frequently backfire. That statement, which you and Step seem to take issue with, is 100% factually correct. Instead of encouraging long term solutions government mandates impossible targets over unrealistic time frames, which diverts most (if not all) research and development into meeting the government mandate rather than solving the problem once and for all.

    Government mandates diverting resources, again, is hardly questionable. I really don’t understand how what was written can be questioned. It clearly says that polluting is bad, we should pursue clean technologies, but that government mandates can and frequently do backfire.

    -Gene

  9. Curious August 6, 2016 12:57 am

    And that is exactly that problem. Regulators don’t care how you you achieve the mandates, or even if it is technically feasible.
    Why is that a problem? They are giving industries the flexibility to choose what to accomplish the goal. As far as feasibility, you don’t know unless you try.

    Not always. The patent system is a carrot that costs the government nothing.
    Because the costs are being borne by consumers who pay extra because of less competition. The patent system is special and we aren’t going to find many other programs like it.

    This presupposes that polluting is a crime
    That’s a presumption I’ll work with.

    the entire point of this article is to explain that government mandates frequently backfire
    I’m not sure what you mean by “backfire”? Will some dirty industries (e.g., coal) be hit hard? Yeah — but old industries being pushed aside because of new technology has been going on for decades/centuries. It happens. I don’t see those lost jobs as the regulations “backfiring.”

    I remember back when acid rain was considered to be a major ecological problem. However, because of laws passed in the late 80s, the US has seen a significant reduction in SO2 emissions and acid rain.

    That’s $21 billion per year that did not go to employee wages and couldn’t be used on research and development.That’s $21 billion per year that did not go to employee wages and couldn’t be used on research and development.
    That $21 billion (assuming that number is correct — I skimmed through the quoted paper — they employed a lot of estimates and conjecture) per year didn’t just disappear — it had to be spent on something. Odds are it went into the development/purchase of new technologies. It also paid for a much cleaner environment than existed in the 1970s. You cannot make an omelet without breaking some eggs.

  10. step back August 6, 2016 10:36 am

    @8= “Government mandates diverting resources .. is hardly questionable. I really don’t understand how what was written can be questioned. It clearly says that polluting is bad, we should pursue clean technologies, but that government mandates can and frequently do backfire.

    Gene,

    So what you are saying is that government “mandates” that all children be vaccinated against contagious diseases “frequently backfire”?

    Government “mandates” that all cars stop at red lights and go at green “frequently backfire”?

    Government “mandates” that patent rights of inventors should be respected “frequently backfire”?

    Well, strike that last one, but clearly in many areas, mandates are necessary to promote the general welfare and secure prosperity for ourselves and our progeny. And that includes having a livable climate/ environment in the future.

  11. Anon August 6, 2016 11:35 am

    A bit of levity, but does anyone remember late in the series of STNG, the Federation finding out that its own very mission to explore was disturbing the fabric of space (warp drive “pollution”)…. https://en.wikipedia.org/wiki/Force_of_Nature_(Star_Trek:_The_Next_Generation)

    Then to throw in my “root cause” analysis here (the underlying problem that is not being addressed): over population.

    It is only through the outsize scale of human activity that we have these “pollution” problems. The underlying problem is that our human population is outsized for the ecosystem of Earth, and any solution that does not include at its core some aspect of correcting the underlying problem is – at best – a band-aid, and at worse, may set off unforeseen consequences.

  12. Gene Quinn August 6, 2016 11:51 am

    Curious-

    If you seriously don’t understand why it matters that regulators consider how and whether there mandates are realistic there is no point talking to you.

    Everything in this article is perfectly accurate and should be self evident. Regulators who place unrealistic mandates do not help, they hinder progress. It is shocking this even has to be debated.

    You say: “I’m not sure what you mean by “backfire”? Will some dirty industries (e.g., coal) be hit hard? Yeah — but old industries being pushed aside because of new technology has been going on for decades/centuries.”

    And now we see that you are simply being intellectually dishonest.

    Sure, let’s put coal out of business. Never mind that there is no alternative solution to fill the energy needs that will be lost. We will just have to do with less energy. Brilliant solution.

  13. Gene Quinn August 6, 2016 11:53 am

    One more thought on putting coal out of business… Not only will that force Americans to use less energy since there won’t be anything to fill the gap, but it won’t actually do anything to clean the environment since China and others are using coal and other dirty forms of energy at a record pace.

    So let’s cripple the US economy for no benefit to the environment. That sounds like a BRILLIANT plan!

  14. Steve Brachmann August 6, 2016 11:53 am

    @Step – You haven’t addressed the issue of public money chasing bad science. In #4, you say “Almost no model is perfect.” While it’s true that even scientific theories can be challenged, factually-based challenges to the climate change debate continue and we’re not even close to having a strong model. I’ll reiterate the Stockholm study published in Nature and its findings that hydroclimate variability cannot be modeled accurately after looking at data going back 12 centuries. The only politics involved in this post is questioning whether or not the EPA’s actions here are ultimately useful in getting towards the end goal of a cleaner environment. If that came off as right-wing, that can only be because the left won’t accept a legitimate, rational argument against environmental activism. Also, you’re grasping at straws to argue against Gene’s assertion that government mandates can backfire. No one else here suggested anything in the way of anti-vaccination. Also, the red light argument: If you’re in a car driving a loved one to the hospital for an emergency, no cars are coming and you’re at a red light, you’re not going to break a government mandate in that situation? To be fair, that’s an extreme example, but if we’re talking about government mandates working 100 percent all of the time, it seems like a legitimate argument to make.

  15. Gene Quinn August 6, 2016 12:00 pm

    Step-

    You ask: “So what you are saying is that government “mandates” that all children be vaccinated against contagious diseases “frequently backfire”?”

    Can you please cite to where I said that?

    Obviously you cannot because I didn’t say that. Nice try though. That type of bait and switch is pretty ridiculous, don’t you think?

    Our entire conversation has been about unrealistic technologic mandates, which as I said can and do frequently backfire. It is really pretty straight forward, not sure why anyone is taking an issue with what I’m saying given we all know it to be perfectly true.

    Your rather absurd extrapolation is interesting though. You are equating childhood vaccines with technically unrealistic mandates. Are you saying that you believe that it is technically unrealistic to give children vaccines?

    So let’s go back to the discussion we are having. This article is about the FAA mandating solutions that at the moment appear technically unrealistic. As Curious pointed out (and actually supported my position, not his) the airline industry has had great incentive for years to solve this problem and has not (which is what the article also explains). So if there has already been tremendous incentive and great effort the FAA imposing unrealistic mandates will do nothing to help and can only hurt. Again, self evident if you aren’t looking at this through political colored glasses.

    -Gene

  16. step back August 6, 2016 1:58 pm

    @15 Gene,

    I think we can agree that a totally (100%) mandated economy cannot work and that a totally regulation free (0%) economy cannot work.

    There is some middle ground where some activities must be regulated and the solution to a problem must be fixed (i.e. vaccinating young children instead of killing off the sick ones as a solution to spread of contagion).

    As to the question of whether any and all “government” officials (including our anti-science, anti-patent US Supreme Court justices) know what is best for the rest of us, of course they don’t.

    The totally-divorced from science pronouncements in Alice, Bilski, Myriad prove that absolute power corrupts absolutely and government officials deserve to be criticized.

    But with that said, sometimes you and Steve need to be criticized.

    Helps keep you honest and stepped back a bit from right wing dogma. 😉

    http://patentu.blogspot.com/2016/06/spirit-town.html

  17. Gene Quinn August 6, 2016 2:01 pm

    Step-

    I’m happy to have you criticize us. The back and forth is perfectly fine. We aren’t going to agree on everything, and substantive discussion of the issues is always fun!

    Cheers.

    -Gene

  18. Anon August 6, 2016 2:09 pm

    I cannot believe that Gene did not bite on the Star Trek episode…

  19. step back August 6, 2016 2:13 pm

    Maybe he’s a Star Wars fan? Or Battle Star Galactica?

  20. step back August 6, 2016 2:18 pm

    @17 Gene,

    There is an old joke about an immigrant from a communist country coming to America.

    Someone asks him, “Back in your country did you have freedom of religion?”
    Answer, “No complaints.”
    “Dd you have freedom of speech?”
    Answer, “No complaints.”

    “So why did you come to America?”
    Answer, “To complain”.

    We are a country of complainers and criticizers.
    Thank goodness for the First Amendment.

  21. Curious August 6, 2016 11:56 pm

    If you seriously don’t understand why it matters that regulators consider how and whether there mandates are realistic there is no point talking to you.
    Why are you assuming that the mandates won’t be realistic?

    Everything in this article is perfectly accurate
    You’ve also written that the article is “factual true” (@2), “perfectly true” (@5). Let’s take for example, the statement that “the fact that climate change might not be the nightmare doomsday scenario some of the American political elite has been suggesting.” The fact is that I might win a billion dollar lottery and Trump might win the presidency and Putin might give back the Crimea just for the asking. All these statements are perfectly and factually true.

    Sure, let’s put coal out of business. Never mind that there is no alternative solution to fill the energy needs that will be lost. We will just have to do with less energy. Brilliant solution.
    Not the only solution, but using less energy certainly is a solution. After hearing years and years of the incandescent bulb industry whine about the regulations put into place that have most eliminated that technology in favor of CFL and LED, the prices of these “mandated” technologies have gone down and many people I know (including business) are switching. My electric usage has noticeably dropped as a result of my replacing every light bulb in the house.

    And now we see that you are simply being intellectually dishonest.
    I read these conclusory statements from examiners all the time. What statement are you referring to and why is “intellectually dishonest”?

    Never mind that there is no alternative solution to fill the energy needs that will be lost.
    No alternative solution? Really? You believe that? Natural gas use is steadily increasing. Wind now accounts for 4.7% of energy generation and is making great strides. Nuclear is always an option. While everybody’s whipping boy, solar power is getting real close to making a significant dent. Honestly, how can you say that there are no alternatives?

    it won’t actually do anything to clean the environment since China and others are using coal and other dirty forms of energy at a record pace
    Not all pollution is global. I made that point earlier, and it is worth repeating. Also, it isn’t hard to find articles saying how the Chinese are looking to reduce their consumption of high-sulfur coal. The Chinese may be corrupt but they are not stupid. Again, google how sensitive the Chinese are about their “blue sky days.”

  22. Curious August 7, 2016 12:01 am

    To be fair, that’s an extreme example, but if we’re talking about government mandates working 100 percent all of the time, it seems like a legitimate argument to make.
    So — if government mandates work 99% of the time and “backfire” 1% of the time, should we hail the successes or decry the failures? What if the numbers are 80-20? or 75-25? How successful does the government have to be before we can agree that the government has a legitimate role in creating these mandates?

  23. Curious August 7, 2016 12:30 am

    This article is about the FAA mandating solutions that at the moment appear technically unrealistic.
    Um … the FAA’s “aviation GHG emissions reduction plan” is not a “mandate.” As far as I can tell, this plan is not a regulatory action placing specific burdens on particular industries. Instead, it appears to be a public/private partnership that is more about developing technologies and helping airlines/airports/aircraft manufacturers reach goals.

    the airline industry has had great incentive for years to solve this problem and has not
    Increasing fuel-efficiency on airplanes will be a NEVER-ENDING problem to be solved.

    the FAA imposing unrealistic mandates will do nothing to help and can only hurt
    Again, no mandate being imposed. Setting a goal is not a mandate. The “plan” was described in this document https://www.faa.gov/about/office_org/headquarters_offices/apl/environ_policy_guidance/policy/media/Aviation_Greenhouse_Gas_Emissions_Reduction_Plan.pdf

    and describes “The total federal investment is expected to be $125 million over five to six years with the five aviation manufacturers contributing cost-­?share that matches or exceeds the federal investment. The CLEEN program focuses on advancing pre-­?commercial technologies for inclusion in the commercial aircraft fleet beginning in 2015.” This can only hurt?