As CCJ reported last week, the comments are in on some initial work by NHTSA and EPA on Phase II of the fuel efficiency standards for medium- and heavy-duty trucks. The story featured the formal comments filed by truck and engine makers and industry associations. I didn’t include the comments from environmental advocacy groups because I’d already let the story run long, and my brain hurt from skimming hundreds of pages of climate science.
I’ll not go into much detail here (the documents are linked, so feel free to dig in), but the gist is that it doesn’t matter whether one is terrified of global warming or furious that a malevolent hoax is destroying democracy, the issue is whether the government takes man-made climate change seriously and regulates accordingly.
Here are some highlights from proponents of strict regulation of greenhouse gas emissions:
• The Environmental Defense Fund devoted its comment to explaining the importance of setting an accurate figure for the Social Cost of Carbon. This is important because government rulemaking has to include a cost-benefit analysis. The higher the benefit (reduction of harmful carbon) the higher the cost to industry may be. (Remember FMCSA’s questionable science on the health benefits to drivers of an extra hour of rest?) A federal Interagency Working Group has set the figure at $37 per metric ton of CO2, that’s up from the 2010 estimate of $24/ton.
The bottom line for trucking: EDF calls for at least a 40 percent reduction in average fuel consumption for the entire fleet by 2025, compared to 2010 trucks. “Such standards are technically feasible, economically beneficial and fundamentally required to alter the upwards path of medium- and heavy-duty GHG emissions and fuel consumption,” says the analysis, signed by six PhDs and three lawyers.
Will the industry get tax relief for the investment needed for that 40 percent reduction? Not anywhere near $37/ton in CO2 reduction, I’ll wager.
