Wednesday, December 03, 2008

What ARE they drinking at EPA -- and DHS?

The entertainment never stops! Not even with only 48 days to go before a major changeover in the powers in Washington, D.C.

Our fine friends at the federal level are really beginning to make me worry about their mental faculties -- and I'm not talking about the fine folks at our Friendliest Aeronautical Agency.

I'm talking about the dutiful people who worry about threats from our air and water at the Environmental Protection Agency and the nice folks who worry about threats from bad people at the Department of Homeland Security.

For most of the past eight years, the EPA has acted to reduce or otherwise eliminate protections, while the DHS has worked to guard us against, largely, us. We see the results of the latest DHS concern in the form of its Large Aircraft Security Program proposal;. from the EPA, its a proposal growing out of a court decision essentially forcing the department to regulate Greenhouse Gases, or GHGs -- something the agency's bosses have steadfastly resisted for most of the last six years.

So what does the EPA do, when forced to? Propose GHG regulations with no -- zero, zip, nada -- sense of proportionality.
Stay with me for a few graphs and you'll see what I mean -- and where the lines cross.

Years ago, the EPA evaluated GHG emissions and found that general aviation contributed only 4 percent of all the GHG produced by aviation – and that aviation in total produced only small minority percentage of the overall contribution of transportation equipment…which, in turn, was not a majority contributor of total GHGs emitted by the U.S.

We could have told the EPA that proposing to regulate GHG -- and, also, lead emissions -- for GA was impractical due to the small scale of use and the high cost of any conversion or equipment changes to the aircraft.

After all, according to various sources, U.S. use of avgas in 2006 totaled only 236 million gallons or so; that’s less than one half of one percent of what our cars use – and far, far less than what the kerosene-burners in Diesel- and turbine-powered vehicles burn.

So why – no, seriously, why? – is the EPA wasting valuable staff time and federal dollars, staff time and association dollars, and my time and dollars, even proposing such a non-useful set of rules change encompassing general aviation.

No, seriously! Why?

Isn’t the administration that loves to tout its devotion to the cost/benefit equation?

Unless the Bush EPA wants to tell me why it’s OK to let coal mine operators dump tailings into a stream, as it's about to allow in a loosening of rules, but horrible to let a relative handful of pilots contribute an inconsequential amount of GHG (or tetra ethyl lead) to the environment, it’s hard to believe these ostensibly smart people are serious.

I mean, geez! It took me only three minutes of Internet search time to come up with figures confirming – yes, factually – that avgas, in particular, and Jet A as used by general aviation – amount to a miniscule percentage of the fossil fuels pumped and burned in this country.

As concluded by an earlier EPA analysis of GHG emissions in the U.S., a good method for assessing the contribution of transportation segments is the amount of fuel they burn. Check with the handful of refiners; check with theFBOs; check with the distributors, pilots -- hell, try Wikipedia, for taxpayers' sake!

Guess what, EPA?

GA comes in dead last in the race – behind recreational boats, behind commercial marine vessels, behind our personal cars and commercial Diesel trucks, which all ran ahead of commercial jets.

EPA didn’t even need AOPA’s response. AOPA used EPA’s own GHG emission inventory to point out that general aviation’s contribution is a miniscule 0.74 percent of the overall transportation sector – which means GA’s contribution to the whole of GHG emissions is even smaller! When you peg the piston segment, well, that’s smaller still.

This proposal makes an observer wonder whether the EPA people who proposed this rather draconian idea for a totally inconsequential mode of travel might be sharing a water cooler with their federal colleagues over at the Department of Horrible inSecurities?

Both the EPA's GHG proposal and the DHS’s proposed Large Aircraft Security Program rules stand as sparkling examples of a skewed philosophy of applying to totally non-existent problems wholly ineffective solutions.

But then, why should I expect anything better in the final year of an eight-year run than we’ve gotten in the previous seven?

So if the EPA is open to a suggestion, withdraw your GHG NPRM, rewrite it with at least a nod to the segment with an inconsequential impact, and then resubmit. You'll be cost effective by saving us and you a lot of wasted staff time and money.

Although my expectations are zero for this, maybe EPA’s example would serve to enlighten the DHS and result in that department in withdrawing its LASP proposal – at least, that is, until the DHS can answer the basic question of how its proposal would do anything to improve security.

At least EPA has an answer to how the rules its proposed could improve air quality.

To its credit, DHS did recognize a point of diminishing returns for its theory on "enhancing" aviation security by ignoring airplanes weighing 12,500 pounds or less. But so far, DHS has failed to say anything more useful than the LASP proposed would “serve to enhance” aviation security as a justification.

And that statement carries the weight of credibility not even equal to the weight of hydrogen. Which means it might fly – but it won’t carry anything.

-- Dave Higdon


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