The Trump administration is using fallacious reasoning to justify freezing US vehicle emissions standards at 2020 levels. Canada must not follow suit.
(This article has been translated from French.)
Mincing no words, the latest report of the UN Intergovernmental Panel on Climate Change (IPCC) delivers a sobering reality: to limit global warming to 1.5°C, the human race has 12 years left to change course. A climate catastrophe can still be avoided, say the researchers, because we know what the solutions are and have the technologies to implement them. What is lacking is the political will.
In the United States, nowhere is this lack of political will more evident than in the area of vehicle fuel efficiency. In effect, in April 2018 the Trump administration ordered the US Environmental Protection Agency (EPA) to weaken the federal regulations on greenhouse gas (GHG) emissions from passenger vehicles and light trucks, by proposing to freeze them at 2020 levels. It also attempted to revoke California’s authority to impose stricter standards than those established by the federal government (the state had been entitled to do so since the 1970s due to serious problems with smog). This attempt at revoking California’s authority will be the subject of litigation brought forward by the state. Measured over 10 years, from 2020 to 2030, these decisions will drive up GHG emissions by several million tonnes in the United States. In addition, it will saddle motorists with thousands of additional dollars in gasoline costs over the life of their vehicles, given that automobile manufacturers will no longer be incited to make more energy efficient vehicles.
This is yet another blow in the White House’s war against environmental protection. And this time, the American decision will have a direct impact on Canada, because it could lead to an equivalent freeze on the Canadian regulations, as we explained previously in Policy Options.
Apologists of the rollback
In a 500-page document published this summer, the National Highway Traffic Safety Administration (NHTSA), in cooperation with the EPA and the Department of Energy, stated that if we continued along the same path, our planet would become 4°C hotter by the year 2100. The report describes the disastrous consequences for the environment and humanity: forest fires, rising sea levels, loss of biodiversity and so forth.
Yes, you read right: an agency of the Trump administration recognizes the impact of climate change on the United States, as surprising as that may seem! But hasn’t the President loudly proclaimed global warming to be a hoax? This seeming contradiction has an explanation, albeit a deeply disturbing one.
The authors’ aim in this document was not to expose the threat of climate change, but to serve as apologists for the decision to weaken the federal regulations requiring automobile manufacturers to produce more fuel-efficient vehicles. According to the NHTSA, stricter standards would generate such a negligible GHG emissions reduction that it would simply not be worth the effort. And yet, the cost-benefit analyses carried out for the regulations show the opposite to be true. In Canada alone, the existing regulatory regime is delivering a windfall of several billion dollars in net benefits!
While the US administration’s posturing surprises no one ― the government seems hell-bent on keeping the country reliant on fossil fuels ― its rationale to support this position is troubling, to say the least.
To make its case, the EPA issued a notice of determination. A rhetorical tour de force, the notice argues that the vehicle emission standards would lead to a thousand more deaths per year on America’s highways. The reason? To meet the standards, the EPA argues, automobile manufacturers will have to produce lighter vehicles, which are less resistant to collision and more expensive. A further consequence: thanks to the fuel savings generated, motorists will use their vehicles more and keep them longer because of the higher sticker price. This will raise the death toll on our roads, since the older vehicles will not be equipped with the latest safety technologies.
Scientists have been studying the phenomenon of increased driving due to fuel savings (known as the “rebound effect”) for some years now. Although real, its importance is up for debate. The OECD Environment Working Papers, along with a number of other studies, disprove the assertion that the gains from vehicle fuel efficiency are cancelled out by the rebound effect. Thus, the EPA’s argument does not hold water.
In claiming that the sticker price will dissuade consumers from purchasing newer, safer vehicles, the EPA fails to take into account the savings at the pump, which translate into a two-year return on investment for most vehicles. It also neglects to consider that consumers will save thousands of dollars in fuel costs over the life of their vehicle. The only thing the EPA is factoring in is the purchase price. Its conclusions could not be more wrong.
As for the argument that vehicles will be less resistant to collisions because they will be lighter (albeit safer thanks to cutting-edge technologies), the EPA leaves out an important factor. To replace steel and aluminum, manufacturers will be using more carbon fibre, which is more solid and resistant. “Light” does not mean “less safe,” and yet that is precisely what the EPA would have us believe.
This incoherent argument also obscures the fact that road fatalities are caused by other, widely recognized factors: speeding, traffic violations, driving under the influence, distracted driving, increased traffic and driving without a seatbelt. No one — at least, no one outside the Trump administration — would have the audacity to link motor vehicle mortality to GHG emission standards and fuel savings.
Fatalism as a way out
What is alarming in the NHTSA analysis is that it cherry-picks the worst-case global warming scenario from the IPCC report (Scenario A1FI) and treats it like a fait accompli. Under this scenario, the countries of the world would take no significant measures to curb their carbon emissions. The NHTSA conveniently forgets that 184 countries have ratified the Paris Agreement on climate. Countries, states and cities are actively working to lower their GHG emissions, with success, including the recent reduction in GHG emissions in the USA.
In fact, the NHTSA is using this scenario to justify defanging the vehicle emission standards for passenger vehicles and light trucks. Curbing GHG emissions, it claims, “would require the economy and the vehicle fleet to substantially move away from the use of fossil fuels, which is not currently technologically feasible or economically practicable” [page 5-30]. That is false. On the technological and economic front, electrification of transportation is well under way, and car manufacturers are complying with the regulations and developing technologies faster than expected.
The aim of this article is not to argue that the Trump administration lacks credibility when it comes to combatting climate change — it is making that case all by itself — but to point out how crucial our government’s position will be. If Canada were to follow the US federal administration’s lead, we would be parroting the lies of the White House and giving up the fight against climate change.
To maintain its international credibility and meet its commitments under the Paris Agreement, Canada must break with the United States and establish its own regulations. In fact, it must adopt a more ambitious set of measures to lower GHG emissions from the transportation sector and thereby achieve the targets it has set for 2030.
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