An Oldie But A Goodie: John Christy’s Letter to Lisa Jackson on Fuel Economy Regulation

Well, it’s not really so old. I’m referring to a March 10, 2009 letter by atmospheric scientist John Christy to EPA Administrator Lisa Jackson. I post it on Open Market and GlobalWarming.Org because it is hard to find on the Internet, and Dr. Christy makes a key point that will need to be made again and again in the upcoming Senate battle over the Murkowski resolution of disapproval to veto EPA’s endangerment finding.

The endangerment finding is the  statutory prerequisite for the joint greenhouse gas/fuel economy standards rule that EPA and the National Highway Traffic Safety Administration (NHTSA) finalized on April 1, 2010. Veto the endangerment finding, Murkowski foes warn, and NHTSA will have to ”de-couple” its portion of the joint GHG/fuel economy rule, which could delay by a year implementation of model year 2012 fuel economy standards.

Well, boo-hoo! Keeping the model year 2011 standards in place for an extra year would make no perceptible difference in atmospheric CO2 concentrations, average global temperature, weather patterns, or public health, even if one assumes that climate change is a big problem.

Christy’s letter puts this in perspective. For the sake of argument, Christy adopts the IPCC’s warming projections for its mid-range (A1B) emissions scenario. Even if the United States were to adopt immediately a 43 mpg fuel-economy standard, the net reduction in average global temperature would be 0.01°C in 2100. Such a change would be too small to detect. Even more microscopic would be the impact of the 34.1 mpg standard that NHTSA and EPA want to phase in by model year 2016. Whether that standard is delayed for a year or implemented on schedule is climatologically irrelevant.

In contrast, the economic and safety benefits of a one-year delay could be substantial. The distressed auto industry would not have to spend an estimated $5.9 billion in incremental technology investments (Table 4A.5-6) in model year 2012.

In addition, slower implementation of economy standards would slow the pace at which automakers decrease average vehicle size and weight. Reducing vehicle weight and size is a vintage method of improving fuel economy — but it also negatively affects vehicle safety. NHTSA’s 2002 fuel economy report concluded that regulatory-induced vehicle downsizing contributed to 1,300-2,600 fatalities and 13,000 to 26,000 serious injuries in 1993, a typical year. 

EPA and NHTSA struggle to belittle the size-safety tradeoff in their joint rule. However, they do include a “worst-case” scenario in which the new standards cause an additional 493 deaths in model year 2016 (see p. 144). Slowing the pace of fuel economy regulation would save lives.