European Union\'s New Emmissions Proposal

¶ … European Union's New Emmissions Proposal on U.S.-Based Airlines

Study Structure

EU's Proposed Plans for the Aviation Industry

Stance Regarding the EU's Proposed Plans

How EU's Proposed Plans May Potentially Impact

EU Questions and Answers

Serious Long-Term Environmental Issues

Scientists Dispute

The Clearance

EU's Proposal

Northwest Airlines Plane Taking Off Figure 3: EU's Proposal - U.S. Objections

Northwest Airlines Plane Taking Off LIST of TABLES

Literature Summary on Climate Impacts

Impact of the European Union's New Emmissions Proposal on U.S.-Based Airlines

"By 2020, aviation emissions are forecast to more than double from present levels."

("FAQ on Aviation Emissions and Climate Change," 2008)

Background of the Problem

Emissions Reportedly Higher than Aircraft emissions are reportedly higher than those from certain entire sectors covered by the EU ETS. Contrary to reported successes by a number of other economical sectors to reduce emissions, unless countered, by 2012 emissions increases from flights from EU airports will negate more than one fourth of the 8% emission reduction the first 15 EU member states (EU-15) must achieve to attain their

Kyoto Protocol target. By 2020, as this study's introductory quote reflects, "aviation emissions are forecast to more than double from present levels." ("FAQ on Aviation Emissions and Climate Change," 2008) Until recently, no policies specifically addressing climate change required the aviation sector substantially contribute to reducing this contemporary controversial concern.

Research Question

This researcher contends this capstone paper which examines factors contributing to the contemporary controversial concern constitutes "a polished, proofread piece of writing" ("Guidelines for the Capstone Paper...," 2004) which purports to answer the following research question: Will the European Union's new emission proposal for the aviation industry adversely impact U.S. based airlines?

Statement of the Problem(s)

Concerns relating to the contention that the rapid growth in aviation emissions critically contribute to climate change reportedly prompted the European Commission (EC) to propose to include aviation in the EU Emissions Trading Scheme. The following excerpt from HIS's publication, "FAQ on Aviation Emissions and Climate Change," points out a number of significant statistics and relates to the reported primary problem the EU purports.

Direct emissions from aviation account for about 3% of the total greenhouse gas (GHG) emissions in the European Union (EU). The large majority of these emissions comes from international flights - flights between two member states or between a member state and a non-EU country. This figure does not include indirect warming effects, such as those from nitrogen oxides (NOx) emissions, contrails and cirrus cloud effects. The overall impact is therefore higher. The Intergovernmental Panel on Climate Change (IPCC) has estimated that aviation's total impact is about two to four times higher than the effect of its past CO2 emissions alone. Recent EU research results indicate that this ratio may be somewhat smaller (around two times). None of these estimates take into account the uncertain but potentially very significant effects of cirrus clouds.

EU emissions from international aviation are increasing rapidly - by 87% since 1990 - as air travel becomes cheaper without its environmental costs being addressed. For example, someone flying from London to New York and back generates roughly the same level of emissions as the average person in the EU does by heating his home for a whole year. Emissions from all flights departing from EU airports exceed total verified emissions from activities covered by the EU Emissions Trading Scheme (EU ETS) in 19 of the 25 member states. Emissions from aviation are also higher than from certain entire sectors covered by the EU ETS - for example, refineries and steel production. ("FAQ on Aviation Emissions and Climate Change," 2008)

This study, albeit, addresses the opposing "problem" noted by governments of a number of nations, including the U.S., which challenge the European Union's proposal to include international aviation in its emissions trading system. The EU's proposed approach contradicts ICAO guidance, nations one challenging the EU's contention, insist. The EU argues that compared with a fuel tax or charge, and/or other alternatives, that including aviation in the EU ETS offers identical environmental benefit at lower costs to society, and/or a higher environmental benefit for comparable costs. EU supporters insist that for a given environmental improvement, the impact on ticket prices, airline companies and the overall economy will be less. The impact of the European Union's new emission proposal on U.S. based airlines, however, the United States contends, will negatively impact U.S. based airlines, as "the rules broke with international aviation practices, would cost companies billions of dollars and could lead to sharp increases in airline ticket prices." (Kanter, 2007) in addition, some environmentalists argue efforts proposed by the EU are not enough to effectively counter aviation's contributions to climate change. As this researcher explores various components contributing to the EU's controversial solutions proposed to counter aviation-related climate changes, information from both sides of the conflict is related to determine potential answers to this significant problem.

Significance of the Study

Due to its relevance to the global society today, this researcher purports this study to complement current concerns. In time, findings from this capstone project will prove to be a vital, viable contribution to future researchers and research projects, as well as, constitute a source of information to enlighten readers. As this study focuses on aviation in the global realm, it does not limit itself to any specific location.

The EPA reports that aviation-related climate changes, in terms of human health, can have an effect on the ozone, which "...can affect pulmonary and respiratory health." ("EPA to Revise Aircraft Engine Emission Standards," 2005) in regard to environmental risks, particulate matter (PM) can contribute to acid rain, visibility impairment, and crop damage, and acid rain. Determining whether the impact of the European Union's new emission proposal negatively impacts U.S. based airlines contributes additional insight and considerations relating to a contemporary issue that ultimately impacts individuals worldwide - in the air, both indoors and out.

Due to the significance of the problem(s) reportedly associated with aviation-related climate changes, "aircraft emission standards have a 30-year history in the U.S., with new emissions standards being set for different aspect of engines, including:"

1974: Engine smoke and fuel venting.

1984: Hydrocarbon emissions.

1997: NOx and carbon monoxide.

2005: Updated NOx emission standards (included in this rulemaking)." ("EPA to Revise Aircraft Engine Emission Standards," 2005)

Limitations of this Study

Limitations for this capstone project include time, expense and distance constraints.

A more in-depth study may have, in fact, evolved from more allotted time, along with an unlimited expense account for extensive travel in the U.S. And to Europe to interview experts regarding this study's problem. With resources at hand, however, this researcher contends that limitations of this study do not limit its dedicated efforts to thoroughly instigate its aforementioned research question.

Study Structure

This capstone project includes the following traditional chapters:

Literature Review

Methodology

Results/Analysis

Discussion, Conclusions & Recommendations

The second chapter in this study presents the literature review which included assessing more than 30 sources to secure relevant sources of relevant information. Research primarily evolves from Web sites from Google and Highbeam's data bases. Along with purposefully sifting through resources to secure answers for the designated research question, this researcher also communicated with a pilot for personal thoughts regarding aircraft emissions.

The third chapter of this study relates the fact the Literature Research Methodology is utilized for this project's methodology.

Chapter four of this capstone project notes findings retrieved from analyzing information retrieved during the literature review. A number of figures are presented in chapter four.

This researcher reviews the scope of this research project during chapter five, and discusses conclusions and makes recommendations. Findings relating to the results are also discussed in this chapter. In addition, this researcher assesses whether the research question, introduced at the start of this study, was answered.

During the next chapter, the literature review, this researcher presents the researched information, while simultaneously considering the following sub-questions:

What are the EU's proposed plans for the aviation industry?

Does the U.S. agree with or oppose the EU's proposed plans for the aviation industry?

How will the EU's proposed plans for the aviation industry potentially impact U.S. based airlines?

CHAPTER II: LITERATURE REVIEW

The governments of many nations, including the United States, oppose the European Union's proposal to unilaterally include international aviation in its emissions trading system because the proposed approach is not consistent with ICAO guidance."

Aviation and the Environment," 2008)

EU's Proposed Plans for the Aviation Industry

EU's Plans Contradict ICAO Guidelines roundtrip flight from London to New York reportedly produces approximately the same emissions an average EU family generates from heating their home one year. Despite such comparisons attempting to put the problem related to aircraft emissions, most member countries of the International Civil Aviation Organization (ICAO) will not accept nor adopt the European Union's plans to set up a separate, regional emissions trading system, according to Giovanni Bisignani, chief executive of IATA. He argues, as the introductory quote for this literature review chapter notes, the trading system the EU imposes does not adhere to guidance of the ICAO. (Jordans, 2008) "Europe's unilateral approach will only lead to legal battles and trade wars," Bisignani also stressed. (Jordans, 2008) a hint of this contention occurring in the future was evidenced recently when 27 nations, including the U.S., China and 25 other countries, registered opposition to the EU's attempt to include commercial airlines in its cap-and-trade program by supporting an ICAO-run program. This signal confirmed united opposition to the European Union's intentions to develop a separate, regional emissions trading system. U.S. officials warn that the inclusion of U.S. And other non-European airlines in the EU cap-and-trade program "may break international aviation and trade laws." (Jordans, 2008) Although reasons differ, along with official warnings, scientists raise questions regarding the European program. Airlines, experts basically agree, contribute approximately 2% of man-made emissions of carbon dioxide, a gas reportedly contributing to global warming. Perceptions, nevertheless, differ regarding the impact of other gases aircraft emit, also potentially adding to the reported global warming effect. The FAA insists the EU's proposal to include aviation in its emissions trading scheme not only violates the Chicago Convention on International Civil Aviation and other international agreements, but also disregards U.S. And EU aviation systems' differences. It also pays no heed to the performance-based approach where countries determine which measures prove most pertinent for aircraft emissions' goals. A number of researchers are currently conducting studies relating to the EU emissions trading system, along with consequential, possible impacts on U.S. airlines, and additional concerns connecting to climate change evolving from aviation. ("Aviation and the Environment," 2008)

U.S. Stance Regarding the EU's Proposed Plans

Binding" Reductions

As the Kyoto Protocol, the UN agreement which mandates emissions reductions for industrialized nations through 2012, does not cover developing nations, the United States refuses to sanction because it. According to a February 25, 2008 AFB report, albeit, although the U.S. does not agree with EU's proposed plans regarding solutions to aircraft emissions, an announcement may be made by July 2008 to confirm: "The United States is ready to accept "binding international obligations' to reduce greenhouse gases...." ("U.S. ready for 'binding' reductions," 2008) the undertaking, however, Daniel Price, assistant to President George W. Bush for International Economic Affairs, stated, must be a factor of a "global agreement" where all major economies agree to the same commitment of a long-term global goal to reduce greenhouse gases that reportedly impel climate change.

Currently, the U.S. emits the highest levels of greenhouse gases in the world. Repeated criticisms that the U.S. launched the initiative focusing on technology-driven solutions to climate change to compete with UN-sponsored negotiations are false. "The major economies process is intended to supplement, compliment and support the UN negotiations. It is not an alternative to those negotiations," Prince argues. ("U.S. ready for 'binding' reductions," 2008) Prince points out a number of national programs the U.S. has implemented since 2001 to reduce greenhouse gas emissions and improve energy efficiency and insists this confirms the United States' willingness to engage in binding agreements. One mandate, which proposes to replace 15% of current oil fossil fuel consumption with renewable alternatives, would increase production of renewable fuels by 500% before 2022. Prince argues that, contrary to numerous contentions by other countries, the U.S. does not only favor voluntary, non-binding goals.

Unnecessary Hindrance?

On May 28, 2008, the Independent reported that on May 27, 2008, the European Parliament proposed to accelerate including the aviation industry in the Emissions Trading Scheme, the carbon credit system, the primary component of efforts to curb climate change. The Parliament's environment committee voted to approve the requirement that all aircraft landing in the EU from 2011(a year earlier than previously proposed) adhere to pollution targets the scheme stipulates. In addition, Members of the European Parliament (MEPs) recommended the required amount of carbon permits airlines buy be increased from 10 per cent to 25 per cent. Carriers promptly objected to this particular proposal. One spokesman for easyJet argued:

We have a more fundamental problem with the proposed level auctioning at 25 per cent.... Auctioning at that level seems an unnecessary hindrance at this point." (Fortson, 2008) a Virgin spokesman stated its airline did not object to the plan if it preludes a global program.

According to estimates, a flight within the EU would increase approximately €10 (£8) per trip, while intercontinental trips could increase up to four times that amount. (Fortson, 2008)

Whether the full Parliament will vote to ratify these changes is expected to be known in July. Carbon emissions constitute an issue prompting the airlines to attempt to minimize the financial hit on one side, while on the opposing side; politicians strive to ensure Europe remains at the battlefront against climate change. (Fortson, 2008)

How EU's Proposed Plans May Potentially Impact U.S. Based Airlines Even though the EU's proposal to include international aviation in its emissions trading system may intend to delay anticipated predicted catastrophic climate change effects, to FAA and airlines argue it will definitely adversely affect the aviation industry's financial health. The FAA and airline and aircraft and engine manufacturing industry representatives particularly purport that the EU's proposal may more negatively affect U.S. airlines with older, less fuel-efficient fleets than it would European competitors. According to U.S. airlines, having to pay for emissions credits may cost U.S. airlines money earmarked for investing in newer, more fuel-efficient aircraft, or funds allocated for technological improvements to increase flight efficiency and reduce fuel usage, or other needs. In addition, EU's current "proposed trading scheme unfairly penalizes the aviation sector because it lacks a readily available non-carbon-based alternative fuel, whereas other sectors can use alternative fuels to reduce their emissions." ("Aviation and the Environment," 2008) Stavros Dimas, environment commissioner, argues that including aviation in the EU ETS appears to constitute the most cost-efficient and environmentally effective means to control aviation emissions. "The commission proposal will give airlines annual, tradable CO2 emission allowances. At the end of each year, operators must exchange a proportion of their allowances in relation to their emitted tonnes of CO2." ("Aircraft emissions capped...," 2006) in the future, the airlines' total allowances available to will be capped at the average level of emissions (in tonnes of CO2).

Price hikes are reportedly expected to be limited as airlines may reduce emissions in a number of ways, particularly by investing in more efficient aircraft and engines and optimizing operations. The ticket price for a return flight within the EU could possibly rise from €1.8 to €9 by 2020. ("Aircraft emissions capped...," 2006) Statistics notes that aircraft engines contribute approximately 1% of mobile source NOx emissions in the U.S. On average, however, the number rises to as much as 4% in airport regions. According to FAA predictions, commercial air carrier flights "will increase 9% from 2002 to 2010 and 34% from 2002 to 2020, which means commercial aircraft emissions will increase during a time when other significant mobile and stationary sources are reducing emissions." ("EPA to Revise Aircraft Engine Emission Standards," 2005)

Current air travel growth, which averages approximately 5 to 6% a year, some experts warn, could undo improvement other industries have contributed, ultimately undermining international targets to halve emissions by 2050 compared with 1990.

Jordans (2008), nevertheless, relates warnings that EU's hastily imposed program could worsen contributions aviation currently make to counter climate change as it encourages more fuel-efficient aircraft and less harmful gases. The aircraft industry, along with the scientific and policy community need to join minds and efforts to frame the aviation emission problem, David Fahey, a research physicist at the U.S. National Oceanic and Atmospheric Administration, states. Even without a trading system such as the EU proposes, with fuel expenses for the industry totaling U.S. $156 billion (euro98 billion) during 2007, airlines and aircraft makers have incentives to lower fuel consumption. (Jordans, 2008) Aircraft primarily contributes to aviation emissions, however, airport operations, which include service and passenger vehicles, produce emissions as well. Aircraft operations in airport regions, along with other airport sources emit nitrogen oxides, which lead to ground-level ozone (also known as smog) and other substances, such as carbon dioxide and other greenhouse gases. The resulting substances, which rise into the atmosphere, contribute to climate change, in turn, increasing local air pollution. In the upper atmosphere, aircraft operations serve as "the primary aviation-related source of greenhouse gas emissions. Currently, according to EPA estimates, aviation emissions account for less than 1% of local air pollution nationwide and about 2.7% of U.S. greenhouse gas emissions." ("Aviation and the Environment," 2008)

Regardless of anticipated fuel efficiency improvements, projected increases in air traffic are expected to contribute to an increase in aircraft emissions. If not addressed, the FAA notes, nitrogen oxides emissions from aviation sources will increase by more than 90% by 2025. In turn, this increase is expected to increase ozone, potentially aggravating respiratory ailments. According to the International Panel on Climate Change (IPCC), increased traffic also contributes to increases in carbon dioxide emissions and, consequently reportedly increases aviation's contribution to climate change. ("Aviation and the Environment," 2008)

EU Questions and Answers

The following question/answer segment reflects a number of contentions the EU proposes:

When will aviation emissions be brought into the EU ETS?

Aviation will be brought into the EU ETS in two steps. From the start of 2011, emissions from all domestic and international flights between EU airports will be covered. One year later, at the start of 2012, the scope will be expanded to cover emissions from all international flights - from or to anywhere in the world - that arrive at or depart from an EU airport. The intention is for the EU ETS to serve as a model for other countries considering similar national or regional schemes, and to link these to the EU scheme over time. Therefore, the EU ETS can form the basis for wider, global action.

Which airlines and routes will be affected?

The scheme will cover any aircraft operator, whether EU- or foreign-based, operating international flights on routes to, from or between EU airports. All airlines will thus be treated equally. To reduce administrative costs, each operator will be administered by a single member state regarding emissions from the total of its flights to, from and within the EU. Very light aircraft will not be covered. Military, police, customs and rescue flights, flights on state and government business, and training or testing flights will also be exempted.

Will ticket prices increase?

Including aviation in the EU emissions trading scheme will not directly affect or regulate air transport tickets. However, aircraft operators may have to invest in more efficient planes or buy emission allowances in the market in addition to those allocated to them. The associated costs per ticket are likely to be modest. Assuming airlines fully pass on these extra costs to customers, by 2020 the ticket price for a return flight within the EU could rise by between €1.8 and €9.

Due to their higher environmental impact, long-haul trips could increase by somewhat more, depending on the journey length - for example, a return flight to New York might cost an additional €8 to €40, depending on the market price for CO2 allowances. However, ticket price increases are expected to be significantly lower than the extra costs airlines have passed on to consumers due to world oil price rises in recent years. Including aviation in the EU emissions trading scheme will also have a smaller impact on prices than if the same environmental improvement were to be achieved through other measures, such as a fuel tax or an emissions charge.

What other economic and social impacts will the measure have?

The impact assessment carried out by the EC concludes that the overall effect on the European economy and competitiveness is likely to be very small, both in terms of overall GDP growth and employment. The main impact is likely to be a small reduction in the rate at which demand grows. According to the different scenarios analysed, the reduced growth in demand would vary from 0.1% to 2.1%, assuming CO2 allowance prices of €10 to €30.

Including aviation in the EU ETS is projected to have only a marginal effect on airlines' profitability, since they would be able to pass on most or all of the extra cost to customers. Since all airlines will be treated equally, competition between them is not expected to be significantly affected. Carriers travelling shorter distances, using older aircraft or carrying fewer passengers or less cargo would be affected to a greater extent than more fuel-efficient carriers. Competition between airports and in the tourism sector is also not expected to be significantly affected since forecast demand growth remains high.

What will the effect be on aviation emissions?

The environmental impact of the proposal will be significant because aviation emissions, which are currently growing rapidly, will be capped at their average level in 2004-2006. By 2020 it is estimated that a total of 183 million tonnes of CO2 will be saved per year on the flights covered, a 46% reduction compared with business as usual. This is equivalent, for instance, to twice Austria's annual greenhouse gas emissions from all sources. Some of these reductions are likely to be made by airlines themselves. However, participation in the EU scheme will also give them other options, such as buying additional allowances on the market - that is, paying other participants to reduce their emissions - or investing in emission-saving projects carried out under the Kyoto Protocol's flexible mechanisms. Providing the aviation industry with these options does not reduce the environmental impact of the proposal since the climate impact of emission reductions is the same regardless of where they are made.

How can airlines reduce their emissions in practice?

Airlines can reduce their emissions in several ways, notably by investing in more efficient aircraft and engines and by optimising operations. Although the biggest improvements typically arise from accelerated fleet renewal, many aircraft in the current fleets also hold potential for improvements. For instance, some aircraft can be retrofitted with technical devices at the tip of the wings ("winglets"), new surface treatments that reduce drag (air resistance) and even new engines. Airlines can also optimise their timetables, route network and flight frequencies to minimise the number of empty seats flown. ICAO has published a catalogue of "Operational Opportunities to Minimize Fuel Use and Reduce Emissions," which describes some of these opportunities. In the longer term, research into more efficient technologies and alternative fuels may provide additional opportunities.

How will emissions be monitored? Will airlines have to report details of each flight?

Each airline will calculate its annual emissions on the basis of its fuel consumption multiplied by a standard emission factor. The proposed directive requires that, wherever possible, actual fuel consumption data for each flight should be used, but if this is not available, a standardised method for estimating fuel consumption will be used. Like other participants in the EU ETS, aircraft operators will have to monitor the devil is a known their emissions each year and report them to the administering member state by March 31 of the following year. The reports must be checked by professional verifiers to ensure they are accurate. ("FAQ on Aviation Emissions and Climate Change," 2007)

Serious Long-Term Environmental Issues

Diverse global climate change from greenhouse gas emissions (GHGs) most likely constitute one of the largest and most potentially, serious long-term environmental issues currently challenging the world, Watkiss, Downing, Handley, and Butterfield (2005, p. ii) purport. Their study, "prepared as task 1 of the project 'Modelling support for Future Actions - Benefits and Cost of Climate Change Policies and Measures', ENV.C.2/2004/0088, led by K.U.Leuven, Katholieke Universiteit Leuven," presents a quick review and analysis economic costs and impacts evolving from climate change.

As Watkiss, Downing, Handley, and Butterfield (2005, p. ii) present estimates of EU's reported climate change policy benefits, these authors also review impacts of climate change, examining potential impacts at a European and global level. Their analysis identified and prioritized a number of major climate change effects, perceived to include:

Impacts of sea level rise, erosion, loss of land/coastal wetlands, and need for coastal protection;

Effects on agriculture;

Effects on energy use (including heating and cooling);

Effects to human health from changes in cold related and heat related effects

Effects to human health from the disease burden (and other secondary effects);

Effects on water resources, water supply and water quality;

Changes to tourism potential and destinations;

Effects on ecosystems (loss of productivity and bio-diversity);

Impacts from drought;

Impacts from flooding;

Impacts from storm damage and extreme weather (including costs to infrastructure);

Socially contingent effects (arising from multiple stresses and leading to migration, famine, etc.);

Impacts from major events (e.g. loss of thermo-haline circulation, collapse of West-Antarctic ice sheet, methane hydrates). (Watkiss, Downing, Handley, and Butterfield, 2005, p. ii)

Watkiss, Downing, Handley, and Butterfield (2005, p. 56) conclude that their review confirms "that the impacts of climate change and their economic costs are significant." The authors insist climate change could be evaded, and that post-Kyoto policies' benefits could prove to be considerable in reducing negative impacts and social costs. According to these authors, avoiding climate change contributes to "the major benefit of reducing the risk of major catastrophic events." Research retrieved for this chapter appears to confirm the point Bisignani stressed at the start of this literature review: "Europe's unilateral approach will only lead to legal battles and trade wars." (Jordans, 2008)

Contrary to this synopsis, this researcher's unilateral approach, utilizing the Literature Review Methodology for this project, leads to determining points entwined in researched information to answer this study's research question. The next chapter, the methodology, explains the process.

CHAPTER III: METHODOLOGY

Any sort of emissions trading system should be done on the basis of mutual agreement between governments.

If one government wants to include another airline in their system, then it should come and talk to that government."

Carl Burleson, director of the FAA office of environment and energy (Kanter, 2007)

Methodology Design Considerations

Although not all retrieved information was used to create this paper, the design for this capstone project in a symbolic way, as Kanter (2007) recommends in the introductory quote for this study, involved "talking to various governments" as this researcher collected and collated information from more than 20 various contemporary sources. After retrieving relevant researched information, this researcher analyzed pertinent portions to secure the answer for the research question: Will the European Union's new emission proposal for the aviation industry adversely impact U.S. based airlines?

As English constitutes this researcher's native language, researched articles and information for this global subject were published in English. Dates for retrieved publications were less than five years old to ensure study presented pertinent, current information. For personal input, while focusing on various aspect of this study's subject, this researcher briefly interviewed an airline pilot.

CHAPTER IV: ANALYSIS

It's like comparing apples and oranges."

Helen Rogers (Senior research associate at Cambridge University) (Jordans, 2008)

Scientists Dispute

Rogers, who works in the field of climate modeling purports that scientists dispute the contention that "converting the effects of gases such as water vapor and nitrogen oxide into a carbon dioxide equivalent as part of an emissions trading system..." is comparable to comparing apples and oranges. (Jordans, 2008) Comparing apples and oranges, this researcher contends, in a figurative sense, aptly depicts a number of findings retrieved from the researched literature. Contrary to its understanding of recommendations in the EU proposal, the EPA does not anticipate U.S. manufacturers will incur additional costs from its (EPA's) rulemaking. Previously certified or in-production engine models comply with or perform superior to proposed revised standards. Manufacturers also utilize test procedures to ensure engine models comply. ("EPA to Revise Aircraft Engine Emission Standards," 2005) the following figure (1) illustrates an "apples and oranges" comparison scenario depicted in research revealing responses expected from the EU's proposal.