Domestic co2 Emission Standards. Third, potential domestic reporting requirements for aviation manufacturers under the Clean Air Act. Epa has proposed endangerment findings focus on six key Greenhouse Gases but we concur with this approach with caveats. We agree with epa the assessment scientific uncertainties on the Climate Impact of nitrogen oxides or nox and water vapor emitted at altitude remain high enough so as not to address them in this initial endangerment finding. Science with black carbon to Climate Change on the other hand, is clear. Black carbon was identified as the second most important contributor to anthropogenic emissions in 2013 to. To reflect the latest icp should consider incorporating black carbon in its final aviation endangerment finding. Also while we do not support integrating crude nox under the endangerment finding, epa should consider expanding its existing nox reporting requirement for aircraft, Engine Manufacturers, landing and takeoff emissions to include crude emissions. Icao has outlined two general approaches to the applicability of an international co2 Emission Standard in the first approach only new aircraft designs being typed certified for the first time be required to comply. In the second, that all the aircraft delivered after a certain date, that is, both new design and new in production aircraft, would need to pass. Based upon our analysis covering all new aircraft delivered after a certain date will be necessary for the standard to significant reduce emissions beyond business as usual. Since a new type aircraft are rare, our analysis suggests that a new type only standard beginning in 2020 would only cover about 5 of the global fleet in 2030. As opposed to a requirement after affecting all new aircraft which could cover more than half of the global fleet that year. Furthermore, we do not expect a new type only standard to reduce emissions below business as usual because of the definition that icao has chosen due to technological feasibility. In 2013 icao decided only technology as widely as available for deployment in 2016 across multiple aircraft types will be considered in establishing stringency. A standard implemented in 2024 new applications for Type Certification will affect aircraft types with entry into service of 2024 or later. This time lag combined with a decision that at most a standard to require stateoftheart 2016 technologies when implemented means that even the most aggressive standard will lag the fuelefficient of new type aircraft would enter into service. For these reasons we conclude that covering all the aircraft will be required to meet the purpose of the standard to reduce emissions beyond business as usual. Odds dignity we believe that an international and or domestic, co2 standards should be set to require at least stateoftheart 2016 technologies for new aircraft type certified after the standard takes effect. Icao is also investigating a tiered approach under which deliveries of new and production aircraft or models that are type certified before the standard takes effect may have separate target apply to them. Ending additional analysis, and or stringency love may be appropriate for those types but still within the highest three levels identified by epa in the anpr them. On timing and order to minimize the number of years underneath a predatory level lags us as you to craft a standard should be applied for new types as early as possible. In this case 2020. Early implementation for new in production aircraft even in 20242023 is also preferable. Finally, since good discussions on international Emission Standards assume a static stringency level, it would be appropriate for the us to press for early icao review of any international co2 standards starting in 2019 so that the update of requirement are in place to drive Additional TechnologyDevelopment Beyond 2020. Regarding manufacturing reporting requirements, we recommend that epa consider adopting a domestic reporting requirement for crude co2 and nox under the Clean Air Act. Icao is concerned the development of the voluntary database for co2 only. We believe details mandatory reporting is necessary to ensure transparency and a level Playing Field across manufacturers. Finally, as noted before we believe that a collection of nox data collectively would help improve our understanding of the Climate Impact of aviation nox emissions. Epa would need to analyze the cost and complexity of developing measurement and reporting protocols for crude nox if it decides to pursue this approach. Are more detailed comments will be similar to epa in writing in addition to submit an update to the 2009 study referenced in the anprm entitled efficiency transfer new commercial jet aircraft to the public docket. The two studies together highlight the importance of a meaningful co2 Emission Standards of the u. S. Aviation Greenhouse Gas emissions reduction plan. Thank you for the opportunity to comment here today at the epa is continuing work on this very important topic. Minus nancy young. On the Vice President of our mental affairs or airlines for america representing the major passenger and Cargo Airlines in the United States. We appreciate this opportunity to testify regarding epas proposed findings on aircraft Greenhouse Gas emissions and advancement of proposed rulemaking. As a record of our members demonstrate we take our role in controlling Greenhouse Gas emissions very seriously. For the past several decades u. S. Airlines have dramatically improved fuel efficiency and reduced Carbon Dioxide emissions by investing billions in fuel savings aircraft and engines, Innovative Technologies and cutting edge route optimization software. As a result, although u. S. Airlines comprise 5 of u. S. Economic activity, they account for only 2 of the Greenhouse Gas emissions inventory. The industry improved fuel efficiency 120 since 1978, saving 3. 8 billion metric tons of Carbon Dioxide emissions, the equivalent of taking 23 million cars off the road each of those years. Further the u. S. Airlines carried a 20 more passengers and cargo in 2014 than they did in 2000, while emitting a less Carbon Dioxide. Despite the Industries Strong record to date, however, we are not stopping there. The u. S. Airlines are active participants in a global Aviation Coalition that is committed to 1. 5 annual average fuel efficiency improvements through 2020, and carbonneutral growth from 2020 subject to critical aviation infrastructure and Technology Advances achieved by government and industry. Our members are keenly focused on these advances both a national and International Levels. For example, the u. S. Airlines are partnering to modernize the air Traffic Management system and to reinvigorate research and development in aviation and environmental technology. In addition we are dedicated to developing commercially viable sustainable alternative Aviation Fuel which could further reduce aviation Greenhouse Gas emissions while enhancing u. S. Energy independence and security. A4a is a Founding Member of the commercial aviation alternative fuels initiative, a Publicprivate Partnership with faa and other stakeholders that is working on the development and deployment of such fuels. Having help lay the necessary technical groundwork, a4a members have already begun to use bio jet fuel on commercial flights. Further our Industry Coalition supporting the development of a Global Carbon emissions offset mechanism that could be used to fill the gap should concerted industry and government investments in technology, operations and infrastructure measures otherwise not allow us to achieve our goal of carbonneutral growth from 2020. Its against this backdrop that a4a welcomes the opportunity to submit a full set of comments on epas proposed findings and anpr to august 31, deadline. For purposes of this hearing a4a it offers five preliminary observations. First, a4a concurs with epa that it is appropriate for the agency to limit its endangerment and cause or contribute findings to the six well mixed long lived we house gas emissions. As e. P. Points out in its proposal aircraft only in it to a the sixth emissions are 99 of which is Carbon Dioxide. As Carbon Dioxide is directly related to fuel burn and with jet fuel as the number one cause for commercial airlines, a4a members already have a powerful incentive to continue to reduce co2 output. Second, a4a urges epa to keep our industry strong fuel efficiency record, relative Greenhouse Gas emission contribution, global sector commitment squarely in mind as the agency proceeds. Indeed, commercial aviation accounts or 2 of the nations Greenhouse Gas emissions inventory while the sources epa previously has sought to cover with Greenhouse GasEmissions Regulations on prodemocracy goals and power plants, respectfully account for 23 and 31 . Third, given that industries demonstrate fuel efficiency record and economic incentive to continue that trend theres a real question as to whether any epa regulation of Greenhouse Gas emissions from aircraft engines is needed. That said, as aviation is a Global Industry with airlines operating internationally, and manufacturers selling the aircraft in international markets, it is critical that Aircraft Emissions standards he set at the International Level and not impose unilaterally. Accordingly, we appreciate the direct engagement of epa and the faa and then the development of aircraft Carbon Dioxide certification standards at the International CivilAviation Organization, the United Nations body charged with setting standards and recommended practices for international aviation. Not only is the icao process for setting aircraft standards highly rigorous, but the icao criteria for adopting such standards aligned well with the criteria under section 231 of the Clean Air Act. Four, a4a strong supports epas stated intent to adopt the future icao c2 syndication standards into u. S. Law, consistent with the Clean Air Act, its treaty obligations and in our with the international community. Finally, a4a urges epa to take note of the fact that the future icao c2 certification standards for new aircraft is but one arrow in the Aviation Industries quiver for meeting its emission goals. Faas nextgen initiative, publicprivate research and Development Partnerships are collaborative efforts to deploy sustainable alternative Aviation Fuels at commercial scale, and a vast array of additional operational and infrastructure initiatives being undertaken by airlines, airports, manufacturers and other stakeholders are also critical arrows in that quiver. Commercial aviation has an Important Role to play in how america responds to Climate Change. Be assured that a4a and our members are committed to doing our part. Thank you. Good morning. Im nancy kruger, campy director of the National Association of clean air agencies. Thank you for this opportunity to testify and provide preliminary comments of nacaa on epas proposed aircraft endangerment finding and advanced proposal making seeking input on icaos Ongoing Development of International Aircraft standards for co2 and also the potential Forthcoming Development by epa of aircraft Carbon Dioxide emissions standard. Nacaa as a National Nonprofit nonpartisan association of air Pollution Control Agency in 41 states, addition of columbia, for territories and 116 metropolitan areas. Our members, professionals and our member agencies of a vast expense in improving air quality in the u. S. And our testimony is based on that experience. First with respect to endangerment finding, nacaa commends epa and supports it on its proposal to find that concentration in the atmosphere endanger the Public Health and welfare of current and future generation within the meaning of section 231 a. Of the Clean Air Act. To find that emissions of certain aircraft classes cause or continue to air pollution that endangers Public Health and welfare and also uses the same definition of air pollution under section 231 a. As the agency used in making its 2009 endangerment finding with respect to motor vehicles. Epa states its proposal at the 2009 endangerment 50 is from established and well settled and theres no need to reopen or revisit it nor to make additional finding under section 231. Nacaa agrees and supports epas proposal to make such additional finding out. Epas proposed planting under section 231 sets the stage for harmonizing international and u. S. Aircraft Security Mission standards. With icao expect to adopt a National Standard answer as february 2016, we appreciate epas request to the anpr for input on establishing the standard and the potential use of Clean Air Act section 231, to adopt in government the icao standard domestically. Nacaa support the United States continued support for adopting an interNational Standard as well as epa adoption of a domestic standard that will address this category in a significant way. Aircraft represents the single largest u. S. Transportation source of Greenhouse Gas emissions not yet subject to Greenhouse Gas standards. Clearly this is a sector that marriage regulation commensurate with other transportation sectors. Icao and epa must establish as rigorous and comprehensive a regulatory package as possible. In the u. S. This is especially critical because state and local air pollution control agencies do not have authority under the federal Clean Air Act to regular Aircraft Emissions beyond the limits set by epa. Accordingly nacaa offers the following overarching to limit comment on three key issues highlighted in the anpr, timing and strangest of aircraft into a mission standards. Icao is considering various approaches you to build of aircraft seem to standard with a fundamental question being whether that standard should apply to a to in production airt or only to complete the aircraft type design. Nacaa believes it is essential that the standard applied to both in production aircraft a new type design that the definition of in production be any covert aircraft reduced after the compliance deadline. We simply cannot forgo the Emissions Reductions regarded from production engine and find no persuasive reason to forego them. On the issue of timing, nacaa recommends a standards take effect us as possible, by 2020 for new aircraft type and by 2023 for in production aircraft. Nacaa is still studying the c2 stringency options identified by epa in the anpr. Howeveranpr. Howeveranpr. However, we can see now are Association Strong encourages icao and epa to set a standard that is as strange as possible into this Category Technology forcing rather than technology following. Nacaa would like to touch britain on a few additional issues related to aircrafts you to emissions standards at first we recommend engines associate with but not part of an aircraft also be addressed i aircraft seem to standards, key among these are power units. Second we recommend epa pursue opportunities for establishing standards for in these aircraft which for example, can be retrofitted with winglets to say that fuel. Third although the standard at issue here is for co2, it is all those the potential for additional nox initial reduction to encourage epa to analyze this careful and take steps to maximi