Aerospace Industries Association

AIA tells EPA it “must not adopt a technology-forcing CO2 standard that is based on aircraft designs or control technologies that have not been approved  as airworthy by” the Federal Aviation Administration “and demonstrated through use on existing aircraft.” The group, representing over 300 aerospace and defense manufacturers, stresses the need for EPA, in developing rules governing GHG emissions, to keep “air worthiness” at the center of its focus, as, it says, has the International Civil Aviation Organization, which has been working on international GHG rules. “The central importance of airworthiness is evident in current and past ICAO standards,” consistently avoiding “basing aircraft emission standards on unproven technology and instead has relied on emission control measures that have been established within the aviation sector and proven safe and effective. There is no reason for EPA or ICAO to deviate from that precedent here.” Among other AIA recommendations: EPA should “carefully consider the complex tradeoffs that must necessarily occur between several “ EPA and FAA requirements, “such as noise, non-GHG emission standards, and other environmental requirements such as recyclability, along with reliability, operability and maintainability requirements”; the agency should consider “the steps and commitments that the aviation industry has already made to improve fuel efficiency and thus to reduce GHG emissions from aircraft”; and it worries that ICAO programs may be put into effect before EPA concludes its proceeding, putting U.S,. manufacturers “at a competitive disadvantage if overseas competitors are able to get new type certifications from their domestic agencies, while U.S. manufacturers must await rulemaking before getting new type certifications.”