Sept. 25, 2015
NBAA has joined with other industry stakeholders in formally opposing calls from within Congress for the U.S. Environmental Protection Agency (EPA) to take unilateral action in adopting aircraft emissions standards before the issuance of an internationally agreed-upon standard.
Following extensive deliberations and consultations with industry stakeholders – including NBAA, through its representation on the International Business Aviation Council (IBAC) – the International Civil Aviation Organization (ICAO) is expected to consider emissions proposals during its 39th General Assembly gathering in late 2016.
“The global community is, in fact, at the tail end of a six-year collaborative and complex process to achieve this goal,” noted the Sept. 22 letter to Congress, which was signed by NBAA President and CEO Ed Bolen and leaders of seven additional aviation groups. “The EPA is working actively at ICAO along with the FAA, industry and civil society stakeholders and representatives of all ICAO member countries to develop a CO2 emission standard for future aircraft.”
The EPA first asserted it has the authority to establish a U.S.-specific aircraft emissions standard in an advance notice of proposed rulemaking (ANPRM) issued last June, saying the move was justified because of an endangerment finding that aircraft emissions may pose a human health concern.
NBAA immediately responded, noting in part that aviation emissions account for a mere 2 percent of all transportation emissions globally, and emissions from general aviation aircraft account for only a tiny portion of all aviation emissions. Read NBAA’s June 10, 2015 response to the EPA’s ANPRM on emissions in its entirety.
In comments submitted to the federal docket on Aug. 31 in response to the ANPRM, NBAA reiterated the Association’s significant concerns over any move by the EPA to implement a unilateral aircraft-emissions standard without considering approaches to emissions policy being considered by ICAO, the appropriate international governing authority. Read NBAA’s August 31, 2015 comments to the federal docket in their entirety.
NBAA has continually worked with a coalition of other industry stakeholders regarding aircraft emissions, with Association officials participating on several national and international working groups focused on emissions policies.
On a global scale, the aviation industry contributes less than two percent of total global carbon emissions, with business aviation responsible for just two percent of that total, or .04 percent of worldwide emissions. Furthermore, the U.S. aviation industry has improved its fuel efficiency by more than 120 percent since 1978, saving over 3.8 billion metric tons of CO2 – the equivalent of removing 23 million automobiles from the road in each of those years.
“Our industry-wide efforts are bearing fruit, as the EPA itself has documented,” the industry organizations’ letter continued. “Despite the industry’s strong record to date, we are active participants in a global coalition that has committed to 1.5 percent annual average fuel efficiency improvements through 2020 and carbon-neutral growth from then on, as well as a 50-percent reduction in net emissions by 2050 compared to 2005.”
The groups’ letter also noted the aviation industry’s significant contributions to the U.S. economy, “comprising 5 percent of U.S. economic activity, driving nearly $1.5 trillion in economic activity and 11 million jobs.”
Other signatories to the letter were: Aerospace Industries Association, Air Line Pilots Association International, Aircraft Owners & Pilots Association, Airlines for America, Cargo Airline Association,
General Aviation Manufacturers Association and NetJets Association of Shared Aircraft Pilots.