Oct. 14, 2020

The U.S. Environmental Protection Agency (EPA) has published a notice of proposed rulemaking to match U.S. standards for greenhouse gas emission standards for certain new commercial airplanes with the International Civil Aviation Organization (ICAO) standards adopted in 2017 for airplane carbon dioxide (CO²) emissions.

If adopted, the proposed standards would only apply to new type design airplanes on or after Jan. 1, 2020, and to “in-production” airplanes on or after Jan. 1, 2028, but not already manufactured airplanes currently in use. Certain subsonic jet airplanes with a maximum takeoff mass (MTOM) greater than 12,566 pounds, and larger subsonic turboprop airplanes having an MTOM greater than 18,999 pounds would need to meet the new EPA standards.

“With this proposed rule the EPA is moving toward global initiative to adopt the ICAO CO² standard,” explained Stewart J. D’Leon, NBAA director, technical operations. “NBAA supports this effort, but in speaking with industry colleagues, we all seem to have the same concern with some elements of the proposed rule that are different than the ICAO standard. The most concerning of these differences is the requirement of manufacturers to submit reference geometric factor (RGF) data.

“RGF data and three specific air range (SAR) points are part of the mathematical calculation used to determine the CO² standard metric. SAR data is the definition of the fuel burn of a product and is considered highly commercially sensitive,” D’Leon said, adding that when someone has the RGF data, they can easily reverse the math and calculate the SAR.

“That SAR data is proprietary and if that becomes made available to the public, then that’s a real concern for manufacturers,” he said. This was a point of discussion during the development of the ICAO standard and ultimately led to it being excluded from the reporting requirements in that process. NBAA supports the EPA adopting the same mindset.

NBAA, in its comments, also noted the association and its members have long supported efforts to address aircraft emissions. This includes work through the Business Aviation Commitment on Climate Change, an aggressive collaborative program designed to address the industry’s carbon emissions.

D’Leon urged NBAA members wishing to submit comments to do so before the closing date of Oct. 19.

View the NRPM and submit comments at regulations.cgov.

View NBAA’s comments to the EPA. (PDF)