Public Meeting August 11, 2015

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1 ENVIRONMENTAL PROTECTION AGENCY 

2 PUBLIC HEARING FOR THE PROPOSED FINDING THAT GREENHOUSE 

3 GAS EMISSIONS FROM AIRCRAFT CAUSE OR CONTRIBUTE TO AIR 

4 POLLUTION THAT MAY REASONABLY BE ANTICIPATED TO 

5 ENDANGER PUBLIC HEALTH AND WELFARE 

6

7

8

9

10

11 Tuesday, August 11, 2015 

12 10:08 a.m. 

13

14

15

16

17

18 U.S. EPA Headquarters 

19 William Jefferson Clinton East Building 

20 Room 1153 

21 1201 Constitution Avenue, N.W. 

22 Washington, DC 20004 
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1 PARTICIPANTS 

2 EPA MEMBERS: 

3 PAUL GUNNING, Co-Presiding Officer 

4 BILL CHARMLEY, Co-Presiding Officer 

5 MELINA WILLIAMS 

6 MIKE SAMULSKI 

7 BRYAN MANNING 

8 LESLEY JANTARASAMI 

9

10 GROUP 1: 

11 DR. NIC LUTSEY, International Council on Clean 

12 Transportation 

13 NANCY YOUNG, Airlines for America 

14 NANCY KRUGER, National Association of Clean Air 

15 Agencies 

16

17 GROUP 2: 

18 ERIK WHITE, California Air Resources Board 

19 JOE DePETE, Air Line Pilots Association International 

20 JAMES LEE, member of the public 

21

22

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1 PARTICIPANTS (CONTINUED) 

2 GROUP 3: 

3 LESLIE RIEGLE, Aerospace Industries Association 

4 MICHAEL SARACENO, member of the public 

5 DOUG WOLF, Center for Biological Diversity 

6

7 GROUP 4: 

8 KATHY KINSEY, Northeast States for Coordinated Air Use 

9 Management 

10 ANDRES RESTREPO, Sierra Club 

11

12 GROUP 5: 

13 KATE DeANGELIS, Friends of the Earth 

14 AMANDA BAISE, member of the public 

15 DAVID BAAKE, Natural Resources Defense Council 

16

17 GROUP 6: 

18 PATRICK RODDIE, member of the public 

19 MAX BLISS, member of the public 

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1 P R O C E E D I N G S 

2 MR. GUNNING: Good morning. My name is Paul 

3 Gunning. I am the Director of the Climate Change 

4 Division at the U.S. Environmental Protection Agency. 

5 On behalf of EPA and the Office of Air and Radiation, I 

6 would like to welcome you to today's public hearing. 

7 Thank you all for taking the time out to come and 

8 participate and communicate with us today. 

9 As you all know, just to be clear, the title of 

10 today's hearing is "Proposed Finding that Greenhouse 

11 Gas Emissions from Aircraft Cause or Contribute to Air 

12 Pollution that may Reasonably be Anticipated to 

13 Endanger Public Health and Welfare and the Advance 

14 Notice of Proposed Rulemaking." 

15 I would like to again thank you all for coming 

16 today. I am going to start by introducing my fellow 

17 panel members. Start down on the far left, please. 

18 MS. WILLIAMS: Melina Williams, Office of General 

19 Counsel. 

20 MR. SAMULSKI: Mike Samulski, Director of Large 

21 Marine and Aviation Center. 

22 MR. CHARMLEY: I am Bill Charmley, the Director of 

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1 the Assessment and Standards Division. 

2 MR. MANNING: Bryan Manning from the Large Marine 

3 and Aviation Center. 

4 MS. JANTARASAMI: Lesley Jantarasami from the 

5 Climate Change Division. 

6 MR. GUNNING: Thank you. 

7 Just to reiterate, the purpose of the hearing 

8 today is to receive comments from all interested 

9 parties on the proposed endangerment finding and 

10 advance notice of proposed rulemaking. This action, as 

11 many of you know, was published in the Federal Register 

12 on July 1st, 2015. In this action, the Administrator 

13 is proposing to determine that greenhouse gas 

14 concentrations in the atmosphere endanger the public 

15 health and welfare of current and future generations 

16 within the meaning of section 231(a) of the Clean Air 

17 Act. In addition, the Administrator is proposing to 

18 find that greenhouse gas emissions from certain classes 

19 of engines used primarily in commercial aircraft are 

20 contributing to this mix of greenhouse gas air 

21 pollution in our atmosphere. 

22 Today's hearing provides interested persons the 
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1 opportunity for oral presentations and views and 

2 arguments. Witnesses will be allowed to make oral 

3 statements, which they may later expand in writing for 

4 the record. When you are finished with your comments, 

5 members of this panel may ask clarifying questions. 

6 However, this hearing is not intended to be a 

7 discussion of the proposed findings or the advance 

8 notice of proposed rulemaking. While we might ask 

9 questions or request additional data or supporting 

10 materials, we will not respond to comments in this 

11 forum. Instead, we ask that you please provide written 

12 comments as part of the record in finalizing this 

13 proposal. 

14 If any members of the audience today that wish to 

15 testify have not already signed up, please submit your 

16 name at the registration table back at the entrance to 

17 the room in the foyer. Everyone attending here today 

18 should sign in, regardless of whether or not you are 

19 scheduled to testify. 

20 Finally, before I turn it to my colleague Bill, 

21 let me remind everyone that, in addition to today's 

22 hearing, there is also an opportunity to send us 

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1 written comments. The written comment period closes on 

2 August 31st, 2015 at 11:59 p.m. Eastern time. Details 

3 on where to submit written comments can be found in the 

4 Federal Register notice that announced this proposal as 

5 well as on our website and the fact sheet that is 

6 available out at the registration desk. 

7 So, with that as an introduction, let me turn it 

8 over to Bill. 

9 MR. CHARMLEY: Thank you, Paul, and good morning. 

10 Concurrent with these proposed findings, on July 

11 1, 2015, EPA also issued an advance notice of proposed 

12 rulemaking, referred to as an "ANPR," to provide 

13 information on the process for setting an aircraft 

14 engine greenhouse gas standard under section 231 of the 

15 Clean Air Act should the EPA issue positive final 

16 endangerment and contribution findings under section 

17 231. 

18 The ANPR largely focuses on recent efforts to set 

19 an international CO2 emissions standard for aircraft at 

20 the International Civil Aviation Organization, also 

21 referred to as "ICAO," and how those efforts may inform 

22 EPA's future action. This advance notice describes and 

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1 seeks input on issues related to setting an 

2 international CO2 standard for aircraft and the 

3 potential use of section 231 of the Clean Air Act to 

4 adopt and implement a possibly corresponding 

5 international engine, aircraft engine, CO2 or 

6 greenhouse gas emissions standard domestically. This 

7 international CO2 standard is expected to be adopted by 

8 ICAO in early 2016. 

9 EPA is requesting comment on a number of issues 

10 related to setting the CO2 or greenhouse gas emission 

11 standard for aircraft. These include the appropriate 

12 effective dates for the potential standards, the 

13 appropriate stringency level for a standard, and 

14 whether standards should apply to new in-production 

15 aircraft as well as new-type aircraft. 

16 Now let me go over how we will be conducting 

17 today's hearing. We are conducting this hearing under 

18 section 307(d) of the Clean Air Act to provide 

19 interested persons an opportunity for oral 

20 presentation, in addition to written submissions, on 

21 the proposed findings. We are having this hearing 

22 recorded, and the transcripts will be available for 

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1 public inspection and copying in EPA's air and 

2 radiation docket at docket number EPA-HQ-OAR-2014-0828. 

3 The transcripts will also be available electronically 

4 on EPA's website and on the regulations.gov website in 

5 the same docket number. 

6 The official record of this hearing will be kept 

7 open for 30 days after today to provide opportunity to 

8 submit rebuttal and supplemental testimony. You may 

9 submit this additional testimony to the same docket for 

10 this action by using one of the methods described in 

11 the Federal Register notice announcing the proposal. 

12 This hearing will be conducted informally, and 

13 formal rules of evidence will not apply. Paul and I 

14 will be serving as the co-presiding officers for 

15 today's hearing, and, as such, we are authorized to 

16 apply reasonable limits on the duration of the 

17 statements of any witness. Each person will be given 

18 no more than 10 minutes to provide his or her verbal 

19 testimony. 

20 Paul and I have asked the EPA personnel at this 

21 table to serve as timekeepers right down here to keep 

22 close track of testimony times. The timekeeper will 
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1 indicate to each testifier when you have five minutes 

2 left and also when you have one minute left and when 

3 your time is finished. Please be courteous to those 

4 that follow you and keep your comments to no more than 

5 10 minutes. 

6 We will be using a group format for today's 

7 testimony. Three individuals at a time will be called 

8 up to the testifiers' table here in the front. If you 

9 have not already done so, please check in at the 

10 registration desk for your group number assignment. 

11 When you hear your name or your group number called, 

12 please make your way to the table provided at the front 

13 of the room and be prepared to provide your testimony 

14 in succession. Witnesses must state their name and 

15 affiliation prior to making their statement. Please 

16 speak slowly and clearly so our court recorder can 

17 record these proceedings accurately. 

18 In order to streamline the process, members of 

19 each group should be in the room in advance of their 

20 projected group time and should be prepared to make 

21 their way to the front of the room while the previous 

22 members are giving their testimony. Depending on the 

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1 number of testifiers that we have today, we may end up 

2 taking a break during the day. 

3 Finally, while the EPA representatives speaking 

4 today will attempt to ensure the accuracy of any 

5 description we provide or discussion of the proposal 

6 and the ANPR, the official version of the proposal and 

7 the ANPR is that published in the Federal Register on 

8 July 1st, 2015, and it controls any cases of conflict 

9 between it and what you may hear today. Please refer 

10 to the official version in developing your written 

11 comments on the proposal or on the ANPR. 

12 Thank you. With that, we would like to call the 

13 first group of witnesses to speak in this order: Dr. 

14 Nic Lutsey from the International Council on Clean 

15 Transportation, Nancy Young from Airlines for America, 

16 and Nancy Kruger from the National Association of Clean 

17 Air Agencies. Thank you. 

18 DR. LUTSEY: Good morning. Thanks for the 

19 opportunity to give these remarks. My name is Nic 

20 Lutsey. I am a program director at the International 

21 Council on Clean Transportation. The ICCT is an 

22 independent nonprofit organization founded to provide 

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1 first-rate, unbiased research and technical analysis to 

2 environmental regulators. 

3 The ICCT appreciates the opportunity to provide 

4 this testimony on EPA's aviation endangerment finding 

5 and advance notice of proposed rulemaking on aviation 

6 and greenhouse gas emissions. 

7 Our comments are informed by the engagement of 

8 ICCT staff in environmental working groups to the 

9 International Civil Aviation Organization, or ICAO, 

10 since 2008. In particular, since 2009, we have 

11 contributed technical analysis to efforts to develop 

12 the international carbon dioxide, or CO2, standard that 

13 is referenced heavily within the ANPR. 

14 Our comments will focus on the following points: 

15 first, the scope of the endangerment finding; second, 

16 the applicability, timing, and stringency of an 

17 international or domestic CO2 emissions standard; and, 

18 third, potential domestic reporting requirements for 

19 aviation manufacturers under the Clean Air Act. 

20 EPA has proposed that the endangerment finding 

21 focus on six key greenhouse gases. We concur with this 

22 general approach with caveats. We agree with the EPA's 

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1 assessment that scientific uncertainties on the climate 

2 impact of nitrogen oxides, or NOx, and water vapor 

3 emitted at altitude remain high enough so as not to 

4 address them in this initial endangerment finding. 

5 The science regarding the contribution of black 

6 carbon to climate change, on the other hand, is clear. 

7 Black carbon was identified as the second most 

8 important contributor to anthropogenic emissions in 

9 2013. To reflect the latest science, EPA should 

10 consider incorporating black carbon in its final 

11 aviation endangerment finding. Also, while we do not 

12 support integrating cruise NOx under the endangerment 

13 finding, EPA should consider expanding its existing NOx 

14 reporting requirement for aircraft engine manufacturers 

15 from only landing and takeoff emissions, to include 

16 cruise emissions. 

17 ICAO has outlined two general approaches for the 

18 applicability of an international CO2 emissions 

19 standard: in the first approach, only new aircraft 

20 designs being type certified for the first time be 

21 required to comply; in the second, that all new 

22 aircraft delivered after a certain date; that is, both 
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1 new designs and new in-production aircraft, would need 

2 to pass. 

3 Based upon our analysis, covering all new aircraft 

4 delivered after a certain date, it will be necessary 

5 for the standard to significantly reduce emissions 

6 beyond business as usual. Since new-type aircraft are 

7 rare, our analysis suggests that a new-type-only 

8 standard beginning in 2020 would only cover about 5 

9 percent of the global fleet in 2030, as opposed to a 

10 requirement after affecting all new aircraft, which 

11 could cover more than half of the global fleet that 

12 year. 

13 Furthermore, we do not expect the new-type-only 

14 standard to reduce the emissions below business as 

15 usual because of the definition that ICAO has chosen of 

16 technological feasibility. In 2030, ICAO decided that 

17 only technologies widely available for deployment in 

18 2016 across multiple aircraft types will be considered 

19 in establishing stringency. A standard implemented in 

20 2020 for new applications for type certification will 

21 affect aircraft types with entry into service of 2024 

22 or later due to the time required for certification. 

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1 This time lag, combined with the decision that, at 

2 most, the standards can require state-of-the-art 2016 

3 technologies when implemented means that even the most 

4 aggressive standard will lag the fuel efficiency of 

5 new-type aircraft when they enter into service. 

6 For these reasons, we conclude that covering all 

7 new aircraft will be required to meet the purpose of 

8 the standard to reduce emissions beyond business as 

9 usual. 

10 On stringency, we believe that an international 

11 and/or domestic CO2 standard should be set to require 

12 at least state-of-the-art 2016 technologies for new 

13 aircraft types certified after the standard takes 

14 effect. 

15 ICAO was also investigating a tiered approach, 

16 under which deliveries of new in-production aircraft or 

17 models that are type-certified before the standard 

18 takes effect may have separate targets applied to them. 

19 Pending additional analysis, a lower stringency level 

20 may be appropriate for those types but still within the 

21 highest three levels identified by EPA in the ANPRM. 

22 On timing, in order to minimize the number of 

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1 years that a new-type regulatory level lags business2 as-usual aircraft, the standard should be applied for 

3 new types as early as possible; in this case, 2020. 

4 Early implementation for new in-production aircraft, 

5 either in 2020 or 2023, is also preferable. 

6 Finally, since current discussions on 

7 international emissions standard assume a static 

8 stringency level, it would be appropriate for the U.S. 

9 to press for early ICAO review of any international CO2 

10 standard, starting in 2019, so that the updated 

11 requirements are in place to drive additional 

12 technology development beyond 2020. 

13 Regarding manufacturer reporting requirements, we 

14 recommend that EPA consider adopting a domestic 

15 reporting requirement for cruise CO2 and NOx under the 

16 Clean Air Act. ICAO is considering the development of 

17 a voluntary database for CO2 only. We believe that 

18 detailed mandatory reporting is necessary to ensure 

19 transparency and a level playing field across 

20 manufacturers. 

21 Finally, as noted before, we believe that the 

22 collection of cruise NOx data domestically would help 

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1 improve our understanding of the climate impact of 

2 aviation NOx emissions. EPA would need to analyze the 

3 cost and complexity of developing measurement and 

4 reporting protocols for cruise NOx if it decides to 

5 pursue this approach. Our more detailed comments would 

6 be submitted to EPA in writing. In addition, we will 

7 submit an update to the 2009 study referenced in the 

8 ANPRM entitled "Efficiency Transferred, New Commercial 

9 Jet Aircraft, to the Public Docket." The two studies 

10 together highlight the importance of a meaningful CO2 

11 emission standard to the U.S.' aviation greenhouse gas 

12 emissions reduction plan. 

13 Thank you for the opportunity to comment here 

14 today and for EPA's continuing work on this very 

15 important topic. 

16 MS. YOUNG: My name is Nancy Young. I am the Vice 

17 President of Environmental Affairs for Airlines for 

18 America representing the major passenger and cargo 

19 airlines in the United States. We appreciate this 

20 opportunity to testify regarding EPA's proposed 

21 findings on aircraft greenhouse gas emissions and 

22 advance notice of proposed rulemaking. 
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1 As the record of our members demonstrates, we take 

2 our role in controlling greenhouse gas emissions very 

3 seriously. For the past several decades, U.S. airlines 

4 have dramatically improved fuel efficiency and reduced 

5 carbon dioxide emissions by investing billions in fuel6 saving aircraft and engines, innovative technologies, 

7 like winglets, and cutting-edge route optimization 

8 software. As a result, although U.S. airlines comprise 

9 5 percent of U.S. economic activity, they account for 

10 only 2 percent of the greenhouse gas emissions 

11 inventory. The industry has improved fuel efficiency 

12 120 percent since 1978, saving 3.8 billion metric tons 

13 of carbon dioxide emissions, the equivalent of taking 

14 23 million cars off the road each of those years. 

15 Further, the U.S. airlines carried 20 percent more 

16 passengers in cargo in 2014 than they did in 2000 while 

17 emitting 8 percent less carbon dioxide. 

18 Despite the industry's strong record to date, 

19 however, we are not stopping there. The U.S. airlines 

20 are active participants in a global aviation coalition 

21 that is committed to 1.5 percent annual average fuel 

22 efficiency improvements through 2020 and carbon-neutral 

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1 growth from 2020, subject to critical aviation 

2 infrastructure and technology advances achieved by 

3 government and industry. 

4 Our members are keenly focused on these advances, 

5 both at the national and international levels. For 

6 example, the U.S. airlines are partnering to modernize 

7 the air traffic management system and to reinvigorate 

8 research and development in aviation environmental 

9 technology. 

10 In addition, we are dedicated to developing 

11 commercially viable, sustainable alternative aviation 

12 fuel, which could further reduce aviation's greenhouse 

13 gas emissions while enhancing U.S. energy independence 

14 and security. 

15 A for A is a founding member of the Commercial 

16 Aviation Alternative Fuels Initiative, a public-private 

17 partnership with FAA and other stakeholders that is 

18 working on the development and deployment of such 

19 fuels. 

20 Having helped lay the necessary technical 

21 groundwork, A for A members have already begun to use 

22 biojet fuel on commercial flights. Further, our 

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1 industry coalition is supporting the development of a 

2 global carbon emissions offset mechanism that could be 

3 used to fill the gap should concerted industry and 

4 government investments in technology, operations, and 

5 infrastructure measures otherwise not allow us to 

6 achieve our goal of carbon-neutral growth from 2020. 

7 It is against this backdrop that A for A welcomes 

8 the opportunity to submit a full set of comments on 

9 EPA's proposed findings and ANPR by the August 31 

10 comment deadline. 

11 For purposes of this hearing, A for A offers five 

12 preliminary observations. First, A for A concurs with 

13 EPA that it is appropriate for the agency to limit its 

14 endangerment and cause or contribute findings to the 

15 six well-mixed, long-lived greenhouse gas emissions. 

16 As EPA points out in its proposal, aircraft only emit 

17 two of those 6 emissions, 99 percent of which is carbon 

18 dioxide. As carbon dioxide is directly related to fuel 

19 burn and with jet fuel as the number one cost for 

20 commercial airlines, A for A members already have a 

21 powerful incentive to continue to reduce CO2 output. 

22 Second, A for A urges EPA to keep our industry's 

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1 strong fuel efficiency record, relative greenhouse gas 

2 emissions contribution, and global sectoral approach 

3 commitment squarely in mind as the agency proceeds. 

4 Indeed, commercial aviation accounts for 2 percent of 

5 the nation's greenhouse gas emissions inventory while 

6 the sources EPA previously has sought to cover with 

7 greenhouse gas emissions regulations, on-road motor 

8 vehicles and power plants, respectively, account for 23 

9 and 31 percent. 

10 Third, given the industry's demonstrated fuel 

11 efficiency record and economic incentive to continue 

12 that trend, there is a real question as to whether any 

13 EPA regulation of greenhouse gas emissions from 

14 aircraft engines is needed. That said, as aviation is 

15 a global industry with airlines operating 

16 internationally and manufacturers selling their 

17 aircraft in international markets, it is critical that 

18 aircraft emissions standards be set at the 

19 international level and not imposed unilaterally. 

20 Accordingly, we appreciate the direct engagement of EPA 

21 and FAA in the development of the aircraft carbon 

22 dioxide certification standard at the International 
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1 Civil Aviation Organization, the United Nations body 

2 charged with setting standards and recommended 

3 practices for international aviation. Not only is the 

4 ICAO process for setting aircraft standards highly 

5 rigorous but ICAO criteria for adopting such standards 

6 aligned well with the criteria under section 231 of the 

7 Clean Air Act. 

8 Fourth, A for A strongly supports EPA's stated 

9 intent to adopt the future ICAO CO2 certification 

10 standard into U.S. law consistent with the Clean Air 

11 Act, its treaty obligations, and in harmony with the 

12 international community. 

13 Finally, A for A urges EPA to take note of the 

14 fact that the future ICAO CO2 certification standard 

15 for new aircraft is but one arrow in the aviation 

16 industy's quiver for meeting its emissions goals. 

17 FAA's NextGen initiative, public-private research and 

18 development partnerships, are collaborative efforts to 

19 deploy sustainable alternative aviation fuels at 

20 commercial-scale. And a vast array of additional 

21 operational and infrastructure initiatives being 

22 undertaken by airlines, airports, manufacturers, and 

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1 other stakeholders are also critical arrows in that 

2 quiver. 

3 Commercial aviation has an important role to play 

4 in how America responds to climate change. Be assured 

5 that A for A and our members are committed to doing our 

6 part. 

7 Thank you. 

8 MS. KRUGER: Good morning. I am Nancy Kruger, 

9 Deputy Director of NACAA, the National Association of 

10 Clean Air Agencies. Thank you for this opportunity to 

11 testify and provide preliminary comments of NACAA on 

12 EPA's proposed aircraft endangerment finding and 

13 advance notice of proposed rulemaking seeking input on 

14 ICAO's ongoing development of international aircraft 

15 standards for CO2 and also the potential forthcoming 

16 development by EPA of an aircraft carbon dioxide 

17 emissions standard. 

18 NACAA is a national nonprofit, nonpartisan 

19 association of air pollution control agencies in 41 

20 states, the District of Columbia, 4 territories, and 

21 116 metropolitan areas. Our members, our professionals 

22 in our member agencies, have vast experience in 

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1 improving air quality in the U.S. And our testimony is 

2 based on that experience. 

3 First, with respect to the endangerment finding, 

4 NACAA commends EPA and supports it on its proposal to 

5 find the GHG concentrations in the atmosphere endanger 

6 the public health and welfare of current and future 

7 generations within the meaning of section 231(a) of the 

8 Clean Air Act to find that GHG emissions from certain 

9 aircraft classes cause or contribute to air pollution 

10 that endangers public health and welfare and also to 

11 use the same definition of air pollution under section 

12 231(a) as the agency used in making its 2009 

13 endangerment finding with respect to motor vehicles. 

14 EPA states in its proposal that the 2009 

15 endangerment finding is firmly established and well16 settled and that there is no need to reopen, revisit it 

17 in order to make an additional finding under section 

18 231. NACAA agrees and supports EPA's proposal to make 

19 such an additional finding now. 

20 EPA's proposed finding under section 231 sets the 

21 stage for harmonizing international and U.S. aircraft 

22 CO2 emissions standards. With ICAO expected to adopt 

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1 an international standard as early as February of 2016, 

2 we appreciate EPA's request through the ANPR for input 

3 on establishing that standard and the potential use of 

4 Clean Air Act section 231 to adopt and implement the 

5 ICAO standard domestically. NACAA supports the United 

6 States' continued support for adopting an international 

7 standard as well as EPA adoption of a domestic standard 

8 that will address the source category in a significant 

9 way. 

10 Aircraft represent the single largest U.S. 

11 transportation source of greenhouse gas emissions not 

12 yet subject to greenhouse gas standards. Clearly this 

13 is a sector that merits regulation commensurate with 

14 other transportation sectors. ICAO and EPA must 

15 establish as rigorous and comprehensive a regulatory 

16 package as possible. In the U.S., this is especially 

17 critical because state and local air pollution control 

18 agencies do not have authority under the federal Clean 

19 Air Act to regulate aircraft emissions beyond the 

20 limits set by EPA. 

21 Accordingly, NACAA offers the following over22 arching preliminary comments on three key issues 
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1 highlighted in the ANPR: applicability, timing, and 

2 stringency of an aircraft CO2 emissions standard. ICAO 

3 is considering various approaches for the applicability 

4 of an aircraft CO2 standard with the fundamental 

5 question being whether that standard should apply to 

6 in-production aircraft or only to completely new 

7 aircraft-type designs. NACAA believes it is essential 

8 that the standard apply to both in-production aircraft 

9 and new-type designs and that the definition of in10 production be any covered aircraft produced after the 

11 compliance deadline. We simply cannot forego the 

12 emissions reductions to be garnered from regulating in13 production engines and find no persuasive reason to 

14 forego them. 

15 On the issue of timing, NACAA recommends that the 

16 standard take effect as soon as possible, by 2020 for 

17 new aircraft types and by 2023 for in-production 

18 aircraft. NACAA is still studying the CO2 stringency 

19 options identified by EPA in the ANPR. However, we can 

20 say now that our association strongly encourages ICAO 

21 and EPA to set a standard that is as stringent as 

22 possible and that the standard be technology-forcing, 

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1 rather than technology-following. 

2 NACAA would also like to touch briefly on a few 

3 additional issues related to an aircraft CO2 emissions 

4 standard. First, we recommend that engines associated 

5 with but not part of an aircraft also be addressed by 

6 an aircraft CO2 standard. Key among these are 

7 auxiliary power units. 

8 Second, we recommend that EPA pursue opportunities 

9 for establishing standards for in-use aircraft, which, 

10 for example, can be retrofitted with winglets to reduce 

11 draft and save fuel. 

12 Third, although the standard at issue here is for 

13 CO2, there is also the potential for additional NOx 

14 emissions reductions. And we encourage EPA to analyze 

15 this potential carefully and take steps to maximize 

16 reductions. 

17 Finally, while NACAA supports the establishment of 

18 an international aircraft CO2 standard through ICAO, a 

19 domestic standard that reaps the full measure of 

20 potential reductions from the source category is 

21 critically important. Therefore, we urge that EPA be 

22 prepared to adopt a more rigorous program and standard 

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1 than ICAO if the international standard falls short, 

2 including with respect to the items we have raised in 

3 this testimony. 

4 In the coming weeks, we will continue to study 

5 these and other issues related to EPA's proposed 

6 endangerment finding and ANPR and will offer additional 

7 comments in writing by the August 31st deadline. And 

8 in the meantime, we appreciate this opportunity to 

9 share our views this morning and look forward to 

10 continuing to work with you on this important 

11 initiative. 

12 Thank you. 

13 MR. GUNNING: Thank you all for your thoughtful 

14 comments. I appreciate that. The agency appreciates 

15 your comments. 

16 Let me now call the second group of speakers up, 

17 please. Thank you. So in the second group, we have 

18 Mr. Erik White from the California Air Resources Board; 

19 Joe DePete from the Air Line Pilots Association 

20 International; and Mr. James Lee, member of the public. 

21 And, just for everybody, speak into the mike, please,

22 nice and loud so we can hear. Thank you. 

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1 MR. WHITE: Good morning. Thank you for the 

2 opportunity to testify before you today on the proposed 

3 endangerment finding and advance notice of proposed 

4 rulemaking for greenhouse gas emissions from aircraft. 

5 My name is Erik White, and I am Chief of the Mobile 

6 Source Control Division at California Air Resources 

7 Board. 

8 The Air Resources Board is the California state 

9 agency responsible for meeting federal air quality 

10 standards and coordinating the state's activities to 

11 reduce greenhouse gas emissions. ARB will also be 

12 providing written comments into the docket. However, I 

13 am here today to emphasize the need for strong national 

14 greenhouse gas emissions standards for aircraft and to 

15 reemphasize the unique opportunity that U.S. EPA has to 

16 be a global leader for reducing aviation emissions. 

17 I would like to begin by reiterating part of the 

18 testimony provided by ARB Chairman Mary Nichols in 2008 

19 at the hearing for regulation of greenhouse gases under 

20 the Clean Air Act. At that hearing, Chairman Nichols 

21 said climate change is a real and urgent threat to our 

22 communities, our state, and our nation. Over the past 
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1 100 years, we have experienced a seven-inch sea rise, 

2 eroding our coastal communities and threatening 

3 critical infrastructure. In the winter, more of our 

4 precipitation in California is falling as rain than 

5 snow, leading to less water availability in the 

6 critical spring and summer, an impact that threatens 

7 one of the most productive agricultural regions in the 

8 world and a pillar of the nation's export economy. 

9 Climate change is also a major factor in our longer and 

10 more severe wildfire season. It is predicted that 

11 without major efforts to reduce greenhouse gases in 

12 this century, California will see a 1 to 2-foot sea13 level rise, a 75 percent loss in snow pack, twice the 

14 frequency of drought years, and 55 percent more large 

15 forest fires. Her comments are even truer today than 

16 they were seven years ago, as demonstrated by the 

17 severe drought and wildfires that are gripping 

18 California even as I speak. 

19 The passage of California's assembly bill 32, the 

20 Global Warming Solutions Act, established one of the 

21 world's most comprehensive and ambitious greenhouse gas 

22 reduction programs and positioned California to be on 

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1 the forefront of addressing climate change emissions. 

2 However, in some sectors, such as aviation, California 

3 and the various states are dependent on the federal 

4 government to set the most aggressive standards 

5 feasible. In that vein, the Clean Air Act provides the 

6 U.S. EPA with both the authority and the responsibility 

7 to do what California and the other states cannot do by 

8 themselves. 

9 Today, I speak before you to support the 

10 endangerment finding that greenhouse gas emissions from 

11 aircraft cause or contribute to air pollution that may 

12 be reasonably anticipated to endanger public health and 

13 welfare. 

14 As stated in California's 2007 joint petition for 

15 aircraft GHG emissions rulemaking and comments on the 

16 2008 advance notice of proposed rulemaking for 

17 greenhouse gases under the Clean Air Act, the 

18 overwhelming scientific data support the claim that air 

19 pollution, made up of the elevated atmospheric 

20 concentrations of the 6 well-mixed GHGs, endanger both 

21 the public health and public welfare. Since that time, 

22 new scientific assessments have further substantiated 

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1 the detrimental effect of GHG emissions. As asserted 

2 in 2007, the U.S.A. has the obligation under section 

3 231 of the Clean Air Act to set emissions standards 

4 accordingly once the endangerment finding is made. 

5 As U.S. EPA has noted, aircraft emissions made up 

6 the third largest U.S. transportation source of GHGs 

7 after emissions from light-duty vehicles and medium and 

8 heavy-duty trucks. The aircraft GHG emissions, 11 

9 percent of the U.S. GHG emissions from transportation 

10 are greater than all other transportation sources 

11 combined that come after it. And it remains the single 

12 largest unregulated GHG-emitting transportation source 

13 in the U.S. 

14 Furthermore, it is estimated that U.S. aircraft 

15 will exhibit the largest growth in GHG emissions 

16 amongst all transportation sector locations. As such, 

17 it is imperative that decisive and expeditious action 

18 be carried out to stem GHG emissions from aircraft. 

19 ARB recognizes that the International Civil 

20 Aviation Organization is anticipated to promulgate a 

21 CO2 aircraft emissions standard. While this is a 

22 promising initial step in controlling GHG emissions 

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1 from aircraft, historically ICAO emissions standards 

2 have been technology-following, not technology-forcing. 

3 As such, ARB is concerned that the standards eventually 

4 adopted by ICAO may not sufficiently reduce GHG 

5 emissions past a business-as-usual scenario. ARB 

6 supports the international establishment of aircraft 

7 emissions standards that are as stringent as possible. 

8 And in the absence of a strong showing by ICAO, we urge 

9 the U.S. EPA to extend its regulatory authority further 

10 and adopt a CO2 emissions standard that will forward 

11 technology development and provide accelerated 

12 reductions. 

13 There are a variety of both aircraft design and 

14 aircraft engine technologies under development which 

15 show tremendous promise and further a national and 

16 California GHG emission reduction goals. And these 

17 should be considered as part of this regulation. 

18 ARB recommends the U.S. EPA also look at the use 

19 of biojet fuel as a method to reduce GHG emissions. 

20 From a wells-to-wheel basis, the use of these fuels can 

21 have a substantial impact on reducing GHG emissions 

22 from aviation. Going beyond the business-as-usual also 
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1 means that standards must be adopted that are 

2 applicable both to aircraft models that are in 

3 production after the effective date of the standard as 

4 well as to future aircraft types. 

5 ARB also supports an additional reporting 

6 requirement for aircraft cruise CO2 emission rates due 

7 to the importance of collecting data to ascertain 

8 regulatory compliance as well as to inform policy 

9 decisions on future CO2 emissions reduction 

10 opportunities. The reporting requirement could be 

11 standalone or in conjunction with an emissions standard 

12 for both new and in-production aircraft types. 

13 Further, as a complement to the CO2 emissions 

14 standard, ARB encourages U.S. EPA to seek additional 

15 aircraft-related reduction opportunities. These 

16 include retrofit requirements for existing in-use 

17 aircraft with fuel-efficient technologies and reducing 

18 emissions from auxiliary power units on aircraft. ARB 

19 also encourages U.S. EPA to consider regulations to 

20 further reduce aircraft engine criteria pollutants, 

21 particularly oxides of nitrogen. 

22 The mitigation of aircraft-related emissions 

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1 remains a critical part of ARB's emission reduction 

2 strategies. And ARB is working to do its part by 

3 ensuring other aviation-related emission reduction 

4 opportunities, pursuing other aviation-related emission 

5 opportunities. For instance, in the near term, ARB 

6 will consider measures to reduce emissions from ground 

7 support equipment, airport shuttle buses, and other on8 facility airport-related emissions. 

9 In closing, in the event that ICAO fails to adopt 

10 a meaningful aircraft CO2 emissions standard by next 

11 February, standards that go far beyond business as 

12 usual, ARB urges U.S. EPA to act independently of ICAO 

13 and establish a strong national CO2 emissions standard 

14 without further delay. California believes it is clear 

15 that U.S. EPA has authority to impose more stringent 

16 regulations than ICAO on U.S. aircraft and engine 

17 manufacturers. And we believe the overwhelming 

18 scientific data has proven that aircraft GHG emissions 

19 do endanger public health. Therefore, U.S. EPA has the 

20 obligation under section 231 of the Clean Air Act to 

21 set emissions standards as expeditiously as possible. 

22 Decisive and timely regulation of major GHG sources is 

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1 critical to meet our state and national GHG goals. 

2 Thank you for your time. 

3 MR. GUNNING: Thank you. Thank you, Mr. White. 

4 Mr. DePete, the floor is yours. 

5 MR. DePETE: Thank you. Good Afternoon. Thank 

6 you for the opportunity to present at this important 

7 public hearing. I am Captain Joe DePete. I serve as 

8 the First Vice President of the Air Line Pilots 

9 Association International. And I serve also as the 

10 National Safety Coordinator. I am also a FedEx pilot 

11 and a captain that flies the A300, the Airbus A300. 

12 ALPA is the world's largest professional airline 

13 pilots' union. We have more than 52,000 members, who 

14 fly for 31 airlines in the United States and Canada. I 

15 would like to give ALPA's view on the EPA's proposed 

16 finding regarding greenhouse gas emissions and its 

17 advance notice of proposed rulemaking, but first, 

18 however, I would like to provide some context about why 

19 we are passionate about this subject. I will also talk 

20 about the positive difference that U.S. airlines are 

21 making to reduce emissions while safely transporting 

22 more than 2 million passengers and more than 63,000 

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1 tons of freight and mail each day. Airline pilots sit 

2 literally at the intersection of technology, aircraft 

3 operating procedures, aircraft traffic control 

4 procedures and techniques, and varying aircraft 

5 capabilities. This gives us a unique vantage point 

6 from which to manage our aircraft capabilities in such 

7 a way as to burn less fuel while operating as safely 

8 and efficiently as possible. 

9 ALPA's principal goal is to help further the 

10 advances that aviation has already made towards 

11 reducing greenhouse gas emissions and improving the 

12 efficiency of our industry while maintaining or 

13 improving on our current level of safety. Improved 

14 engine and aircraft technologies have resulted in 

15 significant reductions in harmful emissions. Increased 

16 reliance on satellite-based navigation will lead to 

17 even more significant reductions. In addition, these 

18 improvements contribute to the need to ensure ongoing 

19 viability and sustainability of the airline industry. 

20 Fuel is the largest single expense that our 

21 airline employers face. In addition to the need to act 

22 responsibly toward the environment, airlines have a 
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1 very strong motivation to safely find ways to use as 

2 little fuel as possible and look for alternative fuels 

3 that are not only less expensive but also have less 

4 effect on our environment. 

5 The simple fact is that whatever affects our 

6 employers ultimately affects pilots as well. We have a 

7 similar financial incentive to help them conserve fuel. 

8 Pilots work with their companies and air traffic 

9 control on a daily basis to safely reduce fuel burn 

10 while airborne and on the ground. Additionally, our 

11 membership is cognizant of the need to protect our 

12 environment, just like the airlines. We strive to do 

13 that on every flight within the bounds of safety, which 

14 is, of course, our primary focus. 

15 ALPA strongly supports reducing aviation's already 

16 small percentage of contributions to greenhouse gases 

17 while at the same time preserving the economic 

18 viability of the airline industry. These two goals are 

19 complementary. As fuel and operational efficiency 

20 continue to improve, economic viability is enhanced. 

21 Air transportation is a significant portion of the 

22 mass transportation system here in North America. U.S. 

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1 airlines transport about 775 million passengers and 

2 carry about 23 million tons of freight and mail each 

3 year. Aviation, arguably, has the most successful 

4 record of any sector in the economy in limiting its 

5 impact on the environment while simultaneously 

6 increasing productivity. 

7 Airlines have greatly reduced carbon-based 

8 emissions through ever-advancing engine technology. 

9 That reduces fuel burn and emissions of undesirable 

10 gases and particulates. We also use airframes that are 

11 lighter, stronger, and create less fuel-burning drag. 

12 Compared to 1972, the North American airline industry 

13 now carries 6 times more payload using 60 percent less 

14 fuel per flight. I think that is a significant number. 

15 It has reduced by 95 percent the number of people 

16 significantly impacted by aircraft noise. Because of 

17 these advances, airline domestic travel accounts for 

18 only two percent of all greenhouse gas emissions while 

19 accounting for about five percent of the gross national 

20 product. 

21 The bottom line for ALPA is that we are strong 

22 advocates for staying the course when it comes to 

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1 improving fuel efficiency through new technology. 

2 Airlines must be able to afford to invest in new, more 

3 efficient aircraft and engines that reduce the impact 

4 on the environment, which has been the key to their 

5 success. 

6 Concerning the EPA's announcement, we are pleased 

7 that the agency is working with the ICAO Committee on 

8 Aviation Environmental Protection and is engaged in 

9 developing a future aircraft certification standard for 

10 CO2, carbon dioxide. We urge the agency not to exceed 

11 that standard, which is slated to be considered for 

12 approval February of 2016. 

13 As the EPA knows, ICAO is in a unique position to 

14 bring together governments and world airlines to 

15 collaborate and develop a standard that will be adopted 

16 by member states, including the United States and 

17 Canada. Going beyond these agreed-upon standards could 

18 have a very detrimental effect on our airlines. ALPA 

19 is a strong proponent of a level playing field for all 

20 airlines. The creation of a U.S.-specific emissions 

21 standard that is more stringent than that used by other 

22 ICAO nations would put our carriers at a distinct 

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1 financial disadvantage without a commensurate benefit 

2 to the environment. 

3 Regarding the advance NPRN, ALPA does not believe 

4 that any new emissions standards requirement for 

5 aircraft should involve retrofitting of in-service 

6 aircraft or aircraft already on order. The standard 

7 should apply only to new types of aircraft that are yet 

8 to be certified so as not to cause an undue financial 

9 harm to the airline industry. 

10 I wish to thank you all again for the opportunity 

11 to speak with you today. I would be pleased to take 

12 any questions that you may have. Thank you. 

13 MR. GUNNING: Mr. Lee? 

14 MR. LEE: Hi. My name is James Lee. I am from 

15 Sumter, South Carolina. I am a citizen. 

16 Why is the EPA claiming that six greenhouse gases 

17 emitted from jet planes are a threat to human health 

18 under the Clean Air Act while doing nothing to address 

19 ongoing lawsuits over leaded aviation gasoline or the 

20 real health concerns of stakeholders worldwide, cancer21 causing heavy metals in fuels, and their additives and 

22 aviation-induced cloudiness? You, the EPA, claim the 
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1 authority to regulate aviation emissions under the 

2 Clean Air Act, a law that should protect us from the 

3 aforementioned poisonous pollution. However, the 

4 definition of pollution is being perverted to mean 

5 climate change gases in what can only be called a 

6 violation of the spirit of the law, "air pollution 

7 which may reasonably be anticipated to endanger public 

8 health or welfare." That is the quote. 

9 As you can see by the wording in the Clean Air 

10 Act, lead, barium, aluminum, and trade-secret toxic 

11 chemicals clearly present a greater danger to public 

12 health than greenhouse gases, no matter how much 

13 climate science you accumulate. 

14 Furthermore, material safety data sheets of 

15 aviation fuel and their additives almost always contain 

16 the same warning: Do not dump in water. Yet, raw fuel 

17 dumping or burning these chemicals, dangerous 

18 chemicals, and then dumping them in water is somehow 

19 safe. 

20 Finally, despite great efforts to find 

21 bioaccumulation or biomagnifications studies on 

22 precipitated aviation pollutants, none seem to exist. 

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1 The EPA and Obama administration are ignoring the 

2 global outrage over the most visible climate change 

3 concern from airplanes: cloud creation. Do a search 

4 for the word "contrails" on the Internet, and you will 

5 see millions of concerned citizens who look up and 

6 wonder what in the world are they spraying. Despite 

7 what you may think of the myriad of maladies attributed 

8 to these clouds, the global outrage is, nonetheless, 

9 clear. They are right to be worried, and we should all 

10 be concerned. The EPA's claim that CO2 is a greater 

11 threat to human health than contrails and aviation12 induced cloudiness is based on incomplete IPPC data 

13 that downplays the effects of contrails on our climate. 

14 The IPPC's fourth assessment of contrail-radiated 

15 forcing only accounted for linear contrails, meaning 

16 any contrail that spreads out and turns into cirrus 

17 clouds, was not accounted for. How significant is this 

18 heat-trapping contrail conundrum? "Contrails formed by 

19 aircraft can evolve into cirrus clouds 

20 indistinguishable from those formed naturally. These 

21 spreading contrails may be causing more climate warming 

22 today than all the carbon dioxide emitted by aircraft 

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1 since the start of aviation." 

2 Another researcher stated, "A single aircraft 

3 operating in conditions favorable for persistent 

4 contrail formation appears to exert a contrail-induced 

5 radiative forcing some 5,000 times greater than the 

6 estimates of the average persistent contrail radiative 

7 forcing from the entire civil aviation fleet." 

8 Although this research has now been incorporated 

9 in the IPPC computer models and revised down, in my 

10 opinion, these claims highlight gaping holes in climate 

11 science. As of 2013, "Aerosol cloud interactions are 

12 one of the main uncertainties in climate research." 

13 Scientific understanding of how contrails transitioned 

14 into cirrus clouds is severely lacking but rapidly 

15 evolving with the latest research showing that cirrus 

16 clouds are filled with metal aerosols from human 

17 sources, "The big one we found is lead, coming from 

18 things like tetraethyl lead in fuels, still used today 

19 in light aviation." So that is probably the biggest 

20 metal that we find or the most frequent metal that we 

21 find, but we find a whole host of different metals, 

22 actually. 

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1 Apparently small amounts of metal particulates 

2 have major effects on cirrus clouds, "It would seem 

3 that you would have to change all of the aerosol in the 

4 atmosphere very radically to get a big effect on the 

5 clouds, but because mineral dust and metallic particles 

6 are such a small amount of the particulate matter, just 

7 a percent or two, it means that you only have to change 

8 about a percent or two of the particles to get a big 

9 effect on these clouds." 

10 The latest research casts doubts on the IPPC's 

11 contrail assumptions and requires serious consideration 

12 when addressing the real climate change impact of 

13 aviation. High-altitude metals and cirrus cloud 

14 condensation nuclei are likely coming from leaded AVGAS 

15 and jet exhaust. 

16 Contrails are making cirrus clouds, and small 

17 changes in atmospheric metal have large impacts on 

18 cirrus cloud creation. 

19 Cirrus clouds trap heat and are likely to have a 

20 greater climate change impact than CO2. 

21 Finally, aviation-induced cloudiness endangers 

22 future growth in solar energy, affects tourism and 
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1 spending, and is projected to make terrestrial 

2 astronomy impossible by 2050. Geoengineering 

3 scientists, NASA, NOAA, FAA, USDA, DOE, and 

4 international corporate partners, are discussing the 

5 use of biofuels and sulfur-doped jet fuels for contrail 

6 control and cirrus cloud seeding with bismuth 

7 tri-iodide to melt these clouds away. The EPA should 

8 be directly involved in these discussions. 

9 As a result of these recent findings, I strongly 

10 encourage the EPA to consider expanding the scope of 

11 this endangerment to include metal particulates and 

12 cloud formation from jet exhaust. 

13 If the EPA complies with the spirit of the Clean 

14 Air Act, they will protect us from metal aerosols 

15 attributed to Alzheimer's, autism, cancer, and a 

16 plethora of other debilitating illnesses. 

17 If the EPA is truly concerned about aviation18 induced climate change, they will regulate the 

19 production of contrails and cirrus clouds, which change 

20 our climate to a much greater extent than the sum of 

21 the six greenhouse gases named in this proposal. 

22 Regulating heavy metals and aviation-induced 

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1 cloudiness will be meaningless without proper 

2 verification. Even though ICAO members sign a binding 

3 agreement to only use certain chemicals in their gas 

4 tanks, we all know agreements and regulations are 

5 useless without proper verification. 

6 Therefore, I request mandatory, random testing of 

7 jet exhaust be immediately implemented. This is the 

8 most important step the EPA can take to follow the 

9 spirit of the law, do its due diligence to protect us 

10 from harmful pollution, and get real-world data to 

11 improve future regulations. 

12 Most of the data behind this endangerment finding 

13 comes from research in highly controlled environments 

14 where most variables are known. We need verification 

15 of non-ideal situations where fuel fouling, FAME 

16 contamination, or improper maintenance end in vastly 

17 different exhaust particulates than seen in "lab" 

18 settings. To achieve verification, I propose that the 

19 EPA randomly attach a trailing probe to both foreign 

20 and domestic flights, then collect and analyze the 

21 results to determine real-world exhaust constituents. 

22 Alternatively, ground-based LIDAR observations may be 

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1 possible over fixed, high-traffic areas and prevent 

2 possible terrorist attacks using aerosols. Either way 

3 you choose, we need verification and protection. 

4 In conclusion, the EPA should expand this 

5 endangerment to include metal aerosols and cloud 

6 creation, create a verification system that includes 

7 all aircraft, protects us from aviation pollution, 

8 holds violators accountable, and commits to better 

9 scientific accuracy for future determinations. 

10 Thank you for this opportunity to speak on behalf 

11 of so many who could not be here. And thank you for 

12 listening to a layperson's views on this subject. 

13 While I appreciate the efforts of the Center for 

14 Biological Diversity, the Sierra Group, and the Friends 

15 of the Earth to get the EPA to hold the aviation 

16 industry accountable, the poor people like myself have 

17 to live near these airports, under these fuel dumps, 

18 and under these clouded skies. I hope that some faith 

19 can be restored in our EPA by your action here and now. 

20 Tell the ICAO that they will meet your demands and our 

21 demands, not the other way around. 

22 Thank you very much. 

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1 MR. GUNNING: Thank you, Mr. Lee. Thank you for 

2 all of your comments. 

3 Second panel? 

4 MR. CHARMLEY: Yes. Thank you. I think we are 

5 okay, and then I am going to call forward the group 

6 number 3 panel at this point. So this would be -- I 

7 apologize if I don't pronounce anyone's name properly 

8 -- Leslie Riegle, Doug Wolf, and Michael Saraceno. 

9 MR. RIEGLE: I am Leslie Riegle, Director of 

10 Environmental Policy at the Aerospace Industries 

11 Association. Thank you for the opportunity to testify 

12 on EPA's proposed endangerment finding and advance 

13 notice of proposed rulemaking on aircraft greenhouse 

14 gas emissions. 

15 AIA is the largest aerospace trade association 

16 representing the nation's major aerospace and defense 

17 manufacturers. We represent more than 300 U.S. 

18 manufacturing companies, with nearly one million 

19 skilled employees. Our members are recognized across 

20 the globe for manufacturing reliable, uncompromisingly 

21 safe aircraft that connect passengers and cargo and 

22 help defend our national security. Our industry is 
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1 heavily regulated and must pass grueling safety and 

2 airworthiness criteria on any new aircraft or changes 

3 to existing aircraft. We never compromise on safety. 

4 Aviation is a global industry and works under the 

5 United Nations International Civil Aviation 

6 Organization, ICAO, which has been setting global 

7 aviation standards for environment and safety for over 

8 50 years. This globally harmonized model has worked 

9 well for the United States. The U.S. aviation industry 

10 has thrived on this global playing field, as evidenced 

11 by the positive impact that we play on our national 

12 trade balance. And we hope to continue to build on 

13 this model as we develop new fuel efficiency standards 

14 for aircraft. 

15 The commercial aviation industry has a strong 

16 environmental track record, including study technology 

17 improvements and reducing aircraft carbon dioxide 

18 emissions over time. Today's commercial aircraft are 

19 70 percent more fuel efficient than aircraft flying 50 

20 years ago. 

21 Greater fuel efficiency translates into reductions 

22 in aircraft fuel consumption and CO2 emissions. The 

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1 commercial aviation industry has achieved greater fuel 

2 efficiency and lower emissions, even as it has grown. 

3 Today, more than 3 percent of gross domestic 

4 product is supported by aviation. Yet, only 2 percent 

5 of global CO2 emissions are attributable to aviation. 

6 It is for this reason that the commercial aviation 

7 industry is committed to building upon its strong 

8 environmental track record. 

9 The industry understands that climate change is a 

10 serious global environmental challenge, requiring 

11 credible action. In 2008, the industry agreed to a set 

12 of environmental targets to combat carbon emissions. 

13 They include improving fuel efficiency by an average of 

14 1.5 percent per year from 2009 to 2020, stabilizing 

15 emissions from 2020 with carbon-neutral growth and 

16 reducing net carbon emissions from aviation by 50 

17 percent by 2050, compared to 2005 levels. The industry 

18 will meet these goals through improved aircraft fuel 

19 efficiency, such as the introduction of new aircraft 

20 models with the latest fuel-saving technologies and 

21 advance propulsion systems; operational efficiencies; 

22 air traffic management system modernization and 

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1 improvements, such as NextGen; and greater use of 

2 sustainable aviation biofuels. 

3 In addition, our industry by way of competition 

4 and regulation must make certain that in achieving our 

5 CO2 reduction goals, we address other environmental 

6 considerations, such as particulate matter and NOx as 

7 well as noise. ICAO is the only international body in 

8 which aviation-specific technological feasibility, 

9 economic viability, and environmental benefit can be 

10 evaluated together in shaping policy. It takes a 

11 comprehensive approach to respond to the environmental 

12 challenges facing the commercial aviation industry, 

13 including aircraft CO2 emissions standards. These 

14 interdependencies are critical to consider when any new 

15 regulation is proposed and incorporated into domestic 

16 law. 

17 The U.S. has agreed as one of the 190 parties to 

18 the Chicago convention that ICAO has the authority to 

19 establish environmental standards for aircraft. EPA's 

20 practice has been to adopt ICAO's standards as its own 

21 for new commercial aircraft engines. 

22 The Federal Aviation Administration with support 

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1 from the EPA and other federal agencies has followed a 

2 similar approach in setting aircraft noise standards. 

3 We see no reason for the EPA to deviate from this well4 established practice in addressing aircraft CO2 

5 emissions standards. 

6 The Committee on Aviation Environmental 

7 Protection, CAEP, is expected to adopt a final aircraft 

8 CO2 emissions standard in February 2016 with full 

9 ratification by the ICAO assembly in September of 2016. 

10 This recommendation will be a result of years of data 

11 input, analyses, and careful consideration. Our 

12 members, along with aviation colleagues, government 

13 officials, and NGOs have been working at ICAO on a CO2 

14 standard for civil aircraft for over six years to 

15 ensure that this is done in the most educated and 

16 effective manner. As it has in the past, EPA should 

17 follow this well-established path and adopt the ICAO 

18 standards into U.S. domestic law under section 231. 

19 Doing so will ensure that the U.S. aircraft and engine 

20 manufacturers are not placed at a competitive 

21 disadvantage vis-a-vis international competitors. 

22 Moreover, it will avoid the attendant disruptions to 
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1 air travel from the U.S. having to enforce an aircraft 

2 CO2 emission standard that is different from that 

3 adopted by other countries. 

4 Again, on behalf of AIA and its members, I thank 

5 you for the opportunity to testify today. AIA will 

6 also be submitting comments to the docket relating to 

7 this rulemaking. 

8 MR. SARACENO: Good afternoon. Thank you so much 

9 for having this important hearing. My name is Michael 

10 Saraceno. I am a citizen. 

11 While greenhouse gas emissions from aviation may 

12 be only 2 to 2.5 percent, the global aviation CO2 

13 emission almost equals the amount of CO2 put out by the 

14 Country of Germany. 

15 Others have talked about how CO2 is trapped in the 

16 atmosphere and causing warming of the Earth. So I will 

17 leave more of that to them. But the fact is that the 

18 more CO2 that is put into the atmosphere, that results 

19 in more combustion. And I think one of the biggest 

20 concerns with more combustion from aviation in the sure 

21 increase in aviation, the FAA forecasts that aviation 

22 will grow 2 percent per year, reaching a billion 

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1 passengers by 2029. And the issue with more combustion 

2 not only is more CO2, but the FAA Modernization Act 

3 that was recently passed, in 2012, essentially is 

4 allowing the FAA through precision-based navigation to 

5 save. Yes, they do save fuel on descent because they 

6 are not doing step-down. But what they are not telling 

7 you is the FAA is allowing the airlines to crop dust 

8 U.S.A. Okay? 

9 And the reason why, how they are doing this is 

10 through NextGen or precision-based navigation, they are 

11 allowing the airlines to pack in more planes in title 

12 formation at much lower altitudes. And we know from 

13 NASA that aircraft operations below 3,000 feet 

14 decreased ground-level air quality. Okay? And that is 

15 NASA saying that. And I am submitting my testimony 

16 into the docket as well with all of the references so 

17 you can feel free to look them up yourself. 

18 So we have all around this country the FAA 

19 allowing -- right? They changed the highways in the 

20 sky across the U.S.A. And they have not found one 

21 environmental impact. That is it. You can change the 

22 highway over the entire continental U.S. And there is 

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1 not one environmental impact that that will impose on 

2 anyone or any person. That is absolutely ridiculous. 

3 But the most important issue, the reason why this 

4 needs to be investigated further, is that the more 

5 combustion that we have, the more landings and takeoffs 

6 year over year, impacts the people who live downwind 

7 from airports across the United States. 

8 Now, what is the difference, right, from living 

9 downwind from a highway from living downwind to the 

10 airport? Certainly both of those situations will give 

11 you downwind pollution. And the difference is that 

12 highways have noise barriers or pollution barriers. 

13 And NOAA has done studies on this, that those sound 

14 barriers with vegetation prevent highway pollution from 

15 floating downwind into communities. Okay? Where are 

16 the barriers to downwind pollution from aviation? And 

17 most of that is through approaches. 

18 I have listed several studies that have done, 

19 London Heathrow, LaGuardia, a bunch of different 

20 studies that have shown, that, in fact, airport 

21 particulates can reach as far as 5 to 6, in some cases 

22 10 nautical miles downwind from an airport. Okay? 

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1 And so the biggest issue with that is that we know 

2 that vaccines do not cause autism. Okay? The largest 

3 organization in February 2012 came out and said that 

4 vaccines do not cause autism. And why did they say 

5 that? Because every scientific journal that was 

6 published on that refuted that. And, in fact, it 

7 proved the opposite of that. 

8 We now have 12 peer-reviewed studies. And I have 

9 cited in my references that there is an increased risk 

10 of autism associated with increased air pollution 

11 around conception and/or pregnancy. 

12 The vast majority -- and I talked to Harvard 

13 scientists through personal communication -- is not 

14 genetic. It is environmentally induced pollution. And 

15 environmental induced pollution is what is causing 

16 autism. And we will see a spike in autism across the 

17 U.S.A. And I don't care. They can change a diagnosis 

18 or hide the incidence. But the fact of the matter is 

19 more children are receiving services today than they 

20 were. And they will continue to receive more services 

21 over the next 10 years. 

22 There is a heavy metal load in autism. We know 
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1 that. That is why vaccines were pointed at. The heavy 

2 load, heavy metal load, in air pollution can, in fact, 

3 deposit in the hair and nails of these children. And, 

4 in fact, when they do look back and the hair and nails 

5 of these children, they find that the heavy metal 

6 deposition in the hair and nails is significantly 

7 higher than typically developing children. So we know 

8 they are being exposed to toxic metals. And that is 

9 from environmental pollution. 

10 UC-Davis 2012 just came out with a new study that 

11 said the 2015 cost of autism-related expenses is $268 

12 billion and by the year 2025, it could be anywhere 

13 between $500 to $1 trillion in related costs. 

14 We know that aviation admissions have trace heavy 

15 metals. The byproduct is a NOx. It is sulfur. The 

16 aviation jet fuel contains 100 times more sulfur than 

17 diesel trucks. 

18 And we can talk about autism, but also high air 

19 pollution areas also decrease IQ of children. The very 

20 interesting thing about that is that, even when these 

21 children hit six, seven years old, they still did not 

22 catch up to their peers. So this damage that is being 

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1 caused by low IQ, by pollution-induced -- and it does 

2 have an effect on one of the most important things that 

3 I will tell you. 

4 If you want to know how dangerous air pollution 

5 is, you just have to look at the transgenerational 

6 epigenetic changes. So there was a study done that I 

7 have in the reference by -- let's see where; where is 

8 it? -- by Tracy in 2013. And so what they did is they 

9 exposed mice to jet fuel. And what they found is that 

10 it didn't change the gene, but it changed the way the 

11 gene was expressed. And that change in the way the 

12 gene is expressed got into the genome and was passed on 

13 to subsequent generations. Okay? 

14 And so this is why I care: because my nieces and 

15 nephews, my children could potentially marry somebody 

16 else's kids who are in a heavily polluted environment. 

17 And that change in the genome gets into the gene pool. 

18 So your grandchildren and great-grandchildren could, in 

19 fact, develop transgenerational epigenetic changes 

20 through environmental pollution. 

21 Another way besides greenhouse gases -- and I will 

22 keep this brief -- there is evidence to show that 

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1 persistent contrails do, in fact, warm the Earth. They 

2 trap incoming solar radiation, and they block outgoing 

3 infrared radiation. 

4 And so there were studies done by NASA. And what 

5 they found is that after the 9/11 attacks, there was a 

6 1 degree Celsius spike between the maximum highs and 

7 the maximum lows in terms of temperature. So they 

8 looked at skies without contrails after 9/11 because 

9 the planes were grounded for 3 days, and they found a 

10 spike in the temperature range. So, in fact, contrails 

11 do change the climate. 

12 And I will just end with another NASA scientist 

13 also talked about contrails. And he is using data from 

14 I think the 1990s to 2000s, early 2000s. So this is 

15 old data. But what he says is that increase in surface 

16 and lower atmospheres' temperatures by .36 or .54 

17 degrees Fahrenheit per decade. So that is what he is 

18 saying the contribution of the contrails could be to 

19 warming, .36 to .54 percent Fahrenheit per decade. And 

20 I think that proves that contrails do, in fact, affect 

21 temperature. 

22 The other thing you should know about contrails, 

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1 persistent contrails, is we have more combustion, more 

2 jet aircraft, more airplanes, you are going to get more 

3 contrails and you are going to get more warming. So it 

4 is this whole vicious cycle. 

5 The thing about contrails is that they produce 

6 clouds that morph into cirrus. Okay? When they study 

7 contrail spreading, they only study within the first 

8 few hours. They do not study the whole life of that 

9 artificial cloud that is produced. And that artificial 

10 cloud that is produced would not have formed if there 

11 would not have been a contrail in that area. So these 

12 clouds that are being induced are producing clouds that 

13 would not naturally be there. That changes the 

14 hydrological cycle, which is rain. 

15 The other thing that you should know is that 

16 these, the way it could change the rain is that when 

17 the engine at high altitude freezes the ice crystals in 

18 the atmosphere, it is actually changing the vapor 

19 content in the atmosphere. Okay? So that vapor 

20 content will have a change on regional climate change. 

21 And I thank you very much for having this open 

22 hearing. 
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1 MR. WOLF: My name is Doug Wolf. I am 

2 representing the Center for Biological Diversity. 

3 Thank you for convening this hearing and for soliciting 

4 further public input concerning agency's crucial effort 

5 to promulgate greenhouse gas emissions standards for 

6 aircraft. The Center for Biological Diversity 

7 appreciates the opportunity to comment. 

8 The Center for Biological Diversity is a nonprofit 

9 organization with more than 800,000 members and online 

10 activists. The center's Climate Law Institute seeks to 

11 reduce U.S. greenhouse gas emissions and other air 

12 pollution to protect biological diversity, the 

13 environment, and human health and welfare. Specific 

14 objectives include securing protections for species 

15 threatened by global warming, ensuring compliance with 

16 applicable laws to reduce greenhouse gas emissions and 

17 other air pollution, and educating and mobilizing the 

18 public on global warming and air quality issues. 

19 Climate change is already upon us with 

20 unprecedented temperature increases, rising sea levels, 

21 extraordinary rates of species extinction, and more 

22 extreme weather events. Efforts to quickly and sharply 

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1 curb and then eliminate carbon pollution are essential 

2 if we are to avoid the worst effects of climate change. 

3 Science tells us that this requires the U.S. to 

4 reduce emissions in the range of 35 to 65 percent by 

5 2030 from 1990 baseline levels. To begin to approach 

6 those levels, every significant carbon emissions source 

7 must reduce its emissions. And the aircraft industry 

8 has too long evaded every attempt to make it contribute 

9 its fair share. In fact, if global aircraft CO2 

10 emissions were compared to those of countries, they 

11 would rank seventh, just behind Germany, outranking 

12 about 150 other countries in the world. 

13 Aviation emissions are growing rapidly and could 

14 triple within just a few decades. Unless EPA puts in 

15 place stringent standards to reduce greenhouse gas 

16 emissions, increased aviation traffic will cause the 

17 sector to become one of the fastest growing sources of 

18 harmful emissions. 

19 And within the global community, the United States 

20 is by far the largest emitter of aircraft carbon 

21 pollution with its domestic and international flights 

22 contributing 29 percent of the total, dumping that 

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1 amount into the global skies absolutely unchecked. In 

2 other words, U.S. aviation emissions harmed the global 

3 community in a hugely disproportionate fashion. 

4 The U.S. must reverse the situation and cut 

5 emissions quickly and steeply and must reject the 

6 patently insufficient measures proposed by the 

7 International Civil Aviation Organization, or ICAO. 

8 We fully agree with EPA's finding that aircraft 

9 carbon emissions endanger human health and welfare. We 

10 believe, however, that this proposed finding was much 

11 too late in coming. And we urge the agency to make up 

12 for lost time by finalizing it forthwith and no later 

13 than November 2015, 3 months after the close of the 

14 current comment period. 

15 We also urge EPA to follow up its ANPR with 

16 proposed standards at the same time it finalizes its 

17 endangerment finding. There is no reason to wait the 

18 outcome of negotiations at ICAO as even the most 

19 stringent measures under consideration there would 

20 hardly make a dent in the problem. In fact, under the 

21 likely outcome of the international negotiations, in 

22 2030, only 5 percent of the global aircraft fleet would 

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1 even be regulated and this by a standard based on 

2 technology in existence in 2016, or some 14 years 

3 behind 2030 technology. 

4 Moreover, the ICAO proposal set no cap on 

5 emissions. In other words, ICAO's proposals do next to 

6 nothing to effect business as usual, an outcome utterly 

7 incompatible with EPA's duties under the Clean Air Act, 

8 the President's climate action plan, and the demands of 

9 climate science. EPA should seize the opportunity to 

10 issue proposed emissions standards in time to make a 

11 difference at the Paris climate negotiations in 

12 December of this year. 

13 We are pleased to see EPA's acknowledgement that 

14 the Clean Air Act authorizes it to regulate not just 

15 aircraft engines but the entire aircraft. We add that 

16 the act's delegation of authority to EPA under section 

17 231 is extraordinarily broad and that EPA has 

18 explicitly authorized a set of emissions standards for 

19 all classes of aircraft. 

20 Moreover, as EPA recognized in its 2008 ANPR, 

21 EPA's regulations can encompass aircraft operations and 

22 air traffic management. 
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1 Finally, the standards EPA settles on should be 

2 technology-forcing, not following. 

3 With these premises in mind, EPA should set 

4 emissions standards, not just for new types of aircraft 

5 but also for all aircraft currently in production and 

6 in service, should base them on currently existing as 

7 well as under-development technology, and should 

8 include operational and air traffic management 

9 requirements that reduce emissions. Aircraft failing 

10 to retrofit to meet achievable standards should be 

11 phased out. 

12 We urge EPA to craft these standards by employing 

13 an approach similar to standards for vehicles, setting 

14 fleet-wide averages for new and in-service aircraft. 

15 These standards should be sufficiently stringent not 

16 only to hold total emissions at a set gap but to 

17 actually reduce them for the entire U.S. aviation 

18 sector within the coming decade. 

19 The center will be submitting written comments at 

20 the close of the comment period but working with other 

21 organizations. We thank you for this opportunity to be 

22 heard. 

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1 MR. GUNNING: Thank you very much. Thank you for 

2 all speakers, appreciate your comments and thoughts. 

3 I will now move to the next group of speakers. 

4 After I call your name, please come up to the table. 

5 We have Kathy Kinsey from the Northeast States for 

6 Coordinated Air Use Management; Sue Valdez, a member of 

7 the public; and Andres Restrepo from the Sierra Club. 

8 Thank you. Kathy, go ahead, please. 

9 MS. KINSEY: Thank you. 

10 Good morning. My name is Kathy Kinsey. I am a 

11 senior policy advisor with the Northeast States for 

12 Coordinated Air Use Management. I would like to thank 

13 you today for the opportunity to be here to testify on 

14 EPA's proposed endangerment finding and on the advance 

15 notice of proposed rulemaking. 

16 NESCAUM is an organization of eight states: the 

17 six Northeast states and New York and New Jersey. And 

18 my testimony today here reflects the majority view of 

19 our states and does not necessarily reflect the views 

20 of all of our individual state members. 

21 So NESCAUM supports EPA's proposed finding under 

22 the Clean Air Act section 231 that aircraft greenhouse 

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1 gas emissions endanger public health and welfare. This 

2 support is consistent with the support, our support, in 

3 2009 for EPA's proposed endangerment finding for mobile 

4 sources. Since the 2009 rulemaking, climate science 

5 has only grown stronger. The latest science, as 

6 summarized in the 2014 International Panel on Climate 

7 Change, establishes that climate-related threats are 

8 already affecting our states, our nation, and the 

9 world. 

10 NESCAUM also supports EPA's determination that 

11 aircraft emissions from certain classes of aircraft are 

12 contributing to the mix of greenhouse gases that are 

13 subject to this rulemaking. 

14 We support the development and adoption of 

15 aircraft greenhouse gas standards for U.S. aircraft. 

16 In this regard, we support a whole aircraft approach to 

17 adopting standards that does not focus solely on the 

18 engine. Whole aircraft approach recognizes that 

19 emissions are influenced by aircraft weight, 

20 aerodynamics, and the engine-specific fuel consumption. 

21 We urge EPA to adopt greenhouse gas standards for 

22 new aircraft and in-production aircraft, that that 

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1 approach will begin to materially reduce greenhouse gas 

2 emissions in the next 5 to 10 years from the projected 

3 business-as-usual levels, to be based on a reference 

4 scenario that reflects current aircraft performance. A 

5 reference scenario that is based on outdated aircraft 

6 performance will only lead to inflated estimates of 

7 greenhouse gas emission reductions from current 

8 reductions. 

9 And, finally, NESCAUM urges EPA to take the 

10 opportunity with this rulemaking to revise the current 

11 aircraft NOx emissions standards. Given the continuing 

12 ozone nonattainment problems in our region, the 

13 Northeast region, and the nation as a whole and the 

14 fact that under its current process, ICAO is unlikely 

15 to adopt new aircraft NOx standards prior to 2022, if 

16 then, EPA should take the opportunity to act now and 

17 establish a production cutoff date of December 31st, 

18 2018 for the United States, after which tier 8 NOx 

19 standards will apply to newly manufactured aircraft in 

20 lieu of the tier 6 standards. 

21 NESCAUM intends to submit more detailed written 

22 comments before the close of the record. And, again, 
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1 we thank you very much for the opportunity to be here 

2 today. 

3 MR. RESTREPO: Thank you. My name is Andres 

4 Restrepo, and I am an associate attorney with Sierra 

5 Club's environmental law program. 

6 Sierra Club was founded in 1892 and stands today 

7 as one of the largest and most active grass-roots 

8 environmental organizations in the United States. With 

9 over 2.4 million members and supporters as well as 64 

10 affiliated chapters nationwide, the club works to 

11 secure a cleaner, healthier, and more sustainable 

12 environment for today's world and for future 

13 generations alike. 

14 One of the club's most urgent goals is working to 

15 curb the effects of climate change. And we strongly 

16 advocate for steep and immediate cuts to greenhouse gas 

17 emissions from all sectors of the economy. Unless 

18 governments act now, we will be unable to avoid the 

19 worst impacts of climate change, which include rising 

20 sea levels, more extreme temperatures and weather 

21 events, mass displacement of people, more severe 

22 droughts and floods, enhanced formation of harmful air 

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1 pollution, and widespread extinctions of plant and 

2 animal species. 

3 The Sierra Club strongly supports federal 

4 greenhouse gas regulations for aircraft to help 

5 mitigate the harms posed by climate change. For far 

6 too long, U.S. aircraft have been emitting unlimited 

7 amounts of these pollutants into the atmosphere. 

8 Domestic and international U.S. flights now contribute 

9 nearly 30 percent of the world's CO2 emissions from 

10 aircraft, far more than any other country. In fact, 

11 U.S. aircrafts emit more greenhouse gases than the 

12 entire economies of all but 8 countries, with none with 

13 a population below 80 million. Furthermore, these 

14 emissions will increase by as 50 percent over the next 

15 2 decades unless mandatory restraints are imposed. 

16 EPA's finding that greenhouse gas emissions from 

17 aircraft endanger public health and welfare is, 

18 therefore, entirely sound. The effects of climate 

19 change as well as the climate-disrupting effect of 

20 greenhouse gas emissions are so well-documented that 

21 they require no additional discussion here. Under 

22 section 231 of the Clean Air Act, an endangerment 

Page 72

1 finding triggers the agency's obligation to issue 

2 binding aircraft regulations. 

3 Given the size and scope of this problem, EPA must 

4 not delay the regulatory process in any way. In 

5 particular, the agency must forge ahead with these 

6 regulations without awaiting the greenhouse gas 

7 standards forthcoming from the International Civil 

8 Aviation Organization, or ICAO. 

9 The most stringent proposal currently under 

10 consideration by that body would cover only 5 percent 

11 of global aircraft, would rely on 2016 technology for 

12 aircraft built in 2030, and would not impose a total 

13 cap on emissions from the global fleet. Accordingly, 

14 even under a best-case scenario, the ICAO standards 

15 will do little, if anything, to curb the intensifying 

16 problem of aircraft emissions. The United States must 

17 exhibit leadership on this issue. And EPA should move 

18 forward with strong effective standards under section 

19 231. 

20 To that end, EPA must adhere to several 

21 principles. First, the agency must cover all aircraft 

22 under any final standard. This requires regulation not 

Page 73

1 only of new designs and/or newly constructed aircraft 

2 but of aircraft currently in use as well. EPA is 

3 certainly correct to assert the authority to regulate 

4 emissions from entire aircraft, rather than simply from 

5 emissions or from engines, and may address all 

6 categories of aircraft in its regulations. 

7 Notably, section 231's broad mandate does not 

8 constrain the agency's authority to regulate existing 

9 aircraft in any way. And EPA must take advantage of 

10 this aspect of the statute if it expects to achieve 

11 meaningful reductions from the U.S. fleet. 

12 Second, in keeping with the spirit and purpose of 

13 the Clean Air Act but in marked contrast to ICAO's 

14 efforts, EPA standards must be technology-forcing, 

15 rather than technology-following. 

16 The language of the statute makes clear that 

17 Congress intended for section 231 standards not merely 

18 to reflect what aircraft are capable of achieving at a 

19 given point in time but to enhance those capabilities 

20 above what they would have been otherwise. Hence, 

21 section 231 provides that regulations shall take effect 

22 on a timeframe that would permit the development and 
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1 application of the requisite technology. EPA must, 

2 therefore, base its forthcoming standards not only on 

3 existing technology but on in-development technology as 

4 well. 

5 Next, EPA should consider a fleet-wide averaging 

6 program, also permitted under section 231. A 

7 regulation of this nature would allow the agency to 

8 achieve the greatest emission reductions at the lowest 

9 cost. 

10 The agency should also address operational and air 

11 traffic management practices in its final rule, which 

12 could provide emission reduction opportunities at very 

13 low cost. 

14 Finally, EPA must require any aircraft that cannot 

15 be designed to meet the requisite final standard or 

16 cannot be retrofitted to achieve it to phase out and 

17 ultimately retire. It is critical that EPA prohibit 

18 old and outdated aircraft from continuing to pollute 

19 our skies and contribute to climate change while 

20 better, more efficient designs are readily available. 

21 Sierra Club appreciates EPA's efforts to move 

22 forward with the greenhouse gas regulations for 

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1 aircraft. And we urge the agency to promulgate a 

2 standard that is strong, effective, and technology3 forcing. While EPA must take the time necessary to 

4 develop an appropriate and well-considered final rule, 

5 time is particularly of the essence. 

6 In December, President Obama and administration 

7 officials will travel to Paris to negotiate an 

8 international climate accord with leaders from around 

9 the world. The stronger our commitments to reduce 

10 greenhouse gases domestically, the more effective our 

11 negotiating position will be vis-a-vis other countries. 

12 We, therefore, strongly encourage EPA to move swiftly 

13 ahead with these regulations to help achieve the best 

14 possible outcome this fall in Paris. 

15 I thank you for the opportunity to speak on this 

16 issue and look forward to submitting comments on behalf 

17 of Sierra Club on the agency's proposal in the near 

18 future. Thank you. 

19 MR. GUNNING: Thank you both for your comments and 

20 thoughts. 

21 Before I turn to Bill to introduce the next group, 

22 I want to make one last call. Is Sue Valdez here? No. 

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1 Okay. Thank you both. 

2 MR. CHARMLEY: Thank you. We are now going to 

3 move on to group number 5. So could we please hear 

4 from Kate DeAngelis, Amanda Baise, and David Baake. 

5 Thank you. 

6 MS. DeANGELIS: Thank you for the opportunity to 

7 testify on this important issue. My name is Kate 

8 DeAngelis, and I am a climate and energy campaigner at 

9 Friends of the Earth. 

10 Research has shown that we must keep 80 percent of 

11 the world's fossil fuel reserves in the ground to have 

12 a good chance of avoiding the worst impacts of climate 

13 disruption. As the world's largest historical emitter, 

14 the United States must shoulder the greatest share of 

15 the burden for making emission reductions. In order to 

16 achieve the necessary emission reductions to avert 

17 catastrophic climate disruption, the United States must 

18 take significant strides to reduce carbon pollution 

19 from every sector of the economy, including aircraft. 

20 The EPA has already taken action to reduce 

21 emissions from cars, trucks, and power plants. Now the 

22 EPA needs to show the same leadership and limit 

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1 aircraft carbon dioxide emissions. 

2 Globally, airline operations produced 705 million 

3 metric tons of carbon dioxide in 2013. To put that in 

4 perspective, the global aviation emissions industry 

5 would rank seventh if included in country emissions 

6 rankings, just after Germany's total country emissions. 

7 This sector is too big to leave unregulated. So the 

8 EPA must take immediate action to reduce carbon 

9 pollution from aviation. 

10 Greenhouse gas emissions from aircraft are 

11 currently responsible for more than 3 percent of the 

12 total United States emissions. While this may not seem 

13 significant, emissions from the aviation sector, one of 

14 the fastest growing sources of greenhouse gases in the 

15 world, they are also the largest emissions source that 

16 is unregulated in the United States. Without 

17 regulation to limit the emissions, carbon pollution 

18 from this sector is expected to triple by 2050. 

19 Regulation is especially important because of the 

20 potentially disproportionate climate impact of high21 altitude aircraft emissions. When emissions are higher 

22 in the atmosphere, they can have greater warming impact 
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1 than at ground level. 

2 The United States must take the lead in reducing 

3 emissions from our aircraft since we account for a 

4 large proportion of the world's aviation emissions. 

5 The United States' domestic flights account for 24 

6 percent of the world's commercial aircraft carbon 

7 dioxide emissions and 35 percent of carbon dioxide 

8 emissions from international commercial flights. 

9 When the EPA first began analyzing measures to 

10 reduce carbon dioxide from aviation in 2008, it 

11 estimated greenhouse gas reductions available from 

12 engine and air frame changes alone at 13.3 percent. 

13 Despite this, research shows that from 2012 to 2013, 

14 United States airlines overall did not make any net 

15 fuel efficiency gains. Yet, there are plenty of 

16 improvements that could be made, as evidenced by the 

17 fact that there is a gap of 27 percent from the most to 

18 least fuel-efficient domestic airline. This 

19 demonstrates that the industry is already implementing 

20 retrofits that are effectively reducing carbon dioxide 

21 emissions. EPA regulations would force all airlines to 

22 adopt similar measures. 

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1 The EPA has the legal authority under section 231 

2 of the Clean Air Act to address emissions from 

3 aircraft. This authority to act is broad. The Clean 

4 Air Act requires that EPA put forward emissions 

5 standards for pollution from any class or classes of 

6 aircraft engines that it determines may endanger public 

7 health. The only substantive restriction that the law 

8 places on this authority is that any rules cannot 

9 significantly increase noise or hinder safety. The EPA 

10 first set pollution standards for future and existing 

11 engines in 1973. But these standards did not address 

12 carbon pollution. 

13 At the time these standards were introduced, the 

14 understanding of the impacts and urgency of climate 

15 change was minimal. Since then, the scientific 

16 evidence for the need to address this pollution has 

17 become irrefutable. The EPA must take this opportunity 

18 to put forward new rules that reflect the need to take 

19 fast and meaningful action to reduce our global 

20 warming-inducing emissions. 

21 The United States cannot wait for the 

22 International Civil Aviation Organization to take 

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1 action. So far ICAO has only succeeded in delaying 

2 action, has failed to set any climate policies. ICAO 

3 was finally expected to put forward some standards in 

4 early 2016, but they are likely to be incredibly weak 

5 and insufficient; in part, because they will not apply 

6 to end-use aircraft. The EPA has the legal authority 

7 and the emission reduction potential exists to make far 

8 greater reductions than ICAO is expected to mandate. 

9 The EPA should adopt its proposed finding that 

10 aircraft emissions endanger public health within no 

11 more than three months of the comment period. 

12 In addition, EPA must adopt regulations that are 

13 broad in scope. Rather than focusing only on new 

14 aircraft engines, any rules that EPA puts forward 

15 should include existing aircraft and not limit coverage 

16 to just engines but the entire aircraft. EPA should 

17 use its authority to set emissions standards for all 

18 classes of craft in a way that is technology-forcing, 

19 to ensure the greatest emissions reductions possible. 

20 EP should follow the example it has set for 

21 passenger and medium/heavy-duty vehicles and establish 

22 fleet-wide averages for new and existing aircraft, 

Page 81

1 including those in service. These standards must be 

2 sufficiently stringent to significantly reduce them for 

3 the entire United States aviation sector over time. 

4 Furthermore, the EPA should work with the Federal 

5 Aviation Administration to develop complementary 

6 standards to promote the use of low-carbon jet fuels. 

7 Thank you for taking the time to consider my 

8 comments. 

9 MS. BAISE: Good morning. My name is Amanda 

10 Baise, and I live in Virginia Beach, Virginia. Thank 

11 you for giving me this opportunity to speak to you 

12 today. 

13 For the past five years, I have documented 

14 aircraft emitting trails across the sky. I have taken 

15 hundreds of videos and thousands of photographs of 

16 these persisting emissions. Many of the aircraft I 

17 have witnessed appear to be spraying something into the 

18 atmosphere. 

19 Uneasy with my observations, I wanted to know 

20 exactly what was causing the aircraft to leave visible 

21 trails that did not dissipate. I reached out to local, 

22 state, and federal government agencies for information 
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1 and assistance. What I experienced was disillusioning, 

2 to say the least. When I called the EPA, I was told 

3 that the FAA handled aircraft emissions. When I called 

4 the FAA, they told me to call the EPA. I was shuttled 

5 from office to office with no agency ever accepting 

6 responsibility or accountability. My calls were not 

7 returned. Nor were my concerns ever addressed. 

8 The sage advice I finally received from the EPA 

9 was to hire a plane and do my own testing. This was 

10 especially disheartening since I had been led to 

11 believe that the Environmental Protection Agency was 

12 the ultimate protector of the environment. 

13 Additionally, the EPA advised me to contact the 

14 Department of Environmental Quality for the State of 

15 Virginia. Not surprisingly, the DEQ informed me that 

16 they do not regulate mobile sources of emissions, don't 

17 go to airports, and don't check what is being loaded on 

18 planes. 

19 As for my request for my yard to be tested for 

20 heavy metal, chemical, or biological contamination, I 

21 was told that the Virginia DEQ could not use state 

22 money to test for those materials. Furthermore, my 

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1 complaint was in an area that they had no authority to 

2 investigate, another dead end. 

3 I reported Naval Air Station Oceana military jets 

4 for dumping fuel over my neighborhood and spoke with at 

5 least 30 individuals at the base. I finally spoke with 

6 Terry Chamberlain, head of the Environmental Office at 

7 Oceana. Mr. Chamberlain bluntly informed me that the 

8 military regulates itself. Needless to say, they 

9 continue to dump unburned fuel over the residents 

10 living close to the base. 

11 For several years, I electronically reported on 

12 airplane pollution using the environmental violations 

13 form on EPA's website, epa.gov/tips. It was referred 

14 to me by an ASRC federal contractor working for the 

15 EPA. I have always included my contact information on 

16 the tip report and identified specific aircraft that 

17 can easily be traced. No one from the EPA has 

18 investigated any of my formally filed complaints. 

19 Since I became interested in the possible dangers 

20 of chemicals spraying in the environment, I have 

21 contacted the Virginia Pollution Control Board; 

22 National Weather Service; Oceana and Dam Neck military 

Page 84

1 bases; NOAA; NASA; the Department of Defense; 

2 Brookhaven National Laboratory; the Department of 

3 Energy; the Department of Homeland Security; FEMA; the 

4 Health Department; the Department of Travel, countless 

5 federal agents and operators; the Virginia Beach Police 

6 Department; and even the White House, all to no avail. 

7 To date, no one from any agency has investigated my 

8 complaints. I was told to talk to my local 

9 representatives. 

10 Every agency I contacted responded to my 

11 reports by telling me that I was seeing condensation 

12 from engine exhaust. Aircraft engines do emit water 

13 vapor, of course, but vapor that quickly dissipates. 

14 What I was witnessing was persistent and long-lasting. 

15 How can anyone reasonably conclude that a particular 

16 aircraft emission is merely a contrail without testing 

17 it? That is both unscientific and irresponsible. 

18 Chemtrails, as opposed to contrails, is the term 

19 used to describe persistent aircraft emissions. There 

20 is a rising international concern about the existence 

21 of airborne chemical spraying, bolstered by a growing 

22 body of scientific evidence. 

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1 What is in the air that we are breathing? One 

2 chemtrail activist from California decided to have his 

3 hair tested for heavy metals at his own expense. High 

4 levels of strontium and barium were uncovered. I have 

5 a copy of his lab results that he voluntarily sent to 

6 me. I will post this document on my Facebook page, 

7 Madisonstar Moon, following this hearing. 

8 Did this contamination come from chemical 

9 spraying? How can we know if local, state, and federal 

10 agencies refused to take ownership of the issue to 

11 provide testing and useable data and ultimately 

12 regulate when required? 

13 The whole burden of investigation cannot rest with 

14 the EPA. It must be shared with other agencies and 

15 Congress. However, there must be clear lines of 

16 authority so that the public is fully informed and 

17 protected. 

18 The stated purpose of this hearing is to consider 

19 the full range of pollution generated by aircraft. The 

20 desire for investigation into chemical spraying has 

21 become a worldwide phenomenon. We are counting on you 

22 as the protectors of the environment to act. No more 
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1 runarounds for citizens deeply concerned about the 

2 health of the world and the individuals that inhabit 

3 it. 

4 Thank you. 

5 MR. BAAKE: Thank you for the opportunity to speak 

6 today. My name is David Baake. I am a fellow and 

7 attorney at the Natural Resources Defense Council. 

8 NRDC is a national nonprofit organization that 

9 works on all manner of environmental issues. And we 

10 represent 300,000 members nationwide. 

11 Eight days ago, Administrator McCarthy laid out a 

12 powerful case for acting on climate change. She said, 

13 "Climate change is one of the most important issues we 

14 face as a country and as citizens of the world. It 

15 affects everything we know and love: our kids, our 

16 communities, our ability to earn a decent living. It 

17 impacts our health, our safety, our livelihoods. One 

18 things is crystal clear. Acting on this challenge is a 

19 moral responsibility." 

20 Administrator McCarthy is right. The United 

21 States has a moral obligation to rein in dangerous 

22 climate change. EPA has already shown tremendous and 

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1 admirable leadership in going after emissions from 

2 cars, trucks, and now power plants. And we need to see 

3 the EPA exercise that same leadership when it comes to 

4 regulating aircraft. 

5 Airplanes are the largest unregulated source of 

6 greenhouse gas emissions in the United States 

7 transportation sector. They are responsible for 11 

8 percent of transportation sector emissions, 3 percent 

9 of total U.S. emissions, and 0.5 percent of total 

10 global emissions. These emissions are skyrocketing. 

11 We expect, EPA expects, nearly 50 percent increase 

12 between 2015 and 2035. 

13 In light of these facts, it is indisputable that 

14 aircraft emissions cause or contribute to the air 

15 pollution that may be reasonably anticipated to 

16 endanger public health or welfare within the meaning of 

17 section 231. And EPA should quickly adopt this 

18 proposed finding. Thereafter, EPA must take bold 

19 action to reduce these dangerous emissions. 

20 The United States under President Obama has 

21 pledged to reduce economy-wide emissions by between 26 

22 and 28 percent between 2005 and 2025. We must make 

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1 good on this commitment. It is our moral 

2 responsibility, as Administrator McCarthy reminded us. 

3 But, as the World Resources Institute has shown, 

4 we cannot do so without taking meaningful action to 

5 reduce aircraft emissions. And I include a citation in 

6 my written comments, but WRI has projected that we 

7 would need to reduce aircraft emissions by 2 percent to 

8 meet that target. 

9 Given the urgency of the climate crisis, EPA 

10 should propose standards that go far beyond the options 

11 currently being considered by ICAO. We would welcome 

12 meaningful international standards. And we encourage 

13 EPA to continue pushing ICAO toward greater stringency 

14 and, in particular, to encourage ICAO to adopt coverage 

15 of in-production aircraft, as others have urged the EPA 

16 to do today. 

17 Given that ICAO has already committed to adopting 

18 a technology-following standard and has already ruled 

19 out the possibility of regulating existing aircraft, it 

20 is clear the United States cannot deliver on our 

21 commitments if we simply rubberstamp the ICAO 

22 standards. EPA can and must do more. 

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1 Fortunately, the Clean Air Act provides EPA with 

2 clear authority to rein in aviation emissions. As EPA 

3 recognized in 2008 in its advance notice of proposed 

4 rulemaking on regulating greenhouse gases under the 

5 Clean Air Act, section 231 of the Clean Air Act 

6 authorizes a fleet-wide averaging system that applies 

7 to both new and existing aircraft. Drawing on this 

8 authority, EPA should propose a fleet-wide averaging 

9 system that is sufficiently stringent to stabilize U.S. 

10 aviation emissions by 2020, consistent with industry's 

11 commitment and reducing thereafter. 

12 We know that this can be done. In 2010, at the 

13 request of then Senator Kerry, EPA developed a scenario 

14 for stabilizing aircraft emissions at approximately 250 

15 million metric tons per year by improving fleet-wide 

16 efficiency by 2.2 percent between 2015 and 2030. EPA 

17 noted that airlines have historically improved their 

18 fuel efficiency by 2 to 3 percent per year and 

19 concluded that similar improvements would be achievable 

20 between 2015 and 2030. The agency cited improved 

21 operations and new aircraft technology, including gear 

22 turbofan engines, laminar flow technology, lighter 
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1 airframes, and blended wing body design as possible 

2 contributors to such a reduction. 

3 These operational technological improvements are 

4 clearly achievable as well as cost-effective. And we 

5 believe that EPA should use this 2010 study as a 

6 baseline in setting its proposed domestic standards. 

7 Finally, EPA should also consider the opportunity 

8 to retrofit existing aircraft. Industry leaders have 

9 already taken significant steps with cost-effective, 

10 safe retrofits. A key example here is winglets, which 

11 are wing attachments that reduce drag and improve 

12 efficiency by 3.5 to 4 percent per flight on trips over 

13 1,000 nautical miles. 

14 Alaska Airlines is an industry leader. And they 

15 have recently introduced -- I believe this is 

16 pronounced Scimitar winglets, S-c-i-m-i-t-a-r. It is a 

17 technical term. And they reduce emissions by an 

18 additional almost 2 percent per flight, which brings 

19 you up to about 6 percent total reduction. Since this 

20 technology is safe, technically feasible, and cost21 effective, EPA should propose to require it across the 

22 entire fleet. 

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1 EPA should also work with the FAA to develop 

2 complementary standards to promote the use of low3 carbon jet fuels, jet fuels that reduce lifecycle GHG 

4 emissions, compared to conventional fuels. 

5 Industry leaders are already using these fuels on 

6 a commercial scale. For example, Alaska Airlines has 

7 been using low-carbon biofuel on regularly scheduled 

8 flights since 2011. And United recently invested $30 

9 million in a project to convert household trash into 

10 jet fuel, which it expects to supply enough low-carbon 

11 fuel for 20,000 flights per year at a competitive cost. 

12 Building on this work of industry leaders, EPA should 

13 work with the FAA to develop an ambitious but 

14 achievable low-carbon fuel standard to complement its 

15 231 emissions standard. 

16 In conclusion, EPA should adopt its proposed 

17 endangerment finding as expeditiously as possible. The 

18 science here is indisputable. 

19 Next, EPA should continue pushing ICAO toward 

20 greater stringency, including coverage of in-production 

21 aircraft. However, it also prepare to propose 

22 standards that go far beyond the options the 

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1 organization is considering. Specifically, EPA should 

2 propose a fleet-wide averaging system that is 

3 sufficiently stringent to stabilize U.S. aviation 

4 emissions at 2005 levels by 2020 and reduce them 

5 significantly thereafter. EPA should consider retrofit 

6 options, including the possibility of requiring 

7 airlines to use winglets on their entire fleet. And 

8 EPA should work with the FAA to develop a low-carbon 

9 fuel standard. 

10 Thank you very much for the opportunity to be 

11 heard. 

12 MR. GUNNING: Thank you all for your thoughtful 

13 comments. I would now like to ask and invite up, I 

14 believe, our last two speakers, registered speakers, 

15 for today: Patrick Roddie and Max Bliss. Patrick and 

16 Max? 

17 MR. RODDIE: Good morning. 

18 MR. GUNNING: Good morning. Go ahead. 

19 MR. RODDIE: My name is Patrick Roddie. I am a 

20 San Francisco-based anti-geoengineering activist and 

21 researcher. And I run StopSprayingUs-SF.com. 

22 Today's hearing is supposed to address whether 

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1 greenhouse gas emissions from aircraft endanger public 

2 health, but when you mention greenhouse gas, most 

3 people think of carbon dioxide, a harmless trace gas 

4 essential to all life on Earth. 

5 But CO2 represents just 3 percent of the planet's 

6 greenhouse gas. Ninety-five percent of it is water. 

7 Even preschoolers know overcast skies make the nights 

8 warmer and the days cooler. Clouds insulate, trapping 

9 heat, and reduce the temperature range from the night's 

10 lows to the day's highs, which brings me to persistent 

11 contrails. 

12 All but the willfully ignorant know our skies have 

13 changed dramatically over the last few decades. The 

14 dark blue skies of our childhood have been replaced 

15 with a milky white haze, crisscrossed with fast 

16 expanding persistent contrails, stretching from horizon 

17 to horizon, and spreading out to cover the sky. These 

18 trails can stretch for thousands of miles and can be 

19 seen by anyone visiting NASA.gov. These trails 

20 persist, regardless of altitude, temperature, humidity, 

21 or other atmospheric conditions. Persistent contrails 

22 used to be rare but have now become an everyday 
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1 phenomenon all over the world. If physics hasn't 

2 changed, what has? 

3 So what makes these trails form, persist for 

4 hours, and stretch thousands of miles? Which 

5 condensation nuclei are they forming on? And are these 

6 harmful to human health? 

7 Geoengineers propose spraying tens of millions of 

8 tons of reflective particles into the atmosphere in an 

9 attempt to reflect sunlight back into space and, 

10 thereby, reduce global warming. This is known as solar 

11 radiation management, stratospheric aerosol injection, 

12 or albedo modification. This process, patented by 

13 defense contractor Raytheon, is quite simple. Tiny 

14 particles sprayed from jets would act as condensation 

15 nuclei, attracting atmospheric water vapor to form 

16 persistent artificially nucleated contrails, which 

17 would then spread out and form artificial cloud cover, 

18 artificial cirrus cloud cover. 

19 When geoengineers discuss solar radiation 

20 management in public, the only substances they say they 

21 would consider spraying are sulfates or sulfuric acid. 

22 However, their own literature concludes that sulfates 

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1 have limited effectiveness and that highly toxic nano 

2 particles of aluminum and barium should be used 

3 instead. And when confronted, they doggedly refuse to 

4 address the human health impacts of their proposals. 

5 Other geoengineers are more candid about their 

6 plans to poison the sky. Stanford's Ken Caldeira 

7 admitted in an interview in 2006 that he discussed 

8 putting pathogens in clouds to wage chemical and germ 

9 warfare on civilian populations when he worked at a 

10 government weapons lab. It is no surprise that the 

11 public doubts these scientists have their best 

12 interests at heart. 

13 Last month I brought this paper to the Paris 

14 Climate Conference addressing the human health impacts 

15 of proposed geoengineering solutions. I formally 

16 request it be entered into the record. It documents 

17 the dramatic increase in Alzheimer's and respiratory 

18 failure since the 1990s, when persistent contrails 

19 became commonplace around the world. I conclude that 

20 these persistent contrails are, in fact, artificially 

21 nucleated with the same toxic particulate metals 

22 outlined in Raytheon's patent and that a solar 

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1 radiation management program has been deployed since at 

2 least the 1990s. 

3 Weather modification research is nothing new. The 

4 earliest patent dates back to 1920. Raytheon's patent 

5 proposes reducing global warming by injecting aluminum, 

6 thorium, and other metallic oxides in the 10 to 100-

7 micron range into the stratosphere using jet exhaust. 

8 The U.S. Navy patented another delivery method, 

9 which forms artificially nucleated contrails from metal 

10 oxides with a 0.3-micron particle size. Other methods 

11 include airships, rockets, chimneys, and slurry pipes. 

12 The best known proponent of solar radiation 

13 management is Dr. David Keith. He told the 2010 annual 

14 meeting of the American Association for the Advancement 

15 of Science that aluminum oxide has 4 times the 

16 volumetric radiative forcing for small particles as 

17 does sulfur and 16 times less the coagulation rate. 

18 Sulfur particles stick together and quickly fall out of 

19 the stratosphere and are much less effective per unit 

20 mass. He also said a nano fabrication study proved it 

21 was very simple to spray high-quality alumina particles 

22 from a plane by injecting alumina vapor into the 

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1 exhaust. 

2 His 2010 paper, "Photophoretic Levitation of 

3 Engineered Aerosols for Geoengineering," proposes 

4 spraying 50-nanometer thick discs of aluminum, barium, 

5 titanium, and ferrite, instead of sulfates. 

6 Pope, et al., also concluded aluminum nano 

7 particles were much more effective than sulfates in a 

8 2010 perspective in Nature Climate Change. 

9 The material safety data sheet for nano 

10 particulate aluminum states it is an irritant to the 

11 respiratory system; is implicated in Alzheimer's 

12 disease; can cause pulmonary disease, tumors, and 

13 neoplasms; and should also not be released into the 

14 environment without proper governmental permits. 

15 Alzheimer's disease rose to the sixth leading 

16 cause of death in the United States from the 8th 

17 between 1999 and 2013. In 1994, it didn't even make 

18 the top 10. Now people in their 20s are showing signs 

19 of Alzheimer's. 

20 Research shows that aluminum accumulates in the 

21 brain, bones, and kidneys; is a neurotoxin; accelerates 

22 brain aging; increases oxidative stress and 
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1 inflammation of the brain; and is seven times more 

2 bioavailable when inhaled than when ingested orally. 

3 Barium is much deadlier. According to its 

4 material safety data sheet, exposure to barium salts 

5 can cause pulmonary arrest, vomiting, diarrhea, 

6 convulsive tremors, muscular paralysis, shock, 

7 convulsions, and sudden cardiac failure. Barium 

8 targets the cardiovascular, nervous, gastrointestinal, 

9 hematology, respiratory, reproductive, and renal 

10 systems, as well as the adrenal glands and liver. It 

11 is also an irritant to the skin and should not be 

12 released into the environment. 

13 In 2011, respiratory failure overtook stroke to 

14 become the third leading cause of death in the United 

15 States, at a time when smoking was at an all-time low, 

16 emissions standards on vehicles and power plants were 

17 at their strictest, and heavy industry had relocated to 

18 China. 

19 Hundreds of scientific papers thoroughly prove the 

20 toxicity of both aluminum and barium. It would take 

21 days to cover a fraction of the proof. 

22 According to EPA, particulate pollution can cause 

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1 early death from heart attack, stroke, congestive heart 

2 failure, and chronic obstructive pulmonary disease. It 

3 also causes asthma and inflammation of lung tissue and 

4 may cause cancer, reproductive and developmental harm. 

5 Particulate pollution can lower life expectancy by one 

6 to three years. 

7 Water and ice have refractive indices of 1.333 and 

8 1.309, respectively, and produce rainbows with an 

9 angular radius of 42 degrees, centered on the antisolar 

10 point. 

11 But in recent years a formerly rare phenomenon has 

12 become commonplace, a 21-degree halo completely 

13 encircling the sun. Some argue that these halos or 

14 incredibly rare sun dogs are formed by ice crystals, 

15 but nothing can change the refractive index of water or 

16 ice, which forms 42-degree halos. Metal salts have a 

17 higher refractive index and, therefore, form much 

18 tighter halos. Crystalline aluminum oxide, for 

19 example, has a refractive index of 1.762 to 1.778, 

20 while barium sulfate has a refractive index of 1.636. 

21 My contention that these incredibly rare sun dogs 

22 are, in fact, formed by metal salts with a higher 

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1 refractive index than water is reinforced by rainwater 

2 analysis taken during a 30-day period when I recorded 

3 21 of these halos in March/April 2015. I collected 

4 rainwater in clean glass bowls on the roof of my San 

5 Francisco apartment building on April 5th, 6,000 miles 

6 downwind from the nearest factory, power plant, 

7 refinery, freeway, quarry, or mine. I sent it to a 

8 NELAP-certified lab and they recorded barium at a 

9 staggering 160 micrograms per liter. Less than one 

10 gram will kill an adult human. 

11 An earlier test of rainwater collected in January 

12 '14 recorded aluminum at 190 micrograms per liter. I 

13 submit both these rainwater tests for the record. 

14 San Francisco's air should be pristine. We get 

15 prevailing winds off the Pacific Ocean. Why is it left 

16 to concerned citizens to pay for our own rainwater 

17 analysis, and why did EPA stop publishing data on 

18 airborne aluminum in 2002? Let me take this opportunity 

19 to formally submit a Freedom of Information request for 

20 EPA to release the historical results of metal levels 

21 in our air and rainwater from the 1980s to the present. 

22 I have recorded hundreds of time-lapse videos 

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1 showing the progression of these persistent contrails 

2 since 2011. Thousands of others worldwide have also 

3 documented the alarming increase of these persistent 

4 contrails and been met with deafening silence from 

5 supposedly green organizations like Greenpeace, who are 

6 a proud partner in the solar radiation management 

7 governance initiative and all governmental agencies, 

8 including the EPA. 

9 Your mandate is to protect the environment, 

10 especially the air we breathe. I wouldn't expect you 

11 to admit the existence of a program as covert as the 

12 Manhattan Project, even one blatantly obvious to an 

13 increasingly aware and outraged populace, but when a 

14 geoengineering program is causing millions of premature 

15 deaths a year, you must do more than pass the buck back 

16 and forth between other three-letter agencies. 

17 Do your job. History will judge you on your 

18 actions or inaction. 

19 MR. BLISS: Firstly, I would like to thank the 

20 organizers for making this hearing possible, to thank 

21 the other contributors, and a very big thank you to 

22 those that have helped with the vital funding to make 
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1 my trip possible. 

2 My name is Max Bliss. I am no scientist, In 

3 fact, I am a general builder who has worked outside all 

4 of my life. After moving to the southwest of France in 

5 2009 to a region famed for high sunshine hours and big 

6 blue skies, I became increasingly aware of the 

7 incredible increase in contrails and associated cloud 

8 cover. I began to notice this daily, and it has 

9 greatly troubled me. I started to photograph and film 

10 the sky now for four years. Barely a day goes by 

11 without seeing various contrails, some think spreading, 

12 but most alarming is watching spurts within contrails 

13 and then watching the sky blotted out. 

14 Subsequently, I wanted to learn more and became an 

15 avid researcher and a passionate environmentalist. I 

16 have attended and participated in various high-level 

17 climate change and climate engineering conferences. 

18 With respect to this hearing on the proposed 

19 finding of greenhouse gases from aircraft cause or 

20 contribute to air pollution that may reasonably be 

21 anticipated to engager public health and welfare. The 

22 major component, 95 percent of greenhouse gas is water 

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1 vapor. Together with other constituents from exhaust 

2 or ejected particulate matter from aircraft form 

3 contrails. Contrails, haziness, and cloud blankets, 

4 which eventually -- which certainly do affect changes 

5 to the weather, altering rainfall, altering 

6 temperatures, reducing droughts, reducing frost, et 

7 cetera, and ultimately affecting climate change. 

8 When the planes were grounded following 9/11 and 

9 later in the U.K. in 2010, there were obviously no 

10 contrails. The sky cleared of clouds, a natural clear 

11 blue sky returned, confirming aviation is affecting 

12 cloud cover. 

13 According to various investigations, such as the 

14 1998 subsonic contrail and clouds effects special 

15 study, they have noted that, apart from water and CO2, 

16 there are metal particles, including zinc, aluminum, 

17 and titanium, also soot, sulfates, et cetera, found in 

18 the exhaust blooms, contributing as nuclei for ice 

19 crystals to form contrails. 

20 A 2010 study for the Wright-Patterson Research 

21 Laboratory entitled "Nano-Sized Aluminum-Altered Immune 

22 Function" opens the abstract of this sentence, "On the 

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1 basis of their uses in jet fuels, munitions, the most 

2 likely scenario for aluminum nano-particle exposure is 

3 inhalation." The U.K. Civil Aviation Authority 

4 responded to the concerns of fume incidence. 

5 The 2004 investigation into curbing air quality 

6 found that the peak particulate matter found in the air 

7 ducts was aluminum. Although the study does 

8 hypothesize that this may be from the heated engine 

9 lubricating oils contaminating the air supply via the 

10 air bleed valve, it is worthy to note that 50 percent 

11 of the cabin air comes from the atmosphere. And as 

12 planes often fly through contrails, all of the aerosols 

13 left by other planes are filling investigation into the 

14 presence of nano particles in the troposphere from 

15 planes, although very difficult, must be initiated as 

16 soon as possible. 

17 Many hundreds of pilots and frequent flyers report 

18 debilitating illness linked to cabin air. Please refer 

19 to aero toxic syndrome. 

20 There are many new studies emerging on the links 

21 with aluminum and Alzheimer's, dementia, and various 

22 other serious ailments in humans, animals, whales, 

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1 fish. And even bees, plants, trees, and all life is 

2 affected by aluminum toxicity. 

3 Recently the media has announced that one in three 

4 seniors will die with Alzheimer's. It just becomes 

5 clearer with research that nano particles may already 

6 be in jet fuels and are certainly planned for 

7 implementation in the near future and also, for that 

8 matter, in biodiesel. Aluminum oxide not only has the 

9 potential for negative health impacts; it is also known 

10 to contribute to making clouds as it is used in trace 

11 rockets for NASA. Aluminum oxide has been suggested by 

12 geoengineers for solar radiation management but is 

13 known to damage the ozone. 

14 Aluminum is a cation and is mentioned in with the 

15 weather modification patents, although there are 

16 hundreds of weather modification patents using various 

17 methods and ingredients. 

18 In a 1956 U.S. patent, 2756097, for weather 

19 control, the author states "We have discovered that 

20 quantities of very dry super-heated water vapor will 

21 disturb the thermal and electrical balances of cloud 

22 formation, causing dissipation or precipitation. We 
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1 accomplish this process of our invention by injecting 

2 water or water solutions of ionic salts into heated 

3 exhaust gases of a power plant, such as the internal 

4 combustion engine, jet engine, and the like. 

5 Through investigation into the huge disturbing 

6 increases in contrails, associated cloud covers, and 

7 changes to the weather, one will be left wondering if 

8 this indeed is intentional or deliberate as the extra 

9 contrails and cloud generation is excessive in 

10 correlation with the increasing, growing aviation use. 

11 I have taken pictures of nozzles in line with the 

12 engines on pile-ons. These are described as oil drain 

13 mass. But some patents of similar nozzles state other 

14 materials can be evacuated from them. Even if oil were 

15 leaked out into the hot exhaust plume, smoke would be 

16 generated. And smoke is used for cloud seeding for 

17 weather modification. 

18 A 1970 paper by Wallace B. McCray on the 

19 possibility of weather modification by aircraft 

20 contrails, he described how the ice crystals formed in 

21 contrails. Effectively you can seed cloud decks below 

22 as ice crystals survive falling to lower cloud deck 

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1 altitudes, increasing cloud cover as effectively as dry 

2 ice cloud seeding. McCray writes, "Possible 

3 consequences of this are considerable. In fact, it 

4 seems probable that one of the projects for modifying 

5 the global climate discussed by Fletcher in 1965, 

6 namely modification of cloud cover over the North Polar 

7 Basin by cloud seeding is already underway. 

8 Up until the mid 1970s, documents suggest the 

9 establishment desire was to intentionally melt the 

10 Arctic Sea ice to free up shipping lanes, access risk 

11 resources, and open up vast regions of ice-locked land. 

12 And, adversely, climate changes could likely be blamed 

13 on the anthropogenic global warming to initiate the 

14 beginning of global governance for United Nations 

15 agenda 21, "Sustainable Development" program, to create 

16 the new world order. 

17 Interestingly, when one begins to research the 

18 history of weather and climate modification, it is 

19 surprising how far up the power structure the desire 

20 for developing a large-scale weather and climate 

21 modification program was from Presidents Eisenhower, 

22 J.F.K., Johnson onwards and onwards, with a high 

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1 priority put on these possibilities. The Johnson 

2 administration was using weather modification for 

3 geopolitical leverage with India and Pakistan in 1967. 

4 Would we be naïve to think that the interest just went 

5 away because of the ENMOD treaty? Look up owning the 

6 weather 2025. 

7 In conclusion, pollutants from aircraft that need 

8 prohibition, such as sulfates or the use of any nano 

9 particles which can travel via the air from a source of 

10 combustion into life organisms is causing serious 

11 negative health impacts to many forms of life. This 

12 needs to be tightly regulated and ultimately stopped. 

13 The notion that the climate science is settled is 

14 often repeated over and over by interested 

15 stakeholders, such as those looking for lucrative 

16 funding in the burgeoning climate change arena, the 

17 academics, politicians, or entrepreneurs looking for 

18 success or to get rich or, more darkly, hoping to 

19 implement a one-world government system. 

20 Climate has always had natural variability and 

21 weather extremes. However, these days, some weather 

22 extremes can be stimulated with technology. Is it 

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1 appropriate to reassess the anthropogenic global 

2 warming theory and replace it with climate change is 

3 manmade by using covert weather and climate 

4 modification technology, known as geoengineering, for 

5 geopolitical ends? 

6 We do not need to be scientists to observe the sky 

7 and see the obvious negative effects aviation is having 

8 and research the spiraling health impacts. Just start 

9 looking up and wake up. We do not consent to the use 

10 of weather and climate modification or the despotic new 

11 world order. 

12 God bless and peace for all. 

13 MR. GUNNING: Thank you both for your comments. I 

14 believe unless here are additional registrants that 

15 have come in since a few minutes ago we have concluded 

16 our hearing for today. On behalf of the whole panel 

17 and the EPA, I would like to thank everybody for your 

18 thoughtful comments and suggestions today. 

19 I want to remind everybody, as I said at the 

20 outset, the comment period officially closes on this 

21 action on August the 31st at 11:59. So we encourage 

22 written comments. We want additional information and 
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1 anything you can provide. 

2 So thank you all for taking the time today. We 

3 appreciate it. And we will hope to hear from you soon. 

4 Thank you. 

5 (Whereupon, at 12:15 p.m., the hearing was 

6 adjourned.) 

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A

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$268 58:11

$30 91:8

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absolutely 56:2

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abstract 103:22

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108:17

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33:11

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97:21

accepting 82:5

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106:1

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21:8 78:3,5

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82:6

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48:8,16

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29:9 40:7,10

64:11 72:5,21

74:7,10 75:1

82:5,11 84:7

84:10 89:20

agency's 62:4

72:1 73:8

75:17

agenda 107:15

agents 84:5

aggressive 15:4

31:4

aging 97:22

ago 30:16 50:20

86:11 109:15

agree 12:22 64:8

agreed 51:11

52:17

agreed-upon

40:17

agreement 47:3

agreements 47:4

agrees 24:18

agricultural

30:7

ahead 67:8 72:5
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AIA 49:15 54:4

54:5

ailments 104:22

air 1:3 2:14,18

2:19 3:8 4:5,11

5:16,20 7:15

8:3,18 9:1

11:17 12:19

16:16 19:7

22:7,10 23:10

23:19 24:1,8,9

24:11 25:4,17

25:19 28:18,19

29:6,8,9,20

31:5,11,17,18

32:3 35:20

36:8 38:8,21

41:18 42:2,6,9

46:14 51:22

54:1 55:14

57:10 58:2,18

59:4 62:11,17

62:18 65:7,14

65:22 66:8

67:6,12,22

70:22 71:22

73:13 74:10

78:12 79:2,4

83:3 85:1

87:14 89:1,5,5

100:14,21

101:10 102:20

104:5,6,9,10

104:11,18

108:9

airborne 38:10

84:21 100:18

Airbus 36:11

aircraft 1:3 4:11

5:19 7:13,19

8:2,5,11,15,15

13:14,19,22

14:1,3,6,10,18

14:21 15:5,7

15:13,16 16:2

16:4 17:9,21

18:6 20:16

21:14,17,18,21

22:4,15 23:12

23:14,16 24:9

24:21 25:10,19

26:2,4,6,8,10

26:17,18 27:3

27:5,6,9,18

29:4,14 31:11

31:15 32:5,8

32:14,18,21

33:1,6,13,14

34:2,4,6,12,17

34:18,20 35:10

35:16,18 37:2

37:3,4,6,14

39:16 40:3,9

41:5,6,6,7

43:19,22 44:2

48:7 49:13,21

50:2,3,14,17

50:18,19,22

51:18,19 52:13

52:19,21 53:2

53:4,7,14,19

54:1 55:13

61:2 62:6 63:7

63:9,20 64:8

64:22 65:15,15

65:19,21 66:4

66:5,9,14

67:22 68:11,11

68:15,15,16,18

68:19,22,22

69:4,5,11,15

69:19 71:4,6

71:10,17 72:2

72:11,12,16,21

73:1,2,4,6,9,18

74:14,18 75:1

76:19 77:1,10

77:21 78:3,6

79:3,6 80:6,10

80:14,15,16,22

81:14,16,20

82:3 83:16

84:12,16,19

85:19 87:4,14

88:5,7,15,19

89:7,14,21

90:8 91:21

93:1 102:19

103:2 106:19

108:7

aircraft-related

34:15,22

aircraft-type

26:7

aircrafts 71:11

airframes 39:10

90:1

airline 36:12

37:1,19,21

38:18 39:12,17

41:9 77:2

78:18

airlines 2:13

11:15 17:17,19

18:3,8,15,19

19:6 20:20

21:15 22:22

36:14,20 37:22

38:12 39:1,7

40:2,14,18,20

55:7,11 78:14

78:21 89:17

90:14 91:6

92:7

airplane 83:12

airplanes 43:3

61:2 87:5

airport 35:7

56:10,20,22

airport-related

35:8

airports 22:22

48:17 56:7

82:17

airships 96:11

airworthiness

50:2

al 97:6

alarming 101:3

102:12

Alaska 90:14

91:6

albedo 94:12

aligned 22:6

alike 70:13

all-time 98:15

allow 20:5 74:7

allowed 6:2

allowing 55:4,7

55:11,19

ALPA 36:12

38:15 39:21

40:18 41:3

ALPA's 36:15

37:9

altering 103:5,5

alternative

19:11,16 22:19

38:2

Alternatively

47:22

altitude 13:3

61:17 77:21

93:20

altitudes 55:12

107:1

alumina 96:21

96:22

aluminum 42:10

95:2 96:5,15

97:4,6,10,20

98:20 99:18

100:12,18

103:16 104:2,7

104:21 105:2,8

105:11,14

Aluminum-Al...

103:21

Alzheimer's

46:15 95:17

97:11,15,19

104:21 105:4

Amanda 3:14

76:4 81:9

ambitious 30:21

91:13

America 2:13

11:15 17:18

23:4 38:22

American 39:12

96:14

amount 45:6

54:13 64:1

amounts 45:1

71:7

analyses 53:11

analysis 12:1,11

14:3,7 15:19

100:2,17

analyze 17:2

27:14 47:20

analyzing 78:9

and/or 15:11

57:11 73:1

Andres 3:10

67:7 70:3

angular 99:9

animal 71:2

animals 104:22

announced 7:4

105:3

announcement

40:6

announcing

9:11

annual 18:21

96:13

ANPR 7:12,18

11:6,7,11

12:13 20:9

25:2 26:1,19

28:6 64:15

65:20

ANPRM 15:21
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anthropogenic

13:8 107:13

109:1

anti-geoengin...

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anticipated 1:4

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32:20 42:7

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antisolar 99:9

anyone's 49:7

apart 103:15

apartment

100:5

apologize 49:7

Apparently 45:1

appear 81:17

appears 44:4

applicability

12:16 13:18

26:1,3

applicable 34:2

62:16

application 74:1

applications

14:20

applied 15:18

16:2

applies 89:6

apply 8:14 9:13

9:16 26:5,8

41:7 69:19

80:5

appreciate

17:19 21:20

25:2 28:8,14

48:13 67:2

110:3

appreciates 12:3

28:14 62:7

74:21

approach 12:22

13:19 15:15

17:5 21:2

52:11 53:2

63:5 66:13

68:16,18 69:1

approaches

13:17 26:3

56:17

appropriate

8:11,13 15:20

16:8 20:13

75:4 109:1

approval 40:12

approximately

89:14

April 100:5

ARB 29:11,18

32:19 33:3,5

33:18 34:5,14

34:18 35:2,5

35:12

ARB's 35:1

arching 25:22

Arctic 107:10

area 61:11 83:1

areas 23:21 48:1

58:19

arena 108:16

arguably 39:3

argue 99:13

arguments 6:2

array 22:20

arrest 98:5

arrow 22:15

arrows 23:1

artificial 61:9,9

94:17,18

artificially 94:16

95:20 96:9

as-usual 16:2

ascertain 34:7

asked 9:20

aspect 73:10

ASRC 83:14

assembly 30:19

53:9

assert 73:3

asserted 32:1

assessment 5:1

13:1 43:14

assessments

31:22

assignment

10:10

assistance 82:1

associate 70:4

associated 27:4

57:10 102:7

106:6

association 2:14

2:19 3:3 11:16

23:9,19 26:20

28:19 36:9

49:11,15 96:14

assume 16:7

assumptions

45:11

assured 23:4

asthma 99:3

astronomy 46:2

atmosphere

5:14,21 24:5

45:4 54:16,18

61:18,19 71:7

77:22 81:18

94:8 104:11

atmospheres

60:16

atmospheric

31:19 45:17

93:21 94:15

attach 47:19

attachments

90:11

attack 99:1

attacks 48:2

60:5

attempt 11:4

63:8 94:9

attendant 53:22

attended 102:16

attending 6:17

attorney 70:4

86:7

attracting 94:15

attributable

51:5

attributed 43:7

46:15

audience 6:14

August 1:11 7:2

20:9 28:7

109:21

author 105:19

authority 25:18

31:6 33:9

35:15 42:1

52:18 65:16

73:3,8 79:1,3,8

80:6,17 83:1

85:16 89:2,8

104:3

authorized 9:15

65:18

authorizes 65:14

89:6

autism 46:15

57:2,4,10,16

57:16,22 58:18

autism-related

58:11

auxiliary 27:7

34:18

avail 84:6

availability 30:5

available 7:6

8:22 9:3 14:17

74:20 78:11

Avenue 1:21

average 18:21

44:6 51:13

averages 66:14

80:22

averaging 74:5

89:6,8 92:2

avert 76:16

AVGAS 45:14

aviation 4:21

5:3 7:20 12:4,5

12:9,19 13:11

17:2,11 18:20

19:1,8,11,16

21:4,14 22:1,3

22:15,19 23:3

29:16 31:2

32:20 33:22

37:10 39:3

40:8 41:19

42:1,15,22

43:11 44:1,7

44:19 45:13

46:17 48:7,15

50:4,5,7,9,15

51:1,4,5,6,16

52:2,12,22

53:6,12 54:11

54:12,20,21,21

56:16 58:14,16

63:13,16 64:2

64:7 66:17

72:8 77:4,9,13

78:4,10 79:22

81:3,5 89:2,10

92:3 103:11

104:3 106:10

109:7

aviation's 19:12

38:15

aviation-indu...

41:22 45:21

46:22

aviation-related

35:3,4

aviation-speci...

52:8

avid 102:15

avoid 53:22 63:2

70:18

avoiding 76:12

awaiting 72:6

aware 101:13

102:6
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B 106:18

Baake 3:15 76:4

86:5,6

back 6:16 58:4

94:9 96:4

101:15

backdrop 20:7

Baise 3:14 76:4

81:9,10

balance 50:12

balances 105:21

Barely 102:10

barium 42:10

85:4 95:2 97:4

98:3,4,7,20

99:20 100:8

barriers 56:12

56:12,14,16

base 66:6 74:2

83:5,10

based 14:3 24:2

43:12 65:1

69:3,5

baseline 63:5

90:6

bases 84:1

Basin 107:7

basis 33:20 38:9

104:1

Beach 81:10

84:5

bees 105:1

began 78:9

102:8

beginning 14:8

107:14

begins 107:17

begun 19:21

behalf 4:5 48:10

54:4 75:16

109:16

believe 15:10

16:17,21 35:17

41:3 64:10

82:11 90:5,15

92:14 109:14

believes 26:7

35:14

benefit 41:1

52:9

best 75:13 95:11

96:12

best-case 72:14

better 48:8

74:20

beyond 14:6

15:8 16:12

25:19 33:22

35:11 40:17

88:10 91:22

big 44:17 45:4,8

77:7 101:21

102:5

biggest 44:19

54:19 57:1

bill 2:4 4:22

6:20 7:8 30:19

75:21

billion 18:12

54:22 58:12

billions 18:5

binding 47:2

72:2

bioaccumulati...

42:21

bioavailable

98:2

biodiesel 105:8

biofuel 91:7

biofuels 46:5

52:2

biojet 19:22

33:19

biological 3:5

48:14 62:2,6,8

62:12 82:20

biomagnificat...

42:21

bismuth 46:6

black 13:5,7,10

blamed 107:12

blankets 103:3

blatantly 101:12

bleed 104:10

blended 90:1

bless 109:12

Bliss 3:19 92:15

101:19 102:2

block 60:2

blooms 103:18

blotted 102:13

blue 93:14 102:6

103:11

bluntly 83:7

Board 2:18

28:18 29:7,8

83:21

body 22:1 52:7

72:10 84:22

90:1

bold 87:18

bolstered 84:21

bones 97:21

bottom 39:21

bounds 38:13

bowls 100:4

brain 97:21,22

98:1

break 11:2

breathe 101:10

breathing 85:1

brief 59:22

briefly 27:2

bring 40:14

brings 90:18

93:10

broad 65:17

73:7 79:3

80:13

Brookhaven

84:2

brought 95:13

Bryan 2:7 5:2

buck 101:15

build 50:12

builder 102:3

building 1:19

51:7 91:12

100:5

built 72:12

bunch 56:19

burden 76:15

85:13

burgeoning

108:16

burn 20:19 37:7

38:9 39:9

burning 42:17

buses 35:7

business 14:6,14

15:8 16:1

35:11 65:6

business-as-us...

33:5,22 69:3

byproduct 58:15

C

C 4:1

cabin 104:11,18

CAEP 53:7

Caldeira 95:6

California 2:18

28:18 29:6,8

30:4,12,18,22

31:2,7 33:16

35:14 85:2

California's

30:19 31:14

call 11:12 28:16

49:5 67:4

75:22 82:4

called 10:7,11

42:5 82:2,3

calls 82:6

campaigner

76:8

Canada 36:14

40:17

cancer 41:20

46:15 99:4

candid 95:5

cap 65:4 72:13

capabilities 37:5

37:6 73:19

capable 73:18

captain 36:7,11

carbon 12:12

13:6,7,10 18:5

18:13,17 20:2

20:17,18 21:21

23:16 40:10

43:22 50:17

51:12,16 63:1

63:6,20 64:9

76:18 77:1,3,8

77:17 78:6,7

78:10,20 79:12

91:3 93:3

carbon-based

39:7

carbon-neutral

18:22 20:6

51:15

cardiac 98:7

cardiovascular

98:8

care 57:17 59:14

careful 53:11

carefully 27:15

cargo 17:18

18:16 49:21

Carolina 41:15

carried 18:15

32:18

carriers 40:22

carries 39:13

carry 39:2

cars 18:14 76:21

87:2

case 16:3 86:12

cases 11:8 56:21

casts 45:10

catastrophic

76:17
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categories 73:6

category 25:8

27:20

cation 105:14

cause 1:3 4:11

20:14 24:9

31:11 41:8

57:2,4 63:16

87:14 97:12,16

98:5,14,22

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caused 59:1

causes 99:3

causing 41:21

43:21 54:16

57:15 81:20

101:14 105:22

108:10

caveats 12:22

Celsius 60:6

center 3:5 4:21

5:3 48:13 62:2

62:6,8 66:19

center's 62:10

centered 99:9

century 30:12

certain 5:18

13:22 14:4

24:8 47:3 52:4

68:11

certainly 56:10

73:3 103:4

105:6

certification

14:20,22 21:22

22:9,14 40:9

certified 13:20

15:13 41:8

cetera 103:7,17

Chairman 29:18

29:20

challenge 51:10

86:18

challenges 52:12

Chamberlain

83:6,7

chance 76:12

change 4:3 5:5

13:6 23:4

29:21 30:9

31:1 42:5 43:2

45:3,7,12,20

46:18,19 51:9

55:21 57:17

59:10,11,17

60:11 61:16,20

61:20 62:19

63:2 68:7

70:15,19 71:5

71:19 74:19

79:15 86:12,13

86:22 97:8

99:15 102:17

103:7 108:16

109:2

changed 55:19

59:10 93:13

94:2

changes 45:17

50:2 59:6,19

61:13 78:12

103:4 106:7

107:12

changing 61:18

chapters 70:10

charged 22:2

Charmley 2:4

4:22,22 7:9

49:4 76:2

check 10:9

82:17

chemical 82:20

84:21 85:8,20

95:8

chemicals 42:11

42:17,18 47:3

83:20

chemtrail 85:2

Chemtrails

84:18

Chicago 52:18

Chief 29:5

childhood 93:14

children 57:19

58:3,5,7,19,21

59:15

chimneys 96:11

China 98:18

choose 48:3

chosen 14:15

chronic 99:2

cirrus 43:16,19

44:14,15 45:2

45:13,16,18,19

46:6,19 61:6

94:18

citation 88:5

cited 57:9 89:20

citizen 41:15

54:10

citizens 43:5

86:1,14 100:16

civil 7:20 12:9

22:1 32:19

44:7 50:5

53:14 64:7

72:7 79:22

104:3

civilian 95:9

claim 31:18

41:22 43:10

claiming 41:16

claims 44:10

clarifying 6:5

class 79:5

classes 5:18 24:9

65:19 68:11

79:5 80:18

clean 2:11,14

5:16 7:15 8:3

8:18 11:14,16

11:21 12:19

16:16 22:7,10

23:10 24:8

25:4,18 29:20

31:5,17 32:3

35:20 41:18

42:2,9 46:13

65:7,14 67:22

71:22 73:13

79:2,3 89:1,5,5

100:4

cleaner 70:11

clear 4:9 13:6

35:14 43:9

73:16 85:15

86:18 88:20

89:2 103:10

cleared 103:10

clearer 105:5

clearly 10:16

25:12 42:11

90:4

climate 4:3 5:5

13:1,6 17:1

23:4 29:21

30:9 31:1 42:5

42:13 43:2,13

43:21 44:10,12

45:12,20 46:18

46:20 51:9

60:11 61:20

62:10,19 63:2

65:8,9,11 68:4

68:6 70:15,19

71:5,18 74:19

75:8 76:8,12

76:17 77:20

79:14 80:2

86:12,13,22

88:9 95:14

97:8 102:17,17

103:7 107:5,12

107:18,20

108:13,16,20

109:2,3,10

climate-disru...

71:19

climate-related

68:7

Clinton 1:19

close 9:22 64:13

66:20 69:22

83:10

closes 7:1

109:20

closing 35:9

cloud 43:3 44:11

45:13,18 46:6

46:12 48:5

61:9,10 94:17

94:18 102:7

103:3,12

105:21 106:6,9

106:16,21,22

107:1,2,6,7

clouded 48:18

cloudiness 41:22

43:12 45:21

47:1

clouds 43:8,17

43:19 44:14,16

45:2,5,9,16,19

46:7,19 61:6

61:12,12 93:8

95:8 103:10,14

105:10

club 3:10 67:7

70:6,10 71:3

74:21 75:17

club's 70:5,14

co-presiding 2:3

2:4 9:14

CO2 7:19 8:2,5

8:7,10 12:12

12:17 13:18

15:11 16:9,15

16:17 17:10

20:21 22:9,14

23:15 24:22

26:2,4,18 27:3

27:6,13,18

32:21 33:10

34:6,9,13
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coagulation

96:17

coalition 18:20

20:1

coastal 30:2

cognizant 38:11

collaborate

40:15

collaborative

22:18

colleague 6:20

colleagues 53:12

collect 47:20

collected 100:3

100:11

collecting 34:7

collection 16:22

Columbia 23:20

combat 51:12

combined 15:1

32:11

combustion

54:19,20 55:1

56:5 61:1

106:4 108:10

come 4:7 32:11

67:4 85:8

109:15

comes 39:22

47:13 87:3

104:11

coming 4:15

28:4 44:17

45:14 64:11

66:18

commends 24:4

commensurate

25:13 41:1

comment 7:1 8:9

17:13 20:10

62:7 64:14

66:20 80:11

109:20

comments 5:8

6:4,10,12 7:1,3

10:4 11:11

12:7,14 17:5

20:8 23:11

25:22 28:7,14

28:15 29:12

30:15 31:15

49:2 54:6

66:19 67:2

69:22 75:16,19

81:8 88:6

92:13 109:13

109:18,22

commercial

5:19 17:8

19:15,22 20:20

21:4 23:3

50:15,18 51:1

51:6 52:12,21

78:6,8 91:6

commercial-sc...

22:20

commercially

19:11

commitment

21:3 88:1

89:11

commitments

75:9 88:21

commits 48:8

committed

18:21 23:5

51:7 88:17

Committee 40:7

53:6

commonplace

95:19 99:12

communicate

4:8

communication

57:13

communities

29:22 30:2

56:15 86:16

community

22:12 63:19

64:3

companies 38:8

49:18

compared 39:12

51:17 63:10

91:4

competition

52:3

competitive

53:20 91:11

competitors

53:21

complaint 83:1

complaints

83:18 84:8

complement

34:13 91:14

complementary

38:19 81:5

91:2

completely 26:6

99:12

complexity 17:3

compliance

26:11 34:8

62:15

complies 46:13

comply 13:21

component

102:22

comprehensive

25:15 30:21

52:11

comprise 18:8

compromise

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find 5:18 24:5,8

26:13 38:1

42:20 44:20,21

44:21 58:5

finding 1:2 4:10

5:9 12:4,15,20

13:4,11,13

23:12 24:3,13

24:15,17,19,20

28:6 29:3

31:10 32:4

36:16 47:12

49:12 64:8,10

64:17 67:14,21

68:3 71:16

72:1 80:9

87:18 91:17

102:19

findings 6:7

7:10,16 8:21

17:21 20:9,14

46:9

finished 6:4 10:3

fires 30:15

firmly 24:15

first 11:13 12:15

13:19,20 20:12

24:3 27:4 36:8

36:17 61:7

72:21 78:9

79:10

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Firstly 101:19

fish 105:1

five 10:1 20:11

39:19 81:13

fixed 48:1

fleet 14:9,11

44:7 64:22

72:13 73:11

90:22 92:7

fleet-wide 66:14

74:5 80:22

89:6,8,15 92:2

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flies 36:11

flight 38:13

39:14 90:12,18

flights 19:22

47:20 63:21

71:8 78:5,8

91:8,11

floating 56:15

floods 70:22

floor 36:4

flow 89:22

fly 36:14 104:12

flyers 104:17

flying 50:19

focus 12:14,21

38:14 68:17

focused 19:4

focuses 7:18

focusing 80:13

follow 10:4 47:8

53:17 64:15

80:20

followed 53:1

following 12:14

25:21 66:2

85:7 103:8

force 78:21

forcing 43:15

44:5,7 75:3

96:16

forecasts 54:21

forefront 31:1

forego 26:11,14

foreign 47:19

forest 30:15

forge 72:5

form 83:13 94:3

94:15,17 99:17

103:2,19

formal 9:13

formally 83:18

95:15 100:19

format 10:6

formation 44:4

46:12 55:12

70:22 105:22

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61:10 99:14,22

106:20

formerly 99:11

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forms 96:9

99:16 108:11

forth 101:16

forthcoming

23:15 72:7

74:2

forthwith 64:12

Fortunately

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forum 6:11

forward 28:9
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Francisco-bas...

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Freedom 100:19

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Friends 3:13

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50:21,22 51:1

51:13,18 55:5

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78:15 83:4,9

89:18 91:10,11

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fuel-efficient

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fuel-saving

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fuels 19:16,19

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38:2 41:21

44:18 46:5

81:6 91:3,3,4,5

104:1 105:6

full 20:8 27:19

53:8 85:19

fully 64:8 85:16

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Function 103:22

fundamental

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funding 101:22

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further 18:15

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33:9,15 34:13

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Furthermore

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18:10 19:13

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21:13 25:11,12

29:4,11,14

30:21 31:10

36:16 37:11

39:18 47:3

49:14 54:11

62:5,11,16

63:15 68:1,15

68:21 69:1,7

70:16 71:4,16

71:20 72:6

74:22 77:10

78:11 87:6

93:1,2,3,6

102:22

gases 12:21

29:19 30:11

31:17 38:16

39:10 41:16

42:5,12 46:21

59:21 68:12

71:11 75:10

77:14 89:4

102:19 106:3

gasoline 41:19

gastrointestinal

98:8

gear 89:21

gene 59:10,11,12

59:17

general 4:18

12:22 13:17

102:3

generated 85:19

106:16

generation

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generations 5:15

24:7 59:13

70:13

genetic 57:14

genome 59:12

59:17

geoengineering

46:2 95:15

97:3 101:14

109:4

geoengineers

94:7,19 95:5

105:12

geopolitical

108:3 109:5

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Germany 54:14

63:11

Germany's 77:6

GHG 24:5,8

31:15 32:1,8,9

32:15,18,22

33:4,16,19,21

35:18,22 36:1

91:3

GHG-emitting

32:12

GHGs 31:20

32:6

give 11:19 36:15

56:10

given 9:17 21:10

69:11 72:3

73:19 88:9,17

gives 37:5

giving 10:22

81:11

glands 98:10

glass 100:4

global 14:9,11

18:20 20:2

21:2,15 29:16

30:20 43:2,8

50:4,6,10 51:5

51:10 54:12

62:15,18 63:9

63:19 64:1,2

64:22 72:11,13

77:4 79:19

87:10 94:10

96:5 107:5,13

107:14 109:1

globally 50:8

77:2

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67:8 82:17

88:10 91:22

92:18

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goals 22:16

33:16 36:1

38:18 51:18

52:5 70:14

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40:17 49:5

61:2,3 76:2

87:1

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29:1 36:5 54:8

67:10 76:12

81:9 88:1

92:17,18

governance

101:7 107:14

government

19:3 20:4 31:4

53:12 81:22

95:10 108:19

governmental

97:14 101:7

governments
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21:13 25:11,12

29:4,11,14,19

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31:17 36:16

37:11 38:16

39:18 41:16

42:12 46:21

49:13 54:11

59:21 62:5,11

62:16 63:15

67:22 68:12,15

68:21 69:1,7

70:16 71:4,11

71:16,20 72:6

74:22 75:10

77:10,14 78:11

87:6 89:4 93:1

93:2,6 102:19

102:22

Greenpeace

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gripping 30:17

gross 39:19 51:3

ground 35:6

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78:1

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ground-level

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grounded 60:9

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10:6,10,11,19

10:20 11:13

28:16,17 48:14

49:5 67:3

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growing 63:13

63:17 77:14

84:21 106:10

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growth 19:1

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36:3 41:13

49:1 67:1

75:19 92:12,18

109:13

H

hair 58:3,4,6

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halos 99:13,16

99:18 100:3

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harm 41:9 99:4

harmed 64:2

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47:10 63:18

70:22 94:6

harmless 93:3

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harmony 22:11

harms 71:5

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haziness 103:3

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Headquarters

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31:12,21 35:19

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42:12 43:11

62:13 64:9

68:1 71:17

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87:16 93:2

94:6 95:4,14

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108:11 109:8

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92:11

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61:22 62:3

85:7,18 92:22

101:20 102:18

109:16 110:5

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99:1

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heat-trapping

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106:2

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58:1,2,5,14

82:20 85:3

98:17

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71:4 75:13

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101:22

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high 13:3 58:18

61:17 77:20

85:3 102:5

107:22

High-altitude

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high-level

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high-quality

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high-traffic 48:1

higher 58:7

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highest 15:21

highlight 17:10

44:10

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highly 22:4

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highs 60:6 93:10

highway 55:22

56:9,14

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56:12

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100:20

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89:17

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107:18

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holds 48:8

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hoping 108:18

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93:17

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102:5

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human 41:17

43:11 44:16

62:13 64:9

94:6 95:4,14

100:10

humans 104:22

humidity 93:20

hundreds 81:15

98:19 100:22

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hypothesize

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ICAO 7:21 8:8

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64:7,18 65:4

69:14 72:8,14

80:1,2,8 88:11

88:13,14,17,21

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ICAO's 23:14

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73:13

ICCT 11:21

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99:16 103:18

106:20,22

107:2,10

ice-locked

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identified 13:7

15:21 26:19

83:16

ignorant 93:12

ignoring 43:1

illness 104:18

illnesses 46:16

immediate

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immediately

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impact 13:2

17:1 30:6

33:21 39:5

40:3 45:12,20

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56:1 77:20,22

impacted 39:16

impacts 45:17

56:6 70:19

76:12 79:14

86:17 95:4,14

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109:8

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implementation

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implemented

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47:7

implementing

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implicated

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importance

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important 13:8

17:15 23:3

27:21 28:10

36:6 47:8 54:9

56:3 59:2 76:7

77:19 86:13

impose 35:15

56:1 72:12

imposed 21:19

71:15

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improve 17:1

38:20 47:11

90:11

improved 18:4

18:11 37:13

51:18 89:17,20

improvements

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50:17 52:1

78:16 89:19

90:3

improving 24:1

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in-development

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in-production

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34:12 68:22

88:15 91:20

in-service 41:5

66:14

in-use 27:9

34:16

inaction 101:18

incentive 20:21

21:11 38:7

incidence 57:18

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13:15 34:16

46:11 48:5

51:13 62:14

66:8 70:19

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96:11

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83:15

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including 28:2

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52:13 76:19

81:1 89:21

91:20 92:6

101:8 103:16

incoming 60:2

incompatible

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incomplete

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incorporated

44:8 52:15

incorporating

13:10

increase 54:21

60:15 71:14

79:9 87:11

95:17 101:3

102:7

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57:9,10 63:16

increases 62:20

97:22 106:6

increasing 39:6

106:10 107:1

increasingly

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incredible 102:7

incredibly 80:4

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independence

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independent

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independently

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index 99:15,17

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indicate 10:1

indices 99:7

indisputable

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indistinguisha...

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individual 67:20

individuals 10:7

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induced 43:12

46:18 57:14,15

61:12

Industries 3:3

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industry 18:11

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21:15 37:12,19

38:18 39:12

41:9 48:16

49:22 50:4,9

50:15 51:1,7,9

51:11,17 52:3

52:12 63:7

77:4 78:19

90:8,14 91:5

91:12 98:17

industry's 18:18

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89:10

industy's 22:16

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98:1 99:3

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68:19

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34:8

informally 9:12

information

7:13 81:22

83:15 100:19

109:22

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82:15 83:7

85:16

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infrastructure

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22:21 30:3

ingested 98:2

ingredients

105:17

inhabit 86:2

inhalation 104:3

inhaled 98:2

initial 13:4

32:22
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intensifying

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15:10 16:7,9

19:5 21:17,19

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33:6 36:9 46:4

50:5 52:7

53:21 63:21

64:7,21 68:6

71:8 72:7 75:8

78:8 79:22

84:20 88:12

internationally

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Internet 43:4

intersection

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interview 95:7

introduce 75:21

introduced

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introducing

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introduction 7:7

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invention 106:1

inventory 18:11

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invested 91:8

investigate 83:2

investigated

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investigation

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investigations

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investing 18:5

investments

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involve 41:5

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ionic 106:2

IPPC 43:12 44:9

IPPC's 43:14

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irrefutable

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irresponsible

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irritant 97:10

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issue 7:15 26:15

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56:3 57:1

65:10 72:1,17

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items 28:2

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James 2:20

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Jefferson 1:19

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jet 17:9 20:19

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46:5,12 47:7

58:16 59:9

61:2 81:6 91:3

91:3,10 96:7

104:1 105:6

106:4

jets 83:3 94:14

job 101:17

Joe 2:19 28:19

36:7

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journal 57:5

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July 5:12 7:10

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K

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Kathy 3:8 67:5,8

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20:22 59:22

76:10

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Keith 96:13

Ken 95:6

kept 9:6

Kerry 89:13

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90:10

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kids 59:16 86:15

kill 100:10

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57:1,22 58:7

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lacking 44:14

lag 15:1,4

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LaGuardia

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laid 86:11

laminar 89:22

land 107:11

landing 13:15

landings 56:5

lanes 107:10

language 73:16

large 4:20 5:2

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large-scale

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largely 7:18

largest 25:10

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49:15 57:2

63:20 70:7

76:13 77:15

87:5

late 64:11

latest 13:9 44:15

45:10 51:20

68:5

law 22:10 42:2,6

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laws 62:16

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layperson's

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leave 54:17 77:7

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levels 15:21 19:5

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leverage 108:3

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lieu 69:20

life 61:8 93:4

99:5 102:4

105:1 108:10

108:11

lifecycle 91:3

light 44:19

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light-duty 32:7

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89:22

limit 20:13

76:22 77:17

80:15

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limits 9:16 25:20

line 2:19 28:19

36:8 39:21

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linear 43:15

lines 85:15

linked 104:18

links 104:20

listed 56:18

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liter 100:9,12

literally 37:2

literature 94:22

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livelihoods

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load 57:22 58:2

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local 25:17

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London 56:19

long 63:8 71:6

long-lasting

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longer 30:9

look 28:9 33:18

38:2 43:5

55:17 58:4

59:5 75:16

108:5

looked 60:8

looking 108:15

108:17 109:9

loss 30:13

lost 64:12

loud 28:22

love 86:15

low 59:1 74:13

91:2 98:15

low-carbon 81:6

91:7,10,14

92:8

lower 15:19 51:2

55:12 60:16

99:5 106:22

lowest 74:8

lows 60:7 93:10

lubricating

104:9

lucrative 108:15

lung 99:3

Lutsey 2:11

11:14,18,20

M

Madisonstar

85:7

mail 37:1 39:2

main 44:12

maintaining

37:12

maintenance

47:16

major 17:18

30:9,11 35:22

45:2 49:16

102:22

majority 57:12

67:18

making 10:15

24:12 36:21

45:16 76:15

101:20 105:10

maladies 43:7

manage 37:6

management

3:9 19:7 51:22

65:22 66:8

67:6,12 74:11

94:11,20 96:1

96:13 101:6

105:12

mandate 73:7

80:8 101:9

mandatory

16:18 47:6

71:15

Manhattan

101:12

manmade 109:3

manner 53:16

86:9

Manning 2:7 5:2

5:2

manufactured

69:19

manufacturer

16:13

manufacturers

12:19 13:14

16:20 21:16

22:22 35:17

49:17 53:20

manufacturing

49:18,20

March/April

100:3

Marine 4:21 5:2

marked 73:13

markets 21:17

marry 59:15

Mary 29:18

mass 38:22

70:21 96:20

106:13

material 42:14

97:9 98:4

materially 69:1

materials 6:10

82:22 106:14

matter 42:12

45:6 52:6

57:18 103:2

104:6 105:8

Max 3:19 92:15

92:16 102:2

maximize 27:15

maximum 60:6

60:7

McCarthy 86:11

86:20 88:2

McCray 106:18

107:2

mean 42:4

meaning 5:16

24:7 43:15

87:16

meaningful

17:10 35:10

73:11 79:19

88:4,12

meaningless

47:1

means 15:3 34:1

45:7

measure 27:19

measurement

17:3

measures 20:5

35:6 64:6,19

78:9,22

mechanism 20:2

media 105:3
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membership

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method 33:19

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mid 107:8

mike 2:6 4:20

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miles 56:22

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military 83:3,8

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milky 93:15

million 18:14

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49:18 70:9

71:13 77:2

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millions 43:5

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mind 21:3 66:3

mine 100:7

mineral 45:5

minimal 79:15

minimize 15:22

minute 10:2

minutes 9:18

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mitigate 71:5

mitigation 34:22

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mobile 29:5 68:3

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mobilizing

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modernize 19:6

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money 82:22

month 95:13

months 64:13

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moral 86:19,21

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morning 4:2 7:9

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morph 61:6

motivation 38:1

motor 21:7

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move 67:3 72:17

74:21 75:12

76:3

moving 102:4

multiple 14:18

munitions 104:1

muscular 98:6

myriad 43:7

N

N 4:1

N.W 1:21

NACAA 23:9,11

23:18 24:4,18

25:5,21 26:7

26:15,18 27:2

27:17

nails 58:3,4,6

naïve 108:4

name 4:2 6:16

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17:16 29:5

41:14 49:7

54:9 62:1 67:4

67:10 70:3

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named 46:21

Nancy 2:13,14

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23:8

nano 95:1 96:20

97:6,9 104:14

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nano-particle

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Nano-Sized

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60:12 84:1

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NASA.gov

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nation's 21:5

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national 2:14

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36:1,10 39:19

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nations 22:1

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nationwide

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natural 3:15

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nautical 56:22

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Naval 83:3

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Navy 96:8

near 35:5 48:17

75:17 105:7

nearest 100:6

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necessarily

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75:3 76:16

Neck 83:22

need 14:1 17:2

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37:18,21 38:11

47:14 48:3

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109:6

needed 21:14

Needless 83:8

needs 56:4 76:22

108:12

negative 105:9

108:11 109:7

negotiate 75:7

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new-type 8:15

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new-type-only

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NextGen 22:17

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nice 28:22

Nichols 29:18,20

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NOAA 46:3

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noise 39:16 52:7

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non-ideal 47:15

nonattainment

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nonpartisan

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nonprofit 11:22

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North 38:22

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Notably 73:7

note 22:13

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noted 16:21 32:5

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November 64:13

NOx 13:2,12,13

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NRDC 86:8

nucleated 94:16

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nuclei 45:14

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number 8:9 9:2

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objectives 62:14

obligation 32:2

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obligations

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observations

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obstructive 99:2

obvious 101:12

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Oceana 83:3,7

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offer 28:6

offers 20:11

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office 4:5,18

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Officer 2:3,4

officers 9:14

official 9:6 11:6

11:10

officially 109:20

officials 53:13

75:7

offset 20:2

oil 106:12,14

oils 104:9

okay 49:5 55:8

55:14 56:15,22

57:2 59:13

61:6,19 76:1

old 58:21 60:15

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on-road 21:7

once 32:4

one-world

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ongoing 23:14

37:18 41:19

online 62:9

onwards 107:22

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open 9:7 61:21

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opens 103:22

operating 21:15

37:3,7 44:3

operational

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51:21 66:8

74:10 90:3

operations 20:4

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77:2 89:21

operators 84:5

opinion 44:10

opportunities

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opportunity 6:1

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23:10 28:8

29:2,15 36:6

41:10 48:10

49:11 54:5

62:7 65:9

66:21 67:13

69:10,16 70:1

75:15 76:6

79:17 81:11

86:5 90:7

92:10 100:18

opposed 14:9

84:18

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optimization

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options 26:19

88:10 91:22

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oral 6:1,2 8:19

orally 98:2

order 10:18

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24:17 41:6

76:15 107:16

109:11

organisms

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organization

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32:20 50:6

57:3 62:9 64:7

67:16 72:8

79:22 86:8

92:1

organizations

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101:5

organizers

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outcome 64:18

64:21 65:6

75:14

outdated 69:5

74:18

outgoing 60:2

outlined 13:17

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output 20:21

outrage 43:2,8
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particulate 45:6

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passenger 17:18

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patented 94:12

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peace 109:12

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63:4,22 64:22

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93:5,6 102:22

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percentage

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performance

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period 7:1 64:14

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permit 73:22

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persist 93:20

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persistent 44:3,6

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persisting 81:16

person 9:17 56:2

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personnel 9:20

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petition 31:14

phase 74:16

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Photophoretic

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63:15

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plane 82:9 96:22

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play 23:3 50:11

playing 16:19

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please 4:17 6:11

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10:15 11:9

28:17,21 67:4

67:8 76:3

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pleased 40:6

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pledged 87:21

plenty 78:15

plethora 46:16

plume 106:15

point 37:5 49:6

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pointed 58:1

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20:16

poison 95:6

poisonous 42:3

Polar 107:6

Police 84:5
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preschoolers

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procedures 37:3

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produce 61:5

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producing 61:12

product 39:20

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productivity

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professionals

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49:12,13 52:15

64:6,10,16

65:10 67:14,15

67:21 68:3

80:9 87:18

89:3 90:6

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proposes 96:5

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proposing 5:13
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public-private

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published 5:11

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publishing

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pulmonary

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purpose 5:7

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purposes 20:11

pursue 17:5

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pursuing 35:4

pushing 88:13

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put 40:22 54:13

54:18 77:3

79:4,18 80:3

108:1

puts 63:14 80:14

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Q

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quantities

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question 21:12

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questions 6:5,9

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quite 94:13

quiver 22:16

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Alderson Reporting Company

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2010 89:12 90:5

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2011 91:8 98:13

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2012 55:3 57:3

58:10 78:13

2013 13:9 44:11

59:8 77:3

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2014 18:16 68:6

2015 1:11 5:12

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Alderson Reporting Company

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