400 Main Street MS 162

- 24
East Hartford, Connecticut 06108

Phone: 860

- 565

- 7774

Alan H. Epstein

Vice President Technology & Environment

March 1 , 2012

Mr. Cass Sunstein Administrator, Office of Information and Regulatory Affairs

Off ice of Management and Budget Eisenhower Executive Office Building

Room 216 Washington, DC 20503

Re: Proposed Aircraft Engine Emissions Standards and Transition Process

Dear Mr. Sunstein:

I am writing on behalf of Pratt & Whitney to express support for the Environmental Protection Agency’s (“EPA”) and the Federal Aviation Administration’s (“FAA”) ongoing efforts to finalize new standards for aircraft engine emissions, which were initiated by EPA’s Proposed Rule last summer, and to establish a transition

pro cess implementing the new standards. See Control of Air Pollution From Aircraft and Aircraft Engines; Proposed Emission Standards and Test Procedures, 76 Fed. Reg. 45,012 (July 27, 2011).

We are aware that the Aerospace Industries Association (“AIA”) rec ently has submitted a letter to EPA and FAA in support of finalizing new emissions standards and establishing a workable transition to those standards. As a member of AIA, Pratt & Whitney joins that letter’s support for the process FAA has proposed to add ress transition issues and for EPA’s efforts to finalize the standards. In addition to echoing AIA’s support, we respectfully would highlight two key pragmatic issues as the rulemaking moves toward completion that are critical to Pratt & Whitney’s ability to comply with the proposed regulations without disruption to existing contracts and jobs: (1) ensuring limited exceptions and exemptions for newly manufactured engines, and (2) endorsing the ongoing military exception to emissions standards.

Pratt & Whi tney supports the finalization of new aircraft emissions standards as part of EPA’s and FAA’s continuing effort to harmonize domestic standards with ICAO international standards, thereby improving local air quality in the United States, and securing the be nefits of a uniform international market for American manufacturers. Importantly, our understanding is that EPA and FAA will address the pragmatic realities of industry commitments to deliver engines that have been ordered years in advance in

accordance w ith ICAO standards. Specifically, we understand that the Final Rule will2 allow each manufacturer six (6) automatic exceptions for newly manufactured engines delivered during the first six

- to

- eight (6

- 8) months that the Final Rule takes effect.

These tran sitional exceptions are vital for preserving current production obligations and the jobs dependent upon them, and our support for the Final Rule presumes this approach. Similarly, consistent with current regulations and the ICAO Convention, we

understand that the Final Rule’s standards for newly certified and newly manufactured engines will not apply to engines manufactured for military use, which are to be excepted, regardless of the country of use. Both of these issues are critical to ensuring

that Prat t & Whitney is able to comply with the standards in a way that does not disrupt existing contracts or jeopardize jobs, and our support for FAA’s proposed process and EPA’s finalization of the standards is based on our understanding that these concerns

will be addressed in the Final Rule.

We are aware that both EPA and FAA have been working tirelessly to make certain this rule is not delayed, and we are willing to assist to ensure that this hard work is not tied up with a lengthy regulatory process. W hile we appreciate the flexibility demonstrated by FAA and EPA regarding implementation of the Final Rule and efforts to ensure an orderly transition to new standards, we feel strongly that any final regulation of aircraft emissions standards must offer the nec essary flexibility for industry and government stakeholders to respond to unique or unforeseen circumstances that inevitably arise in implementing a new complex regulatory scheme in a relatively short time and for an industry as complex as aircraft engine manufacturing. For example, any delay in finalizing or implementing the regulatory process for additional case

- by

- case exemptions could create a need for EPA to extend the period and number of automatic exceptions or for the FAA and EPA to provide further flexibility as a result of delayed circumstances or missed deadlines. Similarly, on the industry side, unanticipated interruptions in the supply chain or production process, among other unforeseen circumstances, could require manufactures to seek leave t o use their automatic exceptions outside of the initial six

- to

- eight month transition period. Whether these particular problems arise, or some other unforeseen challenges, providing necessary and appropriate regulatory flexibility in implementing this app roach will be an essential tool for maintaining the stream of commerce and protecting the significant jobs in the aircraft engine industry at this critical time.

Pratt & Whitney is grateful for this opportunity to offer its support for and understanding of EPA’s forthcoming Final Rule. We believe the timely implementation of the Rule to be very important to U.S. industry’s ability to preserve jobs, and meet domestic and export commitments. Please do not hesitate to contact me if we can be of any further as sistance.

Sincerely,3 Alan Epstein

Vice President Technology & Environment

cc: Kevin Neyland , Deputy Administrator

, O ffice of Informa tion and Regulatory

Affairs , Office of Management and Budget

Margo Oge, Director, Office of Tra nsportation and Air Quality, Environmental Protection Agency

Lourdes Maurice

, Executive Director, Offic e of Environment and En ergy, F ederal

Aviation Administration