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

Office 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 

process 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”) recently 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 address 

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 & Whitney 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 benefits 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 with ICAO standards. Specifically, we understand that the Final Rule will 
2

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 transitional 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 Pratt & 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. While 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 necessary 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 to 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 approach 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 assistance.

Sincerely,
3

Alan Epstein

Vice President

Technology & Environment

cc: Kevin Neyland, Deputy Administrator, Office of Information and Regulatory 

Affairs, Office of Management and Budget

Margo Oge, Director, Office of Transportation and Air Quality, Environmental 

Protection Agency

Lourdes Maurice, Executive Director, Office of Environment and Energy, Federal 

Aviation Administration