February 2 3 , 2012

Dr. Lourdes Maurice
Executive Director Office of Environment and Energy
Federal Aviation Administration
800 Independence Avenue, SW Washington, DC 20591

Re: EPA’s Proposed Rule on Nit rogen Oxide (NOx)

Dear Dr. Maurice :

I write on behalf of The Aerospace Industries Association (AIA) to express my sincere hope that
the EPA

, FAA , and OMB will do all they can to speed up r ulemaking for the Environmental Protection Agency’s ( EPA) Proposed Rule

, “Control of Air Pollution From Aircraft and Aircraft Engines; Proposed Emission Standards and Test Procedures”, which includes consequent

re visions to the Federal Aviation Administration’s (FAA) 40 CFR Part 87

.

T he civil aviation ind ustry, inclusive of AIA members, has a strong track record of producing

year

- over

- year reductions in NOx

, and other criteria pollutants , and strives to produce products that minimize environmental impact

. The industry has devoted substantive research investments and resources for e missions reduction technologies and has worked closely with the International Civil Av iation Organization (ICAO) to recognize these improvements. As you know, ICAO is the core regulator of international civil aviation

, and is best suited to do so given the global nature of the industry. It is vital that ICAO member States to adopt ICA O standards for aircraft engines in order to maintain international harmonization and a level playing field in
the international market

.

During its eighth meeting, ICAO’s Committee of Aviation Environmental Protection (CAEP) agreed on a cut

- off for aircraft engines whose NOx emissions do no t meet Amendment 6 to ICAO Volume II (known as CAEP6 or to EPA as Tier6 in the NPRM ). Global regulators are thereby left to codify these agreements. We are confident that other agencies worl dwide are on
track to meet the cut

- off date of December 31, 2012, which is rapidly approaching. However,

we fear EPA will not meet this crucial deadline, putting manufacturers and the FAA at a tremendous disadvantage as both manufacturers and the FAA attempt to meet international
standards not yet codified in the United States

.

Although we do have some concerns about the EPA proposal, as outlined in comments submitted by AIA and General Aviation Manufacturers Association (GAMA) on September 26, 2011, AIA supports the NPRM as part of EPA’s and FAA’s continuing effort to harmonize
domestic standards w ith ICAO international standards, thereby improving US local air quality, and securing the benefits of a uniform international market for American manufacturers. Our understanding is that EPA and FAA will address the pragmatic realities of industry commit mentsto deliver engines that have been ordered years in advance

, in accordance with ICAO

standards.

The FAA has also proposed a 6

- step process in order to establish procedures that would attempt to minimize the burden to both industry and government , while maintaining the integrity of the compliance process associated with this rule

. While we ar e general ly supportive of the outlined plan, and appreciate the steps taken to minimize a potentially harmful consequence,
AIA intends to address this more c omplex issue in a separate document

. Our intent is to gain
from the FAA

, further understanding of the process, as suggested by our preliminary questions. After we have been provided with this further detail, we will be in a better position to assess the impact on our membership.

EPA and FAA have worked tirelessly to make certain this rule is not delayed, and we hope that this hard work is not tied up with a lengthy regulatory process. W e appreciate the flexibility demonstrated by FAA and EPA regarding implement ation of the F inal R ule and efforts to ensure an orderly transition to new standards , but we feel strongly that any final regulation of aircraft
emissions standards must offer industry and government stakeholders the necess ary flexibility to respond to unique or unforeseen circumstances that inevitably arise when a complex new regulation is imp lemented in a relatively short amount of time

.

Any delay in finalizing or implementing the F inal Rule carries a real risk to disrupti on in the flow

of commerce

, which could lead to tangible and irreversible loss to industry

, operators , and

go vernment, during a vulnerable economic time

. T o avoid further complication, we urge the FAA, EPA

, and the Office of M anagement and Budget ( OMB ) to expedite th e promulgation of

the EPA’s rule

.
Sincerely,

Leslie Riegle Director of Civil Aviation, Environment & Security Aerospace Industries Association (AIA)

Attachment : Submitted AIA/GAMA Comments to EPA’s NOx Proposed Rule, September 26,
2011

Cc: Environmental Protection Agency Office of Management and Budget