### International Coordinating Coun cil of Aerospace Industries
Associations

c/o Aerospace Industries Association
1000 Wilson Boulevard, Suite 1700 Arlington, VA 22209-3928

United States of America info@iccaia.org www.iccaia.org

AeroSpace and Defence Industries Association of Eur ope • Aerospace Industries Association of America • Aerospace Industries Association of Brazil Aerospace Industries Association of Canada • Society of Japanese Aerospace Companies • Union of Aviation Industrialists Page 1 of 3 Mr. James Jones
Assistant Administrator Office of Chemical Safety and Pollution
Prevention
1201 Constitution Ave. NW Washington, DC 20460

Ms. Janet McCabe
Assistant Administrator
Office of Air and Radiation Environmental Protection Agency William Jefferson Clinton Building 1200 Pennsylvania Avenue, N. W.
Mail Code: 6101A Washington, DC 20460 18 December 2015
ICCAIA/AWC/094

Subject: ICCAIA Cabin Safety Working Group, Fire Extinguishing Agent AMPAC 2-BTP, Request to Expedite Review and Approval

Reference: Case #P-14-0260 - 2-brom o-3,3,3-trifluoropropene (2-BTP)

Dear Assistant Administrators Jones and McCabe:

We are writing to request that the EPA e xpedite review and approval of 2-BTP, an environmentally friendly alternative to halon-ba sed extinguishing agents currently used in handheld fire extinguishers on commercial airplanes.

Being an accredited body to the Internati onal Civil Aviation Orga nization (ICAO), ICCAIA represents aircraft manufacturers in the United St ates, Europe, Canada, Brazil , Russia and Japan. Under ICCAIA leadership, working groups pr ovide industry positions to support ICAO in developing Standards and Recommended Practi ces (SARPS) which ICAO contracting Nations are obliged to implement into their national regulations or to consider as guidance materials. Under the oversight of the I CCAIA Airworthiness Committee, the ICCAIA Cabin Safety Working Group is tasked to work on all cabin safe ty regulatory issues, including firefighting and related equipment standards.AeroSpace and Defence Industries Association of Europe • Aerospace Industries Association of America • Aerospace Industries Association of Brazil Aerospace Industries Association of Canada • Society of Japanese Aerospace Companies • Union of Aviation Industrialists Page 2 of 3 Decades of experience with the complex scenario of firefighting in an occupied aircraft cabin or cockpit in flight has led to halon 1211 becomi ng the preferred fire ex tinguishing agent in transport aircraft providing suffi cient fire-fighting properties, be ing non-toxic to occupants, and allowing equipment small and light enough to be used in an emergency situ ation in the confines of an aircraft cabin or cockpit.

However, in order to implement the Montreal Pr otocol on Ozone Depleting Substances with its production ban of halons, in 2011 ICAO published revisions to its Annex 6 “Operation of Aircraft” requiring that all aircraft placed in to service on or after December 31st 2016 be equipped with halon-free ha ndheld fire extinguishers.

Currently there are no approved fire extinguishing agents available which are equivalent to halon 1211 in all relevant aspects. To provide the fire-fighting capacities of halon 1211, extinguishers with currently approved alternative agents are significantly heavier and larger. As such, these fire extinguishers (agents) would result in seve re impacts on cabin/cockpit design, equipment accessibility and handling by aircraft crews. Further, some currently-approved halon-free extinguishing agents are expected to be subject to future enviro nmental restrictions in production

and use.

From an environmental perspective, the best solution would be a non-ozone depleting substance (ODS) with low global warming potential (GWP) which can serve as a “drop-in” replacement for halon 1211 extinguishers. In di scussions with ICAO and aviation regulators (such as the US FAA), aircraft OEM experts are focused on 2-BT P which is currently being reviewed by the EPA for approval. EPA SNAP approval is one of the pre-requisites fo r agent manufacturers to establish economically viable agent production, agent recycling, and product support programs

for civil aviation. This is because civil aviation is a high-risk indus try but relatively small sector needing only a limited quantity of fire-fighting agents but requiring reli able product quality and availability for several decades.

The agent 2-BTP, developed by the US manufact urer AMPAC, is a non-ODS and has a GWP of less than 1. It would allow compliance with th e Montreal Protocol and related national implementing regulations. Due to its composition it is not subject to future production bans under HFC-regulations.

With regard to fire-fighting, 2-BTP has pa ssed UL fire tests and the US FAA Minimum Performance Standards. Although 2-BTP fire ex tinguishers are slightly heavier than current halon fire extinguishers, they are sized to be drop-in replacements, so the impacts on aircraft design, safety and fire-fighting procedures would be minimal. Drop-in replacement fire extinguishers will enable airline operators to mo re easily retrofit their fleets, and therefore will likely result in more rapid removal of halon fr om airplanes and the associated environmental

benefits.AeroSpace and Defence Industries Association of Europe • Aerospace Industries Association of America • Aerospace Industries Association of Brazil Aerospace Industries Association of Canada • Society of Japanese Aerospace Companies • Union of Aviation Industrialists Page 3 of 3 Taking into account the time needed to devel op, certify and introduce aviation-approved fireextinguishing equipment into the fleet of commerc ial airplanes, the airc raft OEMs are concerned about the lack of any reliable schedule re garding an EPA decision on 2-BTP approval. To overcome this situation, the aircraft OEMs organized in ICCA IA respectfully request that EPA expedite the review/approval, or grant an approval with restricti ons or requirements for mitigation means, to allow 2-BTP production and us e for aviation handheld fire-extinguishers.

The ICCAIA Cabin Safety Working Group thanks EPA for considering th is request. We would be happy to provide any aircraft -related information needed to complete your approval process as we both work towards our joint goal of environmental protection.

Respectfully,

Simon Lie Chair, ICCAIA Airworthiness Committee Tim Holey Chair, ICCAIA Cabin Safety Working Group