And expedia should consider a fleet wide averageing program permitted spender section 231 which would allow the agency to achieve the greatest initial reduction at lowest cost. The agency should address operational and air Traffic Management practices which could provide Emission Reduction opportunities that lowcost. Finally epa must require any aircraft that cannot meet the requisite final standard or cannot be retrofitted to achieve it to phase out and ultimately retire. It is critical epa credible that outdated aircraft from polluting our skies and contributing to Climate Change while more efficient designs are readily available. Sierra club appreciates epas efforts to move forward with Greenhouse Gas emissions for aircraft and we urge the agency to the epicenter strong force the epa must take the time necessary to develop appropriate and well considered final rule, time is of the essence. In december president obama and Administration Officials will travel to paris to negotiate an
Domestic co2 Emission Standards. Third, potential domestic reporting requirements for aviation manufacturers under the Clean Air Act. Epa has proposed endangerment findings focus on six key Greenhouse Gases but we concur with this approach with caveats. We agree with epa the assessment scientific uncertainties on the Climate Impact of nitrogen oxides or nox and water vapor emitted at altitude remain high enough so as not to address them in this initial endangerment finding. Science with black carbon to Climate Change on the other hand, is clear. Black carbon was identified as the second most important contributor to anthropogenic emissions in 2013 to. To reflect the latest icp should consider incorporating black carbon in its final aviation endangerment finding. Also while we do not support integrating crude nox under the endangerment finding, epa should consider expanding its existing nox reporting requirement for aircraft, Engine Manufacturers, landing and takeoff emissions to includ
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